Strunk v. U.S. Department of State et al.

DCDC 08-cv-2234

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA
--------------------------------------------------x Case No.: 08-cv-2234 (RJL)
:
CHRISTOPHER EARL STRUNK : SUPPLEMENT AMENDED
: VERIFIED COMPLAINT
Petitioner, : AND PETITION FOR
v. : WRIT OF MANDAMUS
: UNDER F.O.I.A.
U.S. DEPARTMENT OF STATE, and :
U.S. DEPARTMENT OF HOMELAND :
SECURITY, :
Defendants. :
:
-------------------------------------------------x

NOW COMES Christopher Earl Strunk, as the Petitioner, and

brings this Supplement Amended Complaint under Federal Rules of Civil

Procedure Rule 15(a)(1)(c)(1)(B)(d) of the Complaint filed with the clerk of

the District Court on November 26. 2008, and pursuant to the Freedom of

Information Act, 5 U.S.C. §552, et sequitur, against the Defendants the

United States Department of State, and U.S. Department of Homeland

Security, stating:

JURISDICTION AND VENUE

1. This cause of action arises under the Freedom of Information Act

pursuant to 5 U.S.C. §552. Jurisdiction is properly before this Court

pursuant to that federal statute with the United States District Courts under

28 USC §1331 with a Federal question and under 28 USC §1346.

Supplement Petition for Writ of Mandamus – Page 1 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

2. This particular District Court for the District of Columbia affords the

proper venue under 28 USC §1391 (e) (2) for this action in that the

Defendant U.S. Department of State and Defendant U.S. Department of

Homeland Security as each is located within the District of Columbia and

the failure of the Defendant and or Defendants to act separately and or in

concert was also within the District of Columbia.

3. Petitioner filed this complaint requesting this Court to Order the U.S.

Department of State and U.S. Department of Homeland Security to fulfill

their obligations pursuant to the Freedom of Information Act (hereinafter

"FOIA") immediately turn over the following documents on the following

individual:

a. Stanley Ann Dunham, a/k/a Ann Dunham a/k/a Stanley Ann

Obama a/k/a Ann Obama a/k/a Stanley Ann Soetoro a/k/a Ann

Soetoro a/k/a Stanley Ann Sutoro a/k/a Ann Sutoro a/k/a

Stanley Ann Dunham Obama a/k/a Ann Dunham Obama, born

November 29, 1942 at Wichita Leavenworth KS. U.S., a.k.a.

Stanley Ann Dunham Obama and who died on November 7,

1995 under the name Stanley Ann Dunham Soetoro (a.k.a.

Sutoro), SSN: 535-40-8522; and

b. Barack Hussein Obama, Jr. a/k/a Barry Soetoro Date of Birth:

Supplement Petition for Writ of Mandamus – Page 2 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

August 4, 1961 and as a living natural person; and

4. The following documents:

a. Any and all U.S. Applications for a U.S. Passport;

b. Entry and Exit Passport Records pertaining to the United States

and Kenya from the period of time of January 01, 1960 to

December 31, 1975 and January 1, 1979 to December 31,

1985;

c. Entry and Exit Passport Records pertaining to the United States

and Indonesia from the period of time of January 01, 1960 to

December 31, 1973 and January 1, 1979 to December 31, 1985;

d. The above travel records on for the dates specified travelling on

a U.S. Passport, Kenyan Passport, Indonesian Passport or any

other foreign passport and/or visa;

e. Foreign Birth Certificate registered and filed with the U.S.

Embassy, Kenya and/or U.S. Embassy of Indonesia for Barack

H. Obama a/k/a Barry Soetoro, Date of Birth: August 4, 1961;

f. Foreign Birth Registry filed with the U.S. Embassy, Kenya

and/or U.S. Embassy of Indonesia by Stanley Ann Dunham, et

al. Registering the birth of Barack H. Obama a/k/a Barry

Soetoro, Date of Birth: August 4, 1961; and

Supplement Petition for Writ of Mandamus – Page 3 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

g. Adoption Records and/or Governmental "Acknowledgment"

wherein Barack H. Obama a/k/a Barry Soetoro was

"acknowledged" as Lolo Soetoro, M.A.'s son.

5. Pursuant to the Freedom of Information Act, the Petitioner,

Christopher Earl Strunk, petitions this Court for extraordinary relief in

the nature of a writ of mandamus under 28 USC §1651, directed to

Respondent, United States Department of State, and its employees and

agents in the United States Department of State and ;

6. This action seeks to compel the U.S. Department of State to

turn over the records requested pursuant to a Freedom of Information Act

referred to herein.

7. In support of this amended verified petition, Petitioner avers the

following:

THE PARTIES

8. Petitioner, Christopher Earl Strunk (hereinafter "Petitioner"), is an

individual who resides with place for service at 593 Vanderbilt Avenue #281

Brooklyn, NY 11238; Email: uncasvotes2@yahoo.com, cell-845-901-6767.

9. Defendant, United States Department of State, is a Governmental

Agency located at 2201 C Street N.W., Washington, D.C. 20520.

10. Defendant, United States Department of Homeland Security, is a

Supplement Petition for Writ of Mandamus – Page 4 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

governmental agency created pursuant the Patriot Act, and whose Executive

level cabinet Secretary is Michael Chertoff with mailing address located at

Washington, DC 20528.

11. That under the Patriot Act the U.S. Department of Homeland

Security is in control of the Bureau of Customs and Border Control located

at 799 Ninth Street, N. W. at the Mint Annex Washington D.C. 20229.

FACTS

12. On October 17, 2008, Petitioner filed a FOIA request directed to the

United States Department of State request for the above cited records for the

person referenced at paragraph 3 (a) for the period from 1960 through 1963,

and Petitioner sent the request via United States Postal Service, Certified

Mail, Return Receipt Requested; a true and correct copy of Petitioner's letter

is attached hereto and incorporated in by reference as Exhibit A.

