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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF KINGS IndexNo.:


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#&a-2(3/1
X
Christopher-Earl: Strunk, in esse
Plaint* Filed: March 22,2011

NEW YORK STATE BOARD OF ELECTIONS; JAMES A. VERIFIED


WALSH / Co-Chair, DOUGLAS A. KELLNER / Co-Chair,
EVELYN J. AQUILA / Commissioner, GREGORY P. COMPLAINT
PETERSON / Commissioner, Deputy Director TODD D.
VALENTINE, Deputy Director STANLEY ZALEN;
ANDREW CUOMO, ERIC SCHNEIDERMAN, THOMAS P.
DINAPOLI, RUTH NO EM^ COLON, in their Official and trial)
(J~rg
individual capacity; Fr. JOSEPH A. O'HARE, S.J.;
-
Fr. JOSEPH P. PARKES, S.J.; FREDERICK A.O. SCHWARZ, JR.;
PETER G. PETERSEN, ZBIGNIEW KAIMIERZ BRZEZINSKI;
MARK BRZEZINSKI; JOSEPH R. BIDEN, JR.; SOEBARKAH
(a.k.a. Barry Soetoro; a.k.a. Barack Hussein Obama 11,
a.k.a. Steve Dunham); NANCY PELOSI; DEMOCRATIC
STATE COMMITTEE OF THE STATE OF NEW YORK;
STATE COMMIlTEE OF THE WORKING FAMILIES
PARTY OF NEW YORK STATE; ROGER CALERO;
THE SOCIALIST WORKERS PARTY; IAN J. BRZEZINSKI;
JOHN SIDNEY MCCAIN 111; JOHN A. BOEHNER;
THE NEW YORK STATE REPUBLICAN STATE COMMITTEE;
THE NEW YORK STATE COMMITTEE OF THE
IND~PENDENCEPARTY; STATE COMMITTEE OF
THE CONSERVATIVE PARTY OF NEW YORK STATE; ,

PENNY S. PRITZKER; GEORGE SOROS; O B M FOR


AMERICA; OBAMA K7CTORYFUh.IT); MCCATN WCTORY
2008; MCCXTN-PALIN WCTORY 2008;; John and Jane -Does;
and XYZ Entities.

Defendants.

Plaintiff, Christopher-Earl: Strunk in esse, a s and for the Complaint filed with jurisdiction

of New York State Election Law Article 5 16-100 over Article 12 related to the November 4,

2008 General Election inter alia equity relief and damages caused by a n ongoing schem&to

defraud with CPLR § 213 Actions to be commenced within six years, upon information and

belief and a t all times hereinafter mentioned, respectfully allege of Defendants a s follows:

Verified Complaint Page 1of 45


FIRST CAUSE OF ACTION

(Breach of State Constitutional fiduciary duty as against all Public Officer Defendants)

1. Plaintiff Christopher-Earl: Strunk, in esse (“Plaintiff” or “voter”), is a natural born

Citizen resident in New York who was and is a qualified voter registered to vote in the 2008

election cycle and participate in the November 4, 2008 General Election in the State of New

York, and whose principal place for service is located at 593 Vanderbilt Avenue #281,

Brooklyn, New York 11238.

2. That this complaint is fairly traceable to the events and actions leading up to the Party

primaries during the 2008 election cycle for the ballot access of the Presidential slates at

the November 4, 2008 General Election as complained of in the related election law case

Strunk v. Paterson et al. NYS Supreme Court in the County Kings with Index No.: 29642-

08 before the Honorable Justice David I. Schmidt of Part 1 as an election law matter.

3. That Defendant NEW YORK STATE BOARD OF ELECTIONS, (Defendant NYS BOE)

with four commissioners two appointed from each major state party Defendant JAMES A.

WALSH / Co-Chair, Defendant DOUGLAS A. KELLNER / Co-Chair, Defendant EVELYN

J. AQUILA / Commissioner, Defendant GREGORY P. PETERSON / Commissioner, and

two deputy directors of elections Deputy Director Defendant TODD D. VALENTINE,

Deputy Director Defendant STANLEY ZALEN, are all located at the New York State Board

of Elections 40 Steuben Street Albany, NY 12207; and

4. Defendant NYS BOE and its agents have authority over their agents at the local boards

of election both for ballot access and the certification of the Presidential Elector Candidates

slates and committees for the names Barack Hussein Obama (BHO, SOEBARKAH), John

M. McCain III (McCain) and Roger Calero (Calero) hereinafter known as “Defendant

Presidential Candidate(s)” with the November 4 2008 General Election results published.

5. Based upon information and belief the Presidential Elector Candidate Defendants as a

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class represented by Andrew Cuomo having replaced David Paterson as Governor on the

Democratic side and Republican Majority leader Dean Skelos representing the McCain

Electors with notice to then secretary of state LORRAINE A. CORTEZ-VAZQUEZ

appointed by Governor Paterson and Spitzer, now replaced by RUTH NOEMÍ COLÓN

New York State Acting Secretary of State; that according to the Help America to Vote Act of

2002 (HAVA) section 213 (a) (1) (A) are in their Official capacity are both Federal and State

officers who serve as an unpaid employee of the United States Election Assistance

Commission (EAC), and represent the Class of the Calero Electors along with those of the

Cuomo and Skelos classes; and that the Governor Cuomo appointee, RUTH NOEMÍ

COLÓN is located at the Department of State One Commerce Plaza 99 Washington Ave,

Albany, NY 12231-0001).

6. That the Secretary of State and Attorney General Eric Schneiderman are responsible

for the enforcement of NYS Civil Rights Law Chapter 6 Article 5-A Sections 53 through 57

Membership Corporations and Unincorporated Associations., which is not done in regards to

the exclusive membership of Jesuits having an exclusive constitution and oath of induction

within the New York Province for the Society of Jesus.

7. Defendant ERIC SCHNEIDERMAN is sued in his capacity of Attorney General of New

York state and individually with place of business located at The Office of the Attorney

General The Capitol Albany, New York 12224, was duly elected at the 2010 General

Election replaced Andrew Cuomo then Attorney General during the 2008 Election cycle.

8. The Defendants NYS BOE their agents John and Jane Does and with due notice

LORRAINE A. CORTEZ-VAZQUEZ represent the class of 2008 presidential electors and

their agents having misapplied and mis-administered their public officer fiduciary duties

under NYS BOE regulation by failure to obtain and ascertain proof that each Defendant

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Presidential Candidate is a natural-born Citizen (NBC), that otherwise is contrary to State

Law, regulations and the United States Constitution Article 2 Section 1 Clause 5:

“No Person except a natural born Citizen, or a Citizen of the United States, at the time
of the Adoption of this Constitution, shall be eligible to the Office of President; neither
shall any Person be eligible to that Office who shall not have attained to the Age of
thirty five Years, and been fourteen Years a Resident within the United States.”

9. Based upon information and belief the State Defendants, Defendant Presidential

Candidates, various Defendant Campaign Committees and their agents have not presented

a certified copy of the “long-form” birth certificate of the Defendant Presidential Candidates

for ballot access to the New York November 4, 2008 General Election / 2008 election cycle.

10. That based upon information and belief the NYS BOE has not maintained the

consistency of Presidential Candidate Certificate documents used for ballot access by mal-

administration of the law and regulations.

11. There has never legally been an Article II Executive who has ever been a native

born, naturalized citizen or a non-citizen as it is against the mandate of the U.S.

Constitution Article II Section 1 Clause 5 must be a Natural-born citizen to be eligible.

12. There has never legally been an Article II Executive who is a citizen of a foreign

nation and or has dual allegiance with a foreign nation.

13. That the Supreme Court of the United State opinion in McCreery's Lessee v

Somerville 22 US 354 (1824) explains the difference between a Natural-born and Native-

born U.S. Citizen as is to be applied with U.S. Constitution Article 2 Section 1 Clause 5.

14. That were the executive to be occupied by a foreign citizen would constitute an

invasion, coup-d-tat and trespass upon the sovereign citizen of New York a taking as of

right under the 10th Amendment become the basis for New York state and its People to

secede from the Union until such time the Union were made whole and laws enforced again.

15. Those Defendant BOE and Presidential Electors having been duly served prior to

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the general election knew they have a duty to prevent any person who is not a natural born

citizen from ballot access in the state of New York when running for President and or Vice

President and have maliciously acted contrary to their fiduciary duty.

16. Those Officer Defendants and the NYS BOE have not fulfilled the due diligence

necessary to protect the voter(s) during the 2008 election cycle, are ultra vires, are

individually liable, and intend to repeat the outrageous injury in 2012.

17. That Defendant NYS BOE and its agents certified the Elector Defendants for each

Defendant Presidential Candidate to be on the ballot at the November 4, 2008 General

Election for the preference election of the New York Electoral College;

18. That Defendant NYS BOE and its agents and Officer Defendants Cuomo, DiNapoli,

Colon, Schneiderman do not intend to enforce the requirements of the U.S. Constitution

Article II Section 1 Clause 5 and New York State ballot access eligibility requirements for

prospective candidates for POTUS ballot access at the 2012 election cycle.

19. That under the New York State Constitution the State of New York Legislature has

a winner take all system of Electoral College with 31 votes for selection of President and

Vice President based upon 29 House seats and two (2) U.S. Senators at large during the

2008 election cycle and will be 29 votes for the 2012 election cycle.

20. That Defendant JOSEPH ROBINETTE "JOE" BIDEN, JR. (a.k.a. Joe Biden)

individually as a Jesuit Coadjutor member of the Council on Foreign Relations and a papal

knight with place of business located at his Office: c/o the White House 1600 Pennsylvania

Avenue NW Washington, DC 20500; 202-456-1111; was the Vice Presidential Candidate on

the ballot in the New York 2008 Election cycle and intends ballot status in the 2012 cycle.

21. Since shortly following Biden's withdrawal from the presidential race, Obama had

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been privately telling Biden (1) that he was interested in finding an important place for him

in a possible Obama administration. Biden declined Obama's first request to vet him for the

vice presidential slot, fearing the vice presidency would represent a loss in status and voice

from his senate position, but subsequently changed his mind. In a June 22, 2008, interview

on NBC's Meet the Press, Biden confirmed that, although he was not actively seeking a spot

on the ticket, he would accept the vice presidential nomination if offered. In early August,

Obama and Biden met in secret to discuss a possible vice-presidential relationship, and the

two hit it off well personally. On August 22, 2008, Barack Obama announced that Biden

would be his running mate. The New York Times reported that the strategy behind the

choice reflected a desire to fill out the ticket with someone who has foreign policy and

national security experience—and not to help the ticket win a swing state or to emphasize

Obama's "change" message. Other observers pointed out Biden's appeal to middle class and

blue-collar voters, as a Jesuit coadjutor for their “Social Justice” doctrine as well as his

willingness to aggressively challenge Republican nominee John McCain in a way that

Obama seemed uncomfortable doing at times.

22. Defendant Biden knew that Soebarkah is not eligible to run for president because he is

not a Natural-Born Citizen with a British Subject Father with a student visa, however in

furtherance of CFR foreign policy initiatives in the mid-east supported Soebarkah as a Muslim.

23. That Defendant SOEBARKAH (a.k.a Barry Soetoro, a.k.a. Birdie Dunham, a.k.a.

Barack Hussein Obama III, Defendant Democrat Presidential Candidate) individually

under the name Barack Hussein Obama is located in care of c/o The White House 1600

1
1. Joe Biden has received honorary degrees from the University of Scranton (1976), Saint
Joseph's University (1981),Widener University School of Law (2000), Emerson College (2003), his
alma mater the University of Delaware (2004), Suffolk University Law School (2005),and his other
alma mater Syracuse University (2009); and received the Chancellor Medal from his alma mater,
Syracuse University, in 1980. In 2005, he received the George Arents Pioneer Medal—Syracuse's
highest alumni award—"for excellence in public affairs."

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Pennsylvania Avenue, N.W. Washington, District of Columbia 20500, was a Presidential

Candidate on the ballot in the New York 2008 Election cycle and intends ballot status in

the 2012 cycle.

