UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

Dr. ORLY TAITZ, ESQ, PRO SE §

Plaintiff, § Freedom of information violation

§ 5USC §552

v. §

§

Michael Astrue, Commissioner of the §

Social Security Administration, §

§

§

Does 1-100 §

§

Respondents §

COMPLAINT

JURISDICTION and venue

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, Commissioner of the Social Security Administration

1. Plaintiff brings this action pursuant to the provisions of USC §552 known as the “Freedom of Information Act” (FOIA) and in particular 5 U.S.C. §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.
4. Plaintiff received a report and an affidavit from a licensed investigator and former Elite Anti Communist proliferation and Anti Organized Crime unit Scotland Yard officer Neil Sankey. (Exhibit 2 A and B)Mr. Sankey’s report and an affidavit, showed that Barack Hussein Obama, the President of the United States (hereinafter “Obama”) is linked in the National databases to some 39 Social Security numbers and multiple addresses. The number he used most often since around 1980 is xxx-xx-4425. According to Lexis Nexis and Choice Point this number originally was assigned to an elderly individual born in 1890, who resided in CT, but was assumed by Obama from around 1980-1981.
5. The first three digits of the Social Security number signify the state. 042 signifies the state of Connecticut.
6. Obama was never a resident of Connecticut.
7. At the time Obama obtained such Social Security number he was a student, residing in Hawaii.
8. To confirm such findings Taitz obtained an opinion of yet another licensed investigator, Susan Daniels, who attested to the fact that national databases show multiple social security numbers associated with the name Barack Obama, among them CT Social Security number xxx-xx-4425 used most often. She, also, found that this number was assigned originally to an individual born in 1890. Later, the same number was associated with the birth date 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 1
9. 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 xxx-xx-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.
10. 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.
11. This social security xxx-xx-5154 is noteworthy, as it was assigned to Lucille I Ballantyne, born 12.22.1912, deceased 09.13.1998
12. 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.
13. Obama’s selective service certificate verification, readily available on the world wide web, shows a complete match with the number xxx-xx-4425, therefore verification of Obama’s use of this number since 1980. Exhibit 4
14. Taitz verified this data with the third investigator, retired Senior Investigator with the Department of Homeland Security John Sampson.
15. 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 CT 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. Exhibit 3.

::::snipp::::

IMPORTANT NOTICE OF REDACTION RESPONSIBILITY: All filers must redact: Social Security or taxpayer-identification numbers; dates of birth; names of minor children; financial account numbers; and, in criminal cases, home addresses, in compliance with Fed. R. Civ. P. 5.2 or Fed. R. Crim. P. 49.1. This requirement applies to all documents, including attachments.

( ) I understand that, if I file, I must comply with the redaction rules. I have read this notice.

...Barack Hussein Obama, the President of the United States...

# In December of 2010 and January 2011 Taitz sent two follow up certified mail letters, where she stated that she treated lack of requested information as a denial and she demanded that SSA grant her FOIA request or officially deny it. None was received. As such SSA is in violation of the 5 U.S. §552 and Taitz requests an order and adjudication from this Honorable Court, directing Mr. Michael Astrue, Commissioner of the Social Security Administration to provide Taitz the information requested.

I CERTIFY THAT TRUE AND CORRECT COPY OF THE ABOVE PLEADINGS WERE SERVED on 02.01. 2011 on

Alan Burch, Assistant United States Attorney for the District of Columbia

555 4th str.,N.W.

Washington D.C. 20530 VIA MAIL and ELECTRONIC FILING

/s/Orly Taitz

...Mr. Sampson provided an expert opinion, that there is no reasonable explanation for one residing in HI to get a CT social security number....

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

If you are filing pro se, WTF does Defend Our Freedoms foundation [sic] have to do with anything?

In a separate letter Taitz requested for the SSA application for deceased Thomas Wood, SS number 042-68-4424. SSA acknowledged Taitz requests, however no information was ever provided and no denial of the request was ever received in 120 days.

Which more than likely indicates she had assistance.

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

If you are filing pro se, WTF does Defend Our Freedoms foundation [sic] have to do with anything?

She, also, found that this number was assigned originally to an individual born in 1890.

(B) On complaint, the district court of the United States in the district in which the complainant resides, or has his principal place of business, or in which the agency records are situated, or in the District of Columbia, has jurisdiction to enjoin the agency from withholding agency records and to order the production of any agency records improperly withheld from the complainant. In such a case the court shall determine the matter de novo, and may examine the contents of such agency records in camera to determine whether such records or any part thereof shall be withheld under any of the exemptions set forth in subsection (b) of this section, and the burden is on the agency to sustain its action. In addition to any other matters to which a court accords substantial weight, a court shall accord substantial weight to an affidavit of an agency concerning the agency’s determination as to technical feasibility under paragraph (2)(C) and subsection (b) and reproducibility under paragraph (3)(B).

This section does not apply to matters that are—
….
(3) specifically exempted from disclosure by statute (other than section 552b of this title), if that statute—
(A)
(i) requires that the matters be withheld from the public in such a manner as to leave no discretion on the issue; or
(ii) establishes particular criteria for withholding or refers to particular types of matters to be withheld; and
(C) could reasonably be expected to constitute an unwarranted invasion of personal privacy,

(a) Definitions.— For purposes of this section—
(1) the term “agency” means agency as defined in section 552 (e) [1] of this title;
(2) the term “individual” means a citizen of the United States or an alien lawfully admitted for permanent residence;
(3) the term “maintain” includes maintain, collect, use, or disseminate;
(4) the term “record” means any item, collection, or grouping of information about an individual that is maintained by an agency, including, but not limited to, his education, financial transactions, medical history, and criminal or employment history and that contains his name, or the identifying number, symbol, or other identifying particular assigned to the individual, such as a finger or voice print or a photograph;
(5) the term “system of records” means a group of any records under the control of any agency from which information is retrieved by the name of the individual or by some identifying number, symbol, or other identifying particular assigned to the individual;

(b) Conditions of Disclosure.— No agency shall disclose any record which is contained in a system of records by any means of communication to any person, or to another agency, except pursuant to a written request by, or with the prior written consent of, the individual to whom the record pertains, unless disclosure of the record would be—

Why didn't Taitz file this in the Central District of California? I look forward to the entire complaint. I suspect Mr. Copyright in esse helped her with it. I also suspect it will be dismissed fairly quickly since social security information on living persons is subject to an express exemption under FOIA, and it isn't the purpose of FOIA to answer questions that a requester may have, only to require production of documents.

I also suspect it will be dismissed fairly quickly since social security information on living persons is subject to an express exemption under FOIA, and it isn't the purpose of FOIA to answer questions that a requester may have, only to require production of documents.

Hopefully this will get assigned to Judge Lamberth. Hopefully he will see the error of his ways in failing to sanction her for her previous frivolous filings.

Additionally, as usual, she completely fucked up in not rounding up a plaintiff or two for this.