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1 Pamela Barnett, Pro Se Plaintiff

2541 Warrego Way


2 Sacramento, CA, 95826
Telephone: (415)846-7170 IDORSED
3 Pb_realestate@yahoo.com
4 JUN - 7 2010
5 PAMELA BARNETT, IN PRO SE
A. WOOD:
6

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA


9
FOR THE COUNTY OF SACRAMENTO
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13 Pamela Barnett, Case No.: 34-2010-00077415

14 EXPARTE APPLICATION FOR


Plaintiff, EMERGENCY RECONSIDERATION OF
15 HEARING TO ADJUDICATE WHETHER
VS. VOTES SHOULD BE COUNTED FOR
16
DAMON QLINN JUNE 8. 2010
Damon Jerrell Dunn (aka Damon Dunn);
17
Requested Hearina: ^
Debra Bowen individually and officially as Date: June 8, 2010
The California Secretary of State; Edmund ] Time: 1:45 p.m.
18
G. Brown Jr. (aka Jerry Brown) Officially Dept: 54
as The California Attorney General and Judge: Hon. Shelleyanne W.L. Chang
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individually; and John Doe(s) and Jane
Action Filed: May 10,2010
20 Does, Trial Date. Not set
Defendants
21

22

23 J O THE COURT:
24 ^ PAMELA BARNETT, declare as follows:

25 ' 1. I am the pro se Plaintiff in this action.


2. Request hearing June 8, 2010 to determine whether votes should be counted for
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Darnon Dunn for Secretary of State June 8, 2010. The Court has been duly
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notified that Damon Dunn has done the following actions:
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EX PARTE REQUEST FOR RECONSIDERATION OF HEARING


1 a. Dunn left Block 16 blank on his voter registration form on March 13, 2009 where
2 according to election code he is to fill out his prior registration information even
though Florida has confirmed he was registered as a Democrat there;
3
b. Contacted Florida Election Officials to try to erase his voter registration record in
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July 10, 2009. This action confirms Damon Dunn's knowledge of his prior
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voter registration (CEC 18203,18500);
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c. Instead of correcting his voter registration form to comply with the NVRA and
7 HAVA State to State notification of change after speaking with the Florida election
8 officials in July, Dunn then goes on to signing his Candidate Intention Statement
9 November 13, 2009 with a perjured and effectively void Voter Registration Form
10 on file. Dunn at this point can no longer use the excuse that he didn't know that

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he was registered before;
d. Some time after Nov. 13, 20009, Dunn begins to accept donations and solicit
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nomination signatures based on a fraudulent Candidate Intention Statement CAL
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ELEC CODE 18203;
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e. Dunn is required to be a registered voter able to vote for the position of Secretary
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of State at the time he receives his nomination paperwork. CAL ELEC Code 201.
16 Dunn still has not corrected his California Voter Registration Form on file with
17 Orange County.
18 3. Dunn does NOT meet this qualification to be on the ballot for Secretary of

19 State under Statute for CAL ELEC CODE 201, and does not meet the requirement to be a
Registered Republican for either the 3 or 12 month requirements based on his perjured void
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voter registration on file under CEC 8001 (a)2. However he was also last registered as a
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Democrat and would need 12 months as a registered Republican under the law.
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4. This is a vitally important matter before the court, because if the court allows
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the count ofthe votes to occur for an ineligible candidate, Damon Dunn, that did the
24 preceding actions, will the court be complicit in breaking Cal. Elec. CODE 18500 and 18501
25 codes'? This would put a dark cloud on the honorable court and the integrity of the elections
26 in California, and would cause major disenfranchisement of a large group of voters which
27 would then open up the doors to many lawsuits against the State of California. You can't

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put a price on the breach of trust of the California electorate.

- 2 -
EX PARTE REQUEST FOR RECONSIDERATION OF HEARING
1 5 PlaintifTs Ex Parte request for a hearing June 2, 2010 was erroroneously denied

2 by Judge Shelleyanne W.L. Chang, and subsequently, so was Plaintiffs request for a
hearing June 4, 2010 to decide whether to remove Damon Dunn from the ballot and/or not
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have votes counted for him as a Secretary of State candidate.
4
6 Judge Chang stated in the Order "No explanation is given for why plaintiff waited
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several monttis after tfie candidate filed tiis requisite papers before seeking an OST for an
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Order to Sfiow Cause RE- Injunctive Relief"; to which Plaintiff contends is contrary to the
7 facts that:
8 a. Plaintiff only had a tentative confirmation that Damon Dunn's Declaration of
9 Candidacy and California Voter Registration Form were erroneous and
10 fraudulent, on or about April 13 when Plaintiff received a copy of the letter from

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Jean Mane Atkins, Director of Voter Administration, Office ofthe Supervisor of
Elections, Florida, confirming that Damon Dunn had a prior voter registration as a
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Democrat in Florida and tried to get the Florida elections department to erase his
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voter registration record;
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b. Plaintiff filed a formal complaint with the Secretary of State's Office May 3, 2010,
15 as the proper channel for voter, ballot, and election fraud. While waiting for an
16 answer from the Secretary of State's Election Fraud Division (that came by mail
17 after May 12, 2010 while I was out of town.). Plaintiff filed her complaint against
18 Damon Dunn, Debra Bowen, and Edmund G. Brown May 10, 2010;

19 c. Plaintiff, a pro se party did research how to get an expedited hearing on removing
Damon Dunn from the ballot. While Plaintiff attended an important matter in New
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York from May 12, 2010 through May 20, 2010. Plaintiffdid assign an agent,
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Shirley Freemen, assigned to file plaintiffs proposed Order to Show Cause (OSC)
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for an expedited hearing in conformance with any such request for injunctive
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relief, but the OSC was rejected by the Clerk ofthe Court 4 days before plaintiff
24 re-filed the Proposed Order to Show Cause for injunctive Relief May 21, 2010
25 requesting a expedited hearing to have Damon Dunn removed from the ballot and
26 not have any votes be counted for him.
27 d. Plaintiff was then denied two more times by Court officials despite Plaintiff

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compliance with each phone line request authonzed according to the Superior

- 3-
EX PARTE REQUEST FOR RECONSIDERATION OF HEARING
1 Court Website to set up an Ex Parte hearing, and in which Phone records are
2 available. After great effort and insistence that the Court follow its own rules,
Plaintiffwas successful on the third attempt on June 1, 2010 to obtain an ex parte
hearing; however despite the requirement of code for Election matters with time
as the essence Judge Chang did not give the urgent matter the attention merited
for an election fraud complaint even though all defendants had representation at
the Ex Parte hearing June 2, 2010
That Plaintiff appeared at the Courthouse on June 2, 2010 with all the attorneys /

8 counsels for the Defendants who all waited there for a hearing before the Judge to
9 no avail was never heard; With Plaintiff were Mr. Dunn's counsel Brian Hildreth

10 Esq. of counsel to BELL, ANDREWS, HILTACHK LLP 455 Capital Mall Suite 801,
Sacramento CA. 95814 Telephone (916) 442-7757 fax (916) 442-7759, and
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Secretary of State Bowen's and Attorney General Brown's counsel is Anthony
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O'Brien Assistant Attorney General (accompanied by three other Assistant A.G.s)
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California Department of Justice Office of the Attorney General " I " Street - Suite
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125 Sacramento, California 94244-2550, Telephone: (916) 323 6879 fax (916)
15 324-8835 anthony.obnen(5)doi.ca.qov
16 f. Plaintiff thought that the Clerk included the stamped Declaration of Ex Parte

17 Notice in the submission to the Judge before the hearing. After all the
shenanigans by the Clerks, to this day my Declaration of Notice of Ex Parte
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Hearing after all the unnecessary fanfare with all parties present on June 2, 2010
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even now has not been docketed (as of June 4, 2010) but is attached for review
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(see Exhibit 1). The fact that all defendants had representation at the hearing
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proves the Defendants were all properly noticed and Judge Change lost an
22 opportunity to render a decision on an important election fraud matter
23 g. Plaintiff contends that Judge Chang didn't review the documents presented to the
24 Court by Plaintiff and Defendants' counsels, had erred because if Judge Chang
25 had granted a hearing on the evidence in the vitally important election matter
26 regarding fraud there would be no other conclusion to reach except that
2.^ demanded by Plaintiff

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- 4
EX PARTE REQUEST FOR RECONSIDERATION OF HEARING
1 h. These statements affirm my due diligence in trying to get a hearing on removing

2 Damon Dunn from the ballot as he is not qualified and properly following court
rules of procedure regarding noticing of the parties.
3
7. This Application is based on the following information attached:
4
the Order to Show Cause for Injunctive Relief which I originally attempted to have
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filed under Article III but had been rejected by the Clerk of the Court on May 14, 2010 and
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then again with the Ex Parte Hearing June 2, 2008 (see Exhibit 2):
7 The June 2, 2010, erroneous Order regarding Ex Parte Hearing by Judge
8 Shelleyanne W.L. Chang (see Exhibit 3);
9 On June 2, 2010, the Clerk ofthe Court received Plaintiff's declaration with four

10 additional pieces of evidence (see Exhibit 4): (i) a letter from the Secretary of State dated
May 12, 2010 requesting additional evidence of Mr. Dunn's intentional malice; (ii.) The
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Newspaper Article published by Hermosa Beach Patch showing a picture of Damon Dunn
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being served with the Summons and Complaint in this case and wherein the Article refers to
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Mr. Dunn's Democratic Party background; (iii.) a Notarized certification ofthe Apirl 13, 2010
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letter from the Duval County Registrar; and (iv.) a copy ofthe March 10, 2010 certified
15 Declaration of Candidacy wherein on page 2 Mr. Dunn affirms that he has "no prior
16 registration" before the Orange County Registrar of Voters.
17 That the additional evidence of fraud shown as Exhibit 4 was filed June 2 about 2

18 p.m. before supposed tfie Ex Parte Hearing was not docketed by the Clerk even though a
document filed after plaintiffs on June 2 by a Defendant was docketed by the Clerk, raises a
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question of unequal treatment of Plaintiff by the Court.
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I declare under penalty of perjury under the laws of the State of California that the
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foregoing is true and correct as of June 4, 2010, at Sacramento, California.
22

23
Dated<jjj^i2.9^^'^
24

25 , Pro Se.

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- 5 -
EX PARTE REQUEST FOR RECONSIDERATION OF HEARING
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EXHIBIT 1

EX PARTE REQUEST FOR RECONSIDERATION OF HEARING


I Pamela Barnett, Pro Se PlaintifT ' , ~^ ~; : " - ~
2541 Warrego Way ' '
2 Sacramento, CA, 95826 ,rs i i r ; - ? PH i:S<3
3
Telephone: (415)846-7170 ' ^"^^ • "- '
Pb_realestate@yahoo.com .-r,AL FRCCi;i^ ?f'r
4

5 PAMELA BARNETT. IN PRO SE


6

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA


9
FOR THE COUNTY OF SACRAMENTO
10

11

12

13 Pamela Bamett, ) Case No.: 34-2010-00077415

14 j DECLARATION OF EX PARTE NOTICE


Plaintiff, <
15
vs. ) Date: June 2.2010
16 j Time: 10:00 am
Damon Jerrell Dunn (aka Damon Dunn); ^e^*^. ^4 ^ shelleyanne W.L. Chang
17 Debra Bowen individually and officially as <
18
The California Secretary of State; Edmund J Action Filed: May 10,2010
G. Brown Jr. (aka Jerry Brown) Officially j Trial Date: Not set
19 as The Caiifomia Attomey General and )
individually; and John Doe(s) and Jane \
20 Does,
21
Defendants i
22

23 TO THE COURT:
24 I, PAMELA BARNETT, submit that all Defendants were noticed of the Ex Parte
25 Hearing. See Attached. / / T ^

26
Pamela Barnett, Plaintitf, Pro Se"
27

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- 1 -
DECLARATION OF EX PARTE NOTICE
Print Page 1 of 1

From: MyFax (NoReply(gMyFax.com)


To: pb_realestate@yahoo.com;
Date: Tue, June 1, 2010 3:13:59 PM
Cc:
Subject: Fax Delivery Successful to 19164456749

e fax Successful fax sent frorrt MyFax.

Fax Delivery Number 19164456749


c- D -^o.. To Ex Parte Heanng Notice for Case 34-
Fax Kecipient. 2010-000774
Fax for Free.
Tell a friend about NIvFax
today. Sent a t 06/01/2010 06:13-56 PM (GMT-4 00)
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Thank you for using C fax

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Print Page 1 of 6

From: Hector M. Barajas (hbarajas(^bellorhq.coin)


To: pb_realestate@yahoo.com;
Date: Tue, June 1, 2010 9:27:55 PM
Cc:
Subject: Re: NOTICE OF EX PARTE HEARING FOR BARNETT V. DUNN ET AL

Like I said you are probably right, no need to get upset. I am sure you know the law.

So you did not answer my question. Will you be serving Orly for violating several state election laws?

Hector M. Barajas
Bellor Communications, Inc.
916.509.9478 office
916.290.0238 fax
www.bellorhq.com

From: "P. B." <pb_realestate@yahoo.com>


Oate: Tue. 1 Jun 2010 20:28:39 -0700 (PDT)
To: Hector Barajas <hbaraj'as(S>bellorhq.com>
Subject: Re: NOTICE OF EX PARTE HEARING FOR BARNETT V DUNN ETAL

You can try to play games if you would like.

The proceedure of serving someone Is to drop It at their feet if they refuse to


accept it Into their hands like Dunn did.

FYI.

P. B.

"If virtue and knowledge are diffused among the people, they will never be enslaved. This will be their
great Security." Samuel Adams

"For our struggle is n o t against flesh a n d blood, b u t against the rulers, against the authorities, against
the powers o f t h i s dark worid and against the spiritual forces o f evil in tfie heavenly realms. Therefore
p u t on the full armor o f God, so that when the day o f 61/77 comes, you may be able to stand your
ground, and after you have done everything, to stand."- Ephesians 6:12-13

ht^://us.mgl .mail.yahoo.coni/dcyiaunch?.gx=l&.rand=713pgf33ps3c9 6/2/2010


Print Page 2 of 6

From: Bellor Communications <hbarajas@bellorhq.com>


To: P. B. <pb_realestate@yahoo.com>
Sent: Tue, June 1, 2010 8:01:04 PM
Subject: Re: NOTICE OF EX PARTE HEARING FOR BARNETT V. DUNN ET AL

You might be right but the video I saw he never accepted anything and as far as the media is concemed
they don't believe he wa served.

Ate you fllling a suit againt Orly for violatmg state elections law?

Sent from my iPhone

On Jun 1,2010, at 7:56 PM, "P. B." <pb_realestate@yahoo.com> wrote:

The service is filed in court and we have the sen/Ice on video., and
confirmed by the media.

FYI.

Pamela Barnett

P.B.

"If virtue and knowledge are diffused among the people, they will never be enslaved. This
will be their great Security." Samuel Adams

"For our struggle is not against flesh and blood, but against the rulers, against the
authorities, against the powers of tJiis dark worid and against the spiritual forces of evil in
tile heavenly realms. Therefore put on the full armor of God, so that when the day of evil
comes, you may be able to stand your ground, and after you have done everything, to
stand."- Ephesians 6:12-13

From: Hector M. Barajas <hbarajas@beilorhq.com>


To: P. B. <pb_realestate@yahoo.com>
Sent: Tue, June 1, 2010 7:36:42 PM
S u b j e c t : Re: NOTICE OF EX PARTE HEARING FOR BARNETF V. DUNN ET AL

Not sure if you ever served him. But I will ask.

See you on Election Day.

http://us.mg 1 .maiLyahoo.com/dc/launch?.gx=l«fejand=713pgG3ps3c9 6/2/2010


Print Page 3 of 6

Hector M. Barajas
Bellor Communications, Inc.
916.509.9478 office
916.290.0238 fax
www.beHorhq.com <http://www.beilorhq.com/> <http://www.bellorhq com/>

From: "P. B." <pb_realestate@yahoo.com <mailto:pb realestate@yahoo.com> >


Date: Tue, 1 Jun 201019:00:32 -0700 (PDT)
To: Hector Barajas <hbarajas@bellorhq.com <m3ilto:hbaraias@bellorhq.com> >
Subject: Re: IMOTICE OF EX PARTE HEARING FOR BARNETT V. DUNN ETAL

Thank you for your response. As an official staff member of Damon


Dunn for Secretary of State campaign, you have been duly informed of
the Ex Paret hearing tomorrow. You have a professional responsibility
to inform Damon Dunn of the hearing tomorrow. If you don't, he will
not have a chance to defend himself In court.

Hopefully, Mr. Dunn has reviewed the complaint that he was personally
sen/ed with a couple weeks ago.

For your convenience here Is a link to the original complaint against Mr.
Dunn and Scrlbd.com <http://scrlbd.com/> <http://scribd.com/>
links to the other documents that I already sent to you today.

http://www.scrlbd.com/doc/31177742/Barnett-v-Dunn-Et-/VI-With-
Exhlblts-Redacted-Scribd
<http://www.scribd.com/doc/31177742/Bamett-v-Dunn-Et-AI-With-
Exhlblts-Redacted-Scribd
<http://www.scrlbd.com/doc/31177742/Bamett-v-Dunn-Et-/M-With-
Exhlbits-Redacted-Scnbd> >
http://www.scribd.com/doc/32218Q88/Barnett-v-Dunn-Bowen-Brown-
Official-Notice-of-Ex-Parte-Hearinq
<http://www.saibd.com/doc/32218088/Barnett-v-Dunn-Bowen-Brown-
Offlcial-Notlce-of-Ex-Parte-Hearinq
<http://www.scribd.com/doc/32218088/Barnett-v-Dunn-Bowen-Brown-
C)fFiclal-Notice-of-Ex-Parte-l-learinq> >
http://www.scrlbd.com/doc/32309545/Barnett-v-Dunn-Bowen-Brown-
Order-to-Show-Cause <http://www.scribd.com/doc/32309545/Barnett-
v-Dunn-Bowen-Brown-Order-to-Show-Cause
<http://www.scrlbd.com/doc/32309545/Barnett-v-Dunn-Bowen-Brown-

http://us.mgl.mail.yahoo.com/dc/launch?.gx=l&.rand=713pgf33ps3c9 6/2/2010
Print Page 4 of 6

Qrder-to-Show-Cause> >
http://www.scribd.com/doc/32341135/Dunn-Ex-Parte-App-and-Order

Sincerely, Pamela Barnett


415.846.7170

P.B.

"If virtue and knowledge are diffused among the people, they will never be enslaved. This
will be their great Security." Samuel Adams

"Fa- our struggle is not againd flesh and blocxJ, but against ttie rulers, against the
authorities, against the powers ofthis dark worid and againd the spiritual forces of evil in
the heavenly realms. Therefore put on the full armor of God, so that when the day r^evil
comes, you may tie able to stand your ground, and after you have done everything, to
stand."- Ephesians 6:12-13

From: Hector Barajas <hbarajas@beilorhq.com <mailto:hbaraias@)bellorhq.com>


>
To: P. B. <pb_realestate@yahoo.com <mailto:Db realestate@vahoo.com> >
Cc: orly.taitz@gmail.com <mailto:orlv.taitz(g)qmaiLcom>
Sent: Tue, June 1, 2010 5:43:17 PM
Subject: Re: NOTICE OF EX PARTE HEARING FOR BARNETT V. DUNN ET AL

We are not into the lawsuit business- another expense of taxpayer money at a time when our
state is already $19. L billion in debt

So consider this a public service armouncement: ifyou want to see someone who is in direct
vioiation of numerous FPPC and CA Election Law Violations you need to look no ftnther
than Orly Taitz.

Look at her website, emails, and robocalls - they are all in violation of simple Election Law
codes.

How can Orly be a credible candidate when she can't even follow simple election law
requirements?

I say this because Orly has a right to run for office and don't want to see any Republican
getting fined and using up more time and money from taxpayer resources.

http.7/us.mg I .mail.y ahoo.com/dc/launch?.gx= I &.rand=713pgB3ps3c9 6/2/2010


Print Page 5 of 6

Pamela: Damon has a constitutional right to run for oflEice. He is a United States citizen,
lawftilly and legally registered to vote in the State ofCaiifomia.

Have a good day - see you on Election Day.

On Tue, Jun 1, 2010 at 2:27 PM, P. B. <pb_realestate@yahoo.com


<mailto'pb realestate@yahoo.com> > wrote:

Please get this information to Damon Dunn. It Is very


important and concerns him being removed from the ballot.

Sincerely,

Pamela Barnett, 415.846.7170

P. B.

"If virtue and knowledge are diffused among the people, they will never be
enslaved. This will be their great Security." Samuel Adams

"For our struggle is not againstfleshand blood, but against the rulers, against
the authorities, against the powers ofthis dark worid and against the ^Iritual
forces of evil in the heavenly realms. Therefore put on the fiill armor of God,
so that when ffie day ofewl canes, you may be able to stand your ground,
and after you have date everything, to stand."- Ephesans 6:12-13

Forwarded Message —
From: P. B. <pb_realestate@yahoo.com
<mailto:Db realestate@vahoo.com> >
To: damon@damondunn.com <maiito:damon@damondunn.com>;
JSTtELE@S0S.CA.GOV <mailto:JSTEELE@50S.CA.GOV>
Cc: orly.taltz@gmail.com <mailto:orlv.taitz@qmail.com>
Sent: Tue, June 1, 2010 2:03:27 PM
Subject: NOTICE OF EX PARTE HEARING FOR BARNETT V. DUNN ET
AL

Damon Dunn;
Debra Bowen;

http://us.mgl.mail.yahoo.com/dc/launch?.gx=l&.rand=713pgf33ps3c9 6/2/2010
Print Page 6 of 6

Attached are all of the documents pertaining to the Ex Parte


Hearing tomorrow June 2, 2010, at California Superior Court,
Dept. 54 at 2:15pm. Please disregard other email regarding
the Ex Parte Hearing, as I forgot to attach one file.

