1 1.

MEMORANDUM IN SUPPORT OF PLAINTIFF’S MOTION

2 FOR AN INJUNCTIVE RELIEF ORDER

3 1.1. Plaintiff Bryan T. Terry, Sr, [hereinafter “Plaintiff”] hereby offers

4 this memorandum in support of his motion for injunctive relief, to

5 demand performance of constitutional duties related to the Office

6 of Georgia State, Secretary of State by Karen C. Handel,

7 [hereinafter Defendant”].

8 1.2. Plaintiff’s complaint challenges the presidential candidate Mr.

9 Barack Obama’s eligibility to run for the Office of President and

10 demands that the Office of Secretary of State make such

11 determination by acquisition of original documentation or by

12 receipt of verifiable information from another government entity so

13 charged with overseeing the election process such as the Federal

14 Elections Commission.

15 1.3. Plaintive argues that when a challenge is received by the Secretary

16 of State for the State of Georgia to the qualification for office of a

17 candidate appearing on the Georgia State Ballot that the entire

18 burden of proof falls on the Candidate for Office to present such

19 information and documentation to the Secretary of State for the

20 State of Georgia as would be normal and customary to establish

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21 one’s minimum qualifications for office.

22 1.4. Plaintiff argues that the Office of Secretary of State has the

23 Constitutional and Statutory authority to make such determinations

24 as part of certifying and executing fair and open elections.

25 1.5. Plaintiff argues that is it only sufficient to show reasonable cause

26 for complaint to the Secretary of State for her Office to require

27 documentation of the respective candidate relevant to

28 determination of minimum qualification; that lacking explicit

29 statute defining the requisite documentation that the Secretary of

30 State has the intrinsic authority to set those reasonable standards

31 that would establish certain confidence in the people in the

32 electoral process.

33 1.6. Plaintiff seeks focused and expedited review, to protect the veracity

34 of the electoral process and maintain the people’s confidence in the

35 government.

36

37

38 2. COMPLAINT FOR INJUNCTIVE RELIEF - PRELIMINARY

39 STATEMENT

40 2.1. Article II, Section I of the United States Constitution, states in

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41 particular part, "No Person except a natural born citizen, or a

42 citizen of the United States at the time of the adoption of this

43 constitution, shall be eligible to the Office of President; neither

44 shall any person be eligible to that office who shall not have

45 attained to the age of thirty five years, and been fourteen years a

46 resident within the United States."

47 2.2. Mr. Barack H. Obama is a candidate for United States Office of the

48 President. However, Mr. Obama must meet the qualifications

49 specified for the United States Office of the President, which is, he

50 must be a "natural born" citizen. Mr. Obama has failed to

51 demonstrate that he is a "natural born" citizen. There are other legal

52 challenges before the Federal Courts regarding aspects of lost or

53 dual citizenship, in addition to legal challenges filed in other states.

54 That challenge in an of itself further demonstrates plaintiff’s

55 argument that reasonable doubt exists as to the veracity of the

56 electoral process that would allow such fundamental questions exist

57 at this late hour preceding the election.

58 2.3. The Georgia State office of Secretary of State is responsible for the

59 veracity of the Georgia State election process from verifying ahead

60 of time the qualification of the voters, the ballots themselves, the

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61 candidates and the final counting and certification of results. That

62 office is intended to be non-biased and to provide the critical sense

63 of fairness and correctness necessary for the people to have faith in

64 the fundamental underpinnings of the democratic basis for our

65 republic. Heretofore, Georgia Code, O.C.G.A § 21-2-50:

66 “(a) The Secretary of State shall exercise all the powers granted to

67 the Secretary of State by this chapter and shall perform all the

68 duties imposed by this chapter, which shall include the

69 following:

70 (2) To receive registration statements from political parties and

71 bodies and to determine their sufficiency prior to filing, in

72 accordance with this chapter, and to settle any disputes

73 concerning such statements;

74 (3) To receive and determine the sufficiency of nomination

75 petitions of candidates filing notice of their candidacy with the

76 Secretary of State in accordance with this chapter;”

77 Additionally, the Secretary of State is empowered to challenge the

78 qualifications of any candidate per Georgia Code, O.C.G.A § 21-2-5:

