Case 3:12-cv-03251-P Document 8 Filed 08/31/12

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DALLAS DIVISION
DR. ORLY TAITZ, ESQ

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Plaintiff,
vs.

KATHLEEN SEBELIUS, In her capacity of Secretary of

Defendant.

Health and Human Services et.al.

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Case No.: 3: 12-cv-03251-P

VIOLATION OF 14TH AMENDMENT EQUAL PROTECTION RIGHTS, ESTABLISHMENT CLAUSE ARTICLE 2 SEC 1 OF COSTITUTIO INJUNCTIVE RELIEF, STAY DECLARATORY RELIEF
RTCO, PREDECATE CRIMES
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FRAUD, AIDING AND ABETTING FORGERY AND UTTERING OF FORGED DOCI]MENTS TO COMMIT ELECTIONS FRAUD
7TH AMENDMENT JURY

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DEMANDED

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REQUEST FOR JUDICIAL NOTICE FILBD IN CONJI.INCTION WITH

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MOTIOI\ FOR STAY/PRELIMINARY INJUNCTION

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Tait:z v Sebelius et.al.

Request for Judicial Notice

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IN THE US DISTRICT COURT FOR THE NORTHERII DISTRICT OF TEXAS

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Pro se plaintiff

Dr. Orly Taitz, ESQ 29839 Santa Margarita, ste 100 Rancho Santa Margarita, CA 92688 Ph. 949-683-54 1 1 fax 949-7 66-7 603

Case 3:12-cv-03251-P Document 8 Filed 08/31/12

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Plaintiff Pro Se Dr. Orly Taitz (hereinafter "Taitz") hereby requests that the
Court take judicial notice of the following document attached as Exhibit 1. This
request is made pursuant to Rule 201 of the Federal Rules of Evidence. This

request is made in connection with Taitz's Motion for Preliminary Injunction filed

by plaintiff.
recent case Newland et. al. v Sebelius, case No:

Exhibit 1 - Order from Senior U.S. District Court Judge John L. Kane in
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l:I2-cv-1123-ILK.

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Courts may take judiciat notice of proceedings in other courts. U.S. ex rel

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BASIS FOR REQUESTING JUDICIAL NOTICE

Robinsoru Rancheria Citizens Council v. Borneo, 1992)

Inc.,g7l F.2d244,248

(citing

St.

Louis Baptist Temple, Inc. v. FDIC,605 F.2d 11,69 (1Oth Cir.

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matters at issue."'). Exhibit 1 is a decision of other federal district court.

The content of that decision is a public record that is "not subject to

reasonable dispute [and] capable of accurate and ready determination by resort to
sources whose accuracy cannot reasonably be questioned." Fed. R. Evid.

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201(bX2). This exhibit reflects the decision in other federal court, and is appropriate for judicial notice as set forth in

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("[W]e 'may take notice of proceedings in other courts, both within and without the federal judicial system, if those proceedings have a direct relation to
1979))

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rel Robinson Rancheria

Citizens Council.Taitzrequests that this Court take judicial notice of Exhibitl solely to demonstrate its existence and the similarity of the claims in the cases, and

not for the truth of their contents.

This order is a precedent to the case at hand. In Newland v Sebelius, the

Plaintiffs sought an injunction from providing coverage for abortifacient drugs, contraception, sterilizationand the healthcare plan due to their religions aversion
Taitz v Sebelius et. al. Request for Judicial Notice

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(9th Cir.

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Case 3:12-cv-03251-P Document 8 Filed 08/31/12

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against abortions and birth control. The court found that the provision in PPACA

violates the Plaintiff

Speech and RFRA.

First Amendment rights of Free Exercise of Religion, Free

Similarly, case at hand Taitz v Sebelius is seeking an injunction against the

same affordable care act on the grounds that it violates First Amendment rights

Free Exercise of Religion, violates First Amendment Establishment Clause, Fifth

Amendment Due Process Clause and Fourteenth Amendment Equal Protection

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Clause as PPACA gives preference to citizens of certain religions such as

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members of other religions such as Christians and Jews through mandating to purchase health insurance or penalizing by penalty tax insurance.

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Respectfully submitted, August 28,2012

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Bv /s/ Dr. Orly Taitz

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Dr. Orly Taitz ESQ

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PlaintiffPro

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Taitz v Sebelius et.al. Request for Judlcial Notice

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Muslims exempting then from purchase of health insurance and punishing

if they do not purchase such

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