Voeltz Obama ReplytoLawMemo061512

7/31/2019 Voeltz Obama ReplytoLawMemo061512

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IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT

IN AND FOR LEON COUNTY, FLORIDA

MICHAEL C. VOELTZ, ))

Plaintiff, )

)vs. )

) Case No.: 2012CA00467

BARACK HUSSEIN OBAMA, et. al. ))

)

Defendants. )

)

____________________________________________ )

PLAINTIFF'S REPLY TO DEFENDANT OBAMA'S MEMORANDUM OF LAW OF

JUNE 15, 2012 IN SUPPORT OF HIS MOTION TO DISMISS AND PLAINTIFFS

SECOND SUPPLEMENTAL MEMORANDUM

Plaintiff Michael Voeltz, submits this reply memorandum to further show that justiciable

causes of action have been clearly plead and established, and providing further evidence of the

meaning of "natural born citizen.

When the Florida Democratic Party submitted Defendant Obama's name, and his name

alone, as a candidate for the Presidential Primary, it was plead and made clear that he is the

nominee. He was elected as of January 31, 2012, the date of the Presidential Primary. The

winner of the Presidential Primary is, by law, the nominee for the Democratic Party. Based on

these events, there has been a nomination that may be contested "by any elector qualified to vote

in the election." Section 102.168(1).


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The citizens are the members of the civil society; bound to this society by certain

duties, and subject to its authority, they equally participate in its advantages. Thenatives, or natural-born citizens, are those born in the country, of parents

who are citizens."

"Law of Nations," Book 1, Chapter 19, 212 (emphasis added)(Exhibit 1). Vattel went on to

clarify and confirm, the country of the father is the country of the son.Id.

Not coincidentally, the Supreme Court in The Venus, 12 U.S. 253 (1814), Justice John

Marshall, in a case entirely decided by the legal concepts of the law of nations, directly quotes

the above definition by Vattel almost verbatim. Justice Marshall wrote:

Vattel, who, though not very full to this point, is more explicit and more

satisfactory on it than any other whose work has fallen into my hands, says 'Thecitizens are the members of the civil society; bound to this society by certain

duties, and subject to its authority, they equally participate in its advantages. Thenatives or indigenes are those born in the country of parents who are citizens.

Society not being able to subsist and to perpetuate itself but by the children of the

citizens, those children naturally follow the condition of their fathers, and succeedto all their rights.'

The Venus, 12 US 253, 289 (1814). Justice Marshall went on to explain:

The writers upon the law of nations distinguish between a temporary residence ina foreign country for a special purpose and a residence accompanied with an

intention to make it a permanent place of abode. The latter is styled by Vattel

"domicile," which he defines to be, "a habitation fixed in any place, with anintention of always staying there." Such a person, says this author, becomes a

member of the new society, at least as a permanent inhabitant, and is a kind of

citizen of an inferior order from the native citizens, but is nevertheless united andsubject to the society without participating in all its advantages.

Id. at 278. Thus, The Venus stands for the proposition that allegiance to one's country cannot be

established by domicile because it is easily disintegrated when a person moves back to his native

country. The framers wanted a solid bond to one's country. Citizenship through this temporary

allegiance cannot be what the framers were looking for when requiring the future president to be

a "natural born citizen," for the purpose of the prevention of foreign influence. The framers

desired and mandated that a deep abiding allegiance to the United States for the future president


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must be had, as this person would be the Commander In Chief of the U.S. Armed Forces. They

were looking for allegiance derived from at least naturalized U.S. Citizen parents, on the

standing of a "Native," who had legally thrown off native allegiances and pledged sole allegiance

to their new nation, not the temporary allegiance of inhabitants, simply changed by moving

domicile.

As stated in Plaintiff's Supplemental Memorandum, the definition that a natural born

citizen was one born in the country with two citizen parents, was the prevalent view of the time.

In his landmark treatise "A Treatise on Citizenship," following the law of nations codified in

Vattels "Law Of Nations," Alexander Peter Morse definitively stated and reiterated the accepted

law on "natural born citizen," "A citizen, in the largest sense, is any native or naturalized

person who is entitled to full protection in the exercise and enjoyment of the so-called

private rights. The natural born, or native is one who is born in the country, of citizen

parents." Morse, Alexander Peter,A Treatise on Citizenship pp. xi (1881)( Exhibit 2). "Under

the view of the law of nations, natives, or natural born citizens, are those born in the

country, of parents who are citizens." Id. at 7.