Pamela Barnett
415.846.7170

Forwarded Message —
From: P. B. <pb_realestate@yahoo.com
<mailto:pb realestate@vahoo.com> >
To: damon@damondunn.com <mailto:damon@damondunn.com>;
JSTEELE@S0S.CA.GOV <mailto:JSrEELE@S0S.CA.GOV>
Cc: 0RLY.TArrz@GMAIL.COM <mailto:0RLY.TArTZ@GMAIL.COM>
Sent: Tue, June 1, 2010 1:59:20 PM
Subject: NOTICE OF EX PARTE HEARING FOR BARNETT V. DUNN ET
AL

P. B.

"If virtue and knowledge are diffused among the people, they will never be
enslaved. This will be their great Security." Samuel Adams

"For our struggle is not againstfleshand blood, but againd the rulers, against
the authorities, against the powers ofthis dark vmrid and against the spiritual
forces of evil in the heavenly realms. Therefore put on the full armor of God,
so that when the day of evil comes, you may be able to stand your ground,
and after you have done everything, to stand."- Ephesians 6:12-13

Hector M. Barajas
hbarajas@bellorhq.com <mailto:hbaraiasfa;bellorliq.com>

http://us.mgl .mail.yahoo.com/dc/launch?.gx=l&.rand=713pg03ps3c9 6/2/2010


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28 EXHIBIT 2

EX PARTE REQUEST FOR RECONSIDERATION OF HEARING


1 place for Republican Party electors that Damon Dunn is not duly qualified to be voted for on

2 the Ballot for Secretary of State.

3
Let the respondents or their attorney show cause at the Part , Room
4
, of this Court, to be held at the Courthouse, 720 9th Street Sacramento, CA
5
95814, on the day of . 2010, at o'clock in the
6
noon or as soon as counsel may be heard why an order should not be made affecting a Writ
7 of Prohibition, Writ of Mandate and or other relief; and Sufficient cause appearing therefore
8 (et personal service of this order, and the papers upon which this order is granted, upon the
9 State respondents Debra Bowen, Jenry Brown, and Damon Dunn or upon their counsel on
10 or before the day of May 2010 be deemed good and sufficient. An affidavit or other

11 proof of service shall be presented to this Court on the return date directed in tfie second
paragraph of this order.
12

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Dated.
14

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16 Judge of the Superior Court

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- 2 -
ORDER TO SHOW CAUSE OF INJUNCTIVE RELIEF
1 SUPERIOR COURT OF CALIFORNIA
2
3 COUNTY OF SACRAMENTO
4
5
6 Pamela Barnett Case No. 34-2010-00077415
7 Plaintiff,
8
9 Damon Jerrell Dunn (A K A. Damon Dunn), DECLARATION IN SUPPORT
10 Debra Bowen individually and officially as
11 The California Secretary of State; OF INJUNCTIVE RELIEF BY
12 Edmund G. Brown Jr (A.K.A. Jerry Brown)
13 Officially as The California Attorney General WRIT OF PROHIBITION
14 and individually, and John Doe(s)
15 and Jane Doe(s) AND
16 Defendants
17 WRIT OF MANDAMUS

18

19 I, Pamela Barnett, declare and say under penalty of perjury under the laws of the State

20 of California that

21 1. Declarant is the Plaintiff with the underlying Complaint No. 34-2010-00077415

22 with five causes of action with ten Exhibits A through J annexed thereto duly filed May

23 10, 2010 with the Clerk of the Court see Exhibit 1.

24 2. That Plaintiff has duly effected personal service of the Summons and Complaint

25 upon the Defendants

26 3. Declarant makes this declaration n in support of injunctive relief by Writ of

27 Prohibition and Wnt of Mandamus ofthe California Secretary of State Debra Bowen and

28 or her agents regarding the Republican Party Direct Pnmary ballot for Candidates for

29 Secretary of State in the election June 8, 2010.

30 4. Declarant requires expedited injunctive relief by a Court order of Defendants to

31 appear to show cause at a heanng within five days of the date of issuance why the

1
1 Court should not immediately order.

2 a. a Writ of Prohibition restraining the California Secretary of State Debra Bowen

3 and or her agents from recording the votes of electors for Damon Jerrell Dunn

4 (a k.a. Damon Dunn) at the statewide Republican Party Pnmary if held on

5 Junes, 2010 and

6 b a Writ of Mandate of the California Secretary of State Debra Bowen and or her

7 agents to duly notify the Registrars of all the County sub-divisions of the State

8 of California to prominently post notices at every polling place for Republican

9 Party electors that Damon Dunn is not duly qualified to be voted for on the

10 Ballot for Secretary of State

11 5. That time is of the essence with imminent irreparable harm in that on June 8,

12 2010 the California Republican Party Direct Primary is scheduled when in fact as

13 alleged in the First Cause of Action of the Complaint paragraphs 6 through 27 that

14 Defendant Damon Dunn maliciously concealed his previous place of voter registration

15 address on the California Voter Registration Form filed March 13, 2009 with the

16 California Secretary of State see Exhibit 1 sub exhibit A.

17 6. Defendant Dunn by not revealing his previous address of registration at line 16 of

18 the California Registration form shown as Exhibit 1 sub-exhibit A means that the

19 registration is "NEW" and that Defendant Dunn had never registered previously that

20 constitutes a violation of the NVRA and HAVA as is incorporated in the California

21 Election Code as well as every other State of the several States statutes that maintain a

22 voting registration record, and that Defendant Dunn made a false representation that he

23 I was a N E W Republican Party member within the 3 month rule of CEC §8001 (a)1 ONLY

24 misrepresenting that the 12 month rule of CEC §8001 (a)2 does not apply, when in fact it
1 does apply and proves that the Declaration of Candidacy shown as Exhibit 1 sub exhibit

2 B IS filed November 13, 2009 in bad faith because were the previous registration

3 address shown on the Voter Registration Form shown as Exhibit 1 sub exhibit A would

4 control the applicability ofthe 12 month rule of CEC §8001 (a)2 dunng ministerial review

5 by the Secretary of State who from then on irrevocably represents the filer.

6 7. That in fact Defendant Dunn had previously registered to vote in Florida as a

7 Democrat see Exhibit 1 sub exhibit C.

8 8. No where on the California Registration Form does it ask whether or not the

9 previous registration is active, inactive or expired, the Form merely asks for the address

10 of the previous registration as shown on Exhibit 1 sub exhibit A.

11 9. To withhold such information is a cnme and certainly in the events of error or

12 omission would require a good faith correction ofthe record, which was never done, nor

13 was an attempt ever initiated by Defendant Dunn.

14 10. Further, to show Defendant Dunn's bad faith on or about July 10, 2009 he

15 contacted the Registrar ofthe Flonda Board of Elections and attempted to have the

16 records expunged as alleged by the registrar in a letter dated Apnl 10, 2010 shown as

17 Exhibit 1 sub exhibit D, and will be affirmed in testimony at a preliminary heanng by the

18 matenal witness to that transaction Dr. Orly Taitz DDS Esq

19 11 .That it will also be affirmed at hearing that Defendant Dunn spoliated the record

20 of his registration in the State of Texas and similariy attempted to expunge his record of

21 an additional registration in the State of Arizona beside that of Flonda and Texas, that

22 I suggests four different addresses with multiple registrations all at once including the

23 California registration

24 12. That the Ballot for the California Republican Party Direct Pnmary on June 8, 2010
V-_

1 only has two candidate Damon Dunn and Oriy Ta'rtz with no other declared candidates

2 (see Exhibit 2) and therefore mandates that this court immediately issues a preliminary

3 injunction for each candidate to show cause why the SOS should not be ordered to

4 strike Damon Dunn from the Ballot and declare Orly Taitz the nominee ofthe

5 Republican Party at the November General Election ballot

6 13. That at the hearing proof of Democratic Party meddling Into the Republican Party

7 Primary process involves not only Democrat Debra Bowen but that she is aided and

8 abetted by George Soros and agents of the Secretary of State Project and Project Vote

9 in Califomia and nationally shown on the wet)site with financial contributions to Debra

10 Bowen fsee Exhibit 3) and Declarant demands an immediate restraining order of Debra

.11 Bowen, George Soros et al, and all those agents nationally from any further

12 interference with the Republican Party Primary process.

13 14. There has never been a previous application for any injunctive relief, TRO or an

14 OSC in this case.

15

16 I declare under penalty of perjury under the laws of the State of Califomia that the

17 foregoing is true and correct.

18 DATED: ^ / / / / O
19
20 Pamela se Plaintiff
21 J541 Warregorway
22 Sacramento, CA. 95826
23 Ph: (415) 846-7170
24 Fax: (866) 908-2252
Declaration in support of expedited injunctive relief

Superior Court of California County of Sacramento Case No: 34-2010-00077415

Pamela Bamett v. Damon Dunn. Debra Bowen. Jeny Brown. John and Jane Doe(s)

EXHIBIT 1
1 Pamela Barnett, Pro se Plaintiff
MLfc
2 2541 Warrego Way Superior Coyrt Of Qs n?omiSj
3 Sacramento, CA, 95826
4 Telephone: (415)846-7170
5 Fax: (866)908-2252
6
B>? Deputy
7 SUPERIOR COURT OF CALIFORNIA
8
9 COUNTY OF SACRAMENTO 34-2010=00071415
10
11 — X

12 Pamela Bamett Case No. Department

13 Plaintiff, Assignments
Case Management 35
14 COMPLAINT Law and Motion 54
Minors Compromise 14
15 Damon Jerrell Dunn (A.K.A. Damon Dunn);
16 Debra Bowen individually and officially as with Cal. Election Code §8001 (a) 2
17 The California Secretary of State;
18 Edmund G. Brown Jr. (A.K.A. Jerry Brown) Cal. Election Code § 8800
19 Officially as The California Attomey General
20 and individually; and John Doe(s) NVRA / HAVA related Law
21 and Jane Doe(s)
22 Defendants and Jury trial for damages
23
24
25 Plaintiff Pamela Barnett alleges:
26
27 I - INTRODUCTION
28 Parties
29 1 Defendant Damon Jerrell Dunn (a.k.a Damon Dunn, Defendant Dunn), is a

30 natural person resident in California (CA) at 3131 Michelson Unit 708W Irvine CA 92612

31 with mailing address located at 2070 Business Center Drive Suite 140 Irvine CA 92612

32 with Email damondunn(S)vahoo.com ; and is questionably on the California Republican

33 Party primary ballot as a declared candidate for the State of California Republican Party

34 Candidate for Secretary of State of California on June 8, 2010.

/^/\mi-»loint D a n o 1 n f 1 Q
1 2. Defendant Debra Bowen (Defendant Bowen, SOS), is a natural person sued in

2 her official capacity as the Secretary of State of the State of California (SOS), with place

3 of business located at 1500 1V" Street, 5^'' Floor Sacramento, CA, 95814 Fax (916) 653-

4 3214 with CAL. ELEC. CODE § 10. California Code - Section 10 is the chief of elections

5 officer of the state, and has the powers and duties specified in Section 12172 5 of the

6 Government Code; and is sued individually herein for breach of Fiduciary Duty.

3. Defendant Edmund G. Brown Jr. (A.K.A. Jerry Brown, Defendant Brown, AG) is a

natural person sued in his official capacity as The California Attorney General (AG),

9 I with place of business located at California Department of Justice Office of the Attorney

10 General 1300 "I" Street - Suite 125 Sacramento, California 94244-2550 is the chief law

11 enforcement officer of the state with powers and duties specified with Government code

12 to prosecute election cnme, and is sued individually herein for breach of Fiduciary Duty

13 4. Plaintiff Pamela Barnett, is a natural person with place for service located at 2541

14 Warrego Way, Sacramento, CA, 95826 Telephone: (415) 846-7170 Fax: (866) 908-

15 2252, and who is duly registered to vote in California and enrolled / affiliated member of

16 the California Republican Party eligible to vote at the California Republican Party

17 Pnmary scheduled for June 8, 2010 and at the General Election in 2010

18 II-JURISDICTION
19 5 Venue is proper in the County of Sacramento and this is the proper court for this
20 complaint as the events complained of occurred within this county because it involves
21 the Secretary of State of California (SOS) and a candidate for Secretary of State as is

Complaint Page 2 of 18
1 Defendant in the California statewide Republican Party Direct Pnmary *^', and then the

2 General Election ballots with CA Election Code (CEC) § 12, and at a Jury tnal General

3 Damages be assessed were the Primary to proceed illegally, would result in Defendants

4 liability to reimburse the cost ofthe Republican pnmary and costs incurred of any

5 opposing candidate and or Plaintiff herein along with those similarly situated; and that

6 jurisdiction shall be given preference in the CA Courts with CAL. CCP. CODE § 44^^^

7 that according to CAL. ELEC. CODE § 8800- California Code - Section 8800. No

8 candidate whose declaration of candidacy has been filed for any primary election may

9 withdraw as a candidate at that pnmary election. Must be removed by Judicial Order.

10 Ill - BACKGROUND FACTS

11 FIRST CAUSE OF ACTION


12 Defendant Dunn Maliciously Violated CEC § 8001 (a) 2 / NVRA / HAVA

13 6. Plaintiff realleges each and every allegation contained in the above paragraphs 1

14 through 5 with the same force and effect as though herein set forth at length omits it for

15 brevity.

16 7. Plaintiff alleges that Defendant Dunn's actions constituted a violation of California

17 Civil Code § 8001(a) 2 national Voter Registration Act of 1993 (NVRA) and Help

18 Amenca to Vote Act of 2002 (HAVA) in that defendant had at all times mentioned herein

19 with explicit knowledge of the law acts with malice

^ CAL ELEC. CODE § 316- California Code - Section 316 "Direct pnmary" is the pnmary
election held on the first Tuesday after the first Monday in June in each even-numbered year, to
nominate candidates to be voted for at the ensuing general election or to elect members of a
party central committee.
^. CA. CCP Code § 44, California Code - Section 44. Appeals in probate proceedings, in
contested election cases, and in actions for libel or slander by a person wno holds any elective
public office or a candidate for any such office alleged to have occurred durina the course of an
election campaign shall be given preference in hearing in the courts of appeal, and in the
Supreme Court when transferred thereto All these cases shall be placed on the calendar in the
order of their date of issue, next after cases in which the people of the state are parties.

Complaint Page 3 of 18
1 8. The California Election Code (CEC) requires that to be eligible to be a qualified

2 candidate for Secretary of State a declared and a nominated candidate shall under §201

3 of the California Elections Code "be a registered voter and othenA/ise qualified to vote for

4 that office at the time nomination papers are issued to the person"; and

5 9. On March 13, 2009, Defendant Dunn filed a registration to vote in California and

6 to affiliate with the California Republican Party (see ExhibitA).

7 10 Defendant Dunn filed his voter card registration in CA on March 13 2009, less

8 then 8 months pnor to his declaration of candidacy on November 5, 2009;

9 11. Further, CEC and related law requires with CEC § 8001. California Code -

10 Section 8001. (a) No declaration of candidacy for a partisan office... shall be filed, by a

11 candidate unless (1) at the time of presentation ofthe declaration and continuously for

12 not less than three months immediately prior to that time, or for as long as he has been

13 eligible to register to vote in the state, the candidate is shown by his affidavit of

14 registration to be affiliated with the political party the nomination of which he seeks, and

15 (2) the candidate has not been registered as affiliated with a qualified political pariy

16 other than that political pariy the nomination of which he seeks within 12 months, or, in

17 the case of an election governed by Chapter 1 (commencing with Section 10700) of Part

18 6 of Division 10, within three months immediately pnor to the filing of the declaration.

19 (b)The elections official shall attach a certificate to the declaration of candidacy showing

20 the date on which the candidate registered as intending to affiliate with the political party

21 the nomination of which he seeks, and indicating that the candidate has not been

22 affiliated with any other qualified political party for the penod specified in subdivision (a)

23 immediately preceding the filing of the declaration. This section shall not apply to

Complaint Page 4 of 18
1 declarations of candidacy filed by a candidate of a political party participating in its first

2 direct pnmary election subsequent to its qualification as a political party pursuant to

3 Section 5100 (Emphasis added by Plaintiff)

4 12. Defendant Dunn had not been registered and enrolled / affiliated with the

5 Republican Party of California, any State, and or National Republican Party affiliation for

6 12 months as of November 13, 2010.

7 13 On or about November 5, 2009, Defendant Dunn, who had been registered and

8 enrolled / affiliated with the Florida Democratic Party within 12 months, filed the

9 declaration for his candidacy (See Exhibit B) for the California Republican Party

10 nomination Direct Pnmary with Defendant Bowen.

11 14. That according to CAL. ELEC CODE § 305. California Code - Section 305.

12 (a)"Candidate," for purposes of Section 2184, includes any person who declares in

13 writing, under penalty of perjury that he or she is a candidate, naming the office.

14 (b)"Candidate," as used in Article 1 (commencing with Section 20200) of Chapter 3 of

15 Division 20, means an individual Iisted on the ballot, or who has qualified to have write-

16 in votes on his or her behalf counted by election officials, for nomination or for election

17 to any elective state or local office, or who receives a contnbution or makes an

18 expenditure or gives his or her consent for any other person to receive a contnbution or

19 makes an expenditure with a view to bringing about his or her nomination or election to

20 any elective state or local office, whether or not the specific elective office for which he

21 or she will seek nomination or election is known at the time the contnbution is received

22 or the expenditure is made. The term "candidate" includes any officeholder who is

23 subject to a recall election. CEC Section 305 (c)"Candidate for public office," as used in

Complaint Page 5 of 18
Chapter 5 (commencing with Section 20400) of Division 20, means an individual who

2 has qualified to have his or her name listed on the ballot of any election, or who has

3 qualified to have written votes on his or her behalf counted by election officials, for

4 nomination for, or election to, any state, regional, county, municipal, or distnct office

5 which IS filled at an election.

6 15. Defendant Dunn filed as early as possible to maximize press coverage to take

7 advantage over not being affiliated as a Republican Party Member with more Campaign

8 exposure.

9 16. Defendant Dunn sought out advice from John and Jane Doe(s) to violate CEC §

10 8001 (a) 2 in order to maximize advantage over any other affiliated California

11 Republican Party candidate if any were to file a declaration by say March 2010 or the

12 minimum available time before the primary election on June 8, 2010.

13 17. Defendant Dunn knew that by filing early he was violating CEC § 8001 (a) 2 and

14 was only an affiliated republican for about 8 months and decided not to wait until say

15 March to file the Declaration, instead sought to conceal and expunge his Florida

16 Democratic Party affiliation record.

17 18. That based upon information and belief and according to a letter written April 13,

18 2010 by Jean Mane Atkins Director of Voter Administration the Duval County Board of

19 Election and obtained in person by Dr. Orly Taitz while in Flonda (see Exhibit C). on July

20 10, 2009, Defendant Dunn contacted the Florida Board of Elections to have any record

21 of enrollment or affiliation with the Flonda Democratic Party in the Duval County

22 database expunged from the official record.

23 19 The Florida Board of Election database in Duval County records that Defendant

24 Dunn registered in Flonda (see Exhibit D) is affiliated with the Democratic Party.

Complaint Page 6 of 18
1 20 That based upon information and belief the Flonda Board of Elections Official

2 with the fiduciary duty to safeguard the records of the Board of Elections including those

3 of Defendant Dunn refused to expunge the records when he asked July 10. 2009, and

4 prove that Defendant Dunn was a Florida Democrat within the 12 month penod pnor to

5 Defendant Dunn declaring his candidacy in California on November 5, 2009.

6 21 For the purpose of adhering to the CEC §8001 (a)2 requirement Defendant Dunn

7 in effect was affiliated with the Democratic Party in Florida prior to November 5 2009,

8 when he filed his declaration of candidacy and intends to file nomination papers with

9 CEC §8040, acted in bad faith to falsify the California Election Record and circumvent

10 requirements of NVRA and HAVA requinng State to State notification of change.

11 22. Defendant Dunn violated NVRA and HAVA with the filings shown as Exhibit A

12 and Exhibit B thereby injunng Plaintiff along with those similariy situated.

13 23. Moreover, Defendant Dunn committed voter fraud according to statutes CEC

14 §18203 and §18500 by intentionally not entering in his voter registration card

15 information about the fact that he registered somewhere before and that he registered

16 as a Democrat, maliciously failed to provide at Section 16 ofthe form shown as Exhibit

17 A that he was previously registered in Flonda, and thereby concealed evidence of a

18 crime Defendant Dunn intended to commit to become California SOS.

19 24. Plaintiff is a supporter and contnbutor to the candidacy of Dr. Orly Taitz, DDS

20 J.D. Esq., who is a duly declared candidate on the ballot at the California Republican

21 Party Primary scheduled for June 8, 2010 for the nomination by the California

22 Republican Party as the Republican Candidate for the California Secretary of State at

23 the November 2010 General Election, and that Dr Taitz's only opponent is Defendant

Complaint Page 7 of 18
1 Dunn at the Republican Nomination at the Primary other than write-in candidates, and

2 were Defendant Dunn removed from the Primary Ballot as demanded herein, Dr. Taitz

3 would be the Republican candidate for California SOS on the General Election Ballot of

November 2010.

5 25. Defendant Dunn poaching as a Democrat has infringed Plaintiff's First

6 amendment rights to protected speech and association along with those similariy

7 situated as an enrolled affiliated member of the California Republican Party with CEC

8 8001(a) 2.

9 26. Defendant Dunn and the State of California Secretary of State Defendant Bowen

10 whose state action has infringed Republican Party Affiliation nghts and success at the

11 elections have infringed Plaintiff's right to a reasonable expectation of participation and

12 success with like-minded Party members atthe Elections.

13 27. Because ofthe violation of Law by Defendant Dunn, Plaintiff is damaged

14 financially and will suffer irreparable harm were Defendant Dunn allowed by Defendant

15 Bowen and or the SOS agents to remain on the pnmary ballot and that time is of the

16 essence in order to prevent irreparable harm in the pnmary on June 8, 2010.

17 SECOND CAUSE OF ACTION

18 Defendant Bowen and Defendant Dunn Maliciously Violated CEC § 8001(a) 2


19 NVRA / HAVA and related law

20 28. Plaintiff realleges each and every allegation contained in the above paragraphs 1

21 through 27 with the same force and effect as though herein set forth at length omits it for

22 brevity.

23 29. Plaintiff alleges that Defendants' actions constitute a violation of California Civil

Complaint Page 8 of 18
1 Code § 8001 (a)2 NVRA HAVA and related law in that Defendant Bowen and Defendant

2 Dunn (Defendants) act together after November 5, 2009 at all times mentioned herein

3 with explicit knowledge of the law act with malice in regards to the Declaration of

4 Candidacy of Oriy Taitz.

5 30. That Based upon information and belief.

