Tag Archives: Donofrio

“The Dianna” Wears Pravda!!! (Биртхерс всех стран, объединяйтесь!)

She Proudly Strutted Her Busy Print In Front Of The Foreigners

Dianna Cotter, aka Freeper Danae, recently took the Birther Complaint to Russia. Along the way, she got mentioned on The Drudge Report, which is usually a good thing. However, the jury is still out on whether whining to the Ruskies is one of those things which simply isn’t done. See Hanoi Jane. First, here is a link to the story:


Here are some excerpts:

A singularly remarkable event has taken place in the United States of America. This event occurred in Arizona on March 1st and was an earth shattering revelation.

A long awaited press conference was given by Maricopa County Sheriff Joe Arpaio, a five time elected Sheriff, which should have made national and international headlines. Arpaio’s credentials include serving in the United States Army from 1950 to 1953, service as a federal narcotics agent serving in countries all over the world with the U.S. Drug Enforcement Agency (DEA), and served as the head of the Arizona DEA. Without doubt, this is a serious Law Enforcement Officer, not one to be taken in by tin-foil-hat wearing loons.

Yet, in the five days since his revelations there has been little in the way of serious reporting on the findings he presented in his presser. With 6 short videos, the Sheriff and his team presented a devastating case, one the tame US press is apparently unable to report.

This is about what you would expect from a Donofrio Groupie namely, a complete disconnect from Reality. The MSM is pretty much ignoring the story because Sheriff Joe and The Cold Case Posse lack credibility. Most people, including journalists, realize that something is wrong when a law enforcement investigation lets a person with a grudge, like Jerome “Jerry” Corsi, participate in the first place, and provide evidence, and be responsible for examining documents. Documents which supposedly are now missing.

And the ones too dense to pick up on that, will hopefully still stumble over the fact that one of the investigators, Deputy Michael Zullo, had a pre-existing book deal with Corsi. Which means Zullo and Corsi had a financial interest in the outcome of the investigation. Yep, most Americans would have an instinctual distrust of such a thing, and would probably see the actions of Sheriff Joe and the Cold Case Posse as more interesting than their silly, flawed, and unprofessional findings.

Sooo, what’s a Good Birther to do when they have this earth-shattering story and Americans do a collective yawn??? Wouldn’t it be nice if there was a country where people didn’t find crooked investigations, abuse of power, and money-grubbing Polizei out of the ordinary??? Somewhere like maybe a former communist country where American ideas of fairness seem pollyanny??? Hmmm. Oh yes!!! RUSSIA!!!

This shows how far the Birthers have sunk in their  mad attempt to get Obama on this issue. Cotter’s story was even carried at that Bastion Of Conservatism, Free Republic, with nary a whimper from the anti-commie crowd there:


However, publishing an article in Pravda isn’t really the issue. The more important questions are why and how Cotter missed the whopping big story about Corsi’s involvement and the pre-existing book deal.  Did it not ever occur to her, as a journalist,  that there was a good reason why the American MSM ignored the story??? A reason that maybe had nothing to do with protecting Obama??? I hope that she takes off her Birfer-colored glasses long enough to reflect on that. Because without that critical sense, all Cotter can look forward to are more hack writing jobs. Perhaps working at World Net Daily. 

Do svidaniya!

Squeeky Fromm
Girl Reporter

Note 1: Биртхерс всех стран, объединяйтесь! Well, if I did the translation thing correctly, this means, “Birthers of all countries, Unite!” Which is based on “Workers of the World, Unite!” Wiki says:

The political slogan Workers of the world, unite! (German: “Proletarier aller Länder vereinigt Euch!”, literally “Proletarians of all countries, unite!”) is one of the most famous rallying cries of communism, found in The Communist Manifesto (1848), by Karl Marx and Friedrich Engels. A variation (“Workers of all lands, unite”) is also inscribed on Marx’s tombstone.

This slogan was the USSR State motto (Пролетарии всех стран, соединяйтесь! Proletariy vsekh stran, soyedinyaytes’!), appeared in the coat of arms of the Soviet Union, on 1919 Russian SFSR banknotes (in German, French, Chinese, English, and Arabic) and in most Soviet newspapers. Contemporarily, some socialist and communist parties continue using it. Moreover, it is a common usage in popular culture, often chanted during labour strikes and protests[1]

Note 2. Ruskies. The Urban Dictionary says:

7. Ruskie:

Prounciation: “Ruu-skee”
Term coined during the Crimean War. Popularized my America during the cold war as a derogatory term.
“Nuke those damn Ruskies.”

Note 3. Salvador Dali. Yes, that is him in the Image. It is from this absolutely fascinating blog, More Things Than Are Dreamt Of:


Twin Piques – The Birther Summit On Ice!!!

Leo's Party Was Interesting For A Season, But It Was Time To Leave

Dean Haskins has indefinitely postponed The Birther Summit scheduled for late March 2012. His two main piques seem to have been the schism between himself and Orly Taitz, and general apathy on the part of Birthers.  In his own words, with bolding by me:

Additionally, we have observed other calls for mass gatherings and demonstrations, and have had to accept the fact that, barring some major event occurring, levels of apathy about issues such as ours seem nearly impossible to overcome. It is far easier to air one’s complaints via computer keyboard than it is to leave the comfort of one’s home and actually make a physical effort. Past participation in such calls for mass gatherings have been highly embarrassing, and that is certainly not an indictment of the individuals who planned them. Our nation is likely on a crash-course toward extinction simply because of the apathy of our citizenry toward doing anything beyond “talking tough” on the Internet.

Moreover, our message is currently nowhere near cohesive, as disinformation and incompetence are still driving people to believe things that are simply not true, and the gullible few who swallow the spin don’t even realize that it is unethically being used to elicit funding. Even though the truth has been explained at length, there are still folks who view themselves as being part of our team, and yet cling to demonstrably false notions about things like the laws that apply to birth certificates in general, and in Hawaii specifically.

That is largely due to a steady stream of incompetence that continues to flow from one who some still regard as possessing any knowledge of the law and legal procedure. Anytime we come across one who speaks of things like “access to the ‘original’ or ‘vault copy’ of Obama’s birth certificate,” or such absurdities as a state court on the mainland having jurisdictional authority to force Hawaii to break its laws regarding vital statistics records, we must recognize such a person as being complacent in his ignorance of the law (much like the glory hound he likely supports).

We have concluded that providing a venue for those who still seem to support the one who is arguably the worst attorney ever, would not only be a disservice to our country, but it could be considered irresponsible, as a gathering of such people might actually constitute a public danger—for anyone who could still be supporting such an aberration cannot be believed to be mentally or emotionally stable.


