STATE OF CALIFORNIA                                                                                                




            BEFORE ME, the undersigned Notary, on this ______ day of March, 2009, personally appeared ORLY TAITZ, known to me to be a credible person and of lawful age, who being by me first duly sworn, on her oath, deposes and says:  


1.                  I, ORLY TAITZ, am a resident of Orange County, California. 


2.                  I am duly licensed to practice law within the State of California, US Federal Courts and US Supreme Court, and am engaged in the practice of law as a solo practitioner with the Law Office of Dr. Orly Taitz, located at 26302 La Paz , Suite 211 , Mission Viejo, Orange County , California .  


3.                  I am one of two attorneys representing Dr. Alan Keyes in Cause No. 34‑2008-80000096-CU-WM-GDS, Keyes v. Bowen, brought in the Superior Court of California, County of Sacramento (hereinafter called the "Keyes Case"), alleging in part that Debra Bowen, as the California Secretary of State, improperly certified Barack Hussein Obama aka Barry Soetoro (hereinafter called "Obama") as a US presidential candidate in California after accepting only a signed personal statement from Obama, in which he asserted that he was an eligible candidate, and without demanding any supporting verification, proving that Obama was Constitutionally eligible to be a US President under Article II, Section 1 (4) of the US Constitution.  


4.                  In addition to being an attorney on the Keyes Case and other related matters regarding similar issues associated with the Obama presidency, I have a website, currently located at, which informs the public about the various concerns.  My original blog, located at, was sabotaged, but the number of people visiting my site and working with me to uncover the truth about these matters continues to grow.  After only two (2) months of existence, starting in November 2008, my blog had over eight million (8,000,000) visitors a month.  


5.                  I am fully competent to make this affidavit and have personal knowledge of the facts stated herein and that they are all true and correct.  


6.                  On January 19, 2009, plaintiffs in the Keyes Case issued a Deposition Subpoena for Production of Business Records to the US Department of Justice (hereinafter called the "USDOJ"), which was served on the USDOJ on February 10, 2009.  


7.                  By a letter dated February 18, 2009, counsel for the USDOJ proposed that the Keyes Case plaintiffs and the USDOJ treat plaintiffs’ subpoena as an informational demand under the administrative procedure set out in 28 C.F.R. Part 16 (USDOJ's regulation under United States ex rel. Touhy v. Ragen (1951) 340 U.S. 462, or "Touhy Regulation") instead of as a subpoena.  


8.                  In compliance with that proposal and resulting stipulation in the Keyes Case, this affidavit is being submitted to Lawrence G. Brown, Acting US Attorney and Yoshinori H. T. Himel, Assistant US Attorney for the Eastern District of California, both acting on behalf of Eric Holder, the US Attorney General.  


9.                  The Keyes Case was filed because in spite of Obama’s personal assurances of his eligibility to be a US President, Obama has patently and continually refused to produce his original vault (long form) copy of his Hawaiian birth certificate.  On his own campaign website, Obama acknowledged that he is a "native born" citizen and that his father, Barack H. Obama, Sr. (hereinafter called "Obama Sr."). was a Kenyan native whose citizenship, as well as the citizenship of Obama Sr.’s children, was governed by The British Nationality Act of 1948 and that Obama  had dual citizenship with Kenya until age 21.  


10.              Article II, Section 1 (4) of the US Constitution requires that a US President must be a "natural born Citizen."  Although the Constitution does not define this term, various lawsuits, including US v. Wong Kim Ark, 169 U.S. 649 (1898) and Minor v. Happersett, 88 U.S. 162 (1874) have defined "natural born" to mean a person who was born under the jurisdiction of the United States to two parents who were US citizens. Perkins v. Elg, 307 US 325 (1939) provides examples to distinguish the differences among a "US citizen," a "native born US citizen," as Obama claims to be on his campaign website, and a "natural born US citizen," as required for the eligibility of a US President.  The fact that Obama has openly acknowledged that he is "native born" and not "natural born" and that his father, Obama Sr., was not a US citizen automatically places Obama’s "natural born" citizenship status in question and jeopardy under these definitions.  


