Multi-District Quo Warranto Matter in Re Strunk Consolidated Reply Declaration in ACORN V USA EDNY 08-Cv-4888

Christopher-Earl: Stnu& in esse
593 V-It Avenue #281

Brooklyn, New Yo* I 1238
Email: ci&@hmkws
Ce11-845-901-6767
The HmrabIe Royce C. Lamberth

United States District ChiefJudge for the
U.S. District for the District of Columbia
333 ComtitutionAvenue, NW,
washington, DC 20001
b Tailz v. ObumgpCD 1OcvaO151 and related case
~ ~ D C D o & C v - 2 2 (RIL) 3 4
Subject: Request for permissionto transfk with the 28 USC 91407
The Multidistrict matter ACORN et al. v. U,SA, e4 al.
EDNY 09-c~-4888(BIG)with demand for Quo Warranto
inquest of Barack Hussein Obama (akaBarry !hetom).
I am the Petitioner, Chri--Earl: Stnmk in esse, with the pending motion to

intervene Win as a ex-refator Pfaintifffbm the r e W case before US.District Mge Richard
J. Leon. Judge Leon ordered a stay of discovery pending a decision on my Quo Warranto
demand fbr an inquest ofmuttidegimce hcb sssociated with thc August 4,1%1 birtb of
B m k Hussein Obama Jr., &a Barry Soetoro (the Usurper).and make this statement under
penalty ofperjury pursumt to 28 USC $1746. Declarant is self-- in the above civil
actions on-going in Washington District of Coiumbia, and hereby m p s t ptms6ssion to transfer
with the 28 USC $1407 dK matter D R N et sl, v. U,S.A. et d.EDNY 09-cv-4888 presentfy
before Judge N im Gersban when my Motion to intervene there is decided by &at Court in that
as I argue lhere on January 23,2009 1duty fired the Def- O h because He is unqualified
to act with mypower of attarney because He has dual ailegiamx at birth by his own admission
and his actions are void ab initio; and therefm,with dual all- i d i g i i e to hald the office
of President accoPding to U.S. constitution Article II Section 1, is nat a m t m h m 4 t i z e n
without two U.S. Citizen parents on his birth August 4,1961. Of importance to the Plaintiff
herein,I concr~with an cxpe&ed inquest schedule recyuwted by Dr. Taitz on k t s filed befare
this Comt lhat prove the D e f a hrts comrnittad a fiaud that personally injmedShe and me.
I am f d i a r with the facts associated 64th the referenced cases as each are
telated and subject to the transfer here as an urgent matter of National Security before this Court
and that the U.S.Government has argued that any Quo Warranto be done in Wasbgton District
of Columbia and I urge hesein applies with a Multi-ct Judicial Panel accdingly. A copy of
thisrequesthasbecnseutmhlsdcomtinboth
cc: 3eRicAafda-
Judge Nina Gershon ..
United States District Courts
York In Case - ACORN et d.v. U.S.A.et al. EDNY 09-cv-4888
Eastern District o f ~ e w
Washington District of Columbia In Case - Taitz v. Obama DCD 10-cv-0015 1
Washington District of Columbia In Case - Stnmk v. DOS et al. DCD 08-cv-2234
CERTIFICATE OF SERVICE
On February 17,2010, I, Christopher Earl Strunk, declare and certifjr under penalty of perjury
pursuant to 28 USC 51746: That I caused the service of Nine (9) copies of the Christopher-Earl:
Strunk in esse Request for permission to transfer with the 28 USC $1407 The Multidistrict matter
ACORN et al. v. U.S.A. et al. EDNY 09-cv-4888 (NG) declared February 16,2010, with exhibits
annexed and that each set was placed in a sealed folder properly addressed with proper postage for
United States Postal Service Delivery by mail upon:
The Honorable Nina Gershon Andrew Cuomo New York State Attorney
United States District Judge for the General 120 Broadway 24&Floor New York
U. S.D.C. for the Eastern District of New York New York 10271
225 Cadman Plaza East
Brooklyn New York 11207 Channing Philips, the U.S. Attorney
C/OWynne P. Kelly, AUSA
The Honorable Richard J. Leon Office of the U.S. Attorney for the
United States District Judge for the Washington District of Columbia
U.S. District for the District of Columbia 555 4th St, N.W.
333 Constitution Avenue, NW, Room 6315, Washington, D.C. 20530
Washington, DC 2000 1
Eric Holder, U.S. Attorney General
Dr. Orly Taitz, D.D.S. C/O Brigham John Bowen, AUSA
29839 Santa Margarita Parkway, STE 100 U. S. DEPARTMENT OF JUSTICE
Rancho Santa Margarita CA 92688 20 Massachusetts Avenue, NW
Washington, DC 20530
Darius Charney, Esq. Center for
Constitutional Rights 666 Broadway, 7th Barack Hussein Obarna in esse
Floor New York, NY 10012 C/O The White House
1600 Pennsylvania Avenue NW
Peter D. Leary USAAG Department of Justice Washington, DC 20500
20 Massachusetts Avenue, NW Room 7322
Dated: February
Brooklyn New York
Christopher-Earl: Strunk in esse
593 Vanderbilt Avenue #28 1
Brooklyn, New York 1 1238
Email: chris@stnmk.ws Ph: 845-901-6767
01
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
---- ___________l__l-l_----- x Case No.: 09-cv-4888
ACORN (Association of Community Organizations for

Reform Now) ACORN Institute, Inc., and NEW YORK @GI &B)
ACORN HOUSING INC.
Plaintiffs,
v.
UNITED STATES of AMERICA et al.. *A N

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(845) 901-6767 Email: chris@,strunk.ws x 2
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PETITIONER'S CONSOLIDATED REPLY DECLARATION IN SUPPORT

OF THE NOTICE OF MOTION TO INTERVENE AS A EX-RELATOR
INTERVENER-DEFENDANT U.S.A. CITIZEN AND
STATE OF NEW YORK CITIZEN.
I, Christopher-Earl: Strunk in esse. declare and say under penalty of perjury with
---- -.-..-- . - --- -- - ------ - --- -- - -
28 USC 8 1746:
1. Declarant is petitioner herein requesting Court permission to allow this
consolidated reply declaration in support of the notice of motion to intervene as an

ex-relator intervener-defendant U.S.A. Citizen and State of New York Citizen to
the memorandum of law in opposition to motion for intervention filed February 9,
2010 by Defendants’ local counsel F. Franklin Amanat Assistant United States
Attorney for BENTON J. CAMPBELL United States Attorney for the Eastern
District of New York (See Exhibit G), and consolidated because Plaintiffs on
February 9, 2010 filed a response join in and incorporate by reference
Defendants' Memorandum of Law in Opposition to Motion of Non-Party
Christopher Strunk, except to the extent to which Defendants characterize the legal
question before the Court in this litigation as "whether Congress has the
constitutional authority to enact appropriations legislation which temporarily
suspends ACORN'S access to federal funding while a government-wide
investigation takes place." (See Exhibit H).
2. That this reply declaration adds additional Exhibits as a continuation of
Christopher-Earl: Strunk in esse Affidavit in support of the notice of motion to
intervene as a ex-relator intervener-defendant U.S.A. citizen and State of New
York citizen with Exhibits A through F.
3. Declarant’s preliminary statement of the controlling facts in reply that are
germane to the disposition of not only this matter of intervention but are material
facts that may decide the entire case; that as such the following material facts
require a dismissal of the complaint, and or short of immediate dismissal, the
-2-
transfer of this case with 28 USC §1407 to the proper venue and jurisdiction of the
U.S. District Court in Washington District of Columbia where all the void ab initio
actions of Barack Hussein Obama occur(ed) to endorse the Continuing Resolution
(CR) 163 and Mini-bus Bill and all others, are hereby challenged as actions that
must be deemed void ab initio, not only as to the CR 163 and Mini-Bus Bill too;
and that Chief Judge Lamberth is notified by the letter (See Exhibit I);
4. Further, because there is the Quo Warranto matter before the Honorable
Royce C. Lamberth Chief Judge of the United States Court of the District of
Columbia in Taitz v Obama DCD 10-cv-00151, in which Declarant filed a motion
to intervene therein (See Exhibit J with Sub-exhibits 1 through 4) with the
request to transfer and consolidate Declarant’s Quo Warranto Verified Complaint
by severing the matter from Strunk v U.S. Department of State et al. DCD 08-cv-
2234 presently before Distinct Judge Richard J. Leon; and
5. Further, where-in both 10-cv-00151 and 08-cv-2234, Declarant on
application is an ex-relator requesting a declaratory judgment on the facts
presented without need for any discovery on the question of first impression on
admission by Barack Hussein Obama, that He is not a natural born citizen because
he has dual allegiance at birth is ineligible to hold the office of the President of the
United States (POTUS); and by the fact of Obama’s own admission has Dual
Allegiance at Birth with a British Citizen Father and an American Citizen Mother
-3-
on August 4, 1961, notwithstanding where he was born is not material per se
nevertheless with the fact of Dual Allegiance is ineligible for office of POTUS.
6. That Declarant on January 23, 2009 duly fired Barack Hussein Obama from
the POTUS Trustee / Administrator use of Declarant’s Power of Attorney as
shown as Exhibit J sub-exhibit 1, and that Declarant is the only person in the
Country duly entitled to refer to Barack Hussein Obama as the “Usurper”, which
he is.
7. Further because the Usurper signed the Bills in question both are null and
void therefore there is no bill of attainder per se - there is no case;
8. Further because Congress has delegated the Executive administrative
authority to review payment of Plaintiffs’ several Contracts such administrative
process take precedence before this court has jurisdiction to review a complaint per
se if at all; and further
9. Further, because the Usurper by his actions threw the Plaintiffs under the bus
so to speak by endorsing the bill(s), rather than doing nothing by a pocket veto,
Congress must rely upon the delegated authority over said contracts for executive
administrative review accordingly until the process is exhausted.
10. Furthermore, this Court has no jurisdiction to hear the Quo Warranto matter
with the request for a declaratory judgment that may only be done in Washington
District of Columbia by the controlling statute.
-4-
11. That the foregoing facts are dispositive and essential to resolve the matter
herein in which Declarant replies with denials to the several Defendants’ Local
Counsel contentions that Petitioner’s affidavit is difficult to follow and denies the
allegations by which Mr. Amanat wrongly alleges without specificity that
Petitioner’s affidavit quote ”..contains a good deal of ‘immaterial, impertinent, or
scandalous matter,’” as if Fed. R. Civ. P. 12(f) is to apply and that it does not
except insofar as Mr. Amanat's own statement to be stricken instead.
12. Declarant agrees that because he has righteously sued the federal
government in the active case Strunk v. US DOS et al. DCD 08-cv-2234 is where
Declarant was injured by Eric Holder directly, and [who] is hostile to Declarant;
thereby impacting Taitz v Obama DCD 10-cv-00151 and in Strunk v US DOC
Bureau of Census et al. DCD 09-cv-1295, Strunk v. The New York Province of the
Society of Jesus et al. DCD 09-cv-1249, Strunk v US Department of Interior et al.
10-cv-0066, wherein the U.S. Attorney of District of Columbia represents each of
those defendants as also thereafter effects ACORN et al. v. U.S.A. et al. EDNY 09-
cv-4888 (NG) and colors Strunk v. Paterson et al. NYS Supreme Court in Kings
County Index no.: 08-29642 before the Honorable New York Supreme Court
Justice David I. Schmidt.
13. That in the matter Strunk v. Paterson et al. NYS Supreme Court in Kings
-5-
Justice David I. Schmidt in the hearing for a protective order on November 24,
2009 wherein Declarant’s Exhibit D the Court reporter swear she “lost” the
transcript, but after a complaint was filed with the Court Administration “found “
the transcript on January 26, 2010 (See Exhibit K); and wherein the transcript
Declarant refers to “the Corporation” which is in fact the ACORN Plaintiffs herein.
14. That Declarant denies that Eric Holder has ever been involved in any other
case involving Declarant except those listed above.
15. That Declarant denies being an abusive filer in this or any other Court, and
that every case I have ever been involved with since 1995 is in good faith with the
respective court in which Declarant commenced litigation against federal and state
agencies and other persons.
16. That Declarant contends that Judge Ross is predisposed to a bias towards
Declarant in all the cases assigned to her because she was once an employee of
General Motors that is controlled by the Knights of the Sovereign Military Order
of Malta (SMOM) and, in which Judge Ross unreasonably dismissed all Strunk’s
claims under 28 U.S.C. § 1915(e)(2)(B), alleging that the facts alleged “rise to the
level of the irrational or the wholly incredible . . . and that there is no legal theory
on which he may rely.” Strunk v. CIA, No. 08-CV-1196 (ARR/LB) (E.D.N.Y.
Mar. 27, 2008) (docket no. 4). See also Thomas v. Federal Reserve Bank, No. 07-
CV-1171 (ARR/LB) (E.D.N.Y. May 29, 2007) (dismissing Strunk’s complaint as
-6-
frivolous and denying IFP status for purposes of appeal); Strunk v. United States
Postal Service, No. 08-CV-1744 (ARR/LB) (E.D.N.Y. May 9 and June 13, 2008)
(same), aff’d, No. 08-3242-cv, 2010 WL Strunk v. New York State Bd. of Elec., No.
08-CV-4289 (ARR/LB) (E.D.N.Y. Oct. 30, 2008); Declarant is not responsible for
the bias of a Judge who must recuse when favoring the Freemasons and SMOM.
17. As for the case Fitzgerald v. Kellner, No. 02-CV-926 (NAM/RFT), 2006 2/
WL 3489051 (N.D.N.Y. Dec. 1, 2006) Declarant was represented by an attorney
initially therein; and thereafter, upon an unusual error by Judge Mordue after years
was restored to the calendar, and wherein the matter complained of originally was
transformed to include very arcane New York Election Law Lock-box matters, and
allegations made by other Plaintiffs therein other than Declarant.
18. Declarant’s history as a litigant has nothing whatsoever to do with the
intervention in the matter before the Court, Mr. Amanat defends this friendly suit.
19. Declarant denies any alleged abuse and disrespect of the courts – and
particularly his continued efforts to intervene were done for sound reasons that
were based upon more than generalized grievances, and accomplished the purposes
for which intervention was intended.
20. That based upon information and belief Declarant recognizes the Fact that
Her Honor was selected as a Rhodes Scholar during the time when the Rhodes
Round-Table was an old boys club before the Sex Discrimination Act 1975 in the
-7-
United Kingdom was done away with along with another Act of Parliament to
change the Rhodes' will extended selection criteria in 1977to include women
meritoriously selected, and such is a testimonial to Judge Gershon's capabilities
and recognition by the Jesuits and Illuminati they want Her Honor on the bench in
Second Circuit rather than as a plaintiffs attorney able to challenge the status quo.
2 1.That based upon the foregoing especially the material facts of paragraphs 3
through 10 that will resolve the case herein, Declarant has an interest relating to the
subject of this action, is so situated that without intervention the disposition of the
present action may as a practical matter impair or impede his ability to protect his
interests; has shown that his interest, such as it is, is not adequately represented by
existing parties; that permissive intervention should be granted.
CONCLUSION IN REPLY 1
For the foregoing reasons, Declarant's motion to intervene as a defendant in the
case, whether as of right or by permission, should be granted along with the relief
i
requested, along with other and different relief that the Court deems necessary.
16
Dated: February - ,2010
Brooklyn New York
~%T6topher-~arl: Strunk in esse

Brooklyn, New York 11238
Email: chris@strunk.ws
Cell-845-901-6767
Christopher-Earl: Strunk In Esse DECLARATION IN SUPPORT OF
THE NOTICE OF MOTION TO INTERVENE AS A EX-RELATOR
Exhibit G
)
ASSOCIATION OF COMMUNITY )
ORGANIZATIONS FOR REFORM NOW, )
INC., et al., ) No. 09-CV-4888 (NG/LB)
Plaintiffs, )
v. ) (Gershon, J.)
) (Bloom, M.J.)
UNITED STATES OF AMERICA, et al., )
)
Defendants. )
)
NOTICE TO PRO SE LITIGANT PURSUANT TO LOCAL CIVIL RULE 7.1(C)
To: Christopher Earl Strunk, pro se

593 Vanderbilt Avenue, Apt. 281
Brooklyn, NY 11238
chris@strunk.ws
PLEASE TAKE NOTICE that Local Civil Rule 7.1(c) provides that “In cases involving
a pro se litigant, counsel shall, when serving a memorandum of law (or other submissions to
the Court), provide the pro se litigant (but not other counsel or the Court) with printed
copies of decisions cited therein that are unreported or reported exclusively on computerized
databases.” Pursuant to said rule, Defendants hereby provide you with printed copies of the
following unreported decisions which are cited in Defendants’ Memorandum of Law:
Fitzgerald v. Kellner, No. 02-CV-926 (NAM/RFT), 2006 WL 3489051 (N.D.N.Y. Dec. 1, 2006)
Green Party of New York State v. New York State Bd. of Elec., No. 02-CV-6465 (JG/SMG)
(E.D.N.Y. Apr. 2, 2003)
State Comm. of Indep. v. Berman, No. 03 Civ.4123 JSR, 2003 WL 22801908 (S.D.N.Y. Nov.
21, 2003)
Strunk v. CIA, No. 08-CV-1196 (ARR/LB) (E.D.N.Y. Mar. 27, 2008)

Strunk v. Department of Housing & Urban Dev’t, No. 99-CV-6840 (NG/MDG) (E.D.N.Y.
Apr. 3, 2001)
Strunk v. New York State Bd. of Elec., No. 08-CV-4289 (ARR/LB) (E.D.N.Y. Oct. 30, 2008)
Strunk v. New York State Ins. Fund, No. 02-CV-1273 (NG/LB) (E.D.N.Y. Mar. 20, 2002)
Strunk v. United States House of Representatives, No. 99-CV-2168 (NG/MDG) (E.D.N.Y.

June 13, 2002)
Strunk v. United States Postal Service, No. 08-CV-1744 (ARR/LB) (E.D.N.Y. May 9 and June
13, 2008)
Strunk v. United States Postal Service, No. 08-3242-cv, 2010 WL 227651 (2d Cir. Jan. 19,
2010)
Thomas v. Federal Reserve Bank, No. 07-CV-1171 (ARR/LB) (E.D.N.Y. May 29, 2007)
Torres v. New York State Bd. of Elec., No. 04-CV-1129 (JG/SMG) (E.D.N.Y. Apr. 18, 2006)
We have not included in this disclosure copies of cases reported in the Federal
Appendix which are cited in Defendants’ Memorandum. Should you not have access to that
reporter and wish to receive copies of any of the cases reported therein which are cited in
Defendants’ Memorandum, please contact the undersigned, who will arrange for printed
copies of the cases to be provided to you.
Dated: Brooklyn, New York BENTON J. CAMPBELL

February 9, 2010 United States Attorney
Eastern District of New York
Brooklyn, NY 11201-1820
By: /s/ {FILED ELECTRONICALLY}

F. FRANKLIN AMANAT (FA6117)
Assistant United States Attorney
(718) 254-6024
franklin.amanat@usdoj.gov
N O TICE PU R SU AN T TO L.C.R . 7.1(c)

ACO RN v. United States, No. 09-CV-4888 (NG/LB) 2
Dated: Washington, D.C. TONY WEST
February 9, 2010 Assistant Attorney General
Civil Division
IAN HEATH GERSHENGORN

Deputy Assistant Attorney General
MICHAEL SITCOV , Trial Attorney

PETER D. LEARY, Trial Attorney
BRADLEY H. COHEN , Trial Attorney
U.S. Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Ave., N.W., Room 7322
P.O. Box 883
(202) 514-3313
peter.leary@usdoj.gov
Attorneys for Defendants
* * * ELECTRONICALLY FILED WITHOUT ATTACHMENTS * * *

I, F. Franklin Amanat, hereby certify under penalties of perjury that on this 9th day
of February, 2010, I did cause true and correct copies of the above and foregoing instrument,
Notice to Pro Se Litigant Pursuant to Local Civil Rule 7.1(c), to be served in the manner
indicated below on the following persons:
BY FIRST CLASS MAIL (w/ ATTACHMENTS)

AND BY EMAIL (w/o ATTACHMENTS)
Christopher Earl Strunk, pro se

Brooklyn, NY 11238
chris@strunk.ws
BY ECF NOTIFICATION AND BY EMAIL

(w/o ATTACHMENTS)
Darius Charney, Esq.

