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Motion for reconsideration of order to strike the opposition to the MSJ

Posted on | July 21, 2011 | 5 Comments

Dr. Orly Taitz, ESQ

29839 Santa Margarita Parkway, STE 100

Rancho Santa Margarita CA 92688

Tel: (949) 683-5411; Fax (949) 766-7603 

E-Mail: dr_taitz@yahoo.com, orly.taitz@gmail.com

UNITED STATES DISTRICT COURT

FOR THE  DISTRICT OF COLUMBIA

Dr. ORLY TAITZ, ESQ, PRO SE                        §

                             Plaintiff,                         § Freedom of information violation

                                                                   §             5USC §552     

                   v.                                             §           

                                                                   §   Certified mail proof of service  

Michael Astrue, Commissioner of the            §    returned     

     Social Security Administration,             §     11-cv-00402

                                                                   §

                                                                     §  Honorable Royce Lamberth       

                             Respondent                    § Chief Justice presiding

Emergency motion for reconsideration of 07.21.2011 order striking the opposition to MSJ, due to the fact, that corrected redacted opposition was received by the court on 07.15.2011 by Federal Express and was not docketed by the clerk.

 

This motion is based on the memorandum of  points and authorities attached herein and oral argument, if the oral argument is granted.

Emergency motion requesting to grant all pending motions by the Plaintiff, as defendant did not oppose any of the motions.

 MEMORANDUM OF POINTS AND AUTHORITIES

On 07.13.2011 Plaintiff filed by Fed Ex opposition to motion for Summary Judgment filed by the defendant. After the opposition was shipped by Fed Ex Plaintiff realized that the social security number was not redacted. The next day she printed out the motion and all the exhibits, redacted them and shipped by Fed Ex redacted version with  a specific request for the clerk of the court to docket the second, redacted version. The second, redacted version, was received by the court timely on  July 15th .   (Fedex receipts are attached as an exhibit1 and 2).  
Even though the clerk of the court got a specific letter and a redacted version, the posted the first  unredacted  version.

On the evening of  07.2o.2011 Mr. Nemeroff, attorney for the defendant filed a motion to strike the opposition due to the fact that the social security number was not redacted.  Plaintiff called Mr. Nemeroff immediately and explained, that there was an error or sabotage by somebody in the clerk’s office, who intentionally did not post the letter from the Plaintiff and the redacted pleading. Today on July 21, 2011 Plaintiff called the court, left two messages for deputy Robert Elliott and talked to the clerks’ office employee, Mr. Johnson. Mr. Johnson stated, that somebody in the clerk’s office probably thought that the second opposition was the same, as the one sent before and threw it away. He did not have an explanation, why would they throw it away, when there was an attached letter, explaining, that the first version was unredacted in error and there was a request to post the second, redacted version. He stated to plaintiff that all she can do, is Fed Ex again the pleadings. After the Plaintiff got off the phone, she got an order striking the opposition.

Plaintiff is greatly concerned, that there is an employee in this court, who is intentionally sabotaging the Plaintiff in order to allow a person of interest in this case, an individual, occupying the position of the President and Commander in Chief  based on a forged long form birth certificate and a fraudulently obtained social security number to continue the usurpation of the U.S. Presidency  in violation of civil rights of the Plaintiff  and 311 million American citizens, who have a right to be governed by a legitimate president.

Additionally, in the period of  five months Plaintiff has filed numerous motions, including a motion for Vogn  index, motion for default judgment, filed due to the fact, that the answer was not filed timely and a number of other motions. Defendant did not oppose any of the motions. As such Plaintiff is requesting granting all of her pending motions.

Defendant is greatly concerned by the fact,  that  all of the Plaintiff’s motions were completely ignored for five months now while  Defendant’s  motions were granted immediately without giving the Plaintiff any opportunity to respond. Plaintiff is greatly concerned that there is more sabotage in this court and someone is intentionally not forwarding to your Honor any of the motions filed by the Plaintiff , while forwarding the motions by the Defendant.

SUMMARY

Plaintiff respectfully requests this court to reconsider its’ order to strike the opposition to the motion for summary judgment and order the clerk of the court to docket the second, redacted version of the motion, which was sent by Fedex on 07.14.2011and received by the court on 07.15.2011.

Plaintiff respectfully requests the court to grant all of her pending motions, as none of her motions were opposed by the defendant.

