Amended Verified Complaint and Petition in Re FOIA USDC DC 08cv2234 010509 With Original FOIA Complaint of 11/22/08

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:

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

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

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).

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

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

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.

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).

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

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

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

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

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,

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

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

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

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

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

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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POSFht EXPERIENCE
VERIFIED COMPLAINT and PETITION for
WRIT OF MANDAMUS under F.O.I.A.
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VEFUFIED COMPLAINT and PETITION for
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:
EXHIBIT "F"
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.
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
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
United States Postal Service, Certified Mall, Return Receipt Requested; That on October

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
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Sales Receipt
Product Sale Unit Final
Description Pty Price Price
WASHINGTON DC 20522
L o w 3 F i rst-Class
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Return Rcpt (Green
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Certified
label #:
Iswe P V I :
Total :
Paid by;
Cash
Change Due:
Order stamps at USPS.corn/shop or

call 1-6WStamp24, Go to
WS.com/cIickn&ip t o print
shippiw labels ~ 5 t hpostage, For
other informatian call
1-800-ASK-USPS ,
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POSTAL EXPERIENCE
YOUR WINION COUNTS
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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”
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

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
-
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
Early life
Photo of' Ann Dunham. circa 1971
Ann Dunham was born in Fort Leavenworth,
Stanley Ann Dunham (some say Wichita, ~ a n s a s )while
,~
Born November 29, 1942 her father was in the n ~ i l i t a r yShe
. ~ was
Fort Leavenworth. Kansas. named after her father,lil who reportedly gave
his daughter and only child his name because
November 7. 1995 (aged 57) he had wanted a boy: however. she \vas
Died referred to as " ~ n n . " ~
Honolulu, Hawaii,
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.
November 22,2008
U.S. District Court Clerk's Office

333 Constitution Avenue, NW,Room 1225,
Washington, DC 20001
Subject: Strunk v. US Department of State

Expedited Request for Poor person relief
Dear Clerk of the COW:
I am the petitioner Christopher Earl Stmnk, pro se without being an attorney, hereby
request expedited processing for poor person relief for filing fees and service of the
combined Verified Complaint and Petition for Writ of Mandamus under the Freedom of
Information Act (FOIA). This is related to the election of the President, and therefore as
it involves imminent irreparable harm as time is of the essence am unable to wait 4 to 6
weeks because it is related to the election of the president by the elec~oralcollege that
will be certified December 1,2008 and assembled to cast a vote on December 15,2008.
That as per your instructions 1 have completed the application to proceed without
prepayment of fees and affidavit. That I am unable to afford the fee and service costs, and
am not able to pay up h n t and would suffer injury were I at least not allowed to make
progress payments at say $50.00 per week which is the most I am able to afford.
Tbis matter complained of is mtremely urgent and requires expedited handling as time is
of the essence and involve matters of irreparable harm if not handled expeditiously.
Thank you in advance for your cooperation in tbis matter aad for firher directions please
Sincerely
Attached:
Application to Proceed without prepayment of fees and affidavit endorsed 112208
The Original and two copies of the Verified Complaint and Petition for Writ of
Mandamus under FOIA with verification afFumed 1 12208;
Certificate of Senrice of notification to the U.S. Department of State

District of COLUJlA
APF'LICATION TO PROCEED
Plaintiff WITHOUT PREPAYMENT OF
FEES AND AFFIDAVIT
v.
VIL CASE NUMBER:
Defendant
declare that I am the (check appropriate box)

other
in the above-entitled p r o d i g ; that in support of my request to proceed without prepayment of fees or costs
under 28 USC 8 19 I5 1declare that 1am unable to pay the costs of these proceedings and that T am entitled to the
relief sought in the complaint/petition/motion.
In support of this application, I snswer the following questions under penalty of perjury:
I . Are you currently incarcerated? 0 Yes %N
-' O , (If "No," go to Part 2)
Are you employed at the institution?

