I am working on this motion draft in Obama SSN case. I am asking researchers, who are doing research on the matter to look at it and let me know if I missed any issues. i would like to consider comments before I complete this motion and submit to Judge Hollander. I am asking O-bots not to waste my time with their nonsense.

Posted on | May 29, 2014 | 14 Comments

Dr. Orly Taitz, ESQ

29839 Santa Margarita, ste 100

Rancho Santa Margarita, CA 92688

ph. 949 -683-5411 fax 949-766-7603

orly.taitz@hushmail.com

IN THE US DISTRICT COURT

FOR THE DISTRICT OF MARYLAND

Dr. Orly Taitz, ESQ                                                  ) Civil Action 13-cv-1878

Plaintiff                                                                    )Hon. Ellen Lipton Hollander

v                                                                                ) Presiding

Carolyn Colvin,                                                        )

in her official capacity as Acting Director               )

of Social Security Administration                            )

Motion for reconsideration under Rule 60 b(1), 60 b(5) and 59 (a-e)  

RULE 60. RELIEF FROM A JUDGMENT OR ORDER

(a) Corrections Based on Clerical Mistakes; Oversights and Omissions. The court may correct a clerical mistake or a mistake arising from oversight or omission whenever one is found in a judgment, order, or other part of the record. The court may do so on motion or on its own, with or without notice. But after an appeal has been docketed in the appellate court and while it is pending, such a mistake may be corrected only with the appellate court’s leave.

(b) Grounds for Relief from a Final Judgment, Order, or Proceeding. On motion and just terms, the court may relieve a party or its legal representative from a final judgment, order, or proceeding for the following reasons:

(1) mistake, inadvertence, surprise, or excusable neglect;

(2) newly discovered evidence that, with reasonable diligence, could not have been discovered in time to move for a new trial under Rule 59(b);

(3) fraud (whether previously called intrinsic or extrinsic), misrepresentation, or misconduct by an opposing party;

(4) the judgment is void;

(5) the judgment has been satisfied, released, or discharged; it is based on an earlier judgment that has been reversed or vacated; or applying it prospectively is no longer equitable; or

(6) any other reason that justifies relief.

Rule 59. New Trial; Altering or Amending a Judgment

(a) In General.

(1) Grounds for New Trial. The court may, on motion, grant a new trial on all or some of the issues—and to any party—as follows:

(A) after a jury trial, for any reason for which a new trial has heretofore been granted in an action at law in federal court; or

(B) after a nonjury trial, for any reason for which a rehearing has heretofore been granted in a suit in equity in federal court.

(2) Further Action After a Nonjury Trial. After a nonjury trial, the court may, on motion for a new trial, open the judgment if one has been entered, take additional testimony, amend findings of fact and conclusions of law or make new ones, and direct the entry of a new judgment.

(b) Time to File a Motion for a New Trial. A motion for a new trial must be filed no later than 28 days after the entry of judgment.

(c) Time to Serve Affidavits. When a motion for a new trial is based on affidavits, they must be filed with the motion. The opposing party has 14 days after being served to file opposing affidavits. The court may permit reply affidavits.

(d) New Trial on the Court’s Initiative or for Reasons Not in the Motion. No later than 28 days after the entry of judgment, the court, on its own, may order a new trial for any reason that would justify granting one on a party’s motion. After giving the parties notice and an opportunity to be heard, the court may grant a timely motion for a new trial for a reason not stated in the motion. In either event, the court must specify the reasons in its order.

(e) Motion to Alter or Amend a Judgment. A motion to alter or amend a judgment must be filed no later than 28 days after the entry of the judgment.

STATEMENT OF FACTS

On 05.13.2014 this court denied the Defendant’s Motion to Dismiss, but granted Plaintiff’s Motion for Summary Judgment. This court denied plaintiff’s motion for Summary Judgment, plaintiff’s request for Vaughn index and Plaintiff’s motion requesting this court under 18 USC §3332 to forward to the Federal Grand Jury for the District of Maryland evidence of offenses against the criminal laws of the US, which was submitted to this court, namely offenses that were committed by Senior FOIA Officer Dawn Wiggins, Defendant, acting SSA Commissioner Carolyn Colvin and citizen of Indonesia Barry Soetoro, aka Barry Soebarkah, aka Barack Hussein Obama, currently occupying the position of the President of the United States. the gist of the case revolves around the refusal by the Social Security administration to produce the SS-5 for SSN xxx-xx-4425, Social Security application, for Harrison (Harry ) Bounel, which the SSA found on November 16, 2012. Importance of this case is in the fact that the Social security number of this individual born in 1890 and presumed to be dismissed , was fraudulently assumed in 1980s by the citizen of Indonesia Barry Soetoro, aka Barry Soebarkah, aka Barack Hussein Obama, who also used multiple other bogus IDs.

The Motion for Summary Judgment was granted to the defendant, acting commissioner of the Social security Carolyn Colvin after conflicting responses were provided by the same FOIA office r Dawn Wiggins. On November 16, 2012 Wiggins refused to  release the SS-5, Social Security application of Harry (Harrison) Bounel, claiming consideration of privacy. In 2013 Plaintiff, Dr. Orly Taitz, submitted a FOIA request seeking SS-5 for the same Harry (Harrison) Bounel, advising the SSA that Bounel was born in 1890 and according to 120 year rule, his SS-5 is considered a record of an extremely aged individual and as such SSA is obligated to release the record and cannot claim an excuse of privacy.  SSA did not respond and Taitz filed a legal action with this court. After the law suit was filed SSA responded by claiming that they do not have records for Harry Bounel and sought a Summary Judgment in their favor due to alleged lack of records. Plaintiff Taitz responded by submitting this court a copy of the letter from the same FOIA officer Wiggins, where she previously refused to grant records due to privacy concerns. Taitz argued that if SSA did not have any records, they would have responded that there are no records at all to begin with, they would not have claimed privacy as an excuse in November 16, 2012 response. The court granted this motion.     