6 a. Dr. Taitz called the office of the Secretary of State at the Elections

7 Division, whose Chief is Cathy Mitchells, and talked to an investigator by

8 the name of Dariene, who did not disclose her last name,

9 b. That Dr Taitz asked Dariene, why Damon Dunn was not removed from the

10 ballot in light of the fact that Dunn was not eligible under CEC § 8001 (a) 2

11 and therefore, did not qualify to be on the Republican Party Pnmary Ballot

12 on June 8, 2010; and

13 c. Further, Dr Taitz asked Dariene what penalties will be assessed in

14 regards to Mr. Dunn's voter fraud, in relation to the fact that he did not

15 disclose his pnor voter registration as a Democrat on the March 13 2009

16 registration form shown as Exhibit A.

17 d Dariene stated to Dr Taitz that she will relate this to her supenor and one

18 of two attorneys working in the department, and said, "Someone will call

19 back". To date Dr Taitz has not received a response as promised and

20 which has precipitated this complaint as time is of the essence with

21 irreparable harm were Mr. Dunn to remain on the ballot;

22 e To date no follow-up by the Chief of Elections has happened.

23 31 .That as a pattern, Dr. Taitz told Plaintiff that when Dr. Taitz reported Barack

24 Hussein Obama ineligible a year and a half ago Defendant Bowen and or agents were

Complaint Page 9 of 18
1 supposed to call Dr. Taitz back and schedule an administrative heanng was never done.

2 32 That on November 17, 2009, progressive community organizer Damon Dunn

3 candidate for the Republican nomination for California Secretary of State was

4 interviewed by Bryan Suits at 7.30 PM on KFI AM 640

5 (http.Z/itunes apple.com/us/podcast/kfi-am-640-brvan-suits/id272690196), during the

6 interview stated he. "Cast first vote May 2009" is a "rags to riches democrat story.."

7 "Family vote as democrat.." "November 2008 Prop 8 ...The Sentinel Newspaper an

8 African Amenca newspaper... community service in my entire life .Make a Wish

9 Foundation ..the Latino Education Attainment Initiative.." and as for his own family in

10 Texas when asked "why are they still living in the trailer? " said "teach them to fish." at

11 Stanford his Mentor "is Condoleezza Rice at Stanford University" and when asked as to

12 his ability to win he said "Barack Obama got record numbers of people to vote for

13 him. ..people follow people not parties.."

14 33. That on January 11, 2010 Defendant Dunn was interviewed (see Exhibit E) by

15 Mark DeVaughn a contributing writer at the Bootleg on Scout com with FoxSports.com

16 outlet who reported that Mr. Dunn as saying

17 "Football IS the common denominator," he said. "It helps in the connection


18 process you have with other people." A recent Los Angeles Times a:\.\c\e about
19 him noted a play that came at the expense of those whose vote he's courting.
20 Conventional wisdom says that USC alumni and fans - heads expanded with
21 success over the past decade - have forgiven Dunn for his 93-yard kickoff return
22 for a touchdown dunng Stanford's 24-20 victory in 1996.
23
24 On non-football topics, Dunn speaks in excited and vibrant tones. Diverse
25 political heroes include l\/lariin Luther King, Barack Obama and Governor Pete
26 Wilson. He remains a political novice, having never run for office previously. He
27 first registered to vote as a Democrat a decade ago but never actually went to the
28 polls until May of 2009. Like a lost soul finding religion, Dunn found the proper
29 path to affecting meaningful change, encouraged by a lasting relationship with
30 former U.S Secretary of State Condi Rice, whom he met while a student at
31 Stanford, when Rice served as the University's Provost. Now Dunn feels he

Complaint Page 10 of 18
1 "gets" It. No more standing on the sidelines and failing to get involved in the
2 process. As he told the Los Angeles Times, "Who better to reach a non-voter
3 than a recovenng non-voter?" (Emphasis added by Plaintiff)
4
5 34. On or about March 16. 2010, the authorized Campaign for Defendant Debra

Bowen sent a campaign contnbution solicitation throughout the State attacking Dr. Taitz

7 as a fringe member of the California Republican Party (see Exhibit F) and therein defers

8 to the "wealthy developer" Defendant Dunn as if a mainstream "nght-wing" Republican

9 Party candidate on the primary ballot and after Defendant Bowen was notified Mr. Dunn

10 like Barack Hussein Obama is also ineligible to run for office in the solicitation states.

11 As you know, wealthy developer Damon Dunn, who says he got into the race at
12 Kari Rove's urging, is also running forthe Republican nomination. Whoever
13 prevails in the pnmary MUST be taken seriously because of their ability to raise
14 money and distort the issues through their national nght-wing networks.
15
16 Please contribute today to help Debra stand against rightwing ideologues like
17 Orly Taitz, and continue serving the people of California!
18
19 Orly Taitz' candidacy would be amusing if it weren't so serious. Her primary
20 reason for running is to challenge President Obama's citizenship and invalidate
21 the 2008 election. In fact, Taitz has sued Debra twice to try to invalidate Obama's
22 victory.
23
24 We can't let fringe conspiracy theorists use this office to get a foot in the door and
25 undemnine our democracy.
26
27 Debra's opponents are well connected, and have the ability to raise large sums of
28 money from across the country. We must make sure she has the resources to
29 beat them.
30
31 Please contribute today to help Debra stand against right-wing ideologues like
32 Orly Taitz, and continue serving the people of Califomia!
33
34 We can't underestimate the importance of this race. The Secretary of State is the
'•=
35 one person in state government who is responsible for the integnty of our
36 elections. As we saw in Flonda in 2000 and in Ohio four years later, we need
37 public servants we trust in this position, not people with a political agenda.
38
39 Debra has long sen/ed the people of California with integrity. We need her in the
40 Secretary of State's office, not a conspiracy theorist like Oriy Taitz
41

Complaint Page 11 of 18
35. However, contrary to the authonzed Bowen Campaign Statement shown as

Exhibit F as to Defendant Dunn that was released on or about March 16, 2010 and that

3 coincided with the release of the Fnday March 5, 2010 Democrat love-fest interview of

4 Defendant Dunn and Defendant Bowen on the California Focus Syndicated Column, a

5 twice-weekly syndicated newspaper column on California public affairs, by Thomas D.

6 Elias in his article "A Down-The-Ticket Race With Two Likelv Winner^' (see Exhibit G)

7 reported Defendant Damon Dunn saying of Defendant Debra Bowen that.

8 "She gets credit for restonng some integrity to the process," Dunn said in an
9 interview, refernng to Bowen's review of electronic voting machines and the
10 resulting return to large-scale use of paper ballots. In fact, she gets so much
11 credit that as of eariy March, Dunn was the only declared Republican candidate
12 running against her. There was still a possibility that another might jump in- Orly
13 Taitz, another Orange County figure who is a leader of the "birther" movement
14 that questions whether President Obama is eligible for his job.
15
16 But Dunn, the only Republican now campaigning, enthusiastically and
17 unequivocally says he will win this fall and become California's first African-
18 American statewide officeholder since Mervyn Dymally was lieutenant governor
19 in the late 1970s
20
21 And further in the article, Mr. Elias continues to report the rebuttal of Defendant Bowen

22 from his interview with her saying that

23 "One thing Bowen doesn't buy is the notion that Dunn's candidacy is the product
24 of a plot devised by Republican strategist Kari Rove, long the chief political
25 adviser to former President George W. Bush, for the GOP to take control of the
26 national election process at the state level.
27
28 Bowen scoffs at the idea of a Rovian plot. "I'm not much for conspiracy theories,"
29 she said. "Besides, I don't think Kari Rove would exactly be an asset in
30 California."
31
32 36. On December 9, 2008, Plaintiff had complained to Defendant Bowen of the

33 ineligibility of Barack Hussein Obama to be on the ballot in California see Exhibit H.

34 37. Defendant Bowen has no opponents in the Democratic Primary June 8, 2010.

35 38 Defendant Bowen chose to take sides and interfere into the internal campaign of

Complaint Page 12 of 18
1 the two candidates for the Republican Party nomination Defendant Dunn and Orly Taitz.

2 39. Arguendo, Defendant Bowen is at best a Progressive Social Democrat on the

3 European model of social democracy, that was devised in the twentieth century by the

4 Catholic scholar Jacques Mantain whose work for the Roman Catholic Church formed

5 the socialist labor unions within a mixed feudal class system, in which governance is

6 done without the consent of the collective social classes that are divided into an

7 imaginary left and right wing, as a form of consumer/producer dialectical matenalism.

and whose European social fascist form of government controls a public dominated

economic collective that diminishes private enterprise and is juxtaposed to the Amencan

10 model of a representative republic of limited government control over the private

11 economy that with the U.S. Constitution and founding documents officials only serve by

12 the consent of the sovereign individual(s) within That there are no collective rights or

13 class structure perse in the United States of America, despite the Euro-socialist

14 tendency to create such; and in the USA the true dynamic between individuals is based

15 upon either greater government interference versus less government interference in

16 private economy that guarantees equal provision of justice for an individual without any

17 collective per se - e.g. individual nghts versus a collective left behind in feudal Europe.

18 40. On April 2, 2010, Plaintiff complained to Defendant Brown of Defendant Bowen

19 who had responded on March 23, 2010 to the complaint shown as Exhibit H in the

20 matter of the ineligibility of Barack Hussein Obama specifically a to the forensic proof of

21 the fraud proven done by Mr Obama and or his agents for the declaration with CEC

22 §8001 (a) 2 for ballot access to the November 2008 General Election (see Exhibit I).

23 41. Defendant Bowen acts under color of CEC §8800 without fulfilling the ministerial

24 I duty to investigate the fraud or filing a Judicial action to remove Defendant Dunn.

Complaint Page 13 of 18
1 42. Defendant Brown has not responded to the filing shown as Exhibit I.

2 43. That Defendant Brown is hereby also served with the charge against Defendant

3 Dunn and Defendant Bowen in the matter of the November 13, 2009 filing of the

4 Declaration shown as Exhibit B and Exhibit A as a violation of the NVRA and HAVA.

5 44. That Plaintiff on May 3, 2010 faxed a complaint letter with attachments to the

6 California Board of Election Chief and followed up with a tnp to the Office to wit nothing

7 has been received to date and thereby requires expedited handling by the Court herein;

8 see a copy of Plaintiff's cover letter with fax confirmation herewith marked see Exhibit J.

45. That according to the CAL. ELEC CODE § 12 California Code - Section 12

10 Whenever any candidate files a declaration of candidacy, nomination paper, or


11 any other paper evidencing an intention to be a candidate for any public office at any
12 election in this state with either the Secretary of State or a county elections official,
13 the candidate shall bv the filing irrevocably appoint the Secretary of State or the
14 county elections officiai with whom the filing is made, and their successors in office,
15 the candidate's attorneys upon whom all process in any action or proceeding against
16 him or her concerning his or her candidacy or the election laws may be served with
17 the same effect as if the candidate had been lawfully served with process. The
18 appointment shall continue until the day ofthe election.
19
20 If in any action or proceeding arising out of onn connection with any matters
21 concernina his or her candidacy or the election laws it is shown by affldavit to the
22 satisfaction ofa couri or judge that personal service of process against the candidate
23 cannot be made with the exercise of due diligence, the couri or judge mav make an
24 order that the service be made upon the candidate bv delivering by hand to the
25 Secretary of State or the county elections official appointed as the candidate's
26 attorney for service of process, or to any person employed in his or her office in the
27 capacity of assistant or deputy, one copy of the process for the defendant to be
28 served, together with a copy of the order authorizing the service. Service in this
29 manner constitutes personal service upon the candidate. The Secretary of State and
30 the county elections officials of all counties shall keep a record of all process served
31 upon them under this section, and shall record therein the time of service and their
32 action with reference thereto.
33
34 Upon the receipt of service of process the Secretary of State or the county
35 elections official shall immediately give notice ofthe service ofthe process to the
36 candidate by forwarding the copy ofthe process to the candidate at the address
37 shown on his or her declaration, nomination paper, affidavit or other evidence of
38 intention to be a candidate filed with that officer, by special delivery registered mail

Complaint Page 14 of 18
1 With reguest for return receipt (Emphasis added by Plaintiff)
2
3 46.That according to CAL. ELEC. CODE § 17. California Code - Section 17.

4 The Secretary of State shall establish and maintain administrative complaint


5 procedures, pursuant to the requirements of the Help Amenca Vote Act of 2002 (42
6 U.S.C. Sec. 15512), in order to remedy grievances in the administration of elections
7 The Secretary of State may not require that the administrative remedies provided in
8 the complaint procedures established pursuant to this section be exhausted in order
9 to pursue any other remedies provided by state or federal law.
10
11 47.That according to CAL. ELEC. CODE § 18203: California Code - Section 18203.

12 Any person who files or submits for filing a nomination paper or declaration of candidacy

13 knowing that it or any part of it has been made falsely is punishable by a fine not

14 exceeding one thousand dollars ($1,000) or by imprisonment in the state pnson for 16

15 months or two or three years or by both the fine and imprisonment

16 48. That both Defendants along with those yet named maliciously filed the

17 Declaration of candidacy shown as Exhibit B.

18 49. That accordingly to CAL. ELEC CODE § 18500: California Code - Section

19 18500. Any person who commits fraud or attempts to commit fraud, and any person who

20 aids or abets fraud or attempts to aid or abet fraud, in connection with any vote cast, to

21 be cast, or attempted to be cast, is guilty of a felony, punishable by imprisonment for 16

22 months or two or three years.

23 50. That Defendants maliciously concealed and entered false statements into the

24 public record with intention of fraudulently obtaining votes.

25 51.That accordingly to CAL ELEC. CODE § 18501. California Code - Section

26 18501. Any public official who knowingly violates any of the provisions of this chapter,

27 and thereby aids in any way the illegal casting or attempting to cast a vote, or who

28 connives to nullify any of the provisions of this chapter in order that fraud may be

Complaint Page 15 of 18
1 perpetrated, shall forever be disqualified from holding office in this state and upon

2 conviction shall be sentenced to a state pnson for 16 months or two or three years

3 52. That Defendant Bowen along with those public officials yet named have

4 maliciously breached the fiduciary duty to aid and abet the violation of law to further

5 conceal and enter false statements into the public record with intention of fraudulently

6 obtaining votes otherwise act individually by ultra vires,.

7 53. That based upon the foregoing series of complaints and lack of response by

8 Defendant Bowen she has not only a conflict of interest in this matter but fails to adhere

9 to her fiduciary duty.

10 54. Irreparable harm to Plaintiff along with those similarly situated includes, (i) the

11 denial of Republican Party voters an accurate ballot and representation according to the

12 law; (ll) the denial of an honest trustworthy SOS on the ballot for the General Voters at

13 the Election were Mr. Dunn somehow to defeat SOS Candidate Orly Taitz at the

14 Republican Pnmary; and (in) cause the need for launching a petition effort for

15 independent candidate ballot access were Dr. Taitz, who is the only qualified declared

16 candidate for the Republican candidacy for the SOS.

17 THIRD CAUSE OF ACTION


18 Defendant Bowen Breach of Fiduciary Duty

19 55. Plaintiff realleges each and every allegation contained in the above paragraphs 1

20 through 54 with the same force and effect as though herein set forth at length omits it for

21 brevity

22 56. Plaintiff alleges that Defendant Bowen's actions constitute a violation of California

23 Civil Code § 18501 in that Defendant Bowen acted with a conflict of interest after

24 November 13, 2009 at all times mentioned herein under color of law with explicit

Complaint Page 16 of 18
1 knowledge of the law with malice when after it was shown that the Defendant Dunn's

2 Voter registration form shown as Exhibit A was incomplete as to his prior registration

address in Florida which effected the Declaration of Candidacy filed on or about

4 November 13, 2009 shown as Exhibit B

5 FOURTH CAUSE OF ACTION


6 Defendant Brown Breach of Fiduciary Duty

57. Plaintiff realleges each and every allegation contained in the above paragraphs 1

8 through 56 with the same force and effect as though herein set forth at length omits it for

9 brevity.

10 58. Plaintiff alleges that Defendant Brown's inaction constitutes a violation of

11 California Civil Code § 18501 in effect is adding and abetting Defendant Bowen when

12 she acted with a conflict of interest after November 13, 2009 at all times mentioned

13 herein with explicit knowledge of the law with malice when after it was shown that the

14 Defendant Dunn's Voter registration form shown as Exhibit A was incomplete as to his

15 pnor registration address in Flonda which effected the Declaration of Candidacy filed on

16 or about November 13, 2009 shown as Exhibit B

17 FIFTH CAUSE OF ACTION


18 ALL Defendants Unjust Enrichment

19 59. Plaintiff realleges each and every allegation contained in the above paragraphs 1

20 through 58 with the same force and effect as though herein set forth at length omits it for

21 brevity.

22 60 Plaintiff alleges that ALL Defendants' actions constitute a common law violation

23 of equity by concealment, bad faith dealing, conflict of interest, entenng false or

24 misleading statements into the public records for the purpose of unjust ennchment to the

Complaint Page 17 of 18
1 detriment of Plaintiff in the amount of $x.xx, and along with those similariy situated in

2 the amount of $x.xx.

3 WHEREFORE, plaintiff prays fbr a judgment against defendants as follows:

4 1. For an order of SOS to remove Defendant Dunn from the Republican Primary

5 Ballot as Mr. Dunn has not met the statutoiy requirement with CEC §8001 (a)2, NVfRA

6 and HAVA; and for consequential damages according to proof at trial by jury and that

7 this matter be referred for criminal prosecutk)n;

8 2. For an order to investigate forensic evidence of document fraud.

9 3. For an order baning Defendant Debra Bowen firom the General Election ballot in

10 that she Is in violation of CEC §18501 NVRA / HAVA; and fbr consequential damages

11 according to proof at trial by jury and that the matter be referred fbr criminal prosecution;

12 4. For an order barring Defendant Jeny Brown from the General Election ballot in

13 that he is in violation of CEC §18501 NVRA and HAVA; and fbr consequential damages

14 according to proof at trial by jury and that the matter be refened for criminal prosecution;

15 5. For punitive damages for fraud, oppression, and malice;

16 6. For costs and attomey fees of suit herein incunied according to statute; and,

17 7. For such ottier and furttier relief as the court may deem just and proper.

18 I declare under penalty of perjury under ttie laws of the State of Califomia that ttie

19 foregoing is tiue and conect.

20 DATED: May 10,2010


21
22
23
24 Sacramento, CA, 95826
25 Ph: (415) 846-7170
26 Fax: (866) 908-2252

Complaint Page 18 of 18
COMPLAINT - Barnett v. Dunn et al

EXHIBITA
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COMPLAINT - Barnett v. Dunn et al

EXHIBIT B
.. ^ S . - J F t h p Secretary at State CANDIDATE INTENTION STATEMENT
Candidate Intention Statement CALIFORNIA
FORIVI
IOV 13 2009
For Official Use Only
Check One: [g] initial • Amendment (Explain)
Socretary of State

1. Candidate Information: l^7.Z-~^^/


NAME OF CANDIDATE tLest Rrst, MHmie Initial) DAYTIME TELEPHONE NUMBER FAX NUMBER (optional) E-MAIL (opUonaO

Dunn, Damon J. ( 949 ) 660-0716 ( )


STREET ADDRESS CITY STATE ZIP CODE

2070 Business Center Drive, Suite 140 Irvine CA 92612


OFFICE SOUGHT (POSITION TITLE) AGENCY NAME DISTRICT NUMBER. tfappScaita • NON-PARTISAN
Secretary of State State of Caiifomia nia PARTY Republican
OFFICE JURISDICTION
[ 3 State IComplete Part 2)
n City n County • Multi-County.
(Name ofMulll-County JuilsiScllon) CYear of Bectton)

2. State Candidate Expenditure Limit Statement:


(CalPERS candidates. Judges, /udiaal candidates, end candidates for tocal offices are nol required to comptete Part 2)

^^'^ Primary/general election special/runoff election


(YearolBectlon) (Year <a Election)

(Cneck one box)


(^ I accept the voluntary expenditure ceiling for ttie election stated above.

Q I do not accept the voluntary expenditure ceiling for the election stated above
¥*
Amendment:
O I did not exceed the expenditure ceiling in the primary or special election held on: and I accept the voluntary expenditure ceiling for the
general or speciai run-off election

(Marl( It appBcatile)
Si
• On / / i contributed personal funds in excess of the expenditure ceiling for the election stated above f

3. Verification:
I certify under penalty of peQury under the laws of the State of California regoing i?" and correct

Executed on. 11/05/09 <aL/t<>wJV\


Signature
(month, day, year) (Candidate)
FPPC F o r m 501 (January/05)
FPPC Toil-Free Helpline: 866/ASK-FPPC (866/275-3772)
COMPLAINT - Barnett v. Dunn et al

EXHIBIT C
OFFICE OF T H E SUPERVISOR OF ELECTIONS

JERRY HOLLAND IOS EAST MONROE STHEET


SUPERVISOR OF ELECTIONS /ACKSO,>JViaE. RORllM J!IO!

aU.I9M))ltM71 E MAIL JHOILANDOCOJ NET

Apnl 13, 2010

Dear Su- or Madam

I am wntmg to document my correspondence with Mr Damon Dunn On July 10, 2009 Mr.
Dunn contacted our office via telephone and asked for his ineligible voter registration tecord
to bc removed from thc Duval County database. 1 contacted the Division of Elecuons later
that day to inquire if this was possible and thc Legal Department for the Division mformed
me that the tecord could not be deleted from the database because voter registration is
permanent record

I then mailed a letter to Mr Dunn infomung him of my findings 1 have not had additional
correspondence with Mr Dunn smce this mudcnL

Thank you.

Jean Mane Atkins


Director of Voter Admimstrauon
COMPLAINT - Barnett v. Dunn et al

EXHIBIT D
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Scan Oate •= 10/31/2003


COMPLAINT - Barnett V Dunn etal

EXHIBIT E
Scout com- Damon Dunn for CA Sec of State' Page 1 of4

Entertainment Money Lifestyle More Bing I Searcti Scout

S C O l i t vi'iih FOXSP'anTS.CQM Sign In Q^JUQ


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Recruiting
Tickets
Damon Dunn for CA Sec of State'
By M a r k DcVaiighn
Contributing Wntcr
Posted Jan II 2010

I More

Former Cardinal wide receiver and kicl< return specialist Damon Dunn once showcased a God-given talent for
following Ins blockers and running for daylight. After a successful career in commercial real estate m Orange
County, the former Texan with finely-tuned rhetorical and communicative skills has set his sights on crossing
another goal-line, this time running for California's Secretary of State!

