North and South America export nearly 30 million barrels per day of crude oil and refined oil products and exports are growing exponentially. particularly in US and Gayana. The world does not really need the Persian Gulf, which exports only 20 mln barrels. Maybe, we should concentrate on increasing the oil exports in our hemisphere instead of sending hundreds of billions of dollars to Iran, which chants death to America. Just a thought.

Posted on | June 19, 2026 | No Comments

North and South America export nearly 30 million barrels per day of crude oil and refined oil products and exports are growing exponentially. particularly in US and Gayana. The world does not really need the Persian Gulf, which exports only 20 mln barrels. Maybe, we should concentrate on increasing the oil exports in our hemisphere instead of sending hundreds of billions of dollars to Iran, which chants death to America. Just a thought. See oil exports by country in Americas

Total crude oil + refined petroleum products exports from North and South America (approximate recent averages, primarily 2025–mid-2026 data, in thousand barrels per day or mb/d).

North America (major total ~18–22+ mb/d combined)
United States: ~11–12 mb/d total (crude ~4 mb/d + products/HGL ~7–8 mb/d). The world’s top petroleum exporter.eia.gov
Canada: ~4–5+ mb/d total (mostly crude ~3.5–4 mb/d heavy/synthetic; products ~1+ mb/d). Exports mainly to the US.www150.statcan.gc.ca
Mexico: ~1.5–2.5 mb/d total (crude ~0.3–1.3 mb/d declining; products vary). Net exporter of crude but importer of products.banxico.org.mx
South / Latin America (major total ~5–7+ mb/d crude + products)
Brazil: ~2.5–3.5+ mb/d total (crude ~2–2.5+ mb/d; growing products). Strong pre-salt growth.reuters.com
Guyana: ~0.7–1.0+ mb/d (almost all crude; rapid expansion, nearly 100% exported).reuters.com
Venezuela: ~0.7–1.3 mb/d (crude dominant; recovering with recent highs).oilprice.com
Colombia: ~0.6–0.8 mb/d (mostly crude).
Argentina: ~0.6–0.9 mb/d (crude growth from Vaca Muerta; some products).
Ecuador: ~0.4–0.5 mb/d (mostly crude).
Others (Trinidad & Tobago, Peru, Suriname, etc.): Smaller, often <0.2 mb/d each.

Regional Summary:

North America: ~18–22 mb/d total petroleum (US dominates).

Latin/South America: ~5–7+ mb/d (crude-heavy; Brazil + Guyana driving growth).
Americas Combined: ~23–29+ mb/d total exports (strong net exporter region).eia.gov

Supplemental brief in favor of the citizenship question in the census

Posted on | June 18, 2026 | No Comments

DOFF v Lutnick motion for leave to file supplemental brief filed

ORLY TAITZ, ESQ

CBN 223433

LAW OFFICES OF ORLY TAITZ

29839 SANTA MARGARITA, STE 100

RANCHO SANTA MARGARITA, CA 92688

US DISTRICT

CENTRAL DISTRICT OF CALIFORNIA

NOTICE OF MOTION AND MOTION FOR A LEAVE OF COURT TO FILE A SUPPLEMENTAL BRIEF

Please take notice that on July 20, 2028 at 1:30 pm., or as soon thereafter as they may be heard, Defend Our Freedoms Foundation (“DOFF”), plaintiff herein, will bring for hearing this Motion to File a Supplemental brief. This motion will be heard before the Honorable Stephen V. Wilson, United States District Court, Courtroom 10A, located at First Street Federal Building Courthouse, 350 W. 1^st. Street, Los Angeles, CA 90012.

The plaintiff moves based on the grounds that additional events make plaintiff’s standing and probability of success on the merits more likely.

The motion is made following the conference of counsel pursuant to Local Rule 7-3 which was held on June 9, 2026.

June 18, 2026

Respectfully submitted,

/s/ Orly Taitz,

Attorney for Plaintiff

Defend Our Freedoms Foundation

NOTICE OF MOTION AND MOTION TO MOTION FOR A LEAVE OF COURT TO FILE A SUPPLEMENTAL BRIEF

Current motion is filed under FRCP 15(d) and the court’s inherent authority.

Additional recent events, authorities and precedent opinions have strengthened the standing and likelihood of success of the plaintiff in the case herein.

SUMMARY OF EVENTS

The case at hand revolves around the fact that the plaintiff herein, Defend Our Freedoms Foundation argues that the citizenship question, which was a part of the US Census for most of the US history and was removed by president Obama should be re-inserted in the census and seeks the Secretary of Commerce, in charge of the Census to re-insert the citizenship question.  The plaintiff argues that the Census act of 1790 and the subsequent 14^th Amendment were intended to count only the US Citizens and as such, a citizenship question is in the census is not discretionary, but MANDATORY, as you cannot count citizens if you do not have a citizenship question in the census.  The defense filed a Motion to Dismiss and argued that such question is discretionary and the court does not have jurisdiction to rule on the matter. Plaintiff filed an opposition to motion to dismiss arguing that even if the court were to find that such act is discretionary, such discretion is not absolute and the plaintiff provided multiple precedents showing that when the constitutional rights of plaintiffs were effected, the court could order the federal agency to act even where such acts are discretionary. Plaintiff argued that this is such a case, where not having a citizenship question and allowing some estimated 36 million illegal aliens and 14 million legal non-citizens residing in mostly Blue sanctuary and gateway states to be included in the census, affected equal protection rights under the 5^th and 14^th Amendments for political representation and equal federal funding for members of Defend Our Freedoms Foundation residing in Red states. This gives the Plaintiff the standing and gives the court the jurisdiction to direct the defendant to act. The motion hearing was conducted on May 18, 2026 and the matter is under submission.