11.              Obama’s paternal grandmother, Sarah Hussein Obama, has claimed that she was present, along with Obama’s half-brother and half-sister, when Obama was born in Kenya on August 4, 1961.  No one in Hawaii has come forward to make any similar statement regarding Obama’s birth in Hawaii , nor has any registration for Obama’s mother, Stanley Ann Dunham, or Obama’s birth been found in any Hawaiian hospital, despite in-depth investigations conducted by US citizens.   Although both Obama and his half-sister, Maya Soetoro-Ng, have identified two different hospitals in Hawaii where Obama was purportedly born, neither hospital has provided any proof of Obama’s birth, nor has any proof been found through numerous citizen investigations.  


12.              Although Obama’s mother was a US citizen, she was 18-years-old at the time of his birth.  In the event Obama was born in Kenya, §301(a)(7) of the 1952 Immigration and Naturalization Act, as amended from the 1940 Act, required that his mother be 19-years-old to transfer her US citizenship to any child that was born outside of the US to one US citizen and one alien citizen.  Since Obama Sr. was an alien citizen, Obama’s mother was not old enough under the statute and could not transfer her US citizenship to him.  


13.              Even if Obama was born in Kenya, he could have received a Hawaiian registration of birth under Hawai’i Revised Statutes §338.17-8, which allows a Hawaiian registration of birth for babies born outside of Hawaii, based on the statement of one relative, as long as the parents had resided in Hawaii for at least one year.  Although this registration is a totally different document from a birth certificate for a child who was actually born in Hawaii , both documents are referred to as "original birth certificates" in Hawaii .  Regardless of this "designation," the Hawaiian birth registration is merely a registration of a live birth outside of Hawaii and it does not, nor can it ever, confer "natural born" US citizenship status to a child who was born outside of the US. Additionally Hawaiian Health Department allows certification of Live birth to be issued based on an affidavit of one relative only, which can be biased.  


14.              Despite news reports to the contrary, no Hawaiian official has ever stated that Obama was born in Honolulu in 1961.  Chiyome Leinaala Fukino, M.D., Director of the Hawaii Department of Health, merely stated on October 31, 2008, "I have personally seen and verified that the Hawai'i State Department of Health has Sen. Obama’s original birth certificate on record in accordance with state policies and procedures."  This statement simply confirms that Hawaii has some sort of birth document on file for Obama in its records in accordance with its state policies and procedures, which include Hawai'i Revised Statutes §338.17-8, designating the registration of birth for babies born anywhere outside of Hawaii as "original birth certificates," regardless of the actual location of birth, it could’ve been a certification of live birth obtained based on a statement of one relative only, without any corroborating evidence. §338-18, prohibits the release of a certified birth certificate to persons who do not have a tangible interest in the vital record.  The purpose of the latter statute is to protect the privacy of Hawaii ’s citizens. Hawaiian health department didn’t consider presidency of the United States and all of our National Security to be a tangible interest.  


15.              As a public person seeking, and now functioning in, the office of the US President, Obama had and continues to have a duty to disclose his original vault Hawaiian birth certificate to prove his Constitutional eligibility to hold that position.  When Obama chose to seek public office, he gave up his privacy rights, that Hawaii is seeking to protect for her other citizens under Hawai'i Revised Statutes §338-18.  Yet despite Obama’s verbal affirmations for openness and transparency, he has refused to respond to the repeated requests by US citizens, including over 50 lawsuits on the matter, and has consistently avoided the production of a $10 to $20 birth certificate, which could put this matter to rest.  Instead, he has chosen to hire several law firms around the country to protect his personal records, including birth, college, employment, medical, bar, and passport records, all of which have been sealed.   Each American citizen has a tangible interest in viewing the content of these records.



16.              Obama has continually asserted that a short form Certification of Live Birth (hereinafter called the "COLB"), which he posted online in June 2008, and was "authenticated" only by various pro-Obama internet websites, is a copy of his birth certificate and "evidence" of his eligibility.   This computer-generated, laser printed document is not only lacking in detail, it has been determined by several forensic document examiners to be a forgery, which "cannot be relied upon as genuine." Claims were made that the COLB was obtained in 2007 and may have been further altered in 2008.  Signs of forgery alleged, have included altered lettering on the words, border differentiation from the form’s date, seal, among other indications of forgery.  


