PHILIP J. BERG v. BARACK HUSSEIN OBAMA - Complaint

U.S.D.C. - E.D. PA ^ | 08/22/2008 | Philip J. Berg

[Diamond]

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UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

PHILIP J. BERG, ESQUIRE

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VS. CIVIL ACTION NO.

BARACK HUSSEIN OBAMA, a1k/a

BARRY SOETORO, a1k/a

BARRY OBAMA, a1k/a JURY TRIAL DEMANDED

BARACK DUNHAM, a/k/a

BARRY DUNHAM, THE

DEMOCRATIC NATIONAL

COMMITTEE, THE FEDERAL

ELECTION COMMISSION AND

DOES 1-50 INCLUSIVE

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Defendants

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COMPLAINT FOR DECLARTORY AND INJUNCTIVE RELIEF PRELIMINARY STATEMENT

1. Article II, Section I of the United States Constitution, states in particular part, "No Person except a natural born Citizen, or a Citizen of the United States at the time of the Adoption of this Constitution, shall be eligible to the Office of President; neither shall any Person be eligible to that Office who shall not have attained to the Age of thirty five Years, and been Fourteen Years a Resident within the United States." Furthermore, all Presidents since and including Martin Van Buren were born in the United States subsequent to the Declaration of Independence.
2. "The general doctrine of our Constitution is, that the executive power of the nation is vested in the President; subject only to the exceptions and qualifications, which are expressed in the instrument." 7 Works of Alexander Hamilton, J. C. Hamilton ed. (New

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York: 1851), 76, 80-81 (emphasis in original), U.S. Constitution, Article II (Hamilton

and Madison.)

1. Obama is a representative of the Democratic People. However, the Obama must meet the Qualifications specified for the United States Office of the President, which is he must be a "natural born" citizen. Unfortunately, Obama is not a "natural born" citizen. Just to name one of the problems, Obama lost his U.S. citizenship when his mother married an Indonesian citizen and relocated herself and Obama to Indonesia wherein Obama's mother naturalized in Indonesia and Obama followed her naturalization, as he was a minor and in the custody of his mother. Obama failed to take the oath of allegiance when he turned eighteen (18) years to regain his United States Citizenship status.
2. The Democratic National Committee is for Plaintiff and "We the People" who believe in the Democratic Vision. The Democratic National Party is supposed to represent the Democratic Americans in seeking honest leadership, Open Government, Real Security, Energy Independence, Economic Prosperity, Educational Excellence, a Healthcare System that works for Everyone and Retirement Security. The Democratic Party is supposed to represent and protect the interests of working Americans and guaranteeing personal liberties for all. Of which includes securing a Democratic Nominee on the Presidential Election ballot who represents the Democratic vision and who is qualified and eligible to run for Office of the President under the qualifications of the United States Constitution.
3. The actions of Obama, a U.S. Senator, in running for President of the United States, knowing he is not eligible, have been taken entirely without authorization under the

United States Constitution, completely ignoring the qualification and procedures created

>by the United States Constitution he is purporting to enforce.

>6. Should Obama become the Nominee of the Democratic Party and then be discovered by virtue of malfeasance, or negligence, on his part not to have revealed material evidence showing him to be Ineligible for the Office of President of the United States of America and thereby his Nomination be declared void by the appropriate Authorities Acting under the Law, Plaintiff as well as other Democratic Americans will suffer Irreparable Harm including but not limited to:

>A) Functional, or Actual, Disenfranchisement of large numbers of Citizens, being members of the Democratic Party, who would have been deprived of the ability to choose a Nominee of their liking;

>B) Irreparable Harm to the structure and integrity of the Democratic Party and the Democratic National Committee. In tum, this too would lead to Disenfranchisement; and

>C) A severe and genuine likelihood of Civil Disturbance by virtue of reaction to said Disenfranchisement.

JURISDICTION AND VENUE

1. This case arises under the Constitution and laws of the United States and presents a federal question within this Court's jurisdiction under Article III of the Constitution and 28 U.S.C. § 1331.
2. This Court has authority to grant declaratory relief pursuant to the Declaratory Judgment Act, 28 U.S. C. § 2201.
3. Venue is proper in this Court under 28 U.S.c. § 1391(b).

