Orly filed something else

Orly Mascot

Orly Mascot

Today Orly Taitz’s First Amended Complaint in Keyes v. Obama was filed in the United States District Court for the Central District of California (Southern Division).

Gone is the Bush Executive Order that formed the basis of the original complaint. Gone are some of the defendants (e.g. Condoleezza Rice), replaced by new faces including Michelle L. R. Obama herself and Hillary Clinton. Found are a motley crew of new plaintiffs including many of the military persuasion and some state representatives. In fact, Orly has even changed the name of the lawsuit to CAPTAIN PAMELA BARNETT V. BARACK HUSSEIN OBAMA ET AL. Indeed the First Amended Complaint has nothing to do with the original suit, except that it is full of lies and targets President Obama.

Orly is even threatening to bring a RICO claim!

125. Because of the complexity of RICO pleading, and because there is presently a rush of time to get the pleadings in this case lodged and served, Plaintiffs reserve their pleadings of allegations under RICO for their Second Amended Complaint, and ask that the Court accept their filings of such pleadings when submitted without further leave of court, because it would have been desirable to consolidate and present all Plaintiffs’ viable claims at the present time.

Can you spell “kitchen sink?”

Orly seems to have invented a new standard of proof: not satisfied by a “preponderance of the evidence”, she demands “clear-and-convincing evidence”. Footnote 1, Page 3.

While Orly claims jurisdiction under FOIA and RICO (I’m not making this up), the meat of the claim seems to be that “knowing without doubt that the president is eligible” is a “civil right” and that the court should (if nobody can find an existing one) invent a law to enforce that civil right (42 U.S.C. §1988(a)). Orly also indicates that Barack and Michelle Obama are residents of California although in California he spells it “Barak”).

Given that all the evidence was invented, I guess it makes a perverted kind of sense to invent the law too.

And to top it all off, she writes:


However, don’t spend too much time getting to know this complaint (trying to find that “gold coin in a bucket of mud”), or marking your calendar for 60 days hence. A Second Amended Complaint is threatened with even more plaintiffs and even more unfounded allegations.

About Dr. Conspiracy

I'm not a real doctor, but I have a master's degree.
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78 Responses to Orly filed something else

  1. Shrieking wombat says:

    I just peeked over at the steaming pile of dog droppings that is the American Grand Jury website and came across this gem of a report of a conversation between Orly and Lou Dobbs:

    ‘Dobbs asked Taitz, If Obama did show a birth certificate, would that satisfy you? Taitz said, “Absolutely no way. He is NOT a natural born citizen.” ‘


  2. misha says:

    I posted this before. On YouTube, she flatly states that Obama can never be NBC because of his father. I guess she is re-writing the 14th Amendment.

    You can’t win with these reptiles. Arguing with them is a fool’s errand.

    If you argue with a fool, make sure you’re not doing the same thing.

  3. What is this insane woman’s fascination with a French national holiday? What am I missing?

  4. Shrieking wombat says:

    I suspect it may have something to do with the Reign of Terror that she imagines herself instigating:


  5. Mary Brown says:

    She believes she has had success with this judge. Remember how she chortled when she met Supreme Court Justices. Any civility on their part was regarded as an affirmation of her position. That’s how she sees the world. In preschool(and we expect this mindset with preop children)we call children who cannot yet see beyond themselves center of the universe kids. Adults, however, should be able to think outside of their own perspective. Dr. Taitz cannot do that. She now believes, I think, that the judge sides with her and she can just keep going.

  6. nolu chan says:

    She has “FILED JULY 14, 2009, BASTILLE DAY” on the bottom of every page. The court has “Filed 7/15/2009” at the top of each page. The Proof of Service is dated July 15.

    At the bottom of each page reads “Dr. Orley Taitz,” misspelled.

    It asks for declaratory judgment per quo warranto – not in the D.C. court but in the Central District of California. She explains that “Judge Robertson made it impossible for the undersigned attorney to obtain admission pro hac vice and try the matter in US court for the District of Columbia, where Quo Warranto is codified, as no DC lawyer would be willing to subject himself to the threat of sanctions from an obviously biased court.”

    The English is improved but the arguments are insane.

  7. Lupin says:

    Despite Madame Lafarge-Taitz’ delusions, I must reveal that we French (at least the ones who know about all this) laugh hysterically at her efforts.

    It is a tribute to America’s spirit of tolerance that she is not dressed in rags handing greasy pamphlets outside subway stations or ranting on a soapbox in Hyde Park.