Sincerely

/s/ Dr. Orly Taitz, ESQ

 

Affidavit of Orly Taitz

I, Orly Taitz, am an attorney licensed by the Supreme Court of California and admitted to practice before the Supreme Court of the United States, 9th circuit court of Appeals and the Third Circuit court of Appeals.

I am over 18 years old, I do not suffer from any mental impairment and I have personal knowledge of the facts below:

  1. On 07.13.2011 I sent by Fedex an opposition for Summary Judgment Exhibit 1Receipt from Fedex
  2. On 07.14.2011 I noticed that the social security number was  not redacted and I sent by Fedex a second redacted version of the opposition to motion for summary judgment. Exhibit 2 Receipt from Fedex
  3. With my second redacted version I included a letter to the clerk of the court, asking her to docket the second redacted version.

I attest under penalty of perjury, that all of the above is true and correct.

/s/ Orly Taitz

07.21.2011

 

Certificate of service

I, Rita Momtazian, certify, that I served the defendant via his attorney Patrick Nemeroff, by fax with the above emergency motion

 

/s/ Rita Momtazian

 

Cc Congressman Darel Issa

Chairman of the House Oversight committee

2347 House Rayburn Building

Washington DC 20515

Congressman Lamar Smith

Chairman House Committee on the Judiciary

2409 Rayburn House office Building

Washington DC 20515

Ph 202-225 -4236

Fax 202-225-8628

Category: Uncategorized

Comments

5 Responses to “Motion for reconsideration of order to strike the opposition to the MSJ”

  1. Starla
    July 21st, 2011 @ 3:54 pm

    It is 100% ILLEGAL & 100% CORRUPT that this court is saying they think your motion was “thrown away” or they “can’t find it!!”

    Dr. Orly, this is simply unbelievable, & I do NOT believe it for one second that this happened: that they lost the motion or threw it away!! By the way, it is 100% malfeseance of duty & 100% illegal for them to do this, what they are claiming as the cause of what happened. Are they saying they are not in control of the court records and of their court actions?!! This is plain B.S. & insanity!!

    There will be open rebellion by We The People if this judge does not do his legal & proper job & rule to continue this case forward in the faavor of TRUTH & RIGHTEOUSNESS & JUSTICE & WISDOM & We The People!!

    ALL this particular judge has to do is to honestly take a look at the OBVIOUS EVIDENCE against the Daily Serial Career Criminal Obama that is OBVIOUSLY contained in your excellent pleadings and to justly rule that this case MUST GO FORWARD to protect We The American People from the 100% deranged, 100% psychopath & lawless daily lying sociopath, & the 100% Daily Serial Career Criminal Barack Obama that is sitting 100% illegally usurping the USA government!!

    I love this especially: “Plaintiff is greatly concerned, that there is an employee in this court, who is intentionally sabotaging the Plaintiff in order to allow a person of interest in this case, an individual, occupying the position of the President and Commander in Chief based on a forged long form birth certificate and a fraudulently obtained social security number to continue the usurpation of the U.S. Presidency in violation of civil rights of the Plaintiff and 311 million American citizens, who have a right to be governed by a legitimate president.” (snip).

    Sincerely

    /s/ Dr. Orly Taitz, ESQ”

    Dr. Orly, Thank you again for everything you are doing to try to save our Constitutional Republic from being overthrown & from collapse in this Coup D’Etat War that we are being attacked in by Obama, Holder, Soros, the Bilderberg’s, and by other foreign & domestic enemies of the United States of America, & the Rule Of Laws in the USA Constitution!!

  2. Hotlanta Mike
    July 21st, 2011 @ 5:50 pm

    It appears someone on the inside is tampering with the federal mail…isn’t that a felony?

    Perhaps Eric Holder or Robert Mueller can get right on it…

  3. jcm52
    July 22nd, 2011 @ 2:02 am

    “It appears someone on the inside is tampering with the federal mail”…

    Hee hee. FedEx ain’t federal mail.

  4. Hotlanta Mike
    July 23rd, 2011 @ 5:36 am

    jcm52
    July 22nd, 2011 @ 2:02 am

    Hee hee. FedEx ain’t federal mail.

    —————————————

    There was proof of delivery to the Courts by the delivery service…so someone within the government is tampering with the mail internally.

  5. Yephora
    July 23rd, 2011 @ 6:04 am

    It appears someone on the inside is tampering with the judicial process.

    Better?

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