In response to a comment on a blog, I contacted one of the attorneys involved in a court case seeking to determine whether BO is a NBC.  I received a reply asking for help.  Here is my response.


I am glad you took me up on my offer to help.

I haven’t formalized my ideas, so I will just throw these out for now.

Okay, let’s talk Plaintiffs, first.  (FYI, I am the person who conceived using National Guard soon-to-be-deployed, as Plaintiffs to gain standing in federal court in a Declaratory Judgment case under the Federal Declaratory Judgment Act – these Plaintiffs are not subject to the Uniform Code of Military Justice until they are federalized – because they could be subject to becoming Defendants in a subsequent prosecution related to whether BO is a NBC…  I am the same person who began posting last summer that a “Certification” is not a “Certificate”; unfortunately, this was right after Berg had already filed his first Complaint, calling the document posted on BO’s “Fight the Smears” site, a “Certificate.”)

Pledged Delegates for HRC who switched to BO; or who were pledged to BO in the first place, and voted for him at the DNC Convention, but would not have voted for him had they known, he is not a NBC, would have standing as Plaintiffs in a civil action for (fraud, unjust enrichment…).  ESPECIALLY DESIRABLE ARE PLEDGED DELEGATES FROM THOSE STATES THAT HAVE ENACTED LAWS REQUIRING DELEGATES PLEDGED AS THE RESULT OF PRIMARY VOTING MUST FOLLOW THEIR CANDIDATES ONTO THE FLOOR OF THE CONVENTION.  (There are around 13 of these ‘binding vote’ states; I have the list.)  And some of these vote binding states also have laws about ballot access, that require the candidate for POTUS from the major political party must be eligible for the job.  (None of these states requires any government official to check.)  Off the top of my head, I know GA is both a vote binding state AND a state requiring the party candidate to be eligible for the job.

As for strategy… Months ago, when drafting the Declaratory Judgment case I mentioned above, I reasoned, it made no sense to try to support a claim, BO is not a NBC.   Instead, I argued, Plaintiffs had reasonable cause to believe, he might not be a NBC, based in large part on his own words and actions.  But since that time, things have changed, especially with regard to these 4 (four) events.  1) Several people have contacted Nancy Pelosi qua Chair of the 2008 DNC Convention to ask on what basis she Certified BO is a NBC.  She refused to respond.  2) HI officials have spoken in circles in a botched attempt to ‘confirm’ BO is a NBC.  3) BO, personally (before being sworn in) and through his spokespeople, continue to dodge the issue by lying that the Certification is a Certificate and proves he is a NBC.  4) In Berg’s Hollister case, BO Motion to Dismiss contained a footnote asking the court to take judicial notice that Annenberg Political Fact Check said he’s for real; and that an announcement of his birth had been published in a HI newspaper.  (Of course, if the judge had taken judicial notice, we lawyers would have known, this meant nothing; but everyone else would have interpreted this to mean, the court has ruled, he is a NBC.  Thank goodness, the court did no such thing.  However, this confirmed my suspicions, as spelled out in the earlier draft of the military Complaint, that the strongest ‘evidence’ BO could proffer to establish he is a NBC, is that stupid photocopied on-line Certification; which means nothing!) Taken together, this could form a good faith belief in a reasonable person that no evidence exists that would establish, BO is a NBC.  SHIFT THE BURDEN OF PROOF AND PRODUCTION TO HIM!  And as for objections to this strategy, argue “unclean hands” (you blocked access to all documentation and now cannot argue, we cannot submit proof); or unjust enrichment (you distributed the COLB to Daily Kos and Annenberg Political Fact Check in order to refute “rumors” about your citizenship status – you said so, on your “Fight the Smears” site – and now, having banked on that COLB, it isn’t fair to raise privilege and confidentiality to block our access to those records that could verify whether your claims are true).

Finally, to overcome claims of sovereign immunity, I would drop all claims against conduct that occurred viz a viz the Congressional ratification of the EC vote; rather, go after NP as Chair of the 2008 DNC Convention.  Go after any other actors not as failed Congresspeople but as co-conspirators to the fraud.

I know this is a lot to digest; let me know what you think.  (I am not going to proof this because I want to get it out ASAP.)



  1. renee says:

    Wow ! It is good jbjd ! As usual,of course !

    renee: Thank you. Please, pass this around. This could give other attorneys, or pledged delegates, or ‘citizens-who-are-mad-as-hell-and-are-not-going-to-take-this-anymore,’ some ideas. ADMINISTRATOR

  2. drkate says:

    Excellent, jbjd. I see your point and Apuzzo’s on Pelosi and Cheney…on standing, it is murky as we all know but it seems Kerchner’s military status is a plus?

    drkate: Thank you. Actually, Kerchner is the wrong Plaintiff and makes more likely the case will be dismissed. See, ‘it’s already been done.’ Right after I posted my template for the military Complaint last December, proposing as Plaintiffs military subject to recall – I had envisioned using National Guard but, Orly Taitz told me she would file this Complaint for specific people already signed on – Phil Berg filed a case using the same basic idea, in Hollister. Only, Hollister was retired military. There was no way he would get called up again; and the Defendants successfully argued this point to the court. Using military for standing requires this set of facts: 1) the military is subject to recall; 2) the military has a good faith question as to whether BO is a NBC; and 3) these concerns could result in Plaintiff in this action becoming a Defendant in a subsequent action based on this uncertainty. (I am oversimplifying.) This means, if Plaintiff is not in any real danger of becoming a Defendant in a subsequent proceeding (for actions taken based on his confusion as to BO’s NBC status) then, there is no case or controversy before the court. The federal court cannot be used to issue an advisory opinion. ADMINISTRATOR

  3. Mick says:

    Unfortunately Orly totally mishandled her case with the reserve officer. He should have never asked to be deployed, that gave the Federal Government the perfect out, just rescind his deployment. It should have been a Declaratory judgement case about a what if he was Federalized scenario or an actual National Guard officer that was in fact Federalized by command, not by volunteering.

    Mick: Cook was fatally flawed from the beginning. 1. WRONG CAUSE OF ACTION. Orly based her Complaint in Cook I on a cause of action that would not have reached the issue of whether BO is a NBC but would only result in a ruling as to whether her client can be Declared a conscientious objector, seeking to carve out a new category of conscientious objector as anyone who (establishes by a preponderance of the evidence that he) conscientiously believes his CIC has no lawful right to issue orders because he is not a NBC. The federal court has no Constitutional right to hear a ‘Complaint’ asking for an advisory opinion.