Two weeks after the hearing the state of California conducted its’ midterm primary elections. Multiple questions relating to election integrity were raised.

On June 7, 2026 First Assistant US Attorney for the Central District of California posted the following:

“F.A. United States Attorney Bill Essayli

@USAttyEssayli

California Is Blocking a Federal Audit of Its Voter Rolls

California allows first-time voters to register using forms of ID that most Americans would find surprising, including:

-Gym membership card

-Employer ID card

-Credit or debit card

-Prescription drug label

-Insurance card (California provides free health coverage to undocumented immigrants)

Full list: https://sos.ca.gov/elections/hava-id-standards

This is permitted when a voter fails to provide a Social Security number or driver’s license at registration. Our office believes this policy deserves a closer look.

We also have serious concerns about how California maintains its voter rolls. There are open questions about whether the state is promptly removing deceased voters, people who have moved, and individuals convicted of disqualifying felonies.

On top of that, California allows third parties to collect and turn in ballots on voters’ behalf (a practice known as ballot harvesting) with few restrictions. This makes it difficult to track who actually received, completed, and submitted each ballot.

For over a year, the Department of Justice has been trying to audit California’s voter rolls. Federal law gives the Attorney General the authority to review state voter files and confirm that only eligible U.S. citizens are voting in federal elections.

@AAGDhillon  sent California a letter explaining our legal authority. California refused to comply, claiming state privacy laws block the review, an argument that does not hold up because those laws don’t apply to the federal government in this context. We’ve sued California in federal court, and the case is before the Ninth Circuit Court of Appeals.

If California genuinely wants voters to trust its elections, it should open its records, not fight to keep them closed.

What are they afraid of?” Posted on: Sunday, June 7, 2026, at 4:47 PM GMT (16:47 UTC).Platform: X (Twitter)

Account: @USAttyEssayli

(F.A. United States Attorney Bill Essayli, First Assistant U.S. Attorney for the Central District of California)This is the original post (Post ID: 2063664190473351169). There were 3.9 million views of the post.

Additionally, there were a number of court rulings that strengthen the plaintiff’s position.

ARGUMENT

Additional facts  make re-insertion of the citizenship question in the census essential, as it becomes the only method of verifying integrity of the elections and the only vehicle of protection of free and fair elections and protection of the Equal Protection rights of members of the Defend Our Freedoms Foundation not only ones that reside in Red States, but also ones that reside in Blue states such as California.

Aforementioned statement was made by Bill Essayli, the First Assistant US Attorney for the Central District of California, who is a de-facto US Attorney, as his confirmation as the US Attorney is being intentionally stalled by California Senators via Blue Slip practice in the Judiciary Committee.

Mr. Essayli stated that the state of California refuses to provide unredacted voter rolls and refuses to cooperate with audits by the Department of Justice. At the same time the State of California allows the following “documents” to register to vote:

“-Gym membership card

-Employer ID card

-Credit or debit card

-Prescription drug label

-Insurance card (California provides free health coverage to undocumented immigrants)”

None of the above “documents” provide any proof of the US citizenship and a right to vote in Federal Elections. This brings the state of California to a level of a banana republic or more accurately an embarrassment to banana republics.

As such, re-insertion of the citizenship question in the US census becomes the only vehicle of auditing the voter rolls, of assuring the free and fair elections and assuring the Equal Protection rights under the 5^th and 14^th Amendments of the members of the Defend Our Freedoms Foundation residing in the state of California and other Blue states that similarly refuse to comply with the audits by the Department of Justice. This is an additional argument for standing on top of the original argument in prior pleadings. The plaintiff herein is the Defend Our Freedoms foundation, which is dedicated to preservation of the constitutional rights. Members and supporters of the DOFF, particularly ones residing in the non-sanctuary, non-gateway Red states, see their voting rights, congressional representation and federal funding being diluted and taken away when illegal aliens and other non-citizens are included in the US Census. Even though those non-citizens are not allowed to vote, they are included in the count and a large number of districts were created in Blue, sanctuary and gateway states. As such, those states and citizens of those states receive proportionally higher congressional representation and larger per-capita federal funding. The citizens of Red states end up with diminution and dilution of their congressional representation and federal funding. Their actual rights of congressional representation and funding are affected, which creates standing.