ARGUMENT

This court made an error of fact and law and the decision needs to be overturned for the following reasons:

1.THERE IS NO EVIDENCE THAT POLICIES, SSA COMMISSIONER CLAIMES TO EXIST , ACTUALLY EXIST. NO REFERENCE TO A SPECIFIC POLICY WAS PROVIDED.

At issue is the fact that Barack Obama has fraudulently used the Social Security number of Harry Bounel and failed E-verify and SSNVS.

SSA originally refused to provide the SS-5, application to the SSN of Harry Bounel, claiming privacy. When Taitz filed a law suit, stating that SSA cannot use privacy as an excuse, as according to its’ own guidelines, it has to release records of individuals born 120 years ago or earlier, SSA provided another answer claiming that the records cannot be found at all.

Taitz provided the court with a written, published policy guidelines of SSA which state that the SS-5 of individuals born 120 years ago or earlier have to be released, as these are considered extremely aged individuals.

THE RESPONSE FROM THE SSA DID NOT PROVIDE ANY REFERENCE TO ANY POLICY, ANY RULE OR EXECUTIVE ORDER.

In response to the motion for Summary Judgment for the Plaintiff on the first amended complaint, defense claimed that there is a policy, where the SSA only checks the SSN, but does not even look at the name of the subject and does not check by the name. No reference was provided to any specific rule or policy.

Taitz responded that this makes no sense and does not mash with the facts of the case, as if the SSA indeed were to check by the number, they would have responded that they cannot release records on this particular number xxx-xx-4425. However that was not what they claimed, they claimed that they cannot release records of Harry Bounel due to considerations of privacy, as such their subsequent letter that the records of Harry Bounel do not exist, constitutes fraudulent statement.

In the motion for Summary Judgment in response to  the Second Amended Complaint (Hereinafter, “SAC”), defendants decided to make up a new policy, claiming that they originally claimed that they cannot release the records due to privacy, since their policy is such that they do not release records if the number does not match the name, even if the records do not exist at all.

Yet again, SSA did not provide the court with any reference to any statute or known policy which would substantiate their second story, their second excuse.

As no reference was provided by the defense to either the first of the second conflicting stories (excuses) the court cannot base its opinion on these made up excuses and cannot give them the presumption of truth.

This court made an error in assuming that there is a law stating that the SSA should respond  by claiming privacy when the records do not exist at all, as SSA never provided any reference to any such specific law. The court cannot consider fiction as law: it is an error of both fact and law. No such law exists, no such law was made available to the public, as such the first letter of November 16, 2012 stating that the records of Harry Bounel cannot be released due to the consideration of privacy, means that the records exist, and as such the SS-5 has to be released under the 120 year rule.

2. RESPONSE BY THE SSA PROVES THAT SS-5 FOR HARRY BOUNEL WITH SSA  XXX-XX-4425  EXISTS, BUT ONLY MINOR DISCREANCY IN THE SECONDARY DATA CAUSED SSA TO CLAIM THAT THE DOCUMENTS DO NOT EXIST.

As stated previously in order to cover up fraudulent use of xxx-xx-4425, SSA made up an excuse, which does not exist in any known rules and regulations,  claiming that  when the documents do not exist or when the name of the subject does not match the Social Security number provided, they give the same response – claiming that the SS-5 cannot be provided due to privacy in order not to reveal private information of someone else. However this response does not make any sense.

Social Security numbers contain 9 digits, meaning that there are nearly a billion numbers, actually one number short of a billion to be exact.  For Social Security to claim that responding that there are no records for Harry Bounel with SSN xxx-xx-4425, would somehow reveal someone else’s  number is an insult to intelligence of every American. This court claimed that this alleged (but not authenticated policy) exists in order for criminals not to guess someone’s Social Security number by submitting multiple requests. Considering that there are nearly a billion numbers, a person would have to submit a billion requests in order to guess someone’s number by simple elimination. This makes absolutely no sense and no proof of such policy was ever provided.
Even if one were to believe this, still conflicting responses by the SSA would lead to a logical conclusion that there are records for Harry Bounel, but some discrepancy in secondary information led SSA to claim in the second response that documents do not exist.

Supplemental Declaration of Dawn Wiggins ECF 12-2 filled 09/16/ 13 states

“3. On or about October 15, 2012, SSA received an internet FOIA request for the Social Security number (SSN) records of Harry Bounel, also known as, Harrison Bounel. Outside of name and gender, the only identifiable information provided to SSA with the October 15, 2012 FOIA request was an SSN. Plaintiff was not the requester in the October 15, 2012 FOIA request

4. SSA conducted  a search of its Privacy Act system of records entitled the Master Files of Social Security  Number Holders and SSN Applications (also known as the “Numident”), system No 60-0058 (published at 75F.R. 82121 (Dec, 2010) for the SSN records requested in the October 15, 2012 FIA request. However, because the October 15, 2012 FOIA request only provided Mr. Bounel’s name and an SSN, any information provided to the requester about SSA’s search would result in validation of the SSN. Consequently, on November16 2012, when SSA responded to the October 15, 2012 FOIA request, SSA advised the requester that the Privacy Act of 1974 and FOIA  exemption 6 restricts  disclosure of the requested information. .

5. Plaintiff’s April 26, 2013 FOIA request provided several pieces of information that Plaintiff asserts are true about Mr. Bounel, including: (1) his name, (2) where he immigrated from (3) his year of birth, (4) when he arrived in the united states, (5) where and when he received a SSN, and (6) his SSN. SSA conducted a search of the Numident for a record that matched the information provided but could not locate a record for Mr. Bounel. Because Plaintiff provided multiple pieces of identifying information with her FOIA request, SSA determined it could disclose to Plaintiff that no records were located because such disclosure would result not result  in validation of the SSN provided by Plaintiff for Mr. Bounel.”