The Birther Think Tank ran a four part trilogy on the schism between Haskins and Taitz, and is not at all surprised by this announcement. In fact, we congratulate Mr. Haskins on his growing dissatisfaction with Birtherism and his willingness to start asking legal questions hithertofore left unquestioned within the Birther Community. If Orly Taitz falls, can Leo Donofrio and Mario Apuzzo be far behind? Oh, and Larry Klayman, too. The Birther Feud Trilogy begins here, and runs for 4 consecutive Internet Articles:


While Mr. Haskins professes to still be a Birther, it is our opinion that he will change his mind. One can not ask the questions and make the observations that he makes, and stay a member in good standing of  the Birther Herd of Ninnies.

Squeeky Fromm
Girl Reporter

Note 1: Twin Piques. This is a wordplay on Twin Peaks, David Lynch’s surreal television series of the eary 90’s. you know, peaks, mountains, summits. Oh, I’m sure everybody gets it.


A feeling of irritation or resentment resulting from a slight, esp. to one’s pride.

Stimulate (interest or curiosity).

Note 2. The Image Above. This is an image of Leo Johnson, a character in Twin Peaks. The reference is to Leo Donofrio, Esq., inventor of the Imaginary two citizen-parent requirement.  About Leo Johnson, Wiki says:

Leo Johnson, a criminal and wife abuser, spends most of the second season in a vegetative state, cared for by Shelly and Bobby, who agree to take him in as part of a scheme to commit insurance fraud. The plan backfires, however, when it turns out that Leo’s home care is far more expensive than they had anticipated, and the pair are left destitute. To vent their frustration, they take to abusing Leo whilst simultaneously flaunting their relationship in front of him.

Near the end of the season, Leo regains some of his cognitive abilities and instinctively attacks Shelly and Bobby. Wounded during the course of a struggle, he staggers into the woods, where he is abducted by escaped mental patient (and former FBI agent) Windom Earle. Earle enslaves the barely coherent Leo by affixing him with a shock collar and forcing him into submission. Leo spends the remainder of the series as a mute drone, serving Windom Earle.

In the third to last episode, Leo seems to regain some more functioning ability, as he frees another one of Earle’s captives,  Major Garland Briggs, believing Shelly’s life to be in danger after Earle posts a photo of her on his cabin wall. In the series finale, Earle leaves Leo for dead, rigging a cage of poisonous tarantulas above Leo’s head, with a string affixed between Leo’s teeth; if Leo lets go of the string, the cage will drop on his face, releasing the agitated tarantulas. His fate is never revealed, although a shooting script indicated that he was supposed to be found by the Twin Peaks’ Sheriff’s Department, and that, upon seeing them break into Earle’s cabin, he would have tried to speak, releasing the cage onto his face.

You know, I sometimes wonder about the cognitive functioning of Donofrio. I wonder if  Mute Drone Shock Collars and Poisonous Tarantula Cage Kits are legal in . . . Oh, never mind.

Leo Donofrio, The Naked Emperor of the Birthers

Donofrio Couldn't Wait To Show Off His Custom Made Sartoria de Pazzo' Threads

Everybody is familiar with the story of The Emperor’s New Clothes, originally written by Hans Christian Andersen.  Wiki says:

A vain Emperor who cares for nothing but his appearance and attire hires two tailors who are really swindlers that promise him the finest, best suit of clothes from a fabric invisible to anyone who is unfit for his position or “just hopelessly stupid”. The Emperor cannot see the cloth himself, but pretends that he can for fear of appearing unfit for his position; his ministers do the same. When the swindlers report that the suit is finished, they mime dressing him and the Emperor then marches in procession before his subjects, who play along with the pretense.

Suddenly, a child in the crowd, too young to understand the desirability of keeping up the pretense, blurts out that the Emperor is wearing nothing at all and the cry is taken up by others. The Emperor cringes, suspecting the assertion is true, but holds himself up proudly and continues the procession, deciding never to be so vain again and to take his position more seriously.

There are many similarities to Leo Donofrio’s position in the Birther community. Some might protest that he comes closer to being one of the swindling tailors than the pompous emperor. But the tailors weren’t the ones prissing down the street in their Birthday Suit, like the Emperor and Donofrio. And, the adoring crowd probably would have had no problem jeering and pointing out that the tailors were nekkid. Except perhaps in San Francisco where such things are supposedly rather commonplace.

No, I think Donofrio is in the same fix as the Emperor. He has gone out there in front of the crowd, naked as a jay bird, and figures the best approach now is to try to bluff it out.  Just like a poker player with the 2,3,4, and 5 of hearts and the 7 of clubs.  Damn that ace or 6 of hearts for not being there!!!  Like the Emperor above, Donofrio also knows that he is holding a hand full of crap, but he is just in too deep to fold.

Donofrio’s fancy threads, the ones that only the stupid and incompetent can’t appreciate; the threads that are supposed to separate the elite from those unfit for his position or “just hopelessly stupid; and the threads that will plop Donofrio I down into the history books as a Great Emperor,  are his recent 209 page Amicus Curiae Brief, tendered to the Georgia Court.  Here is a link to the Brief:


Sooo, we get the 200 page Amicus Curiae brief, full of unintelligible drivel.  The legal equivalent of psycho-babble. Do you know why it is 200 pages??? So that you WILL NOT read it.  You are supposed to be impressed by the weight of the paper alone.  Plus, 3/4 of it consists of photocopies of old books and old law cases. There is only about 50 pages of actual Donofrio Drivel.

Donofrio’s forte is pain and his opus is the equivalent of the old peine forte et dure where the recalcitrant were pressed to plead, or die. By page 17, most of the frail will convert to Birtherism rather read anymore of this crap.  It  has been reported, but not yet confirmed,  that several readers gagged to death as early as page 6, after reading this:

Natural Allegiance – Via Jus Soli – Was A Uniquely Christian Point Of Law
Repugnant To The First Amendment Of The United States Constitution.

The common law rule of jus soli subjection is a complex spiritual concept, which does not simply relate to birth on British soil. Despite popular belief, the common law meaning of “natural-born” is not synonymous with “native-born”. The true nomenclature of “natural-born subject” is rooted in “natural subjection” to the spiritual body of Christ, and therefore our Constitution forbids any construction of the “natural-born citizen”clause that alleges the term to be synonymous with “natural-born subject”.

OK,  that was bad. A religious and First Amendment objection to the current legal interpretations of natural born citizenship???  Funny, but I don’t recall the judges in the Wong Kim Ark case citing the Bible. Nor the judge in Lynch v. Clarke. Or the judges in Ankeny, or in Georgia, or Illinois, or Virginia. This is how we know Donofrio perceives his own nudity.  He is a lawyer, and he has crafted a theory that only the legally ignorant could swallow.

