PLAINTIFF'S REPLY IN SUPPORT OF MOTION FOR LEAVE TO FILE AN AMENDED COMPLAINT AND IN OPPOSITION TO DEFENDANTS’ COMBINED OPPOSITION*

ASA GORDON, ) ) Plaintiff ) ) v. ) Case 1:16-cv-02458-RJL ) NATIONAL ARCHIVES AND ) RECORDS ADMINISTRATION, et al. ) ) Defendants ) _______________________________

"..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. _______________________________ * Case 1:16-cv-02458-RJL _ Document 17 ..."  Click here to view

Affidavit of Asa Gordon, Exe. Dir. DIG...

 Duly sworn, under oath, I Asa Gordon make the following statement:
 I am a co-founder and Executive Director of the Douglass Institute of
Government(DIG). I am a resident of the District of Columbia and a registered voter of
this jurisdiction.
 In mid November of 2000, associates of co-founder of DIG Lawrence Douglass Jamison,esq (dec.)
from across the country, and in particular from the States of Georgia and Florida, made inquiries of
DIG as to what redress or penalties were available to citizens with respect to disenfranchisement in
Florida's 2000 Presidential elections under the Constitution of the United States. Particular inquiries
were made of DIG when it was reported in the media that the Florida legislature had threatened to
select the Florida presidential electors without regard for state or federal court guidelines. In
consultation with Jamison we made several inquiries of local officials, professors of law, civil rights
organizations and attorneys as to what course may be undertaken to lodge a grievance for infringement
on the constitutional right of suffrage and what related information may be readily available to the
public. From these inquiries we were led to reference Government web pages on the Presidential
election process maintained by the National Archives and Records Administrations' (NARA) Office of
the Federal Register (OFR). We passed this information on to those who had made inquiries of DIG
without review at that time.
By late December of 2000, after a later review, I became aware that the OFR had posted at their web
site on the electoral college an Internet reference link to a particular document, Relevant Provisions of
the U.S. Constitution and Federal Law: under the heading General Information. This Internet reference
seriously misinforms the general public of their electoral rights. At this same web site, under the
heading State Resources, the OFR provided a link to Letter from the Archivist to Governors. I became
aware that the flawed document at the agency web site is published in pamphlet form "for use by the
Executives and Electors of the several States in the performance of their duties in connection with
Presidential Electors." See Amended Complaint at ¶8. Before I had made these discoveries I
mistakenly used the OFR internet links to pass their flawed document on to my associates in November
of 2000.
As a consequence of my lectures over the last decade and a half on behalf of DIG and as Secretary
General of the United States Colored Troops chartered by the African American Civil War Museum
Freedom foundation on the post Civil War Reconstruction Era in U.S. history, I became cognizant of
the fact that the OFR had committed a serious error in judgment in the publication of their pamphlet
entitled "Provisions of the Constitution and United States Code relating to Presidential Elections" by
their exclusion of the second section of the fourteenth amendment. To my dismay, I later learned that
local officials, professors of law, civil rights organizations, Internet web sites on electoral rights, law
libraries, Government documents libraries, and attorneys practicing Civil Rights law are profoundly
influenced by this inaccurate OFR source. This misinformation was, in fact, a major cause for the
ignorance and disbelief that many local officials, professors of law, civil rights organizations and
attorneys displayed in response to my personal herculean efforts to bring general public and
professional awareness to this missing provision of the Fourteenth Amendment to the U.S.
Constitution.
 At the Federal Register Main Page ( http://www.archives.gov/federal_register/) the OFR proclaimed
"OFR plays an important role in: The Electoral College",
(http://www.archives.gov/federal_register/electoral_college/electoral_college.html). The OFR also
declared:
"Our Mission
The Office of the Federal Register (OFR) informs citizens of their rights and obligations by
providing ready access to the official text of Federal laws, Presidential documents,
administrative regulations and notices, and descriptions of Federal organizations, programs
and activities."
 At the Electoral College Link), the OFR declared:
"U. S. Electoral College
The Office of the Federal Register coordinates the functions of the Electoral College on
behalf of the Archivist of the United States, the States, the Congress, and the American
People. ..."
In fulfillment of their declared mission, the OFR has produced "Provisions of the Constitution
and United States Code relating to Presidential Elections" as General Information within the zone of
interest of all citizens. This document is posted on the Internet by the OFR and is broadly linked to and
reproduced at numerous public Internet sites. This document has also been reproduced in pamphlet
form for public dissemination by the Superintendent of Documents as Gov. Doc. No. AE 2.102:P
92/2000 for acquisition by public and academic libraries pursuant to the Federal Register Act
44U.S.C.15. & 1CFR2. Thus actual injury to a broadly misinformed citizenry has been realized and
threatens to be perpetuated unabated.
I have informed NARA and the DC Secretary of State of the error in OFRs' judgment to exclude
from the pamphlet "Provisions of the Constitution and United States Code relating to Presidential
Elections" that portion of the Constitution that pertains more directly to voting rights of individuals and
the penalty for disregarding those rights".
 NARA belittles my effort as a member of that class of misinformed and targeted citizens who
has chosen to exercise his obligation to safeguard his rights once realized. Acting under the purview of
the Federal Register Act 44U.S.C.15;1CFR2, NARA has exacted actual injury upon me directly by
asserting they have no obligation to correct any wrongful editorial judgment identified by me in
fulfillment of their stated mission to inform me of my electoral rights, nor or they obligated to correct
any wrongful editorial judgment that threatens injury to my electoral rights by misinformed officials
who rely on NARA for guidance in protecting my electoral rights. Thus the injury I have suffered is
both actual and threatened by the only agency that has the statutory authority and responsibility to
correct this case or controversy.

I affix my signature hereto.
______________________________________
Asa Gordon, PRO SE
Executive Director and Founder
Douglass Institute of Government
digasa@aol.com