13. Petitioner filed the FOIA request for travel records shown as Exhibit

A that was deposited with the USPS certified with return receipt request for

two-day delivery by October 20, 2008, as per the true and correct copy of

the USPS mailing purchase receipt attached herewith marked Exhibit B.

14. That on October 27, 2008, the USPS confirmed delivery of the FOIA

request for records under the control of the United States Department of

State, (see Exhibit C).

Supplement Petition for Writ of Mandamus – Page 5 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

15. That on October 30, 2008, Defendants agent signed the return receipt

for the FOIA request shown as Exhibit A for Petitioner's FOIA request at the

U.S. Department of State; that thereafter, was delivered to my mailing

address by the USPS, (see Exhibit D).

16. On or about November 7, 2008 Petitioner never received any

response from Defendant / Respondent for any of the information requested

in regards to above paragraph 3(a).

17. On November 22, 2008, Petitioner filed the FOIA request with

reference number B8475 the information detailed above in regards to above

living natural person described in paragraph 3(b); see the U.S. Department

of State request confirmation marked Exhibit E.

18. On November 22, 2008, Petitioner filed a declaration in support of

the FOIA request with reference number B8475 the information detailed

above in regards to above living natural person described in paragraph 3(b),

with a cover letter and attachment of the FOIA request on the deceased

person described in paragraph 3(a) see Exhibit F.

19. A true and correct copy of the return receipt is attached hereto and

incorporated see Exhibit G.

20. That as a matter of Bureau of Customs and Border Control concern,

based upon the school records (see Exhibit H) provided by Indonesian

Supplement Petition for Writ of Mandamus – Page 6 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

authorities as to Barry Soetoro’s adoption by Lolo Soetoro and schooling in

Indonesia as a natural born Indonesian citizen, indicates that Barry Soetoro

may be an illegal alien improperly in the United States.

21. That as a matter of Bureau of Customs and Border Control concern,

based upon information and belief there is an imposter presently using the

deceased Stanley Ann Dunham Soetoro’s (a.k.a. Sutoro) SSN: 535-40-8522

for employment at the Ford Foundation and is residing in New York City.

22. On December 26, 2008, Petitioner filed a FOIA request for records

cited above in paragraphs 3 through 4(g) and paragraph 21 directed to the

Bureau of Customs and Border Control of the U.S. Department Of

Homeland Security located at 799 Ninth Street, N. W. in the Mint Annex

Washington D.C. 20229 to the attention of Mark Hanson Director FOIA

Division (see Exhibit I).

23. The above records do not fall within any of FOIA exemptions items.

24. The above documents do not involve any of the FOIA exemptions

which include National defense or foreign policy records, 5 U.S.C. §

552(b)(1), internal personnel rules and practices of an agency, 5 U.S.C.

§552(b)(2); exemption by other federal statutes, 5 U.S.C. § 552(b)(3);

trade secrets, commercial or financial information, 5 U.S.C. § 552(b)(4);

inter-agency or intra-agency memoranda 5 U.S.C. § 552(b)(5); personnel

Supplement Petition for Writ of Mandamus – Page 7 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

and medical files, 5 U.S.C. §552(b)(6); information complied for law

enforcement purposes, 5 U.S.C. §552 (b)(7); information contained in or

related to examination, operating or condition reports prepared by, on behalf

of, or for the use of an agency responsible for the regulation or supervision

of financial institutions. 5 U.S.C. §552(b)(8); nor does the information

requested involve geological and geophysical information, 5 U.S.C.

§552(b)(9).

25. The above requested documents are extremely critical and important

to Petitioner as well as the general public and are of substantial public

interest.

26. The overwhelming majority of the Electoral College slates of the

States of the several States received the majority advisory votes cast for

Barack Hussein (“H.”) Obama a/k/a Barry Soetoro [hereinafter "Obama"]

and thereby won the general election votes on November 4, 2008; and

subsequent to canvassing in each State of the several States the Electoral

College of each state of the several states is to be certified by the state

officials over every state on or about December 1, 2008 is to assembly in

each State of the several States to cast their votes on December 15, 2008.

Supplement Petition for Writ of Mandamus – Page 8 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

27. Mr. Obama is not a U.S. "natural born" citizen and ineligible to serve

as the United States President, pursuant to the United States Constitution,

Article II, Section 1, Clause 5.

28. Although Mr. Obama claims to have been born in two (2) separate

hospitals in Hawaii, he was actually born in Mombasa, Kenya to his mother

a U.S. citizen and his father a Kenyan National.

29. Mr. Obama's mother (referenced above in paragraph 3(a)) was not old

enough pursuant to the Nationality Act of 1940, revised June 1952 to pass

on U.S. "natural born" citizenship to Mr. Obama.

30. The U.S. Law in effect during Mr. Obama's birth stated if you are

born abroad to one U.S. parent and a foreign national, the U.S. parent must

have resided in the United States for ten (10) years, five (5) of which were

after the age of Fourteen (14) in order to register the child's birth abroad in

the United States as a "natural born" U.S. citizen, under the Nationality Act

of 1940, revised June 1952, United States of America v. Cervantes-Nava,

281 F.3d 501 (2002), Drozd v. I.N.S., 155 F.3d 81, 85-88 (2d Cir.1998),

United States v. Gomez-Orozco, 188 F.3d 422, 426-27 (7th Cir. 1999),

Scales v. Immigration and Naturalization Service 232 F.3d 1159 (9th Cir.

2000), Solis-Espinoza v. Gonzales 401 F.3d 1090 (9th Cir. 2005).

Supplement Petition for Writ of Mandamus – Page 9 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

31. Under the Nationality Act of 1940, revised June 1952, is the law that

applies to a birth abroad and is in effect at the time of birth, Marquez-

Marquez a/k/a Moreno v. Gonzales 455 F. 3d 548 (5th Cir. 2006), Runnett v.