    (Or maybe she does that as well?)

    In any case, please do keep the entertainment coming.

  8. brygenon says:

    Taitz thinks that Judge Carter promised to hear her case on the merits, and she knows that he wants to move things along promptly. The result is a rush job by an idiot.

    It looks like she pulled in some inappropriate verbiage she had around. Paragraph 57 ends, “Hopefully the buck stops here, in the Supreme Court”.

    She seems to have run out of time writing the time writing the Prayer for Relief. It is mercifully short, but doesn’t ask for any specific relief, just judgment against Obama and an order that Obama show cause why the plaintiffs should not get the relief they requested.

  9. The allusion was to Madame Defarge, a character in Dickens novel, A Tale of Two Cities, a woman bent on revenge.

    I have this vision of a woman dressed like a bar maid who led some bloodthirsty mob during the Reign of Terror, but I couldn’t find the name in the time I had to prepare my article.

  10. Orly seems to think that her case is a class action suit filed on behalf of the entire country. That in and of itself dooms the case, for lack of standing.

  11. Bob says:

    Pre-hearing article with video on the courthouse steps.

    I hope Taitz doesn’t see this; she’ll really complain about how the camera doesn’t flatter her.

  12. Bob says:

    No shocker: Judge dismissed Cook’s suit as moot.

  13. AdrianInFlorida says:

    Chalk up another dismissal to the list of prior dismissals.

  14. kimba says:

    There will be rending of garments in orly-ville.

  15. AdrianInFlorida says:

    They could find 8mm film of Barack Obama being born on a beach, with Honolulu and thee Punch Bowl in the background, with a copy of that day’s local newpaper to catch the afterbirth, and they’d still say it was either faked, somone else or irrelevent because they know better.

  16. kimba says:

    But the birthers knows Barack was born in a manger with a host of cherabim and seraphim singing and harp-playing. That’s why they call him Messiah. I wonder what bright star was in the heavens over Honolulu that blessed night?

  17. NBC says:

    Orly believes that Judge Carter will let her get away with this.
    When he rules on the case, he may very well make all her ‘arguments’ res judicata… Would that not be a fascinating turn of events

  18. Thanks for the link, Bob. I added it to my Media page.

  19. misha says:

    ” I wonder what bright star was in the heavens over Honolulu that blessed night?”


  20. Bob says:

    There’s a quick bit (before a cut) where you can hear Taitz say grand juries don’t need judges or prosecutors to be valid.

    I can understand a layperson believing that, but even Leo the Poker Player (the Godfather of Presentments) knew that was untrue.

  21. Bob says:

    You might like this on blogtalkradio: This Week in Birfistan.

  22. June bug says:

    Hi NBC – For clarification, are you saying that Carter, presuming he rules against Orly, could preclude her from bringing future actions IN ANY COURT, based on any of the arguments surfaced in this case?

    That would indeed be fascinating…

  23. NBC says:

    I am not a lawyer but there is the doctrine of res judicata

    Res judicata or res judicata (RJ) is the Latin term for “a matter [already] judged”, and may refer to two things: in both civil law and common law legal systems, a case in which there has been a final judgment and is no longer subject to appeal.[1]; and the term is also used to refer to the legal doctrine meant to bar (or preclude) continued litigation of such cases between the same parties, which is different between the two legal systems. In this latter usage, the term is synonymous with “preclusion”.

    See Wikipedia

    I am not a lawyer but if the judge were to rule on the merits of the actions, this may preclude Orly from filing these claims again and again in different courts.

  24. NBC says:

    In civil court the requirements for res judicata are quite narrow and a better approach would be Collateral Estoppel which can be applied even if the case is brought by a different party on a similar claim

    And then of course there is precedent..

  25. SvenMagnussen says:

    Major Cooks appears to be a articulate, reasoned man. It’s a shame BO is too busy attending fundraisers in NJ to have a meeting with Major Cook and present his credentials.

  26. SvenMagnussen says:

    Orly requested an interlocutory appeal on the issue of whether BO was successfully served as an individual and it was denied. Judge Carter had BO served in his capacity as the President.

    If Judge Carter rules against Orly, then I’m sure she’ll appeal Carter’s ruling on service to BO as an individual.

  27. NBC says:

    Why should the President take time off to meet with someone who doubts his established credentials?
    Major Cook is a non-issue and appearances can be deceiving.
    Getting healthcare through Congress and Sotomayor appointed are much higher on our President’s list.