17.              Not only does the question exist about Obama’s "natural born" citizenship status, but it is possible that Obama may not be a US citizen at all.  In his book, Dreams from My Father, Obama mentioned that he immigrated to Indonesia with his mother and stepfather, Lolo Soetoro. His school registration from Indonesia state that his name is Barry Soetoro, an Indonesian citizen, registered as a Muslim.  It is illegal under Indonesian law to hold a dual citizenship, and only Indonesian citizens may attend Indonesian schools or obtain Indonesian passports.  Obama acknowledged in a 2008 speech that he traveled to Pakistan, India and Indonesia when he was 20-years-old.  In 1981, Americans were not allowed to travel to Pakistan.  Obama is reported to have traveled to Pakistan (and the other countries) on an Indonesian passport in 1981, after his age of majority.  


18.              Obama moved back to the United States at age 10 to live with his maternal grandparents in Hawaii but, in all likelihood, he was never repatriated to the US , in the event he ever was a US citizen initially.  There is no proof that Obama’s mother ever took an oath of allegiance for her son at any time nor is there proof that she took one for herself after her divorce.  This would have been necessary to do in order to reestablish US citizenship for Obama, since both he and his mother were officially Indonesian citizens.  Nor is there proof that Obama, himself, ever took an oath of allegiance after reaching his majority age (18) to repatriate himself (again, if he ever was a US citizen) nor does it appear that Obama has ever become a naturalized US citizen.  If Obama did travel on an Indonesian passport at age 20, this complicates the issue and indicates that Obama may, in reality, still be an Indonesian citizen, which would make him an illegal alien in the US and not only make him wholly ineligible to be the US President, but also ineligible to be a US Senator, an Illinois state senator or even a voting citizen.    


19.              It is imperative that all questions raised within items 9 through 18 of this Affidavit be answered so that the truth can be uncovered regarding Obama’s natural born citizenship status and illegal alien status.  The truth to these issues and others mentioned herein affect every American and are essential to the preservation and protection of our country, national security and US Constitution.  In the event Obama is ineligible to be a US President, which appears to be the case according to the accepted definition of a "natural born Citizen," as explained in item 10 above, then nothing that Obama does or Congress does while Obama is posing as a US president will have any legal consequence.  If Obama is ineligible to hold the office he portends to hold and is therefore a usurper, our military has no commander in chief to follow.  This is a Constitutional crisis of the highest magnitude and is being silenced within our country through an apparent media blackout on the subject.  Many Americans are unaware that these issues even exist and must be alerted to the truth.  


20.              The Constitutional crisis and national security ramifications of these issues, along with an apparent media blackout on the subject matter (outside of the internet and information provided about this subject on websites like my own), create an urgency to uncover the truth so that the public can be informed about actual or alleged federal government activity.  These issues obviously affect possible questions about the government’s integrity, which will affect public confidence once the information becomes more widespread.  Additionally, there is a potential loss of substantial due process rights for the American public if the truth is not uncovered as soon as possible.  The Obama administration is moving at warp speed to accomplish its goals, but if Obama is ineligible to be a US president, everything that is being "accomplished" will be illegal.  Consequently, time is of the essence in uncovering the truth and I respectfully request that production of the following information, listed below in this item 20, be expedited under §16.5 (d)(1)(i), (ii), (iii) and (iv).  Unfortunately, lack of expedited treatment could reasonably pose an imminent threat to the life or physical safety of many Americans if Obama is ineligible to hold the office of US President.  Additionally, I respectfully request that all fees associated with the production of the following information be waived under §16.11(k), since these requests concern or affect the operations or activities of the government and are likely to contribute significantly to public understanding of government operations or activities:



a.                   Copy of report (possibly 150 pages) and findings of the Inspector General of the DOJ and/or the State Department investigation report regarding the unauthorized employee access to and tampering with Obama’s passport records on at least three separate occasions in 2008, including whether Obama made an original application or renewal of his American passport on his most recent request, when that application or renewal was made, information about whether an original vault birth certificate or Obama’s online COLB was used to prove Obama’s American citizenship status on his original American passport application and the date when Obama made that original application for an American passport;


b. A retired federal agent has provided a number, associated with a report, generated upon Obama’s arrival to US from Far East around 1981. The number is as follows CD E509B TECX SQSQPQ. We are seeking production of that report, as it might help ascertain his citizenship at age 20.  