Shultz, 901 F.2d 782, 783 (9th Cir.1990) (holding that "the applicable law

for transmitting citizenship to a child born abroad when one parent is a U.S.

citizen is the statute that was in effect at the time of the child's birth").

32. Stanley Ann Dunham, Mr. Barry Soetoro's mother, was only 18 when

she gave birth to Barack Hussein Obama, Jr. She was not old enough to

register Obama's birth in Hawaii or anywhere else as a United States "natural

born" citizen as she did not meet the residency requirements pursuant to our

United States Laws; as such it does not matter that this is a minor

technicality, the law is applied regardless - see United States of America v.

Cervantes-Nava, 281 F.3d 501 (2002), Drozd v. I.N.S., 155 F.3d 81, 85-88

(2d Cir.1998).

33. Mr. Barry Soetoro has been asked for his "vault" version birth

certificate; however, he has refused, which has prompted law suits across the

United States.

34. Instead, Mr. Barry Soetoro and or his agent(s) placed an image of a

Hawaiian Certification of Live Birth (COLB), which is issued for all birth's

Supplement Petition for Writ of Mandamus – Page 10 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

registered in the State of Hawaii; the COLB, does not prove "natural born"

citizenship or birth in Hawaii.

35. A COLB is sufficient proof of citizenship; however, it does not prove

"natural born" citizenship, a COLB is issued to those who are simply

"naturalized".

36. There is absolutely NO doubt in Petitioner’s mind that Mr. Barry

Soetoro's birth in Kenya was registered in Hawaii, at which time, yes they

would have issued a COLB; however, Barry Soetoro's birth could have

ONLY been registered as "naturalized" as his mother did not meet the

citizenship requirements to register Barry Soetoro's birth as "natural born",

Nationality Act of 1940, revised June 1952, United States of America v.

Cervantes-Nava , 281 F.3d 501 (2002), Drozd v. I.N.S., 155 F.3d 81, 85-88

(2d Cir.1998), United States v. Gomez-Orozco, 188 F.3d 422, 426-27 (7th

Cir. 1999), Scales v. Immigration and Naturalization Service 232 F.3d 1159

(9th Cir. 2000), Solis-Espinoza v. Gonzales 401 F.3d 1090 (9th Cir. 2005),

and as such the law that applies to a birth abroad is the law in effect at the

time of birth, Marquez-Marquez a/k/a Moreno v. Gonzales 455 F. 3d 548

(5th Cir. 2006), Runnett v. Shultz, 901 F.2d 782, 783 (9th Cir.1990) (holding

that "the applicable law for transmitting citizenship to a child born abroad

Supplement Petition for Writ of Mandamus – Page 11 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

when one parent is a U.S. citizen is the statute that was in effect at the time

of the child's birth").

37. Mr. Barry Soetoro's citizenship status is further complicated by the

fact he was enrolled by Lolo Soetoro in a public school, Fransiskus Assisi

School in Jakarta, Indonesia; the records received as copies of the school

registration, in which it clearly states Mr. Barack Hussein Obama's name as

"Barry Soetoro" and lists his citizenship as Indonesian, shown as Exhibit H.

38. Mr. Obama's father is listed as Lolo Soetoro, and Mr. Obama's

Religion is listed as Islam.

39. At the time Mr. Obama was registered the public schools obtained

and verified the citizenship status and name of the student through the

Indonesian Government; and that Indonesia at this time was a police state

and foreign students were not allowed to attend public schools.

40. The Indonesian school, upon registration of a new student, verified

the citizenship status and name of the child with the Indonesian

Government; moreover, Indonesian Immigration and police checked all

public schools on a weekly basis to ensure the only students attending were

in fact Indonesian citizens.

41. Due to Mr. Obama's birth abroad, he could only be "naturalized",

second, he became a "natural" citizen of Indonesia; even if Obama's

Supplement Petition for Writ of Mandamus – Page 12 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

adoption and/or acknowledgment allowed him to choose his citizenship

status, there is more involved.

42. Indonesia, still to this day, does not permit dual citizenship, and the

law in Indonesia states if a minor who lost citizenship in another country

may reclaim that citizenship; however, prior to age 21, they must swear a

declaration signed and served and filed with Indonesia their desire to

relinquish their citizenship status.

43. Furthermore, if this is not done by age 21, they lose that right; and as

stated in the Indonesian laws, "at the age of 18, the child can choose whether

to stay an Indonesian citizen or follow their foreign father's citizenship. They

will be then given additional three more years to decide on which nationality

to choose.", e.g. 18 + 3 = 21.

44. The problem here is the citizenship of Mr. Obama's father "Soetoro"

is Indonesian; Indonesia did not recognize dual citizenship.

45. The Indonesian citizenship law was designed to prevent apatride

(stateless) or bipatride (dual citizenship); Indonesian regulations recognize

neither apatride nor bipatride citizenship.

46. The Hague Convention prevented the U.S. from interfering with

Indonesia's laws.

47. Indonesia did not recognize dual citizenship, thus, neither did the

Supplement Petition for Writ of Mandamus – Page 13 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

U.S.; and an adoption per se severs all relationship to the birth place and/or

citizenship of a birth parent.

48. Once Indonesian "natural" citizenship status occurred, it stayed; and

in order, according to Indonesia, which is whose law prevails, Mr. Obama

would have been required to relinquish in writing under oath his Indonesian

citizenship and file the declaration with Indonesia government.

49. Indonesian citizenship does not expire without a person, in

declaration, swears under the penalty of perjury, to relinquish Indonesian

Citizenship and files said document with the government no later then age

21, as under the Indonesian Constitution, Article 2.

50. If Mr. Barry Soetoro wanted to fully regain any U.S. Citizenship

status he may have had, he would have had to undue the adoption or go

through paternity to prove Soetoro was NOT his father in the case of Soetoro

Acknowledging Mr. Obama as his son, both of which gave Mr. Obama

"natural" Indonesian status, which is the same as U.S. "natural born"

citizenship status.

