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STATE OF' ARIZONA 

County of Maricopa 

AFFIDAVIT 

1, the undersigned, being first duly sworn, do hereby state under oath and under 

penalty of perjury that the following facts are true: 

1. I am over the age of i8 and am a resident of Arizona. The information 

contained in this affidavit is based upon my own personal knowledge and, 

if called as a witness, I could testify competently thereto. I am a former 

sworn law enforcement officer and criminal investigator. Since 2007 1 have been duly appointed by the elected Sheriff of Maricopa County, Arizona, Joseph Arpaio, as the chief investigator of his Cold Case Posse. 

2. Under the Arizona Constitution and Arizona Revised Statutes, the Sheriff 

has the authority to request assistance from a volunteer posse ("the Cold 

Case Posse"), a special five-member team of experienced investigators located in the county, to assist him in the execution of his duties. The 

individually-selected team deputized by the Sheriff includes former police detectives and attorneys who work voluntarily and at virtually no expense to the taxpayer whenever the Sheriff authorizes an investigation to address 

any issue as the Sheriff deems appropriate. 

3. In August 2011, a group of citizens from the Surprise Arizona Tea Party organization called upon the Sheriff in his office and presented a petition signed by approximately 250 residents of Maricopa County, requesting the 

Sheriff's Department to investigate whether a document posted on the 

official website of the White House on 27 April 2011 and purporting on its 

face to be an electronic image of the "long-form" or original Hawaiian birth certificate of President Barack Hussein Obama was genuine. 

4. If the image of the birth certificate were not genuine, the question might arise whether Mr Obama had been born within the jurisdiction of the United States and thereby complied with the requirement under Article II of the U.S. Constitution that the President be a "natural-born citizen". 

5. The petitioners expressed their concern that, until that point, no law enforcement agency had ever gone on record as indicating that it had investigated or was willing to investigate whether President Obama was eligible to hold his office. The petitioners said that lack of resources and jurisdictional challenges had inhibited any such investigation elsewhere. 

6. Sheriff Arpaio commissioned the Cold Case Posse to undertake the 

investigation requested by the petitioners. The principal focus of the investigation is the electronic document on the White House website that President Ohama had presented as the image of his long-form birth 

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certificate to the American people and to citizens of Maricopa County at a 

White House press conference on April 27, 2011, when he had said: "We 

provided additional information today about the site of my birth. ... Yes, in 

fact, I was born in Hawaii, August 4, 1961, in Kapi'olani Hospital." 

7. For 17 years from 199? until the year before the Presidential election of 

2008, the annually-revised biography written by Mr Obama and circulated 

by his literary agents had contained the words "Barack Obama, the first 

African-American President of the Harvard Law Review, was born in 

Kenya and raised in Indonesia and Hawaii." 

8. The official Parliamentary Debates of the Kenyan National Assembly for 

25 March 2010 records that Mr Orengo, the Minister for Lands, said: "If 

America ... did not see itself as a multiparty state or nation, how could a 

young man born here in Kenya, who is not even a native American, 

become the President of America?" 

9. The investigation has closely examined the procedures for registration of 

births at the Hawaii Department of Health and various statements made 

by officials of the Hawaii government over the last five years in connection 

with the authenticity of Mr Obama's birth records. We have chronicled a 

series of inconsistent and misleading representations that various officials 

of the government of FIawaii have made since 2007 on the question what 

original birth records, if any, are held by the Hawaii Department of Health. 

10. In February 2012, I reported to Sheriff Arpaio that there was probable 

cause to consider that the White House image of Mr Obama's birth 

certificate was a forgery, and specifically that it was not a true and accurate 

photographic image of a genuine birth record. I advised the Sheriff that 

the forgers had probably committed two crimes: first, fraudulently 

creating a forgery that the White House had characterized, knowingly or 

unknowingly, as an officially-produced governmental birth record; and 

secondly, fraudulently presenting to the residents of Maricopa County and 

to the American public at large a forgery that the White House had 

represented as "proof positive" of President Obama's authentic 1961 

Hawaiian long-form birth certificate. 

ii. These conclusions were reinforced by input from numerous experts in the 

fields of typewriting, typesetting, computer-generated documentation, 

forensic document analysis and Adobe computer programs, as well as 

comparisons with numerous other birth records and expert reviews of 

Hawaii state law and of the regulations, policies and procedures of the 

Hawaii Department of Health. 

