Case 1:1 0-cv-00151-RCL Document 29 Filed 05/19/10 Page 1 of 11

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Dr. Orly Taitz, esq
29839 Santa Margarita Parkway, STE 100
4 Rancho Santa Margarita CA 92688
Tel: (949) 683-5411; Fax (949) 766-7603
5 E-Mail: drtaitz@yahoo.com
6 UNITED STATES DISTRICT COURT
7 FOR THE DISTRICT OF COLUMBIA

8 Dr. ORL Y T AITZ, ESQ, PRO SE §

Plaintiff, §HONORABLE ROYCE LAMBERTH
9 § PRESIDING
v. § Civil Action: 10-151 RCL
10 §
Barack Hussein Obama, §REPL Y TO 05.11.10 OPPOSITION
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§ TO MOTION FOR
12 § RECONSIDERATION
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Defendant. §
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Motion for Reconsideration is allowed and granted when new evidence is
22 presented and when there was a mistake of fact or law in the previous order.
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Three new facts are making an order for reconsideration justified and urgently
24 needed.
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On May 17,2010 Taitz has received a letter from Holder department of Justice
26 demanding $20,000 (Exhibit 1) for filing a legal action on behalf of Captain
27 Rhodes, which Judge Land erroneously considered frivolous. This fact shows
that indeed damages and not conjectural, but rather imminent and substantial,
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which makes the complaint for fraud filed by Taitz, proper and justified. Taitz has
submitted to this court a transcript ofthe assembly of the republic of Kenya
March 25,2010 session, where Minister of Lands, James Orengo, clearly stated
that Obama was born in Kenya. Affidavits from former senior deportation officer
with the department of Homeland security John Sampson, as well as investigator
Susan Daniels and retired Scotland Yard investigator Neil Sankey and official
records of Selective Service show Obama using Social Security number _
4425, which was assigned in the state ofCo=ecticut to another individual born in
1890, which is consistent with all the other evidence of Obama's foreign birth and
need to use a stolen social security number. All of this evidence points to the fact

Taitz v Obama. Reply to Opposition to Motion for reconsideration 1

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3 that Barack Hussein Obama indeed committed massive fraud by submitting his
candidacy for the position of the President. It was foreseeable, that proud
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members of US military, particularly officers will rise and revolt and demand
5 disclosure of the original birth records of the Commander in Chief to ascertain if
6 the orders coming from him down the chain of command are legal, as well as
explanation, as to why Obama is using stolen social security numbers. It was
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foreseeable, that those members of the military will hire an attorney. It was
8 foreseeable that such attorney will be persecuted for representing members of the
9 military standing up to this massive fraud perpetrated by Obama. Current letter of
demand of $20,000 and threat “to pursue enforced collection against you’ directly
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flaws from the fraud committed by Obama. As such, this new evidence shows
11 that Taitz has proper standing to sue Obama for fraud, as she was a foreseeable
12 victim, foreseeable plaintiff and she suffered damages as a result and as a
19 foreseeable consequence of fraud committed by Obama.