+
If "Yes," state the place of your incarceration W/A
Do you receive any payment fiom the institution?
Attach a ledger sheet from the institution(s) of your incarceration showing at least the past six months'
transactions.
2. Are you currently employed? No
a. If the answer is "Yes," state the amount of your Lake-home salary or wages and pay period and give @e
and pay period and the name and adckss of y o u ~employer.

l ~
3. In the past 12 twelve months have you received any money from any of the following sources?
a. Business, profaion or other self-employment %yes No
b. Rent payments, interest or dividends a yes %No
c. Pensions,annuities or life insurance payments Yes mo
d. Disabi liq or workers compensation payments 0 Yes Y o 0
e. Gifts or inheritances El Yes mo
f. Any other sources Yes N o
1f the answer to my ofthe above is 'Yes," describe, on the following page, each source of money and state the
amount received and what you expect you will continue to receive.
4. Do you have any cash or checking or savings accounts? O Yes
If 'Ye%"state the total amount. rJ/a

5.
thing of value? O Yes *
Do you own any real estate, stocks, bonds, securities. other financial instruments. automobiles or any other
If "Yes,"describe the property and state its value
6. List the persons who are dependent on you for support, state your relationship to each person and indicate
how much you contribute to their support. (If children me dependents, please refer to them by their initials)
Y ~ M . O Gl;))hl
D . R F WI AI ~, ~ L D e t ~ ~ W(TH
w-
I declare under penalty of perjury that the above information is true and correct.
Y
Dmc I Signature of Applicant
NOTICE TO PRISONER: A Prisoner seeking to proceed without prepayment of fees shall submit an affidavit
stating a11 assets. In addition, a prisoner must attach a statement certified by the appropriate institutional officer
showing a11receipts, expenditures,and balances during the last six months in your institutional accounts. If you have
multiple accounts, perhaps because you have been in multiple institutions, attach one certified statement of each
account.
Rev. 4
1w
NP
INSTRUCTIONS FOR FILING A C M L COMPLAINT mON-PRISONER1
The filing Fee to file a new civil case is $350.00. If you c m o t afford to pay the filing fee, you may
ask the Court to permit you to proceed without prepayment of costs. To do this, you must complete and sign
the attached Application to Proceed without Prepayment of Fees and Affidavit, and submit it with your
original complaint.
The name ofthis Court must be written at the top of the first page ofyour complaint. (Sample format
attached).
Pursuant to ourLocal Rules, your name,address and teleohone number must appear in the caption.
A Post Office Box is insufficient as an address, unless you file a separate motion asking the Court
to permit such an address.
All defendants be named in the caption. The use of et al. is permitted as the d e s require
you to name each defendant. Please provide the address of each named defendant.
The word COMPLAINT must appear under the caption. Clearly set out your grievance in the body
of the complaint, name those against whom you have a grievance, and what you would like the Court
to do to correct the situation,
Your complaint must be leeibly handwritten or typed on white, letter-size (8 112 x 1 1 inch) paper.
Write only on the front of each page. Your complaintmust be double-spaced. If you are requesting
a jury trial, the jury demand must be stated in your complaint.
You originally sign your complaint in ink.
You file the orbiginallysigned complaint, as well as the originally signed Application to Proceed
without Prepayment of Fees, if applicable. DO NOT SEND BOTH THE FILING FEE AND THE
APPLICATION TO PROCEED WITHOUT PREPAYMENT OF FEES, only onc or the other.
Preparation of the summons will be the responsibility of the Clerk's Office, upon direction of the
Judge.
Please allow approximately 4-6 weeks for approval of the Application to Proceed without
Prepayment of Fees. Written notice will be mailed.
Please mail your complaint and all other appropriate documents to: U.S. District Court Clerk's
Office,333 Constitution Avenue, NW, Room 1225, Washington, DC 20001.
NANCY MAYER-WHIITINGTON, CLERK

--------------------------------------------------x Case No.:
:
CHRISTOPHER EARL STRUNK : VERIFIED COMPLAINT
: AND PETITION FOR
Petitioner, : WRIT OF MANDAMUS
v. : UNDER F.O.I.A.
:
U.S. DEPARTMENT OF STATE :
:
Defendant. :
:
--------------------------------------------------x
NOW COMES Christopher Earl Strunk, as the Petitioner, and
brings this Complaint pursuant to the Freedom of Information Act, 5 U.S.C.
§552, et sequitur, against the Defendant the United States Department of
State, 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.
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 is located within the District of
Petition for Writ of Mandamus – Page 1 of 18

Columbia and the failure of the Defendant to act was also within the District
of Columbia.
3. Petitioner filed this complaint requesting this Court to Order the U.S.
Department of State 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 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 Soetoro (a.k.a.
Sutoro), SSN: 535-40-8522; and
b. Barack Hussein Obama, Jr. a/k/a Barry Soetoro Date of Birth:
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
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;
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 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.
FACTS
10. 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.