Center for Constitutional Rights
dcharney@ccrjustice.org

(718) 254-6024

)
ASSOCIATION OF COMMUNITY )
ORGANIZATIONS FOR REFORM NOW, )
INC., et al., ) No. 09-CV-4888 (NG/LB)
Plaintiffs, )
v. ) (Gershon, J.)
) (Bloom, M.J.)
UNITED STATES OF AMERICA, et al., )
)
Defendants. )
)
DEFENDANTS’ MEMORANDUM OF LAW

IN OPPOSITION TO MOTION OF NON -PARTY CHRISTOPHER STRUNK
FOR INTERVENTION PURSUANT TO FED . R. CIV . P. 24
TONY WEST BENTON J. CAMPBELL

Assistant Attorney General United States Attorney
Civil Division Eastern District of New York

MICHAEL SITCOV F. FRANKLIN AMANAT (FA6117)

PETER D. LEARY Assistant United States Attorney
BRADLEY H. COHEN 271 Cadman Plaza East
Trial Attorneys Brooklyn, NY 11201-1820
United States Department of Justice (718) 254-6024
Civil Division, Federal Programs Branch franklin.amanat@usdoj.gov
P.O. Box 883
Washington, D.C. 20044
(202) 514-3313
February 9, 2010
PRELIMINARY STATEMENT
Christopher Strunk, a pro se non-party to this action, is a frequent filer in this and
other federal courts. The vast majority of the proceedings he has initiated, whether by
complaint or by motion to intervene, have been dismissed as frivolous. On January 10, 2010,
he filed a “Notice of Motion to Intervene as a Ex-Relator Intervener-Defendant U.S.A. Citizen
and State of New York Citizen,” accompanied by a 14-page affidavit in support. While this
affidavit is difficult to follow and contains a good deal of “immaterial, impertinent, or
scandalous matter,” Fed. R. Civ. P. 12(f), its gist appears to be that Strunk wishes to intervene
because he does not have confidence that the governmental defendants will adequately
defend against ACORN’s challenges to the constitutionality of the funding suspension
provisions at issue and because he wants to move to dismiss the complaint.
Strunk’s motion should be denied as without merit. It meets neither the
requirements for intervention as of right, Fed. R. Civ. P. 24(a), nor the requirements for
permissive intervention. Fed. R. Civ. P. 24(b).
BACKGROUND
1. PROCEDURAL BACKGROUND
This case originated on November 12, 2009, when plaintiffs ACORN et al. filed a
complaint asserting a constitutional challenge – on bill of attainder, due process, and First
Amendment grounds – to section 163 of Division B of Pub. L. No. 111-68, the Continuing
Appropriations Resolution, 2010 (reported at 123 Stat. 2023, 2053 (2009) and hereinafter cited
as “Section 163"). See Complaint, docket no. 1. On December 11, 2009, this Court entered an
MEMORANDUM OF LAW IN OPPOSITION TO MOTION FOR INTERVENTION

ACORN v. United States, No. 09-CV-4888 (NG/LB) 1
Opinion and Order (docket nos. 9 and 10, hereinafter “Preliminary Injunction Order”)
granting ACORN’s motion for a preliminary injunction and barring the government from
enforcing Section 163. The government filed a notice of appeal from this decision on
December 16, 2009, and on the same day moved this Court for reconsideration of the
Preliminary Injunction Order. See docket nos. 11 and 12.
On December 15, 2009 – the day before the government filed its notice of appeal
and motion for reconsideration – the parties received copies of correspondence sent to the
Court by pro se movant Strunk. This correspondence, which was docketed on December 22
as no. 23, purported to request a premotion conference in anticipation of Strunk’s filing a
motion for intervention; according to the letter, Strunk wished to intervene as a defendant
in the case so that he could appeal from the Preliminary Injunction Order. The government
responded to Strunk’s letter on December 21 (docket no. 22), asking the Court to deny
Strunk’s request for a premotion conference, chiefly on the grounds that any motion for
intervention would be frivolous, and that Strunk’s intervention was in any event unnecessary
because the government had itself noticed an appeal from the Preliminary Injunction Order.
On December 22, 2009, the Court heard argument (see docket nos. 18, 26) on the
government’s motion for reconsideration of the Preliminary Injunction Order, as well as on
ACORN’s cross-motion (see docket no. 15) to expand the Preliminary Injunction Order to
enjoin five provisions in FY2010 appropriations acts which were enacted after the filing of the

initial complaint.1/ Strunk was present at the December 22 hearing. The Court informed
Strunk that, because he is pro se, he is not required to request a premotion conference under
the relevant Individual Practice Rules and could proceed to file a motion to intervene in the
case should he desire. The Court reminded Strunk, however, that even as a pro se litigant he
must comply with the Federal Rules of Civil Procedure, including Rule 11, and admonished
Strunk to be aware of his obligations under those Rules should he choose to file any motion.
On January 20, 2010, Strunk filed a motion to intervene in this case as a defendant,
along with an affidavit in support. By that time, ACORN had filed an amended and second
amended complaint, as well as a motion for preliminary and permanent injunction and for
a declaratory judgment. See docket nos. 19, 28, 29, 33. The government had, in the
meantime, filed a motion to vacate the Preliminary Injunction Order, and it has since moved
to dismiss the second amended complaint or in the alternative for summary judgment. See
docket nos. 25, 31, 38, 39. The Court directed the parties to respond to Strunk’s intervention
motion by February 9. See docket no. 35.
2. FACTUAL BACKGROUND
As best as can be discerned, Strunk’s purpose in seeking to intervene is to move
to dismiss plaintiffs’ complaint on a variety of grounds and possibly also to implead the State
of New York as a party. Strunk Decl. ¶ 17. The factual basis for Strunk’s motion to intervene
is not entirely clear. Although his Affidavit in support of his motion to intervene is largely
1/
In a Memorandum and Order entered that same date, the Court denied both the government’s
motion for reconsideration and ACORN’s cross-motion to modify and directed the parties to file new pleadings
and motions. See docket no. 24.

unintelligible, Paragraphs 4 through 7 and 9 through 12 appear to set forth summaries of the
litigation Strunk has brought in various courts, with paragraph 4 containing a notation to the
effect that the present case is a “related case” to Strunk’s other litigation.
In paragraph 8, Strunk seems to allege that ACORN has maintained “close partisan
political dealing” with the State Senator against whom Strunk campaigned in 2008 and that
ACORN engaged in illegal lobbying efforts which he believes should be investigated by the
Kings County District Attorney. He also alleges in paragraphs 11 and 12 that ACORN is the
“subject” of an election law case he is pursuing in Kings County State Supreme Court by
virtue of that organization’s “close dealing with the Brooklyn Democratic Party et al.” In
paragraphs 13 and 14, Strunk cryptically repeats his allegations regarding ACORN’s
involvement in unlawful lobbying activities before various State agencies and entities.
The crux of Strunk’s intervention claim appears to be set forth in paragraph 15 of
his Affidavit. There, he seems to express the view that the governmental defendants have
secretly conspired with ACORN and its affiliates to continue a flow of government funds to
ACORN notwithstanding the suspension provisions; this circumstance, he states, precludes
his trust in the defendants to adequately defend the challenged provisions and puts him, as
a citizen of the United States and of New York who has previously litigated claims that were
opposed to ACORN’s interests, in a superior position to defend the challenged statutes:
Affirmant has an interest relating to the property or transaction that is

the subject of the action in that the Usurper Barack Hussein Obama’s
impropriety as the prior attorney to ACORN and its affiliates in
affiliation with SEIU and crony Eric Holder, who are all part of a
continuing enterprise that have maliciously orchestrated a friendly
constitutional tort herein to: circumvent due administrative process

under existing contracts, pre-empt public fiduciary duty to perform
substantive due process and oversight required under statutes . . . .
Strunk Aff. ¶ 15(b). He argues that his interest is not adequately represented by the existing
parties because “the Usurper’s Attorney General and or his agents have not vigorously
represented U.S.A. Citizen, the State of New York Citizen or any other State’s citizen of the
several states . . . in that the necessary Affirmative defense to the Complaint and counter
claims have not been entered into the record.” Id. ¶ 15(d). Elsewhere, he seems to suggest
that because he has sued the federal government in other cases (and lost), he “was injured
by Eric Holder directly, [who] is hostile to Affirmant; and therefore, his agents, no matter
how great an assistant attorney general they may otherwise be, can’t possibly represent my
interests herein.” Id. ¶ 21.
Strunk is a “frequent filer” in this and other Courts, with a long history of
commencing litigation against federal and state agencies. The vast majority of his
proceedings have been dismissed as frivolous. PACER shows at least 27 cases involving
Strunk in the last ten years, at least ten of which have been in this District. In one recent
case, Judge Ross dismissed the bulk of Strunk’s claims under 28 U.S.C. § 1915(e)(2)(B), finding
that the facts alleged “rise to the level of the irrational or the wholly incredible . . . and that
there is no legal theory on which he may rely.” Strunk v. CIA, No. 08-CV-1196 (ARR/LB)
(E.D.N.Y. Mar. 27, 2008) (docket no. 4). See also Thomas v. Federal Reserve Bank, No. 07-CV-
1171 (ARR/LB) (E.D.N.Y. May 29, 2007) (dismissing Strunk’s complaint as frivolous and
denying IFP status for purposes of appeal); Strunk v. United States Postal Service, No. 08-CV-
1744 (ARR/LB) (E.D.N.Y. May 9 and June 13, 2008) (same), aff’d, No. 08-3242-cv, 2010 WL

227651 (2d Cir. Jan. 19, 2010); Strunk v. New York State Bd. of Elec., No. 08-CV-4289 (ARR/LB)
(E.D.N.Y. Oct. 30, 2008) (same).2/
Indeed, your Honor repeatedly dismissed Strunk’s seriatim motions as frivolous,
and ultimately dismissed the complaint as devoid of merit, in Strunk v. United States House
of Representatives, No. 99-CV-2168 (NG/MDG) (E.D.N.Y. June 13, 2002), aff’d, 68 Fed. Appx.
233 (2d Cir. June 23, 2003) (“The District Court properly dismissed Strunk's third amended
complaint and properly denied his motion to file a fourth amended complaint, as his
complaint was unintelligible and his claims indiscernible. In each of his complaints, Strunk
asserted violations of several federal statutes and eleven constitutional amendments, without
explaining what conduct constituted the violations, which defendants violated which statutes
or amendments, or how the alleged violations harmed him.”). See also Strunk v. Department
of Housing & Urban Dev’t, No. 99-CV-6840 (NG/MDG) (E.D.N.Y. Apr. 3, 2001) (sua sponte
dismissing claims for failure to comply with Fed. R. Civ. P. 8); Strunk v. New York State Ins.
Fund, No. 02-CV-1273 (NG/LB) (E.D.N.Y. Mar. 20, 2002) (sua sponte dismissing complaint as
frivolous under 28 U.S.C. § 1915(e)(2) and denying IFP status for purposes of appeal), aff’d,
47 Fed. Appx. 611 (2d Cir. 2002).
Strunk has also filed motions to intervene in a number of other cases. Two such
motions in this Court have been denied as frivolous. See, e.g., Torres v. New York State Bd.
of Elec., No. 04-CV-1129 (JG/SMG) (E.D.N.Y. Apr. 18, 2006) (denying motion to intervene, and
2/
See also Fitzgerald v. Kellner, No. 02-CV-926 (NAM/RFT), 2006 W L 3489051 (N.D.N.Y. Dec. 1,
2006) (dismissing complaint brought by Strunk under Rule 8 “because, inter alia, it was prolix, confusing, and
placed too heavy a burden on defendants and the Court to discern the claim s plaintiffs asserted”).

subsequently (on Feb. 13, 2007), denying IFP status for Strunk’s appeal), aff’d, 300 Fed. Appx.
106 (2d Cir. Nov. 19, 2008); Green Party of New York State v. New York State Bd. of Elec., No.
02-CV-6465 (JG/SMG) (E.D.N.Y. Apr. 2, 2003) (same). Another motion to intervene filed by
Strunk was rejected by a three-judge district court in part because it would “cause undue
distraction, delay and prejudice to the parties and to the Court in the adjudication” of the
underlying cases. Rodriguez v. Pataki, 211 F.R.D. 215, 219 (S.D.N.Y. 2002) (three judge court).
Strunk’s appeal from the denial of his motion to intervene in another case was rejected
because he “allege[d] little more than an abstract interest in the democratic process in New
York State” and failed to show a “direct, substantial, and legally protectable interest in the
litigation.” Person v. New York State Bd. of Elec., 467 F.3d 141, 144 (2d Cir. 2006). See also
Kunz v. New York State Comm’n on Judicial Misconduct, 155 Fed. Appx. 21, 22 (2d Cir. Nov.
8, 2005) (rejecting Strunk’s appeal from denial of motion to intervene because Strunk
asserted only a general interest in the efficient regulation of judicial conduct); Strunk v. Green
Party of New York State, 144 Fed. Appx. 917 (2d Cir. Oct. 5, 2005); State Comm. of Indep. v.
Berman, No. 03 Civ.4123 JSR, 2003 WL 22801908 (S.D.N.Y. Nov. 21, 2003) (denying Strunk’s
motion to intervene).
ARGUMENT
I. STANDARD FOR INTERVENTION
Under Fed. R. Civ. P. 24, a non-party may be allowed to intervene as a party in an
existing lawsuit, either as of right or by permission. Intervention as of right is governed by
Rule 24(a), which provides that, unless a right to intervene is unconditionally granted by

federal statute, a non-party has no right to intervene in a case as a plaintiff or defendant
unless it shows that (1) its motion to intervene was timely filed; (2) it has an interest relating
to the property or transaction that is the subject of the action; (3) it is so situated that
without intervention the disposition of the action may as a practical matter impair or impede
its ability to protect its interest; and (4) its interest is not adequately represented by existing
parties. See Fed. R. Civ. P. 24(a); Butler, Fitzgerald & Potter v. Sequa Corp., 250 F.3d 171, 176
(2d Cir. 2001). “All four parts of the test must be satisfied to qualify for intervention as of
right.” Washington Elec. Coop., Inc. v. Massachusetts Municipal Wholesale Elec. Co., 922 F.2d
92, 96 (2d Cir. 1990); accord D’Amato v. Deutsche Bank, 236 F.3d 78, 84 (2d Cir. 2001) (“Denial
of the motion to intervene is proper if any of these requirements is not met”); United States
v. New York, 820 F.2d 554, 556 (2d Cir. 1987). “The moving party has the burden of
demonstrating its entitlement to intervene.” Seils v. Rochester City Sch. Dist., 199 F.R.D. 506,
509 (W.D.N.Y. 2001).
Permissive intervention is governed by Rule 24(b), which provides that, unless a
right to intervene is conditionally granted by federal statute, a court may not exercise its
discretion to permit a non-party to intervene in an action unless the non-party shows that
its “claim or defense . . . shares with the main action a common question of law or fact.” Fed.
R. Civ. P. 24(b)(1)(B). “The district court has broad discretion to deny an applicant’s motion
for intervention under Rule 24(b).” Seils, 199 F.R.D. at 512 (citation omitted). In exercising
this discretion, “the court shall consider whether the intervention will unduly delay or
prejudice the adjudication of the rights of the original parties.” Fed. R. Civ. P. 24(b)(3). The

Court also may consider “the nature and extent of the intervenor’s interests, whether the
intervenor’s participation will contribute to a just and equitable adjudication of the issues,
and whether the intervenor’s [interests] are adequately represented by the parties of record.”
Sharif v. New York State Educ. Dep’t, 709 F. Supp. 365, 369 (S.D.N.Y. 1989) (citation omitted);
Seils, 199 F.R.D. at 513.
II. STRUNK MAY NOT INTERVENE AS OF RIGHT.
Strunk cannot satisfy the second, third, or fourth requirements of Rule 24(a) for
of right intervention. Because he must satisfy all four requirements to prevail, his motion
must be denied. See D’Amato, 236 F.3d at 84; United States v. New York, 820 F.2d at 556.
A. Strunk Has No Interest Relating to the Subject of This Action.
The second requirement of Rule 24(a) is that he must demonstrate “an interest
relating to the property or transaction that is the subject of the action.” Fed. R. Civ. P. 24(a);
Butler, Fitzgerald & Potter, 250 F.3d at 176. The transaction that is the subject of the present
action is the appropriations legislation passed by Congress in the fall of 2009 which
suspended the flow of federal funds to ACORN and its affiliated organizations pending the
completion of a government-wide investigation. Strunk has failed to demonstrate, whether
in his Affidavit or otherwise, any bona fide individualized interest relating to this legislation.
For example, he nowhere alleges that he has ever been involved in any way with federal
funding for ACORN, that he has ever had a contract with ACORN or with the federal
government, that he has ever competed with ACORN for the receipt of federal funds, or that

he had any involvement in the enactment of the funding suspension legislation that is
currently under challenge.
As best as can be ascertained from his Affidavit, the interest on which he relies is
his desire to move to dismiss plaintiffs’ complaint on a variety of grounds and possibly also
to implead the State of New York as a party – essentially, to ensure that the suspension
provisions remain in force and that funding to ACORN does not resume. Strunk Decl. ¶ 17.
He also expresses an inchoate wish that ACORN be prosecuted in some fashion, by some
governmental authority, for its alleged bad acts. Id. ¶ 15(b). However, in order to claim a
“judicially cognizable ‘injury in fact,’ an intervenor must have a direct stake in the outcome
of a litigation rather than a mere interest in the problem.” Schulz v. Williams, 44 F.3d 48, 52
(2d Cir. 1994) (quotes and citations omitted); see also Brennan v. New York City Bd. of Educ.,
260 F.3d 123, 128 (2d Cir. 2001) (“[F]or an interest to be cognizable under Rule 24(a)(2), it
must be direct, substantial, and legally protectable.”). A general desire, as a citizen, to ensure
or to promote compliance with constitutional requirements, or to procure the prosecution
of bad actors, is a plainly insufficient interest to support intervention as of right. See, e.g.,
United States v. Peoples Benefit Life Ins. Co., 271 F.3d 411, 415 (2d Cir. 2001); Washington Elec.
Coop., 922 F.2d at 97.3/
3/
The Supreme Court has not resolved the question whether a party seeking to intervene under
Rule 24(a) m ust satisfy the requirements of Article III of the Constitution. See Diamond v. Charles, 476 U.S. 54,
68-69 (1986) (citing cases from Courts of Appeals for the Seventh, Eighth, Ninth, and District of Columbia
Circuits). And the Second Circuit has held that a prospective intervenor need not satisfy Article III standing
requirements m erely to participate in district court proceedings. United States Postal Serv. v. Brennan, 579 F.2d
188, 190 (2d Cir. 1978). Nevertheless, an intervenor’s interest must “be direct, substantial, and legally
protectable.” New York News, Inc. v. Kheel, 972 F.2d 482, 486 (2d Cir. 1992) (citation and quotation om itted).
Strunk cannot satisfy this requirement because he has no more than a generalized interest in this matter that
could be shared by any citizen. Cf. Schlesinger v. Reservists Comm. to Stop the War, 418 U.S. 208, 220-21 (1974).

In fact, Strunk’s efforts to intervene in other cases have repeatedly been rejected
on this very ground. See, e.g., Person, 467 F.3d at 144(Strunk’s appeal from the denial of his
motion to intervene rejected because he “allege[d] little more than an abstract interest in the
democratic process in New York State”); Kunz, 155 Fed. Appx. at 22 (rejecting Strunk’s appeal
from denial of motion to intervene because Strunk asserted only a general interest in the
efficient regulation of judicial conduct).
Any interests which may be discerned from Strunk’s Affidavit with respect to
ACORN are entirely collateral to the present litigation and therefore cannot be said to relate
to the transaction that is the subject of the action. See Rodriguez, 211 F.R.D. at 218 (“Mr.
Strunk does not have a ‘stake’ in these claims. Mr. Strunk’s challenge arises from an entirely
different (even if difficult to discern) legal theory which embraces alleged violations of the
Immigration and Naturalization Act . . . . While Mr. Strunk may have a global interest in
election issues, he has alleged little or no interest in the Constitutional and Voting Rights Act
claims raised in this case.”). Strunk therefore cannot satisfy the second requirement of Rule
24(a), and his motion for intervention as of right should be denied.
Accordingly, his motion to intervene should be denied. In addition, to the extent Strunk’s interest in
intervening consists of a desire to appeal from the Preliminary Injunction Order, he cannot satisfy the standing
requirem ents of Article III: “To maintain standing to appeal, an intervenor must have suffered an injury in fact
that is fairly traceable to the challenged action and that is likely to be redressed by the relief requested.” Schulz
v. Williams, 44 F.3d 48, 52 (2d Cir. 1994).