The Supreme Court has similarly made clear that "citizen" and "natural born citizen"

were two distinct and separate terms. Less than a decade after the passage of the Fourteenth

Amendment, the Supreme Court clarified that only "all children born in a country of parents

who were its citizens" were in turn "natural born citizens."Minor v. Happersett, 88 U.S.

162, 167 (1875).

Justice Horace Gray's Supreme Court opinion in United States v. Wong Kim Ark, a case

cited by Defendant Obama, merely held that the children of domiciled resident aliens, would be"

citizens" at birth, if born in America, since they would be subject to the jurisdiction" of the


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United States through the jurisdiction had over their parents. United States v. Wong Kim Ark, 169

U.S. 649 (1898). This case merely determined that the child was a "citizen" and did not establish

that he was a "natural born citizen" since that was not at issue. In fact, "natural born citizen," a

requirement for president, had nothing to do with the case. Not surprisingly, Justice Grey

reiterated theMinor v. Happersettdefinition, that natural born citizens are born of two U.S.

citizen parents, and noted that the parents at issue in the Wong Kim Ark case were not U.S.

citizens.Id. citing Minor v. Happersett, 88 U.S. 162. Justice Gray certainly was not ruling that

children of domiciled resident aliens were natural born citizens, eligible to be president.

Even more, there is clear evidence the founding fathers studied, utilized, and incorporated

the law of nations codified in Vattel's Law of Nations in the crafting and enacting of the

Constitution, and frequently consulted VattelsLaw of Nations thereoften for guidance.

In a letter from Benjamin Franklin to Charles Dumas, editor of the 1775 edition of the

Law of Nations, Franklin specifically thanks Dumas for providing him with copies of the Law

of Nations. This Founding Father and framerwrote:

"I am much obliged by the kind present you have made us of your edition of

Vattel. It came to us in good season, when the circumstances of a rising state

make it necessary frequently to consult the law of nations. Accordingly that copy,which I kept, (after depositing one in our own public library here, and sending the

other to the College of Massachusetts Bay, as you directed,) has been continually

in the hands of the members of our Congress, now sitting, who are much

pleased with your notes and preface, and have entertained a high and just

esteem for their author."

Benjamin Franklin Letter, pp. 1. (Exhibit 3)(emphasis added). This letter of Benjamin Franklin

is a certified copy from the Library of Congress and has been attached as Exhibit 3. Franklin,

who was instrumental in the drafting and enacting of the Constitution, provides confirmation that


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those drafting the Constitution were "frequently consulting" the law of nations codified in Law

of Nations. The framers then knew of and incorporated the definition of "natural born citizen"

which was provided twice within the Law of Nations.

Not surprisingly, a direct reference to legal incorporation of the law of nations as codified

in Vittels "Law of Nations" also appeared in the Constitution itself. In Article 1, Section 8, the

Constitution granted enumerated powers for the legislative branch. One of these enumerated

powers was "To define and punish Piracies and Felonies committed on the high seas, and

Offenses against the Law of Nations;" U.S. Constitution, Article I, Section 8, Clause 10

(emphasis added). The framers took care in incorporating and recognizing the law of nations, and

providing Congress with a means of legislating crimes committed against it.

Even after the Constitution was written, Vattels "Law of Nations" continued to be

consulted and utilized by the leaders of the United States. On October 5, 1789, President George

Washington borrowed from the New York Society Library a copy of Vattel's Law of Nations,

as evidenced by his entry in the ledger. An article with the picture of the ledger has been

attached as Exhibit 4 along with a confirmation by the head Librarian of the New York Society

Library that the article is accurate.

In short, the Supreme Court's decision inMinor v. Happersettrecognized the law of

nations' definition of "natural born citizen" which was adopted by the framers of the

Constitution.

