Dr. Orly Taitz, ESQ

29839 Santa Margarita Parkway, STE 100

Rancho Santa Margarita CA 92688

Tel: (949) 683-5411; Fax (949) 766-7603

E-Mail: dr_taitz@yahoo.com, orly.taitz@gmail.com

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

Dr. ORLY TAITZ, ESQ, PRO SE §

Plaintiff, § Freedom of information violation

§ 5USC §552

v. § CASE # 1:11-cv-00402

§ Assigned to Chief Judge

Michael Astrue, Commissioner of the §

Social Security Administration, § Hon. Royce C. Lamberth

§ Designation: FOIA/Privacy Act

Respondent §

FIRST AMENDED COMPLAINT

JURISDICTION

Current complaint filed under federal statute 5USC § 552 (a) (4)(B) and the respondents are officers of the U.S. government

PLAINTIFF

Plaintiff herein is Dr. Orly Taitz, ESQ, President of “Defend Our Freedoms foundation”, filing pro se

RESPONDENT

Michael Astrue, in his official capacity as the Commissioner of the Social Security Administration

Plaintiff brings this action pursuant to the provisions of 5 USC §552 known as the Freedom of Information Act (FOIA) and in particular 5 USC§552 (a)(4)(B)

ALLEGATIONS

1. Plaintiff, Dr. Orly Taitz, ESQ is the president of the “Defend Our Freedoms” foundation (hereinafter foundation) and an attorney, who represented this foundation.

2. Both the Plaintiff and the foundation are dedicated to the preservation of the Constitutional rights and freedoms of the U.S. citizens.

3. Plaintiff works closely with a number of licensed investigators.

3. Intervener received a report and an affidavit from a licensed investigator and former elite Anti Communist Proliferation and Anti Organized Crime unit of the Scotland Yard officer Neil Sankey. Mr. Sankey’s report showed that Barack Hussein Obama (hereinafter “Obama”) is linked in the national databases to some 39 different Social Security numbers and multiple addresses. None of these numbers was issued in the state of Hawaii. The number that he used most often since around 1980 and still uses today, while residing in the White House, is a Connecticut Social Security number 042-68-4425. According to Lexis Nexis and Choice Point this number was originally issued to an elderly individual born in 1890, who resided in Connecticut, but this number was later assumed by Obama and used by him from around 1980-1981.

4. The first three digits of the Social Security number signify the state. 042 signifies the state of Connecticut.

5. Obama was never a resident of Connecticut.

6. In March-April of 1977 when this number was issued to another individual in Connecticut, Obama was a 16 year old student, residing with his grandparents in Hawaii.

7. To confirm such findings Taitz obtained an opinion of yet another licensed investigator, Susan Daniels, who attested to the fact that the national databases show multiple social security numbers associated with the name Barack Obama, among them Connecticut Social Security number 042-68-4425 used most often. She, also, found that this number was originally assigned to an individual born in 1890. Later, the same number was associated with birth dates 04.08.1961 and 08.04.1961. Dates of 04.08.1961 and 08.04.1961 suggest existence of some documents, created using an European system of dating: Day, Month, Year, versus the American system of Month, day, year. Exhibit 4

8. Obama’s selective service certificate verification, readily available on the world wide web, shows a complete match with the number 042-68-4425, therefore verification of Obama’s use of this number since 1980. Selective service match provides proof and verification via an official document issued by the U.S. government that Barack Obama is using the Social Security number 042-68-4425 Exhibit 1

9. Further use of SSNVS (Social Security Number Verification System ) shows that combination of Barack Obama’s name and the same Social Security number shows as failed, meaning that the number that Barack Obama is using, was not issued to him, but rather to another individual. This provides evidence of the Social Security Fraud and identity fraud by an individual, occupying the position of the President of the United States of America and Commander-in-chief of the US military. Exhibit 2

10 In and around 1976-1977 due to new Social Security requirements multiple elderly individuals, particularly women, who were housewives and never worked before, applied for Social Security numbers in order to obtain Social Security benefits , therefore date of birth of 1890 originally connected to 042-68-4425 was consistent with many other examples of elderly individuals, born between 1890-1915, applying for Social Security cards for the first time between 1976-1977. Exhibit 5 October 3, 2010 FOIA request and March 2, 2011 FOIA response from the Social Security Administration

11. National databases such as Lexis Nexis and Choice Point show another Social Security number, originally assigned to an elderly individual, being connected to the name Barack Obama.

12. This Social Security number 485-40-5154 is noteworthy, as it was assigned to Lucille I Ballantyne, born 12.22.1912, deceased 09.13.1998. Exhibit 4

13. Ms. Ballantyne was the mother of Harry C. Ballantyne, Chief Actuary of the Social Security Administration, who had access to all Social Security databases and death indices.