So, let’s imagine that the defense is telling the truth and aforementioned policy exists, in this case we have two options:

a. SSN xxx-xx-4425 was not assigned to Bounel,

b.  SSN xxx-xx-4425 was assigned to Bounel, but SSA is acting with malice and using a minor discrepancy  in secondary data provided in the second request in order to justify refusal to provide the SS-5 of Bounel in order to aid and abet Barack Obama in committing Social Security fraud, identity theft and  usurpation of the US presidency

So, let us examine option A. According to Merlyn Information Systems 2 individuals used SSN xxx-xx-4425: Harry Bounel and Barack Obama. So let’s assume that even though E- Verify and SSNVS state that the number was never assigned to Barack Obama, let’s assume it belonged to Obama.

October 15, 2012 request sought SS-5, Social Security application for Harry Bounel  with SSN xxx-xx-4425. Second, April 26, 2013 request sought Social Security application for Harry Bounel with SSN  xxx-xx-4425, but provided 4 additional pieces of secondary information : (1) that Harry immigrated from Russia, (2) that he arrived in the U.S. in 1912, (3) that he was born in 1890 and (4) that the SSN was issued in Connecticut in and around March 28, 1977. SSA stated that the first request would result in validation of the SSN   and for that reason they stated that they cannot provide it due to privacy and the second request will no longer validate SSN, meaning it will no longer reveal the identity of the SSN holder and for that reason the second time around they stated that the records do not exist. So, let’s take the first piece of additional information, the fact that Harry came from Russia. How does the fact that Harry arrived from Russia would change anything in validation of another individual? If the SSN was issued to Obama or anyone else for that matter, to John Doe or Joe Shmo,  the fact that Harry Bounel arrived from somewhere in Russia and not Timbuktu or Katmandu or anywhere else on the face of this planet would not change a thing and should trigger the same response from the Senior  FOIA officer Dawn Wiggins. Based on the policy SSA claims to have the response from Wiggins from  November 16, 2012 and her response from  July 29, 2013 would be identical, and they were not.

Next, let’s take the second secondary piece of information, the fact that Harry Bounel immigrated to the US in 1912.  How does the fact that Harry arrived from Russia in 1912 change anything in  identification of Obama and validation of the SSN, if indeed it was assigned to Obama?  If indeed, SSN xxx-xx-4425  was  issued to Obama and not Bounel, then the fact that Harry Bounel immigrated in 1912 and not 1913 or any other time would not make any difference in the response from the SSA from November 16, 2013 and July 29, 2013.

Same goes for the other pieces of information, such as date of birth and the date and place where the SSN was issued.

b. Now, let’s examine option B, namely that SSN xxx-xx-4425 was indeed issued to Harry Bounel. Now, in the second scenario, the difference  between the two responses makes sense in that  a minor discrepancy between the records would lead the SSA claim that the record does not exist. For example, the date of immigration of 1912. If SSA has a different date of immigration, then they can respond that  they have no record and it would explain the difference between the  November 16, 2012 letter and July 29, 2013 letter from Wiggins. Similarly, in the FOIA request Taitz wrote that the SSN was issued in and around March 28, 1977.  If the date of issuance of the SSN was different, then SSA will provide a different response. So, even if one were to believe the reasoning by the SSA, the difference between November 16, 2012 and July, 28, 2013 (ECF 7-2 filed by defense ex parte 08/14/13) leads to only one logical conclusion, namely that the SSN xxx-xx-4425 was indeed issued to Harry Bounel but minor discrepancy in one or more of the four additional pieces of secondary information  caused SSN to provide different responses on November 16, 2012 and August 28, 2013.

So, not only the court needs to reconsider it’s decision and order release of the SS- for SSN xxx-xx-4425,  the court has to demand from the SSA a specific  explanation, what secondary information caused SSA to change its response from  documents cannot be provided due to privacy and the second response that the documents do not exist.

3. SSA’S  OWN REPLY FROM 03.02. 14 SHOWS THAT THERE IS A GENUINE UNRESOLVED QUESTION OF FACT, WHICH CALLS FOR A DISCOVERY AND THE CASE CANNOT BE DISMISSED WITH A MOTION FOR SUMMARY JUDGMENT

In 03.02.14 reply SSA states: “…the declaration further explains that the Numident is a numerically ordered electronic database containing records of each person who has applied for the SSN, there is one Numident record for each SSN ever issued” ECF 32 p9. However the complaint provides competent evidence showing that there are two individuals using the same SSN xxx-xx-4425. Affidavit of Susan Daniels and affidavit of Albert Hendershot provide authenticated excerpts from the national databases, which show that there are two individuals using the same SSN xxx-xx-4425. It is important that Daniels and Hendershot used different databases, which provided the same results. Daniels used “”SSN Verifier Plus”, which showed that SSN xxx-xx-4425 was used by an individual born in 1890 and an individual born in 1961.    Hendershot used Merlyn Information Systems, which showed that  SSN xxx-xx-4425  was used by Harry Bounel and by Barack Obama. This situation can happen when there is Social Security fraud and identity theft and when the numident, Social Security electronic record was changed.  In this case databases would show  two individuals using the same number.

Further defense stated: ” The FOIA requires agencies to conduct a search that is reasonably calculated to uncover all relevant documents” Weisberg v United Dep’t of justice, 705 F 2d 1344,1351 (DCCir 1983).   ECF 32 p8.

So when the SSA and the Department of Justice, representing them, saw that there is evidence of a change in the Numident, electronic record, which allowed Obama to use the SSN of Bounel,  SSA had a duty, based on their own admission, to examine the original paper record to establish, who was the original rightful owner of the SSN xxx-xx-4425. They never did that. So, by her own admission defendant did not fulfill FOIA requirement to conduct a search that is reasonably calculated to uncover all relevant documents. SSA did not even search for the original paper record.

SSA does not state that they did not find the original application of Bounel, they are admitting that they never even looked, even though obligated to do so and even though they had ample evidence of identity theft and falsification of the electronic record.