He just wants the Birthers to play along and pretend that he is wearing clothes. Maybe those people who died after reading that, might have made it, except that their system had already been immuno-compromised even earlier back on page 2, where Leo I, Emperor Magnus, Protector Of Parakeets, and The Defender of Ultima Thule solemnly pronounces:

A. According To Precedents of Statutory Construction, The 14th Amendment Has
Not Repealed Or Modified The Natural Born Citizen Clause.

One wants to Cry DUH!!!, and let slip the dogs of the Insane Asylum to track Donofrio down, and tree him until the men with the butterfly nets arrive.  Perhaps while they are waiting,  Donofrio and the dogs can all howl at the moon together, for entertainment. Didn’t the judges in Wong Kim Ark state that the 14th Amendment actually  AFFIRMED the law of natural born citizenship and enshrined it in the U.S. Constitution. Well, unless I miss my guess, the Birthers will pretend those words aren’t there.

Of course we also get the good old Leo Donofrio Minor v. Happersett argument where the words “For the purposes of this case it is not necessary to solve these doubts” (about whether or not children born in the United States to aliens were citizens) transmogrify through the Arcane Art of Grammatical Misconstruction into the polar opposite and magically solve the doubts.  There about 52 pages of exposition on these 3 main themes, and then a ton of exhibits to finish off.  Much of it consists of photocopies of old books. Some is in Latin, like this, on page 67 of 209:

Rex universis et singulis admirall’, castellan’, custodibus 7 Coke ;/Report 9 a, 77 ER p387 castrorum,

I don’t speak Latin, but I think it means somebody named Rex plans to jail either Walter Fitzpatrick or CDR Kerchner in Spain, ply them with cocaine, and then castrate them at 9:00 AM in the Emergency Room.  If I am totally wrong in my translation, then I  still bet I am no worse than Donofrio trying to translate from English.

And sooo, this is how Leo Donofrio, Naked Emperor of the Birthers, struts his stuff. Unfortunately for him, his Brief is made of the same stuff as the Emperor’s New Clothes – – – Imaginary Threads. And thus his Briefs are showing, and he is exposed.

Squeeky Fromm
Girl Reporter

Note 1. The Emperor’s New Clothes by Hans Christian Andersen. Wiki has more to say, incuding this interesting side note:

Andersen dread the tale in a German translation titled “So ist der Lauf der Welt”. In the source tale, a king is hoodwinked by weavers who claim to make a suit of clothes invisible to any man not the son of his presumed father. Andersen avoided anything risqué in his work and altered the source tale to direct the focus on courtly pride and intellectual vanity rather than adulterous paternity.

Andersen’s manuscript was at the printer’s when he was suddenly inspired to change the original climax of the tale from the emperor’s subjects admiring his invisible clothes to that of the child’s cry. Andersen’s decision to change the ending may have had its source in a childhood incident similar to that in the tale. In 1872, he recalled standing in a crowd with his mother waiting to see King Frederick VI. When the king made his appearance, Andersen cried out, “Oh, he’s nothing more than a human being!” His mother tried to silence him by crying, “Have you gone mad, child?”

Corsi, The Hatchet Man, Gets The Axe!!! (Some Legal Advice)

In A Previous Existence, Corsi Was A Lumberjack In A Pulp Wood Factory

Jerome Corsi, PhD., the Birther Agent Provacateur Extraordinaire, got canned from his day job as senior managing director at investment firm, Gilford Securities. He has been employed by the firm since 2010. Corsi complains that he was fired for working on a money-laundering story for World Net Daily, where he is employed in a part time capacity as a writer and assistant janitor.

Corsi said that Gilford notified him Monday that it would file a U-5 form with the Financial Industry Regulatory Authority, or FINRA, to deregister him from the firm due to “corporate reorganization.”


Time will tell who is telling the truth on this matter, and personally, I wonder whether  he was perhaps sent packing for being a nut. I mean the guy is into all this Obama birth certificate and two citizen-parent Birfer stuff, 9/11 truther stuff, abiotic oil stuff,  and New World Order stuff. I don’t know about the last two of those, but I think I am on firm ground that being a 9/11 Trufer-Birfer is indicative of a strong delusional streak. The kind of delusional thinking that causes people to bet the bank on European Sovereign Debt, and the pet.com sock puppet.  Delusions are not good things in the investment business.

But what I really wanted to do in this Internet Article was to give some legal advice to Corsi.  He is going to have to hire attorneys to help him through this, and I suggest that he hire the Dream Team of  Orly Taitz, Mario Apuzzo, and Leo Donofrio. I am not being sarcastic or anything.

Orly Taitz is nothing, if not a fighter as proven by the number of appeals she files. Leo Donofrio seems to be under-employed and could use the money to pay off some sanctions. He has plenty of time to research the issues, and is not afraid of going all the way back to 1785 to find legal precedents to overturn 1898 SCOTUS cases.  I mean, you just don’t find that kind of dedication every day.  Mario Apuzzo is located right there in New Jersey, so it is just a hop, skip, and a jump over to the Wall Street District for court and depositions and stuff.

Corsi obviously trusts their legal acumen, preferring their legal analysis to the 99.9999% of attorneys who think Obama is a natural born citizen and wonder what all the fuss is about. Corsi and World Net Daily constantly trumpet the findings of each of these attorneys, and you just know they would never do that unless they were really impressed with their legal abilities and talents.

It is true, that none of these three has any securities law background, but a lack of background did not stop them from diving into all this Birther stuff  and coming up with all sorts of new insights that eluded the Brand Name Attorneys and White Shoe Law Firms .  I mean, did Hillary Clinton’s legal advisers realize that Minor v. Happersett was the precedent for determining natural born citizenship??? No. That was Leo Donofrio who discovered that, and Hillary Clinton would be president now if she had been properly advised that Obama was not eligible for the presidency.

Mario Apuzzo is no legal slouch either, and his seminal works on the influence of Emerich de Vattel and French law upon the development of  American Law even escaped the like of Oliver Wendell Holmes, Jr., who foolishly thought it was the English who provided the foundation. Orly Taitz has single-handedly over-turned the outdated twin concepts of judicial immunity and judicial respect, which have long allowed judges in this country to make unpopular decisions with impunity. She has introduced a whole new generation of lawyers to her Moldavan Krav Maga Method of Litigation.

Sooo, in conclusion, I think Jerome Corsi should put them all on his payroll ASAP before Gilford Investments hires them out from under him.  I mean if these lawyers are good enough for Jerome Corsi and World Net Daily to push on the rest  of us,  shouldn’t they be good enough for Corsi???

