Documentos de Académico
Documentos de Profesional
Documentos de Cultura
I
2 3
5 6
'1
I
9
US DISTRICT COURT
10
11
!2
13
al
)
)
15
Plaintiffs, vs.
Barack Obama, et
16
l1
18
) al
)
Rule 60 motion
t9
2A
Defendants
)
) )
2I
22 23
24
25 26 27
REPLY TO OPPOSITION Plaintiffs are replying to the opposition to the motion for reconsideration for
the Leave ofCourt to lile a Second Amended Complaint as follows:
Keyes
et al v
obana Reply
5 6
ll)
9
miliaLe, nadv.fr.nce, !urpris., or.r.usable n.9edi dilrqen..,.ould nor have b..n dis.overed in t
me ro mov ror a new
10
r9{!)
(3) fraud (wherher prevloudy ca d
t1
72
inftrnt. or.xtinsn),
(4) thejudsment
vo di
l3
14
:15
an
.adier
j u
rm6.d orvaGt.d;or
16
11
:18
(d T'Y'M arc
*to
Br r,iloro(
iime- rnd ror reasons (l), (2). and (3) no more rhan
a year
(l) I/,,r9.
rh..ntry
A motio. unner rule 60l!) mus be made a(hln a r.asonable ot rhejudqm.nt orod.r orthe d.te of th. pro.ed'ng.
arir
19
Plaintiffs specifically argued that Rule 60 motion should be granted under Rule 60
b(2) and (6)
20 21
22 23
24
Plaintiffs conveniently twisted the pleading and claimed that the motion is filed
under rule 60b(2) and therefore it is untimely. However time limitation is only
Motion clearly includes 60 b(6). "anv other reason thatjustifies relief'. There is no
time limitation on 60b(6). It can be hled 10 years afterjudgment and a 100 years afterjudgment.
21
2A
At
issue is the most serious crime ever to be committed against the United States o
et a] v
obafra Reply
citizen iflndonesia and possibly still a citizen ofKenya and Creat Britain, Barack
Hussein Obama, who was able to get into the position ofthe U.S. Senator from
a candidate
of
fraud, use of forged and fraudulently obtained lDs and a Racketeering scheme,
which involves corflrpt high ranking officials ofthe U.S. govemment and the
6
It serves iustice for the court to review the evidence provided and grant the leave o
court to file the Second Amended Complaint.
9
There is no other cause that would serve Justice more than ending the usurpation of the U.S. Presidencv and annexation and usurpation of the civil
10
1:l
rishts of everv American citizen due to the usurnation of the U.S. Presidencv.
Defendants attomeys, who are assistant aftomeys ofthe U.S. aftomeys'office
)2
13
clearly saw that Rule60b(6) was stated, they knew that under 60b(6) a Motion for
Reconsideration can be filed at any time, they simply provided a bogus argument
and defrauded the court by claiming that the moiion is not timely and they should
be sanctioned fbr it.
)4
l5 l6
I1
L8
II.
"Res Judicata" is applicable, when the case is heard on the merits and adjudicated 2t
22 23
24
ofa forged birth certificate, forged ofthc U.S. Presidency while being
Selective Service certificate, stolen Connecticut Social Security number xxx-xx4425, a name not legally his and the usurpation
a
of
25
several corrupt federal and state olficials who are criminally complicit and are
aiding and abetting Obama and committing treason against the United States of
2.1
Neither Judge Carter nor any other judge in this nation ever received any valid
identification papers from Obama, which would refute evidence showing him
using all forged IDs. Obama failed to respond to any subpoenas and failed to
appear in court and failed to present his identification papers, even after ajudge in
a
ruled in favor ofthe plaintiffs and denied Obama's motion to quash subpoenas
issued by attorney
mockery ofthe proceedings by the elections commissions and in one aforementioned case in GA, never responded to subpoenas, never provided any
valid identification papers; the plaintiffs and the nation as a whole are yet to see
one single judge hold Obama and his accomplices accountable. 31
I million
American citizens are denied Equal Protection and Equal Consideration, which is
gratuitously given to Obama.
technicality, on standing,
ruling that after the election the candidates do not have standing to bring a
challenge to legitimacy ofthe president. 9th Circuit court ruled on standing as well.