Further, SSA admitted in their own reply that SSA requires them to search paper records. “the FOIA defines
search” as “to review manually or by automatic means, agency records for the purpose  of locating  those records which are responsive to the request” 5 U.S.C. §552(a)(3)(D). The FOIA does require an agency to search paper records. Id”  The defense states that “FOIA does not require agencies to conduct unreasonably burdensome searches of records” ECF 32, p8. So, was this  request  “unreasonably burdensome?”. Some FOIA requests seek thousands of records, some seek hundreds of records, but Taitz did not seek thousands or hundreds or even dozens of records: she sought only one and only single record: original paper application for SSN xxx-xx-4425, which was filed with the records for the state of Connecticut right after the application xxx-xx-4424 for Thomas Woods. It would have taken Commissioner Colvin  only 5 minutes to pull this record. How could Commissioner of Social Security Carolyn Colvin claim that it would be “unreasonably burdensome” for her to pull one single record, when she has in front of her  evidence that this particular number for Harry Bounel was later fraudulently used by Barack Obama and is used to commit the most serious fraud in the US history and the usurpation of the U.S. Presidency? Not only this was not “unreasonably burdensome” for her to pull this one and only original paper application, this is criminal and treasonous for her not to do so. This court flagrantly erred and misinterpreted the facts. Clear evidence showed that there was falsification of the computer records and the paper records were never even searched. As such, this court should order the SSA to pull the paper record for xxx-xx-4425.

4. THE COURT ERRED IN GIVING THE COMMISSIONER OF SSA COLVIN PRESUMPTION OF TRUTHFULNESS, WHILE COMPLETELY IGNORING ALL THE EVIDENCE OF FRAUD PRESENTED IN THIS CASE, WHICH PROVIDED A REBUTTAL TO THE PRESUMTION

Presumption of truth given to the defendant, Commissioner Carolyn Colvin,  was rebutted  by the evidence provided by the plaintiff and as such Motion for Summary Judgment was granted in error and has to be reversed:

1. The court erred in ignoring sworn affidavit from Investigator Albert Hendershot showing that according to Merlins Informations systems database only two individuals in the nation used the same Connecticut Social Security number: Harry Bounel and  Barack Obama
2. Dead people, who were born over 120 years ago do not steal Social Security numbers of young individuals. Young individuals, who are in this country illegally or ones who are running various schemes and Social Security fraud, are using Social Security numbers of individuals who  were born years ago and who are presumed to be dead. For this reason it is likely that the Social Security of Bounel was illegally adopted by Obama and a criminally complicit  employee  of the Social security administration made the change in the computer database. For that reason the computer database cannot be used and there is a need to proceed to discovery and examine the original application to the Connecticut Social security number xxx-xx-4425, which was filed out by Bounel.
3. It is likely that Bounel who lived in New York 1935-1940 according to census, moved to the nearby  Connecticut. There is no evidence of Obama ever residing in Connecticut. As a matter of fact, Obama biography shows that he never resided in Connecticut and in 1977, when the application for the SSN xxx-xx-4425 was submitted and the number was issued, Obama resided in Hawaii, was a 16 year old high school student in   Honolulu, Hawaii, nowhere near Connecticut. This is yet another piece of information pointing to the fact that Obama illegally assumed Bounel’s Social Security number and the court erred in not taking this into consideration and granting a motion for Summary Judgment .
4. The court erred in not taking into consideration the fact that Obama posted his tax returns and failed SSNVS, Second amended Complaint (SAC ECF 20-5) .  SSNVS is an official agency of the US government verifying Social Security fraud, which identifies illegal aliens and others using stolen Social Security numbers. Obama himself posted the  Social Security number he is using on WhiteHouse.gov. Even though subsequently he realized the mistake and redacted the number, it became common knowledge. The fact that SSNVS showed that the number in question was never assigned to Obama, shows that indeed among two individuals, who used the SSN xxx-xx-4425, Bounel was the rightful owner and Obama fraudulently assumed his number and the computer record, Numident cannot be used, the original SS-5, SSN application card  has to be  retrieved from the vault and examined, as all the evidence shows that the card was filled up for  Harry Bounel, born in 1890 and the computer record, Numident was subsequently changed. It shows that the court erred in issuing a summary judgment and discovery has to proceed. If Honorable Ellen Hollander does not reverse her order, she will become complicit to the cover up of the Social security fraud, identity theft and treason due to the usurpation of the US Presidency by a foreign national, citizen of Indonesia using a stolen Connecticut Social Security number of harry Bounel and fabricated IDs.
5.       The court erred in not taking into consideration the fact that Obama posted his tax returns and failed E-Verify.  Plaintiff submitted Exhibit 2, Second amended Complaint (ECF 20-4), sworn affidavit of researcher Linda Jordan, showing that Barack Obama failed E-Verify and is using a Social Security number not assigned to him.  E-Verify is an official agency of the US government verifying Social Security fraud, which identifies illegal aliens and others using stolen Social Security numbers. Obama himself posted the  Social Security number he is using on WhiteHouse.gov. Even though subsequently he realized the mistake and redacted the number, it became common knowledge. The fact that SSNVS showed that the number in question was never assigned to Obama, shows that indeed among two individuals, who used the SSN xxx-xx-4425, Bounel was the rightful owner and Obama fraudulently assumed his number and the computer record, Numident cannot be used, the original SS-5, SSN application card  has to be  retrieved from the vault and examined, as all the evidence shows that the card was filled up for  Harry Bounel, born in 1890 and the computer record, Numident was subsequently changed. It shows that the court erred in issuing a summary judgment and discovery has to proceed. If Honorable Ellen Hollander does not reverse her order, she will become complicit in the cover up of the Social Security fraud, identity theft and treason due to the usurpation of the US Presidency by a foreign national, citizen of Indonesia using a stolen Connecticut Social Security number of Harry Bounel and fabricated IDs.
6.  The Court erred in not considering a sworn affidavit of investigator Albert Hendershot, ECF 20-6, who attested to the fact that in Merlin information system both Harry Bounel an Barack Obama are listed as using the same SSN xxx-xx-4425.  He testified that the latest change in the database of Harry Bounel was by Michelle Obama in and around November 2009 and she is listed as a relative of Harry Bounel, which suggests an effort of cover up which took place in 2009, when it became known from the investigation by Neil Sankey and Susan Daniels that Obama used a SSN xxx-xx-4425, which according to a number of databases was issued to an individual born in 1890. Harry Bounel was this individual.
7. The court erred in refusing  to consider the sworn affidavit of former intelligence officer  Captain  Pamela Barnett, who authenticated a FOIA response received by her from the state department, which stated that Barack Obama’s legal last name  in his mother’s passport records was “Soebarkah”, (ECF 20-8), which shows a pattern of fraud in multiple IDs for Obama and shows that indeed it is more likely that SSN xxx0-xx-4425 was issued to Harry Bounel and later was illegally used by Obama.
8.  The court erred in not considering a sworn affidavit of a licensed investigator Susan Daniels, who attested that  in national databases Obama’s name is linked to a number of Social Security numbers, among them the Social Security number of a deceased Lucille Ballantyne. (Ballantyne’s son, Harry C. Ballantyne worked as a chief SSA actuary, had access to records and is suspected of being an individual who was involved in the falsification of records). Additionally Investigator Daniels provided a page from “SSN Verifier Plus” official database, which shows that xxx-xx-4425 was issued in Connecticut and is associated in this national database with the date of birth 1890 and 1961. Clearly someone born in 1890 did not steal the Social Security number of someone born in 1961 (ECF 20-7).
9. Hon Judge Hollander erred in ignoring the sworn affidavit of John Sampson, Senior Deportation officer, who attested that there is no legitimate reason for Obama to have a Connecticut Social Security number, as Obama was never a resident of Connecticut and never had any connection to Connecticut. Taking into consideration that in multiple national databases it shows that two people used SSN xxx-xx-4425: Harry Bounel and Barack Obama, this is a an additional piece of evidence that shows that Judge Hollander was wrong is assuming that the government is telling the truth in the second letter, claiming that they can no longer find records of Harry Bounel, all of the above evidence is a rebuttal to this presumption and shows that the case should go to trial, to be heard on the merits and this court should order release of the SS-5, application t the SSN xxx-xx-4425.  SAC ECF 20-8
10.  This court erred in completely ignoring a sworn affidavit of Stephen Jeffrey Coffman, high ranking government official, former chief investigator of the Special Investigations unit of the U.S. Coast Guard, who attested under the penalty of perjury that Barack Obama’s Selective Service Certificate is a forgery and it contains a fabricated USPS cancellation 1980 stamp SAC ECF 20-9. This evidence shows a pattern of use of fabricated IDs by Barack Obama and the court had to consider this as a rebuttal in the case at hand, as there is a high likelihood or actually certainty that Barack Obama is using a fabricated Social Security card, which was originally issued to Harry Bounel and high ranking SSA officials and US Attorney representing them are committing treason and are complicit in the Social Security fraud and identity theft.  Refusal to reconsider the decision at hand will make Hon Ellen Hollander complicit.
11.   The court erred in not considering the affidavit of Timothy Adams, assistant clerk for the City and County of Honolulu attesting o the fact that there is no birth certificate for Obama in any hospital in Honolulu, which is yet additional piece of  evidence of massive fraud of IDs for Obama which adds to the likelihood that indeed Obama is using the SSN of Bounel. ECF 20-11
12. The court erred in not considering transcript from the session of the Republic of Kenya, where minister of Health James Orenga stated  that Obama was born in Kenya, which is yet another piece of evidence showing fraud in Obama’s IDs, which ads strength to the rebuttal of the statement by the defense.  ECF 20-12
13.  The court erred in not considering exhibit 20-13 to SAC, autobiography, which Obama submitted to his publisher Acton & Dystal, where  he stated that he was “born in Kenya and raised in Indonesia”. This   biography was posted on the official website of the publisher for 16 years, from 1991 till 2007, when Obama decided to run for the U.S. President and suddenly needed to become “natural born citizen”. This is yet another piece of evidence, showing massive fraud in IDs, which points to the fact that Barack Obama indeed fraudulently issued SSN of Harry Bounel and the court should order the release of  the SS-5 for xxx-xx-4425 and examination of this SS-5 by experts.
14. The court erred in not considering the sworn affidavits of Felichito Papa and Douglas Vogt, who attested to multiple signs of forgery in the alleged copy of the alleged  birth certificate of  Barack Obama, which show the pattern of fraud and forgery in multiple IDs of Obama. (ECF 20-14, 20-15)
15. This court erred in not considering an article and affidavit by typewriting and typesetting expert with 50 years of experience, Paul Irey, where he vividly showed that Barack Obama’s alleged copy of the alleged birth certificate is a laughable forgery with letters and numbers of multiple different fonts. This evidence   related to fraud in multiple fraudulent IDs for Obama and high likelihood of Obama indeed using the  stolen SSN of Harry Bounel and the need for this court to reconsider its decision on Summary Judgment and order discovery. ECF 20-16.
16.  The court erred in not considering the sworn declaration  of Charles Combs, typesetting expert with 34 years of experience, who attested to the fact that alleged copy of the alleged birth certificate for Obama is a forgery and it shows a pattern of fraud and forgery in Obama’s IDs and a need to go to discovery and examine the original SS-5 for SSN xxx-xx-4425. ECF 20-17.
17. The court erred in not considering a sworn affidavit of Sheriff Joe Arpaio of Maricopa county Arizona stating

“Uponcloseexaminationoftheevidence,itismybeliefthatforgeryandfraudwas

likelycommittedinkeyidentitydocumentsincludingPresidentObama’s  long­ form  birth  certificate,  his  Selective  Service  Registration  card,  and  his  SocialSecuritynumber.” ECF 20-18