  28. NBC says:

    Orly requested an interlocutory appeal on the issue of whether BO was successfully served as an individual and it was denied. Judge Carter had BO served in his capacity as the President.

    If Judge Carter rules against Orly, then I’m sure she’ll appeal Carter’s ruling on service to BO as an individual.

    She even failed to properly serve Obama as an individual so that matter would be moot. She dropped off her summons with an unnamed mail clerk at the DOJ…

    I am sure Orly will appeal on anything, the reality is however that the courts will continue to ignore her. And there is nothing really to appeal once she has served Obama, the ruling whether under 4(e) or 4(i) would be similar. The court never accepted service until recently so even if in error this is of no concern to the defendants.

  29. Bob says:

    Did George W. Bush ever get around to meeting with the citizen’s “grand jury” that indicted him for 9/11, so he could answer their “hard questions”?

  30. Bob says:

    If Judge Carter rules against Orly, then I’m sure she’ll appeal Carter’s ruling on service to BO as an individual.

    As Judge Carter didn’t grant her request for an interlocutory appeal, she can raise the whole service (non)issue in the inevitable appeal following the inevitable dismissal.

  31. NBC says:

    Sure she can raise anything she wants but since Judge Carter did not drop the suit due to lack of service but rather gave her an opportunity to properly serve defendants, justice was not denied.
    What Orly is hoping for is that a ruling that Obama was properly served would somehow cause him to be in default. But any such default would be excusable given the fact that the court clearly stated that service had not been effected.

  32. misha says:

    We also provided endless entertainment persecuting Clinton over a girlfriend.

    At Mitterrand’s funeral, his mistress stood next to his wife.

    “ranting on a soapbox in Hyde Park” Or Union Square.

    Hypocrites, all. J’accuse.

  33. misha says:

    No, because Bush is white.

  34. kimba says:

    Where in the world did you folks get the idea that any candidate has to demonstrate his eligibility to you personally? Even the bill currently in Congress doesn’t require that. Get over yourselves.

  35. Précisément!

  36. The shame is that his head is filled with birther lies.

  37. Pamela Barnett. AKA:

    “Black Female Army Captain” on the PUMA blog “TexasDarlin”.

    “Molly Pitcher” at Ed Hale’s Plains Radio forum.

  38. dunstvangeet says:

    Also, the Birth Certificate that Barack Obama has published on the Internet would provide sufficient under the Posey bill to be proof.

  39. kimba says:

    One of the comments at the military blogs:

    “We serve the nation, not the President.”

    I thought that was kind of cool.
    Birther translation: zOMG! The Army is full of smelly Obots! They got to them too!

  40. jtx says:


    Check your law books. Collateral estoppel first requires a valid final decision which would mean that the case would undoubtedly have to have undergone discovery – which of course is the big 800 pound gorilla for the O-borter!!

  41. kimba says:

    Hmmm, someone should post that info with her post about Orly’s “success” over at Plains Radio. I’d do it but I got banned whilst sparring with David the Sarah Fan awhile back. Funny how not long after they all turned on him for being a pompous ass.

  42. Mary Brown says:

    Why was the Major in uniform? As I recall he is forbidden to wear that uniform in a political context. I don’t know the rule but I’ve been a military wife for long enough to know he really should not have worn it. Is he begging them to do something to him?

  43. BlackLion says:

    She still cites John Bingham and claims that he said that a natural born citizen is one born of 2 citizens…Although this has been debunked on numerous occasions, she still brings it up. The scary part is that she actually believes her own lies…

  44. BlackLion says:

    JTX, not true. If it gets that far and Judge Carter hears Orly’s “evidence”, he can rule that there is insufficient admissible evidence to compel the President to do anything. Then there is a possibility that Collateral Estoppel can be applied. Because we all know that Orly will continue with this so called lawsuits to harass the President.

    What you fail to realize is that most supporters want Judge Carter to rule on Orly’s evidence. Because as long as she is using the infamous “grandma tape”, the so called “travel ban” to Pakistan, her numerous social security numbers, and the adoption theory as her evidence, her case will never survive a motion to dismiss or to show cause.

  45. Bob says:

    Here’s the DoD Instruction.

    Yes, you can’t wear it during “political activies.” But many birfers have been arguing Cook’s actions are not about politics. “Uh-huh.”

    Still, the uniform wearing is small potatoes compared to the prohibition against contempt.

  46. Rickey says:

    Orly’s pleadings are always good for a few laughs. She apparently is unaware of the fact that addresses which are dredged up from Lexis-Nexis, Infotek, Intellius or wherever are inherently unreliable and must be independently verified.