    2. WRONG PLAINTIFF (S). Orly chose a Plaintiff in Cook I who was in no real danger of being deployed against his will, since as a member of the army reserve not attached to a unit a) he volunteered for deployment (in May), specifically requesting to be sent to Afghanistan; and b) he retained the right to withdraw his request to be called up for duty, up to the day of deployment. The army notified him in June in accordance with his request, he would be deployed to Afghanistan and should report for duty on July 16. In her pleadings, which she served on the army – I don’t know the date of service but, she filed with the courts on July 8 and served the army after that – she gave constructive notice to the army that her client withdrew his request for deployment. (The ‘money’ quote is on p. 16: “A man who doubts his commander-in-chief cannot be a good soldier…”) The army granted his request to rescind deployment orders. This meant, the issue was now “moot.” The federal court only has the Constitutional right to hear a “case” or “controversy.”

    That’s just for starters. She only made things worse when she added 2 (two) more Plaintiffs, Major General Childers and Lieutenant Colonel Earl-Graef in a botched attempt to survive Defendant’s (army) Motion to Dismiss for mootness. Turns out, months ago Childers had signed one of Orly’s Releases (for representation) assuming she was bringing a case to unseal BO’s records. Evidently, she did not check with him before adding his name as a Plaintiff in this Declaratory Judgment (Conscientious Objector) case. Childers would have been kicked out as a Plaintiff, anyway, because he was Retired and old and thus, not subject to recall. (Having been through this with Orly months ago, I know that she used these men because she assumed their ranks added gravitas to her case, notwithstanding my objections that the court would throw out any Plaintiff not subject to recall, due to age or infirmity. Back then, she told me, ‘Let Defendant argue the Plaintiff is too old.’ Right after that, Berg filed a case which was kicked for the same reason, wrong Plaintiff. (I think this was in Hollister.)) Plus, since the original Cook case was about Declaring Cook a Conscientious Objector, adding Childers and Earl-Graef meant, she was asking the Court to Declare, these 2 (two) men are also seeking a Declaration as Conscientious Objectors based on their beliefs, BO is not legally the CIC.

    In sum, both Cook I and Cook II were fatally flawed from their drafting. ADMINISTRATOR

  4. Ladyhawkke says:

    Excellent jb, I have nothing to add as you have covered all the bases. I hope that someone runs with this. I faxed Nancy Pelosi, as well as Alice Germond, Co-Chair of the DNC, demanding the documentation they used to verify that Obama was constitutionally qualified. Their arrogance in not responding proves their mindset that they are above the law. I ask that we continue to bombard both of their offices with letters, faxes and phone calls. Hold them accountable!

    Ladyhawkke: Hello, my friend! Thank you for the compliment. You know, if I had not been working so hard on these issues throughout the campaign cycle, I could not have come up with this solution at this time. At some point, I will need all those of you who have contacted these DNC officials in vain, to forward the record of such contact. (I do not mean your efforts are in vain insofar as your activism is inspiring; and no answer, in this case, IS an answer. It just is not an answer to the question asked, which is, on what basis did you Certify BO is eligible for the job.) But it appears plain to me that, even in those states that require the candidate for POTUS from the major political party to be eligible for the job, no one has yet been able to ascertain on what basis the DNC Certified such eligibility! Soon we are going to have to shift the focus away from filing court challenges to BO’s Presidency; to amending state election laws. (Geesh, I suppose that means, I am going to have to start posting model legislation!) ADMINISTRATOR

  5. azgo says:

    Would Tommy Vietor qualify as a co-conspirator in your ideas. He is now ‘a spokesman’ in the Whitehouse to Mr. Obama. This 27 year old has been the clean up guy for the Obama campaign and now for the Whitehouse, if he answers your phone calls.

    “The “secrecy” ended when Tommy Vietor at the Obama campaign sent a message to us and other reporters saying, “I know there have been some rumors spreading about Obama’s citizenship, so I wanted to make sure you all had a copy of his birth certificate.” A digital image was attached.”
    According to Brooks Jackson, director of, “We were told that Obama requested it when he first prepared to run. Our contact in the campaign was Tommy Vietor, who is now on the White House staff. If you want to see the thing for yourself, he’s the first guy I would call.”…

    ” It would be good to know where Tommy Vietor got Obama’s COLB. If it was given to him by Barack Obama, then there must have been a request form filled out and signed by Barack Obama, and on file with the Hawaii Department of Health, that is a “State of Hawaii Department of Health Request for Certified Copy of Birth Record.” My call to Tommy Vietor about this matter remains unanswered.”
    Yesterday, WND e-mailed a request to Obama spokesman Tommy Vietor, asking that the White House release Obama’s law school records to resolve the issue.

    During the 2008 presidential campaign, Vietor was a frequent spokesman for the Obama campaign’s “Fight the Smears” website, which has been removed from the Internet.

    WND received no response from Vietor or from the White House press office, which was copied on the e-mail.

    azgo: Thank you for providing such interesting information; I was unaware of any of this.

    Perhaps you misunderstood the point in my posted email to the attorney. One of the problems I find common to many of these lawsuits attempting to get to the question of whether BO is a NBC; is that Plaintiffs name as Defendants people who are protected from lawsuits for work-related conduct by the principle of sovereign immunity. For example, people name Nancy Pelosi qua Speaker of the House, a position which provides her with sovereign immunity. Rather, I propose if they want to sue her, address her capacity as Chair of the 2008 DNC Convention. After all, her signature is on the Certification of Nomination that went to each state in order to get BO’s name printed on the general election ballot. (In HI, per their state law, a line was added to that Certification saying BO was also eligible for the job.) So, given that Congress is protected from civil suits by the principle of sovereign immunity, I tried to find a way these litigants could try to hold responsible any of those government officials they felt had participated in conduct which elevated BO into office, conduct which, in the eyes of the Plaintiff, makes them suitably named Defendants. I came up with a joint venture theory of liability. That is, NP qua Chair of the Convention, a ‘civilian’ position, IS vulnerable to suit; and, to the extent any of these Congresspeople were Super Delegates or, in any other way had a significant role in installing BO as the party nominee, they could thus be brought in as co-conspirators.