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12. The investigation further determined that the Hawaii Department of 

Health has engaged in what the Sheriffs investigators believe is a 

systematic effort to hide from law enforcement and the public whatever 

original 1961 birth records the Hawaii Department of Health may have in 

its possession. The Posse also accumulated evidence that the Hawaii 

government and its agencies had changed their policies and procedures in 

a manner calculated to hinder our law-enforcement investigation. 

13. In furtherance of the investigation, which has now continued for more 

than a year, I have twice visited Hawaii within the last six months. On the 

first occasion, a Maricopa County Sheriffs Office Detective and I 

presented our credentials to the offices of the Hawaii Department of 

I'Iealth and requested to speak to Mr Alvin Onaka, the chief registrar of 

births, a simulacrum of whose signature-stamp had appeared on the 

electronic document on the White House website. We had hoped to ask Mr 

Onaka if he would verify the authenticity of the White Fiouse released 

document and to verify the legitimacy of the registrar's stamp bearing his 

signature. Additionally we hoped to ask him to allow us, for lawenforcement reasons, to inspect the original document and, in due course, 

to subject it to forensic examination. 

14. However, when we presented our credentials at the front desk of the 

Hawaii Department of Health, much to our amazement we were informed 

that Mr Onaka does not speak to the public. We explained that we were 

there on official business. Nevertheless, we were not permitted access to 

Mr Onaka. 15. At our insistence we did have an opportunity to speak with Deputy Attorney General Jill Nagamine. During our meeting Ms. Nagarnine refused to verify the authenticity of the PDF file released by the White 

House. As a matter of fact Ms. Nagamine would not provide us with any confirmation that the document was created by tile Hawaii Department of 

Health. 

iô. Ms. Nagamine accused us of trying to get a verification of a birth record 

without legal authority to do so, even though the document has been 

offered for public view via the World Wide Web. She constantly evaded 

answering every question about the legitimacy of the document by hiding behind State statutes. 17. We also visited the Kapi'olani Hospital, which the document on the White 

House website identifies as the place of Mr Obama's birth. We had 

discovered as a result of our enquiries that the hospital, at the relevant 

time, had maintained a separate record-keeping system by which all births 

at the hospital were recorded. This document is stored in the hospital archives. These archives are accessible to the public by hospital 

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permission. We asked to see the hospital's birth records for 1961 but were 

less than politely refused. At no time did Kapi'olani Hospital ever confirm 

that Mr Obama was in fact born in the hospital. Nor did they confirm that 

they were in possession of his birth records, 

i8. Having regard to the elaborate non-cooperation we received from the State 

of Hawaii, and upon close examination of the evidence, it is my investigational opinion, shared by the Sheriff, that forgery and fraud have 

been committed in key identity records, including President Obama's 

long-form birth certificate; his computerized short-form birth abstract; his 

Selective Service Registration card. 

19. The Cold Case Posse has also noted that Mr Obama's first Executive Order, issued on his first full day as President, was to seal all of his own past records from public scrutiny. Documentation that is not available for Mr 

Obama includes not only his original birth records but also his baptism records, his adoption records, his kindergarten records, his Punahou 

school records, his Occidental College records, his Columbia University records, his Columbia University thesis, his Harvard Law School records, his Harvard Law Review articles, his scholarly articles from the University of Chicago, his passports, his medical records, his files from his years as an 

Illinois State Senator, and his illinois State Bar Association records, 

20. The then Republican Governor, Linda Lingle, stated during an interview 

on New York's WABC radio in 2008 that in an attempt to quell the Birth Certificate issue she had the Birth Certificate inspected by the state's director of health, Chiyorne Fukino. 

