IN THE COURT OF COMMON PLEAS
WARREN COUNTY, OHIO
Memorandum to Complaint
Filed in Warren County Ohio
XXXXX X XXXX
xxxx XXXXXXXXXXX XXXX
XXXXXXXXX, OH xxxxx
XXXXXX XXXXXX, Oh xxxxx
Case # 20CV093603
Plaintiff,
vs.
Tom Perez et al
Chairperson of the Democratic National Committee
430 South Capitol Street South East
Washington, DC 20003
Kamala Harris
Senator from California
Candidate for Vice-President
112 Hart Bldg
Washington, DC 20510
Joe Biden Democratic Nominee
918 Pennsylvania Ave S. E.
Washington, DC 20003, USA
Private home address not available
Warren County Ohio Democratic Party
No Chairman Listed
1975 North Route 42
Lebanon, Ohio 45036
Ohio Democratic Party
David Pepper Chairman
340 East Fulton Street
Columbus, Ohio 43215
1. MEMORANDUM IN SUPPORT OF PLAINTIFF`S MOTION FOR AN INJUNCTIVE RELIEF ORDER
1.1 Plaintiff David M. Neal (hereinafter “Plaintiff”) hereby offers this memorandum in support of his motion for injunctive relief, to demand performance of Constitutional Presidential Requirements of the DNC, Joe Biden, Warren County Ohio Democratic Party, candidate Kamala Harris, and the Ohio Democratic Party in relation to the upcoming 2020 national election.
1.2 Plaintiffs complaint challenges the Vice Presidential candidate Senator Kamala Harris's eligibility to run and hold the office of Vice President and demands that Kamala Harris, Joe Biden, Democratic National Committee (hereinafter “DNC”) and the Warren County Ohio Democrat party by acquisition of existing Law and Senate Resolutions, then remove Kamala Harris name from the Ohio National Election Ballot for being ineligible for the office.
1.3 Plaintiff argues that since there is no legislative requirement other than accepting the political parties assurance that their candidate is eligible, the Ohio Secretary of State, which is the head election official in the state of Ohio has no idea whether the candidate is eligible or not. We, the voters, are left to the qualms and lies of the political parties to be told if their candidate is eligible or not. Only when their noses are held to the book of law will they tell the truth. The proverbial Fox is guarding the hen house and the voters are not OK with that.
1.4 Plaintiff argues that Kamala Harris, Joe Biden and the DNC have the Constitutional and Statutory obligations to make the legal and correct determinations as part of the certification process of the eligibility of Vice Presidential candidate Kamala Harris.
1.5 Plaintiff seeks a focused and expedited review, to protect the veracity and integrity of the electoral process and maintain the peoples confidence in government and elections.
1.6 Plaintiff argues that it is only sufficient to show reasonable cause for complaint to the Democratic National Party et al as to require documentation of the respective candidate relevant to the determination of minimum qualifications based on the criteria as enumerated within the United States Constitution, Article 2 Section 1 Cl. 5.
2. COMPLAINT FOR INJUNCTIVE RELIEF – PRELIMINARY STATEMENT
2.1 "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".
2.2 Senator Kamala Harris is a candidate for United States Office of the Vice President. However, Kamala Harris must meet the requirements specified for the United States Office of President, which is, she must be a “natural born”citizen” as stated in the 12th Amendment. Kamala Harris has failed to demonstrate that she is a natural born citizen based on the status of her parents citizenship at the time of Kamala Harris birth. Her parents being legally domiciled in the US is not an exemption for the requirement to be born of two citizen parents. There are other legal challenges before the Federal Courts regarding the aspects of lost or dual citizenship, in addition to the legal challenges filed against Harris in other states. Those challenges in and of themselves further demonstrates plaintiffs argument that reasonable doubt exists as to the veracity of the electoral process that would allow such fundamental questions to exist at this late hour preceding the election.
2..3 At this point Kamala Harris has not allowed independent or official access to the naturalization papers of her parents with dates to determine when they naturalized and when candidate Harris was born in relation to that process. but Wikipedia states at the time of her birth her father was not naturalized at that time and there is no known record of her mother ever naturalizing.