SUPREME COURT DECISIONS ISSUED AFTER THE BRIEFING IN THIS CASE, SUPPORT THE POSITION OF THE PLAINTIFF

On May 4, 2026, after the Opposition to Motion to Dismiss in this case was already filed, the Supreme Court  of the United States issued an opinion in Callais v Landry, 732 F. Supp. 3d 574 (W.D. La2024). Supreme Court ordered the Secretary of State of Louisiana to redraw the district maps, as the existing maps were infringing upon the Equal Protection rights of the plaintiffs.

On June 2^nd, in the aftermath of Callais id, and in compliance with Callais id, the Supreme Court ruled in WES ALLEN, ALABAMA SECRETARY OF STATE, Et Al. V. EVAN MILLIGAN, et al. On Application for Stay No. 25A1314, allowing the State of Alabama to go back to 2023 districting map.

These cases support the Plaintiff’s position that the violation of the Equal Protection rights of the members of the Defend Our Freedoms Foundation provide sufficient standing and provide the jurisdiction to grant the requested relief. The standing in Callais was based and supported by a precedent United States v Hays, 515 U.S 737 (1995), Shaw v Reno, 509 U.S. 630 (1993); Miller v Johnson, 515 U.S. 900 (1995), North Carolina v Covington, 138 S. Ct. 2548 (2018)

Moreover, there are multiple precedents showing that organizations, legal advocacy groups and foundations have a legal standing in bring challenges on behalf of their members. Hunt v Washington State Apple Advertising Commission, 432 U.S. 333 (1977).An Organization has associational standing to sue on behalf of its members when:

1. Its members would otherwise have standing to sue in their own right (i.e., they suffer a concrete, particularized injury);
2. The interests the organizations seeks to protect, are germane to the organization’s purpose; and
3. Neither the claim asserted nor the relief requested requires the participation of individual members in the lawsuit.

This test is routinely applied in equal Protection cases.

Here, the plaintiff, Defend Our Freedoms Foundation (DOFF) was created to uphold the constitutional freedoms of the US citizens. The members of the DOFF have standing, as their Equal Protection Rights and Due Process rights under the 5^th and 14^th Amendment were affected. As explained supra, DOFF members residing in Red states are losing proportional congressional representation and federal funding due to the fact that illegal aliens and other non-citizens are counted together with the US citizens in the census.

SUPREME COURT FOUND STANDING AND JURISDICTION IN IDENTICAL CASES

In its’ motion to dismiss Defense claimed that this court does not have jurisdiction and the defendant has no standing. However, in  Department of Commerce v New York (588 US 752 (2019) and California v Ross / California v US Department of Commerce, 351 F. Supp. 3d 1265, New York and California argued on behalf of non-citizens and argued that reinstatement of the citizenship question would cause a differential undercount of non-citizens, immigrants, and Hispanic households, directly harming their political representation and billions in federal funding. The Supreme Court has found Article III jurisdiction and standing for those non-citizens, but found that the reasoning provided by the Secretary of Commerce to re-insert the citizenship question, namely violation of Civil Rights Act was a pretext and the question can be added at a later time under a different reasoning. So, here the plaintiff, Defend Our Freedoms Foundation is providing the same argument. It is arguing on behalf of the citizens of Red states, whose congressional representation and federal funding has been severely diminished by the lack of the citizenship question and inclusion of illegals and other non-citizens in the US Census count.   The plaintiff provides the reasoning for this action, namely that the Equal protection rights under the 5^th an 14^th Amendment, as well as the Due Process rights under the 5^th and 14^th Amendments were violated.

Lastly, only a few days ago a ruling was made in National Parks Conservation Association et al. v. Department of the Interior et al 1:26-cv-10877-AK. In that case US District Court judge Angel Kelley ordered the Department of Interior to reinsert certain exhibits that were removed earlier. The dispute stems from a March 2025 executive order signed by President Donald Trump directing federal agencies to eliminate what the administration described as “false revision of history” in parks, monuments, and memorials. The White House pointed out that the exhibits portrayed the United States as “inherently racist, sexist, oppressive, or otherwise irredeemably flawed” and ordered a review of educational materials displayed at federal sites. Based on the presidential executive order, the Secretary of Interior, Doug Burgum, ordered removal of certain exhibits from the National parks. The Conservation society and the Historic society sued and on June 12, 2026 Judge Kelley ordered to reinsert those exhibits within 21 days, by the 4^th of July holiday. It appears Judge Kelley, Biden appointee, disagreed politically with the action, as she called the action “dangerous sanitizing”. Drawing a parallel to the case at hand, the plaintiff herein is seeking reinsertion in the US census of the citizenship question, which was removed by the President Obama. The plaintiff herein argues that insertion of the citizenship question is mandatory, as the intent of the frames of the Census act of 1790 and subsequent 14^th amendment was to count the US citizens. The defense argued that the action is discretionary and the court has no Article 3 jurisdiction to order the Secretary of Commerce in charge of the census to reinsert the question. The precedent   above National Parks Conservation Association et al. v. Department of the Interior et al 1:26-cv-10877-AK shows that indeed where the action is discretionary, the court indeed has Article 3 jurisdiction to re-insert a question, just as the District Court in MA ordered to re-insert exhibits in National parks. While this precedent is not binding, being