11. 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.
12. 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).
13. 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).
14. 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).
15. 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.
16. 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.
17. A true and correct copy of the return receipt is attached hereto and
incorporated see Exhibit G.
18. The above records do not fall within any of FOIA exemptions items.
19. 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
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).

20. The above requested documents are extremely critical and important
to Petitioner as well as the general public and are of substantial public
interest.
21. 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.
22. 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,
23. 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.
24. 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.

25. 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).
26. 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.
27. Stanley Ann Dunham, Senator Obama's mother, was only 18 when
she had Obama. 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).
28. Mr. Obama has been asked for his "vault" version birth certificate;
however, he has refused, which has prompted law suits across the United
States.
29. Instead, Mr. Obama and or his agent(s) placed an image of a
Hawaiian Certification of Live Birth (COLB), which is issued for all birth's
registered in the State of Hawaii; the COLB, does not prove "natural born"
citizenship or birth in Hawaii.
30. 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".
31. There is absolutely NO doubt in Petitioner’s mind that Mr. Obama's
birth in Kenya was registered in Hawaii, at which time, yes they would have
issued a COLB; however, Obama's birth could have ONLY been registered
as "naturalized" as his mother did not meet the citizenship requirements to
register Obama'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 when one parent is a U.S.
32. Mr. Obama'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. Obama's name as "Barry Soetoro" and lists his
citizenship as Indonesian (see Exhibit Addendum).
33. Mr. Obama's father is listed as Lolo Soetoro, and Mr. Obama's
Religion is listed as Islam.
34. 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.
35. 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.
36. Due to Mr. Obama's birth abroad, he could only be "naturalized",
second, he became a "natural" citizen of Indonesia; even if Obama's
adoption and/or acknowledgment allowed him to choose his citizenship
status, there is more involved.
37. 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.
38. 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.
39. The problem here is the citizenship of Mr. Obama's father "Soetoro"
is Indonesian; Indonesia did not recognize dual citizenship.

40. The Indonesian citizenship law was designed to prevent apatride
(stateless) or bipatride (dual citizenship); Indonesian regulations recognize
neither apatride nor bipatride citizenship.
41. The Hague Convention prevented the U.S. from interfering with
Indonesia's laws.
42. Indonesia did not recognize dual citizenship, thus, neither did the
U.S.; and an adoption per se severs all relationship to the birth place and/or
citizenship of a birth parent.
43. 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.
44. 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.
45. If Mr. Obama 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.
46. 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,
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).
47. 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".
48. 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’….”.
49. Furthermore, Indonesia did not allow Dual Citizenship or Dual
Nationality thus Mr. Obama 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.
50. 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
Ivan S Kerno, International Law Commission, United Nations General
Assembly, 6th April 1953.); thus, Mr. Obama is not a "natural born" citizen
and my not even be a naturalized citizen.
ARGUMENT IN SUPPORT OF RELIEF
51. 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).
52. Petitioner / Plaintiff has suffered an informational injury as a voter
and member of the public; and the lack of information on Mr. Obama'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.
53. 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
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."
54. 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.
55. 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).
56. 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).
57. These issues can be easily resolved; the documents requested will
either prove that Obama 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 requires a restraint upon the Electoral College vote cast and
certified on or after December 15, 2008.
58. 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.
59. 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.

60.Under FOIA, 5 U.S.C. § 552, Attorney Fees and Costs are
appropriate pursuant to 8 552 (a)(4)(E).
For the above aforementioned reasons, this Court should Mandate and Orda
the U.S. Department of State to immediately turn over the documents
referred to above.
Respectfilly submitted,
Dated: November 22,2008

Brooklyn, New York
Attached Exhibits A through G
cc:

A/ISS/rPS/RL
Washington, D.C. 20522-8 100
Petition for Writ of Mandamus - Page 17 of 18