2.4 The DNC is responsible for the veracity of the candidate they put forward in the Ohio State election process. From verifying ahead of time the qualifications of the candidate, but also the name on the ballot. The DNC is supposed to be non-biased and to provide a critical sense of fairness and honesty necessary for the people to have faith in the fundamental underpinnings of the democratic basis for our Republic.
2.5 There is a reasonable and common expectation by the people that to qualify for the ballot that the individuals so listed meet the minimum requirements as outlined in the Constitution and that proof of those minimum requirements has been received by the officials executing the election process.
2.6 This complaint of failure to carry out a key task in our election system could be satisfied should verification of candidate requirements be received by the Secretary of State from the DNC, RNC or any political party based on what the constitutions say, both state and federal.
2.7 To avert likely civil unrest and a constitutional crisis, in today's political climate of rioting, looting and burning which would certainly accrue after the election, not to mention the laborious legal challenges and impeachment process, this complaint seeks to resolve such dilemma, prior to the election. It is incumbent on the candidate and political party to be honest of their citizenship qualification situations, but to date Ms. Harris has failed to do so.
2.8 This complaint seeks to verify through Tom Perez and the Democrat National Committee what law they think makes a 14th amendment citizen, born to foreign parents like Kamala Harris, a natural born citizen eligible for the office of President or Vice President.
2.9 This complaint seeks specifically through the office of the Ohio Democrat Party and the Warren County Ohio Democratic Party, what law they think makes a 14th amendment citizen, born to parents with a foreign allegiance, like Kamala Harris, a natural born citizen.
3. According to the FBI, unless your name is Trump, the FBI does not investigate candidates eligibility prior to elections.
3.1 Jurisdiction and Venue
3.2 As we do not have a federal election ballot per se, Ohio State through its office of the Secretary of State creates its own ballot and supervises the same, electing electors to represent our choice for the office of President and Vice President. This case arises under the Ohio Constitution, Article XVII and ORC 3505 and the laws of the United States and presents a Federal, State and County question within this courts jurisdiction. Article 104 of the Constitution states that local courts have jurisdiction ‘in all judicial matters not assigned to the Federal Courts under the Constitution’
4. Parties
4.1 Defendant, Kamala Harris, is an adult individual with an office address of112 Hart Bldg Washington, DC 20510
4.2 Defendant, Tom Perez, is an adult individual with an office address of 430 South Capitol Street South East Washington, DC 20003
4.3 Defendant, Joe Biden, is an adult individual with an office address of 918 Pennsylvania Ave S. E. Washington, DC 20003, USA
4.4 Defendant David Pepper, is an adult individual with an office address of 340 East Fulton Street Columbus, Ohio 43215
4.5 Warren County, Ohio Democratic Party, is made up of adult individuals with an office address of 1975 North Route 42 Lebanon, Ohio 45036 No Chairman Listed
5.0 FACTUAL ALLEGATIONS THAT DEMONSTRATE THE NEED TO PROVE THE CANDATES MINIMUM CONSTITUTIONAL QUALIFICATIONS
5.1 These allegations are not intended to show proof of the status of Kamala Harris citizenship or lack thereof. This hopefully, will be determined in the venue of this court. Since 2007 there have been 7 candidates run for the highest office in this land that were not eligible. The listing of the allegations below are included to demonstrate the reasonable assertion of the need for this Court to step in and reestablish public confidence in the veracity and integrity of the electoral process and the obvious need for this court to look further into these attempted frauds, that we have witnessed for the last 12 years as to a candidate meeting the minimum constitutional requirements. The Secretary of State for Ohio was made aware of this deficiency in 2008, and nothing was done to fix it. The Ohio state legislature was made aware of this problem in 2008 and nothing has happened to fix it. It is time this court steps in immediately to remedy this problem and not kick the can down the road any longer on this subject.
5.2 Plaintiff submits that Kamala Harris was born in Oakland, California, on the 20th of October 1964.
5.3 Harris’s mother is from Tamil Nadu, India; she emigrated from Chennai in India in 1960. Her name was Shyamala Gopalan Harris and she was born in 1938. She died in 2009.