51. Under Indonesian law, when a male acknowledges a child as his son,

it deems the son—in this case Obama—to be an Indonesian State citizen;

the Constitution of Republic of Indonesia, Law No. 62 of 1958 Law No. 12

of 2006 dated 1 Aug. 2006 concerning Citizenship of Republic of Indonesia,

Supplement Petition for Writ of Mandamus – Page 14 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

and Law No. 9 of 1992 dated 31 Mar. 1992 concerning Immigration Affairs

and Indonesian Civil Code (Kitab Undang-undang Hukum Perdata)

(KUHPer) (Burgerlijk Wetboek voor Indonesie).

52. Further, the Indonesia Constitution, Article 2 states "It is stipulated

that an adopted child has the same status as a natural child and that his or

her relationship to the birth parents is severed by adoption".

53. Further, the Indonesia Constitution, Article 2 states: "on the condition

of ratification of the adoption by the District Court: ‘The law stipulates that

children of mixed couples automatically assume their father's citizenship,

and a divorced wife cannot take custody of her children because they have

different citizenship’….”.

54. Furthermore, Indonesia did not allow Dual Citizenship or Dual

Nationality thus Mr. Barry Soetoro is not a U.S. Citizen, he is Indonesian;

neither Mr. Obama's place of birth or the nationality of his American parent

are relevant, the Indonesian Law takes precedence under The Master

Nationality Rule of Article 4 of the Hague Convention of 1930.

55. The United States accepts the existence of Dual Nationality only if

the other country does; however, Hague Conventions are applied by the

United States and this has been in effect since before 1930 (Memorandum

on Nationality, including Statelessness: Document A/CN.4/67, Prepared by

Supplement Petition for Writ of Mandamus – Page 15 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

Ivan S Kerno, International Law Commission, United Nations General

Assembly, 6th April 1953.); thus, Mr. Barry Soetoro is not a "natural born"

citizen and my not even be a naturalized citizen.

ARGUMENT IN SUPPORT OF RELIEF

56. Petitioner / Plaintiff has standing to sue under the Freedom of

Information Act (FOIA), 5 U.S.C. § 552 et seq. (1994); and anyone denied

information under the Freedom of Information Act (FOIA), 5 U.S.C. § 552

et seq. (1994) has standing to sue regardless of his or her reasons. Akins

vs.FEC, 322 US. App. D.C. 58; 101 F.3d 731; 1996 U.S. App. LEXIS 31253

(1996), 524 U.S. 11 (1998); Public Citizen vs. FTC, 276 U.S. App. D.C.

222, 869 F.2d 1541(D.C. Cir. 1989).

57. Petitioner / Plaintiff has suffered an informational injury as a voter

and member of the public; and the lack of information on Mr. Barry

Soetoro's citizenship, caused by the State Departments action, limited the

information available to him as a voter and impaired his ability to influence

and inform the public and policymakers.

58. If a party is denied information that will help it in making a voting

decision that party is obviously injured in fact; and as stated in Akins, the

court noted that:

"[a] voter deprived of useful information at the time he or she votes

suffers a particularized injury in some respects unique to him or herself

Supplement Petition for Writ of Mandamus – Page 16 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

just as a government contractor, allegedly wrongfully deprived of

information to be made available at the time bids are due, would suffer a
particularized injury even if all other bidders also suffered an injury."

59. Even if all individuals who voted for any of the other Democratic

candidates for President, suffered the same injury that does not take away

from the individual injury that Petitioner / Plaintiff suffered.

60. Even assuming a request under FOIA triggered legitimate Privacy

Act concerns, the U.S. Department of State was required to provide

Petitioner with reasonably segregable portions of that correspondence, 5

U.S.C. §552(b); Department of State v. Ray, 502 U.S. 164 (1991) (disclosure

of personal information without identifying details), Baltimore Sun v.

Marshals Service, 131 F. Supp. 2d 725, 729 (D. Md. 2001) (identity of

purchasers of seized government property disclosed).

61. There are no per se rules of nondisclosure, see Stern v. FBI, 737 F.2d

84, 91 (D.C. Cir. 1984); and FOIA Exemption 6 does not justify the

withholding of information regarding individuals particularly where the

privacy interest is minimal and the public interest in disclosure is strong, and

the balance of interests under Exemption 6 "instructs the court to tilt the

balance in favor of disclosure." Getman v. NLRB, 450 F.2d 670, 674 (D.C.

Cir. 1971).

62. These issues can be easily resolved; the documents requested will

Supplement Petition for Writ of Mandamus – Page 17 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

either prove that Barry Soetoro is in fact a "natural born" U.S. Citizen or

they will prove he is not, at which point he will have to be removed as the

Presidential candidate and would require a restraint upon the Electoral

College vote cast and certified on or after December 15, 2008; however,

after January 20, 2009 will require Defendant U.S. Department Of

Homeland Security with control of the Bureau of Customs and Border

Control to enforce U.S. Title 8 and related laws as to Mr. Barry Soetoro, and

the living person using the SSN: 535-40-8522 accordingly in coordination

with the U.S. Department of Justice.

63. For the above aforementioned reasons, the above requested

documents are of great public interest and without receiving said documents;

our Country is at risk of allowing an illegal candidate to serve as President

of the United States which constitutes a huge National Security dilemma.

64. The court determines whether disclosure is warranted by

"balanc[ing] the public interest in disclosure against the [privacy] interest

Congress intended the Exemption to protect." Dep't of Justice v. Reporters

Comm. for Freedom of Press, 489 U.S. 749, 776 (1989). The public interest

in disclosure lies in "open[ing] agency action to the light of public scrutiny,"

Reporters Comm., 489 U.S. at 772.

