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AMENDED SUMMONS and VERIFIED COMPLAINT For Strunk V NYS BOE Et Al NYS 6500-2011 With The Complaint With Index No.: 29642-08 Annexed
AMENDED SUMMONS and VERIFIED COMPLAINT For Strunk V NYS BOE Et Al NYS 6500-2011 With The Complaint With Index No.: 29642-08 Annexed
Defendants.
Plaintiff, Christopher-Earl: Strunk in esse, a s and for the Complaint filed with jurisdiction
of New York State Election Law Article 5 16-100 over Article 12 related to the November 4,
2008 General Election inter alia equity relief and damages caused by a n ongoing schem&to
defraud with CPLR § 213 Actions to be commenced within six years, upon information and
belief and a t all times hereinafter mentioned, respectfully allege of Defendants a s follows:
(Breach of State Constitutional fiduciary duty as against all Public Officer Defendants)
Citizen resident in New York who was and is a qualified voter registered to vote in the 2008
election cycle and participate in the November 4, 2008 General Election in the State of New
York, and whose principal place for service is located at 593 Vanderbilt Avenue #281,
2. That this complaint is fairly traceable to the events and actions leading up to the Party
primaries during the 2008 election cycle for the ballot access of the Presidential slates at
the November 4, 2008 General Election as complained of in the related election law case
Strunk v. Paterson et al. NYS Supreme Court in the County Kings with Index No.: 29642-
08 before the Honorable Justice David I. Schmidt of Part 1 as an election law matter.
3. That Defendant NEW YORK STATE BOARD OF ELECTIONS, (Defendant NYS BOE)
with four commissioners two appointed from each major state party Defendant JAMES A.
Deputy Director Defendant STANLEY ZALEN, are all located at the New York State Board
4. Defendant NYS BOE and its agents have authority over their agents at the local boards
of election both for ballot access and the certification of the Presidential Elector Candidates
slates and committees for the names Barack Hussein Obama (BHO, SOEBARKAH), John
M. McCain III (McCain) and Roger Calero (Calero) hereinafter known as “Defendant
Presidential Candidate(s)” with the November 4 2008 General Election results published.
5. Based upon information and belief the Presidential Elector Candidate Defendants as a
Democratic side and Republican Majority leader Dean Skelos representing the McCain
appointed by Governor Paterson and Spitzer, now replaced by RUTH NOEMÍ COLÓN
New York State Acting Secretary of State; that according to the Help America to Vote Act of
2002 (HAVA) section 213 (a) (1) (A) are in their Official capacity are both Federal and State
officers who serve as an unpaid employee of the United States Election Assistance
Commission (EAC), and represent the Class of the Calero Electors along with those of the
Cuomo and Skelos classes; and that the Governor Cuomo appointee, RUTH NOEMÍ
COLÓN is located at the Department of State One Commerce Plaza 99 Washington Ave,
Albany, NY 12231-0001).
6. That the Secretary of State and Attorney General Eric Schneiderman are responsible
for the enforcement of NYS Civil Rights Law Chapter 6 Article 5-A Sections 53 through 57
the exclusive membership of Jesuits having an exclusive constitution and oath of induction
York state and individually with place of business located at The Office of the Attorney
General The Capitol Albany, New York 12224, was duly elected at the 2010 General
Election replaced Andrew Cuomo then Attorney General during the 2008 Election cycle.
8. The Defendants NYS BOE their agents John and Jane Does and with due notice
their agents having misapplied and mis-administered their public officer fiduciary duties
under NYS BOE regulation by failure to obtain and ascertain proof that each Defendant
Law, regulations and the United States Constitution Article 2 Section 1 Clause 5:
“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.”
9. Based upon information and belief the State Defendants, Defendant Presidential
Candidates, various Defendant Campaign Committees and their agents have not presented
a certified copy of the “long-form” birth certificate of the Defendant Presidential Candidates
for ballot access to the New York November 4, 2008 General Election / 2008 election cycle.
10. That based upon information and belief the NYS BOE has not maintained the
consistency of Presidential Candidate Certificate documents used for ballot access by mal-
11. There has never legally been an Article II Executive who has ever been a native
12. There has never legally been an Article II Executive who is a citizen of a foreign
13. That the Supreme Court of the United State opinion in McCreery's Lessee v
Somerville 22 US 354 (1824) explains the difference between a Natural-born and Native-
born U.S. Citizen as is to be applied with U.S. Constitution Article 2 Section 1 Clause 5.
14. That were the executive to be occupied by a foreign citizen would constitute an
invasion, coup-d-tat and trespass upon the sovereign citizen of New York a taking as of
right under the 10th Amendment become the basis for New York state and its People to
secede from the Union until such time the Union were made whole and laws enforced again.
15. Those Defendant BOE and Presidential Electors having been duly served prior to
citizen from ballot access in the state of New York when running for President and or Vice
16. Those Officer Defendants and the NYS BOE have not fulfilled the due diligence
necessary to protect the voter(s) during the 2008 election cycle, are ultra vires, are
17. That Defendant NYS BOE and its agents certified the Elector Defendants for each
Election for the preference election of the New York Electoral College;
18. That Defendant NYS BOE and its agents and Officer Defendants Cuomo, DiNapoli,
Colon, Schneiderman do not intend to enforce the requirements of the U.S. Constitution
Article II Section 1 Clause 5 and New York State ballot access eligibility requirements for
prospective candidates for POTUS ballot access at the 2012 election cycle.
19. That under the New York State Constitution the State of New York Legislature has
a winner take all system of Electoral College with 31 votes for selection of President and
Vice President based upon 29 House seats and two (2) U.S. Senators at large during the
2008 election cycle and will be 29 votes for the 2012 election cycle.
20. That Defendant JOSEPH ROBINETTE "JOE" BIDEN, JR. (a.k.a. Joe Biden)
individually as a Jesuit Coadjutor member of the Council on Foreign Relations and a papal
knight with place of business located at his Office: c/o the White House 1600 Pennsylvania
the ballot in the New York 2008 Election cycle and intends ballot status in the 2012 cycle.
21. Since shortly following Biden's withdrawal from the presidential race, Obama had
in a possible Obama administration. Biden declined Obama's first request to vet him for the
vice presidential slot, fearing the vice presidency would represent a loss in status and voice
from his senate position, but subsequently changed his mind. In a June 22, 2008, interview
on NBC's Meet the Press, Biden confirmed that, although he was not actively seeking a spot
on the ticket, he would accept the vice presidential nomination if offered. In early August,
Obama and Biden met in secret to discuss a possible vice-presidential relationship, and the
two hit it off well personally. On August 22, 2008, Barack Obama announced that Biden
would be his running mate. The New York Times reported that the strategy behind the
choice reflected a desire to fill out the ticket with someone who has foreign policy and
national security experience—and not to help the ticket win a swing state or to emphasize
Obama's "change" message. Other observers pointed out Biden's appeal to middle class and
blue-collar voters, as a Jesuit coadjutor for their “Social Justice” doctrine as well as his
22. Defendant Biden knew that Soebarkah is not eligible to run for president because he is
not a Natural-Born Citizen with a British Subject Father with a student visa, however in
furtherance of CFR foreign policy initiatives in the mid-east supported Soebarkah as a Muslim.
23. That Defendant SOEBARKAH (a.k.a Barry Soetoro, a.k.a. Birdie Dunham, a.k.a.
under the name Barack Hussein Obama is located in care of c/o The White House 1600
1
1. Joe Biden has received honorary degrees from the University of Scranton (1976), Saint
Joseph's University (1981),Widener University School of Law (2000), Emerson College (2003), his
alma mater the University of Delaware (2004), Suffolk University Law School (2005),and his other
alma mater Syracuse University (2009); and received the Chancellor Medal from his alma mater,
Syracuse University, in 1980. In 2005, he received the George Arents Pioneer Medal—Syracuse's
highest alumni award—"for excellence in public affairs."
Candidate on the ballot in the New York 2008 Election cycle and intends ballot status in
24. SOEBARKAH is a Madrasah trained radical Sunni Muslim by birth right according
to the Koran through his father Barack Hussein Obama Sr. (a Sunni Muslim), and that by
training and practice admitted during the speech to the Muslim Brotherhood in Cairo in
2009 – SOEBARKAH practices Shariah law, and is devoted to King Saud of Saudi Arabia
who based upon information paid for the Columbia and Harvard university expenses with
the full knowledge and blessing of Defendants: Peter G. Petersen; Zbigniew Brzezinski, his
sons Mark and Ian; Penny S. Pritzker; George Soros; Jesuits Fathers: Joseph P. O’Hare,
Joseph P. Parkes; Brennan Center Executive Frederick A.O. Schwarz, Jr.; Nancy Pelosi;
John Sidney McCain III; John A. Boehner; Hillary Clinton; Richard Durbin and others.
25. Defendant Soebarkah practices Al takia or the Islamist art of fooling the enemy and
26. Defendant SOEBARKAH admits his natural father at the time of his birth is a
citizen of the United Kingdom and as the British Nationality Act of 1948 governs dual
citizenship at birth; Soebarkah has dual allegiance at best by his own admission is not a
Natural-born citizen with the full knowledge and blessing of Defendants: Peter G. Petersen;
Zbigniew Brzezinski, his sons Mark and Ian; Penny S. Pritzker; George Soros; Jesuits
Fathers: Joseph P. O’Hare, Joseph P. Parkes; Brennan Center Executive Frederick A.O.
Schwarz, Jr.; Nancy Pelosi; John Sidney McCain III; John A. Boehner; and others.