8. This court erred in not taking into consideration Barack Obama’s school registration from Jakarta, Indonesia, which showed that his legal last name is Barry Soetoro and his citizenship is Indonesian, which showed the motif doe him to use stolen SSN of Harry Bounel, which means that discovery is necessary to ascertain whether the SS-5 for SSN xxx-xx-4425 was indeed assigned to harry Bounel and the defendant is committing fraud and treason by claiming that the document cannot be found. ECF 20-19
9.  This court erred in not taking into consideration exhibit ECF 20-20, which shows forgery and falsification of the NARA immigration records for August 1961, when Obama and his mother Stanley Ann Dunham allegedly arrived in the US, which shows a high likelihood of a similar falsification of the Social Security records.
10. This court erred in not taking into consideration Exhibit ECF 20-21, which shows that the Chairman of the Democratic Party of Hawaii Brian Schatz and secretary Lynn Matusow falsified the Official Certification of Nomination and removed the wording “ Legally qualified to serve under the provisions of the U.S. constitution” in order to “qualify” unqualified Obama. Similarly there is a high likelihood of egregious falsification of the Social Security records and fraud by the defendant and FOIA officer Dawn Wiggins, in order to cover up falsification of the SS-5 of Harry Bounel in order to provide aid and comfort to Obama.
11.  This court erred in not taking into consideration fraud committed by Obama in his registration as an attorney in Illinois and hiding two of his prior identities under the last names of Soetoro and Soebarkah. This is an additional evidence of a motif and a need to commit Social Security fraud and identity theft and use a stolen Social Security of Bounel. ECF 20-23
12.  This court erred in not considering fraud committed by Obama in his account of his college records in his claims that he studied for two years in Columbia University while ECF 20-24 showed that he attended Columbia just for nine months. This is yet another piece of evidence showing massive fraud.
13.  This court erred in ignoring exhibit ECF-25, which shows more fraud in Obama’s official biography, where he states that he moved to Indonesia in 1967, while his school pictures show that Barack Obama resided in Hawaii until 1969 and a completely different young man, Barry Soetoro, resided in Indonesia from between 1967 and 1969. there is a high likelihood that Barry Soetoro returned to the US in 1971.
14. This court erred in ignoring glaring inconsistencies in a report of death of Loretta Fuddy, director of Health of Hawaii, the only person in the nation, who allegedly saw and verified Obama’s long form birth certificate and a high likelihood of murder of Loretta Fuddy in order to tie loose ends. Refusal to reconsider
15. The court erred in failing to consider the motif for either destroying evidence or falsifying evidence.

Based on all of the above this court erred in giving a presumption of truthfulness to the third sworn affidavit proffered  by the agency, where the agency stated that it could not locate records for Bounel and refusing to give the same presumption of truthfulness to all the other government records and sworn affidavits of government officials listed above and submitted with the Second Amended Complaint and other documents. Even if this court were to believe that the mountain of evidence provided by the plaintiff was not sufficient in order to grant a Motion for summary Judgment in favor of the plaintiff, it was clearly sufficient  for a rebuttal and showing that there is a genuine question of triable fact whether the SS-5 for xxx-xx-4425 was issued to Barack Obama or was issued to Harry Bounel and the number later was fraudulently assumed by Obama and the claim of lack of record is a flagrantly fraudulent statement made to the court by the defendant and her representative Dawn Wiggins, who is criminally complicit in the cover up of fraud, forgery, Social Security fraud, identity theft and treason.

5. THIS COURT ERRED IN RULING THAT THERE IS NO TRIABLE QUESTION OF FACT OR LAW BASED ON ONE UNSUPPORTED STATEMENT OF AN OFFICIAL, WHICH REPRESENTS A DOUBLE LAYER OF HEARSAY, PRESENTED AFTER THREE CHANGES OF THE STATEMENT, WHILE DISREGARDING OTHER CONFLICTING STATEMENTS  BY THIS OFFICIAL AND ALL THE CONFLICTING RECORDS PROVIDED BY THE PLAINTIFF.

Plaintiff provided  this court with ample evidence, including November 2012 letter from SSA, showing that SSA has SS-5, original application for SSN for Harry Bounel, which is xxx-xx-4425, as reflected in the Merlin  Information Systems database ECF 20-6.

Against evidence provided by the plaintiff, defense provided only two conflicted statements by one employee of the SSA, Dawn Wiggins, who based her statement on the Numident, which is not even a document, but a list of Social Security numbers and corresponding information, which were manually entered into the computer database. Computer entry is notorious for errors at the very least, could have been changed, as multiple high ranking employees were appointed by Barack Obama and had a motif to either change or destroy records to aid and abet Obama. As a matter of fact in this very court, in this very case, the clerk of the US District Court for the state of Maryland deleted pleadings and documents from the record and the plaintiff had to lodge a complaint and demand the records to be re-enetered and this court had to order the documents posted back on the record. Additionally the clerk of the court wrongfully refused to docket reply to the opposition.  ( ECF 34.)  Though Hon Judge Hollander tried to be diplomatic towards her own employees in stating that Plaintiff could not see documents in docket entry ECF 7 and the court contacted the clerk’s office and the problem was resolved, in reality not just the plaintiff could not see the records, the whole nation could not see the records in this very case, in this very court, because the records ECF 7 were simply deleted by someone in the clerk’s office and later reposted after the complaint by the plaintiff. This has been a common occurrence in multiple courts in cases dealing with Obama and the plaintiff had to go through a total nightmare for five years now in trying to preserve the records, particularly for historic posterity as sooner or later this fraud will be prosecuted, just as the Watergate was. There had to be an administrative hearing by this court and investigation to ascertain the name of the employee who deleted the records in this very case and the name of the government official who told the clerk to do so. So far the matter of falsification of records in this very court has not been investigated and has not been resolved, identity of individuals involved has not been provided.     So, Hon Judge Hollander knows first hand that the clerks and other government employees at times either make errors in entering records in computer database of falsifying records. If the records of this case could disappear in this very court, how can Honorable Judge Hollander even suggest that this cannot happen at SSA, when all the voluminous evidence in the case shows fraud and falsification of the original SSA records of Harry Bounel in order to create a bogus record for the citizen of Indonesia Barry Soetoro, aka Barry Soebarkah, aka Barack Hussein Obama.  At the very minimum the third modified declaration by SSA FOIA officer Dawn Wiggins represents a double layer hearsay and the plaintiff provided a valid rebuttal, which shows that this statement is either flagrantly fraudulent or Wiggins is relying on falsified records or some type of minor discrepancy. This warrants reconsideration and denial of the Summary Judgment in favor of the defendant and discovery and the order by this court to produce SS-5 for xxx-xx-4425 to ascertain if indeed it was assigned to Harry Bounel and the SSA is covering up this fact.