14. It is also noteworthy, that Obama’s grandmother Madeline Payne Dunham was known to volunteer at the Oahu Circuit court probate department and had access to Social Security numbers of the recently deceased individuals, whose death may or may not have been reported to the Social Security administration.

15. Taitz verified this data with the third investigator, retired Senior Deportation Officer with the Department of Homeland Security John Sampson. Exhibit 7

Mr. Sampson provided Taitz with an affidavit, stating that according to his investigation, the number Obama is using most of his life, is indeed a Connecticut Social Security number. Mr. Sampson provided an expert opinion, that there is no reasonable explanation for one residing in HI to get a CT Social Security number. He also found that on one of Obama’s entry questioners the country of origin is listed as an Equatorial Guinea, not Kenya or Hawaii.

16. At the same time Taitz found that national databases show different dates of birth for Obama: 08.01 1961, 08.04.1961 and 04.08.1961 as well as 1890.

11. Recently released passport records of Obama’s mother, Ann Dunham, show that Obama was listed in her passport under a name Soebarkah. Exhibit 6

12. AP report from Indonesia, where Obama resided, show Obama’s elementary school record under the last name Soetoro.

13. Recently Neil Abercrombie, governor of Hawaii, in an interview to Honolulu Star Advertiser admitted that he was not able to locate the original birth certificate for Obama, only a notation by someone in archives that some record exists, though no actual original certified long form U.S. birth certificate was ever found for Obama.

14. Obama provided the public only a short form certification of live birth created in 2007, right before the election, which does not contain any essential information, which typically would be found in the original long form birth certificate , such as the name of the hospital, the name of the attending physician and signatures. The state of HI statute 338-17 allows a foreign born child of Hawaiian resident to obtain a Hawaiian birth certificate.

15. The state of Hawaii statute 338-5 allows one to obtain a birth certificate based on a statement of one relative only without any corroborating evidence from any hospital.

16. The state of Hawaii statute 338-6 allows one to get a late birth certificate, obtained as a result of adoption or loss of an original birth certificate.

17. Numerous reports, claiming that prior Governor of Hawaii Linda Lingle examined Obama’s birth certificate were false as well. Lingle’s interview reveals that she relied on a statement of former Director of the Health Department Chiyome Fukino, but Lingle never personally saw a birth certificate for Obama, which means that her statement was a hearsay.

18. Director of the Health Department Chiyome Fukino made a carefully crafted statement that there is a birth record in Hawaii, but in spite of thousands of demands for clarification from the media and citizens, she refused to clarify, what record exists there. A record or notation in archives created pursuant to statute 338-5, 338-6, 338-17 would constitute “a record”, but would not be sufficient to establish Obama’s birth in Hawaii without examining corroborating evidence from the hospital, which was never produced.

19. There were reports of newspaper articles, announcing Obama’s birth in HI. Follow up research did not uncover any such article anywhere. Nobody ever produced an actual newspaper with an announcement of Obama’s birth in the U.S. Only a microfiche image was found. There is no evidence, verifying when this image was created. Even if one were to believe that such news paper announcement actually existed in 1961, when Obama was born, it still does not prove that Obama was born in HI, as news paper article is not a prima facia evidence of birth and it could have been created based on a birth certificate, created under statute 338-5, 338-6, 338-17, which do not provide proof of birth in Hawaii.

20 . Senior Deportation officer John Sampson provided Taitz with a second affidavit, stating that when there is a suspicion of illegal use of a Social Security number of another individual, Social Security Administration routinely provides redacted information regarding the original SS_5 application to the Social Security administration. Such information includes gender, race, age at application, zip code. Such information is general enough not to reveal the identity of the live holder of the social security number, but it is extremely helpful in identifying fraudulent use. Taitz repeatedly submitted FOIA requests to the SSA, but was repeatedly stonewalled and even redacted information was not provided regarding the social security number 042-68-4425. Exhibit 7, 8

21. As above information shows that Obama does not possess either a long form birth certificate or a Social Security number of his own, Taitz filed a FOIA request for the SS-5 for 042-68-4425, she agreed to accept a redacted SS-5, but it was denied.

22. In MArch of 2010 Taitz filed an appeal and obtained a final determination on May 18, 2010, when her SSA FOIA appeal was denied by Jonathan R. Canthor, Executive Director, Office of Privacy and Disclosure of the social security administration.

23. Taitz appealed to the US District Court, District of Columbia 1:2010-cv-00151, Chief Judge of the DC Court, Hon Royce Lamberth.

24. Court denied the appeal, citing that the court appeal was filed prior to the final disposition by the agency and citing privacy considerations.