27. That Rep. John Bingham, author of the 14th Amendment, Congressional Globe,
“… every human being born within the jurisdiction of the United States of parents
not owing allegiance to any foreign sovereignty is, in the language of your
Constitution itself, a natural-born citizen.”
placed an image of a Hawaiian Certification of Live Birth (COLB) on the Internet, which in
Hawaii per se is issued for all birth's registered by the State of Hawaii whether the human
being is born there or not, and as a prima facia fact means the Hawaii issued COLB does
not prove "natural born" citizenship or birth in Hawaii, only a long form document would.
29. Whether Hawaii was a territory or a state, historically it issued a COLB certifying
that the named person was born alive no matter where that may have been as evidenced by
the COLB; and for instance Sun Yat-sen was born on 12 November 1866 to a Hakka family
Guangdong province (26 km or 16 miles north of Macau), in the Empire of the Great Qing of
China. At age thirteen, Sun went to live with his elder brother, Sun Mei, in Honolulu. Sun
Mei, who was fifteen years Sun Yat-sen senior, had immigrated to the Hawaiian Islands as
a laborer and had become a prosperous merchant. Sun Yat-sen studied at the Iolani School
where he learned English, mathematics and science. Originally unable to speak the English
language, Sun Yat-sen picked up the language so quickly that he received a prize for
outstanding achievement from King David Kalākaua. While at Iolani, he befriended Tong
Phong, who later founded the First Chinese- American Bank. After attending Iolani School,
from which he graduated in 1882, Sun enrolled in Oahu College (now Punahou School, the
same private school where BHO was educated) for further studies for one semester. He was
soon sent home to China as his brother was becoming afraid that Sun Yat-sen was about to
embrace Christianity, which he did, but he returned to Hawaii at least twice, in 1900 and
1901. In March 1904, he obtained a Certificate of live Hawaiian Birth, issued by the
Territory of Hawaii, stating he was born on November 24, 1870 in Kula, Maui, and just as
the BHO HI COLB alleges he also was alive at birth on August 4, 1961 in Honolulu Oahu
the same in meaning and intent, and that BHO dual allegiance and dual citizenship at
30. A COLB issued to those who are "naturalized" in Hawaii is of questionable legal
issue contrary to U.S. Constitution Article 1 §8 Clause 4, Article I §9 Clause 1, Article 1 §10
Clause 1, and as a matter of first impression conflicts with the full faith and credit clause.
31. That Defendant SOEBARKAH at six years of age used the name given upon his
Armed Forces who had married Stanley Ann Obama, and as an Indonesian Citizen from six
years of age SOEBARKAH is presumed to have an Indonesian passport after removal from
the U.S. Passport of Stanley Ann Soetoro as released to Plaintiff on July 29, 2010 by the
32. That Defendant SOEBARKAH is also not eligible for the Office of the President
because with the McCarran-Walter Act of 1952 as the controlling legal authority for the
birth of BHO, and especially when the transmission of British citizenship to BHO at birth
no matter where the location is proves a dual citizen at birth, as a treaty matter between
Britain and the USA, and that with the admission against interest of both Stanley Ann
Dunham Obama and Barack Hussein Obama Sr. in a marriage in Hawaii entered after
conception, in which both parents attribute Paternity to BHO Sr. without challenge at the
time of the March 20, 1964 divorce decree makes BHO Jr. a British subject with dual
citizenship and multi-allegiances at best that by the 1952 McCarran-Walter Act, therefore
33. Further, Defendant SOEBARKAH lost his U.S. citizenship when his mother married
an Indonesian citizen and became a naturalized citizen of Indonesia and in that Indonesia
does not recognize dual citizenship, and because Defendant SOEBARKAH did not take an
retains Indonesian Citizenship having renounced his previous U.S. Naturalized citizenship
34. Plaintiff furthermore alleges, that had SOEBARKAH followed up with his resident
status after 1971 while living with his Grandmother in Hawaii to become naturalized, he
failed to take an oath of allegiance when SOEBARKAH turned 18 years old to regain his
U.S. citizenship status, and then obtained school financing as a foreign exchange student in
Hawaii and again at Occidental College in Los Angeles as done at Columbia and Harvard,
at best has multiple citizenship status with allegiances to Indonesia, Great Britain, Kenya
perhaps; however is not a natural-born citizen of the United States and according to the
public record is not even a citizen of the United States, and therefore, ineligible for the
presidency with NBC Clause as mandated by the Defendant NYS BOE; and
35. The Defendant class of the New York State Democratic Party Committee Candidates
for Presidential Electoral College from the State of New York for Presidential Candidate
Barack Hussein Obama and Vice Presidential Candidate Joseph Biden (“Democrat Party
Defendants certified with the New York State Board of Elections and related local entities
under New York state Election Law (EL) on or about September 24, 2008.
36. That on August 28, 2008 Defendant NANCY PELOSI individually with her place of
business located at Washington, D.C. Address 235 Cannon House Office Building
Washington, DC 20515-0508, and as chair failed to affirm for the Democratic National
(NYDP) the eligibility of BHO for ballot access in the State of New York November 4, 2008
General Election using the terms that “the following were duly nominated as candidates of
said Party for President and Vice President of the United States respectively:” and nowhere
website provisions citing Article II Section 1 Clause 5 in any of the several states and or
territories except for the State of Hawaii; however Defendant Pelosi as an admission
37. That on August 28, 2008 Defendant Pelosi individually and as Chair affirmed the
alleged eligibility of BHO for ballot access in the State of Hawaii November 4, 2008 General
Election differently than done for any other state or territory including New York using the
terms that “the following candidates for President and Vice President of the United States
are legally qualified to serve under the provisions of the United States Constitution” as
38. That on September 15, 2008, Defendant STATE COMMITTEE OF THE WORKING
Officer affirmed the alleged eligibility of BHO and the electors for ballot access in the State
of New York November 4, 2008 General Election using the terms that “by majority vote of
the members present, voting by weighted ballot, nominate the following Working Families
Party candidates for office at the General election to be held November 4, 2008:” nowhere
39. That the Democratic Party Elector Candidates are Velda Jeffrey, June F. O'Neill,
Dennis Mehiel, David A. Paterson, Andrew Cuomo, Thomas P. DiNapoli, Sheldon Silver,
Malcom Smith, Maria Luna, Robert Master, Pamela Green-Perkins, Helen D. Foster, Jon
Cooper, Hakeem Jeffries, Richard Fife, Deborah A. Slott, Terrence Yang, George Arthur,
George Gresham, Alan Van Capelle, Inez Dickens, Suzy Ballantyne, Alan Lubin, Bethaida
Gonzalez, Christine Quinn, William Thompson, Stuart Applebaum, Maritza Davila, Ivan
40. That in November 2008 the Court rendered an opinion in association with the
for any Electoral College Elector to hold more than one public office for compensation and
that all the democratic electors were duly served notice of both actions including the
underlying complaint herein regarding the improper ballot access for Barack Hussein
Obama before the November election, and that otherwise Plaintiff is damaged and injured
as a result of the Democratic Electors breach of duty as to ballot access for Presidential
41. Plaintiff seeks a decision by the Court as to whether or not the Candidate(s) are
eligible for Office of President of the United States (POTUS) as required with the United
York State Board of Elections including inter alia based upon the Certificate of Live Birth
matter Plaintiff seeks a Court decision herein as to whether or not Obama in fact has Dual
Allegiance, is not a Natural Born Citizen per se but merely a Native-Born citizen if that;
because BHO Jr.’s father, BHO Sr., is a British subject with a student visa at that time,
and is shown to be the purported father of BHO Jr. by both the newspaper announcement
and the COLB shown by Fact Check.org; and therefore, at best BHO Jr. is only a "Native"
born citizen, if that, with only one U.S. Citizen parent mother as a minor at his birth, and
that without two U.S. Citizen parents - BHO Jr. is NOT a "Natural" born citizen at best is
“Native” born - no matter where BHO was born the HI COLB does not prove NBC status;
42. That Defendant ROGER CALERO (Defendant Calero, Presidential Candidate) with
place for service located at the Committee Address: 1000 Grand Concourse, #4A Bronx, NY
10451, was born in Nicaragua in 1969. He and his family fled via Los Angeles, California in
1985. Calero is now a permanent resident alien (holding a green card) since 1990. While in
Proposition 187 in the early 90s, and is presumed to have filed a certification for ballot
access through the respective Defendant Socialist Worker’s Party Committee, but is not a
natural-born U.S. Citizen with the U.S. Constitution Article II Section 1 Clause 5 as
43. In that on April 10, 2008 as part of the scheme to defraud, U.S. Senator Barack
Hussein Obama was the Sponsor of the U.S. Senate sense resolution S 511 along with other
U.S. Senators Mrs. MCCASKILL, Mr. LEAHY, Mr. COBURN, Mrs. CLINTON, and Mr.
WEBB, and who maliciously submitted the S 511 resolution knowing it was false as to the
natural-born Citizen status of Senator John Sidney McCain III, in violation of 18 USC
§1001; and in which S 511 was referred to the Committee on the Judiciary then to the U.S.
