Draft of GA renewed complaint

Dr. Orly Taitz ESQ

29839 Santa Margarita ste 100

Rancho Santa Margarita, Ca 92688

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

[email protected]

David Farrar                                            )  Appeal of decision by Secretary of State of GA

V                                                               )  Declaratory Relief

Barack Obama,                                      )

Brian Kemp, secretary of State          )  Injunctive Relief

JURISDICTION AND VENUE

Jurisdiction is proper as Administrative court of Georgia is the first level of appeal court in a challenge of actions by an agency, such as Secretary of State.

Attorney Taitz was previously granted by this court a Pro Hac Vice to represent  registered voter David Farrar, challenging  candidate Obama

PARTIES

David Farrar -Registered voter in the state of Georgia

Brian Kemp -Secretary of State of Georgia

Barack Obama-candidate for the U.S. President in the General election

ALLEGATIONS

1. Plaintiff David Farrar filed a challenge to Candidate Obama in primary election under O.C.G.A. § 21-2-5

2. In his challenge Farrar brought forward an overwhelming amount of prima facie evidence showing that candidate for the U.S. President in the Primary election Citizen of Indonesia Barack Hussein Obama is not eligible for the U.S. Presidency due to his foreign citizenship and his use of forged identification papers and a stolen Connecticut Social Security number 042-68-4425 as a basis for his identity.

3. Obama and his attorney Michael Jablonski boycotted the trial, did not show up any evidence in rebuttal.

4. Inexplicably this court found that the evidence brought forward by 7 experts and competent witnesses at trial was “not convincing enough” and allowed Obama to stay on the ballot.

5. Plaintiff appealed, however the Superior court of Georgia ruled, that since this is only a primary election and Obama has not been nominated by his party yet, superior Court does not have jurisdiction yet to hear the appeal.

6. Plaintiff Farrar   brought a challenge against Candidate Obama in the General election. Exhibit 1

7. Farrar received an e-mail from Vincent Russo, legal counsel for Secretary of State Kemp, stating that since a challenge was heard in the primary election, it will not be heard in the general election.

8. Farrar is challenging this decision by  Secretary of State Kemp due to the fact that Kemp flagrantly violated  Georgia statute O.C.G.A. § 21-2-5(b) and denied Farrar his right to challenge a candidate in General election and due to the fact that his challenge was wrongly denied in this court, as defense presented no rebuttal to prima facie evidence of forgery and fraud in Obama ‘s IDs and Superior court refused to hear the case stating that it did not have jurisdiction prior to the nomination preceding general election. Additionally Plaintiff is bringing forward new evidence, which reinforces his case.

9. Plaintiff brings forward  a sworn affidavit and videotaped press conference from Sheriff Joseph Arpaio of Maricopa County Arizona, attesting to forgery in Obama’s birth Certificate, selective service certificate and Social Security number. Exhibit 2

10. Plaintiff brings forward transcript of March 25 hearing of Assembly of Kenya, where Minister of Lands, James Orengo states that Obama was born in Kenya Exhibit 3

11. Obama’s biography submitted by Obama to his literary agent Acton-Dystel publishing in 1991 and kept on the web site of Acton Dystel until 2007, which stated that Obama was born in Kenya.  In 2007, when Obama decided to falsify his records, biography was removed from the web site, but was uncovered using “wayback machine” software. Exhibit 4

12. Sworn affidavit by an assistant registrar-clerk in Hawaii, stating that there is no record of Obama’s birth in any hospital in Hawaii. Exhibit 5

additionally, Plaintiff incorporates by reference all of the affidavits and sworn witness testimony provided by him at trial in Farrar v Obama OSAH -SECSTATE-CE-1215136-60-MALIHI

13. Plaintiff is seeking Declaratory relief and Injunctive relief

Stay/injuction

O.C.G.A. §21-2-5(e)states in relevant part “(T)he reviewing court may order a stay upon appropriate terms for good cause shown” Georgia  Courts   have  broad  discretion   under  OCGA   §  9-5-8   m  deciding whether  to grant a request  for an interlocutory  injunction.  Kinard  v.  Ryman  Farm Homeowners’  Ass’n, Inc., 278 Ga. 149,  149 (2004);  citing West v. Kaufman, 259 Ga.  505  (1989).  To  obtain  a  preliminary   injunction,  a  movant  must  show:  ( 1) likelihood  of success  on the merits; (2) the preliminary  injunction  is necessary  to prevent   irreparable   injury;  (3)  the  threatened    injury  outweighs   the  harm  the preliminary  injunction  would  inflict on the non-movant;  and (4) the preliminary injunction  would serve the public interest.  A1cDonald’s Corp.  v. Robertson,  147 F.3d 1301, 1306 (I lth Cir.l998).