    Now, the information about his campaign’s distribution of the COLB, if true, would appear to provide additional evidence in support of my legal argument that, having distributed the document to non-governmental entities to obtain from them a seal of authenticity, for the specific purpose of responding to public concerns as to his citizenship; he is now estopped from asserting rights to privacy so as to bar the public’s access to these documents by citizens who want to confirm for themselves, these are for real. ADMINISTRATOR

  6. Hello,

    I read your thoughts regarding the EC members being defrauded. I wish I had a law degree…it sounds good, if that is any encouragement.

    If QW will not be pursued by the respective AGs than it will most likely take a case that involves a civil matter…that would eventually have to go to the USSC for determination of the merits (NBC). Good luck and great epiphany.


    Noz: I wrote a long response to your other note but, I realized I forgot something. I believe there is ample evidence in SCOTUS decisions to establish, given a specific set of facts, even a lower federal court can decisively rule as to whether BO is a NBC. I will be writing more on that later. ADMINISTRATOR

  7. Val says:


    Great job! … As always!

    Val: Hey, nice to see you over here! Thanks for the compliment. ADMINISTRATOR

  8. jbjd,

    My recent epiphany (albeit sans law degree) involved the process by which we held the AGs accountable for at least investigating the merits of a federal office holder unqualified to hold their position;

    1. Submit researched, evidenced, reasoned request to respective AG with stated expectation for reply analysis as to the merits of the matter.

    2. Sue the SOBs for failure to respond, investigate, or provide analysis to citizen(s) request.

    Some research is required as to the regulations, laws, mandates, oaths, etc. that command the AG office.

    I think it presumptive to sue initially for lack of pursueing QW…start small and see what happens.


    Noz: Hello, again. No, this does not have to go to QW. The courts are not the only venue for redress of grievances of these issues. Each of us is a citizen of a state. Every voter in every state can go to her or his AG and file a complaint of voter fraud alleging NP and the DNC Certified BO is a NBC to get his name printed onto the state general election ballot but refuse all requests to provide documentation on which such Certification was based. And this leads the voter to suspect, he is not Constitutionally eligible for the job! (Note, this is not asking the AG to investigate WHETHER BO is eligible for the job; but rather, to investigate whether the DNC investigated whether he was eligible, before Certifying, he was!) (DNC rules state that the candidate for the Democratic nomination for President shall meet those requirements set forth by the United States Constitution and any law of the United States. Thus, by confirming Mr. Obama was the Democratic candidate, NP was also warranteeing, he was Constitutionally eligible for the job, that is, he is a NBC. Plus, in accordance with Hawaiian Revised Statutes §11-113, on the Certification forwarded to HI elections officials, NP affirmatively added this additional line: he was Constitutionally eligible for the job.)

    As for wishing you had gone to law school; well, it took a lot of lawyers to get us into this mess. ADMINISTRATOR

  9. azgo says:

    I didn’t misunderstand your point, I almost didn’t send that information but I find him to be an interesting character with a few years of history with barackO. Vietor worked for John Edwards in 2004 and when things went array he joined then Senator Obama as a press secretary.
    He been a strategist for Obama for a while and also has been coined ‘tommy-vietor pinocchio’.

    Now would ‘The OFA Party’, Organizing For America, have a claim of sovereign immunity since this group is “A Project of the Democratic National Committee”?
    (look at the bottom left corner of the pages)
    Fight the Smears has set forth Obama’s ‘native’ and ‘British – at birth’ citizenship.

    azgo: Sovereign immunity is the ages old legal principle that says, the sovereign or, king – basically, the government – is immune from suit, without the sovereign’s consent. With few exceptions, the DNC is clearly a private actor and not a governmental actor. (The exception in this instance is this. In a state that has enacted a law (statute, regulation, or rule) requiring the candidate for POTUS from the major political party must be a NBC; given that no corresponding law requires the state to check AND that states have admitted, when it came to Constitutional eligibility, they assumed the party had vetted their candidate; I would argue the party WAS a state actor for the purpose of submitting the name of only eligible candidates to the state elections officials – usually the Secretary of State – for the purpose of getting their names onto the states’ ballots.) ADMINISTRATOR

  10. azgo says:

    Thanks for your great answers!
    So would the Fight the smears BC page, being a part of the DNC, be the only other evidence of vetting the candidate in that he has a birth certificate and he is a ‘native born’ American citizen?

    azgo: BINGO, almost. I am assuming that the COLB is the strongest evidence NP could have seen, if anything, because BO asked the court in Hollister to take judicial notice (that Annenberg Political Fact Check – he said in his pleadings but, I like to use the real name – said, it’s a bona fide document). This was a ‘tell’ for me that, this was the strongest evidence ‘out there’ of his NBC status. (He wrote on his web site this “Official Birth Certificate” proves he is a “native” but, as we know, the criterion for POTUS is natural born, not native. (Thank you for acknowledging the caliber of answers I supply to readers’ questions. When you refer people to this blog, please remind them to read the comments.) ADMINISTRATOR

  11. azgo says:

    “I am assuming that the COLB is the strongest evidence NP could have seen,”
    NP had to endorse in some way the BC web page as being a member (and probably a high ranking member) of the Democratic National Committee.

    “Hon. Nancy Pelosi – Washington, DC”

    Seems to me, NP (as well as all members of the DNC) and then as chair of the the convention had to be a responsible party as to the BC web page ‘almost’ evidence whether the act was direct or indirect.

    Obama was not responsible in any way for the content of this web page in that he was not a member of the DNC and as the web page states;

    (bottom left corner of the page)

    (Although, press secretary Mr. Gibbs has referred to the BC as something like ‘we put up on the internet…’)

    So I suppose the DNC through the ‘Organizing For America’ project are fully responsible for the content of the BC web page and being a non-governmental entity have no claim of sovereign immunity.

    This BC web page gave the American people including Congress, journalists, reporters etc. only an ‘impression of the candidate being qualified’ and not ‘fact of the candidate being qualified’. Of course this page has misled so many people then and still today. I’m assuming this ‘almost’ evidence could only serve, maybe, to the point that the DNC did not vet the candidate properly in that they claimed him to be a ‘native born’ and some readers of the page misled themselves ‘by their very own impression’ of the content and probably not knowing what ‘natural born’ means or even not knowing the requirement existed.

    The DNC only provided information about Obama, probably told the truth and the content was not about addressing the requirement for president.