24. SOEBARKAH is a Madrasah trained radical Sunni Muslim by birth right according

to the Koran through his father Barack Hussein Obama Sr. (a Sunni Muslim), and that by

training and practice admitted during the speech to the Muslim Brotherhood in Cairo in

2009 – SOEBARKAH practices Shariah law, and is devoted to King Saud of Saudi Arabia

who based upon information paid for the Columbia and Harvard university expenses with

the full knowledge and blessing of Defendants: Peter G. Petersen; Zbigniew Brzezinski, his

sons Mark and Ian; Penny S. Pritzker; George Soros; Jesuits Fathers: Joseph P. O’Hare,

Joseph P. Parkes; Brennan Center Executive Frederick A.O. Schwarz, Jr.; Nancy Pelosi;

John Sidney McCain III; John A. Boehner; Hillary Clinton; Richard Durbin and others.

25. Defendant Soebarkah practices Al takia or the Islamist art of fooling the enemy and

professes to be a Christian when in fact a Muslim is a liar by training - never to be trusted.

26. Defendant SOEBARKAH admits his natural father at the time of his birth is a

citizen of the United Kingdom and as the British Nationality Act of 1948 governs dual

citizenship at birth; Soebarkah has dual allegiance at best by his own admission is not a

Natural-born citizen with the full knowledge and blessing of Defendants: Peter G. Petersen;

Zbigniew Brzezinski, his sons Mark and Ian; Penny S. Pritzker; George Soros; Jesuits

Fathers: Joseph P. O’Hare, Joseph P. Parkes; Brennan Center Executive Frederick A.O.

Schwarz, Jr.; Nancy Pelosi; John Sidney McCain III; John A. Boehner; and others.

27. That Rep. John Bingham, author of the 14th Amendment, Congressional Globe,

39th, 1st Sess., pg 1291 (March 9, 1866) stated:

“… every human being born within the jurisdiction of the United States of parents
not owing allegiance to any foreign sovereignty is, in the language of your
Constitution itself, a natural-born citizen.”

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28. That Defendant SOEBARKAH and or his agent(s) as part of the scheme to defraud

placed an image of a Hawaiian Certification of Live Birth (COLB) on the Internet, which in

Hawaii per se is issued for all birth's registered by the State of Hawaii whether the human

being is born there or not, and as a prima facia fact means the Hawaii issued COLB does

not prove "natural born" citizenship or birth in Hawaii, only a long form document would.

29. Whether Hawaii was a territory or a state, historically it issued a COLB certifying

that the named person was born alive no matter where that may have been as evidenced by

the COLB; and for instance Sun Yat-sen was born on 12 November 1866 to a Hakka family

in the village of Cuiheng, Xiangshan (later Zhongshan) county, Guangzhou prefecture,

Guangdong province (26 km or 16 miles north of Macau), in the Empire of the Great Qing of

China. At age thirteen, Sun went to live with his elder brother, Sun Mei, in Honolulu. Sun

Mei, who was fifteen years Sun Yat-sen senior, had immigrated to the Hawaiian Islands as

a laborer and had become a prosperous merchant. Sun Yat-sen studied at the Iolani School

where he learned English, mathematics and science. Originally unable to speak the English

language, Sun Yat-sen picked up the language so quickly that he received a prize for

outstanding achievement from King David Kalākaua. While at Iolani, he befriended Tong

Phong, who later founded the First Chinese- American Bank. After attending Iolani School,

from which he graduated in 1882, Sun enrolled in Oahu College (now Punahou School, the

same private school where BHO was educated) for further studies for one semester. He was

soon sent home to China as his brother was becoming afraid that Sun Yat-sen was about to

embrace Christianity, which he did, but he returned to Hawaii at least twice, in 1900 and

1901. In March 1904, he obtained a Certificate of live Hawaiian Birth, issued by the

Territory of Hawaii, stating he was born on November 24, 1870 in Kula, Maui, and just as

the BHO HI COLB alleges he also was alive at birth on August 4, 1961 in Honolulu Oahu

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just like Sun was born on November 24, 1870 in Kula, Maui. The HI law as used remains

the same in meaning and intent, and that BHO dual allegiance and dual citizenship at

birth alone is more than sufficient to prove BHO ineligible.

30. A COLB issued to those who are "naturalized" in Hawaii is of questionable legal

issue contrary to U.S. Constitution Article 1 §8 Clause 4, Article I §9 Clause 1, Article 1 §10

Clause 1, and as a matter of first impression conflicts with the full faith and credit clause.

31. That Defendant SOEBARKAH at six years of age used the name given upon his

adoption by Lolo S. Soetoro Mangunharjo, an Indonesian colonel in General Suharto's

Armed Forces who had married Stanley Ann Obama, and as an Indonesian Citizen from six

years of age SOEBARKAH is presumed to have an Indonesian passport after removal from

the U.S. Passport of Stanley Ann Soetoro as released to Plaintiff on July 29, 2010 by the

U.S. Department of State.

32. That Defendant SOEBARKAH is also not eligible for the Office of the President

because with the McCarran-Walter Act of 1952 as the controlling legal authority for the

birth of BHO, and especially when the transmission of British citizenship to BHO at birth

no matter where the location is proves a dual citizen at birth, as a treaty matter between

Britain and the USA, and that with the admission against interest of both Stanley Ann

Dunham Obama and Barack Hussein Obama Sr. in a marriage in Hawaii entered after

conception, in which both parents attribute Paternity to BHO Sr. without challenge at the

time of the March 20, 1964 divorce decree makes BHO Jr. a British subject with dual

citizenship and multi-allegiances at best that by the 1952 McCarran-Walter Act, therefore

BHO Jr. is not a Natural Born Citizen; and

33. Further, Defendant SOEBARKAH lost his U.S. citizenship when his mother married

an Indonesian citizen and became a naturalized citizen of Indonesia and in that Indonesia

does not recognize dual citizenship, and because Defendant SOEBARKAH did not take an

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oath of allegiance to the USA when reaching the proper age while resident in the USA

retains Indonesian Citizenship having renounced his previous U.S. Naturalized citizenship

/ British Citizen status; and

34. Plaintiff furthermore alleges, that had SOEBARKAH followed up with his resident

status after 1971 while living with his Grandmother in Hawaii to become naturalized, he

failed to take an oath of allegiance when SOEBARKAH turned 18 years old to regain his

U.S. citizenship status, and then obtained school financing as a foreign exchange student in

Hawaii and again at Occidental College in Los Angeles as done at Columbia and Harvard,

at best has multiple citizenship status with allegiances to Indonesia, Great Britain, Kenya

perhaps; however is not a natural-born citizen of the United States and according to the

public record is not even a citizen of the United States, and therefore, ineligible for the

presidency with NBC Clause as mandated by the Defendant NYS BOE; and

35. The Defendant class of the New York State Democratic Party Committee Candidates

for Presidential Electoral College from the State of New York for Presidential Candidate

Barack Hussein Obama and Vice Presidential Candidate Joseph Biden (“Democrat Party

Elector Candidates”, “Democrat Party Elector Defendants”) as a class of elector candidates

Defendants certified with the New York State Board of Elections and related local entities

under New York state Election Law (EL) on or about September 24, 2008.

36. That on August 28, 2008 Defendant NANCY PELOSI individually with her place of

business located at Washington, D.C. Address 235 Cannon House Office Building

Washington, DC 20515-0508, and as chair failed to affirm for the Democratic National

Committee and DEMOCRATIC STATE COMMITTEE OF THE STATE OF NEW YORK

(NYDP) the eligibility of BHO for ballot access in the State of New York November 4, 2008

General Election using the terms that “the following were duly nominated as candidates of

said Party for President and Vice President of the United States respectively:” and nowhere

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affirms that the candidates are eligible as required by the NYS BOE as shown at its

website provisions citing Article II Section 1 Clause 5 in any of the several states and or

territories except for the State of Hawaii; however Defendant Pelosi as an admission

against interest also affirmed differently for Hawaii as follows:

37. That on August 28, 2008 Defendant Pelosi individually and as Chair affirmed the

alleged eligibility of BHO for ballot access in the State of Hawaii November 4, 2008 General

Election differently than done for any other state or territory including New York using the

terms that “the following candidates for President and Vice President of the United States

are legally qualified to serve under the provisions of the United States Constitution” as

certified for the Hawaii Secretary of State.

38. That on September 15, 2008, Defendant STATE COMMITTEE OF THE WORKING

FAMILIES PARTY OF NEW YORK STATE (NYWFP) by Robert P. Master Presiding

Officer affirmed the alleged eligibility of BHO and the electors for ballot access in the State

of New York November 4, 2008 General Election using the terms that “by majority vote of

the members present, voting by weighted ballot, nominate the following Working Families

Party candidates for office at the General election to be held November 4, 2008:” nowhere

affirms the Constitutional eligibility of BHO.

39. That the Democratic Party Elector Candidates are Velda Jeffrey, June F. O'Neill,

Dennis Mehiel, David A. Paterson, Andrew Cuomo, Thomas P. DiNapoli, Sheldon Silver,

Malcom Smith, Maria Luna, Robert Master, Pamela Green-Perkins, Helen D. Foster, Jon

Cooper, Hakeem Jeffries, Richard Fife, Deborah A. Slott, Terrence Yang, George Arthur,

George Gresham, Alan Van Capelle, Inez Dickens, Suzy Ballantyne, Alan Lubin, Bethaida

Gonzalez, Christine Quinn, William Thompson, Stuart Applebaum, Maritza Davila, Ivan

Young, Barbara Fiala, Frank A. Bolz, III.

40. That in November 2008 the Court rendered an opinion in association with the

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Article 78 Petition 2008/29641 held that there is no breach of the State Constitution or bar

for any Electoral College Elector to hold more than one public office for compensation and

that all the democratic electors were duly served notice of both actions including the

underlying complaint herein regarding the improper ballot access for Barack Hussein

Obama before the November election, and that otherwise Plaintiff is damaged and injured

as a result of the Democratic Electors breach of duty as to ballot access for Presidential

Candidates Obama, McCain, and Calero.

41. Plaintiff seeks a decision by the Court as to whether or not the Candidate(s) are

eligible for Office of President of the United States (POTUS) as required with the United

States Constitution Article 2 Section 1 Clause 5 as required as a regulation by the New

York State Board of Elections including inter alia based upon the Certificate of Live Birth

published August 21, 2008 by Annenberg Political Fact Check at FactCheck.org

http://www.factcheck.org/elections-2008/born_in_the_usa.html ; and that as a prima facie

matter Plaintiff seeks a Court decision herein as to whether or not Obama in fact has Dual

Allegiance, is not a Natural Born Citizen per se but merely a Native-Born citizen if that;

because BHO Jr.’s father, BHO Sr., is a British subject with a student visa at that time,

and is shown to be the purported father of BHO Jr. by both the newspaper announcement

and the COLB shown by Fact Check.org; and therefore, at best BHO Jr. is only a "Native"

born citizen, if that, with only one U.S. Citizen parent mother as a minor at his birth, and

that without two U.S. Citizen parents - BHO Jr. is NOT a "Natural" born citizen at best is

“Native” born - no matter where BHO was born the HI COLB does not prove NBC status;

42. That Defendant ROGER CALERO (Defendant Calero, Presidential Candidate) with

place for service located at the Committee Address: 1000 Grand Concourse, #4A Bronx, NY

10451, was born in Nicaragua in 1969. He and his family fled via Los Angeles, California in

1985. Calero is now a permanent resident alien (holding a green card) since 1990. While in

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Los Angeles, Calero joined a socialist movement and helped mobilize support against

Proposition 187 in the early 90s, and is presumed to have filed a certification for ballot

access through the respective Defendant Socialist Worker’s Party Committee, but is not a

natural-born U.S. Citizen with the U.S. Constitution Article II Section 1 Clause 5 as

mandated by the Defendant NYS BOE.

43. In that on April 10, 2008 as part of the scheme to defraud, U.S. Senator Barack

Hussein Obama was the Sponsor of the U.S. Senate sense resolution S 511 along with other

U.S. Senators Mrs. MCCASKILL, Mr. LEAHY, Mr. COBURN, Mrs. CLINTON, and Mr.