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PARTIES

1. Plaintiff, Plaintiff, Philip J. Berg, Esquire [hereinafter "Plaintiff'], is an adult individual with a businessaddress of 555 Andorra Glen Court, Suite 12, Lafayette Hill, PA 19444-2531.
2. Defendant, Barack Hussein Obama, alk/a Barry Soetoro, alkla Barry Obama, alk/a Barack Dunham, a/kla Barry Dunham [hereinafter "Obama" is an adult individual with an office address of713 Hatch, Senate Office Building, Washington D.C.
3. Obama, The Democratic National Committee (hereinafter referred to as "DNC") is a Corporation with a principal address of 430 S. Capitol Street SE, Washington, DC 20003.
4. Defendant, The Federal Election Commission (FEC) was created in 1975 by Congress to administer and enforce the Federal Election Campaign Act (FECA). The FEC is a Governmental Agency with a principal address of 999 E Street, NW, Washington, DC 20463.

FACTUAL ALLEGATIONS

1. Since the beginning of the U.S. Constitution, in order to run for Office of the President, you must be a "natural born citizen" and you may not hold dual citizenship or multiple citizenships with foreign Countries. U.S. Constitution, Article II, Section 1.
2. There are questions as to where Obama was actually born, in the United States or abroad and then registered his birth. There are further questions regarding Obama's United States Citizenship, ifhe ever held such, being expatriated and his failure to regain his citizenship by taking the oath of allegiance once he turned eighteen (18) years of age. There are additional questions regarding Obama's multi citizenships with foreign countries, which he still maintains. To date, Obama has refused to prove he is qualified under the U.S. Constitution and his eligibility to run as President ofthe United States.
3. The facts are undisputed by Obama that his mother, Stanley Ann Dunham, was a U.S. Citizen however, his father, Barack Obama, Sr., was a Citizen of Kenya. Obama's parents, according to divorce records, were married on or about February 2, 1961.
4. Obama claims he was born in Honolulu, Hawaii on August 4, 1961; however, has never given the name of the hospital he was born in; whereas Obama's grandmother on his father's side, half brother and half sister claim Obama was born in Kenya. Reports reflect Obama's mother went to Kenya during her pregnancy; however, she was prevented from boarding a flight from Kenya to Hawaii at her late stage of pregnancy, which apparently was a normal restriction to avoid births during a flight. Stanley Ann Dunham (Obama) gave birth to Obama in Kenya, after which she flew to Hawaii and registered Obama's birth. There are records of a "registry of birth" for Obama, on or about August 8, 1961 in the public records office in Hawaii.
5. Upon investigation into the birth of Barack Hussein Obama in Honolulu, Hawaii, Obama's birth is reported as occurring at two (2) separate hospitals, Kapiolani Hospital and Queens Hospital. Wikipedia English Version under the subject "Barack Obama"

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states Obama was born at Kapiolani Hospital. Wikipedia Italian Version under the subject "Queens Hospital" states Barack Obama was born in Queens Hospital.

1. There are further references circulating on the internet claiming examination of the hospital's records in Hawaii show no birthing records for Stanley Ann Dunham (Obama), Obama's mother. However, there are records of a "registry of birth" for Obama, on or about August 8, 1961 in the public records office in Hawaii.
2. Wayne Madsen, Journalist with Online Journal was a contributing writer and published an article on June 9, 2008 stating the GOP sent a research team to Mombasa, Kenya and located a Certificate Registering the birth of Barack Obama, Jr. at a Maternity Hospital, to his father, a Kenyan Citizen and his mother, a U.S. Citizen.
3. At the time ofObama's birth in 1961, Kenya was a British Colony.
4. There is a Canadian Birth Certificate posted on the Internet in the name of Barack Hussein Obama, Jr.; however, the date of birth shows to be August 23, 1961.
5. Under the Independence Constitution of Kenya, Obama became a Kenyan citizen on December 12, 1963. Chicago-based Internet journalist, broadcaster and critic Andy Martin states Obama has never renounced his Kenyan citizenship. Andy Martin further states on Obama's Senate web site, Obama tap dances around his own dual nationality when discussing his father. Obama obviously knows, because his father told the Obama, that he (Obama) also held/holds Kenyan nationality.
6. If in fact Obama was born in Kenya, the laws on the books at the time of his birth stated if a child is born abroad and one parent was a U.S. Citizen, which would have been his mother, Stanley Ann Dunham, Obama's mother would have had to live ten (10) years in the United States, five (5) of which were after the age of fourteen (14). At the time of

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Obama's birth, his mother was only eighteen (18) and therefore did not meet the

residency requirements under the law to give her son (Obama) U.S. Citizenship. The laws in effect at the time of Obama's birth prevented U.S. Citizenship at birth of children born abroad to a U.S. Citizen parent and a non-citizen parent, if the citizen parent was under the age of nineteen (19) at the time of the birth of the child. Obama's mother did not qualify under the law on the books to register Obama as a "natural born" citizen. Section 301(a)(7) of the Immigration and Nationality Act of June 27,1952,66 Stat. 163, 235, 8 U.S.c. §1401(b), Matter of S-F-and G-, 2 I & N Dec. 182 (B.I.A.) approved (Att'y Gen. 1944). Obama would have only been Naturalized and a Naturalized citizen is not qualified and/or eligible to run for Office of the President. U.S. Constitution, Article II, Section Clause 4.