Squeeky Fromm
Girl Reporter

Note 1: Moldavan Krav Maga Method of Litigation. This approach to litigation, with its emphasis on brutality, no rules, and a no frills street fighting efficiency, is based on the Krav Maga fighting method. Wiki says:

Krav Maga  /krɑːv məˈɡɑː/ (Hebrew: קרב מגע‎ [ˈkʁav maˈɡa], lit. “contact combat”) is a noncompetitive eclectic self-defense system developed in Israel that involves striking techniques, wrestling and grappling. Krav Maga is known for its focus on real-world situations and extremely efficient, brutal counter-attacks. It was derived from street-fighting skills developed by Imi Lichtenfeld, who made use of his training as a boxer and wrestler, as a means of defending the Jewish quarter against fascist groups in Bratislava in the mid-to-late 1930s. In the late-1940s, following his immigration to Israel, he began to provide lessons on combat training to what was to become the IDF, who went on to develop the system that became known as Krav Maga. It has since been refined for civilian, police and military applications.

Krav Maga has a philosophy emphasizing threat neutralization, simultaneous defensive and offensive maneuvers, and aggression. Krav Maga is used by Israeli Defense Forces, both regular and special forces, and several closely related variations have been developed and adopted by law enforcement and intelligence organizations, Mossad and Shin Bet. Outside Israel, Krav Maga is used by various special police, military and intelligence forces, such as American CIA, FBI, US Marshals, USAF, DEA, Federal Air Marshals, various police departments (SWAT teams), French GIGN, Belgian Army, etc.

A key principle of Krav Maga is finishing a fight as quickly as possible and therefore all attacks are aimed towards the most vulnerable parts of the body (e.g., face, neck, groin, knee, etc.). Because there are no sporting rules, individuals trained in Krav Maga are not limited to techniques that avoid severely injuring their opponents, but training and sparring drills provide maximum safety to the students by the use of protective equipment and the use of reasonable force. For example, kicks to the groin during sparring is commonplace, but groin protection must be worn and students should demonstrate due diligence with regards for their partners’ safety. Students learn to defend against all variety of attacks before engaging in full-contact sparring. Students are taught to respond to attacks in the quickest and most efficient way; a common lesson taught is ‘always use the nearest tool for the job’. This basically means use whichever limb is closest to your attacker at the time and whichever feels most natural. Men and women generally undergo the same drills. It has no sporting federation and there are no official uniforms such as a gi. Usual training attire consists of a t-shirt and loose fitting trousers. Krav Maga is also one of the few martial arts in which footwear is habitually worn due to it being ‘reality based training’. Most organizations recognize progress through training with rank badges, different levels, and belts.

General principles include:

* Counter attacking as soon as possible (or attacking preemptively).
* Targeting attacks to the body’s most vulnerable points such as the eyes, jaw, throat, groin, knee, etc.
* Neutralizing the opponent as quickly as possible by responding with an unbroken stream of counter attacks and if necessary a take down/joint break.
* Maintaining awareness of surroundings while dealing with the threat in order to look for escape routes, further attackers, objects that could be used to defend or help attack and so on.

The Rictal Scale of Birther Lawsuits

Poor Rocky, The Gargoyle, Had The Misfortune To Live On The World Net Daily Building

Apparently, the Deluge of Birther lawsuits will continue for quote a while. I suspect appeal after appeal will be filed as these stinkers get drop kicked out of the courthouses. Some of these will be pro se lawsuits filed by individual Birthers untrained in the law. Others will be filed by attorneys. Their level of absurdity will vary greatly. There needs to be some way to rate these lawsuits, much like the Richter Scale and Fujita scale are used to rate earthquakes and tornadoes.

But there is a problem. Part of rating earthquakes and tornadoes relates to the amount of damage done, and Birther lawsuits don’t do any damage outside of wasting the Court’s time. Paraphrasing Shakespeare, these are lawsuits filed by idiots,  full of sound and fury and signifying nothing.  However, if we can’t rate Birther lawsuits by the output, maybe we can rate them by the input!

To that end, I propose The Rictal Scale!!! Rictal is the adjective form of Rictus which is defined as:

ric·tus [ˈrɪktəs]
n. pl. rictus or ric·tus·es
1. The expanse of an open mouth, a bird’s beak, or similar structure.
2. A gaping grimace: “his mouth gaping in a kind of rictus of startled alarm” (Richard Adams).
3. a fixed or unnatural grin or grimace, as in horror or death.

rictal adj.

In other words, the more we groan at the lawsuit, and make faces, the higher on the scale it is. All we have to do is identify the elements which make us groan and assign them a numerical value.  Here are  my thoughts.  A Birther Lawsuit gets a point for each of these elements of absurdity:

1 Point for citing Minor v. Happersett as a precedent.

1 Point for stating there is a legal requirement for two citizen parents.

1 Point for simultaneously raising fraudulent birth certificate issues.

1 Point for citing the Dred Scott decision in support.

1 Chutzpah points for introducing Obama’s birth certificate as evidence  Obama’s father was a non-citizen while also claiming the birth certificate is fraudulent and false.

1 Point for claiming there is a difference between a 14th Amendment Citizen born in the United States and an Article 2 Section 1 Clause 5 natural born citizen.

1 Point for more than 10 spelling errors in the Complaint.

1 Point for suing the wrong party, with 1 Point for each additional mistake in service.

1 Point for mentioning Emerich de Vattel.

1 Point if the Complaint states The Law of Nations book is included in the U.S. Constitution.

1 Point for filing on a  pro se basis.

1 Point for filing in forma pauperis.

1 Point for requesting no empty chairs be allowed in the courtroom.

1 Point for filing after inauguration should Obama win in November 2012.

1 Point if the Plaintiff describes himself as a “patriot.”

1 Point if the Complaint mentions Leo Donofrio or Mario Apuzzo.

1 Point for each time a judge is asked to recuse himself.

1 Point if the Plaintiff accuses Obama of being a British citizen.

1 Points if the attorney is Orly Taitz.

1 Point if the Plaintiff prepares and files his own Amicus Curiae brief.

1 Point if the Plaintiff fails to mention Wong Kim Ark in the Complaint, or any Brief.

1 Point for each Amended Complaint.

1 Point for each Motion for Reconsideration.

1 Point for missing the Appeals deadline.

1 Point if any of the following words or terms are found in the Complaint or any Briefs: Usurper, frog march, Kenya, Muslim, Admiralty Court, New World Order, or gold fringe.

1 Point if the Plaintiff types his name in all lower case letters.

1 Point if the Plaintiff files as John Doe, or Anonymous.

1 Point for each and every other Absurd claim found in the Complaint or any Briefs as long as such absurdity is clearly listed.

Now this list could go on and on, but the beauty of the Rictal Scale, is that there is no upper limit like is found in the Fujita Tornado Scale or even in the Richter Earthquake Scale where as a practical matter, 9.5 seems to be tops. This is a good thing, for who could ever hope to predict the upper limits of Birther Absurdity.

Please consider the Rictal Scale, as a work in progress, and any and all contributions to further refining this tool will be appreciated.