2. Florida's Challenge of Elections Works in Conjunction With the U.S. Constitution

Defendants disingenuously allege that for Florida to determine eligibility would be

contrary to the Constitution, specifically the Twentieth Amendment and 3 USC 15. This


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argument is non-meritorious. The Twentieth Amendment simply states the procedure "ifthe

President elect shall have failed to qualify." There is no mention about the method of

qualification, only that the electors shall meet and vote by ballot. Defendant Obama claims

federal statute 3 USC 15, "describe[s], in detail, the process for raising and resolving

challenges to the qualifications." Yet this statute simply states the procedure for counting the

electoral votes, and objections if improper votes are cast. Nothing is stated about challenging the

qualification of a candidate.

Nor is Florida law interfering with presidential electors. The Florida law allows

challenges to those who are nominated or elected. These actions occur before the electors cast

their votes, and are simply in place to ensure that the presidential elector votes for an eligible

candidate. It would surely be possible for a disqualified candidate to be declared ineligible,

leaving the electors with the duty to vote for the remaining candidates. This is precisely the

outcome Plaintiff, a registered member of the Democratic Party, and Florida law seek to avoid.

Plaintiff wishes to ensure that if Defendant Obama is the Democratic Party nominee then his

vote, and the vote of the presidential elector, will not end up going to the other candidates and/or

for naught.

A presidential election is not, ipso facto, an exclusively federal process. In fact, electors,

those chosen to ultimately select the President, were to be designated exclusively by the state

legislatures. Article II, section 1, clause 2. Presidential elections are thus a cooperative and

complementary effort of both the state and federal government. The state of Florida, through its

legislative branch, is simply ensuring that eligible candidates, for all elected offices, are chosen.

Thus, there is thus no preclusion under any law which Defendants Obama has argued.

CONCLUSION


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With all this evidence, it clear not only that Plaintiff has established clear causes of action

but also that Defendant Barack Obama has not, and cannot, meet the requirement of "natural

born citizen." Even if Defendant Obama was born within Hawaii -- and there are sworn

controverted facts contained in affidavits before the court in his regard-- he was born to a father

who was a British subject and not a U.S. citizen. Since Defendant Obama was not born to two

U.S. citizen parents he is not a "natural born citizen," and is not eligible for the 2012 Florida

primary, general election, or for the Office of the President of the United States. Moreover,

Florida's election laws work in conjunction with federal laws, and are not precluded.

Defendant Obamas eligibility to run for president on the Florida ballot should not and

cannot, under Florida election law, be treated any differently than would be the case with any

other candidate for federal or state officesimply because he is currently president. Under our

system of justice, no one is above the law, and indeed as one of the greatest founding fathers and

later presidents, John Adams, stressed at the time that the Declaration of Independence was

signed in Philadelphia in 1776, the new republic and nation was created to be a country of

laws and not men. This honorable court is respectfully asked to analyze and rule upon the

applicable facts and laws in this context and Plaintiff has faith and prays that it will.

For all these reasons, Plaintiff respectfully requests that this Court deny Defendants'

Motions to Dismiss or Alternative Motion for Summary Judgment.

Dated: June 15, 2012

Respectfully submitted,

/s/ Larry Klayman

Larry Klayman, Esq.

F.L. Bar No. 246220


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Klayman Law Firm

2020 Pennsylvania Ave. NW, Suite 800Washington, DC 20006

Tel: (310) 595-0800

Email: [email protected]


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Exhibit 1


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Exhibit 2


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Exhibit 3


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Exhibit 4


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14/12 Overdue: Shedding some light on the George Washington l ibrary book story BonnevilleMariner.com

wordpress.com/2010//overdue-shedding-some-light-on-the-george-washington-library-book-story/

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Overdue: Shedding some light on the George

Washington library book story

27 May

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(https://reader009.{domain}/reader009/html5/0430/5ae66f825be70/5ae66f931a91d.jpg)The copy of Vattel's The Law of Nations that was given to the New York Society Library by George

Washington's Mount Vernon Estate

Im at once amused and fascinated by the matter of George Washingtons overdue library books.Amused because, after all, Washington sewed seeds that changed the world. Men of his honor andcaliber rarely grace the history pages. Considering the political scandals of present, its fun to look

back on trivialities of the past.