B. Strunk is Not So Situated that Without Intervention the Disposition
of the Present Action May as a Practical Matter Impair or Impede His
Ability to Protect His Interests.
Nor can Strunk satisfy the third requirement of Rule 24(a). As noted above, Strunk
is an extremely litigious individual who has filed numerous lawsuits in this and other courts.
Strunk attempts to argue in his Affidavit that the present litigation is somehow vaguely
“related to” his other cases (see Strunk Aff. ¶¶ 4-7, 9-12), but he has failed to explain how this
Court’s disposition of the question before it – whether Congress has the constitutional
authority to enact appropriations legislation which temporarily suspends ACORN’s access
to federal funding while a government-wide investigation takes place – could possibly impair
or impede his ability to protect or pursue whatever interests he believes he is advancing with
his other cases. Nor has he articulated how this Court’s disposition of that legal issue could
as a practical matter affect his electoral ambitions or the pursuit of his political agenda.
Strunk fares no better with his opaque allegations that he is somehow injured by
virtue of ACORN’s alleged “close partisan political dealings” with the Brooklyn Democratic
Party or with the State Senator against whom he campaigned in 2008, or by ACORN’s alleged
involvement in illegal lobbying efforts. See Strunk Aff. ¶¶ 8, 11, 12, 13, 14. These allegations
have nothing to do with ACORN’s receipt of the federal funding that was suspended by the
legislation at issue here. If Strunk was genuinely injured by ACORN’s activities in this regard,
the injury would have taken place regardless of whether ACORN received federal funding,
and the disposition of the present litigation would in no way impede Strunk’s ability to
pursue available remedies for such injuries in the appropriate fora. See, e.g., Rodriguez, 211

F.R.D. at 218 (“Mr. Strunk also fails to identify any interest of his that might be impaired by
the disposition of this action. Since the issues do not coincide, whatever the outcome of this
litigation, Mr. Strunk is free to bring an independent action. As noted, Mr. Strunk is already
party to a number of other election cases.”).
C. Strunk Has Not Shown that His Interest, Such as It Is, Is Not
Adequately Represented by Existing Parties.
Strunk’s motion for intervention as of right is equally doomed under the fourth
prong of Rule 24(a). Strunk essentially argues that he does not trust the governmental
defendants to fully defend the constitutionality of the funding suspension provisions because
of an alleged secret conspiracy between the government and ACORN that has its genesis in
the President’s alleged former relationship with that organization. Strunk Aff. ¶ 15(b), 15(d).
He also seems to suggest that because he has sued the federal government in other cases (and
lost), he cannot rely on the Department of Justice to represent his interests. Id. ¶ 21. Even
if these arguments were not patently predicated on fanciful and fantastic speculation, they
would border on folly given the considerable lengths to which the government has already
gone to defend the constitutionality of the challenged statutes – including its notice of appeal
from the Preliminary Injunction Order, its motion to vacate that order, and its motion to
dismiss the Second Amended Complaint or in the alternative for summary judgment.
Indeed, it is obvious that Strunk’s participation in the suit is not remotely necessary, because
the government has shown itself more than willing and able to respond to plaintiffs’ claims.

Because Strunk has failed to meet his burden of demonstrating an entitlement to
intervene, his motion under Rule 24(a) must be denied. Seils, 199 F.R.D. at 509.
III. PERMISSIVE INTERVENTION SHOULD BE DENIED .
A court may not exercise its discretion to permit a non-party to intervene in an
action unless the non-party shows that its “claim or defense . . . shares with the main action
a common question of law or fact.” Fed. R. Civ. P. 24(b)(1)(B). As elaborated in Part II,
Strunk has failed to intelligibly articulate any legitimate, individualized claim or defense
relating to ACORN, much less one which shares a common question of law or fact with this
case. On this ground alone, his claim for permissive intervention must be denied.
Moreover, in exercising its broad discretion under Rule 24(b), a court considers
“the nature and extent of the intervenor’s interests, . . . and whether the intervenor’s
[interests] are adequately represented by the parties of record.” Sharif v. New York State
Educ. Dep’t, 709 F. Supp. 365, 369 (S.D.N.Y. 1989) (citation omitted); Seils, 199 F.R.D. at 513.
The arguments set forth in Part II with respect to why intervention as of right should be
denied thus apply with equal force to permissive intervention: Strunk’s interests, if any, are
vague, generalized, and collateral, and he has no basis to argue that those interests (such as
they are) are not adequately represented by the parties of record.
Permissive intervention also implicates “whether the intervention will unduly delay
or prejudice the adjudication of the rights of the original parties,” Fed. R. Civ. P. 24(b)(3), or,
put otherwise, “whether the intervenor’s participation will contribute to a just and equitable
adjudication of the issues.” Sharif, 709 F. Supp. at 369. Setting aside the arguments already

made above, a cursory perusal of Strunk’s submission demonstrates why permissive
intervention is not conducive to a just and equitable adjudication of the important issues in
this case. Strunk’s affidavit is largely unintelligible, and it contains a good deal of
“immaterial, impertinent, or scandalous matter” that should be stricken under Fed. R. Civ.
P. 12(f), such as repeated inappropriate references to the President of the United States as the
“Usurper.” Many of the factual allegations in the affidavit, in addition to being wholly
irrelevant to the issues before the Court, are wildly speculative and grounded either in absurd
conspiracy theories or in Strunk’s political agenda. Strunk in no wise suggests that he
possesses factual evidence, not otherwise available to the parties, that would aid the Court
in its disposition of the legal issues before it; nor does he advance a single non-frivolous legal
theory that the Court must address in order to assess the claims and defenses of the parties.
Strunk’s history as a litigant who has repeatedly filed baseless court cases should
also be considered by the Court as it assesses whether to exercise its discretion in favor of
permissive intervention. The vast majority of his proceedings have been dismissed as
frivolous, courts often having found that his allegations “rise to the level of the irrational or
the wholly incredible . . . and that there is no legal theory on which he may rely.” Strunk v.
CIA, No. 08-CV-1196 (ARR/LB) (E.D.N.Y. Mar. 27, 2008) (docket no. 4). His motion and
supporting affidavit in this case are equally irrational and incredible, and fail to articulate any
viable legal theory. Like his submission in this case, his complaints have repeatedly been
characterized as “unintelligible,” his claims “indiscernible.” Strunk v. United States House of
Representatives, 68 Fed. Appx. 233 (2d Cir. June 23, 2003). Moreover, his motions for

intervention have almost uniformly been rejected as frivolous, courts observing that his
participation in the cases would, as it would here, “cause undue distraction, delay and
prejudice to the parties and to the Court.” Rodriguez, 211 F.R.D. at 219. Strunk’s repeated
abuse and disrespect of the courts – and particularly his continued efforts to intervene in
cases based on generalized grievances, even after having been told by other courts that such
grievances are not sufficient to support intervention – does not warrant an exercise of
permissive discretion in his favor.
Far from contributing to a just and equitable adjudication of the issues in this case,
Strunk’s intervention would be likely to distract both the Court and the parties with frivolous
and tendentious litigation over collateral and inconsequential matters. It should be denied.
CONCLUSION
For the foregoing reasons, Strunk’s motion to intervene as a defendant in the case,
whether as of right or by permission, should be denied.
Dated: Brooklyn, New York BENTON J. CAMPBELL

February 9, 2010 United States Attorney
Brooklyn, NY 11201-1820

(718) 254-6024
franklin.amanat@usdoj.gov
... (continued)

Dated: Washington, D.C. TONY WEST
February 9, 2010 Assistant Attorney General
Civil Division

MICHAEL SITCOV , Trial Attorney

PETER D. LEARY, Trial Attorney
BRADLEY H. COHEN , Trial Attorney
U.S. Department of Justice
Civil Division, Federal Programs Branch
P.O. Box 883
(202) 514-3313
Attorneys for Defendants

I, F. Franklin Amanat, hereby certify under penalties of perjury that on this 9th day
of February, 2010, I did cause true and correct copies of the above and foregoing instrument,
Defendants’ Memorandum of Law in Opposition to Motion of Non-Party Christopher
Strunkfor Intervention Pursuant to Fed. R. Civ. P. 24, to be served in the manner indicated
below on the following persons:
BY FIRST CLASS MAIL AND BY EMAIL
Christopher Earl Strunk, pro se

Brooklyn, NY 11238
chris@strunk.ws
BY ECF NOTIFICATION AND BY EMAIL
Darius Charney, Esq.

dcharney@ccrjustice.org

F. FRANKLIN AMANAT
(718) 254-6024

Exhibit H
UNlTED STATES DISTRICT COURT
EA!XERN DKlWCL''OF NEW YORK
ASSOCIATION OF COMMUNITY
ORGANIZATIONS FOR REFORM NOW;
ACORN INSTITUTE, MC.;and ClVILACnUNNUMBER
MHANY MANAGFMENT, INC,WaNEW YORK
1 ACORN HOUSING COMPANY, INC, m ~ @ w . -
. ,
PlainaifEs
versus
%; &:%%: - 3 q - . -< . -.,= **.-&++
, . -- - ..
~ & A T E S G AMERICA;
F +" -- + -
-
SHAUN DONOVAN, Secretary of the Department

of Housing and Urban Development;
PETER ORSZAG, h t o r ,
Office of Management and Budget;
TIMOTHY GEITHNER, Secretary of the
Department of Treasury of the United States;
LISA B. JACKSON, Administrator of the Envbmental
Protection Agency, GARY LOCKE,Serretary of
Commerce;and ROBERT GATES, Secretary of De6mse
I Defendants
PLATNTIFWS MEMORANDUM OF LAW IN OPPOSITION TO MOTION OF NON-

PARTY CHRISTOPHER STRUNK TO INTERVENE PURSUANT TO F.RC.P. 24
Plaintiffs hereby join in and incorporateby refixmceDefendants' Memorandum of Law

'----. 2-g?
in Oppositibn to Motion of Nm-Party Christophei S
-.-*
&-Or
~011Purswutdo
-
Fed.RCiv.P. 24 @kt # 40), except to the extent to which Defendants chamcterhthe legal
question before the Court in this litigation as "whether Congress has the constitutional authority
to enact appropriations legislation which temporarily suspends ACORN'S acoess to federal
funding while a government-wide investigationtakes place." See Defi' Mem. @kt # 40) at 12.
Plaintiffs submit that Defendants' description of the legal question befbre this Court severely
rnischaracterizes the nature of the ACORN funding bans which Plain- are chalIenging in this
action as well as the relationship between such bans and government investigations of ACORN
and ACORN-affiliatdorganhatiom.
Dated: New York, New York

February 9,201 0
Respectfullysubmitted,
---a
By:
-
Darius Charney (DC1619)
William Quigley (Legal Director)
666 Broadway, 7th Floor
New York, NY 10012
Tel.: (2 12) 614-6475; (212) 614-6427
Fax: (2 12) 614-6499
CCR Cboperating Attorneys
Jules Lobel (admitted in NY & this court JL8780)

3900 Forbes Avenue
Pittsburgh, PA 15260
Goodman & Hurwitz, P.C.

William Goodman (admitted in NY &this court
WG1241)
Julie H. Hurwitz
1394 East Jefferson
Detroib wchigaq48207
313.567.6170
Arthur Z. Schwartz (A252683)

275 Seventh Avenue
New York, N Y 10001
I, Darius Chamey, hereby certify under penalty of perjury that on this day of
February, 2010, I did cause true and correct copies of the above and foregoing to
instrument, Plaintiffs' Memorandum of Law in Opposition to Motion of Non-Party
Christopher Strunk to Intervene Pursuant to F.R.C.P.24, to be sewed in a manner
indicated below on the following persons:
BY FIRST CLASS MAIL AND EMAIL

Christopher Earl Stnmk, pro se
539 Vanderbilt Ave, Apt 281
Brooklyn, NY 11238
chris@strunk.ws
-- .- -up -
BY ECF NOTIFICATION
F. Franklin Arnanat .
Eastern District of New Yo*
firanklin.amanat@,usdoi.~ov
Peter Leary
U.S.Department of Justice
Civil Division
Federal Programs Branch
peter.leary@doi .nov
kb*Chamey u
w. . - w

666 Broadway,'7 Floor
New York, 10012
(2 12) 614-6475
dcharney@,,ccriustice.org
Exhibit I
Christopher-Earl: Stnmk in esse
Email: chris@stnmk.ws
Cell-845-901-6767
The Honorable Royce C. Lamberth

United States District Chief Judge for the
333 Constitution Avenue, NW,
Re: Taitz v. Obama DCD 10-cv-00151 and related case
Strunk v. DOS et aI. DCD 08-c~-2234(RJL)
Subject: Request for permission to transfer with the 28 USC 8 1407
The Multidistrict matter ACORN et al. v. U.S.A. et d.
EDNY 09-cv-4888 (NG) with demand for Quo Warranto
inquest of Barack Hussein Obama (a.k.a Barry Soetoro).
The Honorable Chief Judge Lamberth,
I am the Petitioner, Christopher-Earl: Strunk in esse, with the pending motion to

intervene herein as a ex-relator Plaintiff from the related case before U.S. District Judge Richard
J. Leon. Judge Leon ordered a stay of discovery pending a decision on my Quo Warranto
demand for an inquest of multi-allegiance facts associated with the August 4,1961 birth of
Barack Hussein Obama Jr., a.k.a. Barry Soetoro (the Usurper).and make this statement under
penalty of perjury pursuant to 28 USC $1746. Declarant is self-represented in the above civil
actions on-going in Washington District of Columbia, and hereby request permission to transfer
with the 28 USC $1407 the matter ACORN et al. v. U.S.A. et al. EDNY 09-cv-4888 presently
before Judge Nina Gershon when my Motion to intervene there is decided by that Court in that
as I argue there on January 23,2009 I duly fired the Defendant Obama because He is unqualified
to act with mypower of attorney because He has dual allegiance at birth by his own admission
and his actions are void ab initio; and therefore, with dual allegiance ineligible to hold the office
of President according to U.S. Constitution Article IT Section 1, is not a natural-born-citizen
without two U.S. Citizen parents on his birth August 4, 1961. Of importance to the Plaintiff
herein, I concur with an expedited inquest schedule requested by Dr. Taitz on facts filed before
this Court that prove the Defendant has committed a fraud that personally injured She and me.
I am familiar with the facts associated with the referenced cases as each are
related and subject to the transfer here as an urgent matter of National Security before this Court
and that the U.S. Government has argued that any Quo Warranto be done in Washington District
of Columbia and I urge herein applies with a Multi-district Judicial Panel accordingly. A copy of
this request has been sent to Counsels and Court in both case
Date: February&, 2010

Brooklyn New York
cc: Judge R i c b d 4. L h
Judge Nina Gershon . .
United States District Courts
Eastern District of New York In Case – ACORN et al. v. U.S.A. et al. EDNY 09-cv-4888
Washington District of Columbia In Case – Taitz v. Obama DCD 10-cv-00151
Washington District of Columbia In Case – Strunk v. DOS et al. DCD 08-cv-2234
On February 17, 2010, I, Christopher Earl Strunk, declare and certify under penalty of perjury
pursuant to 28 USC §1746: That I caused the service of Nine (9) copies of the Christopher-Earl:
Strunk in esse Request for permission to transfer with the 28 USC §1407 The Multidistrict matter
ACORN et al. v. U.S.A. et al. EDNY 09-cv-4888 (NG) declared February 16, 2010, with exhibits
annexed and that each set was placed in a sealed folder properly addressed with proper postage for
United States Postal Service Delivery by mail upon:
The Honorable Nina Gershon Andrew Cuomo New York State Attorney
United States District Judge for the General 120 Broadway 24th Floor New York
U.S.D.C. for the Eastern District of New York New York 10271
Brooklyn New York 11207 Channing Philips, the U.S. Attorney
c/o Wynne P. Kelly, AUSA
U.S. District for the District of Columbia 555 4th St., N.W.
Dr. Orly Taitz, D.D.S. c/o Brigham John Bowen, AUSA
29839 Santa Margarita Parkway, STE 100 U.S. DEPARTMENT OF JUSTICE
Rancho Santa Margarita CA 92688 20 Massachusetts Avenue, NW
Constitutional Rights 666 Broadway, 7th Barack Hussein Obama in esse
Floor New York, NY 10012 c/o The White House
I do declare and certify under penalty of perjury:
Dated: February ____, 2010

Brooklyn New York _____________________________
593 Vanderbilt Avenue #281
Email: chris@strunk.ws Ph: 845-901-6767
Exhibit J
FOR THE DISTRICT OF COLUMBIA
............................................................... X
Dr. Orly Taitz, PRO SE §
29839 Santa Margarita Parkway, STE 100 5
Rancho Santa ~argaritaCA 92688 §
Tel: (949) 683-541 1; Fax (949) 766-7603 Civil Action: 10-CV-00151
E-Mail: dr taitz@vahoo.com § (RCL)
§
Plaintiff, §
v. §
§
Barack Hussein Obama, §
C/OThe White House §
1 600 Pennsylvania Avenue, N.W. 8
Washington, District of Columbia 2 0 5 0 0 §
Defendant.
i
--
CHRISTOPHER-EARL: STRUNK IN ESSE NOTICE OF MOTION TO INTERVENE
AS A EX-RELATOR INTERVENER-PLAINTIFF.
PLEASE TAKE NOTICE that upon the annexed affidavit of Christopher-Earl : Strunk, by
Special-Appearance, affirmed January 29,20 10 will move this Court to intervene as a ex-relator
intervener-plaintiff before Chief District Judge Royce C. Lemberth at time afforded by the
Court if necessary at the United States Courthouse, at 333 Constitution Avenue NW Washington
District of Columbia, on the day and month in 2010, at a time and courtroom designated by the
court, or as soon thereafter as counsel can be heard.
29
Dated: J a n u a r y , 2010
Brooklyn New Yor i
Brooklyn, New York 1 1238

Email: chris@strunk.ws
Cell-845-90 1-6767
Christopher-Earl: Strunk O in esse
cc: listing of service to follow

The Honorable Richard J. Leon
United States District Judge for the
333 Constitution Avenue, NW, Room 6315,
Dr. Orly Taitz, D.D.S.

29839 Santa Margarita Parkway, STE 100
Rancho Santa Margarita CA 92688
Channing Philips, the U.S. Attorney

c/o Wynne P. Kelly, AUSA
Office of the U.S. Attorney for the
Washington District of Columbia
555 4th St., N.W.

c/o Brigham John Bowen, AUSA
U.S. DEPARTMENT OF JUSTICE
20 Massachusetts Avenue, NW
Barack Hussein Obama in esse

c/o The White House
---------------------------------------------------------------x
Dr. Orly Taitz, PRO SE §
29839 Santa Margarita Parkway, STE 100 §
Rancho Santa Margarita CA 92688 §
Tel: (949) 683-5411; Fax (949) 766-7603 § Civil Action: 10-CV-00151
E-Mail: dr taitz@yahoo.com § (RCL)
§
Plaintiff, §
and §
§
Christopher-Earl: Strunk in esse, § AFFIDAVIT IN SUPPORT
593 Vanderbilt Avenue - #281 §
Brooklyn., New York 11238 § OF INTERVENTION AS A
(845) 901-6767 Email: chris@strunk.ws §
§ EX-RELATOR-PLAINTIFF
Ex-relator-Intervener-Plaintiff. §
§ IN THE QUO WARRANTO
v. §
§ PETITION FOR WRIT
Barack Hussein Obama, §
c/o The White House § OF MANDAMUS
1600 Pennsylvania Avenue, N.W. §
Washington, District of Columbia 20500 §
§
Defendant. §
§
--------------------------------------------------------x
STATE OF NEW YORK )

) ss.:
COUNTY OF KINGS )
I, Christopher–Earl: Strunk in esse, being duly sworn, depose and say:

1. Affirmant place for service is 593 Vanderbilt Avenue #281 Brooklyn,
New York 11238 with telephone 845-901-6767 and email; chris@strunk.ws.
-1-
2. Affirmant files this Affidavit in support of the Notice of Motion to
Intervene as an Ex-relator Intervener-Plaintiff with FRCvP Rule 19(a) (1) and 24(2).
3. That Affirmant is a required party herein and whose joinder will not
deprive the court of subject matter jurisdiction; and that Affirmant claims an
1
FRCvP Rule 19. Required Joinder of Parties. (a) Persons Required to Be Joined if
Feasible. (1) Required Party. A person who is subject to service of process and whose
joinder will not deprive the court of subject-matter jurisdiction must be joined as a party if:
(A) in that person's absence, the court cannot accord complete relief among existing
parties; or (B) that person claims an interest relating to the subject of the action and is
so situated that disposing of the action in the person's absence may: (i) as a practical
matter impair or impede the person's ability to protect the interest; or (ii) leave an
existing party subject to a substantial risk of incurring double, multiple, or otherwise
inconsistent obligations because of the interest.
(2) Joinder by Court Order. If a person has not been joined as required, the court
must order that the person be made a party. A person who refuses to join as a plaintiff
may be made either a defendant or, in a proper case, an involuntary plaintiff.
(3) Venue. If a joined party objects to venue and the joinder would make venue
improper, the court must dismiss that party.
2
FRCvP Rule 24. Intervention
(a) Intervention of Right. On timely motion, the court must permit anyone to
intervene who: (1) is given an unconditional right to intervene by a federal statute; or
(2) claims an interest relating to the property or transaction that is the subject of the
action, and is so situated that disposing of the action may as a practical matter impair
or impede the movant's ability to protect its interest, unless existing parties adequately
represent that interest.
(b) Permissive Intervention. (1) In General. On timely motion, the court may
permit anyone to intervene who: (A) is given a conditional right to intervene by a
federal statute; or (B) has a claim or defense that shares with the main action a
common question of law or fact. (2) By a Government Officer or Agency. On timely
motion, the court may permit a federal or state governmental officer or agency to
intervene if a party's claim or defense is based on: (A) a statute or executive order
administered by the officer or agency; or (B) any regulation, order, requirement, or
agreement issued or made under the statute or executive order. (3) Delay or Prejudice.
In exercising its discretion, the court must consider whether the intervention will
unduly delay or prejudice the adjudication of the original parties' rights.
(c) Notice and Pleading Required. A motion to intervene must be served on the
parties as provided in Rule 5. The motion must state the grounds for intervention and
be accompanied by a pleading that sets out the claim or defense for which intervention
is sought.
-2-
interest relating to the subject of the action and is so situated that disposing of the
action in the person's absence may: (i) as a practical matter impair or impede
Affirmant’s ability to protect the interest; and or (ii) leave Dr. Taitz as an existing
party subject to a substantial risk of incurring double, multiple, or otherwise
inconsistent obligations because of the interest.
4. Affirmant is an ex-relator Plaintiff with 28 USC §1345 (3) seeking to
recover the Office of the President of the United States (POTUS) for Joseph Biden,
now is President of the U.S. Senate. in which this Court has jurisdiction with 28
USC §1343(4), based upon Defendant’s intent 28 USC §1344 (5), 28 USC §1357 (6),
3
§ 1345. United States as plaintiff - Except as otherwise provided by Act of Congress, the
district courts shall have original jurisdiction of all civil actions, suits or proceedings commenced
by the United States, or by any agency or officer thereof expressly authorized to sue by Act of
Congress.
4
§ 1343. Civil rights and elective franchise. (a) The district courts shall have original
jurisdiction of any civil action authorized by law to be commenced by any person: (1) To recover
damages for injury to his person or property, or because of the deprivation of any right or
privilege of a citizen of the United States, by any act done in furtherance of any conspiracy
mentioned in section 1985 of Title 42; (2) To recover damages from any person who fails to
prevent or to aid in preventing any wrongs mentioned in section 1985 of Title 42 which he had
knowledge were about to occur and power to prevent; (3) To redress the deprivation, under
color of any State law, statute, ordinance, regulation, custom or usage, of any right, privilege or
immunity secured by the Constitution of the United States or by any Act of Congress providing
for equal rights of citizens or of all persons within the jurisdiction of the United States; (4) To
recover damages or to secure equitable or other relief under any Act of Congress providing for
the protection of civil rights, including the right to vote.
(b) For purposes of this section— (1) the District of Columbia shall be considered to be
a State; and (2) any Act of Congress applicable exclusively to the District of Columbia shall be
considered to be a statute of the District of Columbia.
5
§ 1344. Election disputes. The district courts shall have original jurisdiction of any civil action
to recover possession of any office, except that of elector of President or Vice President, United
States Senator, Representative in or delegate to Congress, or member of a state legislature,
authorized by law to be commenced, where in it appears that the sole question touching the title
to office arises out of denial of the right to vote, to any citizen offering to vote, on account of
race, color or previous condition of servitude.
-3-
28 USC §1361 (7) , 42 USC §1985 (8) with related law accordingly and District of
The jurisdiction under this section shall extend only so far as to determine the rights of
the parties to office by reason of the denial of the right, guaranteed by the Constitution of the
United States and secured by any law, to enforce the right of citizens of the United States to vote
in all the States.
6
§ 1357. Injuries under Federal laws. The district courts shall have original jurisdiction of any
civil action commenced by any person to recover damages for any injury to his person or
property on account of any act done by him, under any Act of Congress, for the protection or
collection of any of the revenues, or to enforce the right of citizens of the United States to vote in
any State.
7
§ 1361. Action to compel an officer of the United States to perform his duty. The district
courts shall have original jurisdiction of any action in the nature of mandamus to compel an
officer or employee of the United States or any agency thereof to perform a duty owed to the
plaintiff.
8
§ 1985. Conspiracy to interfere with civil rights. (1) Preventing officer from performing
duties. If two or more persons in any State or Territory conspire to prevent, by force,
intimidation, or threat, any person from accepting or holding any office, trust, or place of
confidence under the United States, or from discharging any duties thereof; or to induce by like
means any officer of the United States to leave any State, district, or place, where his duties as an
officer are required to be performed, or to injure him in his person or property on account of his
lawful discharge of the duties of his office, or while engaged in the lawful discharge thereof, or
to injure his property so as to molest, interrupt, hinder, or impede him in the discharge of his
official duties; (2) Obstructing justice; intimidating party, witness, or juror . If two or more
persons in any State or Territory conspire to deter, by force, intimidation, or threat, any party or
witness in any court of the United States from attending such court, or from testifying to any
matter pending therein, freely, fully, and truthfully, or to injure such party or witness in his
person or property on account of his having so attended or testified, or to influence the verdict,
presentment, or indictment of any grand or petit juror in any such court, or to injure such juror in
his person or property on account of any verdict, presentment, or indictment lawfully assented to
by him, or of his being or having been such juror; or if two or more persons conspire for the
purpose of impeding, hindering, obstructing, or defeating, in any manner, the due course of
justice in any State or Territory, with intent to deny to any citizen the equal protection of the
laws, or to injure him or his property for lawfully enforcing, or attempting to enforce, the right of
any person, or class of persons, to the equal protection of the laws; (3) Depriving persons of
rights or privileges. If two or more persons in any State or Territory conspire or go in disguise
on the highway or on the premises of another, for the purpose of depriving, either directly or
indirectly, any person or class of persons of the equal protection of the laws, or of equal
privileges and immunities under the laws; or for the purpose of preventing or hindering the
constituted authorities of any State or Territory from giving or securing to all persons within
such State or Territory the equal protection of the laws; or if two or more persons conspire to
prevent by force, intimidation, or threat, any citizen who is lawfully entitled to vote, from giving
his support or advocacy in a legal manner, toward or in favor of the election of any lawfully
qualified person as an elector for President or Vice President, or as a Member of Congress of the
United States; or to injure any citizen in person or property on account of such support or
advocacy; in any case of conspiracy set forth in this section, if one or more persons engaged
-4-
Columbia Code (DCC) Chapters 35 (See Endnotes) and 37 (See Endnotes) with related law
in its entirety, and the U.S. Constitution in its entirety especially emphasizing
Article 2 Section 1 (9) and Article 7 Amendment 25 (10) specifically, and
therein do, or cause to be done, any act in furtherance of the object of such conspiracy, whereby
another is injured in his person or property, or deprived of having and exercising any right or
privilege of a citizen of the United States, the party so injured or deprived may have an action for
the recovery of damages occasioned by such injury or deprivation, against any one or more of
the conspirators.
9
Section 1. The executive power shall be vested in a President of the United States of America.
He shall hold his office during the term of four years, and, together with the Vice President,
chosen for the same term, be elected, as follows:
Clause 1. Each state shall appoint, in such manner as the Legislature thereof may direct, a
number of electors, equal to the whole number of Senators and Representatives to which the
State may be entitled in the Congress: but no Senator or Representative, or person holding an
office of trust or profit under the United States, shall be appointed an elector.
Clause 2. The electors shall meet in their respective states, and vote by ballot for two
persons, of whom one at least shall not be an inhabitant of the same state with themselves. And
they shall make a list of all the persons voted for, and of the number of votes for each; which list
they shall sign and certify, and transmit sealed to the seat of the government of the United States,
directed to the President of the Senate. The President of the Senate shall, in the presence of the
Senate and House of Representatives, open all the certificates, and the votes shall then be
counted. The person having the greatest number of votes shall be the President, if such number
be a majority of the whole number of electors appointed; and if there be more than one who have
such majority, and have an equal number of votes, then the House of Representatives shall
immediately choose by ballot one of them for President; and if no person have a majority, then
from the five highest on the list the said House shall in like manner choose the President. But in
choosing the President, the votes shall be taken by States, the representation from each state
having one vote; A quorum for this purpose shall consist of a member or members from two
thirds of the states, and a majority of all the states shall be necessary to a choice. In every case,
after the choice of the President, the person having the greatest number of votes of the electors
shall be the Vice President. But if there should remain two or more who have equal votes, the
Senate shall choose from them by ballot the Vice President.
Clause 3. The Congress may determine the time of choosing the electors, and the day on
which they shall give their votes; which day shall be the same throughout the United States.
No person except a natural born citizen, or a citizen of the United States, at the time of the
adoption of this Constitution, shall be eligible to the office of President; neither shall any person
be eligible to that office who shall not have attained to the age of thirty five years, and been
fourteen Years a resident within the United States. (emphasis by Affirmant)
Clause 4. In case of the removal of the President from office, or of his death, resignation,
or inability to discharge the powers and duties of the said office, the same shall devolve on the
Vice President, and the Congress may by law provide for the case of removal, death, resignation
-5-
accordingly the U.S. Constitution and laws in relation to the various Constitutions
of the State of New York and the several States in its entirety for the People with
or inability, both of the President and Vice President, declaring what officer shall then act as
President, and such officer shall act accordingly, until the disability be removed, or a President
shall be elected. (emphasis by Affirmant)
Clause 5. The President shall, at stated times, receive for his services, a compensation,
which shall neither be increased nor diminished during the period for which he shall have been
elected, and he shall not receive within that period any other emolument from the United States,
or any of them.
Clause 6. Before he enter on the execution of his office, he shall take the following oath
or affirmation:--"I do solemnly swear (or affirm) that I will faithfully execute the office of
President of the United States, and will to the best of my ability, preserve, protect and defend the
Constitution of the United States."
10
Amendment XXV.
Section 1. In case of the removal of the President from office or of his death or
resignation, the Vice President shall become President.
Section 2. Whenever there is a vacancy in the office of the Vice President, the President
shall nominate a Vice President who shall take office upon confirmation by a majority vote of
both Houses of Congress.
Section 3. Whenever the President transmits to the President pro tempore of the Senate
and the Speaker of the House of Representatives his written declaration that he is unable to
discharge the powers and duties of his office, and until he transmits to them a written declaration
to the contrary, such powers and duties shall be discharged by the Vice President as Acting
President.
Section 4. Whenever the Vice President and a majority of either the principal officers of
the executive departments or of such other body as Congress may by law provide, transmit to the
President pro tempore of the Senate and the Speaker of the House of Representatives their
written declaration that the President is unable to discharge the powers and duties of his office,
the Vice President shall immediately assume the powers and duties of the office as Acting
President.
Thereafter, when the President transmits to the President pro tempore of the Senate and
the Speaker of the House of Representatives his written declaration that no inability exists, he
shall resume the powers and duties of his office unless the Vice President and a majority of
either the principal officers of the executive department or of such other body as Congress may
by law provide, transmit within four days to the President pro tempore of the Senate and the
Speaker of the House of Representatives their written declaration that the President is unable to
discharge the powers and duties of his office. Thereupon Congress shall decide the issue,
assembling within forty-eight hours for that purpose if not in session. If the Congress, within
twenty-one days after receipt of the latter written declaration, or, if Congress is not in session,
within twenty-one days after Congress is required to assemble, determines by two-thirds vote of
both Houses that the President is unable to discharge the powers and duties of his office, the Vice
President shall continue to discharge the same as Acting President; otherwise, the President shall
resume the powers and duties of his office.
-6-
suffrage there in election of the respective electoral college of each State in the
2008 General Election deprived a reasonable expectation of effective participation.
5. Affirmant on January 23, 2009 duly “Fired” the Defendant for cause
(See Exhibit 1) in that Defendant Obama has “Dual Allegiance” at birth, and
failed to prove eligibility to serve as POTUS and therefore may not use
Affirmant’s power of attorney as the POTUS trustee / administrator.
6. That on or about May 20, 2009, Affirmant duly served notice by letter
memorandum with the Verified Complaint duly serve notice (See Exhibit 2) to
U.S. Attorney Jeffery Taylor and U.S. Attorney General Eric Holder for a Quo
Warranto Inquest on the Defendant Obama in accordance with DCC Chapter 35§
16-3502 for The Attorney General of the United States or the United States
Attorney who may institute a proceeding pursuant to the subchapter on Affirmant’s
own motion or on the relation of a third person in the matter of infliction of injury.
7. That on or about May 27, 2009, Affirmant filed a Cross Motion with
attachments, including the duplicate Verified Complaint (See Exhibit 3) for a Quo
Warranto at Exhibit 15 as shown as Exhibit 2, to proceed with DCC Chapter 35
Section 16-3503 as the “ex-relator” Plaintiff in the case Strunk v. US Department
of States et al. DCD 08-cv-2234 alleging that: (i) on or about February 2, 2009
Defendant Barack Hussein Obama and Eric Holder (the Usurpers) injured
Affirmant by the Usurpers’ bad faith breach of substantive due process in
-7-
conjunction within DCD 08-cv-2234 by not notifying Plaintiff of replacement of
then Counsel U.S. Attorney Jeffery Taylor and or his agent; (ii) the direct injury to
Affirmant related to the fact that Affirmant on January 23, 2009 duly “Fired” the
Defendant for cause in that Defendant Obama has “Dual Allegiance” at birth, and
failed to prove eligibility to serve as POTUS, and (iii) Defendant Obama with Dual
Allegiance is ineligible to serve as the Administer and Trustee of Affirmant’s
power of attorney over Affirmant’s personal account at the U.S. Department of
Treasury; (iv) that subsequent to duly firing Barack Hussein Obama (a.k.a. “Barry
Soetoro”, a.k.a. “Steve Dunham”, a.k.a. “Birdie Obama”) Affirmant asset is
wasting as a direct personal injury on-going by Defendant’s mis-administration
and mis-application of the fiduciary duties of the Trustee and Administrator,
accordingly the subject of a pending Replevin with District of Columbia Code
Chapter 37 (See Exhibit 4); and (v) furthermore, Defendant Obama in conspiracy
with Eric Holder and other(s) yet named have denied President Joseph Biden, now
serving as President of the U.S. Senate, his rightful Office as the President of the
United States. Affirmant is the Ex-relator in that Eric Holder and Jeffery Taylor
failed to act to recover President Biden’s rightful office accordingly with the due
process of law under DCC Chapter 35 empowers Ex-relator to act for the U.S.A.;
and accordingly Ex-relator wishes a Declaratory Judgment on the Law with 28
-8-
USC §2201 and Writ of Mandamus with FRCvP Rule 65 (11) of Defendant and
directive to Congress.
11
VIII. PROVISIONAL AND FINAL REMEDIES ; Rule 65. Injunctions and Restraining
Orders. (a) Preliminary Injunction. (1) Notice. The court may issue a preliminary injunction only
on notice to the adverse party.(2) Consolidating the Hearing with the Trial on the Merits. Before
or after beginning the hearing on a motion for a preliminary injunction, the court may advance
the trial on the merits and consolidate it with the hearing. Even when consolidation is not
ordered, evidence that is received on the motion and that would be admissible at trial becomes
part of the trial record and need not be repeated at trial. But the court must preserve any party's
right to a jury trial.
(b) Temporary Restraining Order. (1) Issuing Without Notice. The court may
issue a temporary restraining order without written or oral notice to the adverse party or
its attorney only if: (A) specific facts in an affidavit or a verified complaint clearly show
that immediate and irreparable injury, loss, or damage will result to the movant before the
adverse party can be heard in opposition; and (B) the movant's attorney certifies in
writing any efforts made to give notice and the reasons why it should not be required.
(2) Contents; Expiration. Every temporary restraining order issued without notice must
state the date and hour it was issued; describe the injury and state why it is irreparable;
state why the order was issued without notice; and be promptly filed in the clerk's office
and entered in the record. The order expires at the time after entry; not to exceed 14 days;
that the court sets, unless before that time the court, for good cause, extends it for a like
period or the adverse party consents to a longer extension. The reasons for an extension
must be entered in the record. (3) Expediting the Preliminary-Injunction Hearing. If the
order is issued without notice, the motion for a preliminary injunction must be set for
hearing at the earliest possible time, taking precedence over all other matters except
hearings on older matters of the same character. At the hearing, the party who obtained
the order must proceed with the motion; if the party does not, the court must dissolve the
order. (4) Motion to Dissolve. On 2 days' notice to the party who obtained the order
without notice; or on shorter notice set by the court; the adverse party may appear and
move to dissolve or modify the order. The court must then hear and decide the motion as
promptly as justice requires.
(c) Security. The court may issue a preliminary injunction or a temporary
restraining order only if the movant gives security in an amount that the court considers
proper to pay the costs and damages sustained by any party found to have been
wrongfully enjoined or restrained. The United States, its officers, and its agencies are not
required to give security.
(d) Contents and Scope of Every Injunction and Restraining Order. (1) Contents.
Every order granting an injunction and every restraining order must: (A) state the reasons
why it issued; (B) state its terms specifically; and (C) describe in reasonable detail; and
not by referring to the complaint or other document; the act or acts restrained or required.
(2) Persons Bound. The order binds only the following who receive actual notice of it by
personal service or otherwise: (A) the parties; (B) the parties' officers, agents, servants,
employees, and attorneys; and (C) other persons who are in active concert or
participation with anyone described in Rule 65(d)(2)(A) or (B).
-9-
8. To date Judge Richard J. Leon has not issued a decision on the Cross
Motion in that Defendants’ Counsel therein argued that a FOIA Complaint may not
be converted, and as such the matter remains pending; however, by judicial notice
of this Motion to Intervene herein, Judge Leon and Counsel in Strunk v. US
Department of States et al. DCD 08-cv-2234 are duly notified, with a request to
sever the issue from that case to this matter of intervention (See Exhibit 5).
9. That Affirmant’s Intervention as of right is governed by Rule 24(a),
which provides the right to intervene is unconditionally granted by federal statute
with above cited and footnotes laws and with the DCC Chapter 35 and 37 cited in
the Endnotes; and accordingly when a non-party right to intervene shows that:
a) Affirmant’s motion to intervene is timely filed by Local Rules as herein;

b) Affirmant has an interest relating to the property or transaction that is the
subject of the action
c) That Affirmant is so situated that without intervention the disposition of the
action may as a practical matter impair or impede Affirmant ability to protect
interest in the cases Strunk v. US DOS et al. DCD 08-cv-2234, Strunk v US
DOC Bureau of Census et al. DCD 09-cv-1295, Strunk v. The New York
Province of the Society of Jesus et al. DCD 09-cv-1249, Strunk v US
Department of Interior et al. 10-cv-0066, ACORN et al. v. U.S.A. et al. EDNY
09-cv-4888 (NG) and Strunk v. Paterson et al. NYS Supreme Court in Kings
Justice David I. Schmidt.
- 10 -
d) Affirmant’s interest is not adequately represented by existing parties, in that the
Usurper’s Attorney General and or his agents have not vigorously represented
U.S.A. Citizens, the State Of New York Citizens and or any other State’s
citizens of the several States accordingly, and as such Affirmant as the Ex-
Relator litigant herein, it is necessary Affirmative’s claims be entered into the
record herein.
e) That Affirmant contends that after due notice required by law the Defendant
Barack Hussein Obama responded in writing with a special demurer on or about
August 26, 2009 (See Exhibit 6); however, the U.S. Attorney General Eric
Holder and U.S. Attorney Jeffery Taylor and or his replacement have failed to
respond or otherwise appear, and that Affirmant has exhausted the
administrative process and other available remedy to appear as the ex-relator
afforded by law.
10. This case raises important legal and constitutional issues, the
resolution of which has the potential to affect not only the parties to this case but
many non-parties, as well; and that Affirmant’s intervention, in particular, should
not be rejected as to do so would not contribute to a just and equitable adjudication
of the issues in this case, but instead would be likely to distract both the Court and
the parties when time is of the esse as a national security matter with an ongoing
irreparable harm requiring Affirmant petition supplement with FRCvP R. 15(d).
11. Affirmant has read the foregoing along with Plaintiff’s Complaint
with Exhibits filed January 27, 2010 and Affirmant supports Plaintiff’s request for
necessary equity relief and that this matter be immediately expedited for due
- 11 -
process herein with an immediate writ of mandamus with an order of the
Defendant Barack Hussein Obama; the U.S. Attorney Channing Philips, U.S.
Attorney General Eric Holder, President Joseph Biden, and Congress to appear
before this Court to show cause why relief should not be granted for Plaintiff(s),
Ex-relator Intervener-Plaintiff and the People of the U.S.A.; and
12. Accordingly, until such hearing and appearance is had granted,
Affirmant demands a Temporary Restraining Order of Defendant Obama cease
and desist from the duties of POTUS until at such time Congress may act with the
law of the land and or parties appear at a preliminary hearing convened by order of
this Court; and I have read the Verified Quo Warranto Petition for a Writ of
Mandamus and know the contents thereof, and effects those matters have upon me,
and that this affidavit is true to my own knowledge, except as to the matters therein
stated to be alleged on information and belief, and as to.those matters I believe it to
be true. The grounds of my beliefs as to all matters not stated upon information and
belief are as follows: third parties, books and records, and personal knowledge.
Sworn to before me this

the 2 4'" day of January 2010
GEORGE ANDERSON
Notary Public, State of New Yo&
No. 01AN5070990
Qualified in Kings County
- 12-
Commission Expires Jan. 6, 20 1 1
ENDNOTES
DC ST § 16-3501 formerly cited as DC ST 1981 § 16-3501
District of Columbia Official Code 2001 Edition Currentness