5.3.1 Kamala’s father, Donald Harris, is a retired Stanford University economics professor whose biography affirms that he arrived in the U.S. in 1961 as an “Issa Scholar” from Jamaica. It adds that he was born in Jamaica and naturalized in the U.S. but the date is unknown. Neither parent reportedly was present in the U.S. as a legal resident for the requisite five years prior to Harris’s birth, a requirement before her parents can apply for naturalization, making Kamala Harris a 14th amendment native born citizen of foreign parents.
5.3.2 To be a natural born citizen one cannot hold dual citizenship. She automatically acquires both her parents citizenship and allegiance at birth making her Jamaican / Indian and American. To be a US natural born citizen one needs to be 100% American. You cannot be a dual citizen and be Article II Sec 1 eligible.
5.3.3 Plaintiff suggests that to understand the 14th amendment one needs to read the published writings on the thoughts and discussions that went on in the congressional deliberations of the 14th amendment.
5.3.4 Sen. Jacob Howard and Sen. Lyman Trumbull, made it clear that “jurisdiction”, as used in the 14th amendment, means sole and complete U.S. jurisdiction, ie., not subject to any foreign power.
5.3.5 In 1866, Senator Jacob Howard clearly spelled out the intent of the 14th amendment by stating: "Every person born within the limits of the United States, and subject to their jurisdiction, is by virtue of natural law and national law a citizen of theUnited States. This will not, of course, include persons born in the United States who are foreigners, aliens, who belong to the families of ambassadors or foreign ministers accredited to the Government of the United States, but will include every other class of persons. It settles the great question of citizenship and removes all doubt as to what persons are or are not citizens of the United States. This has long been a great desideratum in the jurisprudence and legislation of this country." (See Exhibit J Madison 14th explained).
5.3.6 Senator Howard`s intention of the 14th amendment was reaffirmed by Senator Edward Cowan, who stated: "[A foreigner in the United States] has a right to the protection of the laws; but he is not a citizen in the ordinary acceptance of the word..."
5.3.7 Again, we are fortunate to have on record the highest authority to tell us, Sen. Lyman Trumbull, Chairman of the Judiciary Committee, author of the 13th amendment and the one who inserted the citizenship phrase into the 14th amendment, stated:[T]he provision is, that 'all persons born in the United States, and subject to the jurisdiction thereof, are citizens.' That means 'subject to the complete jurisdiction thereof.' What do we mean by 'complete jurisdiction thereof?' Not owing allegiance to anybody else. That is what it means.
5.3.8 Known in that time as the Citizenship Clause, it is contained in Section One of the Fourteenth Amendment. The clause conferred U.S. and state citizenship to all freed black slaves and at birth to individuals born in the United States to citizen parents . [T]he provision is, that 'all persons born in the United States, and subject to the jurisdiction thereof, are citizens. ' That means 'subject to the complete jurisdiction thereof. ' What do we mean by complete jurisdiction thereof? ' Not owing allegiance to anybody else. That is what it means. Kamala Harris inherited her foreign allegiance from her foreign parents at birth.
5.3.9 Just like the words “natural born” cannot be removed from Article II Sec. I Cl. 5, they cannot be added to the 14th amendment either.
5.4 In 1866, two years before the 14th amendment, by U.S. statute Sec. 1992 of U.S. Revised defined who is a citizen: “All persons born in the United States and not subject to any foreign power … are declared to be citizens of the United States”.
5.5 The Supreme Court in Inglis v.Trustees (1830) and Elk v. Wilkins (1884) ruled that a child born on U.S. soil, of a father who owes allegiance to a sovereignty other than the United States (a foreigner), is not a U.S. citizen at birth; and that the citizenship of such a child is that of its father, not its place of birth.
5.5.1 Kamala Harris would have been classified as a foreigner in 1830 and 1884, even 1897, how can she now be a natural born citizen in 2020? She is whats referred to as an “AnchorBaby”. She derived her “birth right citizenship” from a statutory law, so how can one be a foreigner in 1897 and be a natural born citizen in 2020? Nowhere in any law prior to 1897 would she have even been classified as a citizen, let alone a natural born citizen.
5.6 Plaintiff submits to start from the beginning:with the text of the Constitution. In the relevant part, Article II, Section 1 Clause 5 it reads: "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".
5.7 Plaintiff submits the language of the 14th amendment: "All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are CITIZENS of the United States and the State wherein they reside."