WEBB, and who maliciously submitted the S 511 resolution knowing it was false as to the

natural-born Citizen status of Senator John Sidney McCain III, in violation of 18 USC

§1001; and in which S 511 was referred to the Committee on the Judiciary then to the U.S.

Senate as a fraud upon Congress and the People of the several states and territories

contrary to the facts stated:

“Whereas John Sidney McCain, III, was born to American citizens on an American
military base in the Panama Canal Zone in 1936:”

44. That U.S. Senator Barack Hussein Obama acknowledges endorsing Senate

Resolution 511 that one needs two (2) U.S.A. Citizen parents at birth to be qualified to be a

natural born citizen.

45. Further by U.S. Senate resolution is underscored and confirmed by the Honorable

United States District Judge Michael Chertoff then serving as the Secretary of Homeland

Security in testimony under oath before the U.S. Senate Committee and as reprinted in the

Congressional Record pages S2950 and S2951 stated:

CHERTOFF. “My assumption and my understanding is that if you are born of


American parents, you are naturally a natural-born American citizen.”

46. That on November 30, 2007, Barack Hussein Obama II, and on October 9th 2007,

John Sidney McCain III each affirmed an affidavit for the Arizona Secretary of State to

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gain ballot access in the Arizona 2008 Presidential Preference Election Ballot and that both

affirmations were duly filed with the AZ Secretary of State who certified each affirmed:

“I do solemnly swear (or affirm) that all the information in this Nomination Paper is
true, that as to these and all other qualifications, I am qualified to hold the office
that I seek, having fulfilled the United States constitutional requirements for
holding said office. I further swear (or affirm) that I have fulfilled Arizona's
statutory requirement for placing my name on the Presidential Preference Election
ballot.”

47. That on November 4, 2008, Plaintiff, as a victim of the scheme to defraud, voted for

the electors representing the Republican Party Presidential Candidate John Sidney McCain

III (McCain), that based upon information and belief that McCain was alleged to be a

natural-born Citizen and whom subsequently did not obtain sufficient votes to win the

winner take all Electoral College from New York; and thereafter was discovered not a

natural-born U.S. Citizen.

48. That Defendant JOHN SIDNEY MCCAIN III individually with place of business

located at Washington Office: 241 Russell Senate Office Building Washington, DC 20510,;

was a Presidential candidate at the New York 2008 election cycle without being a Natural-

born citizen with the full knowledge and blessing of Defendants: Peter G. Petersen;

Zbigniew Brzezinski, his sons Mark and Ian; Penny S. Pritzker; George Soros; Jesuits

Fathers: Joseph P. O’Hare, Joseph P. Parkes; Brennan Center Executive Frederick A.O.

Schwarz, Jr.; Nancy Pelosi; John Sidney McCain III; John A. Boehner; Hillary Clinton;

Richard Durbin and others.

49. In good faith with the alleged NBC status as part of the scheme to defraud, Plaintiff

voted for Candidate McCain despite the fact that his wife is a most devoted Roman Catholic

whose two sons were educated by Jesuit priests went to Brophy Prep, School where Mrs.

McCain is a member of Brophy's board of regents and where the McCains have been

generous supporters of Brophy by support of vouchers for Catholic schools like Brophy.

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50. Unbeknownst to Plaintiff, Father Edward Reese S.J., who is the brother of Fr.

Thomas J. Reese S.J., (former editor of America and senior fellow at the Woodstock

Theological Center at Georgetown University), spoke in support for Candidate McCain at

the Republican National Convention at the direction of the Jesuits at Fordham University

controlling the Archbishop of New York City and the Jesuits of Georgetown University

controlling the Archbishop of Washington, DC; and notwithstanding the requirements of

the Vienna Convention of Consular Affairs that agents of a sovereign state not interfere

with the domestic affairs of the USA.

51. Defendant John Sidney McCain III was born on August 29, 1936 in Colon Hospital,

Colon Panama, according to the Panama Canal Health Department not in the Panama

Canal Zone, which is authenticated by Donald Lynn Lamb representing the Panama

Railroad Company with authority over the Hospital in Colon; and

52. That according to the Hay-Banau-Varilla Treaty of November 18, 1903 that has 26

articles in which the two pertinent to the status of the city of Colon under that Treaty refer

to the Convention for the Construction of a Ship Canal says that the Colon Panama, the

birth city cited on McCain’s 1936 long form birth certificate where he was witnessed being

born, and where his parents resided, Colon, Republic de Panama, is not part of the Canal

Zone, quote:

ARTICLE I The United States guarantees and will maintain the independence of the
Republic of Panama.
ARTICLE II The Republic of Panama grants to the United States in perpetuity the use,
occupation and control of a zone of land and land under water for the construction
maintenance, operation, sanitation and protection of said Canal of the width of ten miles
extending to the distance of five miles on each side of the center line of the route of the
Canal to be constructed; the said zone beginning in the Caribbean Sea three marine miles
from mean low water mark and extending to and across the Isthmus of Panama into the
Pacific ocean to a distance of three marine miles from mean low water mark WITH THE
PROVISO THAT THE CITIES OF PANAMA AND COLON and the harbors adjacent to
said cities, WHICH ARE INCLUDED WITHIN THE BOUNDARIES OF THE ZONE
ABOVE DESCRIBED, SHALL NOT BE INCLUDED WITHIN THIS GRANT…”

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and therefore, Defendant McCain is not a natural-born Citizen as he was not born on U.S.

Territory or the USA and is not eligible for the Presidency with the U.S. Constitution

Article II Section One Clause 5 as mandated by the Defendant NYS BOE.

53. The New York State Republican Party Committee Candidates for Presidential

Electoral College from the State of New York for Presidential Candidate John S. McCain

and Vice Presidential Candidate Sarah Palin as a class of elector candidate Defendants

certified with the Defendants NYS BOE and Secretary of State and by related local entities

under New York state Election Law (EL) on or about September 24, 2008.

54. That on September 4, 2008, Defendant JOHN A. BOEHNER, individually with

place of business located at Washington, D.C. Office 1011 Longworth H.O.B. Washington,

DC 20515, and as Chairman affirmed for the Republican National Committee and

Defendant THE NEW YORK STATE REPUBLICAN STATE COMMITTEE (NYRP) the

alleged eligibility of McCain for ballot access in the State of New York November 4, 2008

General Election using the terms that “the following person, meeting the constitutional

requirements for the Office of President of the United States,”

55. Defendant John Boehner, when pressed on the BHO eligibility issue said: "The state of

Hawaii has said that President Obama was born there. That's good enough for me."

56. That on September 21, 2008, Defendant THE NEW YORK STATE COMMITTEE

OF THE INDEPENDENCE PARTY (NYIP) by Frank McKay Chairman affirmed the

alleged eligibility of McCain and the electors for ballot access in the State of New York

November 4, 2008 General Election using the terms that “do hereby certify that the

following persons were duly nominated by majority vote for the office of President and Vice

President of the United States”

57. That on September 22, 2008, Defendant STATE COMMITTEE OF THE

Verified Complaint Page 16 of 45


CONSERVATIVE PARTY OF NEW YORK STATE (NYCP) by Michael R. Long Chairman

affirmed the alleged eligibility of McCain and the electors for ballot access in the State of

New York November 4, 2008 General Election using the terms that “do hereby certify that

the following persons were duly nominated by majority vote for the office of President and

Vice President of the United States”

58. There are 31 Candidates for the Republican Party Committee Presidential Elector

Slate under the names: Jesus Garcia, Gary Melius, Roger C. Bogsted, Lawrence Kadish,

Angelo Corva, Katherine A. James, Fred Ramstel, Debra Leible, Jane E. Deacy, Diane

Haslett Rudiano, Myrtle G. Whitmore, Richard Alicea, Jim Tedisco, Jim Kerr, Denice

Johns, Ed Cox, Doug Colety, Vincent Reda, Louis Liotti, Jasper Nolan, Kathy Jimino, Bijoy

Datta, James Ellis, Michael Nouolio, William Gilberti, Jr., Dean Skelos, James

Domalgalski, Henry Wojtaszek, Thomas D. Cook, Joseph N. Mondello, Rudy Giuliani

(member of SMOM) on the ballot at the November 4, 2008 General Election.

59. That Defendant NYS BOE and its agents have not provided the ballot certification

requested with Plaintiff’s FOIL for Roger Calero’s Committee with THE SOCIALIST

WORKERS PARTY, the DEMOCRATIC STATE COMMITTEE OF THE STATE OF NEW

YORK and or THE NEW YORK STATE REPUBLICAN STATE COMMITTEE and others.

60. Plaintiff, along with those similarly situated, suffers injury to his individual

sovereignty as guaranteed under New York State Civil Rights Law Chapter 6 Section 2 as a

sovereign citizen of the State of New York that here guarantees the Supreme sovereignty in

the people; and whereas, no authority can, on any pretence whatsoever, be exercised over

the citizens of this state, but such as is or shall be derived from and granted by the people

of this state; is denied equal treatment under the NYS Constitution guarantee for

individual voter suffrage and liberty.

Verified Complaint Page 17 of 45


SECOND CAUSE OF ACTION

(Denial of equal protection for voter expectation of a uniform true and correct ballot
according to law and regulations by the Defendants BOE and its agents, Candidates,
Committees and Political Parties)

61. Plaintiff repeats each and every allegation contained in the First Cause of Action

paragraphs 1 thru 60 with the same force and effect as though herein set forth at length.

62. Defendants by reason of their actions to seek election to the Electoral College on

November 4, 2008 with due notice otherwise before the General Election voted without

expressing intention to resign from the electoral college slate simultaneous with the

certification of the winning Electoral College slate under EL §12-102 by December 1, 2008,

intentionally are in breach of their oath of office and subject to impeachment.

63. That public officers of the NYS BOE Defendant and the Public Officer Defendants

intentionally Breach their oath of Office to be placed on the November 4, 2008 ballot as

candidates for electors of the Electoral College and fiduciary duty to the voter(s).

64. Plaintiff, along with those similarly situated, suffers injury to his sovereignty as

guaranteed under New York State Civil Rights Law Chapter 6 Section 2 as a sovereign

citizen of the State of New York that here guarantees the Supreme sovereignty in the

people; and whereas, no authority can, on any pretence whatsoever, be exercised over the

citizens of this state, but such as is or shall be derived from and granted by the people of

this state.

65. That Plaintiff individually as a natural person as with those similarly situated as

We The People as natural persons of the State of New York (a corporate entity) resident in

New York state are grateful to Almighty God for our Freedom, in order to secure its

blessings apart from any such corporate fiction or pretender monarch, and or as further

guaranteed by the 9th and 10th Amendments to the Federal Constitution, and Magna Carta.

66. That nunc pro tunc Plaintiff inherits all the sovereign rights, privileges and property

Verified Complaint Page 18 of 45


that a living natural human inures from the creator Yahweh whose son Jesus Christ

guarantees the sovereign Freedom from Almighty God against corporate fiction and Public

Officer Defendants and their agents who are ultra vires and bent on enslaving plaintiff and

those similarly situated.

67. That the failure of the NYS BOE its agents and candidates and various committees

to verify and protect Plaintiff an those similarly situated from the wrongful certifications

for ballot access at the November 4, 2008 general election for President / Vice President

have done so with impunity and that the mal-administration of law by public officers is an

egregious habit that without correction will continue by the “bi-partisan” control over

elections are expected to continue to repeat the same actions at the 2012 election cycle that

without restraint and injunction imposed with oversight available to the Court under NYS

CPLR and Election Law will further injure Plaintiff along with those similarly situated and

that Plaintiff has no other means to obtain relief in that Officer Defendants are ultra vires.

THIRD CAUSE OF ACTION

(Denial of substantive due process for voter expectation of a uniform true and correct ballot
according to law and regulations by the Defendants BOE and its agents, Candidates,
Committees and Political Parties aided and abetted unjust enrichment)

68. Plaintiff repeats each and every allegation contained in the First through Second

Cause of Action paragraphs 1 through 67 with the same force and effect as though herein

set forth at length.