Division II. Judiciary and Judicial Procedure
Title 16. Particular Actions, Proceedings and Matters. (Refs & Annos)
Chapter 35. Quo Warranto.
Subchapter I. Actions Against Officers of the United States. (Refs & Annos)
§ 16-3501. Persons against whom issued; civil action.
A quo warranto may be issued from the United States District Court for the District of Columbia in the
name of the United States against a person who within the District of Columbia usurps, intrudes into,
or unlawfully holds or exercises, a franchise conferred by the United States or a public office of the
United States, civil or military. The proceedings shall be deemed a civil action.
CREDIT(S): (Dec. 23, 1963, 77 Stat. 602, Pub. L. 88-241, § 1; July 29, 1970, 84 Stat. 562, Pub. L.
91-358, title I, § 145(n).); HISTORICAL AND STATUTORY NOTES: Prior Codifications: 1981 Ed., § 16-
3501., 1973 Ed., § 16-3501.; DC CODE § 16-3501 Current through October 4, 2009

Subchapter I. Actions Against Officers of the United States. (Refs & Annos)
§ 16-3503. Refusal of Attorney General or United States attorney to act;

procedure.
If the Attorney General or United States attorney refuses to institute a quo warranto proceeding
on the request of a person interested, the interested person may apply to the court by certified
petition for leave to have the writ issued. When, in the opinion of the court, the reasons set forth
in the petition are sufficient in law, the writ shall be allowed to be issued by any attorney, in the
name of the United States, on the relation of the interested person on his compliance with the
condition prescribed by section 16-3502 as to security for costs.
CREDIT(S): (Dec. 23, 1963, 77 Stat. 602, Pub. L. 88-241, § 1; July 29, 1970, 84 Stat. 562, Pub.
L. 91-358, title I, § 145(n).)
HISTORICAL AND STATUTORY NOTES: Prior Codifications - 1981 Ed., § 16-3503., 1973
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Ed., § 16-3503. DC CODE § 16-3503 Current through October 4, 2009
Subchapter III. Procedures and Judgments.
§ 16-3543. Proceedings on default.
If the defendant does not appear as required by a writ of quo warranto, after being served, the
court may proceed to hear proof in support of the writ and render judgment accordingly.
CREDIT(S) : (Dec. 23, 1963, 77 Stat. 603, Pub. L. 88-241, § 1; July 29, 1970, 84 Stat. 563, Pub.
L. 91-358, title I, § 145(n).) HISTORICAL AND STATUTORY NOTES : Prior Codifications-
1981 Ed., § 16-3543. 1973 Ed., § 16-3543.; DC CODE § 16-3543 Current through October 4,
2009

§ 16-3544. Pleading; jury trial.
In a quo warranto proceeding, the defendant may demur, plead specially, or plead "not guilty" as
the general issue, and the United States or the District of Columbia, as the case may be, may
reply as in other actions of a civil character. Issues of fact shall be tried by a jury if either party
requests it. Otherwise they shall be determined by the court.
L. 91-358, title I, § 145(n).); HISTORICAL AND STATUTORY NOTES: Prior Codifications-
1981 Ed., § 16-3544., 1973 Ed., § 16-3544., DC CODE § 16-3544 Current through October 4,
2009
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§ 16-3545. Verdict and judgment.
Where a defendant in a quo warranto proceeding is found by the jury to have usurped, intruded
into, or unlawfully held or exercised an office or franchise, the verdict shall be that he is guilty of
the act or acts in question, and judgment shall be rendered that he be ousted and excluded
therefrom and that the relator recover his costs.
CREDIT(S) : (Dec. 23, 1963, 77 Stat. 603, Pub. L. 88-241, § 1; July 29, 1970, 84 Stat. 563, Pub.
L. 91-358, title I, § 145(n).); HISTORICAL AND STATUTORY NOTES: Prior Codifications:
1981 Ed., § 16-3545., 1973 Ed., § 16-3545., DC CODE § 16-3545 Current through October 4,
2009

§ 16-3548. Recovery of damages from usurper; limitation.
At any time within a year from a judgment in a quo warranto proceeding, the relator may bring
an action against the party ousted and recover the damages sustained by the relator by reason of
the ousted party's usurpation of the office to which the relator was entitled.
L. 91-358, title I, § 145(n).); HISTORICAL AND STATUTORY NOTES: Prior Codifications:
1981 Ed., § 16-3548., 1973 Ed., § 16-3548.; DC CODE § 16-3548
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Chapter 37. Replevin.
§ 16-3701. Demand prior to action; costs.
In an action of replevin brought to recover personal property to which the plaintiff is entitled,
that is alleged to have been wrongfully taken by or to be in the possession of and wrongfully
detained by the defendant, it is not necessary to demand possession of the property before
bringing the action; but the costs of the action may be awarded as the court orders.
CREDIT(S): (Dec. 23, 1963, 77 Stat. 604, Pub. L. 88-241, § 1.); HISTORICAL AND
STATUTORY NOTES: Prior Codifications: 1981 Ed., § 16-3701., 1973 Ed., § 16-3701.; DC
CODE § 16-3701 Current through October 4, 2009

§ 16-3702. Form of complaint.
A complaint in replevin shall be in the following or equivalent form:
"The plaintiff sues the defendant for (wrongly taking and detaining) (unjustly detaining) the
plaintiff's goods and chattels, to wit: (describe them) of the value of ___ dollars. And the plaintiff
claims that the same be taken from the defendant and delivered to him; or, if they are eloigned,
that he may have judgment of their value and all mesne profits and damages, which he estimates
at ___ dollars, besides costs."
CODE § 16-3702
Current through October 4, 2009.

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§ 16-3703. Affidavit; contents.
At the time of filing a complaint in replevin, the plaintiff, his agent, or attorney shall file an
affidavit stating that --
(1) according to affiant's information and belief, the plaintiff is entitled to recover possession
of chattels proposed to be replevied, being the same described in the complaint;
(2) the defendant has seized and detained or detains the chattels; and
(3) the chattels were not subject to the seizure or detention and were not taken upon a writ of
replevin between the parties.
CODE § 16-3703
Current through October 4, 2009

§ 16-3704. Undertaking to abide judgment of the court.
At the time of filing a complaint in replevin, the plaintiff shall enter into an undertaking by
himself or his agent with surety, approved by the clerk, to abide by and perform the judgment of
the court.
CREDIT(S) : (Dec. 23, 1963, 77 Stat. 604, Pub. L. 88-241, § 1.); HISTORICAL AND
CODE § 16-3704

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§ 16-3705. Failure of officer to obtain possession; procedure.
When the officer's return of a writ of replevin issued pursuant to this subchapter is that he has
served the defendant with copies of the complaint, affidavit, and summons, but that he could not
obtain possession of the goods and chattels sued for, the plaintiff may prosecute the action for
the value of the property and damages for detention, or he may renew the writ in order to obtain
possession of the goods and chattels themselves.
CODE § 16-3705

§ 16-3707. Default.
If, after notice as provided by section 16-3706, the defendant fails to appear, the court may
proceed as in case of default after personal service.
CODE § 16-3707

§ 16-3708. Motion for return of property; procedure; objection to sufficiency of

security.
(a) On the taking possession of the goods and chattels by the marshal by virtue of a writ of
replevin, the defendant may, on one day's notice to the plaintiff or his attorney, move for a return
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of the property to his possession. Thereupon, the court may inquire into the circumstances and
manner of the defendant's obtaining possession of the property, and, if it seems just, may order
the property to be returned to the possession of the defendant, to abide the final judgment in the
action. The court may require the defendant to enter into an undertaking with surety or sureties,
similar to that required of the plaintiff upon the commencement of the action. In such case, the
court shall render judgment against the surety or sureties, as well as against the defendant.
(b) When it appears that the possession of the property was forcibly or fraudulently obtained by
the defendant, or that the possession, being first in the plaintiff, was procured or retained by the
defendant without authority from the plaintiff, the court may refuse to order the return of the
property to the possession of the defendant. The defendant may also, on similar notice, object to
the sufficiency of the security in the undertaking of the plaintiff, and the court may require
additional security, in default of which the property shall be returned to the defendant, but the
action may proceed as if the property had not been taken.
CODE § 16-3708

§ 16-3709. Notice to officer of intention to move for return; duty of officer; time of
motion.
If the defendant in an action of replevin notifies the officer taking possession of the property, in
writing, of his intention to make either of the motions specified by section 16-3708, the officer
shall retain possession of the property until the motion is disposed of, if the motion is filed and
notice given, as provided by section 16-3708, to the plaintiff or his attorney, within two days
thereafter.
STATUTORY NOTES: Prior Codifications: 1981 Ed., § 16-3709., 1973 Ed., § 16-3709.: DC
CODE § 16-3709
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§ 16-3710. Determination and measure of plaintiff's damages.
Whether, in an action of replevin, the defendant answers and the issue thereon joined is found
against him, or judgment is rendered against him on proper motion under rules of court, or he
makes default after personal service or publication, the plaintiff's damages shall be ascertained
by the jury trying the issue, where one is joined, or by a jury of inquest, where jury trial had been
waived or there is no issue of fact, and the damages shall be the full value of the goods, if
eloigned by the defendant, including, in every case, the loss sustained by the plaintiff by reason
of the detention, and the judgment shall be rendered for the plaintiff accordingly.
CODE § 16-3710

§ 16-3713. Judgment where goods are eloigned.
The judgment in a case where the defendant has eloigned the goods sued for, shall be that the
plaintiff recover against the defendant the value of the goods as found and the damages so
assessed, to be discharged by the return of the things, within ten days after the judgment, with
damages for detention, which the jury shall also assess.
STATUTORY NOTES: Prior Codifications: 1981 Ed., § 16-3713., 1973 Ed., § 16-3713.;
DC CODE § 16-3713
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Affirmant Affidavit in support of the Notice of Motion to Intervene as
an Ex-relator Intervener-Plaintiff in Taitz v Obama DCD 10-cv-00151
Exhibit 1
Ia atre of:
593 Vsmdertrilt Avenue -281
Brookrlp New York
Zip Code exempt DMM 122-32
CI~k~pher-Earl: Stm& Q
Not a c a p a t i o z i
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h c k H& O h in @8@, No Third P d e s
&a Bany S m in as%,
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DBA BARACE:HSJSSEIN O B U INC.
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the AGENT m*CHARGE OF THE
UNITED STATES SECRET SERVICE
9tJF~eoft3avmmmf rmd Pubficflairs
245 M.lrpay Drive*
Budding 410,
Washingtan, DC 20223
NOTICE TO THE AGENT IS NOTICE TO PWCIPAL NOTICE TO PRFNCIPAL

IS NOTICE TO AGENT
RE:OFFER OF CONTRACT
Received 20 January 2009 and received 21 January 2009
FOR TEE RECORD

RlETURN AM) REDRAPT
TIMELY1WITHOUT DISHONOR
WrrH THE l W S l 3 U m SPECIAL-APPlURANCE
NOT A COWORATION
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Oath of 20 January 2009 offer for mntrmt /Returned & R e d d b d
* Oath of21 darmary 2009 off= for csntract IReturnd & R*
* Notice to the Clerk of Records
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the Offlce of President of the ljnitea States, and I will to the k t of my

the ~o~wfttution
of the united ~ t a ~ s . " w;JP-d~
NOTlCE TO W E CLERK OF RECORDS
Ttit minnteyon d v e any recod, document, paper, proceeding, map, book or o d ~ mthing depOsitea with
you, you are commhhg aim= against justice d m Revised S W t s of the United Stam First Section
43 Congms, Sections 5403,5407 aad 5408 totaling up to $9,000 in h w and up to 12 years in prison pm
a&hvityaufailtoremrd T i t l e l 8 U S C ~ m 2 0 7 1atsocaui-kqimpriisonmentand
dkplification of&- If p u t county attorney toid you not to file any documents like mine, yon are
still rsspomible, as I da no acmpt
h m the hwydng d am dl e rd-party-intebvenem. Any attorney, district attorney, or q m e
parties and do not have a licu~seto make a legal detmmhation in
this matter as they do not represent M e and Yau, the oomty c l e do not have the authority to r e p m t
Me. Should You fail to uphold Your swom o& and +rm your duties I will h v e no choice but to
rcwrd aaA€iiaaVit ofC r i m i d Complaint agahtst Your amd Liend a mpy to Your bonding company.
Title I X X 4 ~ , - C W . 4 . CIUMES AGAINST JUSTICE
5-03. Every person who willfully destroys Mattempts to deshoy, or, with intent to steal or d m y ,
takes and carries away any mmd, paper, or promding of a c o w of justice, filed or deposited with any
c l d or oEcer of so& court, or any papa, or document, or record fled or depasikd in any public ofice,
or wid^ any judicial or public officer, &dl, withunt rehmce to the vaIue of the record,paper, d o m e d ,
or procGediag srr taken, pay a h e ofnot more than two thousand dollars, or s* imprisonment, at hard
l a b , aot mwe thaa tree ywm, or both: [S* Q 8 54083411,54 t 4.1J Titie =.- C - . - CH.4.
CRIMES AGAINST msnm h,pablic-ds.)
SC5407. Iftwo or more peasons in my State or Taritory conspire for the purpose ofimpeding
hindering.o b c h g or defeating,ia any m ,thed m come ofjustice in any State or Territory, with
intent d q to my citizenthe equd protection of the laws, or to in* him or his property fur lawhlly
wforcin& or att~tllptingto enforce, the right of any person, or class of person, to the equal protection of
thelaws, ewhofsochpersonshall beprmishedby a f i n e o f n o t l ~ t b a n ~ e h m d r e d n o r m o r e ~ f i v e
thomaad dollam, or by imprkoammt, witb or w i t h u t harrl I&ra wt less than six month nor more tban
six years, or by both sueh h e and imprisonmeai. S w 5 9 1977-1991,20042010,5506-5510.1 Tide LXX
- -
CIUMES. CK.4. CRIMES AGAINST JUSTICE (Conspiracy to defeat enfammart ofthe laws.)
SEC5408. Evwy officer, having the custody of my m r d , document, paper, or proceding specified in
e m fifty-fim hundrcd and three,who f m d d d y takes away, or withdraws, or destroys any soah
rwmd, docmmt, paper, or p m c d k g filed in his OEM or depsitsd with him or in his cmtody, shall
pay a fine of not more fhan two thougand dollars, or d e r imigrisoammtat bard labor not more than three
yms,or bo€band W moreaver, Wcit his office and be foreva d k w a r d disqualified froan holding
arry ofice u a d a the Govmment of the United States. @esbyiug record by oEca in charge.)
S d o n 2071. Concealment, ternoval, or mutilation geblmlly
(a) Whoever wiifulIy and unlawfUfly c m c d s , removes, mutilates, obliterab, or d a m p , w

attmnpts to do so, or, with intent to do so takes and canim away my record, proceeding, map,
book, paper, documen5 or other thing, flbd or dtposited with any clak or o f i c a ofany mnd of
the United W,or in any public office, or with any jdicia! orpublic o 5 c a ofh e United
States, shall be ha under ihs title w imprisoned not more tban kyears, or both
(b) W
h-, M g the wstody ofmy such reed., proceeding, map, book, doarmeat, paper, or
other thing, wiIlllly and d a w f d y conads, removes, mutilates, obliterates, fddies, or destroys
the same, Bhall be fined unda this title or imprimned mot more than tbrae years, Mhth; d s h d
forfeit his office andbe disqualified ftwn ho?di~~gany office mdu the United States. As used in
this subsection, the t m u~ffi~e" does not include the oftice held by my pason as a reaired officer
ofthe Armed F o m of the United States.
[While the misrcpresentetiw of a matend fact, pgst or present may eonslim basis
for an inf- of 1-1 Viad." any act omission or- &ih holves
a breach oflewl duty, mor cmf~dencc justly r e p o d and is injurious m another.
or hy which an undue advantage is taken of another, may become the hundation far
i n f of~fraud, aud wtren them is a duty to t t matetiid
k o o ~ l m e r rofa
fact may b equally rts wrongful as t positive misctpnsenhtbn.Tex.Civ. App. 1943
Ruebeck t*, Hrt~tt.171 SW2d 895, Wwmed I v6 S1Ud 7382 I42 T m 167i I50 A. L.R
""5.1
(Party having supmior knowWge who takes ahan- of mother's ignoramx of the
law to deceiivs him by studied canceatment or mismpremtatiwr can be held reqm-
h k 726
sible fbr that conduct. rex. 1987. FinaSup&. Im v. rfbileneNati~~nul
SW2d S3A
[We(judge5j have na mom right ta decline ttu3 exercise ofjraisdiction which is given,
(thb will include the county court of recodjradgg Victw CariIlo) than lo usurp tha~
which is n d given. The one or the other would be -I to the C.nnstitution."
Chhm v. 6 Kkut 264. (1821); U.S v. WiIJ, 499 US.2M.I
'W)heaa governmwa becomes a patw in my imdhp company, i r diva^^ h l f ,
r(
s(l far tls tmcenc~the mwactim of dmt cornparry. of its sovereign c b t c r , and
t a b that ofa private c m . .-It &ends to a level with t b a with whom it associate
i ~ i fand
, rakes the c w which b b g s to its asxxiahts and to the business
which is to be transacted.* &rnk tfUhiledSIata v. PI MI^ ' Bank rlfUmr~iu
22 US.904(lrP24I.J
["The United States as drawee of cdmmemial p p r stands in no dierent light tfian

any o h r drawee." "The IJpited S t a t u does business on busirmtss terms.It is not
exem@ fKHn the gem1 rules governing the ii@mand duties of drawees by the
largmts of its deaIinp and its having& employ agents to do what ifdone by a
principal in p m m would kave no mom for dmMWCI@& Mt C h v. United
318 iLS. 36311943),]
,SCLICRP.
1°C- enforcing mem saaates do mot act judicially, but rninkwialiy, having na
judieial lmulunky, and unlike Corpts of LAW, do not obtainjlPisdition by m i c e of
pmmnor even by A m s t and Compelled Appemme." BanueII v. Qrir, 9 HOW&
336, 34x1
VWant uf jurisdiction may not be cured by ms

m t ofthe ~ ' e s . I" ~ i d . t r l r l i i t > n
Asstxiation E CL R.323 US 310.3 13.1
[ Judicial Notice ]
1. ["A judgment rendered in violation of due process is void" World Wde VoIKrwagot
W d e r r , 444 US.286,29 I ; National Bmtk v. WiZey, 195 US 257; Penmyer v. Ne_t
95 US 7143
[ ",.. the .mpkmmtsofdue process must b met Wore the court can properly assert in
persomnt j ~ c t i o n "WeZIsFargo v. W e b Fargo,556 F2d 406,416.1
[. Notification of legal respnsibiity is we essential of due process of law."