5.7.1 Plaintiff submits the pertinent part of the12th amendment: “But no person constitutionally ineligible to the office of President shall be eligible to that of Vice-President of the United States”.
5.8 Plaintiff submits Article II Section 1 Clause 5 says that only those CITIZENS that were present at the signing of the constitution will be eligible for president, after that it take a natural born citizen.
5.9 Plaintiff submits the 14th amendment was just an extension of existing law. In 1866, two years before the 14th Amendment, by U.S. statute Sec. 1992 of U.S. Revised defined who is a citizen: “All persons born in the United States and not subject to any foreign ower… are declared to be citizens of the United States”.
6.0 Plaintiff submits that to be a natural born citizen simply means to be born on US soil to two US citizen parents as will be shown..The children born to the citizens after the signing of the constitution became the first natural born citizens. Jus Soli and Jus Sanquinis.
6.1 Plaintiff submits ‘Natural-Born Citizen’ as defined by one of the people responsible for the writing of the 14th Amendment who knew all about the definitions of the various types of US citizenship, Ohio Representative John Bingham requires 3 things: that you are born within the jurisdiction of the United States, that BOTH parents are citizens of the U.S. either by naturalization OR by being natural born themselves AND that both parents must NOT owe ANY ALLEGIANCE to ANY FOREIGN country.
6.2 Nowhere in the 14th amendment does it make anyone a natural born citizen. Only a citizen the same as a naturalized citizen.
6.2.1 In Zimmer v. Acheson which was decided in the US Court of Appeals for the 10th Circuit (1951) demonstrates that statutory citizenship, as in the 14th amendment, is in fact a form of “naturalized” citizenship. Persons in whom citizenship is vested by such statutes are naturalized citizens and not natural-born citizens. Zimmer v. Acheson, 10 Cir., 1951, 191 F.2d 209, 211;
6.2.2 Plaintiff submits that is why the 14th amendment has always been referred to as the CITIZENship clause. No where in the 14th amendment does it make anyone natural born.
6.3 Plaintiff submits that the definition of natural born citizen has been settled several times only to be argued again because it interferes with peoples progressive political agendas.
6.4 The Constitution states the Congress shall have the only power to determine a ‘naturalization process’ for citizens and who will be classified under the process as U.S. Citizens. In order to determine who would be eligible to become naturalized U.S. Citizens, the House of Representatives had to define what a ‘natural born citizen’ was. In 1862 during the 37th Congressional debate on the 14th amendment, Ohio Representative John Bingham, known as the Chief Architect and Father of the 14th Amendment stated: “All from other lands, who by the terms of [congressional] laws and a compliance with their provisions become naturalized, are adopted citizens of the United States; all other persons born within the Republic, of parents owing allegiance to no other sovereignty, are natural born citizens. Gentleman can find no exception to this statement touching natural-born citizens except what is said in the Constitution relating to Indians.” (Cong. Globe, 37th, 2nd Sess., 1639 (1862))
6.5 In 1866, during 14th amendment House debates, Ohio Representative John Bingham, stated: “I find no fault with the introductory clause, which is simply declaratory of what is written in the Constitution, that 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; but, sir, I may be allowed to say further, that I deny that the Congress of the United States ever had the power or color of power to say that any man born within the jurisdiction of the United States, and not owing a foreign allegiance, is not and shall not be a citizen of the United States.” John A. Bingham, (R-Ohio) US Congressman, Architect of Section 1 of the 14th Amendment, March 9, 1866, Cong. Globe, 39th, 1st Sess., 1291 (1866), Sec. 1992 of U.S. Revised Statutes (1866), Cf. U.S. Const. XIVth Amend.
6.6 Additionally in 1872, Bingham again defined ‘natural-born citizen’ during a House Floor hearing regarding the status of U.S. citizenship of Dr. Houard, who had been incarcerated in Spain. Here he clearly states 2 requirements for being natural born…born to citizen parents (mother and father) and within the jurisdiction of the United States: “As to the question of citizenship I am willing to resolve all doubts in favor of a citizen of the United States. That Dr. Houard is a natural-born citizen of the United States there is not room for the shadow of a doubt. He was born of naturalized parents within the jurisdiction of the United States, and by the express words of the Constitution, as amended to-day, he is declared to all the world to be a citizen of the United States by birth.” (The term “to-day”, as used by Bingham, means “to date”.