Squeeky Fromm
Girl Reporter

Note 1:  Thanks to G, at Obama Conspiracy Theories, for suggsting a point be added for Birther Plaintiffs citing the Dred Scott Decision!!!

Note 2: After initial publication of this Internet Article, the scale was renamed The Rictal Scale, the adjective form of the noun rictus being deemed more grammatically correct as descriptive of the noun scale. Like I said, this is a work in progress.

Yes, Virginia, There Is NO Two Citizen-Parents Clause

No, Mario. I'm Only Asking About Santa Claus. Everybody Knows The Two Citizen-Parents Requirement Is Just A Childish Fantasy.

Now, in a short and sweet decision, a Federal court in the State of Virginia has pricked another Birther Balloon. One, Charles Tisdale, filed a complaint alleging:

Mr. Tisdale seeks an injunction enjoining the Virginia State Board of Elections from certifying any candidate who lacks standing as a “natural born citizen” from appearing on the ballot for the upcoming presidential general election on November 6, 2012.Specifically, Mr. Tisdale cites Barack Obama, Mitt Romney, and Ron Paul as ineligible to appear on the ballot, on the grounds that each had at least one parent who was not a citizen of the United States. The Court rules that the Complaint does not state a claim upon which relief may be granted.

The Federal Judge slapped the suit down holding:

The eligibility requirements to be President of the United States are such that the individual must be a “natural born citizen” of the United States and at least thirty-five years of age. U.S. Const. art. II, § 1. It is well settled that those born in the United States are considered natural born citizens. See, e.g., United States v. Ark, 169 U.S. 649, 702 (1898) (“Every person born in the United States, and subject to the jurisdiction thereof, becomes at once a citizen of the United States.”); Perkis v. Elg, 99 F.2d 408, 409 (1938). Moreover, “those born ‘in the United States, and subject to the jurisdiction thereof,’ … have been considered American citizens under American law in effect since the time of the founding … and thus eligible for the presidency.” Hollander v. McCain, 566 F. Supp. 2d 63, 66 (D.N.H 2008). Thus, Mr. Tisdale’s contention that President Obama, Governor Romney, and Congressman Paul are not eligible to be President due to their nationalities is without merit.

And, the ruling was “with prejudice” which means the Plaintiff can’t come back with an Amended suit:

Accordingly, the Court dismisses the Complaint for failure to state a claim. This dismissal is with prejudice, as the Court finds that allowing leave to refile would yield the same result, given the underlying premise of Mr. Tisdale’s claim.

This is about the same thing as coming right out and calling the suit frivolous. Where, O Where is all that legal jargon that Mario Apuzzo, Esq. and Leo Donofrio, Esq. like to bandy about??? Court after court is simply chucking the imaginary two citizen-parents requirement in the garbage can where it belongs.  Here is where you can read the whole 3 page decision:


Squeeky Fromm
Girl Reporter

Friday Nite Smackdown!!! – “Triple M” Hits Birthers With The Metal Folding Chair Of Truth!!!

As He Lay On The Mat, Mario "The Mangler" Apuzzo Pondered How He Could Spin This Loss

On Friday, February 3, 2012,  Administrative Law Judge Michael M. Malihi aka Triple M, clobbered the two-citizen parent Birthers with his decision in the Farrar, Welden, Swensson, & Powell v. Obama presidential eligibility suit. Here is the decision, from the Native and Natural Born Citizenship Explored blog, which is a very good place to get legal information on the Birther issues:


No real surprises to anybody who can read. Minor v. Happersett was properly NOT recognized as PRECEDENT for resolving the issue in language lifted straight from the Ankeny decision, stating:

The Minor Court left open the issue of whether a child born within the United States of alien parent(s) is a natural born citizen.

This finding left Leo “The Paraclete” Donofrio figuratively in the following position:

After His Signature Wrestling Move, The Minor Happersett Atomic Butt Buster, Proved A Dud, The Paraclete Foolishly Decided To Head-Butt The Metal Folding Chair

Relying mostly on the Ankeny v. Governor decision from 2009 and by extension, Wong Kim Ark from 1898, the Malihi Court pretty much told the two-citizen Birthers the same thing myself and others have been telling them for quite some time. To wit:

Relying on the language of the Constitution and the historical reviews and analyses of Minor and Wong Kim Ark, the Indiana Court concluded that persons born within the borders of the United States are “natural born citizens” for Article II, Section 1 purposes, regardless of the citizenship of their parents. Just as a person “born within the British dominions [was] a natural-born British subject” at the time of the framing of the U.S. Constitution, so too were those “born in the allegiance of the United States natural-born citizens.”

916 N.E.2d at 688. The Indiana Court determined that a person qualifies as a natural born citizen if he was born in the United States because he became a United States citizen at birth.

For the purposes of this analysis, this Court considered that President Barack Obama was born in the United States. Therefore, as discussed in Ankeny, he became a citizen at birth and is a natural born citizen. Accordingly,


President Barack Obama is eligible as a candidate for the presidential primary election under O.C.G.A. § 21-2-5(b).

SO ORDERED, February 2012.

Plaintiff David Farrar seemed to have accepted the loss with the most calmness and serenity of any of the Plaintiffs.

Meanwhile, the other plaintiffs, and most of the Birther “legal experts,” are exhibiting various degrees of oral frothing, ill-tempers, and paranoia.  To be on the safe side, I am reviewing and updating my Zombie Plan.

Tee Hee! Tee Hee!

Squeeky Fromm
Girl Reporter

Note 1:  The judge’s name is Michael M. Malihi.  Sooo, Triple M is a word-play on Triple H, a well known professional wrestler.

Note 2. Folding Chairs in Wrestling. Wiki says:

Many items are used as weapons in professional wrestling. Some of the more common weapons used include chairs, guitars, folding tables, title belts, “kendo sticks”, and trash cans. While picking up the upper half of the ring steps for use as a weapon is illegal, slamming an opponent into the ring steps is not considered illegal, though it is frowned upon. However, these weapons are legal in hardcore matches.

Chair shot

A wrestler simply hits the opponent with a chair. In modern wrestling steel/metal folding chairs are used with the strike being performed with the flat face of the chair to slow the swing and distribute the impact, to prevent injury.


Waiting For The Paraclete’s Other Sandal To Drop (Or, What Is The Sound Of One Foot Stomping???)

Supposedly Tired Of Their Childishness, The Paraclete Gave His Followers The Boot

A few week ago on November 19, 2011,  Leo Donofrio, Esq., aka The Paraclete, booted his followers off his website supposedly in the hopes that only attorneys would post there and perhaps give the joint a little class.

From now on, if you want to post here, you must be licensed to practice law.  State your real name and the jurisdiction(s) you are licensed in.  NO EXCEPTIONS. The national dialogue on the legal issues discussed here has often become juvenile at best and intentionally misleading at worst.