    Thanks jbjd and have a great weekend!

    azgo: You are not going to believe this… When I received your message, I was thrilled you had sent me this other piece of information, which was new to me: the DNC blurb at the bottom of the “Fight the Smears” web site, disclaiming BO’s involvement in the site. I did a search for “Fight the Smears,” clicked on the link, and sure enough, there was the disclaimer. I wondered how I had missed such a critical piece of information; maybe I had been too focused on the COLB, and the hubris that to authenticate the COLB, there was a link to Annenberg (Political Fact Check), BO’s former employer. Then, I recalled that I might have saved a screen shot of that COLB page, last year. And there it was, on my desktop. And guess what? Turns out, at least this time, I hadn’t missed anything at all. Because on the bottom of the old COLB page, there is no DNC disclaimer. Instead, this appears: PAID FOR BY OBAMA FOR AMERICA. But wait, it gets better. On the new “Fight the Smears,” which contains the DNC blurb on the bottom, is a page with several pictoral links, one of which is the COLB. I clicked on that. And guess what? It is identical to the old COLB page in all other respects except one: on the bottom of this ‘new’ old COLB page, instead of PAID FOR BY OBAMA FOR AMERICA, is the disclaimer from the DNC.

    I need to process this and figure out how to effectively incorporate this information into a prescription for action. At a minimum, this conduct of ‘labeling’ demonstrates such conduct was not unintentional.

    Thank you so much for taking the time with me to figure this out. ADMINISTRATOR

    azgo: I just thought of something. If the DNC merely took over the old “Fight the Smears” site, and continued administering it; the ‘footnote’ from the old site would have been replaced by the new footnote. What this still means, however, is that the DNC is actually using this COLB to prove BO is a NBC. Wow; this is huge. ADMINISTRATOR

  12. Maddie says:

    Super analysis! Question: So at the state level it is each SOS who verifies the eligibility of the candidate and NP basically signed off (assuming the
    vetting has already taken place)? Explain please.

    Maddie: Nice to hear from you! As you probably know, the general election for President is a state by state affair. Each state’s elections official – usually this is the Secretary of State but, in some states, there are other executives assigned to oversee elections, like a Commissioner of Elections, etc. – promulgates rules or regulations to carry out state law regarding how to get the names of the candidates printed onto the state’s general election ballot. (Hereinafter, I will use the general term “laws.”) Most states have 2 (two) different sets of laws, one for candidates from the major political parties; and one for everyone else. (Most states also have different sets of laws for these 2 (two) categories of candidates in the primaries/caucuses, too.) Anyway, when it comes to the nominee for POTUS from the major political party, most state laws entitle the name of that nominee to be printed on the ballot. But first, the Chair of the State Party for that party must notify the elections official, again, usually the SoS, who is the nominee. Nancy Pelosi was the Chair of the 2008 DNC National Convention. In that role, she signed the Official Certification of Nomination, swearing BO was the party nominee. This Certification was then forwarded to the state official, either directly by the National D Party or, through the state D party (depending on state laws). In other words, just by swearing BO was the nominee, NP had guaranteed his name would be on the state ballots. Now, some states have laws that explicitly say, the candidate for POTUS from the major political party must be eligible for the job. But there is no correlating law saying, someone in government has to check. However, surely the law would ring hollow if a citizen tries to ascertain the basis for the party’s Certification of eligibility – and in those states with laws that require the candidate to be eligible, a Certification from the party that he is the nominee is tantamount to swearing, he has the requisite qualifications for the job, because that’s in the DNC rules (see my response to Noz), right? – and is met with nothing else but silence. I contend that, this looks like fraud. That is, it looks like the DNC swore BO was Constitutionally eligible without actually vetting him for the job. And that would violate state elections law, an infraction that puts it in the jurisdiction of the state AG. Notice, I am not alleging BO is not a NBC, just that, the DNC failed to determine whether he was before they swore, he is.

    HI is a different matter, because HI state law requires the party to Certify not only the name of the nominee but also that the nominee is Constitutionally eligible for the job. (The cites are in another comment.)

  13. jo chgo says:

    Brilliant strategy, jb! I am starting to see some rays of hope.

    jo chgo: Welcome and thank you. What gives me hope are these 2 (two) factors. 1) Initially, I proposed ordinary citizens could file election fraud charges with their A’sG. After all, investigating election fraud is one of those duties we pay them to carry out on our behalf. Now, with even more questionable information coming out, this would make a complaint of election fraud even stronger. 2) I remembered, several months ago, before everyone was trying to figure out how to establish standing in federal court, I had posited, pledged delegates could establish standing in state court. And, armed with the report of the AG (and perhaps a state prosecution for criminal activity), this would lay the groundwork for the filing by the pledged delegate for a civil Complaint for fraud. ADMINISTRATOR

  14. Brian H says:

    “Failure to verify” is not the only possibility, you realize. It is, IMO, equally or more likely that the DNC colluded with Obama to get him on the ballot and elected despite having full awareness that he did not satisfy the NBC requirement.

    Anent which I believe it is worth mentioning once or twice in any filing that the CIC/POTUS is the only person or official in the United States required to meet that standard, in order, according to contemporary correspondence at the time of preparation of the Constitution, that the armed forces of the country not be commanded by someone with compromised loyalties. The NBC requirement (with its presumption that the natural born citizen would be brought up and acculturated solely as an American) was the closest the Founders could come to enforcing and establishing that protection against a fatal betrayal of the nation.

    Brian H: From the beginning of my work on this campaign and election cycle, I have understood that people ‘wanted’ to establish certain conditions existed to prevent BO from being nominated; and then from being elected; then from taking office; and now, from remaining there. But I could not care less on what basis he is driven from office; I only care that, he is. I try to be careful not to engage in speculation unsupported by the facts. (This does not mean, in my imagination, I have not arrived at the same conclusions as others.) So, given only the facts, I looked for a sound legal theory on which I could base my efforts to help him out of office. And the scenario briefly outlined in the memo could work, as supported by the facts (which, as you noticed, are constantly changing). If it makes you feel better, keep in mind, just because the goal is to establish the D’s committed election fraud through a bad process, does not mean, in pursuit of the facts, the issue of whether BO is really a NBC will not arise. ADMINISTRATOR

  15. Brian H says:

    I was also gently hinting that collusion in a fraudulent enterprise on the part of the DNC might lurk in the weeds, too! 🙂

    Brian H: I heard you. ADMINISTRATOR

  16. Portuguese Rev War Hero Peter Francisco says:


    Good job,

    Just so you know back in around Spetember/October 2008 I started called DNC headquarters and acting like Democratic voter ask them if anyone had seen the actual Documents, each time they put me ot the legal dept. I believe each time I talked to a lady named Valerie and each time I called (5-6 time in a few days) she would explain that it was online. I would reply screaming “We are depending on documents online, are you for real? Did anyone there see the actual Documents”. She said NO, we just go by what was put online and has checked it out.
    I screaming told her “We are electing someone as president based on pic the internet? the same internet that can get a pic of you head and put it on a naked body and say that you have a naked pic online?” She was speechless. Then I said something like we are gonna lose this election because of incompetents like you and anyone that depends on internet to show documents.