6.6.1 Plaintiff submits Senator Reverdy Johnson said in the debate on Hourd: “Now, all this amendment provides is, that all persons born in the United States and not subject to some foreign Power–for that, no doubt, is the meaning of the committee who have brought the matter before us–shall be considered as citizens of the United States…If there are to be citizens of the United States entitled everywhere to the character of citizens of the United States, there should be some certain definition of what citizenship is, what has created the character of citizen as between himself and the United States, and the amendment says citizenship may depend upon birth, and I know of no better way to give rise to citizenship than the fact of birth within the territory of the United States, born to parents who at the time were subject to the authority of the United States
6.6.2 In this Rep. Bingham and Senator Johnson cite 3 factors that declares Dr. Houard to be a “natural-born citizen”: born of citizen “parents” (plural not singular therefore requiring you to have 2 U.S. Citizen parents for this status) AND born within the ‘jurisdiction of the United States and owing allegiance to no other country. Known throughout history as the three legged stool test. If one leg is missing then the stool will not stand.
6.7 Minor v. Happersett 88 U.S. 162 (1874), U.S. Supreme Court case in which the court ruled unanimously: "The Constitution does not, in words, say who shall be natural-born citizens. Resort must be had elsewhere to ascertain that. At common-law, with the nomenclature of which the framers of the Constitution were familiar, it was never doubted that all children born in a country of PARENTS (plural) who were its CITIZENS (plural) became themselves, upon their birth, citizens also. These were natives, or natural-born citizens, as distinguished from aliens or foreigners.". Minor was unanimous and written by Chief Justice Morrison Waite. The nomenclature Waite speaks of at the time was the same as Vattel`s book: The Laws of Nations or The Principles of the Laws of Nature In Book I, Chapter 19, § 212, of the English translation of 1797 (p. 110) Vattel describes what is meant by the term Natural Born Citizen: The natives, or natural-born citizens, are those born in the country, of parents who are citizens.
6.8 Over the course of this country’s history , at least 5 separate U.S. Supreme Court decisions have recognized the same terms as Vattel for being a natural born citizen, with some of these citing Vattel specifically, and others only providing the definition.
1814 – The Venus, 12 U.S. (8 Cranch) 253, 289, (cites Vattel’s definition of natural born citizens)
1857 – Scott v. Sanford, 60 U.S. 393, (Justice Daniel concurring uses same definition and cites Vattel) Link
1875 – Minor v. Happersett, 88 U.S. 162, 167-681884, (same definition without citing
Vattel); Link
1879 – Ex Parte Reynolds, 1879, 5 Dill., 394, 402 (same definition and cites Vattel); Link
1890 – United States v. Ward, 42 F.320 (C.C.S.D.Cal.) (cites and quotes Ex Parte Reynolds, same definition and cites Vattel); Link By somewhat less direct argument:
1872 – Slaughter-House Cases, 83 U.S. 36, 21 L.Ed. 394, 16 Wall. 36 Link
1884 – Elk v. Wilkins, 112 U.S. 94 Link
6.9 British jurist Matthew Bacon recognized the original terms of “natural born subject” to be the same as Vattels: “All those are natural-born subjects whose parents, at the time of their Birth, were under the actual Obedience of our King, and whose Place of Birth was within his dominions”. (Matthew Bacon, A New Abridgment of the Law, 1736, Vol 1, pg 77)
6.9.1 Plaintiff submits the concept of being Natural Born and having advantages over those in a nation state who are not, is not a recent idea and is explained in the ancient history writings of many of our early scholars. In 451 BC, Pericles, a leading Athenian Statesman, introduced legislation, referred to as the Citizenship Law of Pericles, that was to limit the availability of Athenian citizenship to those male children born of two lawfully wedded Athenian citizen parents.