Senate as a fraud upon Congress and the People of the several states and territories
“Whereas John Sidney McCain, III, was born to American citizens on an American
military base in the Panama Canal Zone in 1936:”
44. That U.S. Senator Barack Hussein Obama acknowledges endorsing Senate
Resolution 511 that one needs two (2) U.S.A. Citizen parents at birth to be qualified to be a
45. Further by U.S. Senate resolution is underscored and confirmed by the Honorable
United States District Judge Michael Chertoff then serving as the Secretary of Homeland
Security in testimony under oath before the U.S. Senate Committee and as reprinted in the
46. That on November 30, 2007, Barack Hussein Obama II, and on October 9th 2007,
John Sidney McCain III each affirmed an affidavit for the Arizona Secretary of State to
affirmations were duly filed with the AZ Secretary of State who certified each affirmed:
“I do solemnly swear (or affirm) that all the information in this Nomination Paper is
true, that as to these and all other qualifications, I am qualified to hold the office
that I seek, having fulfilled the United States constitutional requirements for
holding said office. I further swear (or affirm) that I have fulfilled Arizona's
statutory requirement for placing my name on the Presidential Preference Election
ballot.”
47. That on November 4, 2008, Plaintiff, as a victim of the scheme to defraud, voted for
the electors representing the Republican Party Presidential Candidate John Sidney McCain
III (McCain), that based upon information and belief that McCain was alleged to be a
natural-born Citizen and whom subsequently did not obtain sufficient votes to win the
winner take all Electoral College from New York; and thereafter was discovered not a
48. That Defendant JOHN SIDNEY MCCAIN III individually with place of business
located at Washington Office: 241 Russell Senate Office Building Washington, DC 20510,;
was a Presidential candidate at the New York 2008 election cycle without being a Natural-
born citizen with the full knowledge and blessing of Defendants: Peter G. Petersen;
Zbigniew Brzezinski, his sons Mark and Ian; Penny S. Pritzker; George Soros; Jesuits
Fathers: Joseph P. O’Hare, Joseph P. Parkes; Brennan Center Executive Frederick A.O.
Schwarz, Jr.; Nancy Pelosi; John Sidney McCain III; John A. Boehner; Hillary Clinton;
49. In good faith with the alleged NBC status as part of the scheme to defraud, Plaintiff
voted for Candidate McCain despite the fact that his wife is a most devoted Roman Catholic
whose two sons were educated by Jesuit priests went to Brophy Prep, School where Mrs.
McCain is a member of Brophy's board of regents and where the McCains have been
generous supporters of Brophy by support of vouchers for Catholic schools like Brophy.
Thomas J. Reese S.J., (former editor of America and senior fellow at the Woodstock
the Republican National Convention at the direction of the Jesuits at Fordham University
controlling the Archbishop of New York City and the Jesuits of Georgetown University
the Vienna Convention of Consular Affairs that agents of a sovereign state not interfere
51. Defendant John Sidney McCain III was born on August 29, 1936 in Colon Hospital,
Colon Panama, according to the Panama Canal Health Department not in the Panama
Canal Zone, which is authenticated by Donald Lynn Lamb representing the Panama
52. That according to the Hay-Banau-Varilla Treaty of November 18, 1903 that has 26
articles in which the two pertinent to the status of the city of Colon under that Treaty refer
to the Convention for the Construction of a Ship Canal says that the Colon Panama, the
birth city cited on McCain’s 1936 long form birth certificate where he was witnessed being
born, and where his parents resided, Colon, Republic de Panama, is not part of the Canal
Zone, quote:
ARTICLE I The United States guarantees and will maintain the independence of the
Republic of Panama.
ARTICLE II The Republic of Panama grants to the United States in perpetuity the use,
occupation and control of a zone of land and land under water for the construction
maintenance, operation, sanitation and protection of said Canal of the width of ten miles
extending to the distance of five miles on each side of the center line of the route of the
Canal to be constructed; the said zone beginning in the Caribbean Sea three marine miles
from mean low water mark and extending to and across the Isthmus of Panama into the
Pacific ocean to a distance of three marine miles from mean low water mark WITH THE
PROVISO THAT THE CITIES OF PANAMA AND COLON and the harbors adjacent to
said cities, WHICH ARE INCLUDED WITHIN THE BOUNDARIES OF THE ZONE
ABOVE DESCRIBED, SHALL NOT BE INCLUDED WITHIN THIS GRANT…”
Territory or the USA and is not eligible for the Presidency with the U.S. Constitution
53. The New York State Republican Party Committee Candidates for Presidential
Electoral College from the State of New York for Presidential Candidate John S. McCain
and Vice Presidential Candidate Sarah Palin as a class of elector candidate Defendants
certified with the Defendants NYS BOE and Secretary of State and by related local entities
under New York state Election Law (EL) on or about September 24, 2008.
place of business located at Washington, D.C. Office 1011 Longworth H.O.B. Washington,
DC 20515, and as Chairman affirmed for the Republican National Committee and
Defendant THE NEW YORK STATE REPUBLICAN STATE COMMITTEE (NYRP) the
alleged eligibility of McCain for ballot access in the State of New York November 4, 2008
General Election using the terms that “the following person, meeting the constitutional
55. Defendant John Boehner, when pressed on the BHO eligibility issue said: "The state of
Hawaii has said that President Obama was born there. That's good enough for me."
56. That on September 21, 2008, Defendant THE NEW YORK STATE COMMITTEE
alleged eligibility of McCain and the electors for ballot access in the State of New York
November 4, 2008 General Election using the terms that “do hereby certify that the
following persons were duly nominated by majority vote for the office of President and Vice
affirmed the alleged eligibility of McCain and the electors for ballot access in the State of
New York November 4, 2008 General Election using the terms that “do hereby certify that
the following persons were duly nominated by majority vote for the office of President and
58. There are 31 Candidates for the Republican Party Committee Presidential Elector
Slate under the names: Jesus Garcia, Gary Melius, Roger C. Bogsted, Lawrence Kadish,
Angelo Corva, Katherine A. James, Fred Ramstel, Debra Leible, Jane E. Deacy, Diane
Haslett Rudiano, Myrtle G. Whitmore, Richard Alicea, Jim Tedisco, Jim Kerr, Denice
Johns, Ed Cox, Doug Colety, Vincent Reda, Louis Liotti, Jasper Nolan, Kathy Jimino, Bijoy
Datta, James Ellis, Michael Nouolio, William Gilberti, Jr., Dean Skelos, James
59. That Defendant NYS BOE and its agents have not provided the ballot certification
requested with Plaintiff’s FOIL for Roger Calero’s Committee with THE SOCIALIST
YORK and or THE NEW YORK STATE REPUBLICAN STATE COMMITTEE and others.
60. Plaintiff, along with those similarly situated, suffers injury to his individual
sovereignty as guaranteed under New York State Civil Rights Law Chapter 6 Section 2 as a
sovereign citizen of the State of New York that here guarantees the Supreme sovereignty in
the people; and whereas, no authority can, on any pretence whatsoever, be exercised over
the citizens of this state, but such as is or shall be derived from and granted by the people
of this state; is denied equal treatment under the NYS Constitution guarantee for
(Denial of equal protection for voter expectation of a uniform true and correct ballot
according to law and regulations by the Defendants BOE and its agents, Candidates,
Committees and Political Parties)
61. Plaintiff repeats each and every allegation contained in the First Cause of Action
paragraphs 1 thru 60 with the same force and effect as though herein set forth at length.
62. Defendants by reason of their actions to seek election to the Electoral College on
November 4, 2008 with due notice otherwise before the General Election voted without
expressing intention to resign from the electoral college slate simultaneous with the
certification of the winning Electoral College slate under EL §12-102 by December 1, 2008,
63. That public officers of the NYS BOE Defendant and the Public Officer Defendants
intentionally Breach their oath of Office to be placed on the November 4, 2008 ballot as
candidates for electors of the Electoral College and fiduciary duty to the voter(s).
64. Plaintiff, along with those similarly situated, suffers injury to his sovereignty as
guaranteed under New York State Civil Rights Law Chapter 6 Section 2 as a sovereign
citizen of the State of New York that here guarantees the Supreme sovereignty in the
people; and whereas, no authority can, on any pretence whatsoever, be exercised over the
citizens of this state, but such as is or shall be derived from and granted by the people of
this state.
65. That Plaintiff individually as a natural person as with those similarly situated as
We The People as natural persons of the State of New York (a corporate entity) resident in
New York state are grateful to Almighty God for our Freedom, in order to secure its
blessings apart from any such corporate fiction or pretender monarch, and or as further
guaranteed by the 9th and 10th Amendments to the Federal Constitution, and Magna Carta.
66. That nunc pro tunc Plaintiff inherits all the sovereign rights, privileges and property
guarantees the sovereign Freedom from Almighty God against corporate fiction and Public
Officer Defendants and their agents who are ultra vires and bent on enslaving plaintiff and
67. That the failure of the NYS BOE its agents and candidates and various committees
to verify and protect Plaintiff an those similarly situated from the wrongful certifications
for ballot access at the November 4, 2008 general election for President / Vice President
have done so with impunity and that the mal-administration of law by public officers is an
egregious habit that without correction will continue by the “bi-partisan” control over
elections are expected to continue to repeat the same actions at the 2012 election cycle that
without restraint and injunction imposed with oversight available to the Court under NYS
CPLR and Election Law will further injure Plaintiff along with those similarly situated and
that Plaintiff has no other means to obtain relief in that Officer Defendants are ultra vires.
(Denial of substantive due process for voter expectation of a uniform true and correct ballot
according to law and regulations by the Defendants BOE and its agents, Candidates,
Committees and Political Parties aided and abetted unjust enrichment)
68. Plaintiff repeats each and every allegation contained in the First through Second
Cause of Action paragraphs 1 through 67 with the same force and effect as though herein
69. That Official Defendants by denial of substantive due process for voter expectation
of a uniform true and correct ballot according to law and regulations by the Defendants aid
and abet unjust enrichment of all defendant campaign committees and by failure
government, and burden his expectation of effective participation in the general election
were the laws not enforced in good faith with the duties of their office as a taking trespass.
the false billing of Defendant Presidential Candidate campaigns with associated funds from
the New York state taxpayers in the excess of say $10,000,000.00 or more, are liable for the
cost of elections, with interest, and cost of suit caused by the scheme to defraud.