1. Furthermore, if Obama had been born in Kenya, his birth father Barack Obama, Sf. was a citizen of Kenya; therefore, Obama would have automatically become a citizen of Kenya.
2. In or about 1967, when Obama was approximately six (6) years old, his mother, Stanley Ann Dunham married Lolo Soetoro, a citizen of Indonesia and moved to Indonesia with Obama. At this time, if Obama was Registered as a "natural born" citizen, which he did not qualify to be registered as, he would have lost his U.S. Citizenship when his mother married Lolo Soetoro and took up residency in Indonesia. The first requirement is that naturalization must be achieved through "application." Such type of naturalization occurs, for example, when a person acquires a foreign nationality by marriage to a national of that country. Nationality Act of 1940, Section

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>317(b). Additionally, there is rumor circulating on the Internet that his Indonesian stepfather, Lolo Soetoro, adopted Obama.

1. >The Nationality Act of 1940 provided for the loss of citizenship when the person became naturalized upon the naturalization of his or her parent having custody of such person. Obama's mother expatriated her U.s. Citizenship when she married Lolo Soetoro, a citizen of Indonesia and relocated her and her son (Obama) to Indonesia.
2. >Obama was enrolled by his parents in a public school, Fransiskus Assisi School in Jakarta, Indonesia. Plaintiff has received copies of the school registration where it clearly states Obama's name as Barry Soetoro and lists his citizenship as Indonesian, Obama's father is listed as Lolo Soetoro, Obama's date of birth and place of birth are listed as August 4,1961 in Honolulu and Obama's Religion is listed as Islam. This document was verified by television show Inside Edition, whose reporter, Matt Meagher took the actual footage of the school record.
3. >In or about 1971, Obama's mother sent Obama back to Hawaii. Obama was ten (10) years of age upon his return to Hawaii.
4. >Sometime after the return of Obama to Hawaii, Obama's mother, Stanley Ann Dunham returned to Hawaii and divorced her husband, Lolo Soetoro. At the time of Divorce, Obama's mother, Stanley Ann Dunham could have regained her U.S. Citizenship. In order to regain her citizenship, Obama's mother would have had to take the oath of allegiance required. Such oath of allegiance may be taken abroad before a diplomatic or consular of the United States, or in the United States before the Attorney General or the judge or clerk of a Court. Such Oath of allegiance would have been entered in the records of the appropriate embassy, legation, consulate, court or the

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Attorney General and upon demand, a certified copy of the proceedings, including a copy of the oath administered, under the seal of the embassy, legation, consulate, court or the Attorney General shall be delivered. The certified copy shall be evidence of the facts stated therein before any court of record or judicial tribunal and in any department or agencyoftheGovernment oftheUnitedStates. 8U.S.c.§1435.

31. As stated above, The Nationality Act of 1940 provided for the loss of citizenship when the person became naturalized upon the naturalization of his or her parent having custody of such person. Obama's mother expatriated her U.S. Citizenship when she married Lolo Soetoro, a citizen of Indonesia and relocated her and her son (Obama) to Indonesia.

Obama's mother failed to take the oath in order to regam her U.S. Citizenship. Therefore, Obama would not have been able to regain his U.S. Citizenship until he turned eighteen (18) years after he took the oath of allegiance before a diplomatic or consular officer of the United States, or in the U.S. before the Attorney General or the judge or clerk of court. Plaintiff is informed, believes and thereon alleges Obama failed to regain his citizenship by taking the oath of allegiance. Since the oath of allegiance would have been entered in the records of the appropriate embassy, legation, consulate, court or the Attorney General, if Plaintiff is incorrect, then Obama should be able to produce in Court a certified copy of the proceedings, including a copy of the oath administered.

Investigation further showed in 1981, Obama traveled to Pakistan usmg his Indonesian passport. At the time of travels to Indonesia, Obama was twenty (20) years old. He was well aware he maintained his Indonesia citizenship, and failed to regain his United States citizenship. Indonesia does not allow dual citizenship. Had Obama

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regained his United States citizenship, he would have been traveling on a United States Passport.