79 “(b) The Secretary of State upon his or her own motion may

80 challenge the qualifications of any candidate at any time prior

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 81 to the election of such candidate. Within two weeks after the

82 deadline for qualifying, any elector who is eligible to vote for a

83 candidate may challenge the qualifications of the candidate by

84 filing a written complaint with the Secretary of State giving the

85 reasons why the elector believes the candidate is not qualified

86 to seek and hold the public office for which he or she is

87 offering. Upon his or her own motion or upon a challenge being

88 filed, the Secretary of State shall notify the candidate in writing

89 that his or her qualifications are being challenged and the

90 reasons therefor and shall advise the candidate that he or she is

91 requesting a hearing on the matter before an administrative law

92 judge of the Office of State Administrative Hearings pursuant

93 to Article 2 of Chapter 13 of Title 50 and shall inform the

94 candidate of the date, time, and place of the hearing when such

95 information becomes available. The administrative law judge

96 shall report his or her findings to the Secretary of State.

97 (c) The Secretary of State shall determine if the candidate is

98 qualified to seek and hold the public office for which such

99 candidate is offering. If the Secretary of State determines that

100 the candidate is not qualified, the Secretary of State shall

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101 withhold the name of the candidate from the ballot or strike

102 such candidate's name from the ballot if the ballots have been

103 printed. If there is insufficient time to strike the candidate's

104 name or reprint the ballots, a prominent notice shall be placed at

105 each affected polling place advising voters of the

106 disqualification of the candidate and all votes cast for such

107 candidate shall be void and shall not be counted.”

108 2.4. There is a reasonable and common expectation by the people that to

109 qualify for the ballot that the individuals so listed meet the

110 minimum qualifications as outlined in the United States and

111 Georgia Constitutions and that proof of those minimum

112 qualifications has been received by the officials executing the

113 election process. Heretofore,

114 qualification for placement on ballot by the Office of Secretary of

115 State required only that a person be generally recognized as a

116 candidate for president by nomination by a political party or as

117 prescribed by the rules of a political party or by circulation of

118 petitions for nomination. Heretofore Georgia Code, O.C.G.A. § 21-

119 2-130 generally states,

120 “Candidates may qualify for an election by virtue of:

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121 (2) Filing a nomination petition either as an independent

122 candidate or as a nominee of a political body, if duly certified

123 by the chairperson and the secretary of the political body as

124 having been nominated in a duly constituted political body

125 convention as prescribed in Code Section 21-2-172;

126 and,

127 (4) In the case of an election for presidential electors,

128 nomination as prescribed by rules of a political party;”

129 and further, that general recognition is accomplished per Georgia Code,

130 O.C.G.A. § 21-2-132 which states:

131 “(a) The names of nominees of political parties nominated in a

132 primary and the names of nominees of political parties for the

133 office of presidential elector shall be placed on the election

134 ballot without their filing the notice of candidacy otherwise

135 required by this Code section.

136 (f) Each candidate required by this Code section to file a notice of

137 candidacy shall accompany his or her notice of candidacy with

138 an affidavit stating:

139 (7) That he or she is eligible to hold such office; and,

140 (9) That he or she will not knowingly violate this chapter or

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141 rules and regulations adopted under this chapter; and

142 (10) Any other information as may be determined by the

143 Secretary of State to be necessary to comply with federal and

144 state law.”

145 A search of the Elections statutes under the Georgia Code fails to

146 indicate any method by which the Secretary of State is to validate

147 or receive any of the criteria as enumerated within United States

148 Constitution, Article 2, Section 1,

149 "No person except a natural born Citizen, or a Citizen of the

150 United States, at the time of the Adoption of this Constitution,

151 shall be eligible to the Office of President; neither shall any

152 Person be eligible to that Office who shall not have attained to

153 the Age of thirty-five Years, and been fourteen Years a

154 Resident within the United States."

155 This practice, it should be noted, represents a much lower standard

156 than that demanded of one when requesting even a driver’s license.

