NICHOLAS E. PURPURA and
THEODORE T. MORAN,
Petitioner-Appellants,
vs.
BARACK OBAMA,
Respondent-Appellee
SUPERIOR COURT OF NEW JERSEY
APPELLATE DIVISION
Appeal Docket No.: A-4478-11T3
CIVIL ACTION RECENED
On Appeal from a Final \PPELLATE e
Decision of the New Jersey WN 18 20
Secretary of State R
suPERIO!
SUE NeW
SAT BELOW:
Hon. JEF S. MASIN, ALJ o/b/o
NJ. SECRETARY OF STATE
PETITIONER-APPELLANTS’ BRIEF
AND APPENDIX
MARIO APUZZO, ESQ.
On the Brief
Mario Apuzzo, Esq.
185 Gatzmer Avenue
Jamesburg, New Jersey 08831
(732) 521-1900
Attorney for Petitioner-
AppellantsTABLE OF CONTENTS
PAGE
TABLE OF CITATIONS . eeeeeee iii
PROCEDURAL HISTORY ...-..+++-++++ =
STATEMENT OF FACTS.
SUMMARY OF ARGUMENT ......--..5++
LEGAL ARGUMENT. .
I. THE ADMINISTRATIVE LAW JUDGE (ALJ) AND
SECRETARY OF STATE (SOS) ERRED IN FINDING
THAT OBAMA, BECAUSE HE DOES NOT HAVE TO
CONSENT TO HIS NOMINATING PETITION, DOES NOT
HAVE ANY CONSTITUTIONAL AND STATUTORY
OBLIGATION TO PROVIDE ANY EVIDENCE TO THE
NEW JERSEY SECRETARY OF STATE
PROVING WHO HE IS, WHERE HE WAS BORN, AND
THAT HE IS CONSTITUTIONALLY ELIGIBLE TO OCCUPY
THE OFFICE OF PRESIDENT IN ORDER TO BE PLACED ON
THE NEW JERSEY PRIMARY ELECTION BALLOT 10
Il THE ALJ AND SOS ERRED IN FINDING THAT OBAMA
WAS BORN IN HAWAII AND THEREFORE AS A MATTER
OF LAW HE IS AN ARTICLE II “NATURAL BORN CITIZEN”
CONCLUSION 60
1T = Transcript of April 10, 2012 trial
APPENDIX
Objection to Petition of Nomination laInitial Decision of ALJ Ba
Final Decision of the N.J. Secretary of State 52a
Notice of Appeal 54a
Order on Emergent Application 56a
Letter dated July 29, 2010, from Rolbin to Strunk with
Attachment 58a
Computer printout—“Daylife” Ta
Pages of Obama’s High School Yearbook—“Oahuan 1979” 73a
Selective Service System Registration (not in evidence) 8la
Breitbart.com article, “The Vetting-Exclusive-Obama’s
Literary Agent in 1991 Booklet: “Born in Kenya and Raised in
Indonesia and Hawaii” (not in evidence or part of record) 82a