Obama and his Campaign office have been asked Obama's Certificate of Birth in order to prove he is a "natural born" citizen as required by the U.S. Constitution.

1. After many attempts of the public to obtain Obama's Certificate of Birth, a Hawaiian CCl1iticate of Live Birth (COLB) was placed on Obama's campaign website. However, as posted all over the internet, three (3) independent Document Forensic Experts performed extensive Forensic testing on the Certificate of Live Birth posted on Obama's campaign \vebsite. Thc Forensic Expert findings were the Certificate of Live Birth (COLB) was in a forgery. It was further discovered that this original Cer1ificate of Live Bil1h which had becn altered and f()rged was issued to Maya Kasandra Soetoro, born in J 970. Maya Kasandra Soetoro is Obama's half sister \vho was born in Indonesia and her birth was later registered in Hawaii. The altered and forged COLB is still on Obama's website located at http://my.barackobama.com/page/invite/birthcert
2. Further investigation led to Obama's State Bar Registration and Public Disciplinary Record. On the Illinois State Bar Registration and Public Disciplinary Record it specifically asks for "Full former name(s). Obama put "None," when in fact he went by the name Barry Soetoro, and Barry Obama. It is further believed Obama has used the name Barry Dunham. Obama lied on the State government form that he signed under the penalty of perjury.
3. Even if Obama maintained his United States Citizenship, which he failed to do, he also carries citizenships in Kenya and Indonesia. Obama has divided loyalties with

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foreign countries. Thus, Obama carries multiple citizenships and is ineligible to run for President of the United States. United States Constitution, Article II, Section 1.

1. All the efforts of supporters of legitimate citizens were for nothing because the Obama cheated his way into a fraudulent candidacy and cheated legitimately eligible natural born citizens from competing in a fair process and the supporters of their citizen choice for the nomination.
2. Voters donated money, goods and services to select a nominee, and were defrauded by Obama's obfuscations. Obama clearly shows consciousness of guilt by his actions by posting a forged birth certificate on his website, and by and the falsifications he told to cover his loss of citizenship.
3. Obama proclaims himself a Constitutional scholar and lecturer, but did not learn he had no eligibility to become President except by means of obfuscations and deceptions.
4. The injunctive relief must be granted because failing to do so, this inaction defrauds everyone who voted in the Democratic Primary for a nominee that is a fair representation of the voters. Failure to grant injunctive relief would allow a corrupted, fraudulent nomination process to continue.
5. It not only allows, but promotes an overwhelming degree of disrespect and creates such a lack of confidence in voters of the primary process itself, so that it would cement a prevailing belief that no potential candidate has to obey the laws of this country, respect our election process, follow the Constitution, or even suffer any consequence for lying and defrauding voters to get onto the ballot when they have no chance of serving if they fraudulently manage to get elected.
6. If declaratory and injunctive relief is not given, it would be extremely unfair to the country for candidates of either party to become the nominee when there is any question as to the nominee's eligibility to serve if elected.
7. As stated above, Plaintiff as well as Democratic American Citizens will suffer Irreparable Harm if Declaratory and Injunctive relief is not granted. Plaintiff does not have any other way of redress regarding these very significant and important issues.
8. The DNC has failed Plaintiff and the Democratic American Citizens by their failure to perform due diligence and inquire into Obama's eligibility to run for Office of the President.

COUNT ONE

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VIOLATION OF THE UNITED STATES CONSTITUTION, ARTICLE II, SECTION I

1. >Plaintiff hereby incorporates Paragraphs 1 through 45 as if fully set forth herein.
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   1. >The United States Constitution, Article II, Section I, Clause 4, Qualifications, Office of President, states: "No person except a natural born citizen, or a citizen of the United States, at the time of the Adoption of this Constitution, shall be eligible to the Office of President; neither shall any Person be eligible to that Office who shall not have attained to the Age of
   2. >thirty-five Years, and been fourteen Years a Resident within the United States."
2. >Obama's failure to maintain his United States Citizenship makes him ineligible to run for Office ofthe President.
3. >Obama, if born in Kenya would have made him a citizen of Kenya. Furthennore, because of the 1940 Naturalization Act, June 1952, Obama's mother would have had to be nineteen (19) in order for Obama to be a "natural born" United States citizenship upon registration of his birth. Obama's mother was only eighteen (18) when she birthed Obama and therefore was not old enough to meet the residency requirements under our laws at the time of Obama's birth and be able to register her son's birth as a "natural born" citizen.
4. >Even if Obama would have been able to be registered as a "natural born" citizen in Hawaii, he lost his citizenship in the United States when his mother married Lolo Soetoro, a citizen of Indonesia and then took Obama to Indonesia and set up residency with her new husband.
5. >Obama's mother could have regained her and Obama's United States Citizenship status when she divorced her husband, Lolo Soetoro and moved back to Hawaii. However, in order to regain her citizenship in the United States she would have had to take the oath of allegiance, which would have been recorded. Obama's mother never did take the oath of allegiance to regain her citizenship In the United States.
6. >Moreover, Obama could have regained his citizenship in the United States when he turned eighteen (18), again by taking the oath ofallegiance that would have been recorded. However, Obama failed to do so.
7. >The Democratic National Committee (DNC) is supposed to represent and protect the interests of working Americans, which includes securing a Democratic