Is California "Dunn" for Ihe


Sccietaiy''

Damon Dunn for CA Sec of Statei

Explore your freethinking mind to contemplate solutions to California's well-publicized troubles The Golden State is known for its ground-breaking innovation, its
unparalleled creativity and its history of using that brainpower to overcome tough times

"That's just a narrative," Damon Dunn counters "I don't speak in narratives Narratives don't solve problems Actions solve problems"

You once knew htm as No 80, Stanford's playmaking kick-off returner/wide receiver who returned three kickoffs for touchdowns between 1994 a n d l 997 You might
remember Dunn as the player Tyrone Wiiiingham referred to as "Rev," as in Reverend, since Dunn became a licensed Baptist minister at age 19

Dunn ts now out to add another title to his name Secretary of State for California The 33-year-old is the Republican Party candidate for California's top elections
officer, a man who would supervise the state's elections and ballot measures He spent the recent holidays resting up at home in Irvine, prepanng for a challenging
year of campaigning leading up to the 2010 election against Democratic incumbent Debra Bowen

"\Ne have to ask ourselves tough questions," satd Dunn, who grew up in Mansfield, Texas, the same hometown of current Cardinal freshman tailback Slepfan Tavior

The man who speaks of posing hard questions is no stranger to overcoming difficulty Dunn's mother Ramona was oniy 15 when she became pregnant with Damon
The father was Mike Lockett, the University of Texas' starting fullback tn the iate '70s Lockett was kiiied in a car accident while dnvmg back to campus when Dunn
was only three

"My mom wore a scarlet letter on her chest for what she went through at such a young age," Dunn said "She's a success story We talk aii the time She'll always
inspire me"

Since graduating in 1998, Dunn has made a comfortable living in commercial real estate His Stanford roots remain a frequent topic, given that his Orange County
home IS so close to so many USC-backers

"Football IS the common denominator," he said "It helps in the connection process you have with other people" A recent Los Angeles Times article about htm noted a
play that came at the expense of those whose vote he's courting Conventional wisdom says that USC alumni and fans - heads expanded with success over the past
decade - have forgiven Dunn for his 93-yard kickoff return for a touchdown during Stanford's 24-20 victory tn 1996

On non-football topics, Dunn speaks tn excited and vibrant tones Diverse political heroes include Martin Luther King, Barack Obama and Governor Pete Wilson He
remains a political novice, having never mn for office previously He Trst registered to vote as a Democrat a decade ago but never actually went to the polls until May
of 2009 Like a lost soul finding religion, Dunn found the proper path to affecting meaningful change, encouraged by a lasting relationship with former U S Secretary of
State Condi Rice, whom he met while a student at Stanford, when Rice served as the University's Provost Now Dunn feels he "gets" it No more standing on the
sidelines and failing to get involved in the process As he told the Los Angeles Times, "Who better to reach a non-voter than a recovenng non-voter?"

Critics point to a lack of political expenence and the undeniable fact of Dunn's own ptxir history of voting should count against htm [Ed - Yeah, well, a great deal of
"political expenence" and consistent majority-crushing voting by the Dems sure haven't helped California much in recent years)

Dunn spoke of the opportunity presented by California's troubling economic downturn

"If I get elected, I'll take it upon myself to do exit interviews with the companies who leave our state for economic reasons I'll give that information to other elected
officials As of now, oniy the secretary of state gets to know that kind of information We need to grow our revenues We need another version of the tech boom of the
'90s"

Microsoft TV ads of the '90s asked viewers "Where do you want to go today?" At the time, Dunn was busy gaming chunks of gridiron yardage

He was part of the famed 1994 recruiting class, returning kickoffs and snaring passes from Steve Stenstrom, Mark Butterfield and Chad Hutchinson while becoming a
four-year letterman The recruiting Class of '94 group's 14 members started nearly 280 games between them, meaning that each member was a starter for an average
of two full seasons It was an uneasy beginning Dunn lost a fumble on a punt against Northwestern on his first college piay He bounced back to run a kick back 100
yards weeks later at Arizona State

http://stanford.scout.eom/2/936969.html 5/9/2010
Scout.com- Damon Dunn for CA Sec. of State' Page 2 of4

Dunn remains a close friendship with another Texas-bred member of that landmark recruiting class Anthony Bookman a regular caller on Dunn's Blackberry He's
also tight with fellow receiver Trov Wallers, also from Texas The 1999 Biletnikoff Award winner just finished his second season as offensive coordinator and wide
receivers coach for Indiana State, where former Cardinal receiver and All-American return specialist Luke Powell coaches defensive backs

"Being a Stanford football player, it's being the ultimate leader," he said "The combination of the demands of the football field and the classroom, you have no choice
but to assert yourself and be a leader"

Who will lead California? Why not Damon Dunn? He can use some blockers! Republicans are a touchdown underdog these days in the Golden State

For those interested in Dunn's campaign, you can find htm on Facebook and at http //www damondunn com/

Do you have a "premium" subscnption to The Bootleg"! if not, then you are senously missing out on all the top Cardinal coverage we provide daily on our awanj-
winning website Sign up today for the biggest, baddest and best in Stanford sports coverage with TheBootleg com (sign-upll At The Bootleg, 'IVE WRlTEt'

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COMPLAINT - Barnett v. Dunn et al

EXHIBIT F
Print Page I of 2

From: Bill Van Allen (hvanailen@hvc rr.com)


To: DR_taitz@yahoo com.
Date: Wed, March 17, 2010 4:17:51 PM
Cc:
Subject: FW: Debra Bowen attacks Orly Taitz fund raiser presser sent to BAN / Richard Winger

E^EBRABOVHEN
P OR E. C n . C Tr A , n V O F S T. A T E

Dear Richard,

Ttie field of Republicans who want to unseat Debra Bowen as


California's Secretary of State is now set, and we just received
some amazing news — Orly Taitz, the leader of the so-
called "birther" movement that has spent years
challenging President Obama's citizenship, is running
against Debra for Secretary of State.

As you know, wealthy developer Damon Dunn, who says he


got into the race at Karl Rove's urging, is also running for the
Republican nomination Whoever prevails in the pnmary
MUST be taken senously because of their ability to raise
money and distort the issues through their national nght-wing
networks
CONTRIBUTE »
Please contribute today to help Debra stand against right-
wing ideologues like Orly Taitz. and continue serving the
ip«n""sw=a m
people of Californial

Orly Taitz' candidacy would be amusing if it weren't so senous Her pnmary reason for running is to challenge
President Obama's citizenship and invalidate the 2008 election In fact, Taitz has sued Debra twice to try to
invalidate Obama's victory

We can't let fringe conspiracy theorists use this office to get a foot In the door and undermine our
democracy.

Debra's opponents are well connected, and have the ability to raise large sums of money from across the
country We must make sure she has the resources to beat them

Please contribute today to help Debra stand against right-wing ideologues like Orly Taitz, and
continue serving the people of California!

We can't underestimate the importance ofthis race The Secretary of State is the one person in state
government who is responsible for the integnty of our elections As we saw in Flonda in 2000 and in Ohio four
years later, we need public servants we trust in this position, not people with a political agenda

Debra has long served the people of California with integnty We need her in the Secretary of State's office, not
a conspiracy theonst like Orly Taitz

Please contribute $25 or more todav so that Debra can defeat Orly Taitz and her financiai backers —
whose sole goal is to challenge President Obama's citizenship and nght to be President of the United States'

Thank you for your support We must do all we can to re-elect Debra, and fight against the nght-wing radicals
backing her opponents

http://us mg2.mail.yahoo.com/dc/launch?.gx=l&.rand=Ochuhvsiqntii&retry=l 5/9/2010


Print Page 2 of 2

Sincerely,

Steve Barkan
Senior Adviser
Secretary of State Debra Bowen 2010

CONTRIBUTE

600 Playhouse Alley, Suite 504


Pasadena, CA, 91030 ID #1271345

CLICK HERE TO UNSUBSCRIBE

http//us mg2.mail yahoo.com/dc/launch?.gx=l&.rand=Ochuhvsiqntii&retry==l 5/9/2010


COMPLAINT - Barnett v. Dunn et al

EXHIBIT G
California Focus Syndicated Column- A DOWN-THE-TICKLET RACE WITH TWO LIICE... Page 1 of 3

Share Report Abuse Next Blog» Create Blog Sign In

California Focus Syndicated Column


A twice-weekly syndicated newspaper column on California public affairs

FRIDAY, MARCH 5. 2010

A DOWN-THE-TICKET RACE WITH TWO LIKELY


WINNERS"
CALIFORNIA FOCUS
FOR RELEASE TUESDAY, MARCH 16, 2010, OR THEREAFTER

BY THOMAS D ELIAS
"A DOWN-THE-TICKET RACE WITH TWO LIKELY WINNERS"

No one in California politics gives 33-year-old Republican Damon Dunn


much chance of unseating Democratic Secretary of State Debra Bowen
this fall

Not only is she a well-entrenched political veteran, but even Dunn, a


Baptist pastor and former football player turned Orange County-based
real estate developer and shopping mall owner, concedes she has a
record of accomplishment in her first four years of holding statewide
office, especially when it comes to restonng voters' faith in the state's
voting techniques

"She gets credit for restonng some integnty to the process," Dunn said in
an interview, refernng to Bowen's review of electronic voting machines
and the resulting return to large-scale use of paper ballots In fact, she
gets so much credit that as of early March, Dunn was the only declared
Republican candidate running against her There was still a possibility that
another might jump in Orly Taitz, another Orange County figure who is a
leader of the "birther" movement that questions whether President Obama
IS eligible for his job

But Dunn, the only Republican now campaigning, enthusiastically and


unequivocally says he will win this fall and become California's first
Afncan-Amencan statewide officeholder since Mervyn Dymally was
lieutenant governor in the late 1970s

But he won't be bitter if he loses "I'm not in this to win, I'm in this to help,"
he declares "This state made me My mama had me when she was 16 I
was on welfare Few people have lived poorer than me "

He descnbes growing up in a family of 10, but still doing well enough


About Me
academically and athletically to win a Stanford University football
scholarship and later play on four National Football League clubs He California Focus
admits never voting until last spnng's speciai election, saying, "My family
didn't vote - that was a bad habit"

But he insists his ideas for the office are good and that his not having
voted in the past shouldn't matter as he seeks to be California's chief
election officiai "Not voting has nothing to do with the work," he said
Thomas Elias writes the syndicatetJ California
Part of what he envisions "Only the secretary of state gets a notice Focus column, appeanng twice weekly in 93
whenever a business in California shuts down or leaves," Dunn said "The newspapers around California, with
secretary of state can examine the exact reasons and try to get something circulation over 2 2 million He has won
done about them I would assign one of the eight appointees the secretary numerous awards from organizations like the
of state gets to that task alone " National Headliners Club, the California
Newspaper Publishers Association, the
He also thinks he can reach out to other non-voters better than Bowen Greater Los Angeles Press Club, and the
"Who can reach non-voters better than a recovenng non-voter"?" he asks California Taxpayers Association He has

http.//www.califomiafocus net/2010/03/down-ticket-race-with-two-likely.html 5/9/2010


California Focus Syndicated Column: A DOWN-THE-TICKET RACE WITH TWO LIICE... Page 2 of 3

Bowen says she'll gladly debe..>s Dunn sometime after the June pnmary bov-ii nominated three times for the Pulitzer
election, but says his ideas are naive, if idealistic Pnze in distinguished commentary Elias is
the author of two books, "The Burzynski
"Most businesses that close down are not leaving the state," she said Breakthrough The Most Promising Cancer
"Even in good times, only one in eight businesses that starts up will
Treatment and the Government's Campaign
survive the first year A lot of closures are due to bankruptcy, too, and the
economy Businesses are closing at about the same rate in every part of to Squelch II" (now in its third edition, also
the country So ifyou followed up on every closure, you'd be wasting a lot published in Japanese and recently optioned
of time" for a television movie) and "The Simpson
Tnal in Black and White," co-authored with
And when it comes to new voter outreach, she said, "You discover that the late Dennis Schatzman
this IS a huge state and there's a limit to how many places you can
actually go So we accomplish a lot of outreach through partnerships with View mv complete profile
businesses and unions and chambers of commerce and schools You
have to create relationships and then leverage them " Followers
One thing Bowen doesn't buy is the notion that Dunn's candidacy is the
product of a plot devised by Republican strategist Karl Rove, long the Follow £1
chief political adviser to former President George W Bush, for the GOP to with Google Fnend Connect
take control of the national election process at the state level
Followers (15)
Some Democrats claim there is such a Rove-led conspiracy, an extension
of the belief that former Flonda Secretary of State Kathenne Harns threw
the 2000 election to Bush and former Ohio Secretary of State Kenneth
Blackwell did the same for him in 2004

The belief that Dunn might be part of such a plan was furthered by a
newspaper report that Rove now advises Dunn In fact, says Dunn, he
has met Rove only once, fleetingly "He wouldn't remember my name I
Already a member?SiarL!n
wasn't even a candidate when I met him," Dunn said "Nobody recruited
me I wish they did because it would be great to get some donations "
Blog Archive
Bowen scoffs at the idea of a Rovian plot "I'm not much for conspiracy
theones," she said "Besides, I don't think Karl Rove would exactly be an T 2010(38)
asset in California" • May (2)
Even if he were, it would still be difficult to unseat an incumbent widely • April (10)
credited with restonng electoral confidence to California Where does that T March (8)
leave Dunn"? Probably with a promising future, especially since he's BIG OUT-MIGRATION SLOWDOWN
shown a willingness to serve a campaign apprenticeship that will give him SHOULD END A FALSE POLI ..
a leg up in future elections
DID POIZNER WAIT TOO LONG?
Which IS why this contest might be the rare one that produces two WILL BROWN DO THE SAME?
winners GOOD RIDDANCE TO THE CON-CON
CONCEPT
-30-
COUNTING ILLEGALS. IT'S THE LAW
Email Thomas Elias at tdelias@aol com His book, "The Burzynski
AND IT'S GOOD FOR
Breakthrough," is now available in a soft cover fourth edition For more
Elias columns, visit www californiafocus net PARTIES DON'T GET IT AS VOTERS
Posted by California Focus at 1 48 PWI ^3 DECLAREINDEPENDENC.
Labels 2010. MarcliTC
WILL RIVALS BE FOILS FOR A
CANNY JERRY BROWN?
1 comments: IMMIGRANT AMNESTY LITTLE
CHANCE THIS YEAR
Anonymous said A DOWN-THE-TICKET RACE WITH
TWO LIKELY WINNERS"
Dunn claims he didn't vote in the last presidential election,
but says Obama is his hero I'm not buying it People should • February (8)
be aware that Dunn was a registered Democrat for 10 years • January (10)
and failed to disclose that on his registration he is also
• 2009(80)
ineligible to run as a Republican because he has only been
a Republican for 8 months This guy is a shill for the
Democrats to prevent Orly Taitz from winning because they
know she is not going to allow Obama on the ballot in 2012
without proof he is natural-born United States citizen

http //www califomiafocus.net/20I0/03/down-ticket-race-with-two-likely.html 5/9/2010


COMPLAINT - Barnett V Dunn etal

EXHIBIT H
DEBRA BOWEN i SECRETARY OF STATE
STATE OF CALIFORNIA | ELECTIONS
150011th Street, 5th flooi | Sacramento, CA 958141 Tel (916) 657-2166] Fax (916) 653-32141 www.sos.ca gov

March 23, 2010

Pamela Barnett
2541 Warrego Way
Sacramento, CA 95826

Dear Ms. Barnett:

We are responding to your recent complaint regarding what you perceived to be our
failure to act on your 12/09/09 letter questioning Barack Obama's birth records You
also provided a notarized certificate of acknowledgement as required for complaints
alleging a violation of Title III of the Help America Vote Act (HAVA). However, your
complaint was not treated as a HAVA complaint because you did not allege a HAVA
violation.

No authority exists to require the Secretary of State to make an inquiry into or demand
detailed proof of citizenship from Presidential candidates Elections Code section 6901
required the Secretary of State to provide local elections officials with a certified list of
the names and party affiliations of candidates nominated by their respective parties to
appear on the November 4, 2008 Presidential General Election ballot. Afterthe election,
Elections Code section 15505 required the Secretary of State to certify to the Govemor
the names of the electors receiving the highest number of votes

The Secretary of Staie does not have a clear or present ministerial duty to demand
documentary proof that any past or future Presidential candidate is qualified to serve as
President of the United States. Government Code section 12172.5 provides that the
Secretary of State "shall see that state election laws are enforced," but does not impose
such a duty. As no law requires the Secretary of State to demand proof of citizenship
from Presidential candidates, there is no duty to act under GC 12172.5.

For your information, the appropriate remedy for an issue concerning the qualifications
of a President is an action before the United States Congress pursuant to the Twelfth
Amendment to the United States Constitution and 3 U.S.C. section 15.

Sincerely,

Election Fraud Investigation Unit


December 9, 2008

Pamela Barnett
2541 Warrego Way
Sacramento, CA, 95826 ^
(415)846-7170 o " S o
C3 ^
fn j>-'
c~i -pi'
>
December9, 2008 ^ -- rn''-^
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—^ .„.
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Secretary of State -»i rc o'^
1500 i f ' S t *^
Election Division, 5"' Floor -I vo "
Sacramento, CA, 94814

I object to the Electoral College members votes being given to Barack Obama, the Democrat Party
Nominee for POTUS, because I am not satisfied that his birth recorcis indicate he is qualified for the
office of President underthe requirements of Article II o f t h e U.S Constitution; and because he has not
made his birth recoids available to answer the question notwithstanding having been sued on that issue
in courts across the country Obama's Hawaiian Certification of Live Birth has been considered to be a
fraud by document experts. Even if Obama's COLS were authentic, Hawaiian law allowed "foreign"
births to registered at the year Obama reported himself to be born, 1961

Futhermore, even if Obama was born in the United States, he would NOT be considered a Natural Born
citizen because his father was a British Citizen from Kenya Obama admits bemg a British citizen at birth
and then two years later his citizenship was lawfully changed to Kenyan citizenship of which he kept
until he was in his 20's There are cases before the Supreme Court right now to attempt lo clarify this
situation

If you were to allow the electoral vote to happen and then it is determined that Obama is NOT a natural
born citizen, he would then become a Usurper which would put our country in a Constitutional cnsis
Please do whatever it takes to avoid this cnsis DO NOT ALLOW THE ELECTORS TO VOTE FOR OBAMA
UNTIL IT IS PROVEN HE IS A NATURAL BORN CITIZEN I demand that the statc of California hire a
document expert to perform their own investigation into Obama's COLE to determine if he committed
fraud

I have sworn affidavits from document experts if you would like these for the file I also have additional
research to assist you if needed

Sincere1y,N (jjA _ Ij'jsC

r \^^^:b/^- •--
.\! v..._._::.":_---^
Pamela Barnett \l'y > •" V 3", .".- _;
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USPS - Print Order Summary Page I of 1

UMTEDSTATES
POSTALSERVICE* <Back') (IWnfV)

Printed Domestic Labels


Transaction* 163359994
Charged to VISA ** ***9728
Labels Inclutded 1
Print Date/Time 3/8/10 4 14 56 PM CST

1 1 1
Delivery Addres: Package Info Scntice Price
1 1 1
1 of 1 SECRETARY OF STATES Ship Date 03/08/10 Prionty Mail Flat Rate Env $4 75
ELECTION FRAUD INVES Weight Olbs 10oz Delivery Confirm $0 00
1500 11THSTFL5 From 95826 Label Total $4.75
SACRAMENTO, CA 95814-5701
Delivery Confirmation™ Label Number 9405 5036 9930 0166 1993 95

Domestic Order Total: $4.75

https://sss-web usps com/cns/orderSummaryView.do?orderId=I63359994&submitControl= .. 3/8/2010


COMPLAINT - Barnett v. Dunn et al

EXHIBIT I
April 2, 2010

CPT Pamela Barnett, U.S.A Retired


2541 Warrego Way
Sacramento, CA, 95826

Attorney General's Office California Department of Justice Attn- Public Inquiry Unit P O Box 944255
Sacramento, CA 94244-2550
Fax (916) 323-5341

RE: CRIMINAL COMPLAINT AGAINST DEBRA BOWEN, SECRETARY OF STATE

This IS a cnminal complaint against Secretary of State Debra Bowen for committing Misprision of Fraud by failing to
act on my fraud complaint (registered with her office Dec 9, 2008 - attached) that alerted her that Barack Hussein
Obama's online (internet) Hawaii Certification of Live Births (3 versions in total) are all forgenes and that there
were affidavits filed in court that confirmed the fraud. I had asked her to perform an immediate investigation and
halt the elector's vote until the investigation was completed.

As evidenced by a letter I received from the Secretary of State Election Fraud Investigation Unit (dated March 23-
attached), in response to my follow-up letter (letter dated March 7"", attached), Bowen failed to investigate the
fraud that she was mformed of that affected the outcome of the California election of Barack Obama. It is her
duty as the State Representative of elections to ensure legal elections. She has failed to do this by ignoring
election fraud.

Covering up felony fraud is Misprision of felony Fraud. If your office fails to investigate the Obama forgenes, you
are also guilty of misprision of felony fraud

As a California citizen and a registered California voter who voted in the 2008 Presidential election, I fully expect
you to prosecute Secretary of State Debra Bowen for misprision of fraud and investigate the document forgeries
put forth by Barack Hussein Obama Bowen should also be removed immediatety from her position of Secretary of
State as she does not ensure legal elections. The Election Fraud Investigation Unit wrongfully dismisses the fraud
complaint, because they say the SOS does not have the responsibility to vet candidates; however she does have
the duty to investigate and ensure prosecution in matters of election fraud

I pray that Edmund "Gerry" Brown, AG, and his office care more about our Country and the rule of law than his
political career and they fully investigate this fraud performed by Obama and his supporters, as well as the crime
of misprision of felony fraud by Secretary of State Debra Bowen.