As I pointed out in my Internet Article, The Paraclete Gives Up The Ghost, I considered this an admission of defeat by Donofrio on the Birther issues, and a turning point where he could attempt to regain some measure of legal respectability following his creation and pumping of idiotic Birther legal theories like the stupid two citizen-parent nonsense.


Well, he has posted two articles since that date, and on both of them the only comments come from Leo Donofrio himself.  Four from himself on the last post!  His latest article concerns not Birtherism, but martial law, and the suspension of certain habeas corpus rights originally found in that English common law that he once found sooo inferior to Emerich de Vattel, and French law. This also confirms my prediction that he would attempt to regain his lost credibility in the legal community.  Plus, this is great fodder for mega-fangirl Dianna Cotter and her ersatz career as a civil rights reporter.


But also, I wonder how long it will be before Donofrio opens his website back up to a newer group of  non-attorney followers. Maybe he is aiming for a better class of disciple, who unlike the Birthers, is literate and has some minimal reading comprehension skills for a change???  And, is Donofrio going to change the name of his blog from Natural Born Citizen to something less reminiscent of his forays into lunacy???  Since the Paraclete is often represented by a dove, I charitably suggest Rara Avis.

Whatever on the name, I suspect he will have to let his flock of loonies back in to have some exterior validation.   Because, the sound of one foot stomping comes across sounding very much like a tantrum.

Squeeky Fromm
Girl Reporter

Note 1: The Paraclete is a nickname chosen by Donofrio for himself. It has religious and non-religious connotations ranging from Holy Spirit to  lawyer. Wkik says:

Paraclete means advocate or helper. In Christianity, the term most commonly refers to the Holy Spirit. Paraclete comes from the Koine Greek word παράκλητος (paráklētos, that can signify “one who consoles or comforts, one who encourages or uplifts; hence refreshes, and/or one who intercedes on our behalf as an advocate in court”).  The word for “Paraclete” is passive in form, and etymologically (originally) signified “called to one’s side”. The active form of the word, parakletor, is not found in the New Testament but is found in Septuagint in Job 16:2 in the plural, and means “comforters”, in the saying of Job regarding the “miserable comforters” who failed to rekindle his spirit in his time of distress.

“Paraclete” in Classical Greek

The term is not common in non-Jewish texts. The best known use is by Demosthenes::

Citizens of Athens, I do not doubt that you are all pretty well aware that this trial has been the center of keen partisanship and active canvassing, for you saw the people who were accosting and annoying you just now at the casting of lots. But I have to make a request which ought to be granted without asking, that you will all give less weight to private entreaty or personal influence than to the spirit of justice and to the oath which you severally swore when you entered that box. You will reflect that justice and the oath concern yourselves and the commonwealth, whereas the importunity and party spirit of advocates serve the end of those private ambitions which you are convened by the laws to thwart, not to encourage for the advantage of evil-doers. (Demosthenes On the False Embassy 19:1)

Note 2: Rara Avis. A weirdo of sorts.

  rara avis [ˈrɛərə ˈeɪvɪs]

n pl rarae aves[ˈrɛəriː ˈeɪviːz]

An unusual, uncommon, or exceptional person or thing

[Latin: rare bird]
Unusual person.  Anomaly. A rare bird.

With A Kwock Kwock Here And A Quack Quack There

Donofrio's Decoy Was Amateurish, But It Fooled A Few Really Dumb Ducks

This is a short follow-up post concerning the Congressional Research Memo, Qualifications for President and the “Natural Born” Citizenship Eligibility Requirement, by Jack Maskell. This well written memo completely and comprehensively devastates the ridiculous Birther legal theories.

Leo Donofrio, Esq., aka The Paraclete, and major promoter of the two citizen-parent lunacy has launched a feeble counter attack against the memo,  quibbling about the phrasing of one sentence in the report regarding the 1920 SCOTUS case of Kwock Jan Fat v. White:

In one case concerning the identity of a petitioner, the Supreme Court of the United States explained that “[i]t is not disputed that if petitioner is the son” of two Chinese national citizens who were physically in the United States when petitioner was born, then he is “a natural born American citizen ….”221


And in a petulant childish fashion,  Donofrio photo-shopped in the word Propaganda to the memo’s heading:

Donofrio objected to Maskell characterizing the parents as Chinese nationals when there was information in the decision which indicated the parents  were actually citizens. The plaintiff, Kwock Jan Fat was born in America, but because he was of Chinese origin, he had to comply with regulations which required a preinvestigation of his status as an American citizen.

There was a strict immigration policy in force regarding the Chinese, and this was necessary for him to be able to return the United States after a trip to China.  Three people provided information to the Department of Immigration that he was born in America, and thus a natural born citizen.  However between the time he left for China, and the time he returned, somebody provided anonymous information to the government that he was actually another person, born in China, not America.  Upon his return he was imprisoned and he filed a habeas corpus petition which made it to the Supreme Court.

One of the witnesses had provided information in the original preinvestigation application to the Department of Immigration that Kwock Jan Fat’s father, Kwock Tuck Lee was native born and a voter.

Ernest Michaelis, for twenty-six years a justice of the peace and for many years the official collector of fish licenses, testified, making reference, for purpose of identification, to a photograph of the petitioner. He said he had known the parents of the boy since shortly after he himself went to live at Monterey in 1879; that there were two boys and three girls in the family; that he had seen the petitioner frequently as a little fellow when he went to collect fish licenses (the boy’s father was a fisherman), and had known him ever since; and, referring to the photograph, he declared positively that he was sure of his identity and that he was born in Monterey. He added that the father of the boy was native born and was a voter in that community.

However, the Court simply characterized the parents as permanently domiciled in the United States:

It is not disputed that if petitioner is the son of Kwock Tuck Lee and his wife, Tom Ying Shee, he was born to them when they were permanently domiciled in the United States, is a citizen thereof, and is entitled to admission to the country. United States v. Wong Kim Ark, 169 U. S. 649.

Donofrio regards Maskell’s  characterization of the parents as Chinese nationals and “creative use of quotation marks” as part of a “Frankenstein inspired patchwork.” Maskell replied to this claim today, and as reported on Jonathan Turley’s legal blog:


I wrote to Maskell about Kwock; his response:

“I agree that case cite needs clarification to emphasize that Kwock and one witness did aver that his father was born in the United States. It is important, I think, that the Court only mentioned that the parents were permanently “domiciled” in the United States, and thus did not appear to rely on citizenship status, when they accepted the characterization of the Commissioner of Immigration that he was a natural born citizen.”