21, Lingle is quoted "So I had my health director, who is a physician by background, go personally view the birth certificate in the birth records of the Department of Health, and we issued a news release at that time saying that the president was, in fact, born at Kapi'olani Hospital in Honolulu, Hawaii. And that's just a fact and yet people continue to call up and e-mail and want to make it an issue and I think it's again a horrible distraction for the country by those people who continue this." 

22.On October 31, 2008, Dr. Chiyome Fukino released the following statement: "There have been numerous requests for Sen. Barack Hussein Ohama's official birth certificate. State law (Hawai'i Revised Statutes §338-18) prohibits the release of a certified birth certificate to persons who do not have a tangible interest in the vital record. Therefore, I as Director of Health fo.r the State of Hawai'i, along with the Registrar of Vital Statistics, who has statuto.iy authority to oversee and maintain these type of vital records, have personally seen and verified that the Hawai'i State Department of Health has Sen. Obama's original birth certificate on record 

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in accordance with state policies and procedures. No state official, 

including Governor Linda Lingle, has ever instructed that this vital record 

be handled in a manner different from any other vital record in the 

possession of the State of Hawai'i." 

23. Months later, in July 2009, she added another comment: "1, Dr. Chiyome Fukino, Director of the Hawaii State Department of Health, have seen the 

original vital records maintained on file by the Hawaii State Department of 

Health veriing Barack Hussein Obama was born in Hawaii and is a 

natural-born American, I have nothing further to add to this statement or 

my original statement issued in October 2008 over eight months ago." 

Significantly, Fukino changes the wording from viewing Sen. Obama's 

"original birth certificate" to having "seen the original vital records maintained on file by the Hawaii State Department of Health, verifiing Barack Hussein Obarna was born in Hawaii and is a natural-born 

American". 

24.The Governor of Hawaii, Mr Neil Abererombie, has said that he was 

present when Mr. Obama was born. Later, however, he retracted that 

statement and acknowledged that he did not see Obama's parents with their new born son at any hospital, although he said he remembers seeing Obama as a child with his parents at social events. There is no evidence to 

support that claim. No doctor or nurse who attended his birth has come forward to say so. 

25. Abercrombie told the Honolulu Star Advertiser he was searching within the Hawaii Department of Health to find definitive vital records that would prove Obama was born in 1-lawali, because the continuing eligibility controversy could hurt the president's chances of re-election in 2012. 

26.Abercrombie said the birth certificate issue would have "political implications" for the presidential election "thaL we simply cannot have." 

27. Abererombie did not report to the newspaper that he or the Hawaii Department of Health had found Obama's long-form, hospital-generated birth certificate. The governor only suggested his investigations to date had identified an unspecified listing or notation of Obama's birth that 

someone had made in the state archives. 

28.Abercrombie did not say to the newspaper that he or the Hawaii Department of Health had found Obarna's long-form, hospital-generated birth certificate. Nor did he say to the newspaper he had personally seen 

any birth record for Obama. The governor only suggested his investigations to date had identified an unspecified listing or notation of Obama's birth that someone had made in the state archives. 

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29. "It was actually written, I am told, this is what our investigation is 

showing, it actually exists in the archives, written down," Abercrombie 

said. 

30. Conceivably, the yet-undisclosed birth record in the state archives that 

Abererombie said had been discovered may have come from the 

grandparents registering Obama's birth, an event that would automatically 

have triggered both the newspaper birth announcements and availability of a Certification of Live Birth, even if no long-form birth certificate 

existed. 

31. Our investigation has revealed that in 1961, as Hawaiian law then stood, 

Obama's grandparents, Stanley and Madelyn Dunham, could lawfully have 

made an in-person report of a Hawaiian birth even if the infant Barack 

Obama Jr. had been foreign-born. 

32. The newspaper announcements of Mr Obama's birth do not prove he was 

born in Hawaii, since they could have been triggered by the grandparents registering the birth as Hawaiian. They might then have paid for the 

announcement themselves. 