By refusing to reconsider and produce SS- for xxx-xx-4425 which, according to Merlin information systems, was assigned to Harry (Harrison) Bounel, this court will under the color of authority under 18US §242 deprive the whole nation, all 320 million of U.S.  citizens of their civil rights to live in a nation governed by law and Constitution with Constitutionally eligible president, as evidence provided in this case shows that Barack Obama has fraudulently assumed Social Security number xxx-xx-4425 of Harry Bounel.   Due to the refusal of this court to order the defense production of the original application, in spite of evidence of falsification of  records, the court is depriving US Citizens of their right to a constitutional government and they are under the usurpation.

6. THE COURT ERRED IN GRANTING THE SUMMARY JUDGMENT AND MAKING A PRESUMPTION THAT THE DEFENDANTS, EMPLOYEES OF THE FEDERAL GOVERNMENT ARE TELLING THE TRUTH, WHILE REFUSING TO TAKE INTO CONSIDERATION MOUNTING EVIDENCE OF MASSIVE CORRUPTION, FALSIFICATION OF RECORDS AND FRAUD IN MULTIPLE  AGENCIES OF THE FEDERAL GOVERNMENT, PARTICULARLY NOW, DURING OBAMA ADMINISTRATION.

Fast and Furious investigation has found that Department of Justice engaged in gun trafficking to drug cartels in Mexico, while knowing that the cartels are linked to dangerous terrorist organizations. Attorney General Eric Holder was found to be in contempt of the US Congress and currently the US Congress is suing Attorney General Holder and seeking a court order from Federal Judge Amy Berman to order Holder to release “Fast and Furious” documents.

Recent VA scandal revealed that  employees of the Veteran’s Affairs and VA hospitals routinely falsified records of requests for treatment and as a result as many as 40 veterans died due to lack of treatment.

IRS scandal revealed that high ranking IRS officials engaged in persecution of Tea Party members  and refused to grant legitimate non profit status for years. At the same time the manager of the non-profit organizations department Lois Lerner, who led this effort to delay the non profit status to conservatives, granted a non-profit status to a questionable charity , which was headed by Obama’s Kenyan half -brother Malik Obama, she provided a non-profit status for him within three weeks and authorized his application reportedly by  going in on Sunday and back dating the application from this “charity”, which was operated from a POBox.

One will be hard pressed to find a single agency in Obama administration, which was not engulfed in scandals involving fraud and falsification of records.  So, not only the evidence in this case, but the surrounding scandals show mounting evidence of fraud and falsification of official government records by different officials of Obama administration. This is yet another consideration in that the court erred in giving the presumption of truth to the double hearsay proffered by FOIA officer Wiggins, who changed her declaration three times. this presumption was erroneously given without considering the evidence in rebuttal.

7. THE COURT ERRED IN REFUSING TO FORWARD THE EVIDENCE OF SOCIAL SECURITY FRAUD AND IDENTITY THEFT AND USE OF SSN OF BOUNEL BY OBAMA TO THE FEDERAL GRAND JURY under 18 USC §3332

So, we are seeing a pattern of fraud and falsification  of records by high ranking officials in multiple agencies of the US government. We have seen in this case ample evidence of the cover up by the SSA officials of the fact that Barack Obama is fraudulently using a Social Security number which according to SSNVS and E-Verify was never assigned to him and which according to Merlin Information systems and http.www.axciom.com/ identity solutions database was assigned to Harry (Harrison Bounel),  as well as his use of other fabricated IDs, such as Selective Service certificate and birth certificate (Exhibits 1-23 Second Amended Complaint ECF 1-23) . Plaintiff requested this court to forward this evidence to the Federal Grand jury under USC 18§332, which states:  (a) It shall be the duty of each such grand jury impaneled within any judicial district to inquire into offenses against the criminal laws of the United States alleged to have been committed within that district. Such alleged offenses may be brought to the attention of the grand jury BY THE COURT “emphasis added.

Hon Ellen Hollander stated in her order that she will not forward this evidence to the grand jury, even she has the power and jurisdiction to do so under 18 USC 3332, because we have able prosecutors and they can do it. Hon Judge Hollander missed the most important point: our prosecutors, from US Attorney to Attorney General might be able, but they are not willing to uphold their oath of office to protect and defend the US Constitution, they are criminally complicit in the cover up. Plaintiff Taitz provided all the information to the Attorney General Eric Holder, as well as  the U.S. Attorneys’ office. Attorney General and US attorneys are all Obama’s appointees and are refusing to take action and are de facto committing treason against the United States of America and are covering up the usurpation of the US Presidency by a citizen of Indonesia, who is using a stolen Social Security number, which was traced to Harry Bounel and using all fabricated IDs.   In this situation the right of Hon Ellen Hollander to forward this information to the grand Jury rises to the level of duty, as not doing so, will make her complicit in the cover up of all the ample evidence of Obama’s use of fabricated IDs, invalid Social Security number and usurpation of the US Presidency by a citizen of Indonesia  using fabricated IDs.  In this situation, not proceeding to discovery and not ordering the SS-5, original application to the Social Security and not allowing expert investigation of the matter would be tantamount to treason and complicity to the most egregious identity theft and Social Security fraud in the US history.