69. That Official Defendants by denial of substantive due process for voter expectation

of a uniform true and correct ballot according to law and regulations by the Defendants aid

and abet unjust enrichment of all defendant campaign committees and by failure

Defendants infringe Strunk’s individual liberty, expectation of a republican form of

government, and burden his expectation of effective participation in the general election

were the laws not enforced in good faith with the duties of their office as a taking trespass.

Verified Complaint Page 19 of 45


70. That all the Defendants having been culpable to jointly and severally aid and abet

the false billing of Defendant Presidential Candidate campaigns with associated funds from

the New York state taxpayers in the excess of say $10,000,000.00 or more, are liable for the

cost of elections, with interest, and cost of suit caused by the scheme to defraud.

FOURTH CAUSE OF ACTION

(Interference with right to a republican form of government by Fr. Joseph A. O’Hare, S.J.,
Fr. Joseph P. Parkes S.J. and Frederick A.O. Schwarz Jr.)

71. Plaintiff repeats each and every allegation contained in the First through Third

Cause of Action paragraphs 1 through 70 with the same force and effect as though herein

set forth at length.

72. That Defendant Fr. JOSEPH A. O'HARE, S.J. (a.k.a Fr. O’Hare) individually and as

a fourth level induction member of the White and Black Pope’s Militia that by exclusive

oath is a member of the New York Province for the Society of Jesus (NYPSJ) with place for

service located at the offices of the membership association incorporated in the state of New

York in 1944 located at 39 East 83rd Street, New York, New York 10028.

73. Defendant O’Hare from March 1986 until December 1989, Father O'Hare served on

the newly established Mayor's Committee on Appointments, a five-person citizen's

committee charged with interviewing and recommending candidates for New York City

commissions. He also was a member of the Charter Revision Commission of the City of New

York chaired by Richard Ravitch (1986-1988).

74. In April 1988, Mayor Edward I. Koch appointed Fr. O’Hare chair of the NYC

Campaign Finance Board (CFB), a five-member non-partisan board created to oversee a

new law on voluntary public financing of municipal elections established by the City

Council and Mayor Koch in February 1988. He has been reappointed to this position twice

by Mayor Rudolph Giuliani in January 1994 and in April 1999, was reappointed by Mayor

Verified Complaint Page 20 of 45


Bloomberg until 2003, and is now in pastoral service.

75. Defendant Fr. O’Hare, the former president of Fordham University, and presiding

member of the Council on Foreign Relations, came to know Sonia Sotomayor as a Hispanic

Catholic associated with La Raza and the Aztlan Movement and they both served on the New

York City Campaign Finance Board in the 1980s, said: “I just don’t think Sonia would fit in

with Roberts, exactly, and certainly not Scalia. I think they’re very different Catholics.” (2).

76. Defendant Fr. O’Hare made every effort to support the candidacy of Barack Hussein

Obama, even though Fr. O’Hare knew he is not eligible for POTUS, with the intention to

further the Jesuit’s Social Justice doctrine with the work of Antonio Gramsci to elevate

Judge Sotomayor to the Supreme Court, as Judge Sotomayor would support regionalism of

the North American Union and be part of the church’s wing of Hispanic Catholics who are

more liberal than white Catholics on some social and economic issues, like immigration and

health care reform, but more conservative on homosexuality and abortion.

77. Father O'Hare's long association with America began in 1972 and was Editor in Chief

from 1975 until 1984 when then President Ronald Reagan recognized the Sovereignty of the

Vatican State for the First time in history on January 10, 1984 to reset the relationship of all

Jesuits as the Pope’s Militia with an exclusive oath of induction with duties to extirpate heretics.

2
Lucas A. Powe Jr., a professor of law and government at the University of Texas, Austin, said
Chief Justice Roberts and Justices Scalia, Thomas and Alito are “Catholic and movement
conservatives.” “That combination is just golden for being anti-abortion and anti-affirmative action,”
said Mr. Powe, author of “The Supreme Court and the American Elite, 1789-2008” (March 2009,
Harvard University Press). Justice Kennedy, who wrote two decisions favoring equal rights for gay
people, is a “country club Republican,” which Mr. Powe described as “an economic conservative
without some of the social conservatism.” The court’s liberal wing is made up of Justices Ruth Bader
Ginsburg and Stephen G. Breyer, who are Jewish, and John Paul Stevens, a Protestant. Justice
Scalia, whose son is a Catholic priest and Justice Alito are of Italian Catholic ancestry. Justice
Thomas is an African-American convert who once went to seminary, left the church for 28 years and
rejoined in the mid-1990s.

Verified Complaint Page 21 of 45


78. That Fr. O’Hare served NYC Mayors on the NYC Campaign Finance Board (3) from

April 1, 1988 through March 31, 2003, and with Sonia Sotomayor from April 1, 1988

through September 22, 1992.

3
NYC Campaign Finance Board Members and their Terms of Service: July 28, 2010 – Present:
Joseph P. Parkes, S.J., Chairman, Art Chang, Richard J. Davis, Courtney C. Hall , Mark S. Piazza;
July 1, 2009 – July 28, 2010: Joseph P. Parkes, S.J., Chairman, Art Chang, Richard J. Davis,
Katherine C. Patterson, Mark S. Piazza; June 29, 2009 – June 30, 2009: Joseph P. Parkes, S.J.,
Chairman, Richard J. Davis, Katherine C. Patterson, Mark S. Piazza; February 10, 2009 – June 28,
2009: Joseph P. Parkes, S.J., Chairman, Dale C. Christensen, Jr., Katherine C. Patterson, Mark S.
Piazza; April 8, 2008 – February 9, 2009: Joseph P. Parkes, S.J., Chairman; Preeta D. Bansal, Dale
C. Christensen, Jr., Katheryn C. Patterson, Mark S. Piazza ; May 29, 2007 – April 7, 2008: Frederick
A.O. Schwarz, Jr., Chairman, Dale C. Christensen, Jr., Joseph P. Parkes, S.J., Katheryn C.
Patterson, Mark S. Piazza; April 1, 2007 – May 28, 2007 : Frederick A.O. Schwarz, Jr., Chairman,
Dale C. Christensen, Jr., Katheryn C. Patterson, Mark S. Piazza ; May 16, 2006 – March 31, 2007 :
Frederick A.O. Schwarz, Jr., Chairman, Dale C. Christensen, Jr., Katheryn C. Patterson,
Mark S. Piazza, Joseph Potasnik ; April 1, 2006 – May 15, 2006: Frederick A.O. Schwarz, Jr.,
Chairman, Dale C. Christensen, Jr., Katheryn C. Patterson, Joseph Potasnik ; September 16, 2004 –
March 31, 2006: Frederick A.O. Schwarz, Jr., Chairman, Dale C. Christensen, Jr., Katheryn C.
Patterson, Joseph Potasnik, Alan N. Rechtschaffen: October 27, 2003 – September 15, 2004:
Frederick A.O. Schwarz, Jr., Chairman, Alfred C. Cerullo, III, Dale C. Christensen, Jr., Joseph
Potasnik, Alan N. Rechtschaffen; July 30, 2003 – October 26, 2003: Frederick A.O. Schwarz, Jr.,
Chairman, Alfred C. Cerullo, III, Dale C. Christensen, Jr., Joseph Potasnik; April 1, 2003 – July 29,
2003: Frederick A.O. Schwarz, Jr., Chairman, Alfred C. Cerullo, III, Dale C. Christensen, Jr.,
Pamela Jones Harbour, Joseph Potasnik: October 17, 2000 – March 31, 2003: Joseph A. O’Hare, S.J.,
Chairman, Alfred C. Cerullo, III, Dale C. Christensen, Jr., Pamela Jones Harbour, Joseph Potasnik;
September 2, 2000 – October 16, 2000: Joseph A. O’Hare, S.J., Chairman, Alfred C. Cerullo, III, Dale
C. Christensen, Jr., Joseph Potasnik; May 31, 2000 – September 1, 2000: Joseph A. O’Hare,
Chairman, Martin S. Begun, Alfred C. Cerullo, III, Dale C. Christensen, Jr., Joseph Potasnik; May
18, 2000 – May 30, 2000: Joseph A. O’Hare, S.J., Chairman, Martin S. Begun, Dale C. Christensen,
Jr., Bill Green, Joseph Potasnik; May 13, 2000 – May 17, 2000: Joseph A. O’Hare, S.J., Chairman,
Martin S. Begun, Bill Green, Joseph Potasnik; June 28, 1999 – May 12, 2000: Joseph A. O’Hare, S.J.,
Chairman, Martin S. Begun, Bill Green, Dennis Mehiel, Joseph Potasnik; January 12, 1999 – June
27, 1999: Joseph A. O’Hare, S.J., Chairman, Martin S. Begun, Bill Green, Dennis Mehiel; June 1998
– January 11, 1999: Joseph A. O’Hare, S.J., Chairman, Martin S. Begun, Bill Green; September 19,
1997 – June 1998: Joseph A. O’Hare, S.J., Chairman, Martin S. Begun, Joseph Erazo, Bill Green;
June 2, 1997 – September 18, 1997: Joseph A. O’Hare, S.J., Chairman, Martin S. Begun, Bill Green,
Vaughn C. Williams, June 4, 1996 – June 1, 1997: Joseph A. O’Hare, S.J., Chairman, Martin S.
Begun, Bill Green, James I. Lewis, Vaughn C. Williams; June 7, 1995 – June 3, 1996: Joseph A.
O’Hare, S.J., Chairman, Bill Green, James I. Lewis, Vaughn C. Williams; July 21, 1994 – June 6,
1995: Joseph A. O’Hare, S.J., Chairman, Bill Green, James I. Lewis, Joseph Messina, Vaughn C.
Williams; December 11, 1992 – July 20, 1994: Joseph A. O’Hare, S.J., Chairman, James I. Lewis,
Joseph Messina, Vaughn C. Williams; September 23, 1992 – December 10, 1992: Joseph A. O’Hare,
S.J., Chairman, James I. Lewis, Joseph Messina; July 14, 1990 – September 22, 1992: Joseph A.
O’Hare, S.J., Chairman, James I. Lewis, Joseph Messina, Sonia Sotomayor; December 22, 1988 –
July 13, 1990: Joseph A. O’Hare, S.J., Chairman, James I. Lewis, Joseph Messina, Robert B. McKay,
Sonia Sotomayor; April 1, 1988 – December 13, 1988: Joseph A. O’Hare, S.J., Chairman, James I.
Lewis, Frank J. Macchiarola, Robert B. McKay, Sonia Sotomayor.

Verified Complaint Page 22 of 45


79. That Defendant Fr. JOSEPH P. PARKES, S.J., (Fr. Parkes) individually, presiding

member of the Council on Foreign Relations, is a fourth level induction member of the

White and Black Pope’s Militia that by exclusive oath is the Jesuit Provincial member of

the New York Province for the Society of Jesus (NYPSJ) with place of business for service

located at the offices in New York state in 1944 located at 39 East 83rd Street, New York,

New York 10028.

80. Father Parkes (4) was appointed to the Board by Mayor Michael R. Bloomberg on

May 29, 2007 and to chairman on April 8, 2008 whose term will expire November 30, 2013.

81. That Defendant Fr. Parkes served on the NYC CFB with Defendant Frederick A.O.

Schwarz Jr. and collaborates with the litigation efforts of the Brennan Center for Justice at

NYU Law School.

82. Defendant Fr. Parkes made every effort to support the candidacy of Barack Hussein

Obama, even though Fr. Parkes knew Soebarkah is not eligible for POTUS, with intention

to further the Jesuit’s doctrine of Social Justice using the work of Antonio Gramsci(5) acted

to elevate Judge Sotomayor to the SCOTUS.