    They admittted to me that they NEVER SAW the actual documents.

    Now I wonder if Valerie was Valeri Jarrett? Was she part of the legal dept in the campaign?
    each time I was put thru to her. It was the same person thet 5-6 times I called.

    PRWHPF: Too bad you did not keep better records. ADMINISTRATOR

  17. Portuguese Rev War Hero Peter Francisco says:

    How about a Voter Class Action lawsuit?

    After all we were Defrauded of Our Votes and the elction process was compromised.

    PRWHPF: I cannot go into a detailed analysis now but, there is no right to vote for the party nominee of your choice. ADMINISTRATOR

  18. d2i says:

    Stunning, jbjd. Your dialogue w/azgo says so much. Like you, my imagination, at times, gets the better part of me, but what is most important is stating the facts. I come here to get said facts and then use them in my posts at other sites. One of the facts I’ve been stating is 0’s own admission on FtS that he is “native” not “natural born” and that he told us that by birth that he was a governed as a citizen under British law due to his father’s citizenship. I’m starting to see others posting the same information which gives me hope that folks are indeed taking the time to read and learn about this crisis.

    Curious question. I read the other day that his British citizenship DID not automatically expire at the age of 21 and rather, he remains a British subject due to the citizenship laws of Britian. Is this in fact true? If so, could you elaborate.

    Thank you for all you are doing to expose this fraud. I’m so impressed by your tenacity and legal reasoning. I’m so happy you are on the right side of this crisis. We need you!

    d2i: Thank you for appreciating the work. Yes; azgo and I, together, stumbled onto a truth with those ‘attributions in the footnotes,’ the implications of which are significant to a charge of fraud. (I am still trying to digest all of it.) Consider that, the DNC knows Annenberg Political Fact Check, who supposedly authenticated the COLB, has no legal privity with us. That is, they have no legal obligation to provide us with anything; and we have no reasonable expectation to suppose they will. (One of my previous postings discusses privity.) Besides, ever check out their web site? These staffers are not lawyers or documents experts. And the disclaimer on that site explicitly says, ‘We are not responsible…’

    As for BO’s use of that “native” word… way back in December, when I was drafting my military Complaint, I said, the fact that BO swore in December 2007 as part of his primary filing statement to the AZ SoS, he is a “natural born citizen”; and then wrote on FTS in June 2008, this COLB proved he was a “native,” is an example of BO’s conduct that leaves Plaintiffs concerned as to whether he is a NBC. But now, think of the implications if we ascribe the contents of that web site to the DNC. Surely, they know the difference between a natural born citizen and a native born citizen. And they ‘say’ on FTS he is “native” while swearing to the state elections officials, he is “natural born.” Can you spell F-R-A-U-D?

    The circumstantial evidence is mounting that by swearing BO is a NBC so as to get BO’s name printed onto general election ballots, the DNC committed fraud. And in addition to their refusal to provide voters with the basis on which they made such Certification of Constitutional eligibility, there are all these ancillary events. For example, for what reason did Senator McCaskill twice introduce actions in the Senate, first in February 2008 and then in April, when non-binding resolution S511 was passed, to ‘declare’ by definition in that proposal, John McCain is a NBC? And why were BO and HRC co-sponsors of both efforts?

    Bottom line, surely sufficient doubts exist as to whether NP, Chair of the 2008 DNC National Convention (and Alice Germond, Secretary, both of whom signed the Official DNC Certification of Nomination), and the DNC; verified whether BO is Constitutionally eligible for the job before swearing to state elections officials, he is. And in those states that explicitly require the candidate to be eligible for the job in order to get his name printed on the general election ballot, the conduct of these Democrats could be said to constitute election fraud.

    As for your question about the duration of BO’s British involvement… I would have to look it up. But for the purpose of this issue of initiating state inquiries into election fraud, you understand whether BO is a NBC is irrelevant. ADMINISTRATOR

  19. jbjd says:

    So much for the difference between “Certification” and “Certificate.” Recently, I began writing on the blogs that HI has begun calling its “Certification of Live Birth” a “Certificate of Live Birth,” claiming the two terms can be used interchangeably. Seems HI has now made the change official. In an article entitled, “Will changing name of document fix problem? Hawaii officials redefine ‘Certification of Live Birth,” World Net Daily reports that HI has now re-named its computer-generated “Certification of Live Birth,” a copy of which is posted on the DNC’s “Fight the Smears” web site; and is issuing such documents on request, bearing the new title,”Certificate of Live Birth.” Even if true, this information has no effect on the analysis that applies to the DNC actions at the time of their Certification to the states, in August 2008.

  20. Portuguese Rev War Hero Peter Francisco says:

    I still maybe able to get my tel. records if that helps I can look into it.

    PRWHPF: What you and I are discussing now is how to substantiate a claim that, the DNC made an admission against interest that, they had used only BO’s photocopied COLB posted on FTS to verify his Constitutional eligibility to be POTUS, before Certifying he is eligible. I cannot yet predict whether sufficient ‘evidence’ can be gathered to support an allegation that the DNC said what you say they said, which would contribute to the factual puzzle giving rise to the theory that the DNC did not vet the candidate before swearing they did, to a theory. But certainly, see what you can dig up and get back to me. ADMINISTRATOR

  21. jbjd, Your work is tremendously appreciated! I’m not a legal eagle, so it’s a little laborious for me to follow, but you are obviously very thorough, detailed, and offer substantial claims. More power to you.

    snk: Thank you. I will eventually need to re-word a sort of ‘primer for action’ because I want lay people WHO HAPPEN TO HAVE BEEN PLEDGED DELEGATES and who are disturbed that the voting proxies millions of citizens bestowed upon them during the D primary, were fraudulently stolen from them; to seek redress for this unlawful taking through their state government officials paid to assist citizens in this way. ADMINISTRATOR