RtrFUSAL TO GRANT A LEAVE OF COURT TO FILE A SECOND AMENDED COMPLAINT WILL REPRESENT A VIOLATION OF
Under the 5th and 14th amendment citizens have to be given sufficient due
process,
Recently this court, Hon. Judge Carter granted Delegates to the Republican
l
2 :l
ofJustice and other govemmental agencies, as the case dealt with the forgery in
6
I
9
'nd
CERTAIN NON-PARTY
I4
15
\6
L1
Currently new cvidence became available which was submifted to this court with this motion.
Newly submitted evidence includes a sworn affidavit from SheriffJoseph Arpaio attcsting to
forgcry in Obama's Birth certificate, Selective SeNice Cenificate and Social Sccurity NumberThis court allowed to file a Second Amended Cornplaint to Plaintiffs -Delegates to the
r8
79 20
21 22 23
'L4
Republican Convention, whose complaint. if granted, would have benefited Barack Obama,
as
as
ofyet.
Republicans were deried equal protection. Plaintiffs in this case yqg j9a!9t144$!q99y9qy whatsoever, the case was dismissed on standing, and now the del'endants are seeking l{es Judicata in order to use this court as a tool, in order to bury forever the nost serious
25 26
21
2A
Racketeering act and the most scrious crime. ever to be conrmitted against the tjnited States America.
Keyes
of
et al v
Obasa Reply
As Your Honor is an appointee oflhe Democmt President Clinton, the public and the plaintiffs
are deeply concemed that the due process and equal protection rights
2 3
4
ofthe Plaintiffs
are
egrcgiously violated under the color ofauthority in order to promote narrow Democratic Party
interests.
This is parricularly important in light ofthe fact that the threejudge panel olthe 9th Circuit
Court ofAppeals by some lype ofa coiDcidence corrsisted ofall three appointees ofthe same
8
9
This coult did not give the samc consideration. did not grant the same due process and equal
protection to Plaintiffs who challenged Obama, as it gave to the plaintiffs. whose action would
10
1:i
t.l
14
Plaintifls argue that this is a malter of National Security and outmost National importarce.
Plaintill!
attach
herein
r5
16
Scott J. Tepper, who sought ajudicial notice ofa copy ofallegcd birth certificate ofObama,
l-1
t8
19
2A
posted by Obama on WhiteHouse.go\,. Tailz argued that lepper had evidence Obama's birth certiticate and sought iudicial notice. trying to use the
offorgery of
court
its a tool to
legitimize and sanitize forgery. Cust like defendants are trying to use this court to claim that
2I
22
23
24
apply). California Bar responded thal this (referring to Obama's lbrged birth certificate) is a
matter of National Security and needs to be heard by the court. Exhibit I .
2'
26 21
2F
plaintiff, who mistakenly skipped the lower court and wenr straight to
2
a higher
court to appeal the decision by the Secretary ofState of Alabama Beth Chapman to allow Obama on the ballot in light of his forged identification papers. While
ofAL
ofjurisdiction,
I
9
10
11
t2
13
14
:15
Alabama Supreme court. This confirms the assertion by the plaintiffs in the case
at hand that this is a case ofgreat importance to National security, as it shows
16
I1
18 19
Chief
of
2o
2t
22 23
24
authenticity..."
As such granting a leave ofcourt to file a Second Amended complaint in one
case and deny
Keyes
1 2
3
When the first amended complaint was dismissed, it was dismissed based on the standing ofplaintil'fs challenging the sitting President after the election. 9 th
5
6
However, the court never reviewed the standing ofone ofthe Plaintiffs, Alan Keyes, who was the runner up in the senatorial election. Justice was never
served on the issue ofObama stealing that election and getting in the position
I
9
of
the U.S. Senator from Illinois based on fraud and use of forged IDs and while
10
l1 I2
13
being a foreign national. The interest ofJustice demands this court to grant the
leave ofcourt to file a Second Amended Complaint on RICO, a Racketeering
scheme that allowed this fraud to take place. Additionally the court never
14
I5
16
considered the issue of Obama's possible run for the reelection. Currently Obama is running for the reelection. Even ifone considers that no citizen can
I7
18
19
20
2!
