30 a a oe: ua 18 16 uv 18 19 20 a 22 23 aa 28 26 28 ra SUPERIOR COURT OF SALEO™ DR. ORLY TAITZ ESQ, PRO SE ces usnctentres 29839 SANTA TA PRWY 28 2010 RANCHO SANTA MARGARITA CA 92688 JUN Ph 949-683-5411 fax 949-766-7603 7 Orly. taitz@gmail.com annem congas CALIFORNIA SUPERIOR COURT BY": PARBONS ORANGE COUNTY CENTRAL JUSTICE CENTER HONORABLE JEFFREY GLASS PRESIDING NO.: 30-2010 ORLY TAITZ, } 038 00381664 5 parte PLAINTIFF, NOTICE” OF MOTION a MOTION FOR EXPEDITED REPLICATION FOR STAY DAMON DUNN, OF COUNT AND CERTIFICATION OF VOTES DEFENDANT ) FOR DAMON DUNN PENDING RESOLUTION OF TRIAL PRELIMINARY INJUNCTION Notice of Motion Hearing. All parties are notified that an ex parte motion hearing will be held on Thursday, July 1, at 9am, at the Central Justice Center,700 Civic Center Dr, Santa Ana CA MOTION On June 17, 2010, Plaintiff Dr. Orly Taitz,£SQ hereinafter Taitz has filed a complaint for Elections Contest §161661A as well as complaint for £lections Fraud, Voter Registration Fraud, Common Law Fraud, Declaratory Relief and Injunctive relief against Defendant Damon Dunn, seeking Declaratory Relief deeming defendant Dunn ineligible to serve as a candidate for the position of California Secretary of state due to elections fraud, voter fraud, elections registration fraud, nomination vaitz v Duna Election Contest. Notice of motion and Motion of Expedited handling of the case = 1ua as 16 uv 18 as 20 a 22 23 24 25 26 28 fraud. Defendant was served with the complaint at his residence at 3131 Michelson center 708 West, Irvine, CA 92612. Defendant filed an answer on June 28, 2010. Originally the case was heard in Limited division of Harbor Justice Center. On 06.24.10 Honorable Corey Cramin has issued an Order to Show Cause on the Motion by the Plaintif€ for the defendant to show, why a Stay of the certification of votes should not be issued, pending expedited handling of the case and a hearing was continued to 06.28.10. Due to the limitations of jurisdiction at Harbor Center, Laguna Hills Division, Judge Cramin has transferred the case and the order to show cause to Honorable Jeffrey Glass, central Justice Center. As the defendant has filed an answer on 06.28.10. the Plaintiff has filed At issue memorandum for trial setting. Currently Plaintiff is seeking an Order of Stay of certification of votes for Damon Dunn, pending resolution of the issues at trial to be scheduled expeditiously. According to CAL CCP code §44 elections contest should be given preference in CA Courts. According to CEC $8800 “no candidate whose declaration of candidacy has been filed for any primary election may withdraw as a candidate at the primary election. Must be removed by Judicial order”. Taitz and Dunn were candidates in June 8, 2010 primary election for CA secretary of State. Canvassing ends on July 6, 2010. Due to time restrains Plaintiff is seeking expedited scheduling of trial. In 2004 similar case of McKinney v City of San Diego, 21 Cal. Rptr.3d 773 (2004) 124 app.4th the governing authority in this case Fourth District Court of Appeals stayed certification of election results pending resolution of issues at trial. ‘Taitz v dunn Election Contast. Notice of motion and Motion of Expedited handling of the case ~ 210 a 2 e 4 ss a ” ae as Similarly Plaintiff is seeking a stay of certification of the results of the CA Republican primary Contest between Taitz-Plaintiff and Dunn-Defendant, pending resolution of underlying issues of fraud to be resolved at trial. In Gilmore v Jordan Ca. 2d347 (1934) candidacy on the ballot was invalidated due to fraud committed. This case rested on a prior case of Power v Jordan. In case at hand we have an issue of voter registration fraud, voter fraud, elections fraud and nomination fraud committed. Affidavit from a TV reporter William Wagener states that as part of his TV interview, he video taped several sponsors of Dunn nomination, who are stating that they never signed such nomination and it is fraudulent. Video recording of the interview is readily available on the Internet, you Tube channel William Wagener “Nomination Fraud". The video will be shown to the jury at trial, in case elderly "sponsors' of the nomination are not available. Majority of the nominations for Damon Dunn were obtained at the retirement community of Leisure World, where many "sponsors" have hearing problems, vision problems, Alzheimers and so on. There is a serious concern, that many more signatures were obtained from individuals who didn't really know what they were signing, and that is assuming, that they actually signed the nomination in the first place. Complaint also contains Dunn's voter registration, where he was required to provide his prior voter registration, with indication, of the state, where he was registered and party Taitz v Dunn Election Contest. Netice of motion and Motion of Expedited handling of the case - 312 eo: 1 a5 a6 0 18 » 20 a 22 2 2 25 26 28 affiliation. Dunn left it blank. Exhibits in the complaint contain Public Records.com printout showing that Dunn registered in two other states:Tx and FL, where he registered as a Democrat. Moreover, the complaint provides a letter from Jean Marie Adkins, director of voter services from Duval County FL, stating that Dunn contacted them on July 10, 2009 and demanded to have his voter registration records deleted from the database. Even if one were to believe that Dunn didn't remember registering to vote in 2 other states when he registered to vote in CA in March of 2009, above mentioned letter from Duval County FL shows that he knew about his prior registration and simply defrauded Taitz and voters of CA by not including this information. Later in March of 2010 Dunn took and Oath of Office, as an official candidate on the ballot, running in Republican primary in CA, yet he never disclosed the fact that he registered as a Democrat in two other states and continued perpetrating fraud on Taitz and unsuspecting voters. As a result of fraud committed by Dunn Taitz suffered damages of over $40,000 spent in Primary elections campaign against Dunn. As such Dunn has violated Statues 18500, 18501, 18502, 18002 and 18203. As such Taitz is seeking stay and preliminary injunction in certification of any and all votes for Dunn and will be seeking a permanent injunction at trial, as well as compensation for damages and punitive damages to be assessed at trial. Prayer for relic ‘aite v Dunn Election Contest. Notice of motion and Motion of Expedited handling of the case - 410 u 2 a3 u 15 16 a0 18 1s 20 a 2 23 24 25 26 27 28 CA Civ Pro $44 provides for a priority handling of elections complaints. Complaint and answer to the complaint were filed. At issue memorandum for trial setting was filed with the court. 1. Expedited Trial 2. Due to the issue of alleged fraud committed in voter xegistration and nomination of the defendant Damon Dunn, which is at issue and to be resolved at trial, and in order to [preserve status quo, this Court orders Stay of registration of votes by the County registrars for Damon Dunn pending resolution of the trial. 3. Preliminary injunction directing the Registrars of voters not to count and not to certify votes for Damon Dunn, Candidate for Republican nomination for Secretary of State of CA due to alleged violations of CEC 18203, 18500, 18501, 18502, 18002 Orly Taitz 29839 Santa Margarital pkwy, ste 100, RSM, CA 9268 Certificate of service I, Orly Taitz, attest that a true and correct copy of the above notice and motion was served on the defendant on 06.30.10. by e-mail to the attorney for the Defer , Me. Charles Bell, ESQ a Orly af aaa 29839 Santa Margarita Pkwy Rancho Santa Margarita CA 92688, ‘Taitz v Dunn Election Contest. Notice of motion and Motion of Expedited handling of the case - §