V^7>-*-T-^
ela Barjjett
X
b_realestate@yahoo.com

Cc- California Governor's Office, Federal Bureau of Investigation, Departmentof Justice


SECRETARY OF STATE
STATE OF CALIFORNIA
ELECTION COMPLAINT FORM
For Help America Vote Act (HAVA) complaints or other election-related complaints.
Important- Please Type or Pnnt the information on this form
COMPLAINANT INFORMATION

First Name: f^/H^Zv^ Last Name: h N ^ V ^ J T


Street Address: ^ ^ j j i>iprA/l^ao 6^<'^Apt#: City: <P^^ r^^^^^-^i^ State.<:^<2_
Zip Code: 9 s - ^ ^ L Daytime Phone /f^/S'I f*/6 •?/Po Evening-
Fax Number: Email: Ja^j i h ^ r/\. ^r:jcxs e. c^,'^^-^,'/' c^^o^

PERSON(S) OR ORGANIZATION(S) AGAINST WHOM COMPLAINT IS BROUGHT

Name(s): C)Q(^^tf\ <S^Mg?V


Organi2ation(s) S^^^jr^^-kr. L^L/ O ( - S fCi/r^
Position(s) of person(s) (if applicabl^: <:^r y- *L-fr.^ <-tv o ^ S-to h(-

STATEMENT OF FACTS

Date(s) and time(s) alleged event(s) occurred /^j'j loff


Locatior(s) of alleged event(s). /V/^)A-
Names and phone numbers of wrtnesses or other victims (if applicable)

DESCRIBE YOUR COMPLAINT (If necessary, attach additional sheets.)

H ^ etec/Vp,^ o.f- /5<t/-rcr;^ < : j ^ / 9 7 ^ / f ^ f />{^-^i'c:^(?^-h^f^Hrvi JA^i/^dSii^M

'-^^rtd^.^—cMjQu'^r^ Trjr^rH i^^/9-/2y^ (Was <^nf^tC< o^S h a h f ^

SIGNATURE 1 aclcnowtedge that all of the above information is true and accurately reflects the matter
in question, to the^bestof my Icnowledge

SIGNATUR ^ ^ , , i . , i ^ ^ ^ DATE- / i M ^ ^ ^ ^ , y ^ O / i X .
If your cdfnplaint alleges a violation of Title III of HAVA, a notary public nnust
complete the following certificate of acknowledgement.
D E B R A B O W E N | SECRETARY OF STATE
STATE OF CALIFORNIA | ELECTIONS
150011th Street, sth flooi | Sacramento, CA958141 Tel (916) 657-2166I Fax (916) 653-3214I www sos ca gov

March 23, 2010

Pamela Barnett
2541 Warrego Way
Sacramento, CA 95826

Dear Ms. Barnett:

We are responding to your recent complaint regarding what you perceived to be our
failure to act on your 12/09/09 letter questioning Barack Obama's birth records You
also provided a notarized certificate of acknowledgement as required for complaints
alleging a violation of Title III of the Help America Vote Act (HAVA). However, your
complaint was not treated as a HAVA complaint because you did not allege a HAVA
violation.

No authority exists to require the Secretary of State to make an inquiry into or demand
detailed proof of citizenship from Presidential candidates. Elections Code section 6901
required the Secretary of State to provide local elections officials with a certified list of
the names and party affiliations of candidates nominated by their respective parties to
appear on the November 4, 2008 Presidential General Election ballot. Afterthe election,
Elections Code section 15505 required the Secretary of State to certify to the Governor
the names of the electors receiving the highest number of votes

The Secretary of Staie does not have a clear or present ministerial duty to demand
documentary proof that any past or future Presidential candidate is qualified to serve as
President of the United States. Government Code section 12172.5 provides that the
Secretary of State "shall see that state election laws are enforced," but does not impose
such a duty. As no law requires the Secretary of State to demand proof of citizenship
from Presidential candidates, there is no duty to act under GC 12172.5.

For your information, the appropriate remedy for an issue concerning the qualifications
of a President is an action before the United States Congress pursuant to the Twelfth
Amendment to the United States Constitution and 3 U.S.C, section 15.

Sincerely,

Election Fraud Investigation Unit


Decembers, 2008

Pamela Barnett
2541 Warrego Way
C/)
Sacramento, CA, 95826 r-o
m C 3
iTJ
(415)846-7170 o
X}
0 3
o
m C3 53
mm] I-n > :!
C~) Tpi-.
>
December 9, 2008 50 fi'' ^
O
•<
Secretary of State
o
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-D
rK
35
. 1 •

tn
1500 11'*'St >
> tn r-
Election Division, 5^'' Floor -1 03 - i .

Sacramento, CA, 94814

I object to the Electoral College members votes being given to Barack Obama, the Democrat Party
Nommee for POTUS, because I am not satisfied that his birth records indicate he is qualified forthe
office of President under the requirements of Article II of the U.S. Constitution, and because he has not
made his birth recoids available to answer the question notwithstandmg having been sued on that issue
in courts across the country Obama's Hawaiian Certification of Live Birth has been considered to be a
fraud by document experts Even if Obama's COLB were authentic, Hawaiian law allowed "foreign"
births to registered at the year Obama reported himself to be born, 1961

Futhermore, even if Obama was born in the United States, he would NOT be considered a Natural Born
citizen because hts father was a British Citizen from Kenya Obama admits being a British citizen at birth
and then two years later his citizenship was lawfully changed to Kenyan citizenship of which he kept
until he was in his 20's There are cases before the Supreme Court right now to attempt to clarify this
situation

If you were to allow the electoral vote to happen and then it is determmed that Obama is NOT a natural
born citizen, he would then become a Usurper which would put our country in a Constitutional cnsis
Please do whatever it takes to avoid this cnsis DO NOT ALLOW THE ELECTORS TO VOTE FOR OBAMA
UNTIL IT IS PROVEN HE IS A NATURAL BORN CITIZEN I demand that the statc of California hire a
document expert to perform their own investigation into Obama's COLB to determine if he committed
fraud

I have sworn affidavits from document experts if you would like these for the file I also have additional
research to assist you if needed

Sincere1v,\
h^^r----
j Xt,.''.;^' f

Pamela Barnett ,'' ,M,.


k^, J- . ' ' '

1 -i'Si;^'
CERTIFICATE OF ACKNOWLEDGMENT
For HAVA Title III complaints only.

State of California

Countyof S^^fj^f^^^ )

On t h f K h A J ^ 9 ^/^eforeme, ^T U3QAAJJU , HO'kxX^ \'LAQ\JXL


(date) (tnsert name and title of th^^fficer)

, personally appeared f <x>vv\

who proved to me on the basis of satisfactory evidence to be the person(e)-whose name(»^^re


subscribed to the within instrument and acknowledged to me that h e ^ ^ t t i e y executed the same in
hia^l^^heir authorized capacity(je^, and that by h i ^ e ^ e i r signatijre(sfon the instrument the
person(sJ, orthe entity upon behalf of which the person (s)-eicted, executed the instrument

I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing
paragraph is true and correct.

WITNESS my hand and official seal.

JOTARXPUHlIC SIGNATURE) NOTARY PUBLIC SEAL

Return this form to:


SECRETARY OF STATE'S OFFICE
ELECTION FRAUD INVESTIGATION UNIT
1500 11TH STREET, STH FLOOR, SACRAMENTO, CA 95814
For more information or assistance:
English: 1-800-345-VOTE (8683)
Spanish: 1-800-232-VOTA (8682)
www.sos.ca.gov
NO 29473

IN THE SUPREME COURT OF THE STATE OF HAWAII

CONSTITUTION PARTY; ALAN L. KEYES,


ORIGINAL PROCEEDING
Plaintiffs,
DECLARATION OF
vs. XXXXXXXXXXXX; EXHIBIT A

LINDA LINGLE in her official capacity as


Govemor ofthe State of Hawaii; KEVIN B
CRONIN in his official capacity as the Chief
Election Officer for the State of Hawaii; JOHN
DOES 1-50, JANE DOES 1-50; DOE
PARTNERSHIPS 1-50; DOE
CORPORATIONS 1-50; AND DOE
ENTITIES 1-50

Defendants.
F \Activc Clicnts\Smilh, Thomns\Elcction ChallcngcVAnonymous Digitablc Expert
Declaration wpd

DECLARATION OF XXXXXXXXXXXX

I, XXXXXXXXXXXX, declare as follows:

1. I am Dr. XXXXXXXXXXXX, and I hold a PhD in Instructional Systems with 25+ years of

post-doctoral work experience, and a Masters Degree in Educationai Research, Design, and Testing.

I have worked with computers and computer printers, plotters, and optical/digital scanners, typesetting,

offset printing, and automatic typewriters, for over thirty (30) years. I am submitting this opinion

anonymously because I work for a govemment contractor and need to remain anonymous in order to keep

my employer free from any ramifications due to presenting this opmion. In addition, my family needs

the opinion to be anonymous due to the nature ofmy work.

2. In my professional career I have held positions as a Computer Programmer, Web Designer, Media

Consultant, Research Director and Statistician. I have testified as a Statistical Expert in Govemmental

hearings over the last twenty (20) years.


3. I began working with computers on or about 1969 and with graphic arts since 1965 I have

worked with document image scanners since 1982 and with digital images and digital editing

software since 1987.1 have received professional training in the use of Adobe Photoshop and Image

Ready software with a particular focus on creating web graphics I have also worked with laser

printers since 1986

4. My father was a professional photographer who taught me how to use high-end cameras,

such as a Hasselblad he gave me when I was eight (8) years old, and have been using them ever since.

In addition to using DLR and SLR cameras, and running a film developing studio, I started using

digital cameras in my work field on or about 1998

5 With my combined work experiences and education, I am more than capable of detecting

anomalies on digital images and photographs, whether naturally caused or man-made, as well as

determining how the were created, and if they were subsequently modified.

6. During the Barack Hussein Obama's [hereinafter "Obama"] Presidential campaign, there have

been numerous rumors circulating about Obama's citizenship status.

7. Jim Geraghty, a Writer for National Review magazine and the National Review Online,

posted a story to his blog, the Campaign Spot that appeared in the National Review Online, raising

issues that Obama was bom in Kenya, his middle name was really Muhammad and Obama's first

name was really Barry Mr Geraghty stated that several Reporters had asked for a copy of Obama's

birth certificate, but, all requests were subsequently denied Mr. Geraghty further stated Obama

could answer the questions regarding the time and place of his birth, citizenship status, full legal

name, and the names of his biological parents, ifhe would simply release for inspecfion, a copy of

his original, long-form birth certificate.


8. The Daily Kos blog, a pro-Obama website, posted an image, measuring 2427 x 2369 pixels,

at 300 DPI that they claimed was a scanned copy of Obama's "originai birth certificate," sent to them

by a spokesperson for the Obama Campaign. Before cropping, this document image measured 2550

X 3300 pixels. By the end ofthe same day, the Obama Campaign posted a duplicate copy ofthe

same cropped image on their website, My.BarackObama.com, but this image copy had been

proportionately reduced in size by approximately 42% and saved at a lower resolufion The size of

this particular image was 1024 x 1000 pixels at IOO DPI. With this image, Obama's Campaign

placed the following statement on their website-

"You may have recently heard right-wing smears questioning Barack Obama's birth certificate and

citizenship These assertions are completely false and designed to play into the worst kind of

stereotypes You can see Barack Obama's birth certificate for yourself and help push back with the

truth..."

9. The very next day, the Obama's Campaign removed the document image from their

Campaign website, and posted a resized copy ofthe same document image to a new website, "Fight

The Smears" (fightthesmears.com), but only after further reducing the copy size to 585 x 575 pixels,

which was almost half the size ofthe originai posted image, and one-third ofits quality.

10 Also, Politifact.org, a pro-Obama fact checking website, published a copy ofthe same image

as posted on the Daily Kos, but also disproportionately reduced it to 811 x 786 pixels, or 1/3 ofits

size and 1/6 ofits image quality

11. Factcheck.org, a pro-Obama fact checking website posted a full-sized image copy of same

document image that appeared on the Daily Kos and Obama's "Fight The Smears" websites

Factcheck's image copy was identical to the Daily Kos image copy, but was not cropped to the
borders. Factcheck org is run by Obama supporters and is funded by the Annenberg foundation

through the Annenberg Public Policy Center ofthe University of Pennsylvania

12 Factcheck.org made the following statement to explain how they received their image copy:

"Bloggers raised questions based on the absence of evidence, specifically the lack of a

publicly available copy ofa birth certificate and the supposed secrecy surrounding it". According

to FactCheck, Tommy Vietor at the Obama campaign sent a message to them and "other reporters"

saying, "I know there have been some rumors spreading about Obama's citizenship, so I wanted to

make sure you all had a copy of his birth certificate "

13 Three months later, no other "reporters" have ever received a copy ofthis "birth certificate"

image, or any other birth certificate image, from Tommy Vietor or from anyone else connected with

the Obama Campaign. As noted above, the only parties outside ofthe Obama Campaign to have ever

received a copy of this "birth certificate" image are (a) The Daily Kos, a pro-Obama blog, (b)

FactCheck.org, a pro-Obama political research group, and (c) Polififact org, another pro-Obama

political research group. It is also worth mentioning that no copy ofthe reverse side ofthis "birth

certificate" document was ever scanned, a side that contains all of the officiai certification

instruments, such as the official Hawaiian Seal, State Registrar's signature, and date stamp of when

the document was printed.

14 I noticed that the images posted on the Intemet purporting to be the "original birth certificate"

of Barack Hussein Obama, did not look like a regular birth certificate: On the top of the image

border was the phrase, "Certification of Live Birth". Unlike traditional birth certificates, this image

did not show the hospital name where Obama was bom, did not have an attending physician's
signature, did not have any signatures by the parents, or any of the other identifying information

which "original" birth certificates have.

15 After reviewing the images purporting to be Obama's "onginal birth certificate," I contacted

the Hawaii Department of Health and asked numerous questions ofthe Office of Vital Records and

of the State Registrar, whose signature appears on all certified birth documents. I subsequently

leamed that this document, called, a "Certificafion of Live Birth," (COLB), is only a transcript ofa

birth record onfile.This "Certification of Live Birth," (COLB), is a computer-generated graphic that

contains only a limited amount of information retrieved from a person's birth record on file, and is

not the same thing as an original birth certificate: It cannot be used to obtain a passport or to prove

that Its owner is a natural-bom US cifizen. I also leamed that, after this paper document is printed.

It has to be certified or validated by imprmtmg on it a special, embossed seal, a mbber date stamp

showing when the COLB was pnnted, and lastly, a mbber stamp containing the signature of Hawaii's

State Registrar. I also noted that the embossed Seal and Registrar's Signature stamp were not visible

to the naked eye. The date stamp, however, was partially visible, in reverse, as the ink had apparently

bled through from the back to the front side ofthe COLB paper.

16. Although there are four differently-sized images placed on four different websites, they were

all copiedfi-omthe same document image In addition to posting a copy on their Fight The Smears

website, the Obama Campaign emailed copies to the pro-Obama, Daily Kos website, Annenberg's

Factcheck website, and lastly, the St. Petersburg Times, Politifact website. Found on all four images

IS a small, telltale object (actually, a piece of dirt left on the scanner glass) confirming that all four

of these images were copied from a single document image. As I inspected the highest-quality image
copy available (found on the Daily Kos), I saw anomalies in the text that would never exist in a

genuine scan ofa real document.

17. After enlarging the image four times its size, I noticed that the text in the image bore the

Signs of being graphically altered after the image had been created. Specifically, given that the text

in a COLB is prmted on a green background, there should be green dots, or pixels, visible in between

the black letters that comprise the text. What I found was almost the total absence of any green

pixels. In their place, I found gray and white pixels These pixel pattems are significant because they

would never be found in a genuine document scan. To validate my findings that the text in this

COLB document image was intentionally altered, and that the pixel pattems were not naturally-

occurring pnnter or scanner artifacts, I made over 700 test scans and images using an actual paper

COLB and different scanners By trying different combinations of scanning and image parameters.

I was finally able to replicate the Kos image so closely that other image experts thought it was the

same Kos image, and not my "clone " From this date forward, when I first discovered the evidence

of image tampering, and regardless of the unfamiliar format of the COLB and the questionable

information it contained, I collected a great deal of additional evidence, that the scanned image

alleged to be a true copy of Obama's original COLB was forged, and that this altered image of an

official state-issued document is nothing less than a false identification document as defined by

Chapter 18, Section 1028 ofthe United States Code.

18. All ofmy findmgs pertain to a single source image from which the Obama Campaign made

four (4) copies These copies were posted to four different websites: FightTheSmears.com,

DailyKos com, FactCheck.org, and Politifact.com, as referred to and described above. These images
are still posted on these websites, and are descnbed in my Final Report, which is attached hereto and

incorporated in by reference as Exhibit "A"

19 Slightly more than two months after the publication ofthe COLB image on the Daily Kos

and Obama's Campaign website, Factcheck published a story. Bom in the U.S.A., in which they

presented nine digital photographs that they allegedly made of Obama's "real, paper COLB" at his

campaign headquarters - the same COLB used to make the document image they posted on June 16.

Without a doubt, the COLB image that Factcheck posted is a forgery, and that Obama's real COLB,

as proffered by Factcheck, is a nonexistent document. Factcheck had created a conundmm: ifthe

image Factcheck posted is a forgery ofa nonexistent document, then how can any genuine photos

be made ofit? The answer had to be that both the document image and the photographs were all

forgenes.

20. I have thoroughly examined the photographs that FactCheck published, and have

subsequently found clear and irrefutable evidence of tampering in both the alleged COLB object they

photographed and in the photos themselves. One of those COLB objects was, in fact, a printout of

a forged document image with a Seal superimposed onto it. FactCheck's photos reveal both the

absence of known, relevant features found on a genuine 2007 COLB and the presence of illogical

and impossible features that would never be found on a genuine 2007 COLB Specifically, on the

COLB objects photographed, the secunty border closely resembles the border found on a real 2007

COLB. However, both the embossed Seal and the State Registrar's Signature stamp do not match the

same elements found on a real 2007 COLB, but perfectly match those found on a real 2008 COLB,

or, in other words, something that would never happen in real life Hawaii made three important

changes to their COLBs from 2007 to 2008, including the use ofa larger certificate layout, a new

7
security border, and, much to the chagrin of Factcheck and the Obama Campaign, a new Seal and

Signature stamp.

21. With my experience and specialization in document imaging, my fmdings are conclusive and

irrefutable, as outlined in EXHIBIT "A," that the COLB images posted by Obama to his campaign

website, fightthesmears.com, to the dailykos.com, a pro-Obama blog, to FactCheck.org, a pro-

Obama political research group, and to Politifact.org, are, in fact, image forgeries, created with the

intent to defraud the American People into believing that these images were digitally scanned from

Barack Obama's genuine, "original" birth certificate, and that Obama had satisfied the requirement

of being a natural-bom US citizen.

22. With my experience and specialization in photography and digital imaging, my fmdings are

conclusive, as outlined in Exhibit "A," that the COLB photographs posted byFactCheck.org, a pro-

Obama political research group, and to Politifact.org, are, in fact, photographic forgeries, created

with the intent to defraud the American People into believing that these digital photographs were

taken of Obama's genuine, "original" birth certificate, and that Obama was really a natural-bom US

citizen qualified to be President ofthe United States.

23. Attached hereto as Exliibit "A", is a true and correct copy of my opinions concerning the

Obama certification of live birth, which I previously published and incorporate herein as if fully set

forth.

I declare under the penalty ofperjury ofthe laws ofthe United States, that the foregoing is

true and correct.


2008-12-04 10:49 LINES *CENTER 4809664177 » 18005068304 P V2

NO. 29473

IN
THE SUPREME COURT OF THE STATE OF HA WAU

CONSTITUTION PARTY; ALAN L. KEYES;


ORIGINAL PROCEEDING
Plaintiffs,
DECLARATION OF SANDRA
vs. RAMSEY LINES; EXHIBIT C

LINDA LINGLE in her official capacity as


Govemor ofthe State of Hawaii; KEVIN B.
CRONIN in his official capacity as the Chief
Election Officer for the State of Hawaii; JOHN
DOES 1-50; JANE DOES 1-50; DOE
PARTNERSHIPS 1-50; DOE
CORPORATIONS 1-50; AND DOE
ENTITIES 1-50

Defendants.
C \Uscn\Owiiei\I>eiktap\MYriLESUohaM«C«ifl\FMeralCiiw\PlciiiU^
DeclBttlon e f SaiuliB Lmes wpd

DECLARATION OF SANDRA RAMSEY LINES

I, Sandra Ramsey Lines, declare as follows:

1. I am Sandra Ramsey Lines, with an address at 6200 East Cholla Lane, Paradise Vailley,
Arizona 85253.1 am a former federal examiner and law enforcement officer. I began training as
a forensic document examiner in 1991.1 am a Certified Dilomate with the American Boatd of
Forensic Document Examiners, a Fellow b the American Academy of Forensic Sciences, a
member of the American Society of Questioned Document Examiners, a member ot the
Southwestem Association of Forensic Document Examiners, and a member of the Questioned
Document Subcommittee ofthe American Society of Testing and Materials. My background and
credentials are set fbrth in Exhibit I attached hereto.

2. I have reviewed the attached affidavit posted on the internet fiom "Ron Polarik," who has
declined to provide his name because of a number of death threats he has received. After my
review and based upon my years of experience, I can state with certainty that the C O L B
presented on the internet by the various groups, which include the **Daily Kos," the Obama
Campaign, "Factcheck.org" and others cannot be relied upon as genuine. Mr. Polarik raises
issues conceming the COLB that I can affinn. Software such as Adobe Photoshop can produce
2008-12-04 10:49 LINES *CENTEP 4809664177 » 18005068304 P2/2

complete im^es or alter images tfaat appear to be genuine; therefore, any image offered onj the
intemet cannot be relied upon as being a copy of the authentic document.

3. Upon a cursory inspection of the intemet COLB, one aspect of the image that is clearly
questionable is the obliteration of the Certificate No. That number is a tracking number that
would allow anyone to ask the question, "Does this number refer to the Certification of Live
Birth for the child Barack Hussein Obama II?" It would not reveal any fiulher personal
information; therefore, there would be no justifiable reason for obliterating it

4. In my experience as a forensic document examiner, if an original ofany document exists, that


is the document that must be examined to obtain a definitive finding of genuineness or non-
genuineness. In this case, exanunation of the vault birth certificate for President-Elect Obama
would lay this issue to rest once and for all.