But, as I discovered, the SCOTUS may have been more legally precise in their description than it appears to us in hindsight. In 1920 The Geary Act was still in effect, and there appears to have been a legal presumption that persons of Chinese descent were . . .(drumroll) . . . Chinese. From Wiki:

The Geary Act, [1892] besides renewing the exclusion of Chinese laborers for another 10 years, also outlined provisions that required Chinese already in the U.S. to possess “certificates of residence” (as well as “certificates of identity” after the McCreary amendment was added) that served as proof that they entered the U.S. legally and had the right to remain in the country. The certificates of residence contained the name, age, local residence, occupation, and photograph of the applicant. The act placed the burden of proof of their right to be in the U.S. on the Chinese themselves, denied bail to Chinese in habeas corpus proceedings, made it the duty of all Chinese laborers in the U.S. to apply within one year for a certificate of residence, with a duplicate kept in the office of the Collector of Internal Revenue, and suitable penalties were prescribed for any falsification of certificates. Another of the Act’s provisions required two white witnesses to testify to a Chinese person’s immigration status. If any Chinese laborer within the United States without this certificate of residence was “deemed and adjudged to be unlawfully in the United States”, they could be arrested and forced to do hard labor, and be deported after a year.This was the first time ever illegal immigration to the U.S. was made punishable by such a harsh degree.

See also:

  • 1892 Geary Act: Congress extended all previous Chinese Exclusion Laws by ten years.  By requiring Chinese persons in the United States to carry a “certificate of residence” at all times, the Geary Act made Chinese persons who could not produce these certificates presumptively deportable unless they could establish residence through the testimony of “at least one credible white witness.”  Congress also denied bail to Chinese immigrants who applied for writs of habeas corpus.  Text
  • 1902: Congress indefinitely extended all Chinese Exclusion Laws.  Text
  • 1904: Congress made permanent all Chinese Exclusion Laws
  • 1943 Repeal: Congress repealed all laws “relating to the exclusion and deportation of the Chinese.”  Congress permitted 105 persons of Chinese descent to immigrate into the United States each year, and enabled persons of Chinese descent to become American citizens.   The 1943 repeal, however, was enacted a wartime measure to counteract enemy propaganda after China became an ally of the United States during World War II, with little acknowledgment of the injustice of the laws.  Neither then nor afterward has Congress expressed regret at its passage of the Chinese Exclusion Laws.  Text


No such information appeared to be in the file, so while we can presume that Papa Kwock would have been found a natural born citizen based on his birth in the United States, it probably would have taken more the above out-of-court statement by Ernest Michaelis. Just guessing, but this is probably why the SCOTUS defaulted to  “when they were permanently domiciled in the United States.

Therefore, Maskell’s statement is not deceptive, and the natural born citizen status afforded Kwock Jan Fat was NOT based on the citizenship of his parents which was presumptively by law, that they were Chinese.

Squeeky Fromm
Girl Reporter

Note 1: Here and There. Here is, of course, Me, and The Birther Think Tank. There is, the other guys.

The Paraclete Jumps To Another Wrong Conclusion

Chinese Checkers Is More Difficult When You Lose Your Marbles

Well,  Leo Donofrio, Esq., aka The Paraclete, ventured out of his comfy nest made of twigs and bird droppings to attack the 53 page CRS Memo by Jack Maskell, entitled Qualifications for President and the “Natural
Born” Citizenship Eligibility Requirement. The Birthers are going crazy because this memo utterly destroys the two citizen-parent nonsense along with several other imaginary legal theories. The complete memo can also be found at The Birther Think Tank under Natural Born Citizenship in the Header area above.

Donofrio’s dismissal of the entire 53 page report and his entire post is presently based upon his reading of one whole sentence in the report, although we are promised additional quibbling in the future. Excerpts:

The complete refutation will be available soon, but for now I will highlight one particularly deceptive example which illustrates blatant intellectual dishonesty.  On pg. 48, Maskell states:

In one case concerning the identity of a petitioner, the Supreme Court of the United States explained that “[i]t is not disputed that if petitioner is the son” of two Chinese national citizens who were physically in the United States when petitioner was born, then he is “a natural born American citizen ….”221

The petitioner was born in California to parents who were both US citizens.  His father was born in the United States and was a citizen by virtue of the holding in US v. Wong Kim Ark.  His mother’ place of birth was not mentioned.  Regardless, she was covered by the derivative citizenship statute, and was, therefore, a US citizen when the child was born.

But the Supreme Court never said that.  Here’s what they actually said:

“It is not disputed that if petitioner is the son of Kwock Tuck Lee and his wife, Tom Ying Shee, he was born to them when they were permanently domiciled in the United States, is a citizen thereof, and is entitled to admission to the country. United States v. Wong Kim Ark, 169 U.S. 649 , 18 Sup. Ct. 456.”  Kwok Jan Fat v. White, 253 U.S. 454, 457 (1920).


Donofrio commits at least two major errors. Let us first deal with whether or not Jack Maskell was being deceptive in his characterization. Here are excerpts from what the Supreme Court said in the Kwock Jan Fat case:

In January, 1915, Kwock Jan Fat, the petitioner, intending to leave the United States on a temporary visit to China, filed with the Commissioner of Immigration for the Port of San Francisco an application, as provided for by law, for a “preinvestigation of his claimed status as an American citizen by birth.”

He claimed that he was 18 years of age, was born at Monterey, California, was the son of Kwock Tuck Lee, then deceased, who was born in America of Chinese parents and had resided at Monterey for many years; that his mother at the time was living at Monterey, and that there were five children in the family, three girls and two boys.

But, while it is conceded that he is certainly the same person who, upon full investigation, was found, in March, 1915, by the then Commissioner of Immigration, to be a natural born American citizen, the claim is that that Commissioner was deceived, and that petitioner is really Lew Suey Chong, who was admitted to this country in 1909 as a son of a Chinese merchant, Lew Wing Tong, of Oakland, California

It is not disputed that if petitioner is the son of Kwock Tuck Lee and his wife, Tom Ying Shee, he was born to them when they were permanently domiciled in the United States, is a citizen thereof, and is entitled to admission to the country. United States v. Wong Kim Ark, 169 U. S. 649.

It is better that many Chinese immigrants should be improperly admitted than that one natural born citizen of the United States should be permanently excluded from his country.

Here is a link to the case:


Sooo,  the Kwock Jan Fat Court itself said:

[I]f he was born here, when [his parents] were permanently domiciled in the United States, he is a citizen, and that it was  better to err on the side of  a natural born citizen when they released him from imprisonment.

Maskell cited the Kwock Jan Fat Court as EXPLAINING:

the Supreme Court of the United States explained that “[i]t is not disputed that if petitioner is the son” of two Chinese national citizens who were physically in the United States when petitioner was born, then he is “a natural born American citizen ….

Sorry Paraclete, but I don’t see any big difference.  The Court does not go into the citizenship of the parents. After reading what they say, one is left with the sense that it is the place of birth not the citizenship of the parents which provides the citizenship.  Else why go into “ he was born to them when they were permanently domiciled in the United States“?  Plus, “permanently domiciled in the United States” certainly leaves open the implication they were indeed Chinese nationals.  While the fact the father was native born would have probably made him a natural born citizen also, there is no other information provided to the court on that point. The Court does not go into it in their analysis.