157 Since the office of Secretary of State has at its core the mission of

158 certifying and establishing the veracity of the election process, this

159 complaint seeks a directive to the Georgia State Office of Secretary

160 of State to receive appropriate verifiable documentation and certify

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161 any individual’s qualification for Office whose basic credentials for

162 that Office have been challenged by formal request to the Office of

163 Secretary of State from a citizen of the State of Georgia.

164 2.5. In the case of individuals seeking the Office of President of the

165 United States, the US constitution prescribes a system of electors

166 where citizens of the respective state have a state controlled election

167 wherein electors representing the interest of the named individual on

168 the state ballot are so elected to represent the interests of the

169 respective state at the electoral college. Thus, we do not have a

170 federal ballot controlled by the federal government; we have a

171 Georgia State ballot where we elect electors who in turn represent

172 the named individual on the ballot. That is one more reason that the

173 Georgia Secretary of State has purview over the certification of not

174 just the counts of the ballots so cast, but also the veracity of the

175 contents of the ballot. Georgia Code O.C.G.A § 21-2-5 states:

176 “(a) Every candidate for federal and state office who is certified

177 by the state executive committee of a political party or who

178 files a notice of candidacy shall meet the constitutional and

179 statutory qualifications for holding the office being sought.”

180 2.6. This complaint of failure to carry out a key task in our election

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181 system could be satisfied should verification of candidate

182 qualifications be received from original or certified documents

183 from primary sources or from a verifiable report generated from

184 government agencies such as the Federal Elections Commission. It

185 is the Georgia State, Secretary of State’s duty to certify the veracity

186 of documents or reports so received.

187 2.7. To avert likely civil unrest and a constitutional crisis which would

188 certainly accrue after the election through laborious legal

189 challenges and impeachment process, this complaint seeks to

190 resolve such complaints prior to the election. It was incumbent on

191 the candidates to present such documentation, but to date Mr.

192 Obama has failed to do so.

193 2.8. This complaint seeks specifically to verify through the office of the

194 Georgia Secretary of State that Mr. Obama is a "natural born"

195 citizen.

196 2.9. At this point, Mr. Obama has not allowed independent or official

197 access to his birth records and supporting hospital records. Mr.

198 Obama’s citizenship status has and is being challenged in the

199 federal courts which challenge will cast doubt on the veracity of the

200 electoral system regardless of outcome if not resolved prior to the

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201 election. The Georgia State, Secretary of State Office is specifically

202 charged with certifying and guaranteeing the veracity of official

203 documents and overseeing the elections to wit the people’s

204 confidence in the fundamental aspect of democracy is maintained.

205 To date, in this regard, Secretary of State Karen Handel has not

206 carried out that fundamental duty.

207 2.10. The Federal Elections Commission FEC is generally

208 tasked with providing oversight and verifications of federal

209 candidates. To date the FEC has not produced either certification or

210 verifiable documentation regarding the candidate’s basic

211 qualifications for office. Lacking that certification from the FEC,

212 this complaint requests the Georgia State - Secretary of State Karen

213 Handel to formally request of Hawaii State Health Department

214 officials to produce forthwith a certified copy of his “Vault”

215 [original long version] Birth Certificate.

216 2.11. This complaint requests that Georgia State - Secretary of

217 State Karen Handel formally requests primary backup materials if

218 they exist of hospital records that would lend veracity to a Hawaii

219 live birth declaration. A court order of discovery is requested to

220 assist that investigation directed to the respective hospital if so

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221 identified on a live birth certificate.

222 2.12. Should Mr. Obama be discovered, whether by virtue of

223 malfeasance, or negligence, or ignorance on his part to not have a

224 valid certified US birth certificate or to otherwise due to have been

225 revealed by such examination of original records to be ineligible

226 for the Office of President of the United States of America and

227 thereby his nomination be declared void by the appropriate

228 authorities acting under the law, Plaintiff as well as other

229 Americans will suffer irreparable harm including but not limited to:

230 2.12.1. Functional, or actual, disenfranchisement of

231 large numbers of citizens, being members of the Democratic

232 Party, who would have been deprived of the ability to choose

233 a qualified nominee of their liking;

234 2.12.2. Irreparable harm to the structure and integrity of

235 the Democratic Party and the Democratic National

236 Committee. In turn, this too would lead to

237 disenfranchisement.