  22. drkate says:

    jbjd, I read your article again and think I’m getting it….the state i live in is one of those states where delegates are required to vote as the election in the state went…so we should find electors in those states and file with the SOS a claim of voter fraud against the DNC in that state?

    drkate: Nice to hear from you. Anyone can file a complaint with the AG but pledged delegates have the upper hand. Here’s why. Are you familiar with the work I did during the primary on binding vote states? I will re-print the work at some point but, basically, I learned that BO’s people were harassing HRC pledged delegates in these binding vote states to switch their support BEFORE the Convention. I saw this conduct as soliciting them to break the law. So, I wrote to A’sG, the chief law enforcement officials in those states, to turn BO’s people in. A couple of HRC pledged delegates were on the news. They appeared pretty upset at what was going on. (This is what led me to wonder whether there were other pledged delegate states and to conduct the research. I mean, at that time, even Governor Rendell did not know about binding vote states, saying on FOX News, ‘There’s no such thing as a pledged delegate.’ I said to myself, PA must not be a binding vote state!) That’s another reason that I am particularly excited by having pledged delegates in those binding vote states file complaints with their A’sG that now, they have no idea whether BO is a NBC, and to call for an investigation of election fraud. And, as a bonus, if we can get pledged delegates in states with those laws requiring the nominee to be eligible for the job, well, I cannot foresee any excuse to quash such an investigation that will survive public outrage.

    Of course, if any pledged delegates want to file a civil complaint, that would really be explosive. And they definitely have standing to do that, whereas with ordinary citizens, I would have to do some more creative thinking to establish standing .

    Can you say what state you live in? ADMINISTRATOR

  23. drkate says:

    jbjd, thank you for your reply. I live in WY, but have contacts in CO that might work there. What states do you thing have the greatest possibility? This is a very fine idea. I think also (name omitted) is going to take your advice on Pelosi. Excellent work, fellow patriot!

    drkate: Okay, WY is not a binding vote state. As for CO, that is not a binding vote state but, the D Party threatened Sasha Millstone, a HRC pledged delegate, that she would be replaced at the Convention because she said she could not support BO. So, she might be a bit peeved now that, whether BO can even be said to be a NBC based only on representations made by the Party, is anyone’s guess. However, I just checked and, under CO law, the name of the nominee for POTUS from the major political party “shall” be placed on the ballot. That is, CO is not one of those states that requires the candidate for POTUS from the major political party to be eligible for the job. And the case for pursuing a complaint for fraud that is at the heart of this post, whether in the form of a complaint to the state AG; or, a civil complaint in court, occurs in those states with such party eligibility laws, that is, states with laws that define only the names of eligible candidates can appear on the ballot. ADMINISTRATOR

  24. CG says:

    Would Lady Lynn Forester de Rothschild (or other prominent HRC supporters upset with the RBC decision) have access, through DNC friends, etc., to determine the answers to some of the questions which you have not received responses? Or does that not matter at this point if you have reasoned the best approach is to file complaints at the state level? Hope I have interpreted your comments correctly. Is there any way I can help in Washington State? Unfortunately I was nothing more than a HRC precinct delegate and an HRC volunteer, and therefore not someone with direct distinction, but I will be happy to help if I can.

    I appreciate your hard work and effort in determining the best way forward. I find it enormously unsatisfying as a Democrat that the unifying consent of party officials, and the courts, is to ignore requests to merely (and simply) disclose sealed documents, especially if there is nothing to hide. At least to my understanding no one is requesting monetary damages are they? It so bizarre for the DNC to not assert pressure on Obama to release the various documents, to be totally transparent, so as to end the speculation and to not tarnish the Democratic Party any further than the Party has already been disgraced during the primary. I suspect that Obama’s support and the DNC’s, will drop precipitously if unemployment benefits dry up and unemployment and underemployment keep rising at which point some may be more willing to challenge his natural born status. Although I remain a Democrat I decided not to make any further donations, since May 31st, I just can’t in good conscience. And I may give up my affiliation if Obama is the nominee in four years. Thanks again for your efforts.

    CG: Great ideas! Your comment has buoyed me! I cannot believe, in considering how to get the word out, I totally forgot about LLFdR’s bravura performance on the talk shows in support of HRC. I so would like her to read this blog; of course, she has access to pledged delegates in binding vote states, who I imagine were not too happy during the primaries/caucuses to be pressured by BO’s people to change their voting commitment prior to the Convention, in violation of that state’s law. Especially where state law requires the party to submit only the name of the eligible candidate to appear on the state ballot, knowing the D Party refuses to tell voters on what basis they satisfied this law, would make me furious! See, last summer, when I realized no provision in either federal or state law requires anyone to vet the candidate for POTUS from the major political party as to Constitutional eligibility, it makes no difference whether BO is a NBC, I tried to tell people, if he cannot get onto the ballot, he cannot win the general election. So, file a challenge to keep his name off the ballot if you believe he is ineligible. Through this process, make him prove, he is.

    (A commenter on one of the blogs said tonight that now that HI has (supposedly) changed the name of the Certification of Live Birth to Certificate of Live Birth – I put a link to an article about this recent switch I read in WND, in another comment – this negates the purpose of the proposed House bill, requiring candidates to show their “Birth Certificates” to establish eligibility. I wrote back the following.

    There are a million ways to get around this. Could be, HI just found one.

    Of course, just because BO meets any laws regarding his eligibility, does not mean, we have to buy every piece of ‘evidence’ he comes up with.

    I am going to work on writing model legislation for the states, for vetting candidates; just as soon as I give up trying to get citizens to get their state government – A’sG – to investigate election fraud perpetrated by the DNC to get BO onto state general election ballots.

    And this.

    This is where we have the power. Our state money pays for the primaries/caucuses for the major political parties. More voters are registered as “Independent” or “Unenrolled” than as D or R. Off the top of my head, I would propose we can pass laws that say something like this: No candidate will have her/his name printed on the ballot who has not first received Certification from a panel… as to eligibility for the job.’ Mind you, this does not bar a political party from getting its D or R on the ballot. This just means, voters will know the Party did not subject its candidate to the scrutiny of the eligibility panel.

    In what ways do you propose we can ‘get the word out’? ADMINISTRATOR

  25. Brian H says:

    Lynn FdR has caved, pretty much, and now supports (name omitted), though somewhat worried he might be spending too much. According to an interview video I saw a month or so ago, anyway.