83. That THE NEW YORK PROVINCE OF THE SOCIETY OF JESUS was incorporated July

03, 1944 in the Bronx New York and is deemed an active domestic not-for-profit corporation

4
Fr. Parkes is the President of Cristo Rey New York High School in East Harlem. He also sits on
the Boards of St. Aloysius School in Central Harlem, St. Peter’s College in Jersey City, and St. Ann’s
School in East Harlem. He previously served as President of the Fordham Preparatory School. He
also served in a variety of posts within the New York Province of the Society of Jesus before his
appointment as Provincial in 1990. He earned his Bachelor’s degree from the Fordham University
College of Philosophy & Letters, his M.A. in Medieval History from the University of Wisconsin and
his Masters of Divinity from Woodstock College.
5
Antonio Gramsci : (January 22, 1891 – April 27, 1937) was an Italian writer, politician, political
theorist, linguist and philosopher. A founding member and onetime leader of the Communist Party
of Italy, he was imprisoned by Benito Mussolini's Fascist regime safeguarded by Fr. Pietro Tacchi
Venturi, S.J. His writings are heavily concerned with the analysis of culture and political leadership
and he is notable as a highly original thinker within the Marxist tradition. He is renowned for his
concept of cultural hegemony as a means of maintaining the state in a capitalist society.

Verified Complaint Page 23 of 45


where Defendants Fr. O’Hare and Fr. Parkes along with other Jesuits in New York, exceed 19

contributing members who are subject to the restrictions from interfering with Domestic affairs

of New York and the united States of America as a sovereign entity with the Vienna Convention

Treaties of 1961, 1963 and 1969 as applies to consular affairs, and in which the Jesuits order are

agents of the Sovereign Vatican State.

84. That according to NYS Benevolent Orders Law, the members of the Jesuit Order are not

exempt from registering as an exclusive membership organization with a constitution and

exclusive oath of induction that requires strict adherence to NYS Civil Rights Law Chapter 6

Article 5A §§ 53-57 Membership Corporations and Unincorporated Associations., is not done.

85. That Defendants Fr. O’Hare and Fr. Parkes among other members of the Pontifex

Maximus’s Jesuit Militia order here in New York since the January 10, 1984 recognition of the

Sovereignty of the Vatican State are questionably serving on the NYC Campaign Finance

Board Members and by their Terms of Service ongoing, and as well as endorsements of

Barack Hussein Obama to the POTUS, Judge Sotomayor to the SCOTUS and of other

political campaigns and appointments are interfering in the domestic affairs of the people of

New York state, must be restrained from such action; and that the Jesuit Order must be

audited and fined for failure to comply with NYS Civil Right Law Chapter 6 Article 5A.

86. On information and belief, the Defendant Chairmen act to enrich Vatican temporal

power and financial interests in Brooklyn as with the Nehemiah Housing projects here and

elsewhere and use their office to facilitate persons in service of the Jesuit Order and

Vatican, and that interferes with Plaintiff liberty along with those similarly situated.

87. That Plaintiff has been personally injured as a result of the Jesuit Chairmen’s

recommendation for appointments to the various Brooklyn Community Boards including

the Third Community Board for Bedford Stuyvesant and others including that for the

Verified Complaint Page 24 of 45


Atlantic Yards in Prospect Heights, along with such is interference with Plaintiff’s liberty

along with those similarly situated, as Defendant Jesuits and the CFB members approved

campaign matching funds to enable Plaintiff’s enemies the Assemblymen William Boylan of

the 55th Assembly District (AD) and Hakeem Jefferies in the 57th AD and State Senator

Velmanette Montgomery of the 18th Senate District, each have prospered at the loss of

liberty to Plaintiff along with those similarly situated and especially William Boylan who

facilitated the conversion of Plaintiff's interest in real property as a taking of say

$2,000,000 in damages as outlined in the EDNY case Strunk v US HUD et al. 99 cv 6480

(NG), as retribution for when Plaintiff exposed William Boylan's taking of NYC HPD

property for personal gain.

88. William Boylan has been indicted in the SDNY for influence peddling in Brooklyn.

FIFTH CAUSE OF ACTION

(Interference with election franchise by Defendants and Frederick A.O. Schwarz, Jr.)

89. Plaintiff repeats each and every allegation contained in the First through Fourth

Cause of Action paragraphs 1 through 88 with the same force and effect as though herein

set forth at length.

90. That Plaintiff is the founder of the AD HOC Brooklyn Home Rule Coalition (6) for a

referendum with NYS Municipal Home Rule Law Section 37 to return Brooklyn Home Rule

with the bottom-up annual election of a representative in each 5000 person district within

6
BROOKLYN HOME RULE COALITION http://associationforsovereignhomerulewithin.org/brooklyn-
home-rule-coalition.html : As an Ad Hoc group intent on maintaining the integrity of neighborhoods
and subsidiarity in communities within the respective community boards without dismantling gains
made every ten years. Brooklyn is to conduct annual election of neighborhood self-administration,
with One (1) representative Board member for each 5000 person district in each Community Board
(CB) with an average of 25 such districts that in turn each CB elect a chairman (18 in all) to carry
the proxy of each respective board member to advise the Brooklyn Mayor in the governance of
Brooklyn as a sub-division of the state as it once was, rather than the bedroom borough tax farm for
the Manhattan elite that since the Great Mistake of 1898 have depleted the opportunity of each
person in favor of oligarchy. 2011 INITIATIVE REFERENDUM with NYS MHR §37 to amend the
NYC Charter http://associationforsovereignhomerulewithin.org/bhrc-initiative---petition.html.

Verified Complaint Page 25 of 45


each of eighteen Brooklyn Community Boards with the referendum pending US DOJ Voting

Rights Section application for VRA §5 pre-clearance review by the November 2011 election.

91. That members of the Council on Foreign Relations including Peter G. Petersen as

then Chairman that act with the Jesuit Order by the oath of allegiance superior to the

United States Constitution, Treaties and various States’ Constitutions that starting no

later than January 2006 sought to usurp the executive branch of government using Barack

Hussein Obama II and John S. McCain III, as a matched set of contenders then under joint

command and control, to preclude any other contender in preparation for a banking and

sub-prime mortgage collapse that requires subsuming the sovereignty of the people of the

united States of America and New York to International Monetary Fund conditionality with

loss of the dollar reserve currency status, and collapse of the living standards of the vast

majority of Americans to that of a third world status.

92. That the Democratic and Republican Party at the national and State level colluded

in the plan to usurp the POTUS and used both Defendant Pelosi and Defendant Boehner to

carry out the scheme to defraud the voters of New York and the several states.

93. That Defendants Fr. O’Hare and Fr. Parkes along with Sonia Sotomayor and

Defendant Frederick A.O. Schwarz, Jr. as the NYC CFB Chairman from April 1, 2003 until

the April 7 2008 (while chief counsel to the Brennan Center for Justice) acted to interfere

with the election of Justices of the State Supreme Court by approving matching funds for

those Justices that exclusively handle foreclosures and would serve the temporal and

financial interests of the Vatican State to overturn the Judicial election requirements of

the New York State Constitutional election process of Justices done by Assembly Districts.

94. That Defendant FREDERICK A.O. SCHWARZ, JR. (Defendant Schwarz) is sued

individually and as past NYC CFB Chairman serving from April 1, 2003 until the April 7

2008, while the chief senior counsel the Brennan Center for Justice at NYU Law School

Verified Complaint Page 26 of 45


with place of business located c/o the Brennan Center for Justice New York Office 161

Avenue of the Americas, 12th Floor New York, NY 10013.

95. Simultaneously the Brennan Center filed the friendly case Lopez-Torres v the NYS

BOE et al. EDNY 04-cv-1192 (JG), in which Strunk intervened on the side of the State

Constitution and State Justices with an order taken on appeal to the Second Circuit Panel

with Judges Sonia Sotomayor, Peter Hall and Chester Straub in support of dismantling the

State Constitution as to election of Justices and from which the State filed for certiorari and

that was remanded back by the SCOTUS and that Defendant Schwarz had and has a

conflict of interest that has damaged Plaintiff in the amount of $250.

SIXTH CAUSE OF ACTION

(Scheme to defraud Plaintiff and those similarly situated as against all Defendants)

96. Plaintiff repeats each and every allegation contained in the First through Fifth

Cause of Action paragraphs 1 through 95 with the same force and effect as though herein

set forth at length.

97. ALL Defendants act in the scheme to defraud Plaintiff along with those similarly

situated in denial of a reasonable expectation of successful participation in the suffrage

process in conjunction with the private organizations known as the Council on Foreign

Relations with an exclusive secret oath superseding any oath to the U.S. and or respective

State Constitution and Sovereign Military Order of Malta (SMOM) directed by the Jesuit

General, used Peter G. Petersen, Zbigniew Brzezinski, Penny Pritzker, George Soros, et al.

including Fethullah Gulen with Fr. Thomas Michel S.J. and the Gulen Movement with the

Muslim Brotherhood here in Brooklyn (as with Soebarkah and Fr. Gregory Galluzzo, S.J.) to

recreate a worldwide Caliphate, in a push for destruction of the Al-Aqsa Mosque to be

blamed on the USA Military as the Stage Three described in U.S. DOS Publication 7277 to

Verified Complaint Page 27 of 45


facilitate the final temple of Babylon using the Manchurian candidates: Soebarkah since

1995 who co-authored Dreams from My Father and Republican Guard candidate McCain

since 1999 who co-authored, Faith of My Fathers and who both act together to reduce the

United States of America to a mere territorial region without sovereignty.

98. The actual scheme to defraud the voters in 2008 began in earnest on February 22,

2006 when the Editor of the Chicago-Kent Law School Law Review, Sarah P. Herlihy

(Kirkland & Ellis LLP), published a memorandum with approved edits of 11-23-05 entitled

AMENDING THE NATURAL BORN CITIZEN REQUIREMENT: GLOBALIZATION AS

THE IMPETUS AND THE OBSTACLE at Vol. 81: 275 , and with a special footnote

designating the author has a J.D. from Chicago-Kent College of Law, 2005 and “that the

author would like to thank Professor Graeme Dinwoodie, and the 2004–2005 Globalization

and Its Effect on Domestic Law Seminar Class for their valuable comments and insights on

this Note.” (see http://www.scribd.com/doc/48927079)

99. The key to understanding the scheme to defraud the voters in 2008 is the way the

circumvention of U.S. Constitution Article 2 Section 1 Clause 5 required two not one

version of a candidate with flaws Barack Hussein Obama II and John Sidney McCain III.

100. That in the Herlihy memorandum Part one of the paper provides a brief history and

overview of the natural born citizen requirement. Part two discusses the rational reasons

for abolishing this requirement and describes why the increase in globalization makes

abolishing the natural born citizen requirement more necessary than ever. Part three

presents the arguments against allowing naturalized citizens to be eligible for the

presidency and identifies common beliefs about globalization that will cause Americans to

rely on emotion and oppose a Constitutional amendment.

101. That according to Sarah P. Herlihy’s resume on line with the International Law firm

of Kirkland & Ellis LLP in Chicago after Ms. Herlihy was the Law Clerk to the Honorable

Verified Complaint Page 28 of 45


Michael M. Mihm, United States District Court for the Central District of Illinois, 2005 –

2006 she has been employed by the firm and in the resume she is listed with receiving the

award of the Order of the Coif whose various members of the Society are traced throughout

the Obama support network in conspiracy with the Candidates and Campaign Defendants.

102. That a Principal of Kirtland & Ellis LLP, Bruce I. Ettelson, P.C., is Member of

finance committees of U.S. Senators Barack Obama and Richard Durbin.

http://www.kirkland.com (towards bottom of the page) In addition to members of the firm

making donations to the Obama campaign , Jack S. Levin, P.C., another partner who, in

December 2002 was presented the ” Illinois Venture Capital Association’s lifetime

achievement award for service to the private equity/venture capital community” presented

by Illinois Senator Barack Obama.

103. That Kirtland & Ellis LLP is a global firm with powerful international clients listed

on the website that span the business affairs of the Sovereign Military Order of Malta,

including the current client British Petroleum, and includes among its attorneys SMOM

member John Robert Bolton the prior administration’s U.S. United Nations Ambassador.