6.9.2 In defining an Article II Natural Born Citizen it is important to find any authority from the founding period who may inform us how the founders and framers themselves defined the clause. Who else but a highly respected historian from the founding period itself would be highly persuasive in telling us how the founders and framers defined a “natural born citizen. ” Such an Important person is David Ramsay, who in 1789 wrote: A Dissertation on the Manners of Acquiring the Character and Privileges of a Citizen (1789), a very important and influential essay on defining a “natural born citizen.” David Ramsay was an American physician, patriot, and historian from South Carolina and a delegate from that state to the Continental Congress in 1782-1783 and 1785-1786. He was the Acting President of the United States as Congress Assembled. He was one of the American Revolution’s first major historians. A contemporary of Washington, Ramsay writes with the knowledge and insights one acquires only by being personally involved in the events of the founding period. In 1785 he published History of the Revolution of South Carolina (two volumes), in 1789, The History of the American Revolution, in 1807 a Life of Washington, and in 1809 a History of South Carolina (two volumes). Ramsay “was a major intellectual figure in the early republic, known and respected in America and abroad for his medical and historical writings, especially for The History of the American Revolution (1789)…” Arthur H. Shaffer, Between Two Worlds: David Ramsay and the Politics of Slavery, J.S.Hist., Vol. L, No. 2 (May 1984). “During the ogress of the Revolution, Doctor Ramsay collected materials for its history, and his great impartiality, his fine memory, and his acquaintance with many of the actors in the contest, eminently qualified him for the task….” In his 1789 article, Ramsay first explained who the “original citizens” were and then defined the “natural born citizens” as the children born in the country to citizen parents. Remember there was no 14th Amendment at this time. He said concerning the children born after the declaration of independence, “[c]itizenship is the inheritance of the children of those who have taken part in the late revolution; but this is confined exclusively to the children of those who were themselves citizens….” Id. at 6. He added that “citizenship by inheritance belongs to none but the children of those Americans, who, having survived the declaration of independence, acquired that adventitious character in their own right, and transmitted it to their offspring….” Id. at 7. He continued that citizenship “as a natural right, belongs to none but those who have been born of citizens since the 4th of July, 1776….” Id. at 6.
6.9.3 Plaintiff submits to more recent times, the US Senate decided the definition of what the constitution means by being a natural born citizen in Senate Resolution 510 in 2008 on John McCain's eligibility to be President. They seem to have forgotten there own definition of what a natural born citizen is. {See Exhibit G Senate Resolution}
6.9.4 In February, The New York Times published a report calling into question the legality of John McCain’s presidential run. McCain was born to American citizens stationed on an American Naval base in the Panama Canal Zone. He has since served in the U.S. Navy, and, since 1983, has served in the U.S. Congress.
6.9.5 WASHINGTON (Thursday, April 10, 2008) – Sens. Patrick Leahy (D-Vt.) and Claire McCaskill (D-Mo.) introduced a resolution expressing the sense of the U.S. Senate that presidential candidate and current Senator John McCain (R-Ariz.) is a ‘natural born Citizen,’ as specified in the Constitution and eligible to run for President.
6.9.6 “Because he was born to American citizens, there is no doubt in my mind that Senator McCain is a natural born citizen,” said Leahy. “I expect that this will be a unanimous resolution of the Senate.” {See Exhibit G Senate Resolution}
6.9.7 “My assumption and my understanding is that if you are born of American parents, you are naturally a natural-born American citizen,” Chertoff replied. “That is mine, too,” said Leahy. {See Exhibit G Senate Resolution}
6.9.8 Based on the understanding of the pertinent sources of constitutional meaning, it is widely believed that if someone is born to American citizens anywhere in the world they are natural born citizens.
6.9.9 Whereas John Sidney McCain, III, was born to American citizens on an American military base in the Panama Canal Zone in 1936: Now, therefore, be it Resolved,That John Sidney McCain, III, is a ‘‘natural born Citizen’’ under Article II, Section 1, of the Constitution of the United States. {See Exhibit G Senate Resolution)
7.0 Plaintiff submits the most recent discussion on this subject is the testimony of American professor of law at Stanford Law School, who was the Star Witness on election integrity for the House Democrats in the Trump impeachment hearing. In her testimony she explains that just plain citizens, like the 14th amendment makes one, cannot be President. She states that all those that become citizens the one thing not available to them is the Presidency. The 14th amendment makes Kamala Harris a CITIZEN and only a citizen. https://www.youtube.com/watch?v=2xBZTUD5QuA&t=2s
7.1 Plaintiff submits that a natural born citizen cannot be a product of any statutory law, and the entire array of U.S. naturalization laws only apply to “citizen” and “citizenship”, and in no way have any relevance to the terms of natural born citizen. Nowhere in the 14th amendment does it use the term "natural born citizen".
