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East Bay Law

Andrew W. Shalaby sbn 206841

1417 Solano Avenue

Albany, CA 94706

Tel. 510-551-8500

Fax: 510-725-4950

email: andrew@eastbaylaw.com 

Attorneys for Plaintiffs

The People of the State of California, and

The People of the United States of America

IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO

People of the United States of

America and the State of California,

 Plaintiffs,

vs.

Donald Trump; United States of

America,

Defendants.

Case Number: 3:17-cv-451

APPLICATION TO PROCEED IN

FORMA PAUPARIS

TO THE COURT:

Plaintiffs are the People of the United States of America and the State of

California. No one particular individual is named as a plaintiff in the action. It is my

understanding, belief, and opinion that the Court may only look to the assets which

belong to the People with regard to an application for waiver of Court Filing Fees and

Costs. Accordingly, it is my understanding and belief that the sole asset of the People

consists of Federal Taxes paid by the People to the United States Government. Since

taxes are federal funds, it is my understanding, belief and opinion that there are no

Application to Proceed In Forma Pauparis 1 No. 3:17-cv-451

Case 3:17-cv-00451 Document 3 Filed 01/30/17 Page 1 of 2
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separate and independent assets of the People of the United States and the State of

California (generally “the People), and therefore I believe this Application should be

granted on this basis.

As a second basis, the Federal Courts have posted the following on the internet: 

Effective on: December 1, 2016

The United States should not be charged fees under this schedule, with

the exception of those specifically prescribed in Items 2, 4 and 5, when

the information requested is available through remote electronic access. 

The posting is found at: 

http://www.uscourts.gov/services-forms/fees/district-court-miscellane

ous-fee-schedule 

It is my understanding, belief and opinion that an action brought on behalf of the

People of the United States is an action brought on behalf of “the United States.” 

Based on this understanding, belief and opinion, I do not believe that any Court filing

fees or costs can or should be charged in relation to this Action. In the alternative,

because there is not one particular individual plaintiff from which costs may be

collected and charged, I respectfully request the granting of this application as it

would not be fair or proper to require the representing law firm itself to pay the costs.

I declare under penalty of perjury that the foregoing is true and correct and

within my personal knowledge, and where opinions are specified, said opinions are

within my best judgment. The matters expressed above are based on my best

understanding, belief, and opinion.

Executed January 30, 2017 in El Cerrito,

CA

 s/Andrew W. Shalaby

Andrew W. Shalaby 

Application to Proceed In Forma Pauparis 2 No. 3:17-cv-451

Case 3:17-cv-00451 Document 3 Filed 01/30/17 Page 2 of 2