33. However, we have learned that it was not uncommon for local newspapers 

to publish birth announcement paid for by individuals reporting the birth 

in the local paper, even if the child was born elsewhere. If so, the 

registration of an out-of-countiy birth as Hawaiian would have been 

reported in the same way as the registration of an in-country birth. 

Neither of the two advertisements states that Obama was born in a 

particular hospital. Both give very limited information. 

34.To date the purported. undisclosed birth record in the state archives that 

Abercrombie has claimed to have discovered and has described as being "actually written" has never been made public. Being located in the state 

archives, this document should be available for inspection by the general public without restraint. 

35. From Abererombie's admission, it is legitimate to infer that this record, if 

it indeed exists, was not in the possession of the Hawaii Department of 

l-Iealth, which may have had no record of the in-country birth of Mr 

Obama either in hard copy form, such as long form birth certificate, preserved in its vault as described by Dr. Chiyorne Fukino. If such a 

document had existed, Abercromhie would have had it within minutes of 

his request. 

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36. Mr Obama's long-form birth certificate would have been preserved in a 

hard-covered bound volume along with the other long form birth 

certificates of that period. This record would have been easily accessible to 

the Department of Health upon the Governor's request, had it existed. 

37. Dr. Chiyome Ful<ino also gave an interview to CNN on April 26, 2011, in 

which she stated that she simply went into the vault and inspected 

Obama's original Birth Certificate. Inferentially, it should have been that 

easy for Governor Abercrombie to locate it as well. 

38.This circumstance also suggests that the birth record of Mr Obama was 

not at that time recorded in the Department of Health's computerized 

database that has been in use since 2001. 

39. In March 2012, Sheriff Arpaio held a Press Conference during which he 

and I presented an outhne of those aspects of the investigation that would 

not compromise the safety of witnesses or the integrity and future course 

of the investigation. At that time, we had concluded that there was 

probable cause that forgery and fraud had been committed in respect of 

four documents: the long-form or original birth certificate for Mr Obarna, 

which contained multiple errors and anomalies, many of them serious; the 

short-form computer-generated abstract of Mr Obama's birth record that 

the Democratic Party had published in 2007, which was printed using a 

form of words not current at the relevant date; the selective-service 

document for Mr Obama, which contained a two-digit year-stamp contrary 

to specifications written by the Department of Defence to the effect that 

the year of issue should be expressed as four digits on the stamp, and 

contrary to any other selective-service registration document that we have 

been able to examine; and we are aware that the social security number, 

which has a prefix that at the date of issue was unique to Connecticut even 

though Mr Obama has never resided in that State. 

40. In an attempt to verify whether Mr Obama and his mother had arrived in 

the United States at or around the alleged date of his birth, we contacted 

the National Archives to obtain microfilms of the 1-94 immigration 

landing records for the year 1961. All such records were and are available 

for the entire year 1961, except for those on the alleged date of Mr Obarna's 

birth (August 4), three days before that date, and three days after that 

date. The Archivist and his staff did not tell us how the missing records 

had come to be lost, and offered no hope that they would ever come to 

light. 

41. After three months of further investigation, the Sheriff held a second press 

conference to announce, with my support, that it was no longer a question 

of probable cause: it was now certain that the document on the White 

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House website was a forgery. The Sheriff also announced that the 

investigation would continue: and it has continued ever since. 

42.The purpose of holding press conferences was and is to notify the public that an investigation is in progress, with the aim of obtaining additional 

information that might be helpful to the investigators in reaching the 

truth. As a result of both press conferences, additional material of this 

kind became available to us. 

43. Our investigation concludes that President Obama's long-form birth 

certificate is a computer-generated document; that it was manufactured 

piecemeal and electronically; and that it did not originate as a copy of a 

true paper record from a bound volume, as claimed by the White House and by the Governor of Hawaii and by the director of the Health 

Department, cited in a press release issued April 27, 2011, by the Governor 

to coincide with the publication of the document on the White House website. 