My fascination with this story is based less on the historical facts themselves and more on the processof connecting the jigsaw puzzle. I hated history in high school (no offense, Mr. Madsen) because thework had been done for me. My grade depended on memorization and regurgitation, notinvestigation. I wonder how many kids who think they hate history would realize they actually loveit if their teachers thought outside the textbook.

My post (http://bonnevillemariner.wordpress.com/2010/05/26/update-george-washingtons-221-year-overdue-library-book-finally-returned/) about Washingtons library books last week was supposed to

be a simple Friday blurb about an interesting historical factoid (a great date night conversationpiece!).

But the more I researched this story, the more questions arose. Not big conspiratorial questions justcurious questions about the timeline and some inconsistencies in the press reports. Some news reportshad mentioned two books, others mentioned only one. Beyond this, I wished somebody had takentime to flesh the story out a little more.

I started by contacting the New York Society Library (http://www.nysoclib.org/) and the mediaoffice at George Washingtons Mount Vernon Estate & Gardens (http://www.mountvernon.org/) to

ask for help. Both parties were extremely helpful, taking time to answer my questions and send meall sorts of good information. The information presented below was culled from Washingtons diary,press kits, and my interviews with NYSL and Mount Vernon staff. So, Id like to present you whatthe late Paul Harvey would call the rest of the story.

THE CONTEXT

In 1789, the U.S. government was based out of Federal Hall at Wall and Broad Streets in LowerManhattan. Occupying the top floor of the building was the New York Society Library, which wasfounded in 1754. The library was a useful resource for government officials and it was frequented bythe likes of Alexander Hamilton, Aaron Burr, John Jay, and sometimes the president himself.

By fall of 1789, Congress was in recess and the president was preparing to tackle the touchy issue ofdiplomatic affairs with Britain. In fact, hed be meeting with Chief Justice John Jay and TreasurySecretary Alexander Hamilton about these matters on October 7. Given these circumstances, its nosurprise that Washington would check out library material on British parliamentary dealings andinternational diplomacy.


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(https://reader009.{domain}/reader009/html5/0430/5ae66f825be70/5ae66f9433183.jpg)Federal Hall, the shared location of the New York Society Library and the Federal government in

1789 (courtesy of the New York Society Library)

THE TIMELINE

October 5, 1789: Washington (or an aide- we dont know) walked upstairs and checked out two

books from the library: The Law of Nations by Emmerich de Vattel and Vol. 12 of the Commons

Debates. The transaction is recorded in the librarys leather-bound charging ledger. In the borrowercolumn, the librarian simply writes President.

October 15, 1789: Washington leaves New York for a tour of New England. Though he keeps adetailed diary, no mention of the books is made.

November 2, 1789: The books are due, but Washington is fishing for cod off of New HampshiresPortsmouth Harbour. Washington notes in his diary that he and his companions only caught twofish between them. Then, in true fisherman tradition, he justifies the skunking by blaming animproper tide. The library books are likely the last things on his mind. Though no official fine recordexists, a pennies-per-day fine would begin accruing after this date.

April 1792: The 18 lb. ledger is filled and is filed away. It is later misplaced likely during one of thelibrarys re-locations.

Dec. 14, 1799: George Washington dies at Mount Vernon. Most of his belongings, including books,


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are divided up among his family.

1934: NYSL staff rediscover the deteriorating ledger in the basement of the librarys fourthManhattan location. The ledgers pages crumble to the touch, so it is used only rarely for referenceuntil the beginning of its restoration in 2007. NYSL staffer Sara Holliday suspects that theWashington transaction was noticed sometime after the ledger was found, as it had been discussedunofficially and anecdotally among library staff for years.

2007: NYSL begins restoring and digitizing the ledger.

2010: Restoration complete, NYSL staff check their inventory again. Washingtons books are stillmissing. The New York Daily news picks up on the Washington transaction and breaks the story.The fine estimate of $300,000, according to Holliday, was calculated by the Daily News, not theNYSL. She says fine policies changed over time, and that an exact total would be tough todetermine. Anyway, its something the NYSL has no interest in tracking.

Upon hearing about the overdue books, staff at Mount Vernon search their own archives with noluck. Considering The Law of Nations the much more significant of the two books, they purchase anidentical copy online for an undisclosed amount (Im told the price reported by one outlet and echoedin several others is inaccurate).