C o d & v. Geaeral Combwdion Co., 269 US 385,3911
[. w A ~ w h i c h e i t h e r f o r b i & o r r e q ~ ~ d o ' m g o f m ~ i n ~ s o v a g u e t h a t
men ofcommon intelligence must necessarily guess at its meaning and differ as to its
application, violates the tmntial of due process of law." C o d I y v. General
Comimction Co.. 269 U.S. 3 8539I]
[. nWheneverit appears that the court lacks subject matterjuzisdiction, the ant is
obliged to dismiss the actiua" Elly v. Coastal Cop., 503 U.S. 131,136-37; U S. v.
Texar, 252 F. Supp 234,2541
[. " O n o e ~ c t i o in s challenged, the court cannotproceed when it clearly s p p e a ~ s

that the court lacks jurisdiction, the court has no authority to reach merits, but, rather
should d i e the &m'' Melo v, US,505 F.2d 10261
is no d i d o n to ignore lack o f ~ c t i c m "

Joyce v. US,474 F 26 2151
Exhibit 2
Case 1:08-cv-02234-RJL Document 19-2 Filed 06/01/2009 Page 213 of 243
U.S. and ex Rel. Strunk v. Barack Hussein Obama DCDC

--------------------------------------------------
In the Quo Warranto matter of the united States of America
and ex relator Christopher-Earl : Strunk © in esse
Plaintiff / Relator
v.
Barack Hussein Obama (a/k/a Barry Soetoro) in esse
Defendant / Respondent
-------------------------------------------------
QUO WARRANTO COMPLAINT WITH DEMAND FOR JURY TRIAL

AND DECISION ON QUESTION OF FIRST IMPRESSION
Plaintiff/Relator, Christopher-Earl : Strunk © in esse, in the name of the united States of
America brings this Verified Complaint under Federal Rules of Civil Procedure Rule (FRCvP)
81(a)(2) first offered for action by the District Attorney for the Washington District of
Columbia, with TITLE 16 CHAPTER 35 (Quo Warranto) OF THE DISTRICT OF COLUMBIA
CODE in its entirety (1) with allegations of usurpation of Office of the President and failure of
duty against Defendant / Respondent as follows:
1
Chapter 35§ 16-3501 Persons against whom issued; civil action. states: A quo warranto may be issued
from the United States District Court for the District of Columbia in the name of the United States against
a person who within the District of Columbia usurps, intrudes into, or unlawfully holds or exercises, a
franchise conferred by the United States or a public office of the United States, civil or military. The
proceedings shall be deemed a civil action.
Chapter 35§ 16-3502 states: The Attorney General of the United States or the United States attorney may
institute a proceeding pursuant to this subchapter on his own motion or on the relation of a third person.
Chapter 35§ 16-3503 states: If the Attorney General or United States attorney refuses to institute a quo
warranto proceeding on the request of a person interested, the interested person may apply to the court by
certified petition for leave to have the writ issued.
Chapter 35§ 16-3544 states: In a quo warranto proceeding, the defendant may demur, plead specially, or
plead “not guilty” as the general issue, and the United States or the District of Columbia, as the case may
be, may reply as in other actions of a civil character. Issues of fact shall be tried by a jury if either party
requests it. Otherwise they shall be determined by the court.
Quo Warranto Complaint – Page 1 of 8

1. This Complaint is to be heard with 28 USC §1345 in this particular District Court for the
District of Columbia that affords the proper venue under 28 USC §1391 (e) (2) for this action in
that Defendant in esse is usurping the Corporate office of the President of the united States of
America (POTUS) located within the District of Columbia and the failure of the Defendant in
esse to act in good faith with his corporate duty within the District of Columbia.
2. This Petition demands the Quo Warranto Act mandates this Court to create a jury trial to
determine the issue of facts: (i) where Defendant was born and (ii) whether or not both his
parents were united States’ Citizens at his birth; and thereafter a trial on the facts that the Court
as a matter of first impression must determine the law as to what is the natural-born-citizen
requirement of Article 2 Section 1 Clause 5 of the united States’ Constitution.
3. This action demands to compel Defendant to show cause why he should not by removed
from the POTUS office as a usurper for his ineligibility with Article 2 Section 1 Clause 5 and the
25th Amendment to the Constitution as applies to Article 2 Section 1 Clause 6.
4. In support of this verified complaint with two cause, Plaintiff avers the following:
5. Relator, Christopher-Earl: Strunk © in esse (hereinafter "Plaintiff", “Relator”), is an
individual who resides with place for service at 593 Vanderbilt Avenue #281 Brooklyn, NY
11238; Email: cestrunck@yahoo.com, SKYPE: cestrunk.
6. That Plaintiff is a natural-born citizen of New York with both Parents being citizens there
in the city of New York at the time of Plaintiff’s birth, that both Parents were married, and also
natural-born citizens of the united States of America (USA).
7. That Plaintiff is eligible to become the President of the united States of America
(POTUS) unlike Defendant because I meet the three requirements of eligibility: be at least 35
years of age, 14 years resident of the USA and be a natural born citizen at birth.

8. That Plaintiff makes a special-appearance in this action without relinquishing sovereignty
and or any inalienable individual right.
9. In explanation, Plaintiff’s Special-Appearance is as a Living-Soul Son-of-the Most-High-
God-Yahweh in existence nunc pro tunc the moment of Creation in Joint-Heir-with-His-Son
Made Debt-Free with the Yahshua Payment (consideration) of His Blood, in which Strunk
Stands in the Kingdom of the Most-High-God Yahweh, and that is under reserve, without
dishonor, without prejudice, without recourse in good faith, no dolus; and that this court and or
any temporal entity or person is unable to offer a higher consideration.
10. That Plaintiff has inalienable individual rights as described by the Declaration of
Independence of 1776 that pre-existed the creation of the united States’ Constitution.
11. That Plaintiff is the creator of the united States’ Constitution nunc pro tunc at the
moment of his Creation as an inheritance upon birth as a natural born-citizen.
12. That the Federal government is created by Plaintiff’s sovereign authority to protect his
inalienable individual rights and to define express limited rights for government to operate by.
13. That Plaintiff authority creates the corporate office of the President of the united States of
America, POTUS, to which Defendant Barack Hussein Obama was questionably elected without
presenting eligibility proof of his qualifications other than his opinion he was somehow eligible.
14. That Article 2 Section 1 Clause 5 of the united States’ Constitution is controlling and
only requires three qualification be proven to be eligible for assuming the corporate office of the
Presidency, i.e. an applicant shall be 35 years of age, 14 years resident of united States of
America and a natural-born-citizen; this is a case of first impression about natural-born-citizen
15. Defendant, Barack Hussein Obama (a/k/a Barry Soetoro) is located for service in care of
the White House 1600 Pennsylvania Avenue N.W. Washington, D.C. 20500.

16. Respondent Obama is not a USA "natural born" citizen eligible to serve as the united
States President, pursuant to the united States Constitution, Article II, Section 1, Clause 5.
17. Although Mr. Obama claims to have been born in two (2) separate hospitals in Hawaii,
he was actually born in Mombassa, Kenya to his mother a U.S.A. citizen and his father a Kenyan
National within the United Kingdom with law and Monarchy that governs.
18. That Mr. Obama Jr.’s natural father Mr. Obama Senior, was a British Citizen governed
under the laws of the United Kingdom married to Mr. Obama Jr.’s mother Stanley Ann Dunham
at the time of Mr. Obama Jr.’s birth on August 4, 1961.
19. Defendant Obama admits that his father at the time of his birth was a citizen of the
United Kingdom and that the British Nationality Act of 1948 governs dual citizenship at birth.
20. That Defendant Obama acknowledges by endorsing Senate Resolution 511 you need 2
U.S.A. Citizen parents to be qualified to be a natural born citizen.
21. That Rep. John Bingham, author of the 14th Amendment, Congressional Globe, 39th, 1st
Sess., pg 1291 (March 9, 1866) stated: “… every human being born within the jurisdiction of the
United States of parents not owing allegiance to any foreign sovereignty is, in the language of
your Constitution itself, a natural-born citizen.”
22. Defendant Obama has been asked for his "vault" version birth certificate; however, he
has refused, which has prompted law suits across the United States.
23. Instead, Mr. Barry Soetoro and or his agent(s) placed an image of a Hawaiian
Certification of Live Birth (COLB), which is issued for all birth's registered in the State of
Hawaii; the COLB, does not prove "natural born" citizenship or birth in Hawaii.
24. A COLB is sufficient proof of citizenship; however, it does not prove "natural born"
citizenship, a COLB is issued to those who are simply "naturalized".

AS AND FOR THE FIRST CAUSE OF ACTION
(For Defendant’s default and Failure to

Reply to the return of contract further acts are void ab initio)
25. Plaintiff repeats each and every allegation contained in the above introduction and
paragraphs 1 through 24 with the same force and effect as though herein set forth at length.
26. That on January 23, 2009 within 72-hours from Barack Hussein Obama’s offer of His
contract of Oath received by Plaintiff on 20 January 2009 and again on 21 January 2009
respectively, Plaintiff provided a timely return response by Registered mail with the United
States Postal Service (USPS) in care of the Agent in Charge of the united States‘ Secret Service
with NOTICE TO THE AGENT IS NOTICE TO PRINCIPAL NOTICE TO PRINCIPAL IS
NOTICE TO AGENT and FOR THE RECORD, and that both were accepted for value, timely
without dishonor and with consideration returned redrafted in the offer of contract of Plaintiff’s
choosing wishing no contract in full accord with the Unified Commercial Code (U.C.C.); for a
true copy of the original see Exhibit A.
27. That Plaintiff’s return response shown as Exhibit A by Registered mail with the USPS in
care of the Agent in Charge of the Secret Service with Registered mail Label/Receipt Number:
RE40 0301 908US was delivered at 8:07 AM on January 27, 2009 in WASHINGTON, DC
20223, for a copy of the USPS Tracking record and proof of service by registered mail see
Exhibit B.
28. That Plaintiff has received no reply from Defendant Barack Hussein Obama and or his
Agent(s) and remains in office as a usurper despite having been fired.
29. That Defendant Obama in esse fails to reply and is in default to Plaintiff.
30. Defendant Obama in esse is the usurper that has seized the corporate office of the united
States of America Presidency.

31. Defendant Obama in esse is the usurper whose actions while pretending as if the
corporate office of the united States of America Presidency are void ab initio.
32. That Plaintiff as the nunc pro tunc creator of the USA presupposes that the Federal
Constitution is still in effect with full force even under the 1929 reorganization plan that after
1933 with “the Switch in Times Cases” in re United States v. the united States of America, Inc.,
series of SCOTUS cases that allow the creditors to put the united States of America Inc. through
bankruptcy reorganization that in the process transforms the office of the President per se into
the Trustee administrator for the U.S.A. debtor in control of the assets under the bankruptcy
reorganization plan.
33. That the united States of America, Inc. was created when under the first method to repay
the revolutionary War debt the Articles of Confederation failed necessitated the adoption of the
second repayment plan method with the stronger Federal Union in 1789, that then without debt
repayment in 1859 again was transformed the third time promulgating the war between the
states, which then re-emerges as the Jesuit’s 14th Amendment America for the fourth time in
1929 with the Switch in Time cases that transformed the Constitution so that with the
Administrative Procedures Act of 1948 when Administrator Clinton found 5 trillion Dollars to
pay the debt, but rather than to pay the debt eliminated the Glass- Stegall Act of 1933 and
continues the multi-level ponzi scheme again beyond five levels, notwithstanding the SCOTUS
dicta against operation beyond the fifth reorganization cited in the Amway Case decision.
34. Relator / Plaintiff has suffered an informational injury as a voter and member of the
public; and by the lack of information on Mr. Barry Soetoro's citizenship, Defendant continued
usurpation is taking Plaintiffs property without substantive due process afforded that undermines
Plaintiff’s sovereignty and inalienable liberty.

AS AND FOR THE SECOND CAUSE OF ACTION
(For Defendant’s action to pay the debt with debt)
35. Plaintiff repeats each and every allegation contained in the above introduction and
paragraphs 1 through 34 with the same force and effect as though herein set forth at length.
36. Defendant Obama has publicly announced he is paying the debt of the USA with debt,
which is a Federal fraud crime when payment of debt may only be in specie, takes my property.
37. For the above aforementioned reasons, the above requested documents are of great public
interest and without receiving eligibility proof, Plaintiff liberty is at risk were the usurper of the
POTUS administrator which constitutes a huge National Security dilemma to continue.
Wherefore, Relator demands this Court to create a jury trial with the Quo Warranto Act to
determine the issue of facts: (i) where Defendant was born and (ii) whether or not both his
parents were united States’ Citizens at his birth; and thereafter a trial on the facts that the Court
as a matter of first impression must determine the law as to what is the natural-born-citizen
requirement of Article 2 Section 1 Clause 5 of the united States’ Constitution, that the Court
order the removal of the Usurper or legitimize the POTUS administrator, and provide further and
different relief for Justice herein.
Respectfully demanded by,
Dated: May 19th , 2009 /s/ Christopher-Earl : Strunk, in esse

Brooklyn, New York ___________________________
Christopher-Earl : Strunk © in esse
Attached Exhibits A through B
cc: sent via regular and certified mail to Attorney General Eric Holder as well as to the U.S.
Attorney for the District of Columbia, Mr. Jeffrey Taylor; and
Barack Hussein Obama in esse

VERIFICATION
STATE OF NEW YORK )

) ss.
COUNTY OF KINGS )
Accordingly, I, Christopher-Earl: Strunk © in esse, by special-appearance being duly sworn,

depose and say under penalty of perjury:
1. That I am the Plaintiff / Relator, Christopher-Earl: Strunk © in esse, with place for
service at 593 Vanderbilt Avenue #281 Brooklyn, New York 11238.
2. That I am the sovereign employer of the POTUS who exercises authority over my grant
of power of attorney permission given to administer the united States of America Inc.
3. I duly fired Barack Hussein Obama (Respondent) for cause on January 23, 2009 after he
took the oath of office by timely return of the offer of contract wishing no contract thereby
revoked power of attorney due to his failure to prove eligibility as a natural born citizen.
4. That Respondent in esse usurps that office and presumably wishes to have a Quo
Warranto forum to prove his eligibility to be able to return to the corporate office capacity.
5. I hereby give my permission for a Quo Warranto jury trial of the issue of facts.
6. I have read the above Quo Warranto Complaint With Demand For Jury Trial And
Decision On Question Of First Impression with exhibits attached and aver that it is related to the
FOIA Case 08-cv-2234 for Extraordinary Relief in the Nature of a Writ of Mandamus and I
know its contents; the facts stated in the Complaint herein are true to my own personal
knowledge, except as to the matters therein stated to be alleged on information and belief, and as
to those matters I believe it to be true. The grounds of my beliefs as to all matters not stated upon
information and belief are as follows: 3rd parties, books and records, and personal knowledge.
except as to those stated upon information and belief, which I believe to be true.
/s/ Christopher-Earl : Strunk, in esse
________________________
Christopher-Earl : Strunk © in esse
Sworn to before me
This 19th day of May 2009
/s/
_____________________
Notary Public

EXHIBIT A
Ia atre of:
593 Vsmdertrilt Avenue -281
Brookrlp New York
CI~k~pher-Earl: Stm& Q
Not a c a p a t i o z i
Livhg-snul
Deelarant
h c k H& O h in @8@, No Third P d e s
&a Bany S m in as%,
~ a we, ~ ~ h
a l k ( a ~ ~ ~ ~ & ~ ~
DBA BARACE:HSJSSEIN O B U INC.
-VEOR(S), W S ) , AGENTCS),
MSLCI?(S]
InanE~f:
the AGENT m*CHARGE OF THE
UNITED STATES SECRET SERVICE
9tJF~eoft3avmmmf rmd Pubficflairs
245 M.lrpay Drive*
Budding 410,
Washingtan, DC 20223
NOTICE TO THE AGENT IS NOTICE TO PWCIPAL NOTICE TO PRFNCIPAL

IS NOTICE TO AGENT
RE:OFFER OF CONTRACT
Received 20 January 2009 and received 21 January 2009
FOR TEE RECORD

RlETURN AM) REDRAPT
TIMELY1WITHOUT DISHONOR
WrrH THE l W S l 3 U m SPECIAL-APPlURANCE
NOT A COWORATION
The Lming-Soul
Atmhents:
Oath of 20 January 2009 offer for mntrmt /Returned & R e d d b d
* Oath of21 darmary 2009 off= for csntract IReturnd & R*
* Notice to the Clerk of Records
Judicial Notice b e 1 of 2)
* Judicial Notice @age 2 of21
! :
Ohms md US chief
mixed S~te3.''
R&m "And will to toe best &my abiiity."

President Obama; "And will to the best of my abili
P r e s i h t O W a : "Pmewe,pratect and defend the cm

States. "
Robertr;: "So help me e d . "

Pm'sidet O b a :'Sb help me Go&"
Roberts, O b d ' l
hm! yitijd
~ P W
:PmidWal Qath FOX News
Bmck Bbma 3tirmE:ed $qhllj wwr

brief,awkward m m w d in an o t h e w b
ing fine,tT* whi& BEpreS&if repab
mingm la@ TechniGalty,

mmifigpmidenf begins at
n m on Jm. 20
TRANSCRIPTOF O A T ~ ~ E ~
CJ Roberts.
4
-Are you p&ai#l
BHO : "I am.' sJ
BHO : --.-
-----'
to t h e b -
BHO: "#at 1 will &xGicuPe..
CJ Roberts: "faithfully...the OfF1~3of President of We Uniied Sd.-
BHO : 'fhe W e of President of the United States faitbfullfl
CJRobeW "andl wltotlie besfofmyability...
BHO: 'en= !wi! ta a&hest of my stiility..
CJ Roberts: *...preserve protectand defend fheCai~stitutioA
8HO: " .
". .preseTve protect arro'defend the Cmstifufr"0n of the t ..
CJ Roberts: "So he:^ ybti God"
BHO : *So help me Gad",
'4'
U.S: Cadtutioion ArWe 2 Section 1 Clause 8. .. 'I do solernnlv
- - 8
swear tor aHim
--
7 - -
the Offlce of President of the ljnitea States, and I will to the k t of my

the ~o~wfttution
of the united ~ t a ~ s . " w;JP-d~
NOTlCE TO W E CLERK OF RECORDS
Ttit minnteyon d v e any recod, document, paper, proceeding, map, book or o d ~ mthing depOsitea with
you, you are commhhg aim= against justice d m Revised S W t s of the United Stam First Section
43 Congms, Sections 5403,5407 aad 5408 totaling up to $9,000 in h w and up to 12 years in prison pm
a&hvityaufailtoremrd T i t l e l 8 U S C ~ m 2 0 7 1atsocaui-kqimpriisonmentand
dkplification of&- If p u t county attorney toid you not to file any documents like mine, yon are
still rsspomible, as I da no acmpt
h m the hwydng d am dl e rd-party-intebvenem. Any attorney, district attorney, or q m e
parties and do not have a licu~seto make a legal detmmhation in
this matter as they do not represent M e and Yau, the oomty c l e do not have the authority to r e p m t
Me. Should You fail to uphold Your swom o& and +rm your duties I will h v e no choice but to
rcwrd aaA€iiaaVit ofC r i m i d Complaint agahtst Your amd Liend a mpy to Your bonding company.
Title I X X 4 ~ , - C W . 4 . CIUMES AGAINST JUSTICE
5-03. Every person who willfully destroys Mattempts to deshoy, or, with intent to steal or d m y ,
takes and carries away any mmd, paper, or promding of a c o w of justice, filed or deposited with any
c l d or oEcer of so& court, or any papa, or document, or record fled or depasikd in any public ofice,
or wid^ any judicial or public officer, &dl, withunt rehmce to the vaIue of the record,paper, d o m e d ,
or procGediag srr taken, pay a h e ofnot more than two thousand dollars, or s* imprisonment, at hard
l a b , aot mwe thaa tree ywm, or both: [S* Q 8 54083411,54 t 4.1J Titie =.- C - . - CH.4.
CRIMES AGAINST msnm h,pablic-ds.)
SC5407. Iftwo or more peasons in my State or Taritory conspire for the purpose ofimpeding
hindering.o b c h g or defeating,ia any m ,thed m come ofjustice in any State or Territory, with
intent d q to my citizenthe equd protection of the laws, or to in* him or his property fur lawhlly
wforcin& or att~tllptingto enforce, the right of any person, or class of person, to the equal protection of
thelaws, ewhofsochpersonshall beprmishedby a f i n e o f n o t l ~ t b a n ~ e h m d r e d n o r m o r e ~ f i v e
thomaad dollam, or by imprkoammt, witb or w i t h u t harrl I&ra wt less than six month nor more tban
six years, or by both sueh h e and imprisonmeai. S w 5 9 1977-1991,20042010,5506-5510.1 Tide LXX
- -
CIUMES. CK.4. CRIMES AGAINST JUSTICE (Conspiracy to defeat enfammart ofthe laws.)
SEC5408. Evwy officer, having the custody of my m r d , document, paper, or proceding specified in
e m fifty-fim hundrcd and three,who f m d d d y takes away, or withdraws, or destroys any soah
rwmd, docmmt, paper, or p m c d k g filed in his OEM or depsitsd with him or in his cmtody, shall
pay a fine of not more fhan two thougand dollars, or d e r imigrisoammtat bard labor not more than three
yms,or bo€band W moreaver, Wcit his office and be foreva d k w a r d disqualified froan holding
arry ofice u a d a the Govmment of the United States. @esbyiug record by oEca in charge.)
S d o n 2071. Concealment, ternoval, or mutilation geblmlly
(a) Whoever wiifulIy and unlawfUfly c m c d s , removes, mutilates, obliterab, or d a m p , w