    For example, she has Michelle Obama living at 500 S. Buena Vista Street in Burbank, which happens to be the location of Walt Disney Studios.

    She has Barack Obama living at 1680 Video Drive and 1089 Digital Highway in Los Angeles, two non-existent addresses.

    1818 N. Vermont Avenue in L.A., another supposed Michelle Obama address, is a bookstore near the Los Feliz movie theater.

    3654 Barham Boulevard is an apartment building near Universal Studios.

    1045 N. Armando Street in Anaheim is a commercial building which houses a violin rental store, a video production company and a medical supply business.

    7035 Palm Drive in Rancho Cucamonga is a modest split-level home on cul-de-sac near San Bernardino.

    And so it goes.

    That fact that she would include such ridiculous information in a Federal Court complaint would be embarrassing except for the fact that she doesn’t know enough to be embarrassed.

  47. Mary Brown says:

    This major left his soldiers. As you know there is a battle for control of Afghanistan taking place right now. Young soldiers are in harms way and losing their lives. This battle is against the Taliban and followers of Bin Laden. His first responsibility was to those soldiers protecting us from an enemy that really doesn’t care who we are politically. He is as my apolitcal husband says a “blue falcon.” This planned and contrived event meant that someone had to leave quickly to take his billet. Why wouldn’t the military want him. His actions show he cannot put his soldiers first during a time of war. He abandoned them.

  48. Bob says:

    For those unaware: this is a Blue Falcon.

    Whoops! I mean: here is the definition.

  49. Mark says:

    Do you think she “actually” believes that or is this is a publicity/$$$ stunt?

    KO has her number, the worst person in the world.

  50. Mark says:

    “Major Cooks”
    “Major Cook”

    Which is it, genius???

  51. Expelliarmus says:

    JTX, collateral estoppel applies to issue of law as well as fact. So if Carter rules something like this:

    Their political claim does not give rise to a case
    or controversy to be heard in federal court.

    This Court has a duty to follow the United States
    Constitution. That Constitution limits jurisdiction to actual
    cases and controversies. To extend jurisdiction beyond its limits
    would be a violation of that very Constitution upon which Plaintiff
    relies in support of his claims.

    Then that determination could be applied to other cases brought by different plaintiffs under similar circumstances, advancing the same argument. (The above comes from Judge Land’s order today in the Georgia case)

  52. BlackLion says:

    Mark, I think it is both…I think she is a racist and hates President Obama, but I also think she sees how she can con and take advantage of her fellow racists out there that follow her and post to her site.

  53. Mark says:


    Today is a good day. Obama was here in NJ and later in NYC.

    His speech at the NAACP convention was inspiring. I may be the whitest guy you may ever see, but I am impressed with the way that he speaks. Very clear, get to the point. Life is Good.

  54. Bob says:

    collateral estoppel applies to issue of law as well as fact

    Although this is correct, I wonder, as a practical matter, whether the government will bother to raise this when it is much easier just to repeat the successul arguments against these suits without having to invoke collateral estoppel.

  55. Shrieking wombat says:

    You mean the Obamas are involved in the violin rental racket? Who knew?

  56. misha says:

    If you open one of those violins, you can find a Kenyan birth certificate, written in Swahili. Or is it Hebrew?

  57. Shrieking wombat says:

    And then the black helicopters come and whisk you off to perpetual enslavement in a FEMA camp on Tralfamadore.

  58. Expelliarmus says:

    collateral estoppel applies to issue of law as well as fact

    Although this is correct, I wonder, as a practical matter, whether the government will bother to raise this when it is much easier just to repeat the successul arguments against these suits without having to invoke collateral estoppel.

    The Judges don’t need it, but it is the interest of the US Attorneys to raise it along with other claims, as a way of tracking the history of these cases and making sure each judge in turn is aware of the history, and as a foundation to start asking for sanctions. Ultimately some judge is going to get ticked off enough to levy sanctions. I would note that in California it is mandatory for lawyers to report to the State Bar if they are sanctioned by a court for any non-trivial amount (I believe the threshold for reporting is $1000).

  59. misha says:

    It’s true. Michelle Bachmann says so.

  60. AdrianInFlorida says:

    Like most wingnuts, he wraps himself in the flag (His uniform) when convenient, and runs from it when necessary (When trying to get out of going to a war zone).

  61. AdrianInFlorida says:

    Orly is an idiot, she even mis-spelled her own name at the bottom of each page, in the footer. Moron.