That was an accurate summing up of the case. I would not have phrased it the same way as Maskell, but his statement is far from being deceptive. Unless of course one doesn’t like the natural born citizen language. Maybe this is just proof of what I have said all along. Two citizen-parent Birthers are reading comprehension challenged.

Now, let us deal with Donofrio’s second major error, his analysis of Kwock Jan Fat’s parents’ citizenship status. Donofrio waxes pompously:

Having been born in the US of parents who were citizens, petitioner was indeed a natural-born citizen.  But Maskell’s frightening quotation surgery makes it appear as if the petitioner was born of alien parents.  The Supreme Court rejected that contention.  And Maskell’s ruse highlights the depravity of lies being shoved down the nation’s throat on this issue.  I can imagine Mini-Me sitting on his lap while this was being prepared.

Well first, from above, the Kwock Jan Fat Court characterized the parents simply as permanently domiciled in the United States. The Court does not go into any kind of analysis of their citizenship status. Several statements were made by white citizens prior to Kwock’s year long trip to China.  None expressly called Kwock’s father a citizen, although they did note he was born in America and registered to vote.  No documents were presented, and this would have simply been hearsay evidence.  But this was offered simply to prove that Kwock had been born in America, not to prove the citizenship of his father.  As a legal matter, no one on the Court knew or cared what citizenship the father adhered to.  No evidence was submitted that the Father was either a diplomat or invading soldier. And that is additional evidence that the two citizen-parent stuff is nonsense.

Further, at the time of Kwock Jan Fat case, the Chinese Exclusion Act was in effect. Wiki says:

The Chinese Exclusion Act was a United States federal law signed by Chester A. Arthur on May 8, 1882, following revisions made in 1880 to the Burlingame Treaty of 1868. Those revisions allowed the U.S.  to suspend immigration, and Congress subsequently acted quickly to implement the suspension of Chinese immigration, a ban that was intended to last 10 years. This law was repealed by the Magnuson Act on December 17, 1943.

The Act also affected Asians who had already settled in the United States. Any Chinese who left the United States had to obtain certifications for reentry, and the Act made Chinese immigrants permanent aliens by excluding them from U.S. citizenship.After the Act’s passage, Chinese men in the U.S. had little chance of ever reuniting with their wives, or of starting families in their new homes.

Between 1882 and 1905, about 10,000 Chinese appealed against negative immigration decisions to federal court, usually via a petition for habeas corpus. In most of these cases, the courts ruled in favor of the petitioner.Except in cases of bias or negligence, these petitions were barred by an act that passed Congress in 1894 and was upheld by the U.S. Supreme Court in U.S. vs Lem Moon Sing (1895). In U.S. vs Ju Toy (1905), the U.S. Supreme Court reaffirmed that the port inspectors and the Secretary of Commerce had final authority on who could be admitted. Ju Toy’s petition was thus barred despite the fact that the district court found that he was an American citizen. The Supreme Court determined that refusing entry at a port does not require due process and is legally equivalent to refusing entry at a land crossing. This ruling triggered a brief boycott of U.S. goods in China.

The Chinese Exclusion Act was repealed by the 1943 Magnuson Act, which permitted Chinese nationals already residing in the country to become naturalized citizens and stop hiding from the threat of deportation. It also allowed a national quota of 105 Chinese immigrants per year. Large scale Chinese immigration did not occur until the passage of the Immigration Act of 1965. Despite the fact that the exclusion act was repealed in 1943, the law in California that Chinese people were not allowed to marry whites was not repealed until 1948.

Even today, although all its constituent sections have long been repealed, Chapter 7 of Title 8 of the United States Code is headed, “Exclusion of Chinese.” It is the only chapter of the 15 chapters in Title 8 (Aliens and Nationality) that is completely focused on a specific nationality or ethnic group.

In 2011, the US Senate passed a resolution apologising for past discriminatory actions such as this act.


The is no evidence that Kwock’s father ever applied for certification for re-entry, something required for Chinese born here even 22 years after Wong Kim Ark.  And after reference to the Chinese Exclusion Act above, it was far from certain that Kwock’s father would have automatically been presumed to be a citizen without proof of his birth place, which would default to him being deemed a Chinese national a reasonable characterization.

And, another thing that Donofrio misses, is that the dog didn’t bark.  Similarly, the Kwock Jan Fat Court didn’t engage in an analysis of the parent’s citizenship.  The Court’s characterization is simply that they were permanently domiciled in the United States. And it stopped there.  Because the two citizen-parent stuff is just imaginary Birther law. Looking back at the facts, we can engage in that analysis, but that court didn’t.  Real courts don’t do imaginary law very well. There was no reason to inquire into their citizenship status anymore than there was to in Wong Kim Ark. 

It is important to keep in mind where we are in this discussion. A 53 page memo was written which devastates the two citizen-parent theory. In response, Leo Donofrio picks out one sentence of that memo to try to destroy its credibility. That in itself is a silly enterprise, but entirely predictable. The Birthers have a history of ignoring Reality to maintain their theory. It is not surprising that they would attempt to ignore 52+ pages of well documented legal memo to keep up their delusions.

Finally, let me give the Paraclete one last kick in the seat of the pants. How dare YOU, who have made up this two citizen-parent nonsense up out of thin air accuse anyone of misrepresenting anything?  YOU, who mangles and distorts cases like Minor v. Happersett into false precedent. What makes you think that YOU, the inventor of The Donofrio Shuffle, where you substituted the words from the dissent into the majority decision, without cites, have any right to criticize anyone? Remember The Donofrio Shuffle:

How To Do The Donofrio Shuffle: You Put The Wrong Quote In, You Take The Right Quote Out; You Put The Wrong Quote In, And You Twist It All About. . .

Go, Leo. Go in peace. Go in anger. Whatever,  just go.

Squeeky Fromm
Girl Reporter

Note 1: Chinese Checkers. There is more than one way to play. Wiki says:

In the capture variant, all sixty game pieces start out in the hexagonal field in the center of the game board. The center position is left unoccupied, so pieces form a symmetric hexagonal pattern. Color is irrelevant in this variant, so players take turns hopping any game piece over any other eligible game piece(s) on the board. The hopped-over pieces are captured (retired from the game, as in American checkers) and collected in the capturing player’s bin. Only jumping moves are allowed; the game ends when no further jumps are possible. The player with the most captured pieces is the winner.

The board is tightly packed at the start of the game; as more pieces are captured, the board frees up, often allowing multiple captures to take place in a single move.

Two or more players can compete in this game, but if there are more than six players, not everyone will get a fair turn.