65. Under FOIA, 5 U.S.C. § 552, Attorney Fees and Costs are

Supplement Petition for Writ of Mandamus – Page 18 of 20

 Strunk v. U.S. Department of State et al. DCDC 08-cv-2234

AMENDED VERIFICATION

STATE OF NEW YORK )

) ss.
COUNTY OF KINGS )

Accordingly, I, Christopher Earl Strunk, being duly sworn, depose and say under penalty

of perjury:

1. That I am the Plaintiff / Petitioner, Christopher Earl Strunk, pro se without being

an attorney, with place for service at 593 Vanderbilt Avenue #281 Brooklyn, New

York 11238; Email: uncasvotes2@yahoo.com Cell- (845) 901-6767.

2. I am an active voter within the New York 57th Assembly District (AD) and NY

18th Senate District (SD) created in April 2002.

3. I have read the attached Supplement Amended Petition in FOIA Case 08-cv-2234

for Extraordinary Relief in the Nature of a Writ of Mandamus and I know its

contents; the facts stated in the Petition are true to my own personal knowledge,

except as to the matters therein stated to be alleged on information and belief, and

as 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: 3rd parties, books

and records, and personal knowledge. except as to those stated upon information

and belief, which I believe to be true.

________________________
Christopher Earl Strunk
Sworn to before me
This ____ day of January 2009

_____________________
Notary Public

Supplement Petition for Writ of Mandamus – Page 20 of 20

VERUI'IIED COMPLAINT and PETITION for
WRlT OF MANDAMUS under F.O.I.A.

EXNIBIT "A"
 Christopher Earl Stnmk
593 Vanderbilt Av- -#282
Brooklyn, New York 11238

UNITED STATES DEPARTMENT OF STATE

2201 C StreetN.W
WashingtMl D.C 20520

Attn: FOIA Wormation OBcer

Subject: Freedom of Lafhmion Act Request

for tmvd rPconis of Stanley Ann Dunham ( M a ) .
To whom it may concern,
As ofright under the Freedom of I n f o d o n Act, 5 U.SC.
subsection 552, I am reqwdhg hfmnation or records related to StanIey
Ann Dunham born Novernber 29,1942 at Fort Leavenworth KS. US.,a.ka.
Stanley Ann Dtmhm Obama a.ka and who died on November 7,1995
rm&r the name Stanley Am Drmbam Soetoro (aka. Sutaro) for my and or
all exit and entry records fw travel outside of the USA for the period
befweea 1960 through 1963.
If there are anyfees for m b b g fer, reviewing, or copring the
records, please let me know before you task my request.
lfy w deny alI or any part of this quest, please cite each specific
Exemption you think justifiesyour refid to mlease the i n f o d m and
not&rnr uf appeal pkc& availaMe under the law.

Sincerely yam,
VERIFIED CQMPLAWT and PETITION far
WRIT OF MANDAMUS under F,O.I.A.
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VERIFIED COMPLAINT and PETITION for
WRIT OF MANDAMUS under F.O.I.A.

EXHIBIT cCC"
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status: Oeltvered
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Your Hem was delivered at 1252PM on Odokr 27,2008 in
WASHINGTON. DC 20520.

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VEFUFIED COMPLAINT and PETITION for
WRIT OF MANDAMUS under F.O.I.A.
VERIIFIED COMPLALNT and PETITION for
WRIT OF MANDAMUS under F.O.1.A.

EXHIBIT "F;?
Thank you. Your request has been subm-W.

Thls is a request filed under the Freedom of Infomation Act. Return to FOIA Request Generator

Request Date: 11/22/2008 Return to FOIA Home Page

Request Reference Number: 88475

The time period of my request is between 1/1/1960 and 12/31/1985

Description of request:
As a matter of statutory responsibilty by act of Congress the U.S. Department is to
maintarn records for the below listed natural persons and that pursuant to the Freedom
of lnformation Act are to turn over the following documents on the following individual:
1. m n l e y Ann Dunham, a/k/a Ann Dunham a/k/a Stanley Ann Obama a/k/a Ann
Obama a/k/a Stanley Ann Soetoro a/k/a Ann Soetoro a/k/a Stanley Ann Sutoro a/k/a
Ann Sutoro a/k/a Stanley Ann Dusham Obama a/k/a Ann Dunham Obama, born
November 29,1942 a t Fort Leavenworth US. U.S., a k a . Stanley Ann Dunham Obama
and who died on November 7,1995 under the name Stanley Ann Dunham Soetoro (a.La.
Sutoro), SSN: 535-40-8522; and 2. Barack Hussein Obama, Jr. a/k/a Barry Soetoro Date
of Birth: August 4,1961 and The following documents for subjact (1)and (2). a. Any
and all U.S. Applications for a U.S. Passport; b. Entry and Exit Passport Records
pertaining t o the United States and Kenya from the period of time of January 01,1960 t o
December 31,1975 and January 1,1979 t o December 31,1985; c. Entry and Exit
Passport RecoMs pertaining t o the United States and Indonesia from the period of time
of January 01,1960 t o December 31,1973 and January 1,1979 to December 31,1985;
d. The above travel records on for the dates specified travelling on a U.S. Passport,
Kenyan Passport, Zndonesian Passport or any other foreign passport and/or visa; e.
Foreign Birth Certificate registered and filed with the U.S. Embassy, Kenya and/or US.
Embassy of Indonesia for Barack H. Obama a/k/a Barry Soetoro, Date of Birth: August
4, f961; f. Foreign BirZh Registry filed with the U.S. Embassy, Kenya and/or U.S.
Embassy of Indonesia by Stanlq Ann Dunham, et al. Registering the birth of Barack H.
dbama a/k/a Barry Soetoro, Date of Birth: August 4,1961; and g. Adoption Records
and/or Governmental "Acknowledgment" whereln Barack H. Obama a/k/a Barry
Soetoro was "acknowledgedn as Lolo Soetoro, M.A8s son.

For faster processing please restrict the parameters of this FQIA request to the State Archiving
3 System (SAS)--over 25 million efectronfcrecords consisting of telegrams from mid-1973 to
present.