attmnpts to do so, or, with intent to do so takes and canim away my record, proceeding, map,
book, paper, documen5 or other thing, flbd or dtposited with any clak or o f i c a ofany mnd of
the United W,or in any public office, or with any jdicia! orpublic o 5 c a ofh e United
States, shall be ha under ihs title w imprisoned not more tban kyears, or both
(b) W
h-, M g the wstody ofmy such reed., proceeding, map, book, doarmeat, paper, or
other thing, wiIlllly and d a w f d y conads, removes, mutilates, obliterates, fddies, or destroys
the same, Bhall be fined unda this title or imprimned mot more than tbrae years, Mhth; d s h d
forfeit his office andbe disqualified ftwn ho?di~~gany office mdu the United States. As used in
this subsection, the t m u~ffi~e" does not include the oftice held by my pason as a reaired officer
ofthe Armed F o m of the United States.
[While the misrcpresentetiw of a matend fact, pgst or present may eonslim basis
for an inf- of 1-1 Viad." any act omission or- &ih holves
a breach oflewl duty, mor cmf~dencc justly r e p o d and is injurious m another.
or hy which an undue advantage is taken of another, may become the hundation far
i n f of~fraud, aud wtren them is a duty to t t matetiid
k o o ~ l m e r rofa
fact may b equally rts wrongful as t positive misctpnsenhtbn.Tex.Civ. App. 1943
Ruebeck t*, Hrt~tt.171 SW2d 895, Wwmed I v6 S1Ud 7382 I42 T m 167i I50 A. L.R
""5.1
(Party having supmior knowWge who takes ahan- of mother's ignoramx of the
law to deceiivs him by studied canceatment or mismpremtatiwr can be held reqm-
h k 726
sible fbr that conduct. rex. 1987. FinaSup&. Im v. rfbileneNati~~nul
SW2d S3A
[We(judge5j have na mom right ta decline ttu3 exercise ofjraisdiction which is given,
(thb will include the county court of recodjradgg Victw CariIlo) than lo usurp tha~
which is n d given. The one or the other would be -I to the C.nnstitution."
Chhm v. 6 Kkut 264. (1821); U.S v. WiIJ, 499 US.2M.I
'W)heaa governmwa becomes a patw in my imdhp company, i r diva^^ h l f ,
r(
s(l far tls tmcenc~the mwactim of dmt cornparry. of its sovereign c b t c r , and
t a b that ofa private c m . .-It &ends to a level with t b a with whom it associate
i ~ i fand
, rakes the c w which b b g s to its asxxiahts and to the business
which is to be transacted.* &rnk tfUhiledSIata v. PI MI^ ' Bank rlfUmr~iu
22 US.904(lrP24I.J
["The United States as drawee of cdmmemial p p r stands in no dierent light tfian

any o h r drawee." "The IJpited S t a t u does business on busirmtss terms.It is not
exem@ fKHn the gem1 rules governing the ii@mand duties of drawees by the
largmts of its deaIinp and its having& employ agents to do what ifdone by a
principal in p m m would kave no mom for dmMWCI@& Mt C h v. United
318 iLS. 36311943),]
,SCLICRP.
1°C- enforcing mem saaates do mot act judicially, but rninkwialiy, having na
judieial lmulunky, and unlike Corpts of LAW, do not obtainjlPisdition by m i c e of
pmmnor even by A m s t and Compelled Appemme." BanueII v. Qrir, 9 HOW&
336, 34x1
VWant uf jurisdiction may not be cured by ms

m t ofthe ~ ' e s . I" ~ i d . t r l r l i i t > n
Asstxiation E CL R.323 US 310.3 13.1
[ Judicial Notice ]
1. ["A judgment rendered in violation of due process is void" World Wde VoIKrwagot
W d e r r , 444 US.286,29 I ; National Bmtk v. WiZey, 195 US 257; Penmyer v. Ne_t
95 US 7143
[ ",.. the .mpkmmtsofdue process must b met Wore the court can properly assert in
persomnt j ~ c t i o n "WeZIsFargo v. W e b Fargo,556 F2d 406,416.1
[. Notification of legal respnsibiity is we essential of due process of law."

C o d & v. Geaeral Combwdion Co., 269 US 385,3911
[. w A ~ w h i c h e i t h e r f o r b i & o r r e q ~ ~ d o ' m g o f m ~ i n ~ s o v a g u e t h a t
men ofcommon intelligence must necessarily guess at its meaning and differ as to its
application, violates the tmntial of due process of law." C o d I y v. General
Comimction Co.. 269 U.S. 3 8539I]
[. nWheneverit appears that the court lacks subject matterjuzisdiction, the ant is
obliged to dismiss the actiua" Elly v. Coastal Cop., 503 U.S. 131,136-37; U S. v.
Texar, 252 F. Supp 234,2541
[. " O n o e ~ c t i o in s challenged, the court cannotproceed when it clearly s p p e a ~ s

that the court lacks jurisdiction, the court has no authority to reach merits, but, rather
should d i e the &m'' Melo v, US,505 F.2d 10261
is no d i d o n to ignore lack o f ~ c t i c m "

Joyce v. US,474 F 26 2151
EXHIBIT B
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'ps am-3811. ~ebnrary2 0 ~ brmsstic ~etum~eceipt
W .mplete items 1.2, and 3.Aiso complete

' item4ifReshictedDelhmryisdeshed.
Print you name and address on the meme
so that m,can mtum the card to you.
- Attach this card to the back of the mallpiece,
aonlhefmnt if space permits.
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n YES, enter
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.PSFcmn3811. ~etxuary2004 ~eceipt

~anestlc~etum rcag54~&im*-
-% - - i
Exhibit 3
Exhibit 4
Ic' &
:Non-Domestic
In Care of:
V
593 Vanderbilt Avenue - 281
b Brooklyn, New York
Not a corporation
UNITED STATES DISTRICT COURT Living-Soul / Relator
Christopher-Earl: Strunk O in esse, ) /

1
Blaintiff, ) .
v. > Civil Action No.: 08-2234 (RJL)
)
U.S. DEPARTMENT OF STATE, and
U.S. DEPARTMENT OF HOMELAND
SECURITY,
)
)
)
, -
Defendant. )
.................................... X
UNITED STATE3 DISTRICT COURT
\-. . FOR THE DISTRICT OF COLUMBIA
.................................... X
In the Quo Wananto matter of the
United States of America and ex relator JUDICIAL NOTICE
Christopher-Earl: Strunk O in esse .
Plaintiff / Relator
v.
Barack Hussein Obama

(alkla Barry Soetoro) in esse
Defendant / Respondent.
.................................... X
PLEASE TAKE JUDICIAL NOTICE that upon the annexed: (i) a copy of Relator's Replevin Demand
of the Usurper Barack Hussein Obama with DCC Chapter 37 516-3701"); (ii) a copy of Relator's
Replevin Demand of Gary Faye Locke the Usurper's Secretary of the United States Department of
DC Code Chapter 37 $16-3701- In an action of Replevin brought to recover personal property to which
the plaintiff is entitled, that is alleged to have been wrongfully taken by or to be in the possession of and
wrongfully detained by'the defendant, it is not necesqqry to demand possession of the property before
.. -
bringing the action; but the costs of the action may belawarded as the court orders.
Commerce with DCC Chapter 37 3 16-3701 (iii) a copy of Relator's Replevin Demand of Timothy Franz
- Geithner the Usurper's Secretary of the United States Treasury with DCC Chapter 37 $16-3701.
That Relator Christopher-Earl : Strunk in esse, by Special-Appearance herein, declares and states
under penalty of perjury with 28 USC $ 1746:
(1) that Plaintiff / Relator duly served the respective demand upon each Respondent / Debtor
by Certified Return Receipt:
.Debtor- Barack Hussein Obama in esse ......Receipt No: 70092250000365685338
Debtor - Gary Faye Locke in esse.. ............ Receipt No: 70092250000365685277
- ...
Debtor Timothy Franz Geithner in esse.. .Receipt No: 70092250000365685345
(2) that Plaintiff / Relator duly serves hereby notice of the respective demand of each debtor
. named above upon the State of New York Secretary of State under the Uniform Commercial Code
Section 9-501 that governs place of filing. Subsection (a) (2) the financing statement is filed as a fixture
filing and the collateral is goods that are or are to become fixtures. Subsection (a) (2) provides that the
ofice in which to file a financing statement to perfect a security interest is the office of the Secretary of
State in all other cases. Pursuant to subsection (b) a fijrture filing for a transmitting utility would also be
filed with the Secretary of State.
(3) That the respective State of New York Secretary of State oversees the U.S. Treasury
District that has authority over the property where Plaintiff is in esse d8micile resides.
(4) That a copy of this Notice is filed with the State of New York Secretary of State along
with a Ten Dollar filing fee as there required.
Dated: November 2
2009
Brooktyn New York
Christopher-Earl: Strnnk @in esse
Brooklyn, New York;
Attachments
cc: . Brigham John Bowen, AUSA Wynne P. Kelly, AUSA

U.S. DEPARTMENT OF JUSTICE Office of the U.S. Attorney for the
20 Massachusetts Avenue, NW Washington District of Columbia
Washington, DC 20530 555 4th St., N.W.
Barack Hussein Obama in esse Daniel E. Shapiro

C/OThe White House First Deputy Secretary of State
1600 Pennsylvania Avenue NW State of New York Department of State
Washington, DC 20500 One Commerce Plaza
99 Washington Ave,
Albany, NY 12231-000 1
Cert R/RNo: 70083230000005905998
Brooklyn, New York
Not a corporation
Living-Soul 1 Af'fiant
No Third Parties
Timothy Franz Geithner in esse
D/B/A: TIMOTHY FRANZ GEITHNER, INC.
D/B/A: THE UNITED STATES SECRETARY OF THE TREASURY,
SUPERVISOR(S), HETRS(S), AGENT(S), ASSIGN(S)
In care of: The United States Department of the Treasury

1500 Pennsylvania Avenue N.W.
NOTICE TO THE AGENT IS NOTICE TO PRINCIPAL

NOTICE TO PRINCIPAL IS NOTICE TO AGENT
RE: NOTICE OF REPLEVIN DEMAND

FOR THE RECORD WITH WASHINGTON DISTRICT OF COLUMBIA
CODE CHAPTER 37 SECTION 16-3701: DEMAND PRIOR TO ACTION;
COSTS - In an action of replevin brought to recover personal property to which the plaintiff is
entitled, that is alleged to have been wrongfklly taken by or to be in the possession of and
wrongfully detained by the defendant, it is not necessary to demand possession of the property
before bringing the action; but the costs of the action may be awarded as the court orders.
TIMELY WITHOUT DISHONOR WITH THE RESTRICTED SPECIAL

APPEARANCE NOT A CORPORATION -The Living Soul
Attachment: NOTICE OF REPLEVIN DEMAND FOR RETURN OF

PROPERTY PENDING THE REPLEVIN COMPLAINT
FILING af'firmed November 9,2009 Page 2 of 2 ............
Under reserve with the copy-claim
without pr?judice, witbut recourse
O in esse
Page 1 of 2 not a corporation Living-Sou!
STATE OF NEW YORK )
) ss.:
COUNTY OF KINGS )
Accordin~iv,I, Christopher -Earl: Strunk, being duly sworn, depose and say:

In the Replevin matter of

Christopher-Earl : Strunk O in esse
Plaintiff / Claimant
Bolrack Hussein Obama (&a Barry Soetoro) in esse,

Gary F. Locke Secretary of the U.S. Department of Commerce, and
Timothy F. Geithner Secretary of the U.S. Treasury
Defendants / Respondents
--------------------------------------------
NOTICE OF REPLEVIN DEMAND FOR RETURN OF PROPERTY
PENDING THE REPLEVIN COMPLAINT FTLING
The Plaintiff sues the Defendants for unjustly detaining the Plaintiffs goods and chattels, as the
Usurper, Barack Hussein Obama, is ineligible to be the President of the United States Trustee / Administrator
over any United States Departments and Secretaries with fiduciary responsibilities and the Usutper having been
denied use of Plaintips power of Attorney on January 23,2009 has by Usurper's continued actions that are void
ab initio, including the waivers issued as to Defendant Secretaries and others, pillage Plaintiff's personal
property to wit:
A) the Plaintiffs Bond issued upon his birth certificate of CHRlSTOPHER EARL STRUNK after the
birth in New York City on January 23, 1947 in the amount of 19687.5 troy ounces of gold;
B) the Plaintiffs private account at the US Treasury is secured by the Plaintiffs numbered Bond kept at
the U.S. Department of Commerce with the Bond number issued by the Social Security Administration; and
C) The interest accrued upon the Plaintiff's investment into commerce since the year of 1963 thru now
calculated upon the record by the Social Security Earnings Statement compounded annually at the respective
annual U.S. Treasury Bond Rate from 1963.
And the Plaintiff claims that the same be taken from the Defendants and delivered to Plainti% or, if they
are eloigned, that Plaintiff may have judgment of their value and all mesne profits and damages, which he
estimates at the present value of $2 1,656,250.00 dollars based upon the equivalent current market value of gold
with a net present value of 5,431 7 troy ounces of gold, a d 909 troy ounces of gold accumulated interest on
Plaintiffs investment into commerce since 1963 besides costs.

Brooklyn, New York
Zip Code exempt DlWM 122-32
QEOMEANDERSON
-
Email: chris@2trunkws ;Ph- 631-745-6402
Public, State of New W k
the day of November NO.01AN5070990 Under reserve with the co~v-claim
Qualified in Kings County
Comnission Expire6 Jan. 6,20 11 without prejudic
fi
PUBLIC
N O T ~ Y Page 2 of 2 nnt a mmnratinn I i\/inn-.Cni11
P"-
In Care of:
Brooklyn, New York
Not a corporation
Living-Soul 1 Afiant
Gary Faye Locke in esse No Third Parties
allda %%B (pronounced LOR Gua-Foi)
D/B/A: GARY FAYE LOCKE, INC.
D/B/A: UNITED STATES SECRETARY OF THE DEPARTMENT OF
COMMERCE, SUPERVISOR(S), HELRS(S), AGENT@), ASSIGN(S)
In care of: The United States Department of Commerce

1401 Constitution Avenue N.W.

RE: NOTICE OF REPLEVIN D E W D
FOR THE RECORD WITH WASHINGTON DISTRICT OF COLUMBIA

entitled, that is alleged to have been wrongfully taken by or to be in the possession of and
TIMELY WITHOUT DISHONOR WITH THE RESTRICTED SPECIAL-


FILING affirmed November 9,2009 Page 2 of 2 ...,........
Under reserve with the copyclaim
O in esse
Page 1of 2 - - not ahrporation Living-Soul
STATE OF NEW YORK )
) ss.:
c o r n OF KrNGS )
Accordindv, I, Christopher -Earl: Strunk, being duly sworn, depose and say:

FOR TRE DISTRICT OF COLUMBIA

Christopher-Earl :Strunk 8 in esse
Plaintiff / Claimant
Barack Husseie Obama (&a Barry Soetoro) in esse,

------------------------------------
NOTICE OF REPLEVIPl DEMAND FOR RETURN OF PROPERTY
PENDING THE REPLEVIN COMPLAINT FILING
The Plaintiff sues the Defendants for unjustly detaining the Plaintiffs goods and chattels, as the
Usurper, Barack Hussein Obama, is ineligible to be the President of the United States Trustee 1 Adminimtor
over any United States Departments and Secretaries with fiduciary responsibilities and the Usurper having been
denied use of Plaintiffs power of Attorney on January 23,2009 has by Usurper's continued actions that are void
ab initio, including the waivers issued as to Defendant Secretaries and others, pillage Plaintiffs personal
property to wit:
A) the Plaintiffs Bond issued upon his birth certificate of CHRISTOPHER EARt S T R W after the
birth in New York City on Jmuary 23, 1947 in the amount of 19687.5 troy ounces of gold;
B) the Plaintiffs private account at the US Treasury is secured by the Plaintiff's numbered Bond kept at
C) The interest accrued upon the Plaintiffs investment into commerce since the year of 1963 thru now
calculated upon the record by the Social Security l3uning.s Statement compounded annually at the respective
annual U.S. Treasury Bond Rate from 1963.
And the Plaintiffclaims that the same be taken from the Defendants and delivered to Plaintiff; or, if they
with a net present value of 5,817 troy ounces of gold, and 909 troy ounces of gold accumulated interest on
Plaintiff's investment into commerck since 1963besides costs.
593 ~anderbiltAvenue #281

Brooklyn, New York
*-
Email: chris@trunk.ws ;Ph- 631-74S-6402
the day of No mber 2009 Under reserve with the copy-claim
dEORGE ANDERSON
Notary Public, State of New Ybrk
No. 01AN5070090
Qualified in Kings County @ in esse
Commission Expires Jan. 6,20I/ Pgge 2 of 2 not a corporation Living-Soul
Brooklyn, New York
Not a corporation
Living-Soul / Affiant
Barack Hussein Obama in esse No Third Parties
a/Wa Barry Soetoro in esse,
a/Wa Barry Dunham in esse,
D/B/A: BARACK HUSSEIN O B W , INC.
SUPERVISOR(S), HETRS(S), AGETW'(S), ASSIGN@)
In care of: The White House


RE: NOTICE OF REPLEVIN DEMAND
FOR 'THE RECOW WITH WASHINGTON DISTRICT OF COLUMBIA

entitled, that is alleged to have been wrongfully taken by or to be in the possession of and
TIMELY WITHOUT DISHONOR WITH THE RESTRICTED SPECIAL


FILING affirmed November 9,2009 Page 2 of 2 ............
Under reserve with the copy-daim
0 in esse
\-
not a corporation Living-Soul
Page 1of 2 . .,
, .*
STATE OF NEW YORK )
) ss.:
COUNTY OF KINGS )
Accordinely, I, Christopher -Earl: Strunk, being duly sworn, depose and say:


Christopher-Earl :Strunk 0 in esse
Plaintiff 1Claimant
Barack Hussein Obama (a/k/a Barry Soetoro) in esse,

-----------------------------------------
NOTICE OF REPLEVIN DEMAND FOR RETURN OF PROPERTY
PENDING THE REPLEVIN COMPLAINT FILING
The Plaintiff sues the Defendants for unjustly detaining the Plaintiff's goods and chattels, as the
Usurper, Bruack Hussein Obama, is ineligible to be the President of the United States Trustee I Administrator
over any United States Departments and Secretaries with fiduciary responsibilities and the Usurper having been
denied use of Plaintiffs power of Attorney on January 23,2009 has by Usurper's continued actions that are void
ab initio, including the waivers issued as to Defendant Secretaries and others, pillage Plaintiffs personal
property to wit:
A) the Plaintiff's Bond issued upon his birth certificate of CHRISTOPHER EARL STRUNK after the
birth in New York City on January 23,1947 in the amount of 19687.5 troy ounces of gold;
B) the Plaintiffs private account at the US Treasury is secured by the Plaintiffs numbered Bond kept at
C) The interest accrued upon the Plaintiff's investment into commerce since the year of 1963 thru now
calculated upon the record by the Social Security Earnings Statement compounded annually at the respective
annual U.S. Treasury Bond Rate fiom 1963.
And the Plaintiff claims that the same be taken fiom the Defendants and delivered to Plaintiff; or, if they
with a net present value of 5,817 troy ounces of gold, and 909 troy ounces of gold accumulated interest on

Brooklyn, New York
Email: chris@strunkws ;Ph- 631-745-6402
the day 05November 2 0 q Under reserve with the CODY-claim
..
.. QEORGE ANDERSW ,'

Public, State of New Ybrk
~atrry By: O in esse
No.01AN5070990 - not a corporation Living-Soul
Qualified in Kings CouW Page 2 of 2
-on Expires Jan. 6,201I
BROOKLYN, New York
112205313
3568880337-0097
11/10/2009 (718)748-0665 12:02 :20 p~
......................................
............................... - ,
Sales Receipt -----c- -

Product Sale Unit Final
Description Qty Price Price
Postmark
IIASHINGTON DC 20230 ., 1'
$0.44
Here ,
Zone-3 Fi rst-Class Restricted Delivery Fee

0 (Endorsement Required)
Letter
0.70 02.
Return Rcpt (Green $2.30
Card)
Certified $2.80
Label #: 70092250000365685277
--------
Issue PVI: $5.54
WASHINGTON DC 20509 , $0.44
Zone-3 F ir s t -C 1ass '
Letter
0.70 02,
Return Rcpt (Green
Card)
~ e ri ft ied $2.80.
Label #: 70092250000365685338
Y
v)
- Postage / $ 40.44 j om
--------
-------- m. Certif~ed
Fee I S2.M 1 04
Issue PVI: '$5.54 .. Return ReceipLFee
Postmark
(Endorsement Required)
WASHINGTON DC 20220
Zone-3 Fi rst-Class -- .
$0,44
__A_-- u
l
-
0
o
Restricted Deliver/ Fee
(Endorsement Required) 1
1$
M.W
$5.54
I1 ll/lU/?i#)3
Letter Iu
Total Postage& Feas
0.70 02.
7
Gary Faye Locke in esse
3fi DIBIA: W E D STATES SECRETARY '-"""
Return Rcpt (Green OF THE DEPARTMENT OF COM%@,RCE
Card) SUpERVISOR(S), HEIRS(S1 AGENT(%
Certified $2.80 \
ASSIGN(S) 1n are ot
Label #: 70092250000365685345 V.S %putmeat of Commerce ' ,
-------- 1401 Constitution Avenue N.W.