Nominee on the Presidential Election ballot who represents the Democratic vision and who is qualified and eligible to run for Office of the President under the qualifications of the United States Constitution. The DNC has failed to inquire into Obama's eligibility status.

54. For the above aforementioned reasons, Obama needs to immediately supply a certified copy of his oath of allegiance proving he regained his United States Citizenship. In addition, Obama needs to furnish a certified copy of his Certificate of Live Birth to further prove he was born in Hawaii as he claims. However, if Obama is unable to supply a certified record of his oath of allegiance, he needs to immediately step down and withdrawal his candidacy for President.

WHEREFORE, Plaintiff respectfully prays that this Court:

A. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham is ineligible to run for United States Office ofthe President under the United States Constitution, Article II, Section I;

B. Preliminary and permanently enjoin Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham from running for United States Office of the President;

C. Preliminary and permanently enjoin Defendant, The Democratic Committee from nominating Defendant Barack Hussein Obama, a/k/a Barry

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Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham as the Democratic Nominee;

D. Award Plaintiff such costs and fees pursuant to 42 U.S.c. § 1988 and other applicable by law; and

E. Grant Plaintiff such other and further relief as the Court deems just and proper.

COUNT TWO

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DUAL CITIZENSHIP

1. Plaintiff hereby incorporates Paragraphs 1 through 54 as if fully set forth herein.
2. From the beginning of our Constitution, our forefathers inferred a person running for Office of the President could not have divided loyalties. This was a result of people coming from England to the United States who owed loyalties to both England and the United States. Our forefather's did not want a person with dual loyalties to be able to secure the position as President of the United States.
3. This inference is taken from Article II, Section I, which plainly states qualifications for Office of the President must be a "natural born" citizen.
4. The United States President cannot run our Country and have responsibilities and obligations owed to other countries.
5. Obama is not eligible to run for Office of the United States President as his mother failed to regain her citizenship after her divorce to Lolo Soetoro, a citizen of Indonesia, when Obama was a minor and Obama himself failed to regain his

United States Citizenship when he turned eighteen (18). Therefore, Obama is not

>a "natural born" citizen.

1. >Furthermore, Obama is well aware he is not a United States Citizen and does not qualify as a "natural born" citizen. Obama traveled to Pakistan in 1981, at which time he was twenty (20) years old and used his Indonesian Passport, not a United States Passport.
2. >The Democratic National Committee (DNC) is supposed to represent and protect the interests of working Americans, which includes securing a Democratic Nominee on the Presidential Election ballot who represents the Democratic vision and who is qualified and eligible to run for Office of the President under the qualifications of the United States Constitution. The DNC has failed to inquire into Obama's eligibility status.
3. >For the above aforementioned reasons, Obama needs to immediately step down and withdrawal his candidacy for Presidency.

WHEREFORE, PlaintitfrespectfuIly prays that this Court:

>A. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham is ineligible to run for United States Office ofthe President under the United States Constitution, Article II, Section I;

>B. Preliminary and permanently enjoin Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham from running for United States Office of the President;

C. Preliminary and permanently enjoin Defendant, The Democratic Committee from nominating Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham as the Democratic Nominee;

D. Award Plaintiff such costs and fees pursuant to 42 U.S.C. § 1988 and other applicable by law; and

E. Grant Plaintiff such other and further relief as the Court deems just and proper.

COUNT THREE

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FRAUD

1. Plaintiff hereby incorporates Paragraphs 1 through 62 as if fully set forth herein.
2. Obama committed Fraud upon Plaintiff and the American Citizens by running for President claiming to be eligible knowing he was not eligible as a result of his failure to regain his United States Citizenship and by maintaining multi citizenships with Kenya and Indonesia.
3. Obama further committed Fraud upon Plaintiff and the American people by falsifying infonnation on his Illinois State Bar Registration and Public Disciplinary Record. Obama stated on his Application to the State Bar of Illinois, as proven by the Illinois State Bar Registration and Disciplinary Record, stating he never used any other names. Obama signed his

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>application/registration for the Illinois State Bar under the penalty of perjury

>knowing the information to be false. The fact of the matter is Obama used the

>name Barry Soetoro in Indonesia and was registered as a citizen of Indonesia on

>his school records. Obama further used the name Barry Obama and it is further

>believed Obama used the name Barack and/or Barry Dunham.