I am willing to pay fees for this request up to a maxjmum of $100.00

I n order to help to determlne my status to assess fees, you should know that Iam

a representative of the news media affiliated with and this

T! request is made as part of a news gathering effort and not for commerciai use.(~dditional
documentation or comments will be required. See
affiliated with an educational or noncommercial scientific institution, and this request is made for a
(3. scholarly or scientific purpose and not for commercial use.(Additional documentation will be required.
See

an Indlvldual seeking Information for personal use and not for comrnercial'use.

(3 afflliated with a private corporation and am seeking information for use in the company's business.
Additional Comments
As a matter of record and follow-up: On October 17,2008,X filed a FOIA request
regarding Stanley Ann Dunham (0bama)for the period from 1960 through 1963, via
United States Postal Sewlce, Certified Mail, Return Receipt Requested; That on October
30, 2008, Respondent agent signed the return receipt for the FOIA request; and That as
of this date November 21, Petitioner has still not receive any response, as required
pursuant to 5 USC 552.

Thank you for your consideration of my request. Sincerely,

Christopher Earl Strunk.

E-mail Address:
cestrunck@yahoo.com

Street Address :
-
593 VanderbiIt Avenue #28 1
Brooklyn, New York
11238

Telephone Number: 845-901-6 7 67

Fax Number:
VERIFIED COMPLAINT and PETITION for
WRIT OF MANDAMUS under F.O.I.A.

EXHIBIT "F"
 Christopher Earl Strunk
593 Vanderbilt Avenue - #28 1
Brooklyn, New York 1 1238

November 22,2008

Officeof Information Programs and Services

A/?SS/IPSIRL
U. S. Department of State
Washington, D. C. 20522-8 100

Subject: Freedom of Information Act request support

Declaration related to Reference Number: B8475.

Dear FOIA Officer:

The required declaration with original signature under 28 USC 1746 for the
request with the referenced number that seeks personal information about a
livina-pe~son, is herewith for your information and us, along with a
confirmation copy of the actual FOIA request detailed and generated on this
date.

Importantly, as a follow-up to my FOIA request of October 17,2008, having

been recorded as received by the FOLA officer on October 30,2008, for
which I received no response, a copy is attached herewith.

Theses matters are urgent and require expedited handling as time is of the
essence and involve matters of irreparable harm if not handled emditiously.

Sincerely yours,

Attached:

Declaration with original signature;

Copy of the FOIA request ref. no. B8475.
Copy of FOIA request received October 30,2008.
 Subject: Freedom of Information Act request support

Declaration related to Reference Number: B8475.

I, Christopher Earl Strunk, declare under penalty of perjury, pursuant to 28

U.S.C. 5 1746 as follows:

1. I am petitioner with place for service at 593 Vanderbilt Avenue

#281 Brooklyn, New York 11238; Email: cestrufick@yd~oo.

corn with Cell-

(845) 90 1-6767.

2. This declaration is in support of my Freedom of information

Act request related to Reference Number: B8475;and

3. Therequireddeclarationwithoriginalsignatu~eunder28USC

1746 for the request that seeks personal infomation about a living-person.

Respectfully submitted for relief as time is of the essence with imminent

irreparable h m that would result.

Dated: N o v e m b e r g , 2008
Brooklyn New York

Earl
~hristo~hd r Strunk
cc:

Office of Information Programs and Services

A/ISS/IPS/RL
U. S. Department of State
Washington, D. C. 20522-8 100
 Thank 'you,Your request has been submitted.

fhls is B request R I ' d uhder $he Freedom of Information Act.

Request Pate: 11if22~2008
umber: 88475
Request-Refe.rence.ff

O e m t i o n of requesk
4 s a matter of statutory responsibitlty by act of Congress the U.S. Department is to
m a i min records for the below listed natural persans and that pursuant tro the Freedom
ofTnformation A d are to turn over the fallawing documents on the following individual:
1. Stanley Ann Dunham, a/kja Ann bunham a/k/a Stanley Ann O b a m a/k/a Ann
Obama afk f a Stanley Ann Soetoro a/k[a Ann Wekoro a/k/a Stanley Ann S-Q a/k/a
4nn Sutoro 8f k/a Stanley Ann Dunham Qbama a/k/a Ann Dunham Obama, born
November 29,1942 at fort Leavenworth KS. U.S., a,k.a. Stanley Ann Dunham Obama
and who died on November 7, 1995 under the name Stanley Ann Dunham !%Mom(a.k.ab
Sutoro], SSM: 535-404522; and 2. Baradr Hussein Obama, Jr. a/k/a Barry Soetom Pate
of Birth: August 4#2961 and The fatlowing documents for subject (1)and (2): a. Any
and all U.S. Appltcations for a U.S. Passport; b. Entry and Exit Passport Rwords
p-inirrg to the Unitrad Statesand Kenye From the period of time of January 01,1960 to
December 31,1975 and January 1,1979 to December 31,1985; c. and Exit
Passport Records pettahitlg to the UnRed States and f ndonesk from the period of t?me
of Jlanuary Oi, 1960 to December 31,1973 and January I ,
1979 to ~eeember31,198s;
d. The above tritvet records on for the cfates specified t$walling on a US. Passport,
Kenyan Passport, Indonesian Passport or arty other fordgn pass-& and/dr *a; e.
Foreign Birth Certificate registered and filed with the U.S. Embassy, Kenya and/or U.S.
Embassy of Indonesia for Bareck H. Obama a/kja Bany Soetoro, Date of Birth: August
4, 1961; f. Foreign Birth Registry filed with the U.S. Embassy, Kenya andjar US.
E d a s s y of Indonesia by Stanley Ann Dunham, et al. Registering the birth of Etarack H.
Obama a /k/a Barry Soetora, Date of Birth: August 4#1961;and g, Adoption Records
andlor Govemmenbl "Acknowledgment" wherein Barack H. dbama a/k/a Barry
Soetoro was "acknowledged" as Lob Soetoro, M.A.'s eon.