c.                  Names and contact information for investigators, results of the investigations performed and findings on all of the information and documentation forwarded by numerous American citizens, including individuals in Illinois, Washington, California, Texas, Alabama, Tennessee and Florida to the DOJ and FBI over the past several months about Obama, his personal records and his questionable activities, including, but not limited to:  


i.      Obama’s original vault birth certificate;


            ii.      Proof of Obama’s actual birthplace location and details regarding the investigation into Obama’s potential birth in Kenya and Obama’s potential birth in Hawaii;


iii.      Documentation revealing Obama’s school registration in Indonesia , which shows his name to be Barry Soetoro, citizen of Indonesia ;



iv.      Proof that Obama legally changed his name from his adopted Indonesian name, Barry Soetoro, to Barack Hussein Obama and when his name was legally changed;  


v.      Proof that Obama became a repatriated American citizen after returning to the United States from Indonesia at age 10;  


vi.      Obama’s college records, including the name and country of citizenship that Obama used as a college student;  


vii.      Documentation revealing Obama as a foreign exchange student under the name of Barry Soetoro from 1979 to 1981 and during any other time periods;  


viii.      Obama’s Illinois State Bar records;  


ix.      Obama’s medical records;  


x.      The passport that Obama used in 1981 for his trip to Pakistan;  


xi.      The passport that Obama used in 2006 for his trip to Kenya;  


xii.      The use and purpose of $1 million that "Friends of Senator Barack Obama" contributed to Raila Odinga in 2006 for his Kenyan campaign, reportedly used to fund bloodshed, mayhem and the promotion of Sharia law in Kenya;  


xiii.      Affidavits of expert witnesses concerning the forgery of Obama’s birth certificate (Docket #29473) as posted on various pro-Obama websites, including,,,, and;  


xiv.      A list of some 100 addresses found on LEXIS-NEXIS and Choice Point under the name of Barack Obama (and similar spellings) that were attached to various social security numbers, including two in Tennessee , as well as a list of 130 current employments found for Barry Obama, Barack H. Obama and Michelle Obama. The first three digits of the social security number provide information on the states and the social security numbers came from different states all over the country.  One particular social security number, that was used while Obama was a law student at Harvard, was attached to his address in Sommerville , MA , and was issued in Connecticut , this social security number was for a  118 years old;  


xv.      Selective Service System registration ("SSS Form 1") for Obama regarding whether he ever registered for the Selective Service System or if someone committed a crime for him and accompanying computer print out ("SSS Print-out) forgery statement by recently retired federal agent, Stephen Coffman; 


xvi.      Statement made by Obama saying that his mother Ann Dunham gave birth to him in HI, even though investigations indicate otherwise since there have been no birth records or labor and delivery records found in HI for his mother; and  


xvii.      Other conflicting citizenship reports regarding Obama’s travels to Kenya and Indonesia .



Or, alternatively, if no investigations were done on these multiple issues, an explanation as to why nothing was done;  


c.                   Names and contact information for investigators, results of the investigations performed and findings on the information forwarded to the FBI about Obama by the office of US Senator Lamar Alexander from Tennessee, or, alternatively, if no investigations were done on these issues, an explanation as to why nothing was done; and  


Names and contact information for investigators, results and findings of investigations performed regarding additional inconsistencies and/or fraud discovered in the COLB that Obama filed online, which has been determined to have numerous signs of forgery by a number of forensic document examiner experts, as explained in item 16 above.


I am requesting US Attorney for the Eastern District of California


Mr. Raymond Brown, to treat my sworn affidavit as a petition for Quo Warranto for Barack Hussein Obama per US §16-3502.




IN WITNESS WHEREOF, ORLY TAITZ has executed this Affidavit this ______ day of March, 2009.


ORLY TAITZ, Attorney for Ambassador Dr. Alan Keyes, Mr. Markham Robinson and Pastor Dr. Wiley Drake

26302 La Paz , Suite 211,

Mission Viejo, CA  92691







            SUBSCRIBED AND SWORN TO BEFORE ME on the _______ day of March, 2009, by ORLY TAITZ, proved to me on the basis of satisfactory evidence to be the person who appeared before me.


Notary Public in and for(Seal)                           


Orly Taitz DDS Esq


26302 La Paz ste 211

Mission Viejo Ca 92691


29839 S. Margarita Pkwy

Rancho Santa Margarita Ca 92688