238 2.12.3. If the candidate Mr. Obama were to secure the

239 election and later be discovered ineligible, the resulting

240 constitutional and national security crisis that would ensue

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241 would generate a severe and genuine likelihood of civil

242 disturbance by virtue of reaction to said disenfranchisement

243 and upset.

244 2.13. It was well expected that after all the public concern that

245 has been raised over the preceding months now that Mr. Obama

246 would have released for public or official scrutiny the relevant

247 documentation to back up his claim of qualification as a “natural

248 born citizen”. His reaction to public concern and his recent actions

249 in Federal District Court 9/24/2008 demonstrate that Mr. Obama

250 has no intentions of releasing said documentation for review or

251 cannot because they do not exist. The late hour of this request was

252 dictated by the delaying tactics of the candidate Mr. Obama, and

253 the lack of Georgia Elections Code statutorily mandated

254 verification of candidate credentialing materials.

255

256 3. JURISDICTION AND VENUE

257 3.1. As we do not have federal ballot per se, Georgia State, through the

258 office of the Georgia State, Secretary of State creates its own ballot

259 and supervises the same, electing electors to represent our choice

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260 for the Office of President. This case arises under the Georgia

261 Constitution, Article II and the Georgia Code O.C.G.A., Title 21,

262 “Elections”, Chapter 2, “Elections and Primaries Generally”, and

263 the laws of the United States and presents a state question within

264 this Court's jurisdiction.

265

266 4. PARTIES

267 4.1. Plaintiff, Bryan T. Terry, Sr. [hereinafter "Plaintiff'], is an adult

268 individual with a home address of 613 Mead St., SE, Atlanta, GA

269 30312. Citizen USA.

270 4.2. Defendant, Karen C. Handel is an adult individual with an office

271 address of 214 State Capitol, Atlanta, GA 30334. Georgia State,

272 Secretary of State.

273
274

275 5. FACTUAL ALLEGATIONS THAT DEMOSTRATE THE NEED

276 TO PROOF THE CANDIDATE’S MINIMUM

277 CONSTITUTIONAL QUALIFICATION.

278 5.1. These allegations and statements are not intended to be proof of the

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279 status of Mr. Obama’s citizenship or lack thereof. That will be

280 determined in the venue of the US District court. The listing of the

281 allegations detailed below are included to demonstrate the

282 reasonable assertion of the need for the Georgia State, Secretary of

283 State to reestablish public confidence in the veracity of the

284 electoral process and the obvious need for precertification as to a

285 candidate’s meeting the minimum constitutional requirements.

286 5.2. By the U.S. Constitution, in order to run for office of the President,

287 you must be a "natural born citizen" and you may not hold dual

288 citizenship or multiple citizenships with foreign countries. U.S.

289 Constitution, Article II, Section 1.

290 5.3. There are questions as to where Obama was actually born; in the

291 United States or abroad but subsequently registered in Hawaii.

292 There are further questions regarding Obama's United States

293 citizenship, if he ever held such, being expatriated and his failure to

294 regain his citizenship by taking the oath of allegiance once he

295 turned eighteen (18) years of age. There are additional questions

296 regarding Obama's multi-citizenships with foreign countries, which

297 he may still maintain. To date, Obama has refused to prove he is

298 qualified under the U.S. Constitution and his eligibility to run as

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299 President of the United States despite requests and recent

300 opportunities to do so in Federal Court.

301 5.4. The "certificate" that Mr. Obama has posted on his official WEB

302 site is a "Certification of Live Birth," and not a “Birth Certificate”

303 from Hawaii. There is no indication on even this certificate as to

304 specifically where the birth took place.

305 5.5. Researchers have claimed to have been unable to locate any birthing

306 records in island hospitals for Barak Obama’s mother. Mr. Obama

307 has offered none for review.

308 5.6. Three forensic document experts have published extensive reports

309 claiming that there is evidence of tampering on even the Obama

310 WEB site displayed certificate.

311 5.7. Numerous Freedom of Information Requests have been sent to

312 Officials in Hawaii with no response from the public officials nor

313 has Mr. Obama granted access for release of the information

314 lending to the concern over the veracity of the attestation on the

315 candidate’s application for candidacy for the office of President of

316 the United States.