1. >Obama attempted to defraud Plaintiff and the American people by allowing an altered and forged Hawaii Certificate of Live Birth (COLB) to be placed on his campaign website. Obama was well aware the Government issued COLB was altered and forged as the original document was in the name of Maya Kasandra Soetoro born in 1970. Maya Kassandra Soetoro Obama's half sister who was born in Indonesia and her birth was later registered in Hawaii. The altered and forged COLB IS still on Obama's website located at 11 ttV:/1my.barackobama.com/page/invite/birthcert
2. >Obama further attempted to defraud Plaintiff and the American People by claiming to be a United States Citizen, knowing this information to be false. Obama is well aware when his mother married Lolo Soetoro, a citizen of Indonesia and took up residency in Indonesia with Obama, they both naturalized in Indonesia expatriating their United States Citizenship. Obama's mother failed to regain her citizenship after her divorce to Lolo Soetoro, when Obama was a minor and Obama himself failed to regain his United States Citizenship by taking the oath of allegiance, which is recorded when he turned eighteen (18) years.
3. >Furthennore, Obama is well aware he is not a United States Citizen and does not qualify as a "natural born" citizen. Obama traveled to Pakistan in 1981, at which time he was twenty (20) years old and used his Indonesian Passport, not a United States passport.
4. >Moreover, as stated above, Obama was registered in School in Jakarta, Indonesia as Barry Soetoro, a citizen of Indonesia, born in 1961 in Hawaii and his religion was registered as Islam.
5. >The Democratic National Committee (DNC) is supposed to represent and protect the interests of working Americans, which includes securing a Democratic Nominee on the Presidential Election ballot who represents the Democratic vision and who is qualified and eligible to run for Office of the President under the qualifications of the United States Constitution. The DNC has failed to inquire into Obama's eligibility status.
6. >For the above aforementioned reasons, Obama needs to immediately step down and withdrawal his candidacy for Presidency.

WHEREFORE, Plaintiff respectfully prays that this Court:

>A. Declare that Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k/a Barack Dunham is ineligible to run for United States Office of the President under the United States Constitution, Article II, Section I;

>B. Preliminary and pennanently enjoin Defendant Barack Hussein Obama, a/k/a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a

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Barry Dunham, a/k/a Barack Dunham from running for United States Office of the President;

C. Preliminary and pelmanently enjoin Defendant, The Democratic Committee from nominating Defendant Barack Hussein Obama, a/k!a Barry Obama, a/k/a Barry Soetoro, a/k/a Barack Soetoro, a/k/a Barry Dunham, a/k!a Barack Dunham as the Democratic Nominee;

D. Award Plaintiff such costs and fees pursuant to 42 U.S.C. § 1988 and other applicable by law; and

E. Grant Plaintiff such other and further relief as the Court deems just and proper.

Respectfully submitted,

>Attorney in Pro Se 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Identification No. 09867

>(610) 825-3134

>

VERIFICATION

I, PHILIP J. BERG, hereby state that I am the Plaintiff in this action and verify that the statements made in the foregoing Complaint for Declaratory and Injunctive Relief are true and correct to the best of my knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.

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Date

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[Diamond]

Thanks for the posting it. I can use the Data File Host link in the future.

Cordially,

[brityank]

Thanks, Trib.

Sherri — here’s the case filed in Philly; there’s a pdf available at link #186.

Looks valid to me that Obamessiah has stepped in it bigtime, if he can’t prove/disprove the allegations listed. I actually have triple citizenship — US by naturalization; British from birth; and Pennsylvania by residence. Yep; every American is also a dual citizen; your State considers you so, and the US recognizes it and it is subservient to the federal.

Gonna be a fun week next week. LOL !!