44. Most importantly, the "registrar's stamp" in the computer-generated document released by the White House and posted on the White House website may have been imported from another unknown source 

document. The fact that the stamp cannot have been placed on the document pursuant to state and federal laws is one of many indications that the document is a forgery and, therefore, that it cannot be relied upon as verification, legal or otherwise, of the date, place or circumstances of Mr Obama's birth. 

45. The Registrar's date-stamp exhibited a similar grave anomaly, allowing it to be moved about electronically within the document which would have been impossible if the document were the scanned and certified copy that official statements profess it to be. The Registrar's signature-stamp and date-stamp were computer-generated images that were imported into the document. They were not electronic images of actual rubber-stamp imprints inked by hand or machine on to a paper document. Accordingly, the document on the White House website is, at a minimum, misleading to the public in that it has no legal import and cannot be relied upon as a legal document carrying the full faith and credit of the State of Hawaii and verifying the date, place and other circumstances of Mr Obama's birth. A photograph of the Registrar's date-stamp is exhibited and marked "MZ2". 

46. These and numerous other errors and anomalies observed after extensive forensic scrutiny of the electronic image downloaded from the White House website were inconsistent with features to be expected when a 

paper document is placed on the glass plate of a scanner so that it can be captured as an electro-photographic image, or when it is scanned. and then 

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processed either to enhance the clarity of the image by optical character 

recognition or to reduce file-size by file-compression or optimization. 

47. Furthering the investigation, I returned to Hawaii for a second time. I met 

Mr Duncan Sunahara, the brother of Virginia Sunahara, an infant born in 

Hawaii on August 4, 1961, the alleged date of Mr Obama's birth there. Ms 

Sunahara died the following day, August 5, after breathing difficulties. 

When I met Mr Sunahara he had recently applied to the Department of 

Health in Hawaii for a copy of his deceased sister's birth certificate, He 

told me the Department had gone to great lengths to deny him a copy f 

the original long-form birth certificate that a close relative is entitled by 

law to request and the Department is obliged by law to supply. The Cold 

Case Posse is compelled to consider the question why this little girl's 1961 

long-form birth certificate was so disconcerting to the Hawaii Department 

of Health that it did not wish to issue a copy to Mr Sunahara upon request. 

48.1 obtained from Mr Sunahara a copy of proceedings in the Circuit Court of 

the First Circuit, State of Hawaii, in which the Deputy Attorney General, 

Ms Nagamine, appeared before Judge Rhonda Nishirnura on March 8, 

2012, to argue that Mr Sunahara was not entitled under Hawaiian statute 

law to see, still less obtain, a certified copy of his deceased sister's original 

ig6i long-form birth certificate. 

49. During the proceedings, the Attorney General implied that Mr Sunahara's 

request arose from an underlying interest in obtaining evidence that might 

assist in determining whether the document on the White House website 

is indeed a forgeiy. Ms Nagamine said Mr Sunahara ought to be satisfied 

with a short-form extract of the birth record rather than a long-form 

printed image of the original copy in the bound volume for 1961 in the 

vaults of the Health Department. 

50. Ms Nagamine also said that the entire volume of birth certificates 

inferentially containing not only Ms Sunahara's long-form original birth 

certificate but also those of twins born at about the same date had been 

removed to a special, secure location with very limited access. I do not 

know what purpose the Department of Health had in preserving these 

records at all, unless it was to show them upon request to family members 

and others - such as law enforcement with a legitimate and statutory interest in seeing the documents. 

51. Ms Nagamine said that accessing the original birth records was difficult 

and expensive. However, in Dr. Chiyome Fukino's interview with CNN she 

stated that she simply went into the vault and inspected Obama's original 

Birth Certificate. I am told by Mr Sunahara that he was willing to pay any 

reasonable fee to cover the cost. Our investigation indicates that the 

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Health Department's fee is not great: attorneys for Obama had paid $10 

for a certified copy and $4 for a second certified copy. Inferentiafly, such 

small fees are an indication that the difficulty of consulting the archives 

and generating certified copies is not great. And I have come across further 

evidence that the difficulty of consulting the records is not very great: for 

they are normally kept in bound volumes on specially-designed shelves 

known to librarians as "stacks". A picture of Mr Onaka pulling out a book 

of birth records from 1972, just nine years after the year that is of interest 

to our investigation, shows how small the difficulty in consulting the 

records is likely to be. The photograph is marked "MZi", annexed and 

signed as relative hereto. 