317 5.8. The facts are undisputed by Obama that his mother, Stanley Ann

318 Dunham, was a U.S. citizen however, his father, Barack Obama,

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319 Sr., was a citizen of Kenya. Obama's parents, according to divorce

320 records, were married on or about February 2, 1961.

321 5.9. Obama claims he was born in Honolulu, Hawaii on August 4, 1961;

322 however, has never given the name of the hospital he was born in;

323 whereas there are reports that Obama's grandmother on his father's

324 side, half brother and half sister claim Mr. Barack H. Obama was

325 born in Kenya. Reports further reflect that Mr. Obama's mother

326 went to Kenya during her pregnancy. Wayne Madsen, Journalist

327 with ”Online Journal” as a contributing writer and published an

328 article on June 9, 2008 stating that a research team went to

329 Mombassa, Kenya, and located a Certificate Registering the birth

330 of Barack Obama, Jr. at a Kenya Maternity Hospital, to his father, a

331 Kenyan citizen and his mother, a U.S. citizen. There are claims of

332 records of a "registry of birth" for Obama, on or about August 8,

333 1961 in the public records office in Hawaii, but these have not been

334 released for scrutiny. It is alleged in the Federal trial and is a matter

335 of much general speculation that Mr. Obama’s mother was

336 prevented from boarding a flight from Kenya to Hawaii at her late

337 stage of pregnancy, which apparently was a normal restriction to

338 avoid births during a flight. It is likely that Stanley Ann Dunham

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339 (Obama) gave birth to Obama in Kenya, after which she flew to

340 Hawaii and registered Obama's birth.

341 5.10. Regarding the alleged birth of Barack Hussein Obama in

342 Honolulu, Hawaii, it is variously circulated that Obama's birth is

343 reported as occurring at two (2) separate hospitals, Kapiolani

344 Hospital and Queens Hospital. Obama has provided no proof of

345 birth from of either of these or any other US based facility. He has

346 made no effort to address these public concerns.

347 5.11. There are no published or known hospital birthing records

348 for Stanley Ann Dunham (Obama), Obama's mother. There are

349 only claims of records of a "registry of birth" for Obama, on or

350 about August 8, 1961 in the public records office in Hawaii.

351 5.12. There is even a Canadian Birth Certificate posted on the

352 Internet in the name of Barack Hussein Obama, Jr.; however, the

353 date of birth shows to be August 23, 1961

354 5.13. At the time of Obama's birth in 1961, Kenya was a British

355 Colony. Subsequently, under the Independence Constitution of

356 Kenya, Mr. Barack H. Obama became a Kenyan citizen on

357 December 12, 1963. There are no indications or reports that Mr.

358 Obama ever renounced that dual citizenship conferred either by

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359 nature of birth or by virtue of his father’s Kenyan citizenship. On

360 Mr. Obama’s Senate web site, Mr. Obama acknowledges his father

361 holds Kenyan nationality but avoids addressing that that he (Mr.

362 Obama) also held/holds Kenyan nationality.

363 5.14. If in fact Obama was born in Kenya, the laws on the

364 books in the United States at the time of his birth stated if a child is

365 born abroad and one parent was a U.S. Citizen, which would have

366 been his mother, Stanley Ann Dunham, Obama's mother would

367 have had to live ten (10) years in the United States, five (5) of

368 which were after the age of fourteen (14). At the time of Obama's

369 birth, his mother was only eighteen (18) and therefore did not meet

370 the residency requirements under the law to give her son (Obama)

371 U.S. Citizenship much less the status of “natural born.” The laws in

372 effect at the time of Obama's birth prevented U.S. Citizenship at

373 birth of children born abroad to a U.S. Citizen parent and a non-

374 citizen parent, if the citizen parent was under the age of nineteen

375 (19) at the time of the birth of the child. Obama's mother did not

376 qualify under the law on the books to register Obama as a "natural

377 born" citizen. Section 301(a)(7) of the Immigration and Nationality

378 Act of June 27,1952,66 Stat. 163, 235, 8 U.S.C. §1401(b), Matter

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379 of S-F-and G-, 2 I & N Dec. 182 (B.I.A.) approved (Att'y Gen.

