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Important Grinols Ex Parte application to strike motion to dismiss and exhibits

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Proposed order to the ex-Parte Application to Strike Motion to Dismiss

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Orly Taitz
11:20 PM (0 minutes ago)

to mceorders, George, Edward
Dear Judge England,
Please find attached a required proposed order for the Ex-Parte Application to Strike the Motion to Dismiss.
respectfully,
/s/ Orly Taitz, counsel for Plaintiffs
cc Edward Olsen
cc George Waters

IN THE US DISTRICT COURT OF THE EASTERN DISTRICT OF CALIFORNIA

GRINOLS ET AL                               ) Case 12-cv-02997

PLAINTIFFS                                     )

V                                                      )

ELECTORAL COLLEGE ET AL        )

DEFENDANTS                                )

Order

Plaintiffs filed an ex-parte application to strike Defendants Motion to Dismiss.

Plaintiffs argued that this court does not have jurisdiction to hear the Motion to Dismiss by the Department of Justice/ U.S. Attorneys’ Office due to the fact that the U.S. Attorney’ office does not represent any parties in this case. Plaintiffs state that in the motion to dismiss the Department of Justice already admitted that it does not represent the electoral College, as the Electoral College is not a Federal agency. It does not represent Vice President Biden, as Vice President is not a defendant in the Amended Complaint. They do not represent Barack Obama as Barack Obama was NOT sued as a Federal Employee and finally they do not represent the U.S. Congress, as members of the U.S. Congress sought representation by a different attorney, General Counsel of the U.S. House of Representatives. Additionally according to the sworn declaration of Plaintiffs’ Attorney Taitz multiple members of the U.S. Congress advised her that the Department of Justice did not notify them of the representation and intended Motion to dismiss and did not obtain their consent prior to filing a motion to dismiss this case on their behalf.

Plaintiffs also argued that current representation constitute an impermissible conflict of interest between the attorney, here the Department of Justice, and the alleged client. As the premise of the law suit is use by Barack Obama of forged IDs in order to get into the position of the U.S. President by fraud, the interests of the alleged Client, U.S.Congress and the Department of Justice/U.S. Attorneys working for Barack Obama are diametrically opposite, which created an impermissible conflict of interest under the Rules of Ethics by the California Bar association Rule 3-300 and 3-310. Moreover, Plaintiffs argue that though the Department of Justice never placed the U.S. Congress on notice and did not seek the consent of the U.S. Congress in filing this motion to dismiss on behalf of the U.S. . Congress, in case this motion is granted and later the U.S. Congress seeks to impeach and remove from office Barack Obama for his use of forged and stolen IDs, Obama might use this motion as a basis for evading  impeachment on Res Judicata or Collateral Estoppel.

Further Plaintiffs argue that the State Defendants are represented by the Attorney General of California Kamala Harris, who is a major fundraiser for Barack Obama. Additionally Barack Obama is a fundraiser for Kamala Harris. Moreover, close relative of Harris, her brother in law Tony West, is a major bundler for Obama, who bundled reported 65 million  dollars for Obama’s campaign and was rewarded by Obama with the #2 position in the U.S. Department of Justice. As such Plaintiffs argue that Harris had an ethical obligation to report to this court a conflict of interests. Harris did not do so.

The court agrees that indeed there is a conflict of interest. The court grants a Motion to Strike.  U.S. Congress will be given 60 days to advise the court of the counsel of their choice and file a response to the First Amended Complaint by their counsel of choice. State Defendants will be given 21 days to do the same.

So ordered.

___________________________________________________________________

U.S. District Judge Morrison C. England

Date_______________________________________________________________

Grinols Proposed order to the Ex Parte Application to strike.docx
13K   View   Download

2013-04-15 23:33:36

Source: http://www.orlytaitzesq.com/?p=414401


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