52. The reason why law-enforcement investigators wish to examine the 

original long-form birth certificate of Ms Sunahara relates to the practice of the Health Department to number each birth certificate sequentially with the last two digits of the year followed by a five-digit number incremented sequentially by a date-stamp that advanced the counter by i after every stamping. At that time, approximately 48 births occurred every day in Hawaii, and were required to be registered. They were sequentially stamped in order of date of birth. 

53. Photostat images of the long-form original birth certificates of twin daughters born to Eleanor Nordyke at Kapi'olani Hospital August 5, 1961, 

one day after the alleged birth of Mr Obama at the same hospital, have been drawn to the Cold Case Posse's attention. They had been published in the Honolulu Advertiser. As a result of examining these images, the Cold 

Case Posse has reason to suspect that the sequential number on the 

computer-generated short-form abstract that the Health Department released to the family is not the same as that which appears on the long- form original birth certificate that was issued for Ms Sunahara. 

54. Examination of the birth certificates issued to the parents of the Nordyke twins shows that their registration numbers,, 61/10637 and 10638, preceded the number on Mr Obama's short-form and long-form certificates, which is shown as 61/10641, even though he was born a day earlier than they were. Ms Sunahara was born August 4, 1961, and her certificate was stamped by the Hawaii registrar August 8, but her number 

was iio80. The table summarizes the position: 

Name of child Date and time born Registered Certificate # 

Barack Obama Aug 4 at 7:24 pm Aug 8 10641 

Virginia Sunahara Aug 4 at 9:16 pm Aug 10 iio8o 

Susan Nordyke Aug at 2:12 pm Aug 11 10637 

Gretchen Nordyke Aug 5 at 2:17 pin Aug 11 10638 

I'll 

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55. Mr Obama's birth certificate was registered August 8, 1961. The Nordyke twins' birth certificate was registered August 11, 1961. Even if the sequential numbering had followed the date of registration rather than the date of birth, Mr Obama's certificate should have been automatically assigned a number lower, not higher, than the numbers allocated to the 

certificates of the Nordyke twins. And the number currently assigned to Ms Sunahara is entirely out of sequence. 

56, One possible explanation for the out-of-sequence serial numbers might have been that several serialized piles of birth certificates were registered at different hospitals. liowever, Ms Verna K. Lee, an official responsible for the recording of births in Honolulu in 1961, when interviewed by a reporter for wnd.com, said that this was not the case. Ms Lee was the local registrar who apparently signed the document on the White House website (it is possible that the forgers lifted her signature from another birth certificate and inserted it electronically into the computerized compilation that is now on the White House website). 

57. Ms. Lee was surprised that the numbers were out of sequence. Ms. Lee made recorded statements to a WND reporter during a phone interview. I have personally listened to those recordings. On the recorded conversation Ms. Lee said that all of the birth certificates received in a month were ordered chronologically by date and time of birth and numbered sequentially at the end of each month. The only exception not relevant in the present case was that birth certificates received from the islands and from one local out-station in Oahu were grouped separately, so as not to under-represent births outside Honolulu or unattended births occurring at home in the 50% statistical samples by which only even- numbered births were reported to the Federal Government as mandated by the U.S. Office of Vital Statistics. 