Further, affiant sayeth not.

DATED: December 4,2008.

Stateof Arizona )
)ss.
County of Maricopa )

Before me, C^nv^*. S. Q.ij\p^i\er a Notaiy PubHc in and for the aforesaid State and
County, comes Sandra Ramsey Lines, to me known to be the person wfao ex^uted the aforesaid
Affidavit, and who acknowledged same to be true to the best of his knowledge, infonnation and
belief.

Y PUBLIC
NOTARY ^
My Commission Expiies:
'he^, <-f, ;»<!)ia-- SFFERnsa:
CONNIE S. RINGOER
MyCaww. tnJm D«c 4.3012
EXHIBIT I
SANDRA RAMSEY LINES
Forensic Document Examiner
6200 East Cholla Lane
Paradise Valley, Arizona 85253
Business: (480) 429-3999 - Facsimile: (480) 429-4677
E-Mail: SRLines(g)co\.nct
littp://\vwvv.asqde.org/

CURRICULUM VITAE

EXPERIENCE

1999-Present Private Practice, Forensic Document Examiner - Conduct examination of questioned


documents, which consists of the analysis and companson of handwriting, hand printing,
typewriting, commercial printing processes, photocopies, paper, inks, and other documentary
evidence to determine identity, source, authenticity, alterations, additions, deletions, or other
germane issues Examinations include business and/or medical records Expert testimony
experience in state and federal courts, and regulatory hearings

1999 - 2003 Intelligence Specialist - Department of the Treasury, Bureau of Alcohol, Tobacco and Firearms,
Phoenix Field Division, Phoenix, AZ Served as the intelligence coordinator and the Division's
intelligence expert (5 states) Responsible for ascertaining the Division's intelligence needs,
developing and implementing the means to satisfy such requirements Served as Bureau
representative and liaison to outside intelligence related organizations, performed analyses of
major complex investigations, and provided analytical reports of such activities In addition, acted
as forensic document examiner consultant and expert witness in ATF related cases Top secret
clearance

1996- 1999 Senior Document Analyst - Department of the Treasury, Bureau of Alcohol, Tobacco and
Firearms, San Francisco Forensic Science Laboratory, Walnut Creek, CA Conducted
examinations of questioned documents, which consisted of the analysis and comparison of
handwriting, hand printing, typewriting, commercial printing processes, paper, inks, and other
documentary evidence Testified in state and federal courts Secret clearance

1991 - 1996 Forensic Document Examiner - Office of the Attomey General, Phoenix, AZ Established
questioned document laboratory utilized by Medicaid Fraud Units throughout the United States
and developed AZ Police Officer Standards and Trainmg approved lesson plan for training on the
"Techniques of Questioned Document Investigation " Depositions and testimony in state courts,
civil and regulatory proceedings

1985-1996 Special Agent/AZ Certified Peace Officer - Office of the Attomey General, Speciai
Investigations Section, Phoenix, AZ Identified, planned, and developed strategies for complex
felony investigations, which included consumer, medical, financiai frauds, environmental crimes,
political corruption, and other matters

1987 - 1988 Assistant Director - Westem States Hazardous Waste Project, Office ofthe Attorney General,
Phoenix, AZ Maintained coordination and cooperation between members in multi-state program
Developed and implemented training, collected, stored, and disseminated information, prepared
bi-monthly newsletter

1984- 1985 Investigator/AZ Certified Peace Officer - Maricopa County Attomey's Office, Phoenix, AZ
Conducted major felony investigations involving violent crimes and frauds.

1983 - 1984 Investigator - AZ Board of Medical Examiners, Phoenix, AZ. Investigated criminal and civil
complaints pertaining to physicians, physician assistants, unlicensed medical practitioners,
coordinated complex investigations with law enforcement and regulatory agencies

1973-1982 Sergeant/Ohio Certified Peace Officer - Cleveland Police Department, Cleveland, OH.
Supervised platoon of 40 officers in all phases of police work, as a detective assignments included
vice, general duty, strike force, and homicide, and as an evidence technician/patrol officer
responsible for crime scene photographs, latent prints, and trace evidence as well as all other radio
calls

CERTIFICATION

1996 American Board of Forensic Document Examiners, Diplomate Advertising Editor for the
ABFDENews \991-1999

PROFESSIONAL ORGANIZATIONS

1998-Present American Academy of Forensic Sciences, Questioned Document Section, Fellow Member 1996-
1997, Provisional Member I994-I995 Elected Questioned Document Section Secretary for 2004-
2005, Section Chair 2005-2006

1999-Present American Society of Questioned Document Examiners, Member Provisional Member 1995-
1999 Member of the Editorial Board of the Journal of ihe Amencan Society of Questioned
Documeni Examiners, 1997 to 2004 Editor 2004-2007

1995-Present Southwestern Association of Forensic Document Examiners, Member Provisional Member 1993-
1994

2000-Present American Society of Testing and Materials, Member E-30 Forensic Sciences Committee, Member
E30 02 Questioned Document Subcommittee

EDUCATION

Arizona State University, School of Public Affairs/Advanced Public Executive Program and the
State of Anzona, Phoenix, AZ - Certified Public Manager 1993

University of Phoenix, Phoenix, AZ - Bachelor of Arts, Management, 1989

Scottsdale Community College, Scottsdale, AZ - Associate of Arts, Major - Administration of


Justice, Honors, 1987

EXPERT TESTIMONY INCLUDES

Federal courts in Alaska, Arizona, Califomia, Idaho, Texas, and Washington


State courts in Arizona, California, Nevada, and Texas
PUBLICATIONS/PRESENTATIONS

2008 Speaker: "The Work ofthe Forensic Document Examiner" Phoenix North Rotary Club, Phoenix, AZ
(June 12)

2007 Presenter: "A Thumbnail Sketch of Islam and Judaism as They Relate to Forensic Document Examination
and the Courts " Paper presented at the 65''^ Annual Conference of the American Society of Questioned
Document Examiners, Boulder CO (August 16)

2006 Presenter: "Legal Terms for Expressing Conclusions in Court" Paper presented at the 64"' Annual
Conference ofthe American Society of Questioned Document Examiners, Portland, OR (August 22)

2006 Publication: "Examination ofa 'Velasco' Signature on an Oil Painting " Published in the Journal ofthe
Forensics Sciences, My 2006, WQ\ 51, NO 4,pp 929-933

2005 Publication: "A Study of Business Letter Features " ""Lines and Randy B Carodine * Research presented
at the 57"' Annual Meeting of the American Academy of Forensic Sciences, New Orleans, LA (February)
2005, and at the Southwestem Association of Forensic Document Examiners, Monterey, CA (March) 2003.
Puhhshedmthe Journal ofForensic Sciences,Vol 50, No 4, July, 2005, pp 924-927

2005 Speaker: "Forensic Document Examination " Tempe Rotary Club Tempe, AZ(June 14)

2005 Presenter: "Publish or Perish" Paper presented at the Southwestem Association of Forensic
Document Examiners Spring Meeting, Palm Spnngs, CA (May)

2005 Speaker: "What is a Forensic Document Examiner''" The P E O Sisterhood Luncheon Meeting,
Scottsdale, AZ (January)

2003 Publication: "Identifying Manufacturer and Date of Manufacture of CD-R or CD-RW " "^Lines and
Jared Annes •*Research presented at the 61st Annual Meeting of the American Society of Questioned
Document Examiners, Baltimore, MD (August) Published in the Journal of the Amencan Society of
Questioned Documeni Examiners, Vol 6, Number 2, December 2003

2002 Book Review: iVnling and Defending Your Expert Report, The Step-by-Slep Guide wtth Models, Steven
Babitsky and James Mangraviti, Seak, 2002 Review published in The Southwestern Examiner
(September)

2002 Publication: "Triplet & Sibling Handwriting Study to Determine Degree of Individuality and Natural
Variation " *Lines and Frankie E Franck '^Research presented at the 60' Annual Meeting ofthe American
Society of Questioned Document Examiners, San Diego, CA (August) Published in the Journal of the
Amencan Society of Questioned Documeni Examiners, Vol 6, Number 1, June 2003, pp 48-55

2002 Book Review: Opporlunilies in Forensic Science Careers, Biythe Camenson, McGraw Hill, 2001 Review
published in the ABFDE News, Vol XIII, Number 1 (January)

2001 Publication: "Yoeme The Yaqui Alphabet," Research presented at the 20"' Anniversary Meeting,
Southwestem Association of Forensic Document Examiners, Tempe, AZ (September) Published The
International Journal of Forensic Documeni Examiners, Vol 6, No 1, April 2003 (on-line)

2001 Publication: "Dine Bizaad The Navajo Alphabet," Research presented 59"" Annual Meeting of the
American Society of Questioned Document Examiners, Des Moines, IA (August) Published The
International Journal of Forensic Document Examiners, Vol 6, No I, April 2003 (on-line)
1999 Publication: "Normal Course-of-Business Records v Manufactured Records" *Sandra Ramsey Lines,
Jan Seaman Kelly, and Diane K Tolliver *Research presented at the 57"" Annual Meeting of the
American Society of Questioned Document Examiners jointly held with the International Association of
Forensic Sciences in Los Angeles, CA (August) Published Journal ofthe Amencan Society of Questioned
Documeni Examiners, Vol 2, No 1, June Translated into Spanish by Julia E. de la Pena, published
Indagaciones documentales, Ediciones La Rocca Buenos Aires 2008

1998 Book Review: "Review ofthe Modern Scientific Evidence The Law and Science of Expert Testtmony,"
Faigman, D , et al, West, 1997 Review published in The California Identification Digest, Vol 98, Issue 3,
(March)

1997 Publication: "A Study ofthe Evolution of Handwnting from Grades Three to Six" Published in the
Journal ofthe Amencan Society of Questioned Document Examiners, Vol 1, No 1, June Research
presented at the 55"^ Annual Conference of the American Society of Questioned Document Examiners in
Scottsdale, AZ (August)

1997 Paper: "Microsoft® Encarta® A Resource for Forensic Document Examiners," 48th Annual Meeting of
the American Academy of Forensic Sciences, New York, NY (Febmary)

1997 Speaker: "Forensic Document Examination Past and Present," Bay Counties Identification Officer's
Association, Concord, CA (January)

1997 Book Review: The Casebook of Forensic Detection," Colin Evans, John Wiley & Sons, NY, 310 pages
Review published in The Southwestern Examiner, Vol XVI, Issue 1

1996 Publication "Indenture" Historical and legal research of a 1729 document Published in the
International Journal of Forensic Document Examiners, Vol 3, No 3, July/Sept 1997 Presented at the
48th Annual Meeting ofthe Amencan Academy of Forensic Sciences, Nashville, TN (February)

1995 Documentary: "Leaming to Write in the I990's" Co-producer (w/Leslie K Rogers) and co-writer
(w/Rada Tiemey) ofthis minidocumentary film presented with a paper at the 53*^ Annual Conference ofthe
American Society of Questioned Document Examiners, Chicago, IL (September) and the Fall Conference
ofthe Southwestem Association of Forensic Document Examiners, Las Vegas, NV (October)

1995 Speaker: "Fundamentals of Forensic Document Examination" Arizona Women's Accounting Society,
Phoenix, AZ (April)

1995 Publication: "The Effect of Computers on Forensic Document Examiners" Research published in the
International Journal of Forensic Document Examiners, yo\ 2, No 3, July/Sept 1996 Presented at the
47th Annual Meeting of the American Academy of Forensic Sciences, Seattle, WA (February) and the
Spring Conference of the Southwestem Association of Forensic Document Examiners, San Diego, CA
(April)

1994 Speaker: "Computer Technology and the Forensic Document Examiner," Annual Meeting of the
Computer Users Group, Security Division, Intemal Revenue Service, Scottsdale, AZ (September)

1994 Speaker: "Forensics and Fraud," Kiwanis Club, Carefree, AZ (July)

1994 Publication: "The Cherokee Syllabary " Research involving a Native American alphabet still in use today
Published in the Journal of Forensic Sciences, Vol 39, No 4, July Presented at the 46''' Annual Meeting
ofthe American Academy of Forensic Sciences, San Antonio, TX (February) and the Spring Conference of
the Southwestem Association of Forensic Document Examiners, Avalon, CA (April)

1992 Speaker: "The Science of Examining Documentary Evidence," Arizona Chapter of the Association of
Certified Fraud Examiners, Phoenix, AZ (September)
1989 Research Paper: "To What Extent Have Computers and Computer-Generated Documents Impacted on
the Role of the Questioned Document Examiner in Law Enforcement," Southwestern
Association of Forensic Document Examiners, Tucson, AZ (April)

TEACHING/MISCELLANEOUS

2008 Instmctor "Handwriting, Forensic Records, and the New Age of Computer-Based Fraudulent Documents,"
Arizona Association of Criminal Justice, Tempe, AZ (March 13)

2006 Instructor "Forensic Document Examination" Forensic Medical Investigation (by National Faculty
Member Dr Mary Dudley, MD, Chief Medical Examiner, Forensic Pathologist and District Coroner,
Sedgwick County Regional Forensic Science Center, Wichita, KA) Phoenix, AZ (November 9)

2005 Instmctor "Forensic Document Examination Overview" Forensic Medical Investigation Seminar (by
National Faculty Member Dr Mary Dudley, MD, Chief Medical Examiner, Forensic Pathologist and
District Coroner, Sedgwick County Regional Forensic Science Center, Wichita, KA) Phoenix, AZ
(November 3)

2005 Instmctor "Questioned Documents - Including the 'tme story' behind the Dan Rather/CBS debacle
involving the examination of the alleged 'Bush' National Guard memos " Arizona Public Defender's
Association, Tempe, AZ (June 22)

2005 Grand Awards Judge Intel Intemational Science and Engineering Fair, Behavioral and Social Sciences,
Phoenix, AZ (May 10, 11)

2005 Moderator "21*' Century Crime - Forensic Science," American Academy of Forensic Sciences, 57"'
Annual Meeting, New Orleans, LA (Febmary)

2004 Instmctor "Forensic Document Examination Overview" Forensic Medical Investigation Seminar (by
National Faculty Member Dr Mary Dudley, MD, Chief Medical Examiner, Forensic Pathologist and
District Coroner, Sedgwick County Regional Forensic Science Center, Wichita, KA) Phoenix, AZ
(November 11)

2004 Instmctor "Forensic Documents Issues in the Computer Age " Continuing legal education State Bar of
Arizona, San Diego, CA (July 16)

2001 Acknowledged for contribution to the Book Opportunities m Forensic Science Careers, Biythe Camenson,
published by VGM, division of McGraw-Hill Companies, Lincolnwood, IL.

2000 Meeting participant and sub-committee member (since 1998) with the Scientific Working Group for
Document Examiners (SWGDOC) at the Federal Bureau of Investigation Academy in Quantico, VA
SWGDOC is responsible for establishing and publishing written procedures and guidelines for questioned
document examination (January)

1998 Instmctor ATF Agent Training Conference, Oxnard, CA, "The Forensic Document Examiner and the
Agent" (June 8)

1998 Instmctor Provided 36 hours of training at ATF Laboratory to a document examiner trainee with the San
Mateo County ShenfTs Office, CA (April)

1998 Moderator "Dating Document by Ink Analysis and Other Examinations," American Academy of Forensic
Sciences, 50"^ Anniversary Meeting, San Francisco, CA (Febmary)

1997 Document Examiners of Northem California, organized Planned and hosted quarterly study group
meetings 1997 through 1999
1997 Instructor Provided 36 hours of training at ATF Laboratory to two document examiner trainees from
Houston, TX Police Department (June)

1997 Instmctor Provided "Overview of Forensic Document Examination" to the Northern California Forensic
Identification Unit Study Group, Concord Police Department, Concord, CA (January)

1997 Judge Multiple District Four Lions 60"' Annual Student Speakers Program, "Today's Legal System - Is it
Justice''" Concord, CA

1995 Instructor "Curriculum Development Course," Medicaid Fraud Training Program, Federal Law
Enforcement Training Center, sponsored by the National Association of Attorneys General, Glynco, GA
(September)

1995 Training Committee Member Arizona Law Enforcement Coordinating Committee Conference, "Officer
Safety Surviving in Troubled Times" (June).

1995 Instructor "Techniques of Questioned Document Investigation," National Association of Medicaid Fraud
Control Units Training Conference, Memphis, TN (May)

1992 Instructor "Questioned Documents Collection and Submission Guidelines," two training presentations to
Arizona Attomey General staff. Phoenix, AZ (January)

PROFESSIONAL TRAINING AND CONTINUED EDUCATION

Arizona Department of Public Safety, Scientific Analysis Division/Central Regional Crime Laboratory, Questioned
Document Unit, Phoenix, AZ, two-year apprenticeship program in the field of forensic document examination,
1991-1993 (Lockard)

United States Secret Service, Federal Law Enforcement Training Academy, Glynco, GA, Questioned Document
Course, June 1991, 80 hours

Scottsdale Community College, Scottsdale, AZ, Photography I, II, and III, 1991-1992, 9 credit hours

Paper Knowledge Workshop, The Meade Corporation, sponsored by the Southwestem Association of Forensic
Document Examiners, Denver, CO, October 1992, 8 hours

Federal Bureau of Investigation, Quantico, VA, Fundamentals of Questioned Documents Course, 80 hours.
University of Virginia, November 1992, 4 credit hours

United States Postal Crime Laboratory, San Bmno, CA, 160 hours of forensic document training, January 1993
(Lewis, Morton, et al)

San Diego Police Department, Crime Laboratory, Questioned Document Section, San Diego, CA, 160 hours
forensic document training, March 1993 (Oleksow)

Bureau of Alcohol, Tobacco and Firearms, Westem States Regional Laboratory, Walnut Creek, CA, 40 hours
forensic document training, June 1993 (Riker, Blanco)

Cleveland Police Department, Crime Laboratory, Cleveland, OH, 40 hours forensic document training. May 1993
(Wenderoth-Kelly)

Questioned Documents Reference Database and Typewriter Classification Database Workshop, Amencan Academy
of Forensic Sciences, San Antonio, TX, Febmary 1994 (Bouffard), 4 hours
Physical Match Workshop for Forensic Document Examiners, American Academy of Forensic Sciences, San
Antonio, TX, February 1994 (McKasson), 20 hours

Forensic Examination of Counterfeit Documents, American Society of Questioned Document Examiners, Long
Beach, CA, August 1994 (Lamer), 4 hours

Instructor Development Course, AZ Police Officers Standards and Training, Phoenix, AZ, sponsored by the Phoenix
Police Department, January 1995,40 hours

Case Documentation and Note Taking Workshop for ASCLD Lab Accreditation Requirements, Southwestern
Association of Forensic Document Examiners, Reno, NV, April 1996 (Blake, Cunningham), 4 hours

Private Practice Workshop, Amencan Society of Questioned Document Examiners, Washington, D C , August 1996
(Hart, Miller), 4 hours

Ink-Jet Printers, Hewlett Packard (Drago-R&D), Southwestem Association of Forensic Document Examiners,
Tucson, AZ, October 1996, 3 hours

Laser Printer Re-Insertion Problems Workshop, Southwestem Association of Forensic Document Examiners,
Tucson, AZ, October 1996 (Flynn), 4 hours

Difficult and Complex Handwriting Examinations Seminar, sponsored by the Amencan Board of Forensic
Document Examiners, Burlingame, CA, January 1997 (Conway, Cunningham), 24 hours

How to be a Better Expert Witness Workshop (Moseley JD, Dedrick JD), Amencan Academy of Forensic Sciences,
New York, NY, Febmary 1997, 4 hours

Courtroom Testimony, Laboratory Personnel, Bureau of Alcohol, Tobacco and Firearms, Rockvilie, MD, March
1997, 32 hours

Questioned Documents Examination Proficiency Tests, Crime Laboratory Proficiency Testing Program 1996, 1997,
1998

Advanced Handwriting Identification Handwriting Theory, Mechanics and Analysis, and the Fundamentals of
Disguised Writing, University of New Haven Graduate School, School of Public Safety and Professional Studies,
San Francisco, CA, Febmary 1998 (Sang, Richards, Horan), 3 credit hours

Computer Software Training Windows 95, Outlook, Word, Excel, PowerPoint, Access, and Netscape Sponsored
by ATF, Apnl 1-3, 1998, 24 hours

Microscopy Workshop (Kline) sponsored by the Southwestem Association of Forensic Document Examiners,
Breckenndge, CO, October 9, 1998, 4 hours

Check Writer Workshop (Tiemey), sponsored by the Southwestem Association of Forensic Document Examiners,
Breckenndge, CO, October 10, 1998,4 hours

Seminar on Paper Fiber Analysis (Walter J Rantanen, Integrated Paper Services, lnc), sponsored by the
Southwestem Association of Forensic Document Examiners, Marina Del Rey, CA, April 7-9, 2000, 12 hours

Printing Process Identification and Image Analysis for Forensic Document Examiners, Rochester Institute of
Technology, Rochester, NY, June 5-8, 2001, 28 hours

Detection of Counterfeit Documents (Rick Outland of U S Secret Service), sponsored by the Southwestern
Association of Forensic Document Examiners, Tempe, AZ, September 7, 2001, 6 hours
Forensic Examination of Typographic Documents Workshop (Flynn) sponsored by the Southwestern Association of
Forensic Document Examiners, Tempe, AZ, September 8, 2001, 6 hours

Additional software courses offered through the Bureau of Alcohol, Tobacco and Fireanns during 1999, 2000, and
2001

Teaching the Forensic Document Examiner How to Teach (Tarver PhD w/Califomia State University, Fresno),
sponsored by the Southwestem Association of Forensic Document Examiners, Anaheim, CA, April 6, 2003, 3 5
hours

Twenty-First Century Document Examinations Workshop - Part I & II (Gottesman, Belcastro, Mokrzycki of FBI),
sponsored by the Amencan Society of Questioned Document Examiners, Baltimore, MD, August 28, 2003,4 hours

State of the Art Infrared and Ultraviolet Examinations of Documents by the Video Spectral Comparator Workshop
(Richards, Kovarik, Sang), sponsored by the American Academy of Forensic Sciences, New Orleans, LA, 4 hours

Signature Disguise or Signature Forgery Workshop (Found PhD) sponsored by the Amencan Society of Questioned
Document Examiners, August 22, 2006, Portland, OR, 7 hours

Fine and Subtle Features of Handwriting (Cunningham, Morton, Flynn), sponsored by the Amencan Society of
Questioned Document Examiners, Portland, OR, August 23, 2006, 7 hours Appointed Group Leader

Signature Workshop (Rile, Hicks), sponsored by the American Society of Questioned Document Examiners,
Portland, OR, August 24, 2006, 4 hours Appointed Group Leader

Scientific Research A Guide to Designing, Conducting, Writing, Presenting, Publishing, and Analyzing Scientific
Research (Grusezecki PhD, Davis MD, Pmckard MD) Workshop sponsored by the Amencan Academy of Forensic
Sciences, San Antonio, TX, Febmary 20, 2007, 3 25 CE hours

Technical Writing Workshop sponsored by the Southwestem Association of Forensic Document Examiners,
Monterey, CA, Apnl 21-22, 2007, 6 hours

Authenticating Questioned Documents (LaPorte/Secret Service) Workshop sponsored by the American Society of
Questioned Document Examiners, Boulder, CO, August 13, 2007, 3 0 CE points

Examination of Documents by Analyzing the Paper (Rantanen) Workshop sponsored by the American Society of
Questioned Document Examiners, Boulder, CO, August 13, 2007, I 0 CE points

RECOGNITION

1996 Initially selected for iVho's Who in Science and Engineering, Marquis, 4"" Edition, 1998-1999

1997 Initially selected for Who's Who in Amencan Women, Marquis, 21" Edition, 1999-2000

1998 Initially selected for Who's Who in America, Marquis, 53"* Edition, 2000-2001

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COMPLAINT - Barnett v. Dunn et al

EXHIBIT J
Pamela Barnett
2541 Warrego Way
Sacramento, CA, 95826

California Secretary of State .