104. The Jesuits, SMOM, CFR and OPUS DEI (documented by Plaintiff in the EDNY

Case Strunk v CIA et al. 08-cv-1196) are agents of the Holy See and the Vatican sovereign

state, as agents fail to follow 18 USC Chapter 45, Vienna Conventions and related law.

105. Plaintiff’s expert witness Eric Jon Phelps affirms that the CFR and its

affiliates, overseen by the Archbishop of New York City and his Knights of Malta at the

direction of the Pope of Rome on orders of the Jesuit General, are to rebuild the Kingdom of

Babylon including the City of Babylon. This quest will be pursued under the guise of

establishing a new Sunni Caliphate with its capital in Baghdad after the destruction of the

Temple Mount Mosques as well as Mecca and Medina, which destruction will be blamed

upon the USA during this present Papal Crusade in the Middle East. There will be built a

Verified Complaint Page 29 of 45


Third Hebrew Temple in Jerusalem and a Temple in Babylon. The dicta of the Vatican

mandates the Kingdom of Babylon, from Dubai to Baghdad, will be the new economic

capital of the world headed by the final Pope of Rome, murdered and risen from the dead to

be the Antichrist/Man-Beast/King of Babylon.

106. On May 28, 2010, in an radio interview with Eric Jon Phelps, in the context of a

review of Hosea 3:4-5; 6:1-2 and Romans 11:25, Count Vittorio Vivaldi III of Venice Italy

proves Islam is a Creation of the Vatican stated: “The Papacy created Islam to annihilate

the Pope’s Jewish and non-Roman Catholic Christian enemies.” States, “the Koran was

completed in 649 AD Rome under Pope Theodore I…it appears, however, after further

review, the Koran was completed in 632 AD during the pontificate of Pope Honorius I (625-

638 AD), later accursed by Rome as a “heretic.”

107. And for which Count Vivaldi confirms what the ex-Jesuit priest, Alberto Rivera

stated in an interview of December 11, 2001 of How the Vatican created Islam

(see transcript at http://www.scribd.com/doc/48923143 ), which was told to him by Jesuit

Cardinal Augustin Bea while he was at the Vatican, and that based upon secret records in

the Vatican Library confirm starting in the third century the Vatican desperately wanted to

control Jerusalem acted through the Augustinian Monks to create Mohammed as the

Islamic messiah, wrote the Koran whose manuscripts are at the Vatican and prove "The

pope moved quickly and issued bulls granting the Arab generals permission to invade and

conquer the nations of North Africa. The Vatican helped to finance the building of these

massive Islamic armies in exchange for three favors”

108. To that end, Defendant PETER G. PETERSEN (Defendant Petersen) being sued

individually with his place of business as senior chair of the Council on Foreign Relations

located at 58 East 68th Street New York, NY 10065-5953 (212) 434-9400.

Verified Complaint Page 30 of 45


109. That based upon information and belief, Defendant Petersen as a member of the Knights

of Malta (7) as well as Chairmen of the New York Federal Reserves Bank, co-founder of The

Blackstone Group, as founding chair of the Institute for International Economics, in

anticipation of the sub-prime mortgage collapse and as a prior Lehman chair, to be blamed

on Lehman Brothers, Bear Stearns and Bernard Madoff, that requires strategic turmoil to

restructure the Mideast using CFR members Zbigniew Kaimierz Brzezinski, Joseph Biden,

Penny S. Pritzker, George Soros, Nancy Pelosi, John Boehner, Barack Hussein Obama,

Frederick A.O. Schwarz Jr. John S. McCain III et al. to cease the executive in 2008.

110. That Defendant ZBIGNIEW KAIMIERZ BRZEZINSKI, (Defendant Brzezinski)

individually with his place of business at Columbia University in the City of New York

School of Foreign Affairs 2960 Broadway New York, NY 10027-6902, is both a blood

member of the SMOM on "the right" and of the Scottish Rite Freemason Grand Lodge of

Philadelphia on "the left" working for the Jesuits against the sovereign interest of the USA

7
As a member of the Knights of Malta, and by virtue of your blood oath of obedience to the Pope,
you are required to support to the death the desires of the head of the Order of the Knights of Malta-
in this case, Pope Benedict XVI -over and above any other allegiance you may feel or pretend to feel
toward any other loyalty such as a loyalty to the Constitution for the united States of America.
Those who are presently members of the Knights of Malta must on penalty of death support
those policies advocated by the Vatican. It is not hard for them to do this. They BELIEVE in these
policies and principles. The polices which are espoused and proclaimed by the office of the Pope are
as follows:
1. End of sovereignty for the United States and other countries.
2. End of absolute property rights.
3. End of all gun rights.
4. The new international economic Order (world government).
5. The redistribution of wealth and jobs.
6. Calls for nations to trust the United Nations.
7. Total disarmament.
8. Promote the United Nations as the hope for peace.
9. Promote UNESCO, the deadly educational and cultural arm of the United Nations.
10. Promote interdependence.
11. Support sanctions honoring Father Pierre Teilhard de Chardin-the New Age Humanist Priest.
12. Support the belief that the economic principle of traditional Christian or Catholic social
doctrine is the economic principle of communism.
13. Promote the Pope as the acting go-between for the United States and the Soviet Union.

Verified Complaint Page 31 of 45


and plaintiff along with those similarly situated;

111. Defendant Brzezinski as a CFR member and founding member of the Trilateral

Commission, that as National Security Advisor to five presidents maintains the belief that:

"In the economic-technological field, some international cooperation has already been
achieved, but further progress will require greater American sacrifices. More intensive
efforts to shape a new world monetary structure will have to be undertaken, with some
consequent risk to the present relatively favorable American position."
"The technotronic era involves the gradual appearance of a more controlled society. Such a
society would be dominated by an elite, unrestrained by traditional values. Soon it will be
possible to assert almost continuous surveillance over every citizen and maintain up-to-
date complete files containing even the most personal information about the citizen. These
files will be subject to instantaneous retrieval by the authorities."

112. Defendant Brzezinski‘s world outlook and agenda by evidence of writings acts for the

Society of Jesus that eclipses all other influences on SOEBARKAH, McCain and Calero.

113. That Defendant Brzezinski has managed a crucial role for the Vatican State as a

member of the SMOM and as a Freemason of the Philadelphia Grand Lodge to create global

regionalism that subsumes national sovereignty and as Former National Security Adviser

to President Carter expressed his view of regionalism at Mikhail Gorbachev’s October 1995

State of the World Forum, that quote:

“We cannot leap into world government in one quick step...The precondition for
eventual globalization — genuine globalization — is progressive regionalization.”

114. In August 2007, Brzezinski endorsed Democratic presidential candidate Barack

Hussein Obama II. He stated that Obama

"recognizes that the challenge is a new face, a new sense of direction, a new
definition of America's role in the world." Also saying, "What makes Obama
attractive to me is that he understands that we live in a very different world where
we have to relate to a variety of cultures and people."

115. In September 2007 during a speech on the Iraq war, Soebarkah introduced

Brzezinski as "one of our most outstanding thinkers," but some questioned his criticism of

the Israel lobby in the United States.

Verified Complaint Page 32 of 45


116. In a September 2009 interview with The Daily Beast, Brzezinski replied to a

question about how aggressive President Obama should be in insisting Israel not conduct

an air strike on Iran saying: "We are not exactly impotent little babies. They have to fly

over our airspace in Iraq. Are we just going to sit there and watch?" This was interpreted as

supporting the U.S. downing Israeli jets to prevent an attack on Iran.

117. Defendant Brzezinski is on the faculty of Columbia University from 1960 and is now

emeritus, was on the faculty of Harvard University 1953-60. Ph.D., Harvard University,

1953; B.A. and M.A., McGill University 1949 and 1950; and holds Jesuits honorary degrees

from Georgetown University, Williams College, Fordham University, College of the Holy

Cross, Alliance College, the Catholic University of Lublin, Warsaw University, the

University of Tbilisi, the University of Vilnius, the Ukrainian Free University, the

Jagiellonian University, Comenius University (Bratislava); Tashkent University; Baku

State University (Azerbaijan);

118. That Defendant Brzezinski advised CFR members SOEBARKAH and McCain whose

campaigns used his sons, Mark who was a member of the advisors in the SOEBARKAH

Campaign and Ian who was an advisor on the McCain Campaign, all done in exchange for

his sons’ government employment and furtherance of the enterprise corruption associated

with funding raising done by George Soros and King Juan Carlos.

119. Defendant IAN J. BRZEZINSKI individually has his place of business is located at

The Atlantic Council Headquarters 1101 15th Street, NW, 11th Floor Washington, D.C.

20005 U.S.A. Tel: (202) 463-7226 Fax: (202) 463-7241; he is son of Polish American political

scientist, geostrategist, and statesman Zbigniew Brzezinski, brother of American lawyer

and foreign policy expert Mark Brzezinski.

120. Defendant Ian J. Brzezinski was the Foreign policy advisor to the campaign of John

Sidney McCain III.

Verified Complaint Page 33 of 45


121. Ian Joseph Brzezinski is a Senior Fellow in the International Security Program and

is on the Atlantic Council’s Strategic Advisors Group. During George W. Bush presidency of

the United States, he served as Deputy Assistant United States Secretary of Defense for

Europe and NATO Booz Allen Hamilton, Inc. providing policy and technical support to U.S.

combatant commands and foreign clients. Policy (2001–5). Brzezinski is frequent

contributor of American press on foreign policy issues today; he leads the Brzezinski Group

at the Atlantic Council, which provides strategic insight and advice to government and

commercial clients.

122. Defendant MARK BRZEZINSKI is an American lawyer and foreign policy expert

place of business is located at McGuire Woods LLP 2001 K Street N.W. Suite 400

Washington, D.C. 20006-1040 T: 202.857.1717 F: 202.828.2989.

123. He is the son of Polish-born former National Security AdvisorZbigniew Brzezinski.

Brzezinski graduated from Dartmouth College with a Bachelor of Arts in government,

earned a J.D. from the University of Virginia Law School, and holds a D.Phil. in political

science from Oxford University. He also earned a Fulbright Scholarship to study the Polish

Constitutional Court. He was a corporate and securities associate at Hogan & Hartson LLP

in Washington, D.C. from 1996-1999. From 1999-2001, Mr. Brzezinski served in the Clinton

administration as a director of Russian/Eurasian — and later Southeast European affairs -

of the National Security Council at the White House. In that capacity, he was White House

coordinator for U.S. democracy and rule of law assistance programs for the region. He is

currently a partner in the Washington, D.C. office of the law firm McGuireWoods, where he

manages the international practice.

124. Defendant Mark Brzezinski was a foreign policy advisor to the presidential

campaign of Barack Hussein Obama II.

125. That Plaintiff with those similarly situated are denied individual 1st, 5th , 9th and

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10th amendment rights to sovereignty and a republican form of government as well as

financial injury for the cost of the 2008 election cycle in New York..

126. That Democrat Party Elector Candidate Defendants, their agents John and Jane

Does are part of an enterprise who have overthrown the government of the United States in

conjunction with SOEBARKAH, Joseph Biden, McCain, Calero and their agents at the

state and national level with those other candidate elector slates of other states of the

several states.

127. Defendant SOEBARKAH and Defendant McCain as part of Soebarkah’s Republican

Guard committed perjury before a Federal Officer in violation of 18 USC §1001 as part of

the racketeering enterprise corruption.

128. That Defendants infringe Strunk’s individual liberty, expectation of a republican

form of government, and burden his expectation of effective participation in the general

election were the laws not enforced in good faith with the duties of their office.

129. Plaintiff is the only person in the USA to have duly fired fired fired BHO on January

23, 2009 by registered mail (rendering BHO the USURPER as Plaintiff is entitled to

characterize BHO as) on the grounds that he had not proven himself eligible to be the

administrator / trustee of Plaintiff’s private account at the U.S. Treasury as required by

U.S. Constitution Article 2 Section 1 clause 5 with a pending Replevin matter in the

District of Columbia; and all acts by the usurper are void ab initio – a serious problem!