We know that during Watergate  over thirty officials of Nixon administration including Attorney General John Mitchell went to prison for crimes which included fraud and obstruction of justice. So, what is the difference between Watergate and Obamagate? The main difference that during Watergate and ObamaForgeryGate or ObamaIDgate, or ObamaSSNgate  is the fact that top echelons in the US Department of Justice and Judiciary followed their oath of office to protect and defend the US Constitution and were not complicit in the cover up. Attorney General Elliott Richardson appointed a special prosecutor Archibold Cox and later Leon Jaworski . Judge Joseph Sirica ordered release of the White House tapes. Today, Attorney General Eric Holder refused to take any actions on the matter and has been complicit in the cover up. US attorneys under Eric Holder refused to address the issue. Three White House counsel resigned. As stated, due to complicity of the Department of Justice under Eric Holder, federal prosecutors will not forward the evidence to the Federal Grand Jury, as such it becomes a duty of this court to follow the footsteps of Judge Joseph Sirica, who presided over Watergate and reconsider the decision on the Motion for Summary Judgment and order the SSA release of the SS-5 for SSN xxx-xx-4425, which according to Merlin information systems and all of the evidence provided in the case was assigned to Harry (Harison) Bounel in and around 1977 and were  illegally appropriated by Obama   from around 1986 and forward to the Federal Grand Jury per 18USC §2333 for criminal investigation all the evidence provided to this court by the plaintiff.

8. THE COURT ERRED IN ITS ASSERTION THAT THE REQUEST FOR VAUGN INDEX IS MOOT, IT SHOULD BE RECONSIDERED AND THE COURT SHOULD ORDER RELEASE OF THE SS-5 FOR SSN XXX-XX-4425, WHICH ACCORDING TO MERLIN WAS ISSUED TO HARRY BOUNEL AND LATER FRAUDULENTLY ASSUMED BY BARACK OBAMA.

The court erred in denying the motion seeking a release of the Vaughn index as moot. The court erroneously concluded that there are no records pertaining to this case, however by defense own admission November 16, 2012 letter by FOIA officer Wiggins refers to SS-5 to SSN xxx-xx-4425 of Harry Bounel and refuses to release the records due to privacy. All the evidence, provided by the plaintiff and discussed previously, is consistent with this letter and shows that SS-5 for xxx-xx-4425 exists and is being withheld due to the fact that it was later fraudulently assumed by Barack Obama and a number of employees of the SSA are criminally complicit in this fraud, forgery and identity theft. The only inconsistent evidence in this case is a July 28, 2013 letter, where the same FOIA officer Wiggins suddenly could no longer find the records for Bounel and claimed that the SSN xxx-xx-4425 belonged to another individual, ostensibly Barack Obama. At the very minimum we have here a triable issue of fact, as to whom the SS-5 to SSN xxx-xx-4425 belongs to and it was and still is a duty of this court to order the SSA to preserve the original SS-5 to SSN xxx-xx-4425 for this case from destruction/spoliation  and for all future criminal investigations and prosecution and subsequently order expert examination of this original   SS-5 application to establish with the 100 percent certainty who was the original owner of this Social Security number. Refusal to order preservation of records by this court might ultimately make this court complicit in destruction/spoliation of the records, which are of paramount importance for the US National Security and legitimacy of the US Presidency.

RELIEF REQUESTED

Based on all of the above,

1.The court should reconsider the order to grant Motion for Summary judgment and deny aforementioned order for summary judgment.

2. The court should order discovery and order production by the defendant of the SS-5, original Social Security application to the number xxx-xx-4425, which  according to Merlin Information systems and all the evidence in the case was assigned  Harry (Harrison) Bounel and later fraudulently assumed by Barack Obama,

3. This court should demand from the Social Security administration an explanation, which specific additional data provided in the second request for SS-5 for Harry Bounel xxx-xx-4425  caused SSA to change its response from claiming that the records cannot be provided due to privacy to records do not exist at all.

4. This court should order SSA to prepare Vaugh index of all the records n the case, specifically the SS-5 for xxx-xx-4425

5. This court should under 18USC §3332 forward to the Federal  Grand Jury all the evidence of offenses against the criminal laws of the United States which were provided by the Plaintiff to Honorable Judge Hollander  and which were committed by the defendant Acting Commissioner of Social Security Carolyn Colvin, FOIA officer Dawn Wiggins and citizen of Indonesia Barry Soetoro, aka Barry Soebarkah, aka Barack Hussein Obama currently occupying the position of the President of the United States.

Respectfully submitted

Dr. Orly Taitz, ESQ

Cc Congressman Goodlatte- Chair of the House committee on the Judiciary

Cc Congressman Issa-Chair of the oversight committee

cc Congressman Gowdy –Chair of the Select Committee on Benghazi

Inspector General of the SSA

Inspector General Department of Justice

Federal Bureau of Investigations, US Department of Justice

Inter American Commission for Human Rights

International Criminal Court

_________________________________

Taitz v Colvin docket 04.11.2014 Taitz v Colvin Order by Judge Hollander 03.13.2014 Taitz v Colvin filed Reply to opposition to MSJ Taitz v Colvin reply in support of MSJ for plaintiff Taitz v Colvin reply in support of MSJ for plaintiff Taitz v Colvin MSJ 02.19.2014 Taitz v Colvin Motion for Summary Judgment by defense Taitz v Colvin letter from Taitz Taitz v Colvin Letter from US Attorney re extension of time Taitz v Colvin Motion for additional time Taitz v Colvin Motion for extension by the defense Taitz v Colvin replacement of US Attorney Taitz v Colvin filed second amended complaint Taitz v Colvin order to file an amended complaint Taitz v Colvin memorandum with order to file an amended complaint

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