  62. Bob says:

    Orly probably didn’t write that document; her thrice-disbarred convicted felon of a “law clerk” probably did.

  63. Lollie says:

    re: Orly Taitz

    Can some explain to me how Orly Taitz, licensed only in California, is somehow still able practice law in Georgia?

    With her history, I can’t imagine any court granting her a pro hac vice request.

  64. Lollie says:

    Naaah, the major is not begging for them to do something to him.

    The whole thing was nothing but a media gimmick.

    He knew he could request, and receive, a revocation of orders right up to the day he actually had to deploy.

    He and his correspondence school lawyer knew their motion would be dismissed . . . they just wanted as much media coverage for the Obama-hating “birther movement” as they could get.

    But it backfired . . . the facts came out.

    He had volunteered to go to Afghanistan in May 2009 — under the same Obama administration that 2 months later he says is not legit.

    His orders were revoked not because the Army was trying to cover for Obama, but instead because the commanding general of the Command he was ordered to deploy to said, “I don’t want this loon in my command.”

    And when they became aware of it, DoD revoked his security clearance, as they have every legal right to do, most likely for erratic and disturbed behavior that would give rise to a question of increased security risk.

    And his employer company, having signed an agreement with DoD giving them the right to demand termination or reassignment of any contract employee they choose, terminated him. As anyone who’s ever had a contractor security clearance knows, that’s a standard contract agreement when one wants to be a DoD contractor.

    And now he and his lawyer look like wingnutds.

    And the Obama-hating “birther movement” just took another one to the jaw. That’s 26 or 27 now, it’s hard to nail down the exact count, they lose so many. Every single one of their cases, in fact.

    This soldier screwed himself. No one retaliated against him. There’s no conspiracy, no cover up, no protecting Obama.

    The military and DoD did what they’re supposed to do, protect the interests and safety of the United States.

    This time against a near seditious Obama-hating birther in the military.

  65. kimba says:

    I think he was passed over for promotion to Col, and he’s been encouraged to retire soon from the Reserves. If he’s disgruntled, he might hope to cause a little trouble before leaving.

  66. Bob says:

    Can some explain to me how Orly Taitz, licensed only in California, is somehow still able practice law in Georgia?

    Because Taitz graduated from a law school that is not accredited by the ABA, she can only practice law in California’s courts.

    With a big caveat: And the federal courts. To practice in the federal courts, you need only be licensed to practice in any state. And it is entirely possible to appear in a federal court that is not in the state that licensed you.

    Now, there are rules. For example, in the district court in Georgia where Taitz’s filed Cook’s suit, the rules say you must either be licensed by Georgia, or have a certificate of good standing from a federal district court located in the state that licensed you. Taitz has been admitted to the district court for central district of California (which includes Los Angeles and Orange County).

    So it relatively easy for Taitz to comply with that. The Georgia rules, however, also say Taitz was supposed have a local (Georgian) cocounsel, and Taitz didn’t do that. Technically, the judge could have told her to sit down and make Cook argue his own case, but the judge knew this was a one-shot case, so he let her have her say.

  67. kimba says:

    And the poor ledger-enquirer in Columbus, GA and its intrepid reporters are getting more than they bargained for from Birfistan after Drudge linked to their stories on Cook.

  68. Bob says:

    Most of those took exception with one line in the story. “Actually, Obama was born in Hawaii in 1961, two years after it became a state,” Gordon’s story said.

    Of course. Everyone knows Hawaii isn’t a state.

  69. No, no. That traffic was spawned because I linked to it. ROFL. 😉

  70. kimba says:

    Oh shoot, of course. Many apologies Doc! But nobody from here threatened Ms Gordon. We should send her some Obot love!

  71. Epectitus says:

    taht would have actually been promotion to LTC. And yes… at 20+ years he’s more than a little overdue.

  72. Epectitus says:

    Actually… the Posey bill doesn’t even required a certified copy… just a copy. Obama’s COLB would be overkill.

  73. Epectitus says:

    Soon to be 2d Lieutenant Cook.

  74. strikefighter says:

    Notwithstanding the mindnumbing stupidity of her legal arguments, some of the language she uses in this filing is inappropriate. The woman uses an exclamation point after the words lifetime tenure, as if that will drive the point home. She uses the term “warp speed,” which in common usage is fine, but in a legal document dealing with supposed constitutional issues is totally inappropriate.

  75. misha says:

    “She uses the term “warp speed,”

    It is a term from science fiction, which is what her legal writings are.

  76. Snappy.

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