380 1944). Obama would have only been Naturalized and a Naturalized

381 citizen is not qualified nor eligible to run for Office of the

382 President. U.S. Constitution, Article II, Section Clause 4.

383 5.15. Furthermore, if Obama had been born in Kenya, his birth

384 father Barack Obama, Sr. was a citizen of Kenya; therefore, Obama

385 would have automatically become a citizen of Kenya.

386 5.16. The Nationality Act of 1940 provided for the loss of

387 citizenship when the person became naturalized upon the

388 naturalization of his or her parent having custody of such person.

389 Obama's mother expatriated her U.S. Citizenship when she married

390 Lolo Soetoro, a citizen of Indonesia and relocated herself and her

391 son (Obama) to Indonesia.

392 5.17. Obama was enrolled by his parents in a public school,

393 Fransiskus Assisi School in Jakarta, Indonesia. Plaintiff has

394 available copies of the school registration where it clearly states

395 Obama's name as Barry Soetoro and lists his citizenship as

396 Indonesian, Obama's father is listed as Lolo Soetoro, Obama's date

397 of birth and place of birth are listed as August 4,1961 in Honolulu

398 and Obama's Religion is listed as Islam. This document was

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399 verified by television show Inside Edition, whose reporter, Matt

400 Meagher took the actual footage of the school record.

401 5.18. In or about 1971, Obama's mother sent Obama back to

402 Hawaii. Obama was ten (10) years of age upon his return to

403 Hawaii.

404 5.19. Sometime after the return of Obama to Hawaii, Obama's

405 mother, Stanley Ann Dunham returned to Hawaii and divorced her

406 husband, Lolo Soetoro. At the time of divorce, Obama's mother,

407 Stanley Ann Dunham could have regained her U.S. citizenship. In

408 order to regain her citizenship, Obama's mother would have had to

409 take the oath of allegiance required. Such oath of allegiance may be

410 taken abroad before a diplomatic or consular of the United States,

411 or in the United States before the Attorney General or the judge or

412 clerk of a court. Such Oath of Allegiance would have been entered

413 in the records of the appropriate embassy, legation, consulate, court

414 or the Attorney General and upon demand, a certified copy of the

415 proceedings, including a copy of the oath administered, under the

416 seal of the embassy, legation, consulate, court or the Attorney

417 General shall be delivered. The certified copy shall be evidence of

418 the facts stated therein before any court of record or judicial

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419 tribunal and in any department or agency of the Government of the

420 United States. 8U.S.c.§1435.

421 5.20. Obama's mother failed to take the oath in order to regain

422 her U.S. Citizenship. Therefore, Obama would not have been able

423 to regain his U.S. Citizenship until he turned eighteen (18) years

424 and then only after he took the Oath of Allegiance before a

425 diplomatic or consular officer of the United States, or in the U.S.

426 before the Attorney General or the judge or clerk of court. Since

427 the Oath of Allegiance would have been entered in the records of

428 the appropriate embassy, legation, consulate, court or the Attorney

429 General, then Obama should be able to produce in court a certified

430 copy of the proceedings, including a copy of the oath administered.

431 No such copy has been to date produced for public examination.

432 5.21. After many attempts of the public to obtain Obama's

433 Certificate of Birth, a Hawaiian Certificate of Live Birth (COLB)

434 was placed on Obama's campaign website. However, as posted all

435 over the internet, three (3) independent Document Forensic Experts

436 performed extensive forensic testing on the Certificate of Live

437 Birth as posted on Obama's campaign website. The Forensic Expert

438 findings were that the posted Certificate of Live Birth (COLB) was

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439 a forgery. It was further discovered that the posted COLB had