(Interference with right to a republican form of government by Fr. Joseph A. O’Hare, S.J.,
Fr. Joseph P. Parkes S.J. and Frederick A.O. Schwarz Jr.)
71. Plaintiff repeats each and every allegation contained in the First through Third
Cause of Action paragraphs 1 through 70 with the same force and effect as though herein
72. That Defendant Fr. JOSEPH A. O'HARE, S.J. (a.k.a Fr. O’Hare) individually and as
a fourth level induction member of the White and Black Pope’s Militia that by exclusive
oath is a member of the New York Province for the Society of Jesus (NYPSJ) with place for
service located at the offices of the membership association incorporated in the state of New
York in 1944 located at 39 East 83rd Street, New York, New York 10028.
73. Defendant O’Hare from March 1986 until December 1989, Father O'Hare served on
committee charged with interviewing and recommending candidates for New York City
commissions. He also was a member of the Charter Revision Commission of the City of New
74. In April 1988, Mayor Edward I. Koch appointed Fr. O’Hare chair of the NYC
new law on voluntary public financing of municipal elections established by the City
Council and Mayor Koch in February 1988. He has been reappointed to this position twice
by Mayor Rudolph Giuliani in January 1994 and in April 1999, was reappointed by Mayor
75. Defendant Fr. O’Hare, the former president of Fordham University, and presiding
member of the Council on Foreign Relations, came to know Sonia Sotomayor as a Hispanic
Catholic associated with La Raza and the Aztlan Movement and they both served on the New
York City Campaign Finance Board in the 1980s, said: “I just don’t think Sonia would fit in
with Roberts, exactly, and certainly not Scalia. I think they’re very different Catholics.” (2).
76. Defendant Fr. O’Hare made every effort to support the candidacy of Barack Hussein
Obama, even though Fr. O’Hare knew he is not eligible for POTUS, with the intention to
further the Jesuit’s Social Justice doctrine with the work of Antonio Gramsci to elevate
Judge Sotomayor to the Supreme Court, as Judge Sotomayor would support regionalism of
the North American Union and be part of the church’s wing of Hispanic Catholics who are
more liberal than white Catholics on some social and economic issues, like immigration and
77. Father O'Hare's long association with America began in 1972 and was Editor in Chief
from 1975 until 1984 when then President Ronald Reagan recognized the Sovereignty of the
Vatican State for the First time in history on January 10, 1984 to reset the relationship of all
Jesuits as the Pope’s Militia with an exclusive oath of induction with duties to extirpate heretics.
2
Lucas A. Powe Jr., a professor of law and government at the University of Texas, Austin, said
Chief Justice Roberts and Justices Scalia, Thomas and Alito are “Catholic and movement
conservatives.” “That combination is just golden for being anti-abortion and anti-affirmative action,”
said Mr. Powe, author of “The Supreme Court and the American Elite, 1789-2008” (March 2009,
Harvard University Press). Justice Kennedy, who wrote two decisions favoring equal rights for gay
people, is a “country club Republican,” which Mr. Powe described as “an economic conservative
without some of the social conservatism.” The court’s liberal wing is made up of Justices Ruth Bader
Ginsburg and Stephen G. Breyer, who are Jewish, and John Paul Stevens, a Protestant. Justice
Scalia, whose son is a Catholic priest and Justice Alito are of Italian Catholic ancestry. Justice
Thomas is an African-American convert who once went to seminary, left the church for 28 years and
rejoined in the mid-1990s.
April 1, 1988 through March 31, 2003, and with Sonia Sotomayor from April 1, 1988
3
NYC Campaign Finance Board Members and their Terms of Service: July 28, 2010 – Present:
Joseph P. Parkes, S.J., Chairman, Art Chang, Richard J. Davis, Courtney C. Hall , Mark S. Piazza;
July 1, 2009 – July 28, 2010: Joseph P. Parkes, S.J., Chairman, Art Chang, Richard J. Davis,
Katherine C. Patterson, Mark S. Piazza; June 29, 2009 – June 30, 2009: Joseph P. Parkes, S.J.,
Chairman, Richard J. Davis, Katherine C. Patterson, Mark S. Piazza; February 10, 2009 – June 28,
2009: Joseph P. Parkes, S.J., Chairman, Dale C. Christensen, Jr., Katherine C. Patterson, Mark S.
Piazza; April 8, 2008 – February 9, 2009: Joseph P. Parkes, S.J., Chairman; Preeta D. Bansal, Dale
C. Christensen, Jr., Katheryn C. Patterson, Mark S. Piazza ; May 29, 2007 – April 7, 2008: Frederick
A.O. Schwarz, Jr., Chairman, Dale C. Christensen, Jr., Joseph P. Parkes, S.J., Katheryn C.
Patterson, Mark S. Piazza; April 1, 2007 – May 28, 2007 : Frederick A.O. Schwarz, Jr., Chairman,
Dale C. Christensen, Jr., Katheryn C. Patterson, Mark S. Piazza ; May 16, 2006 – March 31, 2007 :
Frederick A.O. Schwarz, Jr., Chairman, Dale C. Christensen, Jr., Katheryn C. Patterson,
Mark S. Piazza, Joseph Potasnik ; April 1, 2006 – May 15, 2006: Frederick A.O. Schwarz, Jr.,
Chairman, Dale C. Christensen, Jr., Katheryn C. Patterson, Joseph Potasnik ; September 16, 2004 –
March 31, 2006: Frederick A.O. Schwarz, Jr., Chairman, Dale C. Christensen, Jr., Katheryn C.
Patterson, Joseph Potasnik, Alan N. Rechtschaffen: October 27, 2003 – September 15, 2004:
Frederick A.O. Schwarz, Jr., Chairman, Alfred C. Cerullo, III, Dale C. Christensen, Jr., Joseph
Potasnik, Alan N. Rechtschaffen; July 30, 2003 – October 26, 2003: Frederick A.O. Schwarz, Jr.,
Chairman, Alfred C. Cerullo, III, Dale C. Christensen, Jr., Joseph Potasnik; April 1, 2003 – July 29,
2003: Frederick A.O. Schwarz, Jr., Chairman, Alfred C. Cerullo, III, Dale C. Christensen, Jr.,
Pamela Jones Harbour, Joseph Potasnik: October 17, 2000 – March 31, 2003: Joseph A. O’Hare, S.J.,
Chairman, Alfred C. Cerullo, III, Dale C. Christensen, Jr., Pamela Jones Harbour, Joseph Potasnik;
September 2, 2000 – October 16, 2000: Joseph A. O’Hare, S.J., Chairman, Alfred C. Cerullo, III, Dale
C. Christensen, Jr., Joseph Potasnik; May 31, 2000 – September 1, 2000: Joseph A. O’Hare,
Chairman, Martin S. Begun, Alfred C. Cerullo, III, Dale C. Christensen, Jr., Joseph Potasnik; May
18, 2000 – May 30, 2000: Joseph A. O’Hare, S.J., Chairman, Martin S. Begun, Dale C. Christensen,
Jr., Bill Green, Joseph Potasnik; May 13, 2000 – May 17, 2000: Joseph A. O’Hare, S.J., Chairman,
Martin S. Begun, Bill Green, Joseph Potasnik; June 28, 1999 – May 12, 2000: Joseph A. O’Hare, S.J.,
Chairman, Martin S. Begun, Bill Green, Dennis Mehiel, Joseph Potasnik; January 12, 1999 – June
27, 1999: Joseph A. O’Hare, S.J., Chairman, Martin S. Begun, Bill Green, Dennis Mehiel; June 1998
– January 11, 1999: Joseph A. O’Hare, S.J., Chairman, Martin S. Begun, Bill Green; September 19,
1997 – June 1998: Joseph A. O’Hare, S.J., Chairman, Martin S. Begun, Joseph Erazo, Bill Green;
June 2, 1997 – September 18, 1997: Joseph A. O’Hare, S.J., Chairman, Martin S. Begun, Bill Green,
Vaughn C. Williams, June 4, 1996 – June 1, 1997: Joseph A. O’Hare, S.J., Chairman, Martin S.
Begun, Bill Green, James I. Lewis, Vaughn C. Williams; June 7, 1995 – June 3, 1996: Joseph A.
O’Hare, S.J., Chairman, Bill Green, James I. Lewis, Vaughn C. Williams; July 21, 1994 – June 6,
1995: Joseph A. O’Hare, S.J., Chairman, Bill Green, James I. Lewis, Joseph Messina, Vaughn C.
Williams; December 11, 1992 – July 20, 1994: Joseph A. O’Hare, S.J., Chairman, James I. Lewis,
Joseph Messina, Vaughn C. Williams; September 23, 1992 – December 10, 1992: Joseph A. O’Hare,
S.J., Chairman, James I. Lewis, Joseph Messina; July 14, 1990 – September 22, 1992: Joseph A.
O’Hare, S.J., Chairman, James I. Lewis, Joseph Messina, Sonia Sotomayor; December 22, 1988 –
July 13, 1990: Joseph A. O’Hare, S.J., Chairman, James I. Lewis, Joseph Messina, Robert B. McKay,
Sonia Sotomayor; April 1, 1988 – December 13, 1988: Joseph A. O’Hare, S.J., Chairman, James I.
