Phil J. Berg filed an amended complaint today in Berg v. Obama. The amended complaint adds the Pennsylvania Department of State, the Secretary of the Commonwealth Pedro A. Cortes (in his official capacity), the U. S. Sentate Committee on Rules and Administration, and Senator Diane Feinstein (in her official capacity as chairman) for their failure to exercise due diligence with respect to Barack Obama's contitutional qualifications to be elected and serve as President of The United States, and for his inclusion on the ballot in Pennsylvania as a candidate for President of the United States.

The amended complaint also bolsters the standing argument and adds additional relevent facts.

Essentially, the argument is this:

Senator Obama could put this whole issue to rest by providing an official "vault copy" birth certificate.
Senator Obama has chosen not to do so.
The defendants (other than Obama) have a responsibility to protect the integrity of the electoral system by properly vetting the qualifications of candidates, which they have failed to perform.
Mr. Berg, other Americans, and our system of government are damaged by this failure.
Senator Obama, who has collected $425,000,000 in campaign contributions, has perpetrated a fraud.
Following are some of the factual statements made in the amended complaint (The complete complaint is attached below):

36. Obama is a representative of the Democratic People. However, Obama must meet the Qualifications specified for the United States Office of the President, which he must be a “natural born” citizen. Additionally, Obama must be at least a “naturalized” citizen to hold his Office of U.S. Senator for Illinois. Unfortunately, Obama is not a “natural born” citizen, nor is he a “naturalized” citizen. Just to name one of the problems, Obama lost his U.S. citizenship when his mother married an Indonesian citizen, Lolo Soetoro who legally “acknowledged” Obama as his son in Indonesia and/or “adopted” Obama, which caused Obama to become a “natural” Indonesian citizen. Stanley Ann Dunham Soetoro relocated herself and Obama to Indonesia wherein Obama’s mother naturalized in Indonesia. This is proven by Obama’s school record with the student’s name as “Barry Soetoro”, Father’s name: Lolo Soetoro, M.A., and Citizenship: Indonesia.

37. There appears to be no question that Defendant Obama’s mother, Stanley Ann Dunham, was a U.S. citizen. It is also undisputed, however, that his father, Barack Obama, Sr., was a citizen of Kenya. Obama’s parents, according to divorce records, were married on or about February 2, 1961.

38. Defendant Obama claims he was born in Honolulu, Hawaii on August 4, 1961 and it is uncertain in which hospital he claims to have been born. Obama’s grandmother on his father’s side, his half-brother and half-sister all claim Obama was born not in Hawaii but in Kenya. Reports reflect that Obama’s mother traveled to Kenya during her pregnancy; however, she was prevented from boarding a flight from Kenya to Hawaii at her late stage of pregnancy (which, apparently, was a normal restriction, to avoid births during a flight). By these reports, Stanley Ann Dunham Obama gave birth to Obama in Kenya, after which she flew home and registered Obama’s birth. There are records of a “registry of birth” for Obama, on or about August 8, 1961 in the public records office in Hawaii.

39. Upon investigation into the alleged birth of Obama in Honolulu, Hawaii, Obama’s birth is reported as occurring at two (2) separate hospitals, Kapiolani Hospital and Queens Hospital. The Rainbow Edition News Letter, November 2004 Edition, published by the Education Laboratory School did a several page article of an interview with Obama and his half-sister, Maya. The Rainbow Edition News Letter reports Obama was born August 4, 1961 at Queens Medical Center in Honolulu, Hawaii. More interesting in February 2008, Obama’s half-sister, Maya, was again interviewed in the Star Bulletin, and this time, Maya states Obama was born August 4, 1961 in Kapi’olani Medical Center for Women & Children.
40. Plaintiff is informed, believes and thereon alleges a research team went to Mombassa, Kenya, and located a Certificate Registering the birth of Barack Obama, Jr. to his father, a Kenyan citizen and his mother, a U.S. citizen.