VERIFICATION
STATE OF NEW YORK )
) ss.
COUNTY OF KINGS 1
Accordingly, I, Estopher Earl Strunk, being duly sworn, depose and say under penalty
ofpejury:
1 That I am the Plaintiff '/ Petitianer, Christopher Earl Strunk, pso se without being
an attorney, with place for service at 593 Vanderbilt Avenue #28 1 Brooklyn, New
York 1 1238; Email: uncasvotes2@yahoo.com Cel I- (845) 90 1 -6767.
2 I am an active voter wirhin the New York 57' Assembly District (AD) and NY
1 8 Senate
~ District (SD)created in April 2002.
3- 1 have read the attached Petition tbr Extraordinary Relief in the Nature of a Writ
of Marzdmus and I know its contents; the facts stated in the Petition are true to
nly 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 tnre. The
grounds of my beliefs as to all matters not stated upon information and belief are
as follows: 3" parties, books and records, and personal knowledge. except as to
those stated upon information and
Swum to before me
Thisla day of November 2008
Notary Public '
CLEVELAND A. aROWN
Motsry Public, %?e o i N-r.ra/York
NO. 22-G&4.3.:;0
Qualifisd in Kitlgs Co~tnty
Commission Expires Apt1130,20
Petition for Writ of Madamus - Page 18 of 18
VERUI'IIED COMPLAINT and PETITION for
WRlT OF MANDAMUS under F.O.I.A.
EXNIBIT "A"
Christopher Earl Stnmk
593 Vanderbilt Av- -#282
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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EXHIBIT cCC"
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Search Results
LabellReceipt Number: 7007 2560 0002 3103 1739
status: Oeltvered
Entar bbeVFbaceipt Number.
Your Hem was delivered at 1252PM on Odokr 27,2008 in
WASHINGTON. DC 20520.
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lwlkamuptim
Track 8 Confim by email
Get m m t event inbrmafion w updates for ywr itemsent to yw or o h m by emeil. @
VEFUFIED COMPLAINT and PETITION for
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
United States Postal Sewlce, Certified Mail, Return Receipt Requested; That on October

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:
EXHIBIT "F"
Brooklyn, New York 1 1238
November 22,2008
Officeof Information Programs and Services

A/?SS/IPSIRL

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

A/ISS/IPS/RL
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\*
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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
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Additional Comments
As a matter of record and follow-up: On October 17, 2008, Ifiled a FOIA request
United States Postal Service, Certified Mall, Return Receipt Requested; That on October

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
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ERRATA
Page 2, (a) Stanley Ann Dunham was born in Wichita, KS as per SSN application;
P. 4 (8) Christopher Earl Strunk (hereinafter "Petitioner") - "hereinafter” is mispelled
P. 7 (22) at the end of the sentence - President, pursuant to the United States Constitution,
P. 10 (32)....
Mr. Obama'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. Obama's name as "Barry Soetoro" and lists his
citizenship as Indonesian (see Exhibit Addendum).

EXHIBIT ADDENDUM
U.S. District Court for the District of Columbia
in re Verified Complaint and Petition for Writ of Mandamus under FOIA
CERTlFICATE OF SERVICE
On November 22,2008,1, Christopher Earl S t d , under penalty of pejury pursuant to 28 USC

1746,
Am the petitloner herein being pro se without being an attorney;
Caused the senice of one complete set of the proposed the combined Verged Complaint and
Petition for Writ ofMandamus under the Freedom of Information Act (FOEA) with the Verification
affirmed November 22,2008 with annexed Exhibits A through G,along with along with the Cover
Iefter to the Clerk ofthe Court requesting expedited handling of attached Poor Person application
for relief wiih supporting afiduvit endorsed November 22,2008, and
did place a compIete in a sealed folder properly addressed with proper postage to be served by
USPS maiI upon:
m c e of Information Programs and Services

MSS/IPS/RL
U.S. Department of State
Washington, D.C. 20522-8100
I do declare and c e m under penalty of perjury:

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CERTIFIED MAIL,. RECEIPT
NOIllsun?nCeCoverage Provided)
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Amended Verified Complaint and Petition in Re FOIA USDC DC 08cv2234 010509 With Original FOIA Complaint of 11/22/08

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

UNITED STATES DISTRICT COURT

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

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

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

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

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

Supplement Petition for Writ of Mandamus – Page 1 of 20

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.

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

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

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,

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

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

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

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

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.