Lewis, Frank J. Macchiarola, Robert B. McKay, Sonia Sotomayor.
member of the Council on Foreign Relations, is a fourth level induction member of the
White and Black Pope’s Militia that by exclusive oath is the Jesuit Provincial member of
the New York Province for the Society of Jesus (NYPSJ) with place of business for service
located at the offices in New York state in 1944 located at 39 East 83rd Street, New York,
80. Father Parkes (4) was appointed to the Board by Mayor Michael R. Bloomberg on
May 29, 2007 and to chairman on April 8, 2008 whose term will expire November 30, 2013.
81. That Defendant Fr. Parkes served on the NYC CFB with Defendant Frederick A.O.
Schwarz Jr. and collaborates with the litigation efforts of the Brennan Center for Justice at
82. Defendant Fr. Parkes made every effort to support the candidacy of Barack Hussein
Obama, even though Fr. Parkes knew Soebarkah is not eligible for POTUS, with intention
to further the Jesuit’s doctrine of Social Justice using the work of Antonio Gramsci(5) acted
83. That THE NEW YORK PROVINCE OF THE SOCIETY OF JESUS was incorporated July
03, 1944 in the Bronx New York and is deemed an active domestic not-for-profit corporation
4
Fr. Parkes is the President of Cristo Rey New York High School in East Harlem. He also sits on
the Boards of St. Aloysius School in Central Harlem, St. Peter’s College in Jersey City, and St. Ann’s
School in East Harlem. He previously served as President of the Fordham Preparatory School. He
also served in a variety of posts within the New York Province of the Society of Jesus before his
appointment as Provincial in 1990. He earned his Bachelor’s degree from the Fordham University
College of Philosophy & Letters, his M.A. in Medieval History from the University of Wisconsin and
his Masters of Divinity from Woodstock College.
5
Antonio Gramsci : (January 22, 1891 – April 27, 1937) was an Italian writer, politician, political
theorist, linguist and philosopher. A founding member and onetime leader of the Communist Party
of Italy, he was imprisoned by Benito Mussolini's Fascist regime safeguarded by Fr. Pietro Tacchi
Venturi, S.J. His writings are heavily concerned with the analysis of culture and political leadership
and he is notable as a highly original thinker within the Marxist tradition. He is renowned for his
concept of cultural hegemony as a means of maintaining the state in a capitalist society.
contributing members who are subject to the restrictions from interfering with Domestic affairs
of New York and the united States of America as a sovereign entity with the Vienna Convention
Treaties of 1961, 1963 and 1969 as applies to consular affairs, and in which the Jesuits order are
84. That according to NYS Benevolent Orders Law, the members of the Jesuit Order are not
exclusive oath of induction that requires strict adherence to NYS Civil Rights Law Chapter 6
85. That Defendants Fr. O’Hare and Fr. Parkes among other members of the Pontifex
Maximus’s Jesuit Militia order here in New York since the January 10, 1984 recognition of the
Sovereignty of the Vatican State are questionably serving on the NYC Campaign Finance
Board Members and by their Terms of Service ongoing, and as well as endorsements of
Barack Hussein Obama to the POTUS, Judge Sotomayor to the SCOTUS and of other
political campaigns and appointments are interfering in the domestic affairs of the people of
New York state, must be restrained from such action; and that the Jesuit Order must be
audited and fined for failure to comply with NYS Civil Right Law Chapter 6 Article 5A.
86. On information and belief, the Defendant Chairmen act to enrich Vatican temporal
power and financial interests in Brooklyn as with the Nehemiah Housing projects here and
elsewhere and use their office to facilitate persons in service of the Jesuit Order and
Vatican, and that interferes with Plaintiff liberty along with those similarly situated.
87. That Plaintiff has been personally injured as a result of the Jesuit Chairmen’s
the Third Community Board for Bedford Stuyvesant and others including that for the
along with those similarly situated, as Defendant Jesuits and the CFB members approved
campaign matching funds to enable Plaintiff’s enemies the Assemblymen William Boylan of
the 55th Assembly District (AD) and Hakeem Jefferies in the 57th AD and State Senator
Velmanette Montgomery of the 18th Senate District, each have prospered at the loss of
liberty to Plaintiff along with those similarly situated and especially William Boylan who
$2,000,000 in damages as outlined in the EDNY case Strunk v US HUD et al. 99 cv 6480
(NG), as retribution for when Plaintiff exposed William Boylan's taking of NYC HPD
88. William Boylan has been indicted in the SDNY for influence peddling in Brooklyn.
(Interference with election franchise by Defendants and Frederick A.O. Schwarz, Jr.)
89. Plaintiff repeats each and every allegation contained in the First through Fourth
Cause of Action paragraphs 1 through 88 with the same force and effect as though herein
90. That Plaintiff is the founder of the AD HOC Brooklyn Home Rule Coalition (6) for a
referendum with NYS Municipal Home Rule Law Section 37 to return Brooklyn Home Rule
with the bottom-up annual election of a representative in each 5000 person district within
6
BROOKLYN HOME RULE COALITION http://associationforsovereignhomerulewithin.org/brooklyn-
home-rule-coalition.html : As an Ad Hoc group intent on maintaining the integrity of neighborhoods
and subsidiarity in communities within the respective community boards without dismantling gains
made every ten years. Brooklyn is to conduct annual election of neighborhood self-administration,
with One (1) representative Board member for each 5000 person district in each Community Board
(CB) with an average of 25 such districts that in turn each CB elect a chairman (18 in all) to carry
the proxy of each respective board member to advise the Brooklyn Mayor in the governance of
Brooklyn as a sub-division of the state as it once was, rather than the bedroom borough tax farm for
the Manhattan elite that since the Great Mistake of 1898 have depleted the opportunity of each
person in favor of oligarchy. 2011 INITIATIVE REFERENDUM with NYS MHR §37 to amend the
NYC Charter http://associationforsovereignhomerulewithin.org/bhrc-initiative---petition.html.
Rights Section application for VRA §5 pre-clearance review by the November 2011 election.
91. That members of the Council on Foreign Relations including Peter G. Petersen as
then Chairman that act with the Jesuit Order by the oath of allegiance superior to the
United States Constitution, Treaties and various States’ Constitutions that starting no
later than January 2006 sought to usurp the executive branch of government using Barack
Hussein Obama II and John S. McCain III, as a matched set of contenders then under joint
command and control, to preclude any other contender in preparation for a banking and
sub-prime mortgage collapse that requires subsuming the sovereignty of the people of the
united States of America and New York to International Monetary Fund conditionality with
loss of the dollar reserve currency status, and collapse of the living standards of the vast
92. That the Democratic and Republican Party at the national and State level colluded
in the plan to usurp the POTUS and used both Defendant Pelosi and Defendant Boehner to
carry out the scheme to defraud the voters of New York and the several states.
93. That Defendants Fr. O’Hare and Fr. Parkes along with Sonia Sotomayor and
Defendant Frederick A.O. Schwarz, Jr. as the NYC CFB Chairman from April 1, 2003 until
the April 7 2008 (while chief counsel to the Brennan Center for Justice) acted to interfere
with the election of Justices of the State Supreme Court by approving matching funds for
those Justices that exclusively handle foreclosures and would serve the temporal and
financial interests of the Vatican State to overturn the Judicial election requirements of
the New York State Constitutional election process of Justices done by Assembly Districts.
94. That Defendant FREDERICK A.O. SCHWARZ, JR. (Defendant Schwarz) is sued
individually and as past NYC CFB Chairman serving from April 1, 2003 until the April 7
2008, while the chief senior counsel the Brennan Center for Justice at NYU Law School
95. Simultaneously the Brennan Center filed the friendly case Lopez-Torres v the NYS
BOE et al. EDNY 04-cv-1192 (JG), in which Strunk intervened on the side of the State
Constitution and State Justices with an order taken on appeal to the Second Circuit Panel
with Judges Sonia Sotomayor, Peter Hall and Chester Straub in support of dismantling the
State Constitution as to election of Justices and from which the State filed for certiorari and
that was remanded back by the SCOTUS and that Defendant Schwarz had and has a
(Scheme to defraud Plaintiff and those similarly situated as against all Defendants)
96. Plaintiff repeats each and every allegation contained in the First through Fifth
Cause of Action paragraphs 1 through 95 with the same force and effect as though herein
97. ALL Defendants act in the scheme to defraud Plaintiff along with those similarly
process in conjunction with the private organizations known as the Council on Foreign
Relations with an exclusive secret oath superseding any oath to the U.S. and or respective
State Constitution and Sovereign Military Order of Malta (SMOM) directed by the Jesuit
General, used Peter G. Petersen, Zbigniew Brzezinski, Penny Pritzker, George Soros, et al.
including Fethullah Gulen with Fr. Thomas Michel S.J. and the Gulen Movement with the
Muslim Brotherhood here in Brooklyn (as with Soebarkah and Fr. Gregory Galluzzo, S.J.) to
blamed on the USA Military as the Stage Three described in U.S. DOS Publication 7277 to
1995 who co-authored Dreams from My Father and Republican Guard candidate McCain
since 1999 who co-authored, Faith of My Fathers and who both act together to reduce the
98. The actual scheme to defraud the voters in 2008 began in earnest on February 22,
2006 when the Editor of the Chicago-Kent Law School Law Review, Sarah P. Herlihy
(Kirkland & Ellis LLP), published a memorandum with approved edits of 11-23-05 entitled
THE IMPETUS AND THE OBSTACLE at Vol. 81: 275 , and with a special footnote
designating the author has a J.D. from Chicago-Kent College of Law, 2005 and “that the
author would like to thank Professor Graeme Dinwoodie, and the 2004–2005 Globalization
and Its Effect on Domestic Law Seminar Class for their valuable comments and insights on
99. The key to understanding the scheme to defraud the voters in 2008 is the way the
circumvention of U.S. Constitution Article 2 Section 1 Clause 5 required two not one
version of a candidate with flaws Barack Hussein Obama II and John Sidney McCain III.