May 19, 2010: In a ceremony at NYSL, Mount Vernon President James Rees and Librarian Joan

Stahl present the replaced book. Most media reports focus only on the return of The Law of Nations,

making no mention of the still missing Commons Debates.

THE EVIDENCEHolliday says restoring the ledger familiarized NYSL staff with habits of their 18th Century

counterparts. Patrons from the Federal government were commonly referred to by their titles, whichis why the informal President appears next to Washingtons checkouts in the images below.

(http://bonnevillemariner.files.wordpress.com/2010/05/ledger-highlight.jpg)Exhibit A: the portion of NYSL's charging ledger that shows the Washington transaction. I've

highlighted the relevant rows.


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(http://bonnevillemariner.files.wordpress.com/2010/05/ledger-markup.jpg)Exhibit A.1: The same portion of the ledger, but I've identified the columns.

Washington is off the hook at least for The Law of Nations. And thats where the media called it

good and skipped out. But the father of our country still has one overdue book out, and thoughhistory has certainly forgiven this oversight, its going to drive me nuts until somebody finds it.Maybe its time to book a trip back east!

-

Copyright 2010 BonnevilleMariner.com. All images courtesy of the New York Society Library. Special

thanks to the NYSL (http://www.nysoclib.org/)s Sara Holliday and Mount Vernon

(http://www.mountvernon.org/)s Melissa Wood and Joan Stahl.

3 CommentsPosted by bonnevillemariner on May 27, 2010 in Americana, History

Tags: george washington, law of nations, mount vernon, new york society library

3 Responses to Overdue: Shedding some light on the George

Washington library book story

1. Michelle Powell

May 27, 2010 at 2:56 pm

WOW..EXCELLENT investigative work once again! I love reading your articles! Just dontleave us Utahns behind when the New York Times calls to offer you a job! Wed be miserable


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with boring articles if you left us!

(Its going to bug me as well until that other book is found! I am fascinated with GeorgeWashington.I was born the same day as he was 2/22. It bugs me that they returned the book221 years overdue. WHY did they not wait one more year and return it 222 years later! Haha! ILove numbers as well!

Reply

bonnevillemariner

May 27, 2010 at 8:58 pm

Thanks, Michelle. I cant leave Utah there are too many stories to tell about our neck of thedesert!

Reply

2. Robert Petrie

June 4, 2010 at 1:09 pm

This almost pains me to write this to inform Michelle that George Washington was born onFebruary 11, 1732. The British empire accepted the Gregorian calendar in 1752 adding 11 days. 2September 1752 was followed by 14 September 1752.

To make amends, please visit the New-York Historical Society after we reopen on 11/11/2011 andIll show you part of the balcony railing of Federal Hall and the chair Washington used during

his inauguration.Bob Petrie, Docent N-YHS

Reply

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14/12 NYSL Article: Book Selections of Founding Fathers by William J. Dean (2007)

ww.nysoclib.org/articles/ny_law_journal.html

O

ARTICLE:Book Selections of Founding Fathers

William J. Dean, New York Law Journal (2007)

This article is reprinted with the permission

of the New York Law Journal, where it first appeared on Feb. 8, 2007.

n April 30, 1789, from the balcony of Federal Hall, George

Washington took the oath of office as President of the United States.

The president and Congress shared space in Federal Hall with the

New York Society Library.

The library had been founded in 1754 by a group of six young New

Yorkers - five lawyers and a merchant - in the belief that "a Publick Library would

be very useful, as well as ornamental to this City..." In the view of one founder,

New York lacked "a spirit of inquiry among the people. It is indeed so prodigious

that in so populous a City...few Gentlemen have any relish for learning. Sensuality

has devoured all greatness of soul and scarce one in a thousand is even disposed to

talk serious."

Books were ordered from England. They included a "Life of Mahomet," the works

of Milton and Locke, a history of France ("the best"), lives of Cromwell and Tsar

Peter, "All Cicero's Works that are translated," and debates in Parliament.

In October 1754, the books arrived from England on the Captain Miller. With a

library, New York now had an opportunity, the New York-Mercury editorialized,

to "show that she comes not short of the other Provinces, in Men of excellent

Genius who, by cultivating the Talents of Nature, will take off that Reflection cast on

us by the neighbouring Colonies, of being an Ignorant People."

