...The constitutional framers of 1787 established a rigged electoral franchise predicated on racial quotas that disproportionately favored a white minority. The original constitution of 1787 racially privileged white minority affirmative action articles is reconstituted in our time by the mechanism of "winner take all" politics that is not grounded in the Constitution or Federal law....Plaintiff is entitled to an order in the nature of a mandamus to compel Defendants to reject Certificates of Votes that only record the award of electors by the least fair allocation of presidential electors on a winner-take-all basis ungrounded in State Law, Federal Law or the US Constitution over the obviously more fair proportional allocation of presidential electors based on Amend14§2, as enforced by 2U.S.C§6...

...Why do we as a nation, choose to accept the least fair allocation of presidential electors on a winner-take-all basis ungrounded in State Law, Federal Law or the US Constitution over the obviously more fair proportional allocation of presidential electors based on Amend14§2, as enforced by 2U.S.C§? Why do we acquiescence in the inauguration of neo-redeemer politics by the election an affirmative action minority polled President that sustains the original intent of the Electoral College origins to preserve white supremacy over Democracy...


Defendants, the National Archives and Records Administration, the Office of the Federal Register, the Archivist of the United States, and the Director of the Office of the Federal Register, hereby move to dismiss Plaintiff Asa Gordon’s complaint in its entirety. As shown in the accompanying brief, Mr. Gordon, lacks standing, his claims are moot, and there is no legal basis for the mandamus relief that he seeks. ...

Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure, Plaintiff respectfully request an enlargement of time, to and including February 10, 2017, within which to respond to DEFENDANTS' MOTION TO DISMISS. Defendants' counsel was contacted on Jan. 17, 2017 and consent to the plaintiff's motion.

ORDERED that plaintiff may have his requested extension to oppose to the defendants' motion to dismiss. Plaintiff shall respond by February 10, 2017, or the Court will treat defendants' motion as conceded and may summarily dismiss the case.

SO ORDERED.


... Finally, as established at the outset of this response, the Defendants' Motion to Dismiss submitted at the Jan. 9th TRO hearing, confirmed Plaintiff's assertion that the Defendants have the authority to provide redress for injury arising from an unconstitutionally constituted Electoral College, QED.
In proceedings before the court to date, i.e. the January 9th, 2017 TRO hearing, the Defendants' Counsel have represented NARA officials presiding over the integrity of the Electoral College and the Presidential electoral process as impotent empires that can call constitutional strikes on electors but cannot call electors out , referees who can call constitutional fouls on offending electors but can exact no penalty.

Pursuant to Rule 15 of the Federal Rules of Civil Procedure, and Local Rule LcvR 7.1(i) Plaintiff respectfully moves this Court for leave to file the attached Amended Complaint, for the reasons set forth in the accompanying Memorandum of Law in Support, because it will clarify the dispute between the parties and will not cause any prejudice.

...Plaintiff's AMENDED COMPLAINT is supported by Defendants’ unwitting affirmation of Plaintiff's principle claim in their Motion to Dismiss... Thus Defendants affirm their authority and responsibility to ensure the constitutional integrity of presidential electors submitted by the states. This singular unwitting admission by Defendants constitutes a nugatory refutation of the entire set of arguments Defendants posit in their now fatally flawed Motion to Dismiss.


...Plaintiff seeks to move this Court to issue declaratory judgments and provide injunctive relief to ensure NARA faithfully discharges its responsibilities in regards to oversight of future presidential elections to certify the integrity of Article II Section 1 presidential electors and inclusive as amended by Section 2 Fourteenth Amendment presidential electors in order to effect an unbiased administration by NARA of all of the constitutional provisions governing presidential elections.
... There is facial evidence that Defendants are complicit in the illegitimate seating of at least 50 Trump Electors in the recent Electoral College in violation of U.S. Const. art. II, § 1. There is facial evidence that Defendants are complicit in at least 62 legitimate Clinton Electors not being seated in the recent Electoral College as alleged in the original complaint in violation of U.S. Const. amend. xiv, § 2.

  Defendants, the National Archives and Records Administration, the Archivist of the  United States, and the Director of the Federal Register, by undersigned counsel, respectfully move for a 7-day extension of time to file a reply in support of their motion to dismiss. ...
  There is good cause for the extension. On February 10, 2017, Plaintiff filed both an opposition to Defendants’ motion to dismiss and a motion to amend his complaint. Both papers raise similar issues including, in particular, Plaintiff’s standing to maintain this action. Under the different response times applicable to replies and oppositions, Defendants’ reply in support of their motion to dismiss is due on February 17, and their opposition to Plaintiff’s motion to amend is due on February 24. It would be more convenient for Defendants to address both Plaintiff’s papers at once given the similarity of issues. Defendants therefore request that the Court extend the deadline for them to file their reply to match the deadline for them to oppose Plaintiff’s motion to amend.

...Defendants now seek leave to further extend their time to file both papers by three weeks, to March 17, 2017.
Plaintiff Asa Gordon lacks the standing necessary to bring this lawsuit, just as he lacked the standing to bring substantially similar claims on two prior occasions. 1 His scattershot attempts to address those standing defects through various arguments and a proposed pleading amendment all fail, and he has not addressed other bases for dismissal put forward in Defendants’ motion to dismiss. Consequently, his motion for leave to amend his complaint should be denied and this action should be dismissed. ...
    This Case or Controversies arises out of the ministerial legal duties of the defendant National Archives and Records Administration’s (NARA) Office of the Federal Register (OFR) required by law to perform certain functions relating to the Electoral College. NARA acting pursuant to 3 U.S.C. 6, 11, 12, and 13, creates legal rights to "ensure" the constitutional integrity of   "Certificates of  Votes", including by its publication of  "Provisions of the Constitution and United States Code relating to Presidential Elections" an enforceable right to receive truthful information concerning the electoral process that automatically creates standing if these rights are violated.

“[t]he actual or threatened injury required by Art. III may exist solely by virtue of ‘statutes creating legal rights, the invasion of which creates standing….’ ” Warth v. Seldin, supra, at 500, 95 S.Ct., at 2205, quoting Linda R.S. v. Richard D., 410 U.S. 614, 617, n. 3, 93 S.Ct. 1146, 1148, n. 3, 35 L.Ed.2d 536 (1973).

    Furthermore, Defendants' have not contested  arguments rasied in Plaintiff's Memorandum in Support of Plaintiff's Motion for leave to File Amended Complaint .