Washington. DC 20230
Issue PVI: $5.54
$1 Wisdom 4 $1 .OO $4.. 00

PSA
Total :
Paid by:
Cash U&HINGTON DC 20500
60.44 0337
Order stamps at USPS.com/shop or
c a l l 1-800-Stamp24. Go t o Cert~f~ed
Fee S2.m O4 Postmark
USPS.com/clicknship t o p r i n t Retum Receipt Fee Here
(Endorsement Reqliiredj $2.30
shipping labels with postage. For
Restricted Dellvery Fee
other informat ion c a l l (Endorsement Required)
1-800-ASK-USPS , In
Iu
Toid Postage & Fees $ 1 $5.54 11/10/2&?9 I
Hussein obamaid eSJe'
",IBIA: B ~ c K W S S EOB~
s u p ~ ~ v c s o R (HEMS),
9. AGENT(%
ASSIGN(S) In care OF. The WhikHouSe
1~ pemsyhania Avenue
-- .- -II_--
U.S. District Court for the District of Columbia
in re Strunk v. U.S. Department of State et al., 08-cv-2234 (RJL)
On November 10,2009, I, Christopher Earl Strunk, under penalty of perjury pursuant to 28 USC
1746,
Am the petitioner herein being pro se without being an attorney caused the service of three (3)
complete sets of the Attachments annexed to JUDICIAL NOTICE declared November 10,2009 ,
and did place a complete set in a sealed folder properly addressed with proper postage to be served
by USPS mail upon:
Wynne P. Kelly, AUSA

Office of the U.S. Attorney for the
Washington District of Columbia
555 4th St., N.W.
Brigham John Bowen, AUSA

Bmack Hussein Obaana in esse

C/OThe White House
Daniel E. Shapiro
First Deputy Secretary of State
State of New York Department of State
One Commerce Plaza
99 Washington Ave,
Albany, NY 12231-0001
Cert RIR No: 70083230000005905998
I do declare and certifl under penalty of perjury:
Dated: November lo ,2009

Brooklyn, New York
Christopher-Earl: Strunk
593 Vanderbilt Avenue - #28 1
Exhibit 5
Christopher-Earl: Strunk
Brooklyn, New Y ork 11238
Cell phone: (845) 90 1-6767
E-mail: chris@strunk.ws
The Honorable Richard J. Leon

United States District Judge for the !
333 Constitution Avenue, NW, Room 63 15,
Regarding: Strunk v. US.De~artmentofstate et al. 08-cv-2234 (RJL)
and Taitz v. Obama 10-cv-0015 1 (RCL)
Subject: Request to sever the proposed Quo Warranto Inquest
The Honorable Richard J. Leon, il
I am the plaintiff Christopher-Earl Strunk, pro se without being an attorney, declare

under penalty of perjury with 28 USC 1746: (i) that there is a pending decision on both the stay
on further discovery and the Cross Motion request for conversion of the FOIA matter to a Quo
Warranto inquest; (ii) As of this reading Declarant has made an application to the Honorable
Chief Judge Lamberth to intervene in Taitz v Obama 10-cv-0015l(RCL) as an Ex-relator
Intervener-Plaintiff (See Attached). Declarant hereby requests an order of the Court to sever the
propased Quo Warranto Inquest from this FOIA case for due process as a supplement in the Quo
Warranto Petition for a Writ of Mandamus therein, and also grant permission to make a motion
to lift the stay on discovery herein.
This matter complained of is extremely urgent and requires expedited handling as time is
of the essence and involves matters of irreparable harm and is a matter of National Security if not
handled expeditiously. Respectfully submitted by: n
Dated: January Zq2009
Brooklyn, New York
593 ~ahderbiltAvenue - #28 1

Cell phone: (845) 90 1-6767
E-mail: chris@strunk.ws
Attached: NOM to Intervene in 10-cv-00151
cc: Brigham John Bowen, AUSA

in re Strunk v. U.S. Department of State et al., 08-cv-2234 @L)
On January 30,2010, I, Christopher-Earl: Strunk in esse, under penalty of perjury pursuant to 28
USC 1746,
Caused the service of one (1) complete set of the Request to sever the proposed Quo Warranto
Inquest along with the attachment CHRISTOPHER-EARL: STRUNK IN ESSE NOTICE OF
MOTION TO INTERVENE AS A EX-RELATOR INTERVENER-PLATNTIFF in 10-CV-00151
with Affidavit in Support with Exhibits annexed affirmed January 29,201 0, and did place a
complete set in a sealed folder properly addressed with proper postage to be served by USPS
mail upon:
Brigham John Bowen, AUSA

U S . DEPARTMENT OF JUSTICE
I do declare
Dated: January 3ofh,2010

Brooklyn, New York
593 vkderbilt Avenue - #28 1

Brooklyn, New York 1I238
Cell phone: (845) 901-6767
Exhibit 6
THE WHITE HOUSE
WASHINGTON
August 26,2009
Mr. Christopher Strunk

Unit 28 1
593 Vanderbilt Avenue
Dear Mr. Strunk:
Thank you for contacting the office of President Barack Obama. The
President appreciates your taking the time to voice your concerns and opinions.
We would like to be of assistance to you; however, due to the separation

of powers, it is not within our authority to become involved in legal matters. You
must resolve this issue through the judicial system.
Please be aware that you can visit www.usa.Pov or call 1-800-FEDINFO

for information about Federal Government assistance.
We hope your concerns are resolved to your satisfaction.
Again, thank you for your correspondence.
Sincerely,
F. Michael Kelleher
.. Special Assistant to the President and
Director of Presidential Correspondence
in re Taitz v. Obama, 10-cv-00151 (RCL)
On January 30,2010, I, Christopher-Earl: Strunk in esse, under penalty of perjury pursuant to 28

USC 1746,
Declarant caused the service of five (5) complete sets of the Request to sever the proposed Quo
Warranto Inquest along with the attachment CHRISTOPHER-EARL: STRUNK IN ESSE NOTICE
OF MOTION TO INTERVENE AS A EX-RELATOR INTERVENER-PLAINTIFF in 10-CV-
00151 with Affidavit in Support with Exhibits annexed a f h n e d January 29,2010, and did place
each complete set in a sealed folder properly addressed with proper postage to be served by USPS
mail upon:
The Honorable Richard J. Leon Eric Holder, U.S. Attorney General
United States District Judge for the C/OBrigham John Bowea, AUSA
U.S. District for the District of Columbia U.S. DEPARTMENT OF JUSTICE
333 Constitution Avenue, NW, Room 63 15, 20 Massachusetts Avenue, NW
Washington, DC 20001 Washington, DC 20530
Delivery Confirmation No.: Delivery Confirmation No.:
03070020000527460107 03070020000527460121
Channing Philips, the U.S. Attorney Barack Hussein Obama in esse

c/o Wynne P. Kelly, AUSA C/OThe White House
W%ce of the U.S. Attorney for the 1600 Pennsylvania Avenue NW
Washington District of Columbia Washington, DC 20500
556 4th St., N.W. Delivery Confirmation No.:
Wtpbington, D.G. 20530 03070020000527460135
R@iveryConfirmation No.:
Q3Q7002000052746009 1 Dr. Orly Taitz, D.D.S.
29839 Santa Margarita Parkway, STE 100
Rancho Santa Margarita CA 92688
Delivery Confirmation No.:
03070020000527460107
Dated: January 3 0 201

~ 0
Brooklyn, New York
Brooklyn New York 11238
Phone: (845) 90 1-6767
Exhibit K
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS: CRIMINAL TERM: PART 47
........................................ -X
CHRISTOPHER EARL STRUNK,
-against- :INDICTMENT NO.

: 29642/08
DAVID A. PATTERSON (NYS Governor), ANDREW:
CUOMO (NYS Attorney General),THOMAS P.
DiNAPOLI (NYS Comptroller), SHELDON SILVER
(NYS Speaker of the Assembly) , MALCOLM :
SMITH(NYS ~enatorj,HAKEEM JEFFRIES (NYS :
~ssemblymanfor the 57th AD), CHR.ISTINE :
QUINN (NYS Speaker of the Council),
WILLIAM THOMPSON (NYC Comptroller), JIM :
TEDISCO (NYS Assemblyman), DEAN SKELOS
(President pro tempore of the NYS Senate) :
in their Official Capacities and
individually, the Democrat Candidate
Presidential Electors as a class, in their
official Capacity and individual1y;The N.:
New York State Board of Elections and John Does and
Jane Does,
360 Adams Street
Brooklyn, New York
November 24, 2009
B +-E-
- F -
0-R -
E: THE HONORABLE DAVID SCHMIDT,
Justice of the Supreme Court
A
-P-P
- E- A- R- A-N-C-E-S-:
STATE OF NEW YORK
OFFICE OF THE ATTORNEY GENERAL
ANDREW M. CUOMO
120 BROADWAY -
.NEW YORK, New York 10271
BY: JOEL GRABER, ESQ.
Assistant Attorney General
ALSO PRESENT: CHRISTOPHER EARL STRUNK
TERI MALTESE
Senior Court Reporter
2
PROCEEDINGS
(Whereupon, the following takes place

on the record in open court in the presence of
the Court, the assistant attorney general and
Christopher Earl Strunk.)
THE COURT: I am going on the record now, I
need quiet. I understand you bring an order to show
cause. What is it for?
MR. STRUNK: For a TRO protective - - a
protective order of myself and material witnesses and
injunction for - - in relation to the executive order
that the governor issued on the 12th of November
regarding census and in the matter of the ongoing
racketeering conspiracy involving chapter 6 of the
election law in regards to valid access for nominated
or convention nominated or declared candidates for
* presidential office and that notwithstanding the fact
that the person who is now occupying the presidency
is in place. Nevertheless, is a continuing
conspiracy regarding he and Miss Pelosi who put him
-
on the ballot in the 50 states plus territories to
subterfuge and direct - - misdirect and as referenced
in Exhibit E and F that had been discovered by me in
my efforts in Washington, D.C. after I sought a
information act request and that it had become known
to me by five attorneys who had been doing work in

3
PROCEEDINGS
California, Hawaii, New Jersey, Washington, DC,
Georgia, Florida, Indiana, that there had been an
irregularity with the democratic party's certificate
of ballot access for the presidential slate. Having
discovered that, have done a freedom information law
request of the board of elections to deliver nine
certificates of all of those - - I think there are
nine of all of the parties that were on the ballot in
November and I - - and I allege that there's a
discrepancy that should have been picked up as a
.fiduciary responsibility of the board of elections in
comparing one document to the other and there's a
significant difference and that Nancy Pelosi as an
individual and in coryeboration with others, Ok

including Mr. Obama, are involved in a conspiracy to
not only legalize changing the immigration laws but
in carrying out the census will directly impact us
for the next 10 years as the 2 0 0 0 census impacted us
and ongoing now with the misuse and misadministration
of the state constitution as to apportionment,
gerrymandering and everything that goes along with I
that, including New York City excee.ding its debt
limitations, using those who were not citizens and,
those not permanent resident aliens exceeded their
debt limit. But t'hey're using as many as a million

r 7
4
f. PROCEEDINGS 1
I
L
1 and a half people as if they were permanent resident ~
2 aliens or citizens of any age and they would include
I
3 those who are tourists who overstayed their visa,
4 tourists per se, diplomatic diplomats and their
6
families. And for instance, those issued from
urn
various embassy metric cards or that State of New
S
n
7 York constitution does not permit a structure with
9
the use of anybody other than permanent
and citizens of any age very specifically laid out in

"6
6resident'a
/r I
10 the constitution. I believe that is the center in
11 terms of debt.
12 THE COURT: What do you want from me?
13 MR. STRUNK: Protective order of myself and my

L as
14 material witness including Reverand Manning, a Pastor
A
15 Manning who basically is-- we're not in the civil
16 - rights movement, we are up against some very serious
17 people. They're consolidating the FBI, Homeland
18 Security and they don't play games and that it's
19 Obama and Holder who I have in several courts, have
20 transferred the Khalid Mohammed thing - - conspiracy

&
21 to cause social disruption and planning. I had

@ w P r a -n m w s 3
22 discussion with his wife ongoing that he is in the
*-. 16: .:L+
-7 =
:
.
-
.
.
s QIRWE~
23 midst of this. He labeled the better - - I'm labeled
331QT= A+-- "
the better, I am being slandered and libeled and it
24
25 is creating a situation where I am about to attack a

L
tm
i
5
PROCEEDINGS
corporation who is going to be hired by the State of
New York to take the census in that Obama as the
attorney for a corporation circumvented the discovery
of their racketeering operation this summer.
THE COURT: I heard you. Let me hear from
him.
MR. GRABER: Joel Graber, Assistant Attorney
General. With respect to this application, the
complaint in this action which is.filed in October of
2008 doesn't say anything about the census.

K
Everything we heard so far from Mr. Strung pertains
to the census, but the complaint doesn't mention the
census at all. So this is not an appropriate
application to make on the October 2008 complaint.
Number two, I don't see any urgency in the
relief that he is seeking. There is not any showing
that would justify temporary restraining order
against anyone. And, of course, from what I've heard
and from what I've seen in this case, Mr. Strunk
-
seems mainly concerned to restrain the New York City
Police Department, possibly the United States
Department of Commerce, the Census Bureau. These
things have really nothing to do with the State of
New York which is my client in this case. ,
THE COURT: Mr. Strunk, you raised serious

6
PROCEEDINGS
I
1 allegations.
L-
2 THE WITNESS: Yes, I have.
3 THE COURT: So what I want to do is I will
4 think about it and I will make my decision as to
5 whether I sign it or not and you will come back
6 tomorrow to the clerk's office and they'll tell you
7 what happened, okay?
8 . THE WITNESS: So - - I don't mean to bring
9 personal matters in, but I have been scheduled for
10 six-seven weeks my son and I are taking a bus at 11.
11 Will that be ll?
12 THE COURT: So you - - it will be available by
13 11. It will be available by five today.

L
14 THE WITNESS: Okay, very good.
15 THE COURT: Probably by 4:30, okay?
16 THE WITNESS: Thank you.
17 MR. GRABER: Have a good day.
18
19
Certified to be a true and accurate

20
-
21 transcript of the stenographic.minutes taken
22 within.
23
24
MALTESE
V~~~~
25 Senior Court Reporter

'
1
United States District Courts I
Eastern District of New York In Case - ACORN et al. v. U.S.A. et al. EDNY 09-cv-4888
Washington District of Columbia In Case - Taitz v. Obama DCD 10-cv-0015 1
Washington District of Columbia In Case - Strunk v. DOS et al. DCD 08-cv-2234
I
On February 17,2010, I, Christopher Earl Strunk, declare and certify under penalty of perjury
pursuant to 28 USC 5 1746: That I caused the service of Nine (9) copies of the Christopher-Earl:
Strunk in esse PETITIONER'S CONSOLIDATED REPLY DECLARATION IN SUPPORT
OF THE NOTICE OF MOTION TO INTERVENE AS A EX-RELATOR INTERVENER- I
DEFENDANT U.S.A. CITIZEN AND STATE OF NEW YORK CITIZEN declared February I
16,2010, with exhibits annexed and that each set was placed in a sealed folder properly addressed
with proper postage for United States Postal Service Delivery by mail upon:
The Honorable Royce C. Lamberth Andrew Cuomo New York State Attorney
United States District Chief Judge for the General 120 Broadway 24'h Floor New York
U.S. District for the District of Columbia New York 10271
333 Constitution Avenue, NW,
Washington, DC 20001 Channing Philips, the U.S. Attorney
C/OWynne P. Kelly, AUSA
U.S. District for the District of Columbia 555 4th St., N.W.
Dr. Orly Taitz, D.D.S. C/O.BrighamJohn Bowen, AUSA
29839 Santa Margarita Parkway, STE 100 U.S. DEPARTMENT OF JUSTICE
Rancho Santa'Margarita CA 92688 20 Massachusetts Avenue, NW
Constitutional Rights 666 Broadway, 7th Barack Hussein Obama in esse
Floor New York, NY 10012 C/OThe White House
xos ~ O U ?D&&&Sebryiry
A'H'0'3
17,2010
~ 3 1 1wrin .c.~rko'klynNew York
h :1
593 ~ a i d e r b i lAvenue
t #28 1
Email: chris@strunk.ws Ph: 845-901-6767

Multi-District Quo Warranto Matter in Re Strunk Consolidated Reply Declaration in ACORN V USA EDNY 08-Cv-4888

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Multi-District Quo Warranto Matter in Re Strunk Consolidated Reply Declaration in ACORN V USA EDNY 08-Cv-4888

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Christopher-Earl: Stnu& in esse

593 V-It Avenue #281

The HmrabIe Royce C. Lamberth

I am the Petitioner, Chri--Earl: Stnmk in esse, with the pending motion to

ACORN (Association of Community Organizations for

UNITED STATES of AMERICA et al.. *A N

- #281 Brooklyn., New York 11238 0 0

PETITIONER'S CONSOLIDATED REPLY DECLARATION IN SUPPORT

1. Declarant is petitioner herein requesting Court permission to allow this

consolidated reply declaration in support of the notice of motion to intervene as an

the memorandum of law in opposition to motion for intervention filed February 9,

2010 by Defendants’ local counsel F. Franklin Amanat Assistant United States

February 9, 2010 filed a response join in and incorporate by reference

Defendants' Memorandum of Law in Opposition to Motion of Non-Party

constitutional authority to enact appropriations legislation which temporarily

suspends ACORN'S access to federal funding while a government-wide

investigation takes place." (See Exhibit H).

2. That this reply declaration adds additional Exhibits as a continuation of

Christopher-Earl: Strunk in esse Affidavit in support of the notice of motion to

intervene as a ex-relator intervener-defendant U.S.A. citizen and State of New

York citizen with Exhibits A through F.

3. Declarant’s preliminary statement of the controlling facts in reply that are

require a dismissal of the complaint, and or short of immediate dismissal, the

actions of Barack Hussein Obama occur(ed) to endorse the Continuing Resolution

Columbia in Taitz v Obama DCD 10-cv-00151, in which Declarant filed a motion

to intervene therein (See Exhibit J with Sub-exhibits 1 through 4) with the

request to transfer and consolidate Declarant’s Quo Warranto Verified Complaint

2234 presently before Distinct Judge Richard J. Leon; and

5. Further, where-in both 10-cv-00151 and 08-cv-2234, Declarant on

application is an ex-relator requesting a declaratory judgment on the facts

the POTUS Trustee / Administrator use of Declarant’s Power of Attorney as

void therefore there is no bill of attainder per se - there is no case;

8. Further because Congress has delegated the Executive administrative

authority to review payment of Plaintiffs’ several Contracts such administrative

se if at all; and further

administrative review accordingly until the process is exhausted.

District of Columbia by the controlling statute.

allegations by which Mr. Amanat wrongly alleges without specificity that

Petitioner’s affidavit quote ”..contains a good deal of ‘immaterial, impertinent, or

except insofar as Mr. Amanat's own statement to be stricken instead.

thereby impacting Taitz v Obama DCD 10-cv-00151 and in Strunk v US DOC

Society of Jesus et al. DCD 09-cv-1249, Strunk v US Department of Interior et al.

10-cv-0066, wherein the U.S. Attorney of District of Columbia represents each of

Justice David I. Schmidt.

case involving Declarant except those listed above.

agencies and other persons.

on which he may rely.” Strunk v. CIA, No. 08-CV-1196 (ARR/LB) (E.D.N.Y.

CV-1171 (ARR/LB) (E.D.N.Y. May 29, 2007) (dismissing Strunk’s complaint as

WL 3489051 (N.D.N.Y. Dec. 1, 2006) Declarant was represented by an attorney

allegations made by other Plaintiffs therein other than Declarant.

18. Declarant’s history as a litigant has nothing whatsoever to do with the

for which intervention was intended.

meritoriously selected, and such is a testimonial to Judge Gershon's capabilities

existing parties; that permissive intervention should be granted.

~%T6topher-~arl: Strunk in esse

NOTICE TO PRO SE LITIGANT PURSUANT TO LOCAL CIVIL RULE 7.1(C)

To: Christopher Earl Strunk, pro se

following unreported decisions which are cited in Defendants’ Memorandum of Law:

Strunk v. CIA, No. 08-CV-1196 (ARR/LB) (E.D.N.Y. Mar. 27, 2008)

Strunk v. United States House of Representatives, No. 99-CV-2168 (NG/MDG) (E.D.N.Y.

copies of the cases to be provided to you.

Dated: Brooklyn, New York BENTON J. CAMPBELL

By: /s/ {FILED ELECTRONICALLY}