58. Ms Lee has said that birth certificates from the hospitals in Oahu were sent directly to the central office of the Department of Health in Honolulu. The birth certificates were all numbered at the end of each month by one person. When Ms Lee was asked whether there might have been mistakes in numbering the birth certificates, she insisted that they were numbered correctly and in sequence. The long-form original certificates were inspected twice for accuracy by two different clerks and then signed by the registrar. They were kept together secured in a certain room until they were all numbered at the end of the month. They were not allowed to become out of order and they were not numbered incorrectly. (It should be noted that the Nordyke twins were born minutes apart and their respective certificate numbering was based not only on date but on time as well. This indicates the clerk scrutinized the documents prior to placing them in chronological order for proper numbering.) Based on Ms Lee's representation, I consider it highly unlikely that a birth certificate so far 

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out of sequence as that which now appears on Ms Sunahara's short-form 

birth abstract could have been accepted at a registrar's office managed by Verna K. Lee. 

59. It is also possible that investigators are being misled into devoting attention to the number on Ms Sunahara's original long-form birth 

certificate, which may after all turn out to be different from that of Mr 

Obama and identical to that which appears on her short-form computer abstract. For that reason among others, investigators would like to inspect and, in due course, forensically to examine the volumes of long-form certificates for 1961, and specifically the long-form original birth 

certificates for Mr Obama, for Ms Sunahara, and for the Nordyke twins. 

6o.A possibility that the investigators are constrained to bear in mind, given the numerous other defects in the document on the White House website, 

is that the number on that document is not a genuine registration number 

assigned to his birth certificate in 1961, but was issued when the shortform document was generated during the 2008 presidential campaign. It 

is possible that the Health Department does not want the public to see the 

original 1961 birth records because forensic examination might establish 

that the forgers had made a mistake in assigning to the forged long-form document on the White House website a number that was out of sequence and that may (or may not) be identical with the number on the long-form original birth certificate of Ms Sunahara. This is one reason why the 

investigators have asked to see the original bound volumes from the 

stacks. 

6i. I am additionally concerned that the Hawaii Department of Health has not 

offered any testimony that the modern computerized data now used to 

generate the short-form abstracts have been safeguarded from numerical 

or other data manipulation. All that the Attorney General of Hawaii 

offered to the Maricopa County Sheriffs Office as proof that Mr Obama 

was born in Hawaii was a computer-generated list of birth registrations that was contained in a ring-binder. Pages could easily be removed, added, 

or removed, altered and reinserted at will. There was no level of security other than closing the rings of the binder holding the pages together. 

62.The investigators have obtained an affidavit from an individual who went 

to the Department of Health when some of the first questions were being raised about Mr Obama's birth certificate. That individual states that when 

he first wen.t to the main office of the Hawaii Department of Health in 

Ilonolulu, Mr Obama's name did not appear in the computerized registration list in the ring binder, but when he went back approximately 

14 days later to re-examine the same list he was surprised to see that Mr 

Obama's name now appeared on it. 

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63. Notwithstanding this affidavit, it is plausible that an original birth record 

for Mr Obarna exists in Hawaii. Our investigation has discovered that at 

that time Hawaiian law contained a specific provision that permitted a 

Hawaiian parent of a child born anywhere in the world or any adult 

purporting to represent that parent, the right to register the child as 

Hawaiian-born. It is for this reason that two entries in the "Births" column 

of the local newspapers at the time do not constitute evidence that Mr 

Obama was born in Hawaii. They are merely evidence suggesting that a 

birth certificate was issued for him in Hawaii, and they tell us nothing 

about whether or not he was born there. In particular they do not as the 

White House document purports to do - identify the hospital of birth. 

64. If Mr Obama had not in fact been born in Hawaii, the long-form original birth certificate would not have stated that he had been born in a 

particular hospital at a particular time, and would not have borne the 

signatures of the attending physician and registrar. The newspaper entries 

would have been identical whether he had been born in Hawaii or 

elsewhere in the world; but the birth records would not have been 

identical. 

65, The existence of this law permitting out-of-country births to be registered 

as though they were Hawaiian births is a further reason why the Sheriff 

wishes his forensic investigators to be given access to the original hound 

volumes of birth certificates for 1961, and to be permitted to carry out 

forensic scrutiny of the volumes and of certain individual certificates, 

including that of Mr Ohama. 