130. Furthermore, New York State Board of Elections individuals; the New York State

Secretary of State individually, the New York State Attorney General Andrew Cuomo

individually as an elector along with John and Jane Does have conspired inter alia for a

breach of fiduciary duties under color of state law enacted by the State Legislature to

protect Plaintiff’s along with those similarly situated right to a reasonable expectation of

participation and success with a proper ballot for the New York electoral college election of

Verified Complaint Page 35 of 45


the 2008 president and vice president of the United States of America in accordance with

United States Constitution Article 2 Section 1 Clause 5.

131. That Defendant PENNY SUE PRITZKER (Defendant Pritzker) is the principal of

the Pritzker Realty Group, L.L.C. 71 S. Wacker Drive 47th Floor Chicago, IL 60606 P:

312.873.4800 F: 312.873.4987 is sued individually as the National Finance Chair of the

Barack Hussein Obama III for President Campaign.

132. Defendant Pritzker (8) raised campaign funds with George Soros, was co-chair of the

2009 Presidential Inaugural Committee, was thought to be in the final stages of vetting to

become commerce secretary in the Obama administration withdrew from consideration.

8
The Superior Bank FSB was a Hinsdale, Illinois-based Savings and loan association that collapsed
in July 2001 [1] with some $2.3b in assets. Synopsis: Superior opened in 1988 under conditions
created by the Federal Home Loan Bank Board, which made generous arrangements for the takeover
of several failed thrifts. The bank was a 50-50 partnership between the Pritzker's jointly (the elder
Jay, Penny and Thomas) and real estate investor Alvin Dworman (architect of the “sub-prime”
mortgage after the collapse of the savings and loan industry), who ran Superior from his New York
office after Pritzker's death in 1997. The Pritzkers and Dworman bought the failed Lyons Federal for
the relatively modest price of $42.5 million, with each using a shell corporation to control half of
Coast-to-Coast Financial Corporation (CCFC), a holding company created to own Superior. The July
2001 collapse, according to a press release from the Office of Thrift Supervision, “Superior Bank
suffered as a result of its former high-risk business strategy, which was focused on the generation of
significant volumes of subprime mortgage and automobile loans for securitization and sale in the
secondary market. OTS found that the bank also suffered from poor lending practices, improper
record keeping and accounting, and ineffective board and management supervision.”
George Kaufman, a finance professor at Loyola University Chicago called Superior's failure
"a tale of gross mismanagement," adding "[Superior] was engaged in relatively unethical practices,
fancy-footwork accounting, playing it very close to the edge." Kaufman says many share in the blame
for the mess-the bank's managers, directors, and auditors, as well as banking regulators-but he also
wonders how the Pritzkers, as co-owners, could have allowed it to happen. "One of the great
mysteries to me is what the Pritzkers were up to, why they took these chances," he said. "It makes
no sense given their wealth and visibility."
The Settlement by the Pritzkers in December 2001, agreed to pay a record $460 million to
the federal government to avoid being punished for the failure of Superior Bank FSB. And the RICO
lawsuit in 2002 uninsured depositors filed federal class-action charges under the RICO Act against
one-time board chairwoman Penny Pritzker, her cousin Thomas Pritzker, Dworman, other bank
principals and Ernst & Young. Plaintiffs’ attorney Clint Krislov claimed that those who controlled
Superior induced depositors to put money in the bank, “corruptly” funneling money out of the bank
to “fraudulently” profit the owners. The lawsuit, Courtney v. Hallerin was an initially filed under a
district court, which dismissed the claims; the appeal was argued before the 7th Circuit of the United
States Court of Appeals on September 25, 2006. In her May 7, 2007 opinion, Judge Wood affirmed
the lower court's decision. http://www.scribd.com/doc/49708919/A-Financial-History-of-Modern-U-S-
Corporate-Scandals-From-Enron-to-Reform see Pages 226-227 and 281-282.

Verified Complaint Page 36 of 45


133. Defendant Pritzker is a longtime friend of Defendant Obama in Chicago and was a

chief architect of his record-breaking fund-raising efforts during the presidential campaign.

Defendant Pritzker’s business dealings raised tough questions during confirmation

hearings that involved running and overseeing Superior Bank, an Illinois institution co-

owned by her family that was at the forefront of turning subprime loans into securities, the

risky practice at the heart of the financial crisis. The bank collapsed in 2001 after

regulators discovered accounting irregularities that overstated its assets.

134. Presently Defendant Pritzker is chair of the newly launched Skills for America's

Future for the administration and is gearing up for a re-election funding in 2012.

135. Defendant Pritzker is associated with Martin H. Nesbitt and George Soros who all

served to raise and bundle campaign funds for the Obama Campaign committees.

136. Defendant Pritzker as Chairman of the board of TransUnion, Chairman/CEO of

Pritzker Realty Group, and Chairman and co-founder of Vi(formerly Classic Residence by

Hyatt), The Parking Spot and Artemis Real Estate Partners. TransUnion is a global

financial information company; the Pritzker Realty Group invests in non-hotel real estate

and developed the award winning Hyatt Center in Chicago's Loop. Vi (pronounced VEE) is

a leading developer and operator of lifestyle communities for older adults, the Parking Spot

in association with Martin H. Nesbitt manages the largest network of off-site airport

parking facilities in the U.S. Launched in 2010, Artemis Real Estate Partners is a private

equity, real estate investment manager.

137. Defendant Pritzker is a board member of the Council on Foreign Relations, a trustee

of Stanford University, a trustee of the John F. Kennedy Center for the Performing Arts, an

advisory board member of Brookings Institution's Hamilton Project, and a former member of

the Harvard University Board of Overseers. Defendant Pritzker’s daughter Rachel Pritzker

Verified Complaint Page 37 of 45


Hunter is treasurer of George Soros’s Media Matters for America $100 million clearing house

known as the Democracy Alliance (DA).

138. That Defendant GEORGE SOROS (a.k.a. George Schwartz) with place for service at

Soros Management 888 7th Avenue Suite 3300 New York, NY 10106, is a Member of: the

Council on Foreign Relations, the Carlyle Group, Major Stockholder: Halliburton, Financial

Backer of Barack Hussein Obama, Friend of Rupert Murdoch (9), and a high level

Freemason.

139. Defendant George Soros proves his allegiance to Rome by promoting Muslim

Brotherhood overt control of Egypt---now a reality. We cannot forget that the Jesuits in

Cairo created the Muslim Brotherhood in 1928, the same year the Order created Opus Dei

in Spain. Egypt is to be the staging base for an Islamic invasion into Israel from the South-

--somewhat like the 1973 Yom Kippur War that was intended not to succeed in destroying

the Pope's Revived Latin Kingdom of Jerusalem (Israel) as the Third Temple must be built

with Jews in Jerusalem acting as a buffer between the Pope's Masonic Labor Zionist

leaders of Israel and resident Arab Muslim "Palestinians," the invasion will serve as the

justification for a US and possible EU military intervention during which time the Temple

Mount Mosques will be destroyed, and that destruction will be blamed on the U.S.A.

thereby inciting the unity of international Sunni Islam and its future invasion of U.S. soil.

140. According to investigative Journalist Aaron Klein, as of February 10, 2011,

Defendant Soros created an international securities fund for the “Country of Palestine”, in

which Defendants Soebarkah and Soros are major shareholders to benefit.

141. Investigative journalist Aaron Klein, Jerusalem bureau chief for World Net Daily,

9
Rupert Murdoch is a Member: Council on Foreign Relations, Knights of St. Gregory, Owner: Fox
News Network and News Corp / Twentieth Century Fox, Friend of George Soros, Occult Protector of
Barack Hussein Obama Bill O’Reilly – The O’Reilly Factor and Glenn Beck

Verified Complaint Page 38 of 45


reports of collaborative actions of both Defendants Soros and Brzezinski that:

An international “crisis management” group led by philanthropist billionaire George


Soros has long petitioned the Egyptian government to normalize ties with the
Muslim Brotherhood.

The International Crisis Group, or ICG, also released a report urging the Egyptian
regime to allow the Brotherhood to establish an Islamist political party.

The ICG includes on its board Mohamed ElBaradei, one of the main opposition
leaders in Egypt, as well as other personalities who champion dialogue with Hamas,
a violent offshoot of the Muslim Brotherhood.

In a June 2008 report entitled “Egypt’s Muslim Brothers Confrontation or


Integration,” Soros’ ICG urges the Egyptian regime to allow the group to participate
in political life.

The report dismisses Egypt’s longstanding government crackdown on the Muslim


Brotherhood as “dangerously short-sighted.”

The ICG report called on President Hosni Mubarak’s regime to “pave the way for the
regularization of the Muslim Brothers’ participation in political life,” including by
allowing for the “establishment of a political party with religious reference.”

The ICG specifically stressed allowing the Brotherhood to serve as an Islamist party
several times in its 2008 report.

The ICG and its personalities have long petitioned the Muslim Brotherhood to be
allowed to join the Egyptian government.

WND reported earlier this week Soros is one of eight members of the ICG executive
committee.

ElBaradei suspended his board membership in the ICG two weeks ago, after he
returned to Egypt to lead the anti-Mubarak protests.

U.S. board members include Zbigniew Brzezinski, who was national security adviser
to Jimmy Carter; Samuel Berger, who was Bill Clinton’s national security adviser;
and retired U.S. ambassador Thomas Pickering, who made headlines in 2009 after
meeting with Hamas leaders and calling for the U.S. to open ties to the Islamist
group.

Another ICG member is Robert Malley, a former adviser to Obama during the 2008
presidential campaign who resigned after it was exposed he had communicated with
Hamas. WND first reported Malley had long petitioned for dialogue with Hamas.
The ICG defines itself as an “independent, non-profit, multinational organization,
with 100 staff members on five continents, working through field-based analysis and
high-level advocacy to prevent and resolve deadly conflict.”

Verified Complaint Page 39 of 45


Meanwhile, Soros also has other ties to opposition groups in the Middle East.
His Open Society Institute’s Middle East and North Africa Initiative has provided
numerous grants to a wide range of projects that promote so-called democratic
issues across the region, including in Egypt, where the Muslim Brotherhood stands
to gain from any future election.

Soros’ Open Society also funded the main opposition voice in Tunisia, Radio Kalima,
which championed the riots there that led to the ouster of President Zine El Abidine
Ben Ali.

In September, Soros’ group was looking to expand its operations in Egypt by hiring a
new project manager for its Egyptian Initiative for Personal Rights, which is run in
partnership with the Open Society Justice Initiative. The group is seeking to develop
a national network of legal empowerment actors for referral of public-interest law
cases. Such organizations in the past have helped represent Muslim Brotherhood
leaders seeking election or more authority in the country.

Soros himself on Friday made public statements in support of the protests in Egypt,
which the Mubarak government has warned will result in the rise of the Muslim
Brotherhood in the country.

In a Washington Post editorial entitled, “Why Obama Has to Get Egypt Right,”
Soros recognized that if free elections were held in Egypt, “the Brotherhood is bound
to emerge as a major political force, though it is far from assured of a majority.”
He stated the U.S. has “much to gain by moving out in front and siding with the
public demand for dignity and democracy” in Egypt.

He claimed the “Muslim Brotherhood’s cooperation with Mohamed ElBaradei … is a


hopeful sign that it intends to play a constructive role in a democratic political
system.”

Soros did not mention his ties to ElBaradei.

Soros did, however, single out Israel as “the main stumbling block” in paving the
way toward transition in the Middle East.

“In reality, Israel has as much to gain from the spread of democracy in the Middle
East as the United States has. But Israel is unlikely to recognize its own best
interests because the change is too sudden and carries too many risks,” he wrote.

SEVENTH CAUSE OF ACTION

(Scheme for Unjust Enrichment, against All Defendants)

142. Plaintiff repeats each and every allegation contained in the First through Sixth

Cause of Action paragraphs 1 through 141 with the same force and effect as though herein

set forth at length.