20 Additionally, new evidence presented in the form of today’s article in Mother

21 Jones magazine Exhibit 2 shows that there was a concerted effort of intimidation
and harassment of Taitz. Previously in her complaint Taitz presented evidence of
22 her car being tampered with, a group of convicted felons, convicted forgers were
23 working in unison and were submitting perjured affidavits, that looked prepared
24 by the same law firm, as well as “art work”, despicable in nature with a common
desire to intimidate and harass Taitz and her whole family and pressure her to
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give up her legal pursuit of fraud committed by Obama and her campaign for the
26 position of CA secretary of state. Defense claimed that all of those incidents were
27 unrelated and did not show concerted effort or damages. Recent article by
Washington burro correspondent Stephanie Mencimer shows that “artist” Dan
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Lacey, who painted despicable art work series “Birther Orly Taitz”, showing
Taitz nude, with her legs spread, giving birth and holding bloody placenta, which
were sent to her children, posted on the Internet and a local paper, did not work
on his own accord. Dan Lacey admitted, that he was commissioned, paid by
someone to do this, it was a clear attempt to intimidate Taitz and pressure her to
withdraw as a candidate. As far as damages are concerned $20,000 is only the tip
of the iceberg, as immeasurable emotional damage was caused to Taitz and her
whole family. Lacey refused to provide the reporter Stephanie Mencimer with the
name of the person who hired him, who paid him, however during the depositions
and upon subpoena this information will be available and will be provided to
Taitz v Obama. Reply to Opposition to Motion for reconsideration 2
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3 court. At the onset of the litigation Taitz cannot provide all the evidence and is
not obligated to do so. Taitz has showed sufficient evidence to show that she has
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standing to proceed. This particular evidence is crucial, as it shows concerted
5 effort. At this time Taitz cannot state with certainty who paid Dan Lacey,
6 however it is common knowledge, that Billionaire George Soros, one of the
biggest backers of Obama, through his organization Moveon.org, has
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commissioned numerous artists to promote Obama and denigrate his opponents
8 and critics. Only discovery will provide the names of all the Jane Does and John
9 Does involved. At the end of the day Watergate was unraveled by tracing the
moneys received, the bank accounts of the Watergate burglars, ObamaFraudGate
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will be fully exposed by tracing the bank accounts of individuals who were
11 involved in intimidation and harassment of Taitz, her family and others and the
12 bank accounts of individuals and organizations that commissioned them, as well
19 as tracing financial transactions correlating to multiple social security numbers
found in the National databases for Barack Obama, Barry Obama and Michelle
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Obama as well as multiple current job employments listed in the dossiers.
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1. Yet another fact, that became known after the original order was issued, is
22 the fact that Obama has appointed Solicitor General Elena Kagan to the
23 position of the Supreme Court judge. Many wondered why would the
24 President appoint a candidate, who never worked as a judge, not even as a
small claims court judge, not even as a traffic court judge. This fact becomes
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less perplexing in light of the following information: Taitz forwarded to
26 Kagan, as a solicitor general, not only her pleadings of Lightfoot v Bowen,
27 submitted to the Supreme Court and distributed by Chief Justice John Roberts
for conference of all nine justices, not only Quo Warranto submitted to the
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Supreme Court, but also all the dossiers sent to Attorney General Holder.
Kagan was sworn to uphold the Constitution and act on behalf of the People of
the United States of America, as a solicitor, top advocate for the United States
of America, not as a private attorney for Obama, she received information
regarding the fact that Obama’s Social Security number was assigned to
another individual, that the certification of life birth provided by Obama to the
public could not be considered genuine without analyzing the original, yet she
did not take action and remained silent. In light of all of the above a question
begs to be asked: was there a quid pro quo, was the appointment to the
Supreme Court a thank you for her silence? This new development makes it so
Taitz v Obama. Reply to Opposition to Motion for reconsideration 3
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3 much more important to proceed with discovery in this case, see the evidence.
Otherwise we might end up with a justice of the Supreme Court who was
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aiding and abetting the most outrageous felonies this nation has ever known.
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Opposition to motion for reconsideration also includes a challenge to adding
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former Presidential Candidate Allan Keyes and Vice presidential Candidate Gail
8 Lightfoot, questioning standing. Standing in this case is quite clear. If one ran in
9 the presidential election, which was won by a candidate, committing fraud, party
10 that lost has suffered damages in the form of lost election. Moreover, Ambassador
Keyes ran against Obama in senatorial election in 2004. Taitz has noved this
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honorable court to grant her privilege to represent these clients without a
12 signature of the local counsel. In extraordinary circumstances a presifing judge
19 can grant Pro Hac Vice or admission to the court without a signature of the local
counsel, only with a signature of the presiding judge. As most attorneys are
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simply paralyzed with fear to stand up to the sitting president and establishment,
21 this constitutes such extraordinary circumstance.
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Wherefore,
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Plaintiff respectfully moves to grant her motion for reconsideration.
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EXHIBIT 1
Demand of $20,000 from the Department of Justice

Taitz v Obama. Reply to Opposition to Motion for reconsideration 4

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3 EXHIBIT 2
4 May 18 2010 article from Mother Jones magazine, confirming that artist Dan Lacey was
5 commissioned (paid) to paint harassing pictures of Dr. Orly Taitz ESQ, Republican candidate for
6 CA Secretary of State.
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9 Advertisement

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Mother Jones
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21 ll Blogs

22 → Culture, Food and Ag, Politics

23 The Birther Queen Bee and the Painted

24 Pancake
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— By Stephanie Mencimer
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| Tue May. 18, 2010 3:00 AM PDT
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— Dan Lacey

Taitz v Obama. Reply to Opposition to Motion for reconsideration 6

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Orly Taitz, the queen bee of the birther movement, sounds distraught. “I’m going through hell,” she says. The California
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dentist-lawyer had called to tell me about what she says is a campaign to scare her family so that she’ll abandon her quest to become
4 California’s next Secretary of State. She says she’s endured death threats and an attempt to tamper with her car. But this time, she
says, her opponents have gone too far. The final straw? An elaborate oil painting of a nude Taitz, legs splayed, giving birth to… a
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pancake.
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First, a little back-story. For two years, Taitz has been demanding that California’s secretary of state request more evidence that
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President Obama is truly an American-born citizen. In March, she got herself on the ballot to run for the job in the Republican
8 primary. But since declaring her candidacy, Taitz says that Obama supporters have been targeting her children—she has two in high
school and one in college—via their Facebook pages with disturbing messages and images of their mother.
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10 Exihibit A, says Taitz, is a series of paintings of her by Dan Lacey, the so-called “pancake painter,” who achieved minor
celebrity during the 2008 presidential race for his numerous depictions of a naked, muscular Obama perched atop a unicorn. He’s
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also painted Sarah Palin, John McCain and Mother Theresa, among other famous figures, with a pile of pancakes atop their heads.
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But Taitz doesn't feel flattered to be in such company. She maintains that the painting titled Orly Taitz, Pancake Birther
23 actually portrays her holding a placenta rather than a pancake. "This is really despicable,” she says, theorizing that one of her many
political enemies put Lacey up to the work. But she says she’s more concerned about the effect the paintings are having on her
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children.
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For his part, Lacey quips, "I thought all of these were rather sweet paintings of her giving birth so I don't know why her family
26 would be upset. Perhaps her children now suspect that they are actually pancakes." He confirms that some of the original Taitz