41. Even if Obama was, in fact, born in Hawaii, he lost his U.S. citizenship when his mother re-married and moved to Indonesia with her Indonesian husband. In or about 1965, when Obama was approximately four (4) years old, his mother, Stanley Ann Dunham, married Lolo Soetoro, a citizen of Indonesia, whom she had met at the Hawaii University, and moved to Indonesia with Obama. Obama lost his U.S. citizenship, when his mother married Lolo Soetoro, and took up citizenship of and residency in Indonesia. Loss of citizenship, in these circumstances, under U.S. law (as in effect in 1965) required that foreign citizenship be achieved through “application.” Such type of naturalization occurred, for example, when a person acquired a foreign nationality by marriage to a national of that country. Nationality Act of 1940, Section 317(b). A minor child follows the naturalization and citizenship status of their custodial parent. A further issue is presented that Obama’s Indonesian stepfather, Lolo Soetoro, either signed an acknowledgement acknowledging Obama as his son or Lolo Soetoro adopted Obama, giving Obama natural Indonesia citizenship which explains the name Barry Soetoro and his citizenship listed as Indonesian.

42. Obama admits in his book, “Dreams from my father” Obama’s memoir (autobiography), that after his mother and Lolo Soetoro were married, Lolo Soetoro left Hawaii rather suddenly and Obama and his mother spent months in preparation for their move to Indonesia. Obama admits when he arrived in Indonesia he had already been enrolled in an Indonesia school and his relatives were waiting to meet him and his mother. Lolo Soetoro, an Indonesian State citizen, could not have enrolled Obama in school unless Lolo Soetoro signed an acknowledgement acknowledging Obama as his son, which had to be filed with the Government. Under Indonesian law, when a male acknowledges a child as his son, it deems the son, in this case Obama, as an Indonesian State citizen. Constitution of Republic of Indonesia, Law No. 62 of 1958 Law No. 12 of 2006 dated 1 Aug. 2006 concerning Citizenship of Republic of Indonesia, Law No. 9 of 1992 dated 31 Mar. 1992 concerning Immigration Affairs and Indonesian Civil Code (Kitab Undang-undang Hukum Perdata) (KUHPer) (Burgerlijk Wetboek voor Indonesie) states in pertinent part, State citizens of Indonesia include: (viii) children who are born outside of legal marriage from foreign State citizen mother who are acknowledged by father who is Indonesian State citizen as his children and that acknowledgment is made prior to children reaching 18 years of age or prior to marriage; Republic of Indonesia Constitution 1945, As amended by the First Amendment of 1999, the Second Amendment of 2000, the Third Amendment of 2001 and the Fourth Amendment of 2002, Chapter X, Citizens and Residents, Article 26 states, “(1) Citizens shall consist of indigenous Indonesian peoples and persons of foreign origin who have been legalized [sic] as citizens in accordance with law. (2) Residents shall consist of Indonesian citizens and foreign nationals living in Indonesia.”

43. Furthermore, under the Indonesian adoption law, once adopted by an Indonesian citizen, the adoption severs the child’s relationship to the birth parents, and the adopted child is given the same status as a natural child, Indonesian Constitution, Article 2. Thus, where Obama was actually born and what his mother’s citizenship status at the time of this birth is irrelevant.

44. The laws in Indonesia at the time of Obama’s arrival did not allow dual citizenship. If an Indonesian citizen married a foreigner, as in this case, Obama’s mother was required to renounce her U.S. citizenship and was sponsored by her Indonesian spouse. During this time, Indonesia was a Police State. The public schools did not allow foreign students, only citizens were allowed to attend as Indonesia was under strict rule and decreed a number of restrictions; therefore, in order for Obama to have attended school in Jakarta, which he did, he had to be a citizen of Indonesia, as the citizenship status of enrolled students was verified with Government records.