22
presidential run.
Additionally the court can raise Rule 60 b motion at any time sua sponte.
purport of each rule will expose whether the aule touches on issues of power orwaiver. Rule 60(b) concerns the maintenance and integrity ofthe couds and the efllcient disposition ofcases.il2 It codifies a court's equitablE authority to give relief to judgments when appropriate and reinfcrces the proscription of faaudulent behavior.n3Judges must be equipped with the tools to maintain the integriry of the courts, and Rule 60(b) is such a iHenry tool. Therefore, judges should be able to raise Rule 6O{b) motions qla sporte.
"The
21
24
25
Brounstein
21
2A
f,om
Cv. P.60(b):This mle does not limit lhe powd ofa courtlo entertain an independent aclion to relieve a party judgmenl order, or proceeding, or to qranl relief to a defendanl
not actually personally nolilied as provicled in Title 28 U.S.C., S 1655, or to set aside a judgment forfraud upon the court. Ltnk,370 u.5. at632.
MOTION SHOULD BE RDVIEWED IN FAVOR OF RESOLVING THE MATTER ON TTIE MERITS AIID FAILIJRE TO GRANT A 60(B) MOTION MAY BE VIEWED AS AN ABUSE OF .II'DICIAL DISCRETION.
III RULE
60 (B)
It is ironic that while originally Obama did not respond to the complaint, this coud pressured the Plaintiffs attorrrey to serwe the U.S. attomeys' office with the complaint, so it will be heard on the merits. The merits ofthe case and particularly RICO wefe nevef heard. In sar,azea !. aHAvEz 2a200122 cA in lhe court or Appeals or
UT 81,1154. 150 P.3d 480 {cirations oDrifted). Additionally. because rule 60(b) is e.quitable in natu.e, "a dislricl court should
Utah, the court slated: Because "tal disllict court has bload discrerion lo rule on a norion !o set aside a default judgnent under lule 60(b) of the Utah Rules of Civil ProcedDie L l . we reliew a district coudb denialofa60(b) motion tforld abuse ofdiscrelion 'Menzies v Galetkn 2006
11
!2
13
ils discrelion in favor of q.anting relief so lhat controversies can be decided on the nerits." Id, !ast. "a district court's ruling on a notion to set aside a default judqnent nust be based on adequate findings of fact and oo the lat." Id. ll 55 (intelnal quotailon narks onitted) . FactDal findings are reviewed for clear error and ..n.lirsi.ns of law are reviewed for colrectness. See id.
exercise
There is no nore imporlant considetation of the interesl of justice, rhan for lhis court to alLo the second anended conplaint to be filed so the issue ol the RIco schene leadinq to lhe usurpation of the U.S. Presidency As this courl noted pleviously: "the nalion needs to know. lhe niliiary needs to know".
15
CONCLUSION
7l
Under Rule 60 (b) 6 "in the interest ofJustice" and due to evidence showing Racketeering conspiracy perpetrated with the goal ofthe usurpation ofthe U.S.
Presidency and massive elections fraud ofthe U.S. citizens during 2004 Senatorial contest ln Illinois between plaintiff Keyes and Defendant Obama and
due to evidence ofelections fraud committed by candidate Obama during
19
2O
21 22 23
24
25 26
21
Keyes
et al v
Obana Reply
Respectfully submitted,
/s/ Dr. Orly Taitz, ESq counsel for Plaintiffs
2 3
4
08.27 .2012
6
'1
I
9
Chairman
House oversight committee
10
Lt
t2
13 14 15 16
17
18
19 20
21
22
23 24
25
21
2A
Inspector General U.S. Department of Justice Investigations Division 950 Pennsylvania Avenue, N.W. Room 4706 Washington, DC 20530
Keyes
5 6
I
9
Signed
10 11
\2
13
14
15
16
1? 18 19 20
2I
22
23 24 25
26
21 28