    Brian H.: I hear you; but surely all the people who want BO authenticated cannot be said to come from the ranks of his detractors. Even assuming this is true that LLFdR now supports BO, this does not mean, understanding the DNC Certified the Constitutional eligibility for POTUS of a man they did not vet, she would not change her mind. ADMINISTRATOR

  26. azgo says:

    Wow, I leave for 2 days and everything happens! Copy of Keyan BC (?) !!!

    Great detective work jbjd on the original FTS site !!!

    Oh Darn! I was going to send you a link to a saved FTS BC page. I had this “…” of the BC page link after it was missing from the site a couple weeks ago or so. I bookmarked the page and it said “Paid for by Barack Obama 2008. All Rights Reserved”. I accidentally refreshed the page and it reverted to the “Paid for by Obama for America” version. I did make a pdf of the page though before I quick-fingered the refresh button and as it says “Paid for by Barack Obama 2008. All Rights Reserved”.

    How strange is that !!! I’ll have to find where I got the link – it was from a commenter telling people to save the link for future reference. Everything else on the page looked the same. Maybe someone got a screen shot of that page.

    Maybe this, “Paid for by Barack Obama 2008. All Rights Reserved”, is what the original FTS BC page said as posted by TheObamaFile. (???)

  27. azgo says:

    Here it is, if you google “Fight the smears, Paid for by Barack Obama 2008. All Rights Reserved” This BC link and other links comes up also!

    “Fight the Smears: The Truth About Barack’s Birth Certificate
    Barack Obama 2008 Presidential Campaign: Fight the Smears. … Paid for by Barack Obama 2008 . All Rights Reserved Powered by Truth and Supporters Like You. – Cached – Similar”

    Though, clicking the link, it comes up with “Paid for by Obama for America”

    So it did say “Paid for by Barack Obama 2008 . All Rights Reserved” at some point.

    I did get a pdf of the google search page, in case somehow that page vanishes.

    wEiRd !!!

  28. jbjd says:

    Readers, here is a question I received today from drkate.

    What’s your take on this new Kenyan BC? Taitz is having it verified (full disclosure, I think Taitz has made a lot of mistakes and I don’t like her style/demeanor).

    Here is my response.


    Every time some ‘new’ piece of evidence surfaces that could indicate, BO is not a NBC; I feel kinda disappointed. That is, people who think he is not a NBC keep looking for a magic pill to prove them right. But, even assuming the existence of such magic pill, when a document that might serve this purpose is located, what then? The document has to be verified as real. Who will determine this, with a gravitas that will be accepted by the American people? AM suggests the FBI should conduct an investigation, but fails to cite a federal law that would support such intervention.But, even assuming the Kenyan document is real, in order to bear on BO’s Constitutional eligibility for POTUS, verification must be made as to whether it proves the fact stated, that is, he was born in Kenya. And then there is the issue of dueling purported proofs, the Kenya Certification vs. the HI Certification-cum-Certificate. At some point in the future, assuming such verification is made and accepted, what then? (Legal experts disagree on whether BO can be said to have been lawfully elected, if he is not a NBC. I think the election was perfectly legal. The people, acting as individual voters; voters of the Electoral College and members of Congress voting on ratification of the EC vote, elected BO as POTUS, notwithstanding no proof exists he is Constitutionally eligible for the job.)

    People complain that when they asked NP and the DNC on what basis they Certified BO is a NBC, they get no response. Why aren’t they complaining to their elected state officials? Specifically, I have been asking people to ask their state officials to investigate whether NP verified BO was a NBC before Certifying he was, and submitting that Certification to state elections officials in order to get his name onto the general election ballot. Contact from the AG ‘asking’ NP to inform on what basis she made this determination would shift the burdens of proof and production as to BO’s Constitutional eligibility to her (or the DNC). This would also cultivate an activist citizenry, so that something like this will not happen again.

    My job as a citizen is not to prove BO is not eligible to be POTUS. Rather, my job is to make him prove, he is.


  29. Brian H says:

    Your final question is rather interesting. The “burden of proof” is surely on the candidate to prove he is; there is no reference in the Constitution to any obligation of the citizenry or voters to prove he is not if he fails the Constitutional requirements.

    Brian: Yes, but, unfortunately, we – and, since the actions of my fellow citizens brought us here, I will use the collective plural – elected BO, through the various Constitutional actors. Now, having let him through without vetting, we can still affect the outcome in other ways. For example, carrying on that principle of shifting the burden of proof and production away from us and onto the supposed wrongdoers, I want NP, or the DNC to prove, they obeyed state election laws to get his name printed onto state general election ballots, given strong circumstantial evidence that indicates, they did not. ADMINISTRATOR

  30. Brian H says:

    Exactly. I wasn’t objecting to your post, simply clarifying a point for myself. Thanks.

    Brian H: I know. You are welcome. ADMINISTRATOR

  31. A-1 says:

    I know your objectons to the bc issues, but just a thought…..
    Is it possible that the Hawaii statute restricting access to birth and death certificates, be attacked as unconstitutional as over broad?
    Federal statutes require that states maintain acurate records of births and deaths within their boundaries. These records are relied upon by federal, state and local entites for a variety of purposes incl but not limited to passports, air travel, school enrollment etc
    These records are considerred public records by statute are case law in many states,. Itt is arguable that there is no compelling interest to deny public access to thaws records. On the other hand there is a compelling interest to subject these records to public
    The state of Hawaii has refused release of the birth records even though there has been an express ( or at the least implied ) consent by placing the document on the website they maintained,
    The state does have a duty to authenticate any documents that are purported to be authentic. I believe all states have procedures to autenticate documents.

    A-1: Because of an epiphany I had at around 4:00A this morning, I am weighing in on the document retrieval angle. I still need to do the research but, points you raise in conjunction with points I raised in this posting, will help me to figure out next steps. And what is the urgency? Read the newest post, “jbjd, BIRTHER. If you want to continue our discussion, post on that thread. ADMINISTRATOR

  32. Patriot Dreamer says:

    jbjd, another problem with Major Cook’s case was in claiming conscientious objection as the cause of action. You have already stated other reasons why, but here’s another: the Department of Defense and each of its services already has regulations in place for conscientious objectors. Here’s a link to the Army’s Regulation 600-43 (Conscientious Objection):

    Click to access r600_43.pdf

    What is the usual disposition of an Army soldier who claims conscientious objector status and who is determined to meet the criteria in AR 600-43? Discharge from the service “for the convenience
    of the Government.”