45. Obama was enrolled by his parents in a public school, Fransiskus Assisi School, a public school, in Jakarta, Indonesia. Plaintiff has received copies of the school registration in which it clearly states Obama’s name as “Barry Soetoro,” and lists his citizenship as Indonesian. Obama’s father is listed as Lolo Soetoro, Obama’s date of birth and place of birth are listed as August 4, 1961 in Hawaii, and Obama’s Religion is listed as Islam. This document was verified by Inside Edition, whose reporter, Matt Meagher, took the actual footage of the school record. At the time Obama was registered the public schools obtained and verified the citizenship status and name of the student through the Indonesian Government. All Indonesian students were required to carry government identity cards, or Karty Tanda Pendudaks, as well as family card identification called a Kartu Keluarga. The Kartu Keluarga is a family card which bears the legal names and citizenship status of all family members.

46. Since Obama’s birth was legally acknowledged by Lolo Soetoro, an Indonesian citizen, and/or Obama was adopted by Lolo Soetoro, which the evidence supports, Obama became an Indonesian citizen and bears the status as an Indonesia natural child (natural-born). For this reason, Obama would have been required to file applications with the U. S. State Department and follow the legal procedures to become a naturalized citizen in the United States, when he returned from Indonesia. If Obama and/or his family failed to follow these procedures, then Obama is an illegal alien.

47. Regardless of whether Obama was officially adopted, (which required a Court process), by his Indonesian stepfather, Lolo Soetoro, or his birth was acknowledged (which only required the signing of a governmental birth acknowledgement form), by Lolo Soetoro, one of which had to occur in order for Obama to have the name Barry Soetoro and his citizenship status listed as “Indonesian”, in either and/or both cases Obama’s name was required to be changed to the Indonesian father’s name, and Obama became a natural citizen of Indonesia. This is proven by the school records in Jakarta, Indonesia showing Obama’s name as Barry Soetoro and his citizenship as Indonesian. Again, the registration of a child in the public schools in Jakarta, Indonesia was verified with the Government Records on file with the Governmental Agencies.

48. The Indonesian citizenship law was designed to prevent apatride (stateless) or bipatride (dual citizenship). Indonesian regulations recognize neither apatride nor bipatride citizenship.

49. In addition, since Indonesia did not allow dual citizenship neither did the United States, Hague Convention of 1930.

50. In or about 1971, Obama’s mother sent Obama back to Hawaii. Obama was ten (10) years of age upon his return to Hawaii.

51. As a result of Obama’s Indonesia “natural” citizenship status, there is absolutely no way Obama could have ever regained U.S. “natural born” status, if he in fact ever held such. Obama could have only become naturalized if the proper paperwork was filed with the U.S. State Department, in which case, Obama would have received a Certification of Citizenship.

52. Plaintiff is informed, believes and thereon alleges Obama was never naturalized in the United States after his return. Obama was ten (10) years old when he returned to Hawaii to live with his grandparents. Obama’s mother did not return with him, and therefore, unable to apply for citizenship of Obama in the United States. If citizenship of Obama had ever been applied for, Obama would have a Certification of Citizenship.

53. Furthermore, Obama traveled to Indonesia, Pakistan and Southern India in 1981. The relations between Pakistan and India were extremely tense and Pakistan was in turmoil and under martial law. The country was filled with Afghan refugees; and Pakistan's Islamist-leaning Interservices Intelligence Agency (ISI) had begun to provide arms to the Afghan mujahideen and to assist the process of recruiting radicalized Muslim men--jihadists--from around the world to fight against the Soviet Union. Pakistan was so dangerous that it was on the State Department's travel ban list for US Citizens. Non-Muslim visitors were not welcome unless sponsored by their embassy for official business. A Muslim citizen of Indonesia traveling on an Indonesian passport would have success entering Indonesia, Pakistan and India. Therefore, it is believed Obama traveled on his Indonesian passport entering the Countries. Indonesian passports require renewal every five (5) years. At the time of Obama’s travels to Indonesia, Pakistan and India, Obama was twenty (20) years old. If Obama would have been a U.S. citizen, which he was not, 8 USC §1481(a)(2) provides loss of nationality by native born citizens upon "taking an oath or making an affirmation or other formal declaration of allegiance to a foreign state...after having attained the age of eighteen years”, in violation of 8 U.S.C. §1401(a)(1). Since Lolo Soetoro legally acknowledged Obama as his son and/or adopted Obama, Obama was a “natural” citizen of Indonesia, as proven by Obama’s school record.