Far fiKter processing please restrict the parameters of this FOfa request to the State Ardllvh¶
System (sAs)--w~~ 25 mlllion e!&mnic records consisting af telegrams from mid- 1 73 to
&7mOfB
1.

it -- Pmm'-+ [F 1 7 ~ I PIsR~Q\*
X
-

f am wllling to pay Fees for this request up to a maxtmum of $100.00

~ I E ~ wa w m - 1
W iW edw%~atW scmtifk inskiwtion, snd<@rs.
request is,W e far 4
S&fhtiy nr & h M k 2 ~ m fix cqtnnad.l M[.-I dosummkatla WI ac ~guirad
w@
Additional Comments
As a matter of record and follow-up: On October 17, 2008, Ifiled a FOIA request
regarding Stanley Ann Dunham (0bama)for the period from 1960 through 1963, via
United States Postal Service, Certified Mall, Return Receipt Requested; That on October
30, 2008, Respondent agent signed the return receipt for the FOIA request; and That as
of this date November 21, Petitioner has still not receive any response, as required
pursuant to 5 USC 552.

Thank you for your consideration of my request. Sincerely,

Christopher Earl Strunk.

E-mail Address:
cestrunck@yahoo.com

Street Address :
593 Vanderbilt Avenue - #281
Brooklyn, New York
1123%
Teiephone Number: 845-901-67 67
Fax Number:
VERIFIED COMPLAINT and PETITTON for
WRIT OF MANDAMUS under F.O.I.A.
--------
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JAF 31st STREET

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11/22/2008 (2123330-2183 09: 55:19 PN
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WASHINGTON DC 20522
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call 1-6WStamp24, Go to
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 SUPPLEMENT TO THE VERIFIED COMPLAINT
and PETITION for WRIT OF MANDAMUS under F.O.I.A.

EXHIBIT “H”
 SUPPLEMENT TO THE VERIFIED COMPLAINT
and PETITION for WRIT OF MANDAMUS under F.O.I.A.

EXHIBIT “I”
 Christopher Earl Strunk
593 Vanderbilt Avenue - #28 1
Brooklyn, New York 11238

Bureau of Custoins and Border Control

of the U.S. Department Of Homeland Security
799 9"' Street, N. W.
Mint Annex
Washington D.C 20229

Attn: Mark I-Ianson Director FOIA Division

Subject: Freedoin of Information Act Request

for travel records of Stanley Ann Dunham
(Obama) and Barack Hussein Obama. Jr. dWa
Barry Soetoro.
Dear Director Hanson.

As of right under the Frccdo~nof Information Act: 5 U.S.C. subsection 552,

1 am requesting information or records related to:

a. Stanley Ann Dunham. M a Ann Dunhain aMa Stanley Ann Obama

a/Wa Ann Obama alkla Stanley Ann Soetoro a/k/a Ann Soetoro a/k/a
Stanley Ann Sutoro a/k/a Ann Sutoro a/k/a Stanley Ann Dunham
Obama dWa Ann Dunhain Obama, born November 29. 1942 at
Wichita KS. U.S., a k a . Stanley Ann Dunhain Obaina and who died
on November 7, 1995 under the name Stanley Ann Dunhain Soetoro
(a.k.a. S u t o r ~ SSN:
) ~ 535-40-8522: and

b. Barack Hussein Obaina. Jr. dk/a Barry Soetoro Date of Birth:

August 4, 196 1 and as a living natural person; and

In regards to the following documents:

c. Any and all U.S. Applications for a U.S. Passport;

d. Entry and Exit Passport Records pertaining to the United States
and Kenya from the period of time of January 0 1. 1960 to December
3 1. 1975 and January 1. 1979 to December 3 1, 1985;
c. Entry and Exit Passport Records pertaining to the United States and
Indonesia from the period of lime of January 0 I , 1960 to December
3 1. 1973 and Januaq- 1. 1979 to December 3 1, 1985:
 f. The above travel records on for the dates specified traveling on a
U.S. I'assport. Kenyan I'assport. Indonesian Passport or any other
foreign passport and/or visa:
0
E'
Foreign Birth Certificate registered and filed ivith thc U.S. Embassy.
Kenya and/or U.S. Embassy of Indonesia for Barack 1-1. Obama a/k/a
Harry Soetoro. Date of Birth: August 4. 1 96 1 :
h. Foreign Birth Registry filed with the U.S. Embassy. Kenya and/or
U.S. Embassy of Indonesia by Stanley Ann Dunham. et al.
Registering the birth of Barack M. Obama a/k/a Barry Soetoro, Date
of Birth: August 4, 196 1 : and
i. Adoption Records and/or Governmental "Acknon-ledgment"
wherein Barack 11. Obama a/k/a Barry Soetoro was "ackno~vledged"
as Lolo Soetoro, M.A.'s son.

I. Christopher Earl Strunk. declare under penalty of perjury. pursuant to 28

U.S.C. 9 1746 as follows:
I am petitioner with place for service at 593 Vanderbilt Avenue #281
Brooklyn. New York 1 1238: Email: cestrunck@vahoo.com with Cell- (845) 90 1 -
6767.
This declaration is in support of my Freedom of Information Act request
that seeks personal information about a living person subject Barry Soetoro a/k/a
Barack Hussein Obarna. as a matter of personal non co~nmercialuse; and that
In addition the deceased person who died on November 7. 1995 under the
name Stanley Ann Ilunharn Soetoro (a.k.a. Sutoro). with SSN: 535-40-8522.
remains deceased according to a Wikipedia report (see attached). and as a matter
of Bureau of Custo~nsand Border Control concern. based upon information and
belief there is an imposter presently using the deceased SSN: 535-40-8522 for
employment at the Ford Foundation and is residing in New York City.
If there are any fees for searching for. reviewing, or copying the records.
please let me h o \ v before you task my request.
If you deny all or an>-part of this request. please cite each specific
Exemption you tliinkjustifies your rehsal to release the inlormation and notify me
of appeal procedures available under the law.
A A