    Patriot Dreamer: Yes; the Cook case attempted to carve out a new definition of conscientious objector as one who refuses to fight based on a belief the CIC is not eligible. There was no way this would ever reach a determination as to whether BO is a NBC. (I was considering whether to put up a separate post about the Cook case…) ADMINISTRATOR

  33. JThompson says:

    I’ve been reviewing your opinions and ideas and I find them very interesting.

    Looks like your idea of putting some pressure on state level officials has been in the works for some time now down in Florida. There is a recent post of an election fraud complaint filed with Florida’s AG against the DNC and State Democrat Party over at the Right Side of Life. Scroll down to; I am a natural born citizen of the USA at this link.

    A final notice to Florida’s Governor and Secretary of State that an election fraud complaint was going to be filed, along with all supporting documents were posted back on July 5 at this link.

    If this guys reading of Florida’s Election Statutes is correct, the SOS already has the legislative authority to promulgate a presidential primary election rule that will require the political parties to submit the documents they used to verify their candidates eligibility but they will not do so. He made the Governor and Secretary the subjects of a 2nd election fraud complaint for collusive election fraud cover-up, cops watching a crime being committed but refusing to intervene.

    Could be interesting.

    JThompson: Hello. And yes, the poster’s FL complaint has been in the works for some time. Let me just point out, FL has no rule that explicitly requires the candidate for POTUS from the major political party to be eligible for the job. So, to construe NP’s Certification to the S o S that BO is eligible, as election fraud – remember, by Certifying he is the nominee, she effectively Certified his eligibility as under DNC rules, the nominee for POTUS must be Constitutionally eligible for the job – the filer had to look for some other provision that required the candidate to be eligible. For example, was he required to swear under the pains and penalties of perjury that he was eligible in his filing papers in the state primary?

    Also, remember, granting legislative authority to promulgate rules is not the same as requiring her to write those rules. (If the law said, she must have rules as to eligibility then, the right plaintiff could file a complaint in mandamus in state court asking the court to order her to carry out this ministerial duty.

  34. JThompson says:

    Thanks, for the quick response. It’s very refreshing being able to communicate to an individual with your reputation as a forward thinker on such matters.

    However, as I continue to digest other’s thoughts on this matter I find the fact that Florida, like most states, has no such statute which also appears to be the very basis of the Florida complaint against the DNC.

    Is it your opinion that voters in these states have no fundamental due process right to hold the DNC accountable for fraud when the DNC refuses to provide public access to the documents they used to verify Obama’s constitutional eligibility?

    Is the DNC in these states above the law and responsible to no one?

    Also please clarify, Is it your opinion Chapter 103.101 paragraph (5) grants the Florida Secretary of State the authority to promulgate such primary rule if he wanted to?

    Finally, if the Secretary of State observes election irregularities or fraud but feels he needs additional legislative authority to prevent it, would it be dereliction of his duty as chief election officer of the State if he fails to submit a request for such legislation?

    JThompson: I anticipate this answer will wholly frustrate you but… The DNC is not above the law but it drafts and passes better laws than does the average citizen. Keep in mind, laws related to state and federal elections – that is, elections for federal offices, carried out by the states – are state laws. State legislatures makes these laws. (Well, technically, they make the statutes and then, the agencies write the regulations to carry out those statutes.) If we want the state to vet the candidates from the major political parties as to Constitutional eligibility, we need to re-write the laws. And if we don’t like the way our elected or appointed state officials carry out their duties, we need to replace these officials. ADMINISTRATOR

  35. JThompson says:

    You are correct, but I am thoroughly confused. Let’s try this again, one point at a time.

    Is it your opinion that voters, in states like Florida that depend solely upon the major political parties to properly vet their presidential candidates, have no fundamental due process right to hold the DNC accountable when the DNC refuses to provide public access to the documents they used to verify Obama’s constitutional eligibility?

    JThompson: No; I am not saying that. But in order to ‘persuade’ a state AG to investigate, the clearest incentive is based in the letter of the law. Thus, an investigation into election fraud, based on a violation of FL law requiring the candidate for POTUS from the major political party to be a NBC; is an easier sell than an investigation by that same office based on, say, consumer fraud, charging the D party used state resources in the primary and general election to champion a candidate who was not even eligible for the job. Does that make sense to you? If not, come back and we will try again. ADMINISTRATOR

  36. JThompson says:

    I think I’ve got it…

    Voters, in states like Florida that depend solely upon the political parties to properly vet their presidential candidates, DO have fundamental due process rights to hold the DNC accountable when the DNC refuses to provide public access to the documents they used to verify Obama’s constitutional eligibility, if the AG chooses to pursue it, but the AG could more easily be persuaded to do so if the state had an eligibility statute.

    If this is correct, thanks for the clarification. If this is incorrect please offer some insight.

    JThompson: Exactly! Nice work. Now, having said that, let me add one more piece of information. What you and I have been talking about is the kind of ‘fraud’ that constitutes a basis for asking the chief law enforcement officer in the state to intervene. But remember, there’s also the tort of fraud. Now, each state has its own tort laws. And, the Plaintiff who pursues NP or the DNC in an action for civil fraud must establish standing. The person best situated to establish standing in that case is a pledged delegate, who could argue that they would not have cast their 1/2 vote each for BO at the Convention, as fiduciaries of all of those citizens who cast votes for their choice of D candidate to become the nominee for POTUS, had they known no one verified whether he was a NBC. And, while FL is not a vote binding state, meaning the pledged delegates are not legally obliged to follow their candidates into the Convention, this still leaves these delegates to follow the DNC rule for casting their votes, which is, use your “best conscience.” I suspect the best conscience of many of those pledged delegates from FL would have been to withhold those votes for BO, as fiduciaries of the voters who sent them to the Convention, until BO was proven to be a NBC. Again, I am not saying he is not a NBC; I am saying, NP and the DNC claimed he was, without prior verification.

    States have enacted laws that allow the major political parties to operate within their borders, even providing tax money to conduct party primaries and caucuses in order that the parties can select the candidates whose names the state will then print onto the ballots. But this does not mean, we have no recourse when the party perpetrates fraud in order to install its candidate into office, regardless of the cost to the rest of the citizens of that state. ADMINISTRATOR

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