100. That in the Herlihy memorandum Part one of the paper provides a brief history and
overview of the natural born citizen requirement. Part two discusses the rational reasons
for abolishing this requirement and describes why the increase in globalization makes
abolishing the natural born citizen requirement more necessary than ever. Part three
presents the arguments against allowing naturalized citizens to be eligible for the
presidency and identifies common beliefs about globalization that will cause Americans to
101. That according to Sarah P. Herlihy’s resume on line with the International Law firm
of Kirkland & Ellis LLP in Chicago after Ms. Herlihy was the Law Clerk to the Honorable
2006 she has been employed by the firm and in the resume she is listed with receiving the
award of the Order of the Coif whose various members of the Society are traced throughout
the Obama support network in conspiracy with the Candidates and Campaign Defendants.
102. That a Principal of Kirtland & Ellis LLP, Bruce I. Ettelson, P.C., is Member of
making donations to the Obama campaign , Jack S. Levin, P.C., another partner who, in
December 2002 was presented the ” Illinois Venture Capital Association’s lifetime
achievement award for service to the private equity/venture capital community” presented
103. That Kirtland & Ellis LLP is a global firm with powerful international clients listed
on the website that span the business affairs of the Sovereign Military Order of Malta,
including the current client British Petroleum, and includes among its attorneys SMOM
member John Robert Bolton the prior administration’s U.S. United Nations Ambassador.
104. The Jesuits, SMOM, CFR and OPUS DEI (documented by Plaintiff in the EDNY
Case Strunk v CIA et al. 08-cv-1196) are agents of the Holy See and the Vatican sovereign
state, as agents fail to follow 18 USC Chapter 45, Vienna Conventions and related law.
105. Plaintiff’s expert witness Eric Jon Phelps affirms that the CFR and its
affiliates, overseen by the Archbishop of New York City and his Knights of Malta at the
direction of the Pope of Rome on orders of the Jesuit General, are to rebuild the Kingdom of
Babylon including the City of Babylon. This quest will be pursued under the guise of
establishing a new Sunni Caliphate with its capital in Baghdad after the destruction of the
Temple Mount Mosques as well as Mecca and Medina, which destruction will be blamed
upon the USA during this present Papal Crusade in the Middle East. There will be built a
mandates the Kingdom of Babylon, from Dubai to Baghdad, will be the new economic
capital of the world headed by the final Pope of Rome, murdered and risen from the dead to
106. On May 28, 2010, in an radio interview with Eric Jon Phelps, in the context of a
review of Hosea 3:4-5; 6:1-2 and Romans 11:25, Count Vittorio Vivaldi III of Venice Italy
proves Islam is a Creation of the Vatican stated: “The Papacy created Islam to annihilate
the Pope’s Jewish and non-Roman Catholic Christian enemies.” States, “the Koran was
completed in 649 AD Rome under Pope Theodore I…it appears, however, after further
review, the Koran was completed in 632 AD during the pontificate of Pope Honorius I (625-
107. And for which Count Vivaldi confirms what the ex-Jesuit priest, Alberto Rivera
stated in an interview of December 11, 2001 of How the Vatican created Islam
Cardinal Augustin Bea while he was at the Vatican, and that based upon secret records in
the Vatican Library confirm starting in the third century the Vatican desperately wanted to
control Jerusalem acted through the Augustinian Monks to create Mohammed as the
Islamic messiah, wrote the Koran whose manuscripts are at the Vatican and prove "The
pope moved quickly and issued bulls granting the Arab generals permission to invade and
conquer the nations of North Africa. The Vatican helped to finance the building of these
108. To that end, Defendant PETER G. PETERSEN (Defendant Petersen) being sued
individually with his place of business as senior chair of the Council on Foreign Relations
of Malta (7) as well as Chairmen of the New York Federal Reserves Bank, co-founder of The
anticipation of the sub-prime mortgage collapse and as a prior Lehman chair, to be blamed
on Lehman Brothers, Bear Stearns and Bernard Madoff, that requires strategic turmoil to
restructure the Mideast using CFR members Zbigniew Kaimierz Brzezinski, Joseph Biden,
Penny S. Pritzker, George Soros, Nancy Pelosi, John Boehner, Barack Hussein Obama,
Frederick A.O. Schwarz Jr. John S. McCain III et al. to cease the executive in 2008.
individually with his place of business at Columbia University in the City of New York
School of Foreign Affairs 2960 Broadway New York, NY 10027-6902, is both a blood
member of the SMOM on "the right" and of the Scottish Rite Freemason Grand Lodge of
Philadelphia on "the left" working for the Jesuits against the sovereign interest of the USA
7
As a member of the Knights of Malta, and by virtue of your blood oath of obedience to the Pope,
you are required to support to the death the desires of the head of the Order of the Knights of Malta-
in this case, Pope Benedict XVI -over and above any other allegiance you may feel or pretend to feel
toward any other loyalty such as a loyalty to the Constitution for the united States of America.
Those who are presently members of the Knights of Malta must on penalty of death support
those policies advocated by the Vatican. It is not hard for them to do this. They BELIEVE in these
policies and principles. The polices which are espoused and proclaimed by the office of the Pope are
as follows:
1. End of sovereignty for the United States and other countries.
2. End of absolute property rights.
3. End of all gun rights.
4. The new international economic Order (world government).
5. The redistribution of wealth and jobs.
6. Calls for nations to trust the United Nations.
7. Total disarmament.
8. Promote the United Nations as the hope for peace.
9. Promote UNESCO, the deadly educational and cultural arm of the United Nations.
10. Promote interdependence.
11. Support sanctions honoring Father Pierre Teilhard de Chardin-the New Age Humanist Priest.
12. Support the belief that the economic principle of traditional Christian or Catholic social
doctrine is the economic principle of communism.
13. Promote the Pope as the acting go-between for the United States and the Soviet Union.
111. Defendant Brzezinski as a CFR member and founding member of the Trilateral
Commission, that as National Security Advisor to five presidents maintains the belief that:
"In the economic-technological field, some international cooperation has already been
achieved, but further progress will require greater American sacrifices. More intensive
efforts to shape a new world monetary structure will have to be undertaken, with some
consequent risk to the present relatively favorable American position."
"The technotronic era involves the gradual appearance of a more controlled society. Such a
society would be dominated by an elite, unrestrained by traditional values. Soon it will be
possible to assert almost continuous surveillance over every citizen and maintain up-to-
date complete files containing even the most personal information about the citizen. These
files will be subject to instantaneous retrieval by the authorities."
112. Defendant Brzezinski‘s world outlook and agenda by evidence of writings acts for the
Society of Jesus that eclipses all other influences on SOEBARKAH, McCain and Calero.
113. That Defendant Brzezinski has managed a crucial role for the Vatican State as a
member of the SMOM and as a Freemason of the Philadelphia Grand Lodge to create global
regionalism that subsumes national sovereignty and as Former National Security Adviser
to President Carter expressed his view of regionalism at Mikhail Gorbachev’s October 1995
“We cannot leap into world government in one quick step...The precondition for
eventual globalization — genuine globalization — is progressive regionalization.”
"recognizes that the challenge is a new face, a new sense of direction, a new
definition of America's role in the world." Also saying, "What makes Obama
attractive to me is that he understands that we live in a very different world where
we have to relate to a variety of cultures and people."
115. In September 2007 during a speech on the Iraq war, Soebarkah introduced
Brzezinski as "one of our most outstanding thinkers," but some questioned his criticism of
question about how aggressive President Obama should be in insisting Israel not conduct
an air strike on Iran saying: "We are not exactly impotent little babies. They have to fly
over our airspace in Iraq. Are we just going to sit there and watch?" This was interpreted as
117. Defendant Brzezinski is on the faculty of Columbia University from 1960 and is now
emeritus, was on the faculty of Harvard University 1953-60. Ph.D., Harvard University,
1953; B.A. and M.A., McGill University 1949 and 1950; and holds Jesuits honorary degrees
from Georgetown University, Williams College, Fordham University, College of the Holy
Cross, Alliance College, the Catholic University of Lublin, Warsaw University, the
University of Tbilisi, the University of Vilnius, the Ukrainian Free University, the
118. That Defendant Brzezinski advised CFR members SOEBARKAH and McCain whose
campaigns used his sons, Mark who was a member of the advisors in the SOEBARKAH
Campaign and Ian who was an advisor on the McCain Campaign, all done in exchange for
his sons’ government employment and furtherance of the enterprise corruption associated
with funding raising done by George Soros and King Juan Carlos.
119. Defendant IAN J. BRZEZINSKI individually has his place of business is located at
The Atlantic Council Headquarters 1101 15th Street, NW, 11th Floor Washington, D.C.
20005 U.S.A. Tel: (202) 463-7226 Fax: (202) 463-7241; he is son of Polish American political
120. Defendant Ian J. Brzezinski was the Foreign policy advisor to the campaign of John
is on the Atlantic Council’s Strategic Advisors Group. During George W. Bush presidency of
the United States, he served as Deputy Assistant United States Secretary of Defense for
Europe and NATO Booz Allen Hamilton, Inc. providing policy and technical support to U.S.
contributor of American press on foreign policy issues today; he leads the Brzezinski Group
at the Atlantic Council, which provides strategic insight and advice to government and
commercial clients.