150011* St., 5'" Floor / ^ ffXf^Ci^f^&V^ )
Sacramento, CA, 95814 \ ^S'Qo^tS J
Fax (916)653-3214 ^ T ^ ^ /

RE: DAMON DUNN, Candidate for Secretary of State, IS NOT LEGALLY QUALIFIED TO BE ON
BALLOT and needs to be removed immediately

Damon Dunn does NOT meet the following qualification for running for Secretary of State of California;

Be a registered voter and otherwise qualified to vote for that office at the time
nomination papers are issued to the person.

Damon Dunn not only committed a crime of peijury by NOT revealing that he was fomierly
registered to vote as a Democrat in Florida and in Texas, but he is also DISQUALIFED for being
a legal candidate on the ballot for Secretary of State because he is NOT considered to be legally
registered to vote and was NOT legally eligible to vote for Secretary of State at the time he was
issued his nomination papers. See attachments for proof pft/WO oro ^^su^ t ^ icdtbn/
^ijaO.'^ 0O\OS (ixrc\STeTH>'^'
I expect the Secretary of State's office to act expeditiously in verifying the attached inforraation
and then remove Mr. Damon Dunnfiromthe primary and/or general election ballot.

ramela Bamett
Registered to Vote Citizen of California
(415)846.7170 . ^
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Declaration in support of expedited injunctive relief

Superior Court of California County of Sacramento Case No. 34-2010-00077415

Pamela Bamett v. Damon Dunn. Debra Bowen. Jerry Brown. John and Jane Doe(s)

EXHIBIT 2
fi^E^O/SPANISH
VIBS901I ON OTHEII StDi
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flEPBT:1
Declaration in support of expedited injunctive relief

Supenor Court of California County of Sacramento Case No- 34-2010-00077415

Pamela Bamett v. Damon Dunn. Debra Bowen. Jerry Brown. John and Jane Doe(s)

EXHIBIT 3
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Declaration in support of expedited injunctive relief

Superior Court of California County of Sacramento Case No. 34-2010-00077415

Pamela Bamett v. Damon Dunn. Debra Bowen. Jen-y Brown. John and Jane Doe(s)

EXHIBIT 4
I uaii^MQii uwu^iJU-JV a i v i w u ^ i ^ b^^JMifii \jn\9 u'j'^iiwju iiiiiw. j,HJ JU rwi r « u * ^ VI «>

T^ie Honorable Robert K. Doman

July f 2006
^DRAFT)
Thc HonoiabL- Chief Judge RH,!-I«K1 .1 Arcara
Forthe United .Slates Distnci Coun
Westem Dwlncr ot New York
.^04 l.'.S Counhouse
6iJ (.'ourt Sireei
Buffalo. Neu York 14202
Re; Fonniie el al v. /T/tC el ul WD.NY 06-<,v.8O i RJAi
Subject; liiteoemion as of Right FRCvP Rut« 24(a)

The Honnrahle Chief Judge Richard J Arcara,


I am fnrmer U S House Representative RoU^n
K Donian, pro se without bein8i'nji"<"»PK:& '^^oYi^^^^W^^S^ ^it»t<}i illeg.il;y by
Democrat Loretta Sanc)^zb}'^WSlieii vntfes m the f^9« CSrfbmia^tieiAl Lleaion. ami tAar
by consensus ofboth the RefMibl.oan aDd Democratic parties behind the scene"; in violation t>f-i»y 79te /^«^6r-/7y
(ff- /^AppoiTapa' nghts conspired then anrt now for oontrol over illegal alien vo^ingriowet in • / ^ J ' j ' J ^ / ^^MX
Cali/omia and seemingly nationwide. Aliens lUegalAvoting with impumif^u-ectfy brought t/f./ *
h.t if:
if our'
fc-jfj:
y*f>/'^' '/.JisjSsi^^lcieiiK to testify .md intervene in suppotl ofthe emKitiled pib^
• testify .md intervene in suppo'rt ofthe emKitiled piVse Pl-iintifts hereiH^
bolh in myownsclf-in1ei«st and for the survival ofournanon as a con-stmition^l lepublic
i t f i ^ / / « t>J( JIM J f
My direct uijury in 1996 and iilterward is the subject of PlamtifYs' Amended C'oirpla/ut
paragraphs 92. 117 thru 118 and 147. As such my inteivention is reqiiire.1 to e^'ablish accuracy
in thc record ofthe undeilying proveedings dating back more than ten years, and thai 1 also
contend will support and form the basi> for proving the partem and conduct associated wirh ^-^ih * " ' " JULJ
harbonng of illegal alien'! and violation of I'.S Citizen propnetary voting rights complainee/of
by Plaintiffs under civil RiCO piovisions
With leave ofthe Court aAer disposition ofthe current .Tune 4, 2006 text order of
Defendants to respond lo the "Remark" Docket #73 (therein requesting a special master to
ascertain auihoritj'rtnd jurisdiction ovei defendants within the stale of New York .^pecifica/^'
pnor to Plaintififs consolidated response in opposition to tbe various inoUou"i to dismiss), if
Plaiiititfs survive I desire to intervene fonnally under provisions ol FRCvP Rule 24t a) aud c be
given standing to testify under oath on the record ofthe proceeding accordingly. That by local
rules I have caused llu^ conespondence to lie duly ser\'ed upon paities hei-ein And t.\\x\ a diip//cate
and certificate of service is herewith attached. RespectHilly submitted foi action by

^Cy^^^^**fli£ ^
ROBERT KEn/NTTH DOJ<NAN
Certificale of Service
Cc; Plaintiffs pii.-ise
Defendants C ounsels

i»r4«:ws»iaBSBatua»wM^'.i
1 Pamela Barnett, Pro se Plaintiff
2 2541 Warrego Way
3 Sacramento, CA, 95826
4 Telephone. (415)846-7170
5 Fax. (866)908-2252
6
7 SUPERIOR COURT OF CALIFORNIA
8
9 COUNTY OF SACRAMENTO
10
11
12 Pamela Barnett Case No. 34-2010-00077415
13 Plaintiff,
14 MEMORANDUM OF LAW
15 Damon Jerrell Dunn (A K.A. Damon Dunn),
16 Debra Bowen individually and officially as in Support of an Order to Show
17 The California Secretary of State,
18 Edmund G. Brown Jr. (A.K.A. Jerry Brown) Cause for Injunctive Relief by
19 Officially as The California Attorney General
20 and individually, and John Doe(s) Writ of Prohibition and
21 and Jane Doe(s)
22 Defendants Writ of Mandamus
23
24

25 INTRODUCTION

26 I am Plaintiff Pamela Barnett self represented without being an attorney. This is

27 the Memorandum of Law accompanying the declaration in support of expedited

28 injunctive relief for a Wnt of Prohibition, Mandamus and other relief based upon

29 precedence facts and law as the Court deems necessary. I am confident in the

30 applicability ofthe relief requested herein based upon the facts, law precedence and

31 my command experience gained in 14 years of military service as a Captain with

32 experience as a public affairs, intelligence staff officer of a communication battalion as

33 commander of 40 solders at any one time training every unit for combat readiness for

Complaint Page 1 of 8
1 the Iraq/Afghan wars; and thereafter am currently raising my infant son and four year old

2 daughter while I am researching state and federal government fraud and filing lawsuits

3 to try to obtain justice for the citizens of the United States and residents of California. I

4 hope to soon attend law school and obtain a legal degree. As alleged in my complaint, I

5 am a duly registered elector and affiliated member of the California Republican Party,

6 and scheduled to vote at the June 8, 2010 Republican primary, and then at the General

7 Election; and as such, I am adamant on the requirement that any candidate for

8 Secretary of State of California must absolutely be above any appearance of

9 impropriety. The California Secretary of State is the fiduciary guardian of public records

10 of the 6"^ largest economy in the world and the top election official of the state that has

11 I the most electoral votes to determine the election of the President, and as such requires

12 a Secretary of State that has great integrity and that follows the law.

13 ARGUMENT OF THE FACTS

14 For very good reason, I do not trust Defendant Damon Jerrell Dunn (a.k.a. Damon

15 Dunn, Defendant Dunn), who based upon facts and law cannot be entrusted with the

16 responsibility to serve as the Secretary of State. To my alarm Dunn has been wrongly

17 placed on the California Republican Party primary ballot as a declared candidate for the

18 State of California Republican Party Candidate for Secretary of State of California on

19 June 8, 2010, aided and abetted by Defendant Debra Bowen who in her official capacity

20 as the Secretary of State ofthe State of California with CAL. ELEC. CODE § 10:

21 California Code - Section 10 is the chief of elections officer of the state, and has the

22 powers and duties specified in Section 12172.5 ofthe Government Code, is without the

23 discretion in her ministerial duties to make the outrageous connivance done in the

24

Complaint Page 2 of 8
1 I the Iraq/Afghan wars, and thereafter am currently raising my infant son and four year old

2 daughter while I am researching state and federal government fraud and filing lawsuits

3 to try to obtain justice for the citizens of the United States and residents of California. I

4 hope to soon attend law school and obtain a legal degree. As alleged in my complaint, I

5 am a duly registered elector and affiliated member of the California Republican Party,

6 and scheduled to vote at the June 8, 2010 Republican primary, and then at the General

Election; and as such, I am adamant on the requirement that any candidate for

8 I Secretary of State of California must absolutely be above any appearance of

9 impropriety. The California Secretary of State is the fiduciary guardian of public records

10 of the 6"^ largest economy in the world and the top election official of the state that has

11 the most electoral votes to determine the election of the President, and as such requires

12 a Secretary of State that has great integrity and that follows the law.

13 ARGUMENT OF THE FACTS

14 For very good reason, I do not trust Defendant Damon Jerrell Dunn (a.k.a. Damon

15 Dunn, Defendant Dunn), who based upon facts and law cannot be entmsted with the

16 responsibility to serve as the Secretary of State. To my alarm Dunn has been wrongly

17 placed on the California Republican Party primary ballot as a declared candidate for the

18 State of California Republican Party Candidate for Secretary of State of California on

19 June 8, 2010, aided and abetted by Defendant Debra Bowen who in her official capacity

20 as the Secretary of State of the State of California with CAL. ELEC. CODE § 10:

21 California Code - Section 10 is the chief of elections officer of the state, and has the

22 powers and duties specified in Section 12172.5 of the Government Code, is without the

23 discretion in her ministerial duties to make the outrageous connivance done in the

24

Complaint Page 2 of 8
1 matter of Mr. Dunn's ballot access, and therefore. Mr. Dunn must be removed before the

2 election and or a writ of prohibition and mandamus issued to guarantee to the people of

3 California that the records and propnetary property would remain safe.

4 That accordingly to CAL. ELEC. CODE § 18500. California Code, as the facts show

5 Mr. Dunn commits fraud or attempts to commit fraud, and as with any person who aids

6 or abets fraud or attempts to aid or abet fraud, in connection with any vote cast, to be

7 cast, or attempted to be cast, is guilty of a felony, punishable by imprisonment for 16

8 months or two or three years, and must be removed from the ballot and the People of

9 California protected from his pattern of connivance entenng such office of trust..

10 Furthermore was he already Secretary of State, accordingly to CAL. ELEC. CODE §

11 18501. California Code - Section 18501, and Mr. Dunn such public officiai who

12 knowingly violates any of the provisions of this chapter, and thereby aids in any way the

13 illegal casting or attempting to cast a vote, or who connives to nullify any of the

14 provisions of this chapter in order that fraud may be perpetrated, shall forever be

15 disqualified from holding office in this state and upon conviction shall be sentenced to a

16 state prison for 16 months or two or three years; and must be removed from the ballot

17 and the people of California protected from his pattern of connivance.

18 That before the advent of the 2002 Help Amenca to Vote Act there is the history

19 surrounding the National Voter Registration Act of 1993 (a.k.a. "Motor Voter") that

20 nationally with ACORN and other Social Justice Organizations is infamously known and

21 here in California especially, has an outrageous history that must not be forgotten and

22 guarded against a repeat by a trustworthy Secretary of State so as not to allow the

23 treachery of voter fraud again as associated with the 1996 election ofthe Honorable

24 Robert K. Dornan, Republican Congressman who in his own words (see Exhibit 4). "n/'as

Complaint Page 3 of 8
1 outrageously defeated by Democrat Loretta Sanchez by a minimum of 2,369 and

2 possibly 4,623 alien votes... with impunity in which not a single individual was charged

3 with thousands of felonies having been committed".

4 That for an example of ballot removal in re. William Wallace Murrey sought the

5 Amencan Independent Party line and was originally approved by the Orange County

6 Registrar on the ballot, and Mr. Kelly the Orange County Registrar was notified that

7 Murrey was a Republican until late December 2009, so Mr. Kelly removed Mr. Murrey

8 from the Ballot and held that it was an oversight by the Orange County Registrar's office,

9 which is a decision available by FOIL

10 However, the case before this Court and the Secretary of State is not about a simple

11 ballot removal as with Mr. Murrey, because Mr. Dunn is culpable by withholding his

12 previous registration address then acted to further conceal the existence of the previous

13 address of registration in Florida by attempting to expunge it thereby exhibits what in

14 junsprudence doctrine of Bad-man theory a bad person represents as the best test of

15 what the law CEC §8001 actually is. Because Mr. Dunn carefully calculated precisely

16 what the rules allow and attempted to operate up to for maximum campaign exposure

17 and fund raising capability with CEC §8001 (a) 1 only, but knowing there was a

18 permanent record in Florida that would jeopardize his candidacy Mr. Dunn went beyond

19 the limits of the law and with unclean hands attempted to expunge the Florida records

20 thereby combine as an admission against interest to be considered by the Court herein.

21 ARGUMENT ON THE LAW

22 The California Election Code (CEC) requires that to be eligible to be a qualified

23 candidate for Secretary of State a declared and a nominated candidate shall under §201

24 ofthe California Elections Code "be a registered voter and othenvise qualified to vote for

Complaint Page 4 of 8
1 that office at the time nomination papers are issued to the person"; and Mr. Dunn's

2 Registration Form is to be deemed invalid for being falsely submitted without voluntary

3 correction of what othenwise would be an inadvertent error or omission wasn't in facts

4 was intentional and malicious concealment in order to circumvent any ministenal

5 investigation of a pnor registration that would trigger use of CEC 8001 (a) 2 beyond the

6 simple "New" registration as applies with use of CEC 8001 (a)1 ONLY.

7 In that CEC and related law requires with CEC § 8001: California Code - Section

8 8001. (a) No declaration of candidacy for a partisan office... shall be filed, by a

9 candidate unless (1) at the time of presentation of the declaration and continuously for

10 not less than three months immediately prior to that time, or for as long as he has been

11 eligible to register to vote in the state, the candidate is shown by his affidavit of

12 registration to be affiliated with the political party the nomination of which he seeks, and

13 12) the candidate has not been registered as affiliated with a qualified political partv

14 other than that political partv the nomination of which he seeks within 12 months.

15 .(b)The elections officiai shall attach a certificate to the declaration of candidacy

16 showing the date on which the candidate registered as intending to affiliate with the

17 political party the nomination of which he seeks, and indicating that the candidate has

18 not been affiliated with any other qualified political party for the penod specified in

19 subdivision (a) immediately preceding the filing of the declaration

20 That according to CAL. ELEC. CODE § 18203. California Code - Section 18203.

21 Mr Dunn must be considered in light of his withholding ofthe pnor registration address

22 from the SOS when he filed or submits for filing a nomination paper or declaration of

23 candidacy knowing that it or any part of it has been made falsely is punishable by a fine

Complaint Page 5 of 8
1 not exceeding one thousand dollars ($1,000) or by impnsonment in the state pnson for

2 16 months or two or three years or by both the fine and imprisonment.

3 Moreover, Defendant Dunn committed voter fraud according to statutes CEC

4 §18203 and §18500 by intentionally not entering in his voter registration card

5 information about the fact that he registered somewhere before and that he registered

6 as a Democrat, maliciously failed to provide at Section 16 ofthe form shown as Exhibit

7 A that he was previously registered in Florida, and thereby concealed evidence of a

8 crime Defendant Dunn intended to commit to become California SOS. The Registration

9 form does NOT differentiate any pnor registration address, which may be active, inactive

10 or expired does not apply and that the SOS ministerial duty does not give discretion.

11 That based upon information and belief and according to a letter written April 13,

12 2010 by Jean Mane Atkins Director of Voter Administration the Duval County Board of

13 Election and obtained in person by Dr. Orly Taitz while in Florida, on July 10, 2009,

14 Defendant Dunn contacted the Flonda Board of Elections to have any record of

15 enrollment or affiliation with the Florida Democratic Party in the Duval County database

16 expunged from the official record.

17 The Florida Board of Election database in Duval County records that Defendant

18 Dunn registered in Florida, is shown previously affiliated with the Democratic Party.

19 That based upon information and belief the Flonda Board of Elections Official with the

20 fiduciary duty to safeguard the records of the Board of Elections including those of

21 Defendant Dunn refused to expunge the records when he asked July 10 2009, and

22 prove that Defendant Dunn was a Florida Democrat within the 12 month penod prior to

23 Defendant Dunn declaring his candidacy in California on November 5, 2009.

Complaint Page 6 of 8
1 That according to CAL. ELEC. CODE § 17. California Code - Section 17. The

2 Secretary of State shall establish and maintain administrative complaint procedures,

3 pursuant to the requirements of the Help America Vote Act of 2002 (42 U.S C. Sec.

4 15512), in order to remedy gnevances in the administration of elections. The Secretary

5 of State may not require that the administrative remedies provided in the complaint

6 procedures established pursuant to this section be exhausted in order to pursue any

7 other remedies provided by state or federal law. The creation of a national voter

8 registration database with the Election Assistance Commission is to prevent multiple

9 registrations and voter fraud that since 1993 and Motor Voter has been rampant and

10 epidemic requinng ngorous use of HAVA to prevent fraud by the SOS and this Court.

11 ARGUMENT FOR RELIEF

12 Venue is proper in the County of Sacramento and this is the proper court for this

13 complaint as the events complained of occurred within this county because it involves

14 the Secretary of State of California (SOS) and a candidate for Secretary of State as is

15 Defendant in the California statewide Republican Party Direct Pnmary ^^\ and then the

16 General Election ballots with CA Election Code (CEC) § 12, and at a Jury tnal General

17 Damages be assessed were the Primary to proceed illegally, would result in Defendants

18 liability to reimburse the cost of the Republican pnmary and costs incurred of any

19 opposing candidate and or Plaintiff herein along with those similarly situated, and that

20 jurisdiction shall be given preference in the CA Courts with CAL. CCP. CODE § 44 *^'

CAL ELEC. CODE § 316- California Code - Section 316 "Direct primary" is the pnmary
election held on the first Tuesday after the first Monday in June in each even-numbered year, to
nominate candidates to be voted for at the ensuing general election or to elect members of a
party central committee
^. CA. CCP Code § 44, California Code - Section 44 Appeals in probate proceedings, in
contested election cases, and in actions for libel or slander by a person wno holds any elective
public office or a candidate for any such office alleged to have occurred dunng the course of an

Complaint Page 7 of 8
1 that according to CAL. ELEC. CODE § 8800: Califomla Code - Seclion 8800. No

2 candidate whose declaration of candidacy has been filed for any primary etection may

3 withdraw as a candidate at that primary election. Must be removed by Judidal Order for

4 injunctive relieve issuance of a Writ of Prohibition and Mandamus accordingly and for

5 such other and further relief as the court may deem just and proper.

6 I declare under penalty of perjury under the laws of the State of Califomia that the

7 foregoing is true and conrect. Respectfully submitted by,

8
9
DATED
••^P//o . ^
10 Barrieftrfro se Plaintiff
11 H Wan-ego Way
12 Sacramento, CA, 95826
13 Ph: (415) 846-7170
14 Fax: (866) 90»-2252

election campaign shall be given preference In hearing in the courts of appeal, and in the
Supreme Court when transrenred thereto. All these cases shall be placed on the calendar In the
order of their date of issue, next after cases in which the people of the state are parties.

Complaint Page 8 of 8
c^ft

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO


ORDER DETERMINING DISPOSITION OF EX PARTE APPLICATION

Case Name Case Number

"Qa^ndt v&.Dunn iO-cccn-T+is


Type of Application By Application Date
QSTnn ftvn^iftr> Oar reJitft^ TT JUM - 2 2010
tMames of Appeanng Party Representing

Antim^ &bnm
tela \Q •p3>arneM- JSL
The Court, having considered the above entitled ex parte application
with appearance as noted above, rules as follows:
J-
[ywithout a hearing LJ after hearing

D The applicaton is granted.