Dated: December
Brooklyn New York
-
Christopher Earl Strunk
attachment
 Stanley Ann Dun ham : From Wikipedia. the fire encyclopedia
\vas an anthropolo~istwho specialized in
Ann Dunham rural development. Born in Kansas. Dunliani
-
attended high school near Seattle,
Washington. and spent most of her adult life
in I-lawaii. She was the mother of United
States Senator and presidential candidate

Photo of' Ann Dunham. circa 1971
Stanley Ann Dunham
Born November 29, 1942
Fort Leavenworth. Kansas.
November 7. 1995 (aged 57)
Died
Honolulu, Hawaii,
Early life
Ann Dunham was born in Fort Leavenworth,
(some say Wichita, ~ a n s a s )while
,~
her father was in the n ~ i l i t a r yShe
. ~ was
named after her father,lil who reportedly gave
his daughter and only child his name because
he had wanted a boy: however. she \vas
referred to as " ~ n n . " ~

Cause of death Ovarian and uterine cancer ller parents. Stanley Arnlour Dunham (born
on March 23. 1918. raised in El Dorado.
Resting place Pacific Ocean Kansas. died Februaq- 8. 1992-buried in the
Nationality American
Punchbowl National Cemetery) and Madelvn
Dunham (nee Madelyn Lee Payne) (kvho was
Education B.A., M.A., P~.D.[" born in 1922 and raised in Augusta Kansas
and is still living in Honolulu. Hawaii), met in
Alma mater Universitv of Hawaii Wichita. Kansas. and married on May 5.
1940.~
Occupation Rural development

Home town --
Wichita Kansas
After the Pearl Harbor attack her father joined
the A r m y and her mother worked at a Boeing
Barack Obarna (Sr.1 . ~the end of World War
plant in ~ i c h i t aAt
(1 96 1-1 964) (divorced) I1 she moved with her parents to California,
-

Lolo Soetoro
Texas, and Seattle. Washington. ~vhereher
father was a furniture salesman and her
(c. 1967-1 980) (divorced)
mother worked for a bank. The family nloved
Barack Obarna to Mercer Island. Washington. in 1956 so that
Children 13-year old Ann could attend the Mercer
Maya Soetoro-Ng
Island high school that had just opened.u
Parents Madelyri and Stanley Dunharn where teachers Val Foubcrt and Jim
Wichterman taught the importance of
challenging societal norms and questioning
Stanley Ann Dunham Soetoro (November authority. Dunhan~took the lessons to heart:
29. 1942 - November 7. 1995). known as "She felt she didn't need to date or marry or
Ann Dunham. and later as Ann !3utoroLll ha\-e children." A classmate remembers her as
"intellectually way more mature than we were and a little bit ahead of her time, in an off-center
~ a y . "One
~ . high school friend described her as: "If you were concerned about something going
wrong in the world. Stanley [Ann] would know about it first ... We were liberals before we knew
what liberals were." Another called her "the original feminist."16-l

Move to Hawaii and first marriage

In 1959 Dullham's parents moved to Hawaii to pursue further business opportunities in the new
state. She soon enrolled at the University of Hawaii at Manoa, where she studied anthropologv. She
met Barack Obama Sr., a student from Kenva and the school's first African student, in a Russian
language class at the ~ n i v e r s i tWhen
~ . ~ they became engaged. both sets of parents opposed the
marriage. with Obanla's father in particular objecting. Nevertheless, the couple married on Febniary
2,1961 in Maui. Hawaii, after discovering she was pregnant. m

On August 4. 1961, at age 18. she gave birth to her first child.
named Barack Obanla 11.

In an interview, Senator Obanla referred to his mother as "the

dominant figure in my fornlative years ... The values she taught ine
continue to be my touchstone when it comes to how I go about the
world of politics."u

Obama Sr. left i h and their son in 1963, when he began studying
at H m a r d Universitv in Cambridge. Massachusetts. Dunham filed
for divorce in Honolulu. Hawaii in January 1964: Obama did not
contest it and the divorce was granted.w The senior Obanla
obtained a masters degree in economics at Harvard and in 1965.
returned to Kenya. wrhere he obtained a position in the Kenyan
government. Friends report that. later in life. he "was drinking too
much" and became bitter and frustratedu He was killed in an
automobile accident in 198LLsl Ann Dunham and Barack Obama

References

1.
2.
Amanda Kipley (2008-04-09). "The Stow of Barack Obama's Mother".
~ l k ~ d e f g h _Scott.
L i
m. Retrieved on 2007-04-09.
Janny (2008-03-14). "A Free-Spirited Wanderer Who Set Obama's Path". New lork Tin~es.
Retrieved on 2008-03-2 1 .
3. A C L C Fred Mann (2008-02-02). "Kansas roots show in Obama", The Ftricl?itaE a ~ l e via. w. p. 1 B. Retrieved on
2008-04-0 1 .
3. A ht~://wnw.wares.com/politicaI/oban~a.litml
5. :Obama Press Office (2008-0 1-29). "Gov. Kathleen Sebelius Endorses Rarack Obama". Reuters. Retrieved on
2008-04-0 1.
B ~ . (2007-03-27). "Obarna's mom: No1 iust a girl from Kansas: Strong personalities shaped a
6. ~ r t h ~ d ~ i ~h r?nJones
future senator". Cl7icaao Tribune. Retrieved on 2008-01-22.
7. " = "A Special Report: The Obama Family Tree". Chicago Sun-Tinres (2007-09-09). Retrieved on 2008-04-01.
8. 2 Muliro Telewa (2004-08-20). "US election makes waves in Kenva", BDC N E ~ I ' SRetrieved
. on 2008-04-01.