25. On October 4, 2010 Taitz filed yet another FOIA request with the Social Security administration requesting redacted information. FOIA requests are supposed to be granted or denied within 20 days. Taitz sent a total of six certified mail letters with requests to either grant or deny her request, but her request was not granted or denied for six months, at which time she filed this legal action. She submitted her original complaint on February 2, 2011, it was docketed on February 16, 2011. After this complaint was filed Taitz received a response from the SSA, but no information was provided regarding SSN 042-68-4425, citing privacy. No answer to the complaint was received yet and Taitz id filing this First Amended Complaint.

26 In this First Amended Complaint Taitz provides additional information, specifically Exhibit 1 Selective Service Application for Barack Obama, showing that he uses SSN 042-68-4425 and Exhibit 2 SSNVS Social Security number Verification System, which shows that this is not a legally obtained Social Security number for Barack Obama. This is a prima facia evidence of Social Security fraud and Identity Fraud obtained from the official records of the United States Government, which coupled with the age of 121years old of the original applicant (date of birth 1890) justify release of at least redacted SS-5 information requested, such as gender, race and age of the SS5 applicant for SSN 042-68-4425 and the zip code, where the original SSN card was mailed by the social Security administration. concealment of such data will constitute aiding and abetting Social Security Fraud and Identity Theft.

27. Further records from the Student Clearing House show even more shocking evidence. In his memoirs and multiple speeches Obama wrote that he studied for two years at Columbia University September 1981-May 1983. He admitted that in summer of 1981 he traveled to Pakistan to visit his friends, but repeatedly claimed that from September 1981 until May of 1983 he resided in New York and studied at Columbia University. Taitz ran a check of his years of attendance at Columbia university and found out that Columbia official records show him attending Columbia university only for nine months September 1982-till May 1983 (Exhibit 3), which means that the President of the United States lied to the whole nation about his whereabouts for a whole year September 1981 until September 1982. One year absence is the best case scenario, as he could get his university credit by reciprocity or through extern studies.

28. As there is no record of Obama residing anywhere else in the United States from September 1981-September 1982, or attending any other university, by way of simple deduction it becomes clear that his visit to Pakistan lasted not a month or two, as he claims, but over a year.

29. In 1981-1982 Pakistan was ruled by a ruthless radical Muslim leader general Zia Ul Hac, who came to power as a result of a military coup, announced himself as a Chief Martial Law Administrator and ruled the country via the system of iron fist terror. Supreme court of Pakistan, apparently afraid for their lives found such rule to be acceptable due to a “necessity” doctrine. Based on verification of Columbia university records, Taitz found that Obama spent at least a year within the regime of general Zia Ul Hac. This revelation adds urgency in processing this complaint, as it shows that we have today an individual usurping the position of the President of the United States and Commander-in-Chief of the whole US military, while using a stolen social security number, not possessing a valid long form U.S. birth certificate and defrauding the nation and concealing a whole year of his whereabouts.

Wherefore the plaintiff respectfully prays this court:

1.To take jurisdiction over this case

2. To order defendant to release limited redacted information from SS-5 application for Social Security number 042-68-4425. Information requested: gender, race, age of the applicant and the zip code, where the Social Security card 042-68-4425 was mailed by the Social Security administration

3. To grant attorneys’ fees

4. To grant such other and further relief as the court may deem proper and just.

03.24.2011

/s/ Dr. Orly Taitz, ESQ

29839 Santa Margarita Pkwy, ste 100

Rancho Santa Margarita CA 92688

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

orly.taitz@gmail.com

Service of process

I certify that a true and correct copy of the above first amended complaint Summons were served on 03.24.2011 on:

Michael Astrue

Commissioner of the Social Security Administration

Social Security Administration

Windsor Park Building

6401 Security Blvd.

Baltimore, MD 21235

Eric Holder-Attorney General of the United States

U.S. Department of Justice

950 Pennsylvania Avenue, NW

Washington, DC 20530-0001

Us Attorney -district of Columbia

William G. Stewart II, Assistant Director

FOIA/Privacy Staff

Executive Office for United States Attorneys

Department of Justice

600 E Street, NW, Room 7300

Washington, DC 20530-0001

(202) 252-6020

cc Congressman Darrell Issa

Chairman

House Oversight Committee

2347 Rayburn House Building

Washington DC, 20515

cc Congressman Mike Rogers

Chairman

House Intelligence Committee

133 Cannon House Office building

Washington DC 20515

cc Congressman Sam Johnson

Chairman

House Subcommittee on Social Security

House Ways and Means Committee

2929 N Central Expy, 240

Richardson, TX 75080

cc Congressman Dana Rohrbacher

Chairman

House Subcommittee on Oversight and Investigations’

House Committee on Foreign Affairs

2300 Rayburn House Building

Washington DC 20515

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