Plaintiff is likely to succeed on the merits, as Plaintiff provided this court with undeniable evidence of forgery in Candidate Obama’s IDs thathe is using as proof of his identity assumed as a candidate on the ballot.

14. Due to the fact that violation of constitutional rights for fair and lawful elections,  Equal Protection, Free Political speech are involved, monetary damages will not suffice and equitable remedy is required.

15. Plaintiff will suffer a irreparable harm in losing his right to participate in lawful elections

16.  In comparing harm to the Plaintiff and harm to defendants, there is no harm to defendants at all, as if Obama was were never entitled to    be on the ballot, he cannot be harmed by being removed from the ballot. If Obama is not eligible to be on the ballot, secretary of state could never lawfully place his name on the ballot and cannot be harmed by a STAY or INJUNCTION preventing certification of Obama’s votes.

17. STAY of INJUNCTION is in public interest and in furtherance of public policy of crime prevention, as there is no more egregious crime than treason in aiding and abetting usurpation of the U.S. Presidency by a foreign national with forged IDs.

13. Plaintiff is seeking a stay of certification in line with Stay of certification of election results granted in a precedent of Miller v Campbell 1-cv-0242 U.S. District Court District of Alaska, Hon. Ralph Beitlin.

13. If this court does not issue an immediate STAY of certification of votes for Obama in general election, this court will become complicit in treason against the United states of America, in misprision of felonies and aiding and abetting forgery, elections fraud, Social Security fraud, identity fraud/identity theft, wire fraud, mail fraud and use of forged identification papers in election, which were committed by Obama and his accomplices.

PRAYER FOR RELIEF

Plaintiff is seeking:

.1Declaratory relief, stating that Secretary of State wrongfully denied a right of a registered voter from challenging a candidate in General election.

2. Declaratory relief stating that votes for Candidate for the U.S. President Barack Obama cannot be certified due to fraud and Obama’s use of forged IDs and a stolen Connecticut Social Security number as a basis for his U.S. identification

3. Emergency stay of certification of any votes for candidate Obama due to fraud and Obama’s use of forged IDs and a stolen Connecticut Social Security number as a basis for his U.S. identification

4. Permanent injunction  of certification of any votes for candidate Obama due to fraud and Obama’s use of forged IDs and a stolen Connecticut Social Security number as a basis for his U.S. identification

Respectfully submitted

Dr. Orly Taitz ESq

/s/ Counsel for Plaintiff

Pro Hac Vice counsel for Plaintiff David Farrar

Exhibit 1

A complaint against Candidate Barack H. Obama

Honorable Brian Kemp

Secretary of State of Georgia

214 State Capitol

Atlanta, GA 30334

CC: via e-mail to Vincent R. Russo Jr. ESQ

Dear Sir,

I am filing this complaint in the abundance of caution since neither I, nor my attorney: Dr. Taitz, have been able to learn precisely when the two- week time period for filing such a complaint officially begins or ends.

This is to serve notice upon you, sir; that I, being an elector of the state of Georgia, do challenge Candidate Barack H. Obama’s name being placed on Georgia’ general election ballot of November 6, 2012, as being unqualified for the public office sought, and to request an immediate hearing to present my supporting prima facie evidence.

It is my understanding that Dr. Orly Taitz was granted Pro hac vice to represent me in this complaint by Judge Michael Malihi. I am requesting that you reconsider my earlier challenge against Candidate Barack H. Obama, as I will be including by reference all of the evidence against Candidate Barack H. Obama that Dr. Taitz listed in her Judd v. Obama complaint.

ex animo
davidfarrar

* Independent of Hawaiina Health Department records
cc: Vincent R. Russo

General Counsel

Office of Secretary of State Brian P. Kemp

3 attachments — Download all attachments

Response to September 13, 2012 Letter

Dear Ms. Taitz,

I am in receipt of your letter dated September 13, 2012, entitled “Renewed Legal Challenge To Candidacy For The U.S. President In 2012 Election Barack Hussein Obama.”

Please be advised that pursuant to O.C.G.A. § 21-2-5(b), a challenge must be filed within two weeks from the deadline for qualifying by an elector who is eligible to vote for the candidate being challenged. Since you are not a registered voter in Georgia, you are unable to file a challenge to a candidate’s qualifications in Georgia. Furthermore, despite the procedural irregularities of your attempted filing, Mr. Farrar’s challenge was previously considered and a final decision was entered. As such, we are unable to reconsider your request at this time.

Thank you for your attention to this matter.

Sincerely,

Vincent R. Russo

General Counsel

Office of Secretary of State Brian P. Kemp