122. Defendant MARK BRZEZINSKI is an American lawyer and foreign policy expert
place of business is located at McGuire Woods LLP 2001 K Street N.W. Suite 400
earned a J.D. from the University of Virginia Law School, and holds a D.Phil. in political
science from Oxford University. He also earned a Fulbright Scholarship to study the Polish
Constitutional Court. He was a corporate and securities associate at Hogan & Hartson LLP
in Washington, D.C. from 1996-1999. From 1999-2001, Mr. Brzezinski served in the Clinton
of the National Security Council at the White House. In that capacity, he was White House
coordinator for U.S. democracy and rule of law assistance programs for the region. He is
currently a partner in the Washington, D.C. office of the law firm McGuireWoods, where he
124. Defendant Mark Brzezinski was a foreign policy advisor to the presidential
125. That Plaintiff with those similarly situated are denied individual 1st, 5th , 9th and
financial injury for the cost of the 2008 election cycle in New York..
126. That Democrat Party Elector Candidate Defendants, their agents John and Jane
Does are part of an enterprise who have overthrown the government of the United States in
conjunction with SOEBARKAH, Joseph Biden, McCain, Calero and their agents at the
state and national level with those other candidate elector slates of other states of the
several states.
Guard committed perjury before a Federal Officer in violation of 18 USC §1001 as part of
form of government, and burden his expectation of effective participation in the general
election were the laws not enforced in good faith with the duties of their office.
129. Plaintiff is the only person in the USA to have duly fired fired fired BHO on January
23, 2009 by registered mail (rendering BHO the USURPER as Plaintiff is entitled to
characterize BHO as) on the grounds that he had not proven himself eligible to be the
U.S. Constitution Article 2 Section 1 clause 5 with a pending Replevin matter in the
District of Columbia; and all acts by the usurper are void ab initio – a serious problem!
130. Furthermore, New York State Board of Elections individuals; the New York State
Secretary of State individually, the New York State Attorney General Andrew Cuomo
individually as an elector along with John and Jane Does have conspired inter alia for a
breach of fiduciary duties under color of state law enacted by the State Legislature to
protect Plaintiff’s along with those similarly situated right to a reasonable expectation of
participation and success with a proper ballot for the New York electoral college election of
131. That Defendant PENNY SUE PRITZKER (Defendant Pritzker) is the principal of
the Pritzker Realty Group, L.L.C. 71 S. Wacker Drive 47th Floor Chicago, IL 60606 P:
132. Defendant Pritzker (8) raised campaign funds with George Soros, was co-chair of the
2009 Presidential Inaugural Committee, was thought to be in the final stages of vetting to
8
The Superior Bank FSB was a Hinsdale, Illinois-based Savings and loan association that collapsed
in July 2001 [1] with some $2.3b in assets. Synopsis: Superior opened in 1988 under conditions
created by the Federal Home Loan Bank Board, which made generous arrangements for the takeover
of several failed thrifts. The bank was a 50-50 partnership between the Pritzker's jointly (the elder
Jay, Penny and Thomas) and real estate investor Alvin Dworman (architect of the “sub-prime”
mortgage after the collapse of the savings and loan industry), who ran Superior from his New York
office after Pritzker's death in 1997. The Pritzkers and Dworman bought the failed Lyons Federal for
the relatively modest price of $42.5 million, with each using a shell corporation to control half of
Coast-to-Coast Financial Corporation (CCFC), a holding company created to own Superior. The July
2001 collapse, according to a press release from the Office of Thrift Supervision, “Superior Bank
suffered as a result of its former high-risk business strategy, which was focused on the generation of
significant volumes of subprime mortgage and automobile loans for securitization and sale in the
secondary market. OTS found that the bank also suffered from poor lending practices, improper
record keeping and accounting, and ineffective board and management supervision.”
George Kaufman, a finance professor at Loyola University Chicago called Superior's failure
"a tale of gross mismanagement," adding "[Superior] was engaged in relatively unethical practices,
fancy-footwork accounting, playing it very close to the edge." Kaufman says many share in the blame
for the mess-the bank's managers, directors, and auditors, as well as banking regulators-but he also
wonders how the Pritzkers, as co-owners, could have allowed it to happen. "One of the great
mysteries to me is what the Pritzkers were up to, why they took these chances," he said. "It makes
no sense given their wealth and visibility."
The Settlement by the Pritzkers in December 2001, agreed to pay a record $460 million to
the federal government to avoid being punished for the failure of Superior Bank FSB. And the RICO
lawsuit in 2002 uninsured depositors filed federal class-action charges under the RICO Act against
one-time board chairwoman Penny Pritzker, her cousin Thomas Pritzker, Dworman, other bank
principals and Ernst & Young. Plaintiffs’ attorney Clint Krislov claimed that those who controlled
Superior induced depositors to put money in the bank, “corruptly” funneling money out of the bank
to “fraudulently” profit the owners. The lawsuit, Courtney v. Hallerin was an initially filed under a
district court, which dismissed the claims; the appeal was argued before the 7th Circuit of the United
States Court of Appeals on September 25, 2006. In her May 7, 2007 opinion, Judge Wood affirmed
the lower court's decision. http://www.scribd.com/doc/49708919/A-Financial-History-of-Modern-U-S-
Corporate-Scandals-From-Enron-to-Reform see Pages 226-227 and 281-282.
chief architect of his record-breaking fund-raising efforts during the presidential campaign.
hearings that involved running and overseeing Superior Bank, an Illinois institution co-
owned by her family that was at the forefront of turning subprime loans into securities, the
risky practice at the heart of the financial crisis. The bank collapsed in 2001 after
134. Presently Defendant Pritzker is chair of the newly launched Skills for America's
Future for the administration and is gearing up for a re-election funding in 2012.
135. Defendant Pritzker is associated with Martin H. Nesbitt and George Soros who all
served to raise and bundle campaign funds for the Obama Campaign committees.
Pritzker Realty Group, and Chairman and co-founder of Vi(formerly Classic Residence by
Hyatt), The Parking Spot and Artemis Real Estate Partners. TransUnion is a global
financial information company; the Pritzker Realty Group invests in non-hotel real estate
and developed the award winning Hyatt Center in Chicago's Loop. Vi (pronounced VEE) is
a leading developer and operator of lifestyle communities for older adults, the Parking Spot
in association with Martin H. Nesbitt manages the largest network of off-site airport
parking facilities in the U.S. Launched in 2010, Artemis Real Estate Partners is a private
137. Defendant Pritzker is a board member of the Council on Foreign Relations, a trustee
of Stanford University, a trustee of the John F. Kennedy Center for the Performing Arts, an
advisory board member of Brookings Institution's Hamilton Project, and a former member of
the Harvard University Board of Overseers. Defendant Pritzker’s daughter Rachel Pritzker
138. That Defendant GEORGE SOROS (a.k.a. George Schwartz) with place for service at
Soros Management 888 7th Avenue Suite 3300 New York, NY 10106, is a Member of: the
Council on Foreign Relations, the Carlyle Group, Major Stockholder: Halliburton, Financial
Backer of Barack Hussein Obama, Friend of Rupert Murdoch (9), and a high level
Freemason.
139. Defendant George Soros proves his allegiance to Rome by promoting Muslim
Brotherhood overt control of Egypt---now a reality. We cannot forget that the Jesuits in
Cairo created the Muslim Brotherhood in 1928, the same year the Order created Opus Dei
in Spain. Egypt is to be the staging base for an Islamic invasion into Israel from the South-
--somewhat like the 1973 Yom Kippur War that was intended not to succeed in destroying
the Pope's Revived Latin Kingdom of Jerusalem (Israel) as the Third Temple must be built
with Jews in Jerusalem acting as a buffer between the Pope's Masonic Labor Zionist
leaders of Israel and resident Arab Muslim "Palestinians," the invasion will serve as the
justification for a US and possible EU military intervention during which time the Temple
Mount Mosques will be destroyed, and that destruction will be blamed on the U.S.A.
thereby inciting the unity of international Sunni Islam and its future invasion of U.S. soil.
Defendant Soros created an international securities fund for the “Country of Palestine”, in
141. Investigative journalist Aaron Klein, Jerusalem bureau chief for World Net Daily,
9
Rupert Murdoch is a Member: Council on Foreign Relations, Knights of St. Gregory, Owner: Fox
News Network and News Corp / Twentieth Century Fox, Friend of George Soros, Occult Protector of
Barack Hussein Obama Bill O’Reilly – The O’Reilly Factor and Glenn Beck
The International Crisis Group, or ICG, also released a report urging the Egyptian
regime to allow the Brotherhood to establish an Islamist political party.
The ICG includes on its board Mohamed ElBaradei, one of the main opposition
leaders in Egypt, as well as other personalities who champion dialogue with Hamas,
a violent offshoot of the Muslim Brotherhood.
The ICG report called on President Hosni Mubarak’s regime to “pave the way for the
regularization of the Muslim Brothers’ participation in political life,” including by
allowing for the “establishment of a political party with religious reference.”
The ICG specifically stressed allowing the Brotherhood to serve as an Islamist party
several times in its 2008 report.
The ICG and its personalities have long petitioned the Muslim Brotherhood to be
allowed to join the Egyptian government.
WND reported earlier this week Soros is one of eight members of the ICG executive
committee.
ElBaradei suspended his board membership in the ICG two weeks ago, after he
returned to Egypt to lead the anti-Mubarak protests.
U.S. board members include Zbigniew Brzezinski, who was national security adviser
to Jimmy Carter; Samuel Berger, who was Bill Clinton’s national security adviser;
and retired U.S. ambassador Thomas Pickering, who made headlines in 2009 after
meeting with Hamas leaders and calling for the U.S. to open ties to the Islamist
group.