[3'The application is denied on the merits of the papers presented to the Court

Q The application is denied without prejudice to its resubmission for the following reason(s):

• The moving party may not proceed except by noticed motion

n other

n Counsel for the. is ordered to prepare fonnal order.

JUN - 2 ZGIO
X.
DATE

CI-1 so (10/2006) ORIGINAL-CASE FILE YELLOW-SUBMrTTING PARTY


2^
PINK-OFFICE COPY
mm URT
The ex parte application for an Order Shortening Time is denied. Plaintiff has not
demonstrated that she has acted diligently in seeking the Order Shortening Time. No
explanation is given for why plaintiff waited several months after the candidate filed his
requisite papers before seekmg an OST for an Order to Show Cause Re; Injunctive
Relief

To the extent an emergency situation exists, moving party created it by a lack of


diligence Relief is properly denied in such circumstances. See Cooksey v. Alexakis
(2004) 123 Cal.App 4'^ 246, 257 (motion to continue summary judgment hearing
properly denied when moving party has not acted diligently)

Moreover, plamtiff failed to comply with CRC 3.1201 and CRC 3.1204, in that
there is no declaration regarding notice ofthis ex parte ^plication to all parties.

Due to the lack of a proper showing, the Court will not grant the relief requested.

The Court declines to entertain oral argument on this ex parte request. There is no
right to oral argument in an ex parte proceeding, the judge may properly decide the
matter on the papers presented See Wilhurn v Oakland Hospital (1989) 213
Cal.App 3d 1107, 1111. As Local Rule 2.04 (A) states, "The adequacy ofthe application
for temporary relief will be determined on the papers submitted. See also. Local Rule
3.14.

u
1

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27
EXHIBIT 4
28

EX PARTE REQUEST FOR RECONSIDERATION OF HEARING


— - -^ . ^

1 Pamela Bamett, Pro Se Plaintiff


2541 Warrego Way - ;» „? p", ?: PO
2 Sacramento, CA, 95826
3
Telephone: (415)846-7170 - ;;.i rrvCCiS? ^ ' '
Pb_realestafe@yahoo.com
4

5 PAMELA BARNETT, IN PRO SE


6

6 SUPERIOR COURT OF THE STATE OF CALIFORNIA


9
FOR THE COUNTY OF SACRAMENTO
10

11

12

13 Pamela Bamett. ) Case No.: 34-2010-00077415

14 a, . ,.^ ) DECLARATION OF EVIDENCE


Plaintrff. ( RECEIVED AFTER COMPLAINT FIUNG
15
vs. )
16 j Date: June 2, 2010
Damon Jen-ell Dunn (aka Damon Dunn); J^^^: mOO am
17
Debra Bowen individually and officially as j Judge: Unknown
18 The Califomia Secretary of State; Edmund) Action Filed: May 10, 2010
G. Brown Jr. (aka Jeny Brown) Officially ) Trial Date: Not set
19 as The California Attomey General and )
individually; and John Doe(s) and Jane (
20
Does, j
21 Defendants )
22

23 TO THE COURT:
24 I, PAMELA BARNETT, submit the following evidence:
25 1. Letter Response from Secretary of Sfate Fraud Unit that asserts their

26
unwillingness to act on items within my complaint.
2. Damon Dunn's Declaration of Candidacy which shows another act of fraud.
27

28

- 1 -
DECLARATION OF EVIDENCE RECEIVED AFTER COMPLAINT FILING
1 3. Damon Dunn article from the Hermosa Beach Patch that proves personal service
2 and Dunn's kno\Medge of his Califbmia voter registration fraud crime.

3
4. Certified letter of Jean Marie Atkins, Director of Voter Administration. Jacksonville.
Florida.
4

5
I declare under penalty of perjury under the laws of the Sfate of Califomia that the
6
foregoing is tme and correct and that this Declaration was executed June 2.2010, at
7
Sacramento, Califomia.
8

10

11 ela Bamett, Plaintiff, Pro Se

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

- 2 -
DECLARATION OF EVIDENCE RECEIVED AFTER COMPLAINT FIUNG
DEBRA B O W E N | SECRETARY OF STATE
STATE OF CALIFORNIA I ELECTIONS
150011thStreet,5thfloorj Sacramento, CA95814ITel (916) 657-2166IFax (916)653-3214I www.sos ca gov

May 12, 2010

Pamela Barnett
2541 Warrego Way
Sacramento, CA 95826

Dear Ms. Bamett

We are responding to your recent faxed complaint questioning the eligibility of Secretary
of State candidate Damon Dunn to be on the ballot.

You questioned Mr. Dunn's eligibility to run based on the conditions set forth in
Elections Code 8001(a)(2). This section requires a candidate to not have been
registered with any party except the one he/she seeks to be nominated from, within the
preceding 12 months. The conflicting party evidence you cited was that Mr Dunn was
previously registered as a Democrat in the state of Florida. However, we contacted the
office of the Duval County Supervisor of Elections and they reported that Mr. Dunn
registered as a Democrat in 1999, but never voted His Florida registration was
subsequentiy cancelled in June 2005. Therefore, in March 2009, when Mr. Dunn
registered as a Republican, he was not currently registered with any state and not
affiliated with any party, in compliance with EC 8001(a)(2).

You also questioned Mr. Dunn's failure to list his previous Florida registration on his
March 2009 California voter registration While Elections Code 2150 (a)(10) requires
those registering to vote to disclose any prior registration, there are no criminal
sanctions for non-compliance If you have evidence that this omission was intentional,
please fonward to our office.

Thank you for bringing this matter to our attention

Sincerely,

Election Fraud Investigation Unit

"Eii!,uririg tlu: integnty of Cahfomia's election process "


Hermosa Beach Patch, CA - Accusations tnu . Tea Party Meetit® httpiZ/hermosabeav xh.com'articles/accusations-interrupt-tea-parQ'-me...

HermosaBeachPatch
ELECTIONS

Accusations Interrupt Tea Party Meeting


Secretary of state candidate Orty TaAz amves uninvited at a Hermosa Beach gattErmg and accuses opponent Damon Dunn ot water fraud

By Jonattian Oyama May 19,2010

An uninvited Califoraia secretaiy of state candidate mteirupted a Tea Party meeting in Hennosa Beach on
Tuesday evening with accusations that her opponent oommitted voter fraud.

The meeting of the South Bay Tea Party (bttp-//www.soutbb!)yteapQrty com/) was hdd at the Church of Chnst
(http://bennosal)ea£h.patchi:oni/listuig3/chiu'cb-of-chiist-at-hennosa-beach!) on A\iatiou BoulevanL

The candidate, Oriy Taitz, daimed that ber opponent. Republican Damon Dunn
(http7/wvn>;damonduiin.coui/), was ineligible to mn because he had tried to alter his voting iccoid. South Bay
Tea Party leader Gary Aven asked Taitz to leave, but she refused.

While Dunn was speaking to the atiwd, a worker for Taitz interrupted him and handed him what she said was a
"summons to court "

Tbe paper outhned a lawsuit filed by Tailz snpporter I^mela Bamett that accnsed Dunn of beiog inehgible
because he bad asked Florida election officials ra July 2009 to remove from his voting record his 1999
registration as a DemotraL

Aven asked tbe civwd how many people would like Tsitz to stav quiet. Many m tbe audience shouted their agreement

"Yon're asked by tbe ccax of tbe party to idease be quiet,* Aven said. "Orly, you are disturbing the peace. And what kind of persou are you? You were not invited. You
didnt tell me you were conung, and yet you want to interrupt my rneeting.'

In response to Taitz's accusations, Dunn said he bad never asked Flonda officials to delete his voting record. He said they deleted bis recoid because Florida law
directs officials to delete the records of peo]de who have not voted in two consecutive federal elections in the state.

Dunn also said tbat Taitz had revealed his bome address and pbone nnmber in a YouT\ibe video for ber carapaign. Nonetheless, be said be was happy to have the
chance to address tfae ad's aoLUsations

T'm actuaUy OK with this, quite honestly,' Dunn said. "I respect that she's here, because I beb'eve that everyone has a oonstitutioual rig^t to run. 1 believe that it's in
God's will that I bave tbe opportunity to represent, for the Republican Party, the state of Cahfornia."

Taitz, an Orange County resident, wasfinedm 2009 by VS. Distiict Court Judge Clay Land forfihngnumerous complaints and motions against President Obama
vnthout a reasonable basis, and for using the courts as a "platform for a political agenda disconnected from any legitiiiiate cause of action." Tailz has also tried to
promote theories that Obama was hom in Kenya and does not hold a U& birth certificate.

Taitz's reputation led Tea Party members to uninvite her from a recent Tax Day Tea Party rally in Pleasanton, CA.

IN TMS ARTICLE
• . . ' ^ Church of Ctnisl at Hennosa Beach
I j p t 1063 Aviation B M

COMMENTS (5)

bordorravon
1 23ain on Thimlay. Ittay 20. 2010
Orly Taftx, may have disturbed the TEA Party meeting, but at least she is the sort of non-pohtically correct person the TEA Party strives for. She's bold, she
steps on toes, but she does the job
Loo In to reply

LawyarwilhareaMegive
4 OSfini cn Itusctey May 20^ 2010
Does what job? Lose every case she's ever filed^ Screw up herfilingpapers nu merous times for tbe office of Secretary of State of California^ Successfiilly
convince the vast majority of the American public that the Bothers and Baggers aie stark raving lunatics? Attract the ubiquitous borderraven to every aitide
that mentions Taitz so be cau praise ber firom the oompnter in his parents' basement?
Log In t o reply

runny haha
4 SSpm on-nureday. «tey 20,2[>10

1 of2 6/1/2010 10.28 PM


Hennosa Beach Patch, CA - Accisations iitei. ^^ Tea Party Meeting fattp://hBnnosabeac Acon^articles/acciBalions-intem^l-tea-par^-ine.,

OMGosh! Tlifa is hilaiions. Does Orly really think that people respect this kind of behavior from poB ticians??? Orly is getting pathetically desperate AGA0^
This IS just petty, childish and ridiculous behavior on her part
Orly never had a chance m this election; she has made it painfiilly obvious tbat she hasn't got a clue about tbe actual responsitnlities and duties ofa SoS.
You know your coo-coo when tfae birthers thmk your nuts. And thefairthersdo Ihmk lh at Orty is nuts
I would have loved to see the look oo hia face when this occurred. "Aven asked tfae crowd how many peopie vrould like Taitz to stay qmet. Many in the audience
shouted their agreement"
Orly IS aflamingNarcissist Seriousty> she has Natdssistic personality Disorder And she is a ndiculous human being. What an embarrassment to dentists.
lawyers and real estate agents every where!
Los in to roply

Wayne Abott
6 4apm on Thiratay. luby 20, 2010
To coin a phrase, "She gnt da aaiy eyes!' Seriously, dick on the 'zoom' feature.
I think her latest ploy here cleaifyiDustjates why Taitz was always a frmge player and will never, e^^er nse above those ranks By this timeshe has tobe
embarrassing even her most ardent supporters/coltists, and those who dioose to still hang with her probably believe little green spacemen are being stored
cryogenieally at RoswelL llieie really onines a point wherp you grow weary of laughing and just vnsh someone would throw a net over her and get her the
bio-chemical hdp she so desperately needs-.
Log In to re;)ly

Piutodog
7 Z3|m on ttimday Msy 20< 2010
Yoo boo!'! Oriy? P s ^ , Orly, it's time for yoor meds, giriftiend!
Log in to reiyy

,- -^^ ......Sf't;™

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2 Of 2 6/1/2010 10:28 PM
COPY CERTIFICATION BY DOCUMENT CUSTODIAN

J hereby declare that the attactied reproduction of

th3»alplian<«Oi1giMDooRia4 v"

IS a true, correct, and comfriete photocopy of a document


in my possession or corrtrgU-
MATT STOEVE J,
COMM...1780936 n • SJatolufa of CiBilndlan of Oiiginal OoamiiBt J ~
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! provedtome on Ite basis o£^«sftct««y evidfsnce to be the pen O«I(B> i«*o appeared bcf^

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Signatare

OPTIONAL
Though the kifonnation b ^ o w Is not rgqwrBd b y law, tt m e / p r o v e valuable to persons retytng on the document anti c o u u praveiU
fraudul&it lemaval a n d reatlactunant of this fomt to another document.

Further Description of Attached Document


Title or Type of Document: u n t PnotJi F L . a A , t . n A . - a f ^ . e C B F n t s x ^ ^ f a u m e ^ of^ €^*rcnatS^

Document Date: h - f t - i ^ t l , ^ ^^16 Number of Pages: L

SignerCs) or Issuing Agency: .Tyftr^u t^^t*^ ^r-tcJ-J

Capacity Claimed by Custodian

e IB«e Nadonal lilQiaiy Aasociiiliai • aaaa Reniinai A m , PO. Box 718} • Canoga pBik, CASl30S-riS4 e n d . No SBOS RaoRter. CBO Ibl-PniD t.6n047MBZ7
OFFICE OF THE SUPERVISOR OF ELECTIONS

JERRY HOLLAND '0^ ^ ^ ^ MONROE STREET


SUPERVlSCai OF ELECTIONS JACXSONVlUf. HORIDA J2202
CttTICT (904)650-1414 F.AX (<»4) 6J0 2910
CEU. 0W> 3I8.«7? E-MAIL- JHOLMNMOOl NET

Apnl 13,2010

Deat Sir ot Madam-

I am wnting to documeat my correspondence with Mr. Damon Dunn. On July 10, 2009 Mi.
Dunn contacted out office via telephone aad asked for his ineligible voter tegisttatton record
to be removed ftom the Duval County database. I contacted the Division of ElecUons later
that day to inquire if this was possible and the Legal Depattmeat for the Division informed
me that the record could not be deleted frotn the database because voter r^;istration is
permanent record.

I then mailed a lettei to Mr. Dunn informing him of my findings. I have noc had addittonal
correspondence with Mr. Dunn since this incident

Thankyou,

Jean Mane Atkins


Director of Voter Administration
OFFICIAL FH.1N6 fOUU
DECLARATION O F CANDIDACY
NEAL KELLEY
REGISTRAR OFJ (Elections Code Sections 200, 8020.8O40)

'10 .WIO 5J0:to


REGISTRAR OF VcmEBS t»E ONLY

. - CONTEST ID: i 0 4 2

1 C'LN' ' • L--M.'r.


I hereby declare myself a Republican Party candidate for nomination to the ofiRce of Secretary of
State, to be voted for at the Statewide Primary Election to be held June 8, 2010 and declare the
following to be true:
My name is: ft vv>ftr\ 03 cx \AV>

I request my name and occupational ballot designation to appear on the ballot as follows:

I CA v ^ r t r > A J: CA v \ <rv
Print Your Name for U s e o n the Ballot
Cairdidate inSialS
rf preferring no
designabon-

Pnnt Occupational Ballol Designation Requested J


Note: A ballot designation is optional If one is requested a txjmpleted BALLOT DESIGNATION WORKSHEFT musi be submitted. If
no ballot designahon is requested, vwite in the word ' N O N E ' and initial in the box. (Elections Code §§ 13107,13107 3)

3^esidenceAddress: S l 3>( M'Y.Ug.1 S>Ov^ U^r^^ i 7 o % u)c-bT


(Required)
aiy ZipCpdr

Q Business Address" J J ^

aty ZfiCodc

n Mailing Address: 5^c xAA ^ ^ L 3 £i_ko J t .

ay St*: ZoCode

J^ Telephone: (4':^1) .^Hy q j ° j . -(__)- S ^ » w C-


, J . - ArsaCoOe Day Area Code Cvcnrng

-=!t:
FAX: ( L E-Mail: o./^wiov'v ^ O ^^ \UMWo AQOA.Qt . -< v \ V V ' < 0 > V N
Ar=aCodc

Official Website: L«^ t^) u ) . <^ ^WAQ/X <:iLiwv\ . C o VSAv

NOT^ii^jJ^cS^etary of State will publish one of the above addresses in the certified list of candidates
and on the SOff website. Please check the appropriate box above to indicate which address you wish
to use for this purpose. If no box is selected, the mailing address will be used.
I meet the statutory and constitutional qualifications for this office (including bul not limiled to
citizenshtp, residency and party afRiiafion, if required). J am at present an incumbent of the following
public office (if any):

IMPORTANT: BACK SIDE OF PAGE MUST BE COMPLETED


ilO/OLO d I S L O e ZZ 50 eZOZ/ll/LO
Vly 1 1 / i.'.ii.o uJ £.0
o «v IOO r WOI V I I

If nominated I will accept the nomination/office and not withdraw.

I dedare under penalty of perim^jjnder the laws QfUie State of California that the foregoing is tme and correct.

s j toj Zo
Date Signature of Candidate
State of California } ss.
C:ounty of Orange )
Subscnbed and swom to before me this t i f ^ day of ^^WXx _. 2010.

Notary Public (or other official)

Examined and certified by me this l(y^ day of h ^ ^ , 2010.

NEAL KELLEY. Registrar of Voters By Deputy

WARNiNO Evety D c r s n R t i l g onbdaffcfacaniSdaieis ^jSy of a msdemeanor «ina o t r n f r v t i f t ^ ^ fte u i w proper ttme snd m me proper iteoe any dedisistton ctcsncMscy m his/her
pasessnn utich i3 ei>titlcd« b« i l o f undsr t v ptoMuons of the Bccoons Code (EkicSdltt Code Sedicn leoOZ)

OATH OF OFFICE
I, OAMON DUNN, do solemnly swear (or affinn) that I will support and defend the Constitution of the United States and
the Constitution of the State of Califomia against ail enemies, foreign and domestc; fhat I will bear true faith and
allegiance to the Constitution of the United States and the Constitution of the State of Califbmia; that 1 take this obligation
freely, without any mental reservation or purpose oLgyasion; and fliaU will well and faittifully discharge the duties upon
which I am about to enter.

State of Califomia } ss. Signature of Candidate


Counfy oi Orange }

Subscribed and swom to before me this /' Q^^ day of f^^^ ^ . 2010.

JL
-z>^ Notary Public (or other official)

Examined and certifled by me this ^ ^ ^ day of ^ ^ ^ , 2010.

NEAL KELLEY, Registrar of Voters By_ Deputy

Certificate as t o Candidate's Political Party Affiliation


(Electiom Code Sccum 8001)

Slate of Calrfornia }
County of Orange } 5S.

\ hereby certify that (1) at the time of presentation of this declaration and continuously for
not less than three months immediately prior thereto, or for as long as he/she has been
eligible to vote io the state, the atx>ve-named candidate is shown by his/her affidavit of
regisiration, executed on J-f'^^cO? . to be affiliated with the political party the
nomination of which he/she seeks, and (2) the candidate has not been registered as
affiliated with any other political party for the twelve-month period immediately preceding
the filing of fhis declaration ^<Sii^s^
Dated this (D^ day of M^^L, . 2010.

Pnor Regtstrabon NEAL KELLEY.


Party A/fikation Dales r- -V *-* •or •-* V "
Registrar of Voters

By. /^-^P^^l
JM. -"-
Deputy
ileciarsiin,') n l Candirfary - PgrSsan 20iO

A'l cocie secho.-' reterenctrj are U/ i')e Caulbmia Elections Code iiniess stated j i h e r w i t e
1 Pamela Barnett, Pro Se Plaintiff
2541 Warrego Way
2 Sacramento, CA, 95826
Telephone: (415)846-7170
3

4
PAMELA BARNETT, IN PRO SE
5

7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8

9 FOR THE COUNTY OF SACRAMENTO

10

11
Pamela Barnett, Case No.: 34-2010-00077415
12
DECLARATION OF EX PARTE NOTICE
13 Plaintiff, OF HEARING FOR EMERGENCY
RECONSIDERATION OF HEARING TO
14 ADJUDICATE WHETHER VOTES
vs.
SHOULD BE COUNTED FOR DAMON
15 DUNN JUNES, 2010
Damon Jerrell Dunn (aka Damon Dunn);
16 Debra Bowen individually and officially as
The California Secretary of State; Edmund' Date Junes, 2010
17 G. Brown Jr. (aka Jerry Brown) Officially Time: 1:45 p.m.
as The California Attorney General and Dept: 54
18 Judge: Hon. Shelleyanne W.L. Chang
individually, and John Doe(s) and Jane
19 Does, ActionFiled: May 14, 2010
Defendants Trial Date: Not set
20

21

22 TO THE COURT-
23 I, PAMELA BARNETT, submit that all Defendants were noticed ofthe Ex Parte

24
Hearing. See attached.

25

26
, Pro Se
27

28

DECLARATION OF EXPARTE NOTICE


Print http./Zus.mgl.mail yahoo.com/dc/launch?.gx=l&.rand=5tlts5vjq6t9n

From: P. B. (pb_realestate@yahoo.com)
To: bhildreth@bmhlaw.com; anthony.obrien@doj.ca.gov;
Date: Mon, June 7, 2010 3:06:31 PM
Cc:
Subject: Ex Parte Application

final file for ex parte tomorrow - hearing at 1:45 Dept. 54.

Regards,
Pamela Barnett
415.846.7170

P. B.

lofl , 6/7/2010 3:20 PM


Print http://us.mgl mail.yahoo.coni/dc/launch?gx=l&rand=5tlts5vjq6t9n

From: P. B. (pb_realestate@yahoo.com)
To: bhildreth@bmhlaw.com;
Date: Mon, June 7, 2010 2:50:14 PM
Cc:
Subject: Ex Parte Notice and Documents Re: Bamett v. Dunn et al

sorry spelled your name wrong first time.

— FonA/arded Message —
From: P. B. <pb_realestate@yahoo.com>
To: anthony.obrien@doj.ca.gov; bhildrith@bmhlaw.com
Sent: Mon, June 7, 2010 2:16:13 PM
Subject: Ex Parte Notice and Documents Re: Bamett v. Dunn et al

Please see review attached Ex Parte Notice for hearing tomorrow June 8, 2010 at
1:45 at Dept. 54 at California Superior Court Sacramento.

Pamela Barnett
415.846.7170

P. B.

lofl 6/7/2010 3:21 PM

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