54. Plaintiff is informed, believes and thereon alleges Obama stated his citizenship as a “Kenya Citizen” when he applied for and was accepted at Columbia University. Obama has refused to release any records from Occidental College, Columbia University, Harvard Law School and any of his medical records.

55. Plaintiffs as well as many other democratic American citizens have requested proof of Obama’s citizenship status, however to no avail. Obama has promised to be an open and honest candidate, however, refuses to remove any doubts from Plaintiff’s and all the other democratic minds and prove his eligibility to serve as President of the United States.

56. Plaintiff’s civil rights under the due process rights and equal protection of the laws secured by the U.S. Constitution, Fourteenth (14 ) Amendment th have been violated by Obama’s illegal campaign and will continue to be violated if Obama is allowed to continue his campaign and if elected, assume the position of President of the United States. The DNC and FEC have allowed Obama to continue his campaigning, knowing these issues have arisen and have failed to take and/or instigate the proper investigation into said matters to protect Plaintiff and other registered voters. Therefore, the only option Plaintiff had to secure and protect his civil rights was to bring action before this Honorable Court. Moreover, our laws which protect Plaintiff, a legal registered voter, and other registered voters from fraudulent campaign schemes have been violated by the Defendants, 2 U.S.C. §437c, 2 U.S.C §437(g). Plaintiff has standing to bring suit pursuant to 5 U.S. C §702, as well as 8 U.S. C §1481(b).

57. Plaintiff’s rights guaranteed under the Liberty clause of the Fourteenth (14th) Amendment of the United States Constitution have already been violated. It has been announced in the main stream media that Obama’s “briefing” has already begun into our National Secrets, our Nations Top Secrets, which Obama is not privy too and in violation of our National Security, as Obama is not a legal citizen of the United States. This has placed Plaintiff and other citizens of the United States in grave danger. Plaintiff’s Liberty as guaranteed will further be violated if Obama is allowed to be voted into and assume the position of President of the United States; Plaintiff will be further damaged and is in serious jeopardy.

58. Plaintiff filed the within action on or about August 21, 2008 against Defendants seeking Declaratory and Injunctive Relief, declaring Obama an illegal alien and/or only a “naturalized” citizen ineligible to serve as President of the United States and enjoining the PA Department of State, Bureau of Commissions, Elections and Legislation, the DNC and FEC from placing Obama’s name on the ballot and prohibiting Obama from further campaigning to be elected as President of the United States, a position he is ineligible to hold.

59. Plaintiff faxed a copy of the original complaint to Obama, the DNC and FEC on August 22, 2008 prior to the hearing on the TRO before this Honorable Court. Defendants were further served by personal service on September 4, 2008. Neither the DNC nor Obama have supplied any type of proof of Obama’s citizenship status and/or eligibility to serve as President of the United States.

60. Plaintiff has asked for a simple resolution. Plaintiff has asked that Obama supply a genuine certified copy of his original long version “vault” Birth Certificate, A Certification of Citizenship and a certified copy of his Oath of Allegiance. If in fact Obama can prove his “natural born” citizenship status, which he cannot, then he has not been prejudiced in anyway, but instead Plaintiff has been protected and his civil rights secured. However, if Obama is unable to supply said documentation, then he needs to withdraw his candidacy, again which will eliminate Plaintiff’s deprivations and instill Plaintiff’s constitutionally protected safeguards and rights.