Verified Complaint Page 40 of 45


143. That based upon information and belief, Russia, Iran , Syria, Saudi Arabia,

Indonesia, Lebanon, Nigeria, Libya, Egypt, Dubai among other sovereign foreign entities

and persons have illegally contributed to the campaign of Defendant SOEBARKAH who

spent $738,812,857 to seize control of the White House and is 46% of the total money raised

for all candidates in the 2008 Presidential Election that compares to three hundred and ten

million spent by Defendant McCain; and as part of the scheme to defraud the Vatican Bank

was used as an intermediary for transfer of funds into its USA landing Banks in New York

that with the release of the banking records of the SOEBARKAH campaign committee will

show substantial illegal foreign involvement to launder funds to buy the presidency as

previously done in the instance of James Riady of the Indonesian Lippo Group for Bill

Clinton in 1992 was not convicted by the DOJ until January 11, 2001.

144. Defendants Penny S. Pritzker, George Soros and their agents bundled foreign

donations for the Soebarkah Campaign with the Vatican landing bank JP Morgan Chase in

New York state (10).

10
There are three direct Vatican Banking mechanisms used to channel money into the
United States:
(i) The Vatican Bank number UID# 014780 BIC/SWIFT : IOPRVAVX a.k.a ISTITUTO PER
LE OPERE DI RELIGIONE of VATICAN CITY in the VATICAN CITY STATE and for which there
are seven (7) banking participants as the landing banks for international wire transfers into the
USA and who directly benefited by putting Obama into office: 0001 THE BANK OF NEW YORK
MELLON; 0002 JPMORGAN CHASE BANK, N.A.; 0008 CITIBANK, N.A.; 0103 DEUTSCHE
BANK TRUST CO AMERICAS; 0108 HSBC BANK USA; 0256 STANDARD CHARTERED BANK;
0509 WELLS FARGO NY INTL FKA WACHOVIA; needless to say the Vatican Bank and the
participating banks are generally owned by the Vatican through the Rothschild who have managed
the Vatican asset since 1824 and keep that control tightly within the family circle even as far back as
Alexander Hamilton who having married a Rothschild cousin setup the Bank of New York in 1784
that only after great effort became chartered after 1791 when he became the US Treasurer; and
(ii) further, the International Catholic Union of the Press (UCIP) is used for the World
Forum of Professionals and Institutions in Secular and Religious Media with the Address: UCIP, CP
197, 1211 Geneva 20, Switzerland and the Vatican name of the account holder: UCIP with the name
of the Bank: IOR, Vatican Swiftcode: IOPRVAVX Account number in Europe: 16586001
http://www.ucip.ch/une/ib.htm and in which the Vatican Interbank clearing account in the US is
with JPM CHASE MANHATTAN BANK NEW YORK Account no.: 001-1-97500; and
(iii) further yet, The Vatican Bank: ISTITUTO PER LE OPERE DI RELIGIONE =
INSTITUTE FOR THE RELIGION WORKS in which the Institute for Works of Religion (Italian:

Verified Complaint Page 41 of 45


145. That Defendants Pritzker and Soros have managed a crucial role for the Vatican

State as a member of the CFR and high level Freemasonry and in conjunction with King

Juan Carlos (the King of Jerusalem) to create global regionalism that subsumes national

sovereignty of the USA and the People of New York state to the detriment of plaintiff and

those similarly situated.

146. Each of the Candidate Defendants and their agents have been unjustly enriched by

the referenced activities to disrupt the election without assuring a duly eligible Presidential

Candidates for the Republican, Democrat and Socialist Workers party under color of state

law, that violates Plaintiff’s and those similarly situated State voter right, imposing

expense as a taking as applies in its entirety with election costs levied upon real property.

147. That Defendant SOEBARKAH used campaign finance committees nationally and in

New York State according to records maintained by the Defendant NYS BOE include but

are not limited to: OBAMA FOR AMERICA by Martin H. Nesbitt (11), Treas. PO Box 8102

Chicago, IL 60680 ; OBAMA VICTORY FUND by Andrew Tobias, Treas. 430 South

Capitol Street SE Washington DC 20003; among others used exclusively in New York state;

and that Defendant Soebarkah conspired with Defendant Nancy Pelosi individually with

place of business located at Washington, D.C. Address 235 Cannon House Office Building

Washington, DC 20515-0508, along with the DEMOCRATIC STATE COMMITTEE OF

THE STATE OF NEW YORK located at 461 Park Avenue South New York, NY 10016 ,

STATE COMMITTEE OF THE WORKING FAMILIES PARTY OF NEW YORK STATE

located at 2-4 Nevins Street Floor 3 Brooklyn, NY 11217 and XYZ JOINT FUNDRAISING

COMMITTEES to use the funds associated with the campaign.

Istituto per le Opere di Religione - IOR) commonly known as Vatican Bank was formed during World
War 2 and is located inside the Vatican City.
11 The Parking Spot: Ms. Pritzker is co-founder and chairman of The Parking Spot, an off-site

airport parking Management Company.http://www.theparkingspot.com/

Verified Complaint Page 42 of 45


148. That Defendant John Sidney McCain III, individually then located at 3501 North

24th Street Phoenix, AZ 85016 used campaign finance committees nationally and in New

York state according to records maintained by the Defendant NYS BOE, and that include

but are not limited to the MCCAIN VICTORY 2008 located at 228 S WASHINGTON ST

STE 115 ALEXANDRIA, VA 22314; MCCAIN-PALIN VICTORY 2008 & The New York

Finance Committee Road to Victory Tour located at 228 S WASHINGTON ST STE 115

ALEXANDRIA, VA 22314, and that Defendant John Sidney McCain located at Campaign

Address 2211 East Camelback Road Phoenix, AZ 85016 and place of business at

Washington, D.C. Address 241 Russell Senate Office Building Washington, DC 20510,

conspired with Defendant John A. Boehner, individually along with THE NEW YORK

STATE REPUBLICAN STATE COMMITTEE located at 315 STATE ST, ALBANY, NY

12210-2001 , THE NEW YORK STATE COMMITTEE OF THE INDEPENDENCE PARTY

located at Frank MacKay, Chairman Independence Party of New York State PO BOX 871

Lindenhurst, NY 11757, STATE COMMITTEE OF THE CONSERVATIVE PARTY OF

NEW YORK STATE located at 486 78TH STREET BROOKLYN, NY 11209, and XYZ

JOINT FUNDRAISING COMMITTEES to use the funds associated with the campaign.

149. That Defendant Róger Calero, individually used campaign finance committees

nationally and in New York state according to records maintained by the Defendant NYS

BOE, and that include but are not limited to persons associated with THE SOCIALIST

WORKERS PARTY located at Committee Address: 1000 Grand Concourse, #4A Bronx, NY

10451, read more: http://www.city-data.com/elec08/CALERO.html#ixzz14RIyR4iu , and

XYZ JOINT FUNDRAISING COMMITTEES to use associated funds with the campaign.

150. That all the Defendants are liable having been culpable to jointly and severally aid

and abet soliciting and false billing of Defendant Presidential Candidate campaigns with

associated funds from the New York state taxpayers in the excess of say $10,000,000.00 or

Verified Complaint Page 43 of 45


more, are liable for the cost of elections, with interest, and cost of suit caused by the fraud.

WHEREFORE,Plaintiff wishes a preliminary injunction hearing with declaratory


judgment with a partial summary judgment under CPLR $3001 against the Defendants

and such other relief as the Court deems just including:

a. Order of Injunction and restraint upon NYS BOE and various agents with

authority over the State political Parties and Presidential Candidates with

. entities presenting certification for ballot access process preparatory for the

various State party primaries and a t the November 6,2012 General Election to

comply to NYSC regulations ballot access requirements for a candidate to

provide proof of eligibility as with the United States Constitution Article 2

Section 1Clause 5.

b. That all certification submissions duly approved by the NYS BOE and its agents

be submitted to the Court for proof of compliance until further notice;

c. Restraint against interference by the Jesuit Order in New York and a

Preliminary injunction requiring compliance with NYS Chap. 6 Article 5-A.

d. That the Court order expedited discovery to determine the scope of the alleged

$12,000,250.00 ,or more actual damages plus after conducting hearings and jury

trial to determine the scope of punitive treble damages;

e. And for further and different relief as the Court may deem necessary herein.

Dated: .March. rn 2011


Brooklyn,New York

self-represent without being an attorney


593 Vanderbilt Avenue #281,
Brooklyn, New York 11238.
(845) 901-6767 E-mail: chris@strunk.ws

Verified Complaint Page 44 of 45


VEFUFICATION AFFIDAVIT

STATE OF NEW YORK )


) se.
COUNTY OF KINGS 1

Accordingly, I, Christopher Earl Strunk,being duly sworn, depose and say under
penalty of perjury:
I have read the foregoing Complaint with seven Causes of Action against Defendants

in their official capacity and or individually, in which Plaintiff requests a preliminary

Injunction with restraint of the NYS Board of Elections and its agents, and Declaratory

Judgment for equity relief a s well as for say $12,000,250.00in damages plus treble

damages determined a t a jury trial; and know the contents thereof apply to me by

misapplication and administration of laws in creation of the New York Electoral College

going into and following the General Election of November 4,2008a s a continuing injury

caused by the scheme to defraud with unjust enrichment that affects Plaintiff and

Plaintiffs AD HOC Brooklyn Home Rule Coalition along with those similarly situated; the

same is true to my own knowledge, except as to the matters therein stated to be alleged on

information and belief, and a s to those matters I believe it to be true. The grounds of my

beliefs as to all matters not stated upon information and belief are as follows: 3d parties,

books and records, and personal knowledge.

..'..
christopher-Earl: Strunk ."-.
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Sworn to before me '3.q'.- 3 -'\ -." S
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This Jday of March 201 1 >-y -.' " ----
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Commi~lonExpires February 28,M I 5

Verified. Complaint Page 45 of 45


SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS Index NO.: b
-------------------------------------------------
X
Christopher-Earl: Strunk, in esse
Plaintiff, Filed: March 22,20 11
-again&-

NEW YORK STATE BOARD OF ELECTIONS;JAMES A.


WALSH I Co-Chair, DOUGLAS A. KELLNER / Co-Chair,
EVELYN J. AQUILA 1 Commissioner, GREGORY P.
PETERSON / Commissioner, Deputy Director TODD D.
VALENTINE, Deputy Director STANLEY ZALEN;
ANDREW CUOMO, ERIC SCHNEIDERMAN, THOMAS P.
DINAPOLI, RUTH NO EM^ COLON, in their Official and
individual capacity; Fr. JOSEPH A. O'HARE, S.J.;
-
Fr. JOSEPH P. PARKES, S.J.; FREDERICK A.O. SCHWARZ, JR.;
PETER G. PETERSEN; ZBIGNIEW KAIMIERZ BRZEZINSKI;
MARK BRZEZINSKI; JOSEPH R. BIDEN, JR.; SOEBARKAH
( a k a . Barry Soetoro, a.k.a. Barack Hussein Obama 11,
a.k.a. Steve Dunham); NANCY PELOSI; DEMOCRATIC -
-
=*:
..-
STATE COMMITTEE OF THE STATE OF NEW YORK; I
;, 1
STATE COMMITTEE OF THE WORKING FAMILIES
PARTYOF NEW YORK STATE; R ~ G E RCALERO;
THE SOCIALIST WORKERS PARTY; IAN J. BRZEZINSKI;
JOHN SIDNEY MCCAIN 111; JOHN A. BOEHNER;
THE NEW YORK STATE REPUBLICAN STATE COMMITTEE;
THE NEW YORK STATE COMMI?TEE OF THE
INDEPENDENCE PARTY; STATE COMMITTEE OF
THE CONSERVATIVE PARTY OF NEW YORK STATE; .
PENNY S. PRITZKER; GEORGE SOROS; OBAMA FOR
AMERICA; OBAMA WCTORYFUAQ MCCAIN WCTORY
2008; MCCRTN-PUN PTCTORY2008;; John and Jane Does;
and XYZ Entities.

Defendants.
................................................................................. X

SUMMONS

VERIFIED COMPLAINT
Dated: March 22,2011
Brooklyn, New York
Christopher-Earl: Strunk, in esse plaintiff
593 Vanderbilt Avenue #281,
Brooklyn, New York 11238
(845) 901-6767 E-mail: chris@strunk.ws

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