27 paintings were commissioned (though he won't say by who). But most of them, he says, were his own inspiration. Lacey listed the
paintings on eBay, where one sold for about $200. "Orly remains a popular auction subject,” he explains, "though not quite as
28 popular as Michael Jackson."

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28 The famously litigious dentist
has not sued Lacey, saying she fears that doing so would only bring him more publicity. But she has used the paintings in a legal
filing against someone else: her opponent in the GOP primary for secretary of state, Damon Dunn. In March, Taitz sent a criminal
complaint to the Orange County registrar of voters accusing Dunn of voter fraud and demanding an investigation into alleged
intimidation aimed at her and her children. Taitz observes in the complaint that Dunn, a former NFL player, had never voted until
nine months before deciding to run for the state’s top elections position. She also accuses him of having been registered a Democrat
in Florida until just a few months before he declared his candidacy in the Republican primary—a fact his campaign has conceded.

Taitz believes Dunn’s campaign is merely one cog in a larger conspiracy to keep her out of office. Her letter to the registrar
includes a reference to the Lacey paintings and emails sent to her kids:

Taitz v Obama. Reply to Opposition to Motion for reconsideration 8

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3 These e-mails were clearly sent with the intent to cause severe emotional distress to my children and to me and with an attempt

4 to harass my whole family, and to intimidate me into dropping out of the race for the Attorney General [sic]. While the e-mail was

5 signed as coming from Damon Dunn, I actually don’t believe that Mr. Dunn personally sent these e-mails. I believe these e-mails

6 were sent by his supporters or by supporters of Mr. Obama, as I currently have an active legal action in the Washington DC Taitz v

Obama 10-cv-151-RCV.
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8 One of the Facebook messages allegedly sent to Taitz’s children came from someone pretending to be Dunn. It said:

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Will you be visiting your mum in jail after she's sent there for approving of, publishing and encouraging her supporters to issue
10 death threats against the family members (little children) of federal court judges in order to intimidate and coerce them into ruling in
11 her favor?

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Another, which went to her husband, read:
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20 Is there some reason her family (ie you) haven't put her into some form of treatment centre for her full blown paranoid

21 delusional state at this point?

22 In her complaint against Dunn, Taitz also mentions voicemail messages that have been left on her cell phone and offers to
submit them to law enforcement for verification. She says one caller told her that, “the best thing you can do for America, is slid
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[sic] your wrists, you fucking bitch.”
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This isn’t the first time Taitz has complained of harassment. In December, in one of her many lawsuits challenging Obama’s
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legitimacy, she insisted that someone had tampered with her car (she included an explanatory drawing).
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But for all the vilification that Taitz describes, she’s keeping her eyes on the prize. If she prevails in her bid for office, she’ll
27 become the gatekeeper for the entire California elections system, meaning that Obama will have to go through her to get his name

28 on the presidential ballot in 2012. And Taitz is emphatic about her intentions if she wins. She writes, "If I become Secretary of
State, I will demand proper original vital records from Obama." Pancakes or no pancakes.

Stephanie Mencimer is a staff reporter in Mother Jones' Washington bureau. For more of her stories, click here. You can also
follow her on twitter.

/s/ DR ORLY TAITZ ESQ

By:__________________________________
Dr. Orly Taitz, Esq. (California Bar 223433)
Taitz v Obama. Reply to Opposition to Motion for reconsideration 9
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3 Attorney for the Plaintiffs
29839 Santa Margarita Parkway ste 100
4 Rancho Santa Margarita CA 92688
Tel.: 949-683-5411; Fax: 949-766-7603
5 E-Mail: dr_taitz@yahoo.com
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27 PROOF OF SERVICE
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I CERTIFY THAT TRUE AND CORRECT COPY OF THE ABOVE
PLEADINGS WAS SERVED on 05.18.10. on
Alan Burch, Assistant United States Attorney for the District of Columbia
555 4th str.,N.W.
Washington D.C. 20530
/s/Orly Taitz

Taitz v Obama. Reply to Opposition to Motion for reconsideration

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Dr. Orly Taitz Esq
3 29839 Santa Margarita PKWY
4 Rancho Santa Margarita CA 92688
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Taitz v Obama. Reply to Opposition to Motion for reconsideration

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