[Fred Nerks]

http://www.recreate68.com/

Cindy Sheehan Joins Us in Denver
The Re-create 68 Alliance also announced that anti-war activist Cindy Sheehan and Green Party Presidential candidate Cynthia McKinney and Green Party Vice Presidential candidate Rosa Clemente will be joining their historic line-up of speakers who include Ida Audeh, Kathleen Cleaver, Ward Churchill, Mark Cohen, Chairman Fred Hampton Jr., Larry Hales, Larry Holmes, Ron Kovic, Glenn Spagnuolo, Pamela Africa, King Downing, Jenny Esquiveo, Mumia Abu Jamal - Current Political Prisoner (Recorded from Death Row for the DNC), Gloria Estela La Riva, Ricardo Romero, Natsu Saito, Ann Erika White Bird, and others.

[1035rep]

Your posting history is full of them. They are there for all to see.

I especially like the one where you hit back on the charge that Obama is unpatriotic for removing the flag from his plane.

"Where is the flag on McCain’s plane? All the pictures I’ve seen have only the blue and gold logo stuff, and the small American flag sticker, like the one on Obama’s flag."

There is no comparison between the unpatriotic, terrorist appeasing Muslim and McCain who served this country with honor. You are wasting your efforts here.

[holden]

"[Berg] does not even know the political affiliations of those who worked with him on preparing materials for the case"

Berg: Yeah, ten paralegals with lots of experience--but not such great writing skills--just showed up on my doorstep the day after I swore over that dinner to help pay off Hillary!s campaign debt that I would file a lawsuit against Obambi if I could just get some help preparing the case. /imagining

HF

[DAVEY CROCKETT]

Did you here about obamas first election? If this lawsuit goes it will be the same thing he did to Alice Palmer! This was also on CNN, yes I watched sorry.

How Barack Obama got his first elective office
Barack Obama this year has shown that he is a master of gaming the rules to his advantage. It turns out he has been this from the beginning of his political career.

Alice Palmer had been an Illinois State Senator for years. Obama was one of her staff members. It seems that in 1996, the local congressman, Mel Reynolds, got into legal trouble over a charge of having sex with a minor. When he left the Congress, Palmer decided to run for the congressional seat, and Obama was her hand-picked successor.

The only trouble was, after Palmer chose to run for the congressional seat, a certain Jesse Jackson, Jr. chose to run for that same seat. With such a famous name running against her, she finished very poorly, actually coming in third after Jackson and another State Senator. So she decided to go back to her old State Senate seat — the only problem was, Obama wanted it now!

In the ensuing primary, each candidate needed to get a certain number of petition signatures to qualify for the ballot. She needed something over 700 signatures, she filed over 1700; but Obama, as machine politicians often do, managed to get around 1000 of Palmer's signatures voided, enough to rule her off. In addition, he got two other competing candidates disqualified the same way, so Obama ran unopposed. Naturally, he won the seat! (It was a solid Democratic district, so the primary was all he needed to win.)

A machine politician par excellence, Barack Obama used all the nasty tricks that the Daley machine is known for. Naturally, since Daley had thought of Alice Palmer as a rival for power, he was not too unhappy at what Obama did.

[dennisw]

Your factcheck site is allied with Obama.

Then how come some of the entries are anti Obama?
Factcheck.org

[dennisw]

In the ensuing primary, each candidate needed to get a certain number of petition signatures to qualify for the ballot. She needed something over 700 signatures, she filed over 1700; but Obama, as machine politicians often do, managed to get around 1000 of Palmer's signatures voided, enough to rule her off. In addition, he got two other competing candidates disqualified the same way, so Obama ran unopposed. Naturally, he won the seat! (It was a solid Democratic district, so the primary was all he needed to win.)

I've read those accounts and I got the impression that signatures where never challenged in the black areas of Chicago

So here comes this Hawaiian "black guy" with no slave ancestors......
He swoops in with a Harvard Law School buddy and challenged all signatures and go his opponents disqualified

Which he also repeated during his Senate run where he got two opponents obliterated by getting their sealed divorce records opened. One opponents divorce records were opened up by him only after months of pressure by the Chicago Tribune instigated by Obama's operatives

Barack Obama records sealed at Illinois: The Swamp
Aug 20, 2008 ... The Tribune went to court to open the sealed private divorce records of the man who ran against Obama for the Senate, Will the paper be as ...
www.swamppolitics.com/news/politics/ blog/2008/08/barack_obama_records_sealed_at.html - 129k - Cached - Similar pages - Note this

This little smart ass POS gets his opponents records opened and keeps all his records sealed and locked away such as at Annenberg Challenge and his Illinois Legislature records and others

[Sandy]

what would be this guy’s standing to sue? Would his status as a citizen be enough?

He has no standing. The guy's an idiot.