7.2 Plaintiff submits that if Osama Bin Laden hadn't been killed and instead was brought to America to stand trial and his pregnant wife came also to observe and gave birth while she was here, then I ask the court would that child be eligible to be President of the United States? No different than what we face with Kamala Harris and her foreign parents.
7.3 Plaintiff submits that if King George III`s grandson and his pregnant wife had slithered into America in say 1800, just a few years after the Revolutionary War, and she gave birth to a child, would that child be eligible to be President of the United States?
7.4 Plaintiff submits that candidate Harris cannot inherit from her parents which they do not possess themselves and that is US citizenship.
8. Wherefore: Plaintiff respectfully prays this court
8.1 Grant injunctive relief demanding Kamala Harris give proof of her parents naturalization dates, if that happened at all.
8.1.1 Plaintiff requests Kamala Harris be made to explain how as a lawyer and former AG of California, how she could not know that 14th amendment citizens born to foreign parents a not eligible to be President.
8.2 If found not eligible to grant injunctive relief demanding Kamala Harris remove her name from the Ohio State Ballot for not meeting the requirements to be President.
8.2.1 Plaintiff requests this court to demand Joe Biden remove Kamala Harris as his running mate on all DNC forms and paperwork for the office of Vice President.
8.2.2 Plaintiff requests injunctive relief demanding the Democratic National Committee remove Kamala Harris name from the Democrat ballot and all advertising in Ohio.
8.3. Plaintiff requests the Warren County Ohio Democratic Party to follow the lead of the Democratic National Committee in removing Kamala Harris name from all Warren County Ohio political advertisements, banners, brochures, yard signs available to the public.
8.4 Plaintiff requests injunctive relief in demanding the Democratic National Committee stop sending forth illegal candidates that are not natural born citizens, they must be born of two citizen parents, for the office of President and Vice President
8.5 Plaintiff Submits the DNC be made to post or make available to all citizens in America that just because you are born on US soil that doesn't make you natural born and this idea needs to be addressed by the court.
8.6 Plaintiff submits this is an on going conspiracy to undermine and erode the Constitution and defraud the people of a legally viable candidate. This is endangering our national security. Can you imagine what our enemies are thinking or planning right now. We look like constitutional fools to even allow this to go this far.
9 Plaintiff begs this court to side with the known intent of the founding fathers not the Democratic National party's agenda to destroy the very document that protects us all.
9.1 Plaintiff submits that by diluting our elections with non qualifying candidates, plaintiff's constitutional rights, as guaranteed in the constitution, are weakened and polluted. Causing a disenfranchisement of plaintiff and all Warren County Ohio voters regardless of party affiliation.
10 Plaintiff submits that what Joe Biden and Kamala Harris are trying to pull off is far more grave to the long term welfare of America than what Julius and Ethel Rosenberg ever did in the late 1940`s. Its up to this court to stop this since no one else will.
10 Plaintiff submits that one of the requisites for obtaining standing is to have a winning case. Plaintiff prays this court has been persuaded to allow this compliant to move forward.
Dated September 23, 2020
Signature of Lawyer or Moving Party WSBA
XXXXX X XXXX
Pro Se
XXXXX X XXXX
xxxx XXXXXXXXXXX XXXX
XXXXXXXXXX, XX xxxxx
xxx-xxx-xxxx
Email:
Verification
I, XXXXX X XXXX,
hereby state that I am the plaintiff in this action and verify that the statements made in the foregoing Complaint for Injunctive Relief are true and correct to the best of my knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of law relating to unworn falsification to authorities. statements made in the foregoing Complaint for Injunctive Relief are true and correct to the best of my knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of law relating to unworn falsification to authorities.
Attached Exhibit G (Senate Resolution on John McCain being a natural born citizen)
Attached Exhibit J (PA Madison on the meaning of the 14th amendment)
26