66. For these reasons, it is necessary for the investigators to bear in mind the 

possibility that the intention of the Hawaii Department of Health in 

refusing to allow Mr Sunahara to have a certified copy of the original birth 

certificate of his deceased sister is to conceal forgery and fraud within the 

Department itself. 

67. The Cold Case Posse's law-enforcement investigation into Mr Obama's 

birth certificate continues, taking account of the additional information 

obtained both as a result of the Cold Case Posse's own enquiries and as a 

result of assistance from the public following the publication of some of 

our results by the Sheriff at the March and July 2012 press conferences. 

68.The law-enforcement investigation by and on behalf of the Sheriff of 

Maricopa County, Arizona, would be greatly assisted, and could be 

brought swiftly, inexpensively, and decisively to an end, if the Department of Health and the management of the Kapi'olani Hospital were willing to 

allow court-recognized forensic experts selected by the Sheriff of Maricopa County to inspect and forensically examine the volumes of long-form 

13 

Case 6:20-cv-00362-ADA Document 1-2 Filed 05/05/20 Page 14 of 17
original birth certificates for 1961 and the birth records kept by the 

Kapi'olani Hospital for that year. It should be .noted that forensic experts 

are trained in the management and preservation of paper records, and 

would cause no damage to the records in the course of their forensic 

examination. 

Executed this day of 2012, 

in Maricopa County', Arizona. 

Michael Zu I lo 

Sworn to and subscribed before me 

this 2012 

JAMES C JACKSON 

I ' Notary Pubflc - Arizona 

I Maricopa County 

My Comm. Expires Jun 3, 2015 t w r r 

Case 6:20-cv-00362-ADA Document 1-2 Filed 05/05/20 Page 15 of 17
MZI 

*** 

, 

: 1L 

:: 

54 

2t 

' 

* This 

for 972 

is the 

from 

photograph of Mr Oriaka withdrawing a bound volume of long-form original birth certitkates 

Hat'aii. The 

the stacks at the Department of l-teatth in Hawaii, referred to in my affidavit in Sunahara v. ihe Record. Siraighi, 

source of the photograph is an interview ol' Rasa Fournier with Mr Ouaka, entitled Keeping published at niidweek .com, November 16. 201 

15 

Case 6:20-cv-00362-ADA Document 1-2 Filed 05/05/20 Page 16 of 17
MZ2 

:;.:TTT 

'? "s-.', 

. . . * 

8AMI NUSSEIM 

I). ..c....,>D. Ea% 5tudt Uarvr C : ____ _____ M bItt 

(* fl.bJ flq.. a - 

This is the image, referred to in my affidavit in Sunahara v. Hawaii of the "long-form birth certificate" for Mr Obama, with the registrar's signature-stamp and, separately, the registrar's date-stamp moved from their original locations on the "certificate", which are indicated by white ghost images towards the foot of the green security paper on to which the fabricated document had been electronically superimposed. That the registrar's date stamp and the registrar's text/signature stamp were both created by links to external objects imported into the Obama birth certificate was also confirmed by turning on the "Links" option in the "Window" menu in Adobe illustrator. The inset image at top right is the list of links that appears when that option is activated. Evidence that the two registrar stamps are external objects imported into the Obama "birth document" can he seen in that the registrar's date stamp and text/signature stamp can easily and separately he electronically' moved, rotated at will, turned sideways or even upside-down. and repositioned anywhere on the document. None of several hundred software suites designed for the automated optical- character recognition, image enhancement, file compression, or optimization of an electro-photographic image olan original paper docwnent that were studied and tested by expert consultants to the investigative team was capable of processing the electronic data representing the image in such a manner as to store the data representing either of the two stamps on a single "layer" so as to allow the stamps to be moved about at wilt. 

/:__'.__ // -7 '.< 

Michael Zu11o' Date 

16 

Case 6:20-cv-00362-ADA Document 1-2 Filed 05/05/20 Page 17 of 17