Another ICG member is Robert Malley, a former adviser to Obama during the 2008
presidential campaign who resigned after it was exposed he had communicated with
Hamas. WND first reported Malley had long petitioned for dialogue with Hamas.
The ICG defines itself as an “independent, non-profit, multinational organization,
with 100 staff members on five continents, working through field-based analysis and
high-level advocacy to prevent and resolve deadly conflict.”
Soros’ Open Society also funded the main opposition voice in Tunisia, Radio Kalima,
which championed the riots there that led to the ouster of President Zine El Abidine
Ben Ali.
In September, Soros’ group was looking to expand its operations in Egypt by hiring a
new project manager for its Egyptian Initiative for Personal Rights, which is run in
partnership with the Open Society Justice Initiative. The group is seeking to develop
a national network of legal empowerment actors for referral of public-interest law
cases. Such organizations in the past have helped represent Muslim Brotherhood
leaders seeking election or more authority in the country.
Soros himself on Friday made public statements in support of the protests in Egypt,
which the Mubarak government has warned will result in the rise of the Muslim
Brotherhood in the country.
In a Washington Post editorial entitled, “Why Obama Has to Get Egypt Right,”
Soros recognized that if free elections were held in Egypt, “the Brotherhood is bound
to emerge as a major political force, though it is far from assured of a majority.”
He stated the U.S. has “much to gain by moving out in front and siding with the
public demand for dignity and democracy” in Egypt.
Soros did, however, single out Israel as “the main stumbling block” in paving the
way toward transition in the Middle East.
“In reality, Israel has as much to gain from the spread of democracy in the Middle
East as the United States has. But Israel is unlikely to recognize its own best
interests because the change is too sudden and carries too many risks,” he wrote.
142. Plaintiff repeats each and every allegation contained in the First through Sixth
Cause of Action paragraphs 1 through 141 with the same force and effect as though herein
Indonesia, Lebanon, Nigeria, Libya, Egypt, Dubai among other sovereign foreign entities
and persons have illegally contributed to the campaign of Defendant SOEBARKAH who
spent $738,812,857 to seize control of the White House and is 46% of the total money raised
for all candidates in the 2008 Presidential Election that compares to three hundred and ten
million spent by Defendant McCain; and as part of the scheme to defraud the Vatican Bank
was used as an intermediary for transfer of funds into its USA landing Banks in New York
that with the release of the banking records of the SOEBARKAH campaign committee will
show substantial illegal foreign involvement to launder funds to buy the presidency as
previously done in the instance of James Riady of the Indonesian Lippo Group for Bill
Clinton in 1992 was not convicted by the DOJ until January 11, 2001.
144. Defendants Penny S. Pritzker, George Soros and their agents bundled foreign
donations for the Soebarkah Campaign with the Vatican landing bank JP Morgan Chase in
10
There are three direct Vatican Banking mechanisms used to channel money into the
United States:
(i) The Vatican Bank number UID# 014780 BIC/SWIFT : IOPRVAVX a.k.a ISTITUTO PER
LE OPERE DI RELIGIONE of VATICAN CITY in the VATICAN CITY STATE and for which there
are seven (7) banking participants as the landing banks for international wire transfers into the
USA and who directly benefited by putting Obama into office: 0001 THE BANK OF NEW YORK
MELLON; 0002 JPMORGAN CHASE BANK, N.A.; 0008 CITIBANK, N.A.; 0103 DEUTSCHE
BANK TRUST CO AMERICAS; 0108 HSBC BANK USA; 0256 STANDARD CHARTERED BANK;
0509 WELLS FARGO NY INTL FKA WACHOVIA; needless to say the Vatican Bank and the
participating banks are generally owned by the Vatican through the Rothschild who have managed
the Vatican asset since 1824 and keep that control tightly within the family circle even as far back as
Alexander Hamilton who having married a Rothschild cousin setup the Bank of New York in 1784
that only after great effort became chartered after 1791 when he became the US Treasurer; and
(ii) further, the International Catholic Union of the Press (UCIP) is used for the World
Forum of Professionals and Institutions in Secular and Religious Media with the Address: UCIP, CP
197, 1211 Geneva 20, Switzerland and the Vatican name of the account holder: UCIP with the name
of the Bank: IOR, Vatican Swiftcode: IOPRVAVX Account number in Europe: 16586001
http://www.ucip.ch/une/ib.htm and in which the Vatican Interbank clearing account in the US is
with JPM CHASE MANHATTAN BANK NEW YORK Account no.: 001-1-97500; and
(iii) further yet, The Vatican Bank: ISTITUTO PER LE OPERE DI RELIGIONE =
INSTITUTE FOR THE RELIGION WORKS in which the Institute for Works of Religion (Italian:
State as a member of the CFR and high level Freemasonry and in conjunction with King
Juan Carlos (the King of Jerusalem) to create global regionalism that subsumes national
sovereignty of the USA and the People of New York state to the detriment of plaintiff and
146. Each of the Candidate Defendants and their agents have been unjustly enriched by
the referenced activities to disrupt the election without assuring a duly eligible Presidential
Candidates for the Republican, Democrat and Socialist Workers party under color of state
law, that violates Plaintiff’s and those similarly situated State voter right, imposing
expense as a taking as applies in its entirety with election costs levied upon real property.
147. That Defendant SOEBARKAH used campaign finance committees nationally and in
New York State according to records maintained by the Defendant NYS BOE include but
are not limited to: OBAMA FOR AMERICA by Martin H. Nesbitt (11), Treas. PO Box 8102
Chicago, IL 60680 ; OBAMA VICTORY FUND by Andrew Tobias, Treas. 430 South
Capitol Street SE Washington DC 20003; among others used exclusively in New York state;
and that Defendant Soebarkah conspired with Defendant Nancy Pelosi individually with
place of business located at Washington, D.C. Address 235 Cannon House Office Building
THE STATE OF NEW YORK located at 461 Park Avenue South New York, NY 10016 ,
located at 2-4 Nevins Street Floor 3 Brooklyn, NY 11217 and XYZ JOINT FUNDRAISING
Istituto per le Opere di Religione - IOR) commonly known as Vatican Bank was formed during World
War 2 and is located inside the Vatican City.
11 The Parking Spot: Ms. Pritzker is co-founder and chairman of The Parking Spot, an off-site
24th Street Phoenix, AZ 85016 used campaign finance committees nationally and in New
York state according to records maintained by the Defendant NYS BOE, and that include
but are not limited to the MCCAIN VICTORY 2008 located at 228 S WASHINGTON ST
STE 115 ALEXANDRIA, VA 22314; MCCAIN-PALIN VICTORY 2008 & The New York
Finance Committee Road to Victory Tour located at 228 S WASHINGTON ST STE 115
ALEXANDRIA, VA 22314, and that Defendant John Sidney McCain located at Campaign
Address 2211 East Camelback Road Phoenix, AZ 85016 and place of business at
Washington, D.C. Address 241 Russell Senate Office Building Washington, DC 20510,
conspired with Defendant John A. Boehner, individually along with THE NEW YORK
located at Frank MacKay, Chairman Independence Party of New York State PO BOX 871
NEW YORK STATE located at 486 78TH STREET BROOKLYN, NY 11209, and XYZ
JOINT FUNDRAISING COMMITTEES to use the funds associated with the campaign.
149. That Defendant Róger Calero, individually used campaign finance committees
nationally and in New York state according to records maintained by the Defendant NYS
BOE, and that include but are not limited to persons associated with THE SOCIALIST
WORKERS PARTY located at Committee Address: 1000 Grand Concourse, #4A Bronx, NY
XYZ JOINT FUNDRAISING COMMITTEES to use associated funds with the campaign.
150. That all the Defendants are liable having been culpable to jointly and severally aid
and abet soliciting and false billing of Defendant Presidential Candidate campaigns with
associated funds from the New York state taxpayers in the excess of say $10,000,000.00 or
a. Order of Injunction and restraint upon NYS BOE and various agents with
authority over the State political Parties and Presidential Candidates with
. entities presenting certification for ballot access process preparatory for the
various State party primaries and a t the November 6,2012 General Election to
Section 1Clause 5.
b. That all certification submissions duly approved by the NYS BOE and its agents
d. That the Court order expedited discovery to determine the scope of the alleged
$12,000,250.00 ,or more actual damages plus after conducting hearings and jury
e. And for further and different relief as the Court may deem necessary herein.
Accordingly, I, Christopher Earl Strunk,being duly sworn, depose and say under
penalty of perjury:
I have read the foregoing Complaint with seven Causes of Action against Defendants
Injunction with restraint of the NYS Board of Elections and its agents, and Declaratory
Judgment for equity relief a s well as for say $12,000,250.00in damages plus treble
damages determined a t a jury trial; and know the contents thereof apply to me by
misapplication and administration of laws in creation of the New York Electoral College
going into and following the General Election of November 4,2008a s a continuing injury
caused by the scheme to defraud with unjust enrichment that affects Plaintiff and
Plaintiffs AD HOC Brooklyn Home Rule Coalition along with those similarly situated; the
same is true to my own knowledge, except as to the matters therein stated to be alleged on
information and belief, and a s to those matters I believe it to be true. The grounds of my
beliefs as to all matters not stated upon information and belief are as follows: 3d parties,
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SUMMONS
VERIFIED COMPLAINT
Dated: March 22,2011
Brooklyn, New York
Christopher-Earl: Strunk, in esse plaintiff
593 Vanderbilt Avenue #281,
Brooklyn, New York 11238
(845) 901-6767 E-mail: chris@strunk.ws