440 evidence of having been created from an altered/forged from a

441 COLB issued to Maya Kasandra Soetoro, born in 1970. Maya

442 Kasandra Soetoro is Obama's half sister who was born in Indonesia

443 and her birth was later registered in Hawaii. The altered and

444 allegedly forged COLB is still on Obama's website located at

445 http://my.barackobama.com/page/invite/birthcert

446 5.22. Even if Obama had and subsequently maintained his

447 United States Citizenship, which citizenship he has failed before

448 District Court to demonstrate, he may still carry citizenships in

449 Kenya and/or Indonesia. These facts call into question what the

450 constitution attempted to address regarding potently divided

451 loyalties with foreign countries. Thus, Mr. Obama carries multiple

452 citizenships and would be ineligible to run for President of the

453 United States. United States Constitution, Article II, Section 1.

454
455

456 6. Failure to grant injunctive relief will realize these detriments:

457 6.1. Failing to officially and publically vet the status of the citizenship

458 claims of Mr. Obama will cast a pall of doubt on the election

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459 process and taint the election results themselves.

460 6.2. Failure to grant injunctive relief would allow a potentially

461 corrupted, fraudulent nomination and election process to continue.

462 6.3. Failure to grant injunctive relief demanding the Georgia State,

463 Secretary of State certify the minimum qualifications of challenged

464 candidates not only allows, but promotes an overwhelming degree

465 of disrespect and creates such a lack of confidence in voters of the

466 primary and electoral process itself, so that it would cement a

467 prevailing belief that no potential candidate has to obey the laws of

468 this country, respect our election process, follow the Constitution,

469 or even suffer any consequence for lying and defrauding voters to

470 get onto the ballot when they have no chance of serving if they

471 fraudulently manage to get elected.

472 6.4. As stated above, Plaintiff as well as all American citizens will suffer

473 irreparable harm if injunctive relief is not granted. Plaintiff does

474 not have any other way of redress regarding these very significant

475 and important issues.

476 6.5. Despite many complaints, the FEC has failed Plaintiff and the

477 American citizens by their failure to date to perform due diligence

478 and inquire into Mr. Obama's eligibility to run for Office of the

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479 President. Lacking such certification, it is incumbent on the

480 Georgia State, Secretary of State to certify or decertify as to the

481 eligibility for office before the election based on the availability of

482 clear documentation demonstrating that minimum qualifications for

483 the respective office has been met by candidates.

484
485

486 7. WHEREFORE, Plaintiff respectfully prays that this Court:

487 7.1. Grant injunctive relief demanding that Georgia State, Secretary of

488 State Karen Handel immediately acquire primary documents or

489 certified copies from primary sources such as Health Department

490 and hospital records or verifiable reports regarding same from the

491 FEC.

492 7.2. Plaintiff requests Georgia State, Secretary of State Karen Handel to

493 immediately demand such verifiable report from the FEC or

494 demand a certified copy of Obama’s Certificate of Live Birth and

495 subpoena as needed for the release hospital records if so claimed on

496 said Live Birth Certificate to further prove he was born in Hawaii

497 as Mr. Obama claims.

498 7.3. Direct Georgia State, Secretary of State Karen Handel to certify or

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499 decertify the challenged candidates prior to the election based on

500 the availability of clear documentation.

501 7.4. Plaintiff requests the Georgia State, Secretary of State Karen

502 Handel to immediately demand a certified copy of Obama’s Oath

503 of Allegiance proving he regained his United States Citizenship.

504 7.5. If Secretary of State Karen Handel is unable to document a certified

505 record of Obama’s oath of allegiance and birth and hospital

506 records, Secretary of State Karen Handel must decertify Mr.

507 Obama as a valid candidate for the office of President of the United

508 States Office of the President under the United States Constitution,

509 Article II, Section I;

510 7.6. Award Plaintiff such costs and fees applicable by law; and further

511 relief as the Court deems just and proper.

512

513 Respectfully Submitted,

514

515 Bryan T. Terry, Sr.

516 613 Mead St., SE, Atlanta, GA 30312

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517 404-627-7101

518

519 VERIFICATION

520 I, BRYAN THOMAS TERRY, SR., hereby state that I am the Plaintiff in

521 this action and verify that the statements made in the foregoing Complaint

522 for Injunctive Relief are true and correct to the best of my knowledge,

523 information and belief. The undersigned understands that the statements

524 therein are made subject to the penalties law relating to unsworn falsification

525 to authorities.

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