[Sandy]

All states have provisions where any citizen can question and bring suit against someone regarding the eligibility of that person to run for any given public office.

This is a federal case. State laws are irrelevant.

[ljswisc]

I'm curious about the following entry in the document:

Obama further committed Fraud upon Plaintiff and the American people by falsifying information on his Illinois State Bar Registration and Public Disciplinary Record.

Obama stated on his Application to the State Bar of Illinois, as proven by the Illinois State Bar Registration and Disciplinary Record, stating he never used any other names. Obama signed his application/registration for the Illinois State Bar under the penalty of perjury knowing the information to be false.

The fact of the matter is Obama used the name Barry Soetoro in Indonesia and was registered as a citizen of Indonesia on his school records. Obama further used the name Barry Obama and it is further believed Obama used the name Barack and/or Barry Dunham.

No one questions that Obama has gone by many other names. Couldn't he be disbarred? Isn't this significant enough to cause some problems despite the question of his citizenship?

I haven't heard any commentary on this part of it.

[Salchaker]

Lawyer Phil Berg will be on http://www.GCNLive.com today at 2 pm ET talking about Barack Obama's citizenship issues and Berg's suit to enjoin the DNC from nominating Obama.

The host is Webster Tarpley who has written a book comparing Obamania to fascism, "Obama - the Postmodern Coup: Making of a Manchurian Candidate".

The show will be available on demand for one week at http://gcnlive.com/Programs/WorldCrisisRadio/On_Demand.html.

Berg's fact brief supporting his suit is also at http://www.waronfreedom.org/dox/BO-NO-Citizen-BriefFacts.htm . The gist plus a list of Obama scandals is at http://www.waronfreedom.org/dox/BONoUsCitizen.htm.

Yes it could get sticky in Denver. Barky's lemmings are past caring if he is a US citizen or not.

[Salchaker]

Here's another link to the story www.americasright.com

By the way Tarpley is left of center but Dr Jerome Corsi - author of Obama nation - recommended his Obama The Postmodern Coup book, they agree on the point of Obamania being a fascist type movement.

[vrajavala]

yes Berg is a Hillary supporter and the Federal Judge, Hon. R. Barclay Surrick, was appointed by Bill Clinton.

[vrajavala]

he lied on his Bar application that he never used any previous names. he will probably be disbarred.

[vrajavala]

It’s on Hannity’s forum. The parties haven’t been served yet. It’s not even in the Pacer system in Pa yet.

[politicalmerc]

To start with, prior to 2007 INDONESIA did not allow you to hold dual citizenship. When he was 20 he flew to Pakistan on an Indonesian passport (which would require that he be a citizen). If he still held his US passport then it was via fraud. He gave up his US Citizenship when he became Indonesian.

This could be legally very serious. But if Hillary does become the Nominee she is doomed because the Obamites will be so upset the party will disintegrate.

[seekthetruth]

Listening now to an interview of Philip J. Berg by Roger Hedgecock that took place yesterday. Interesting. All Obama has to do is provide the proof he is a natural born citizen of the US.

[seekthetruth]

“This could be legally very serious. But if Hillary does become the Nominee she is doomed because the Obamites will be so upset the party will disintegrate.”

What a lovely thought! An end to liberal/socialism, the cancer of America!

[politicalmerc]

He has held, and maybe still does hold, Indonesian citizenship which also makes him ineligible for holding the Office of President. Can’t have dual citizenship and run for President.

Legally, there is no prohibition, but it would be a killer politically. Many Americans hold dual citizenship.<<<<<<<<<<<

This is inaccurate. The Constitution does not allow mixed loyalties either.

More importantly, since he held an Indonesian Citizenship he would have forfeited his US Citizenship because prior to 2007 Indonesia did not allow dual citizenship. We know Obama did not retake his US Citizenship at least until he was 20 since he was in possession of an Indonesian Passport.

I guess that he maintained his US Passport fraudulently; using it to return to the US. Eventually he just discontinued using his Indonesian Citizenship. He may STILL be a citizen there.

He is NOT a citizen here if he did not reaffirm his citizenship. I’m not even certain that he could reaffirm or if he would then be considered naturalized.

The trip to Pakistan on an Indonesian passport at 20 years of age is the act that is going to sink him. Screw the legal argument, Joe Blow is not going to elect a guy who considered himself and Indonesian Muslim while he was in college. Obama has lied. That is the big problem. He lied about his aliases, he lied about his citizenship, he has lied about a lot of things.

Edwards just lied about an affair, you think lying about your citizenship is going to be less damaging?