From 1774 to 1788, the library suspended operations. During the Revolutionary

War, British soldiers carried away library books in their knapsacks, bartering them

for grog. 600 books were removed to St. Paul's Chapel. When the library re-

opened in 1789, it had a collection of 3,100 books.

The library was available as a resource to its 239 subscribing members, among

them Alexander Hamilton, Aaron Burr and John Jay, and to the president, members

of Congress and justices of the Supreme Court. Occupying a room on the top floor,


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14/12 NYSL Article: Book Selections of Founding Fathers by William J. Dean (2007)

ww.nysoclib.org/articles/ny_law_journal.html

"Candidus, or "All For the Best," as the volume is noted in the ledger; "The

Fair Syrian, a novel"; Frances Burney's, "Cecilia, or Memoirs of an Heiress";

"Arabian Nights Entertainments, consisting of one thousand and one stories,

related by the Sultaness of the Indies" and John Aubrey's "Miscellanies," a

collection of stories on ghosts and dreams.

History. Plutarch's, "Lives"; "Lives of the Admirals, and other Eminent British

Seamen"; "The History of the Five Indian Nations of Canada"; "The History

of the Revolution of South Carolina, from a British Province to an

Independent State"; and "An Essay on the Life of the Honorable Major-

General Israel Putnam."

Travel. Captain James Cook's, "A Voyage towards the South Pole, and

Round the World"; "A Tour through Sicily and Malta"; "Travels into

Muscovy, Persia, and Paris of the East-Indies, containing an accurate

description of whatever is most remarkable in those countries"; "A Voyage

Round the World in the Years 1766-1769," by the Comte Louis Antoine de

Bougainville; "A General Description of China, containing the topography ofthe fifteen provinces which compose this vast empire"; "Travels in Spain";

"Travels to Discover the Source of the Nile in 1768-1773"; and "Travels in

North America in the Years 1780-1782", by the Marquis Francois Jean de

Chastellux.

Science. Comte de Buffon's "Natural History"; "Chambers', Cyclopaedia, or

General Dictionary of Arts and Sciences"; and "Essays on the Intellectual

Powers of Man."

Chief Justice Jay must have had his own collection of law books, for few of thebooks borrowed by him from the New York Society Library are law-related. What

stands out when examining the library's charging ledger is both the breadth of his

interests and his wide reading in literature, history, travel and science. May we, as

lawyers, be encouraged by his example to expand, through reading, our own

horizons.

William J. Dean is executive director of Volunteers of Legal

Service. He serves as a trustee of the New York Society Library.

Articles > Main Page


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CERTIFICATION

I HEREBY CERTIFY that a true copy of the foregoing Plaintiff's Reply to Defendant Obama's

Memorandum of Law in Support of His Motion to Dismiss and Plaintiff's Second Supplemental

Memorandum has been served by email and the U.S. mail this 15th day of June, 2012 and by

hand on June 18, 2012 to the following:

Hon. Terry P. Lewis

Circuit JudgeLeon County Courthouse

Room 301-C

301 S. Monroe StreetTallahassee, FL 32301

Daniel Nordy

Ashley E. Davis

Florida Department of StateR.A. Gray Building

500 South Bronough StreetTallahassee, FL 32399

Mark HerronJoseph Brennan Donnelly

Robert J. Telfer, III

Messer, Caparello & Self, P.A.

Post Office Box 15579Tallahassee, FL 32317

Stephen F. Rosenthal

Podhurst Orseck, P.A.

25 West Flagler Street, Suite 800Miami, FL 33130-1720

Richard B. Rosenthal

The Law Offices of Richard B. Rosenthal, P.A.

169 East Flagler Street, Suite 1422Miami FL 33131

James A. Peters

Office of the Attorney GeneralFL-01, The Capital

Tallahassee, FL 32399-1050

Counsel for Defendants

Respectfully submitted,

/s/ Larry Klayman

Larry Klayman, Esq.

F.L. Bar No. 246220

Klayman Law Firm2020 Pennsylvania Ave. NW, Suite 800

Washington, DC 20006

Tel: (310) 595-0800Email: [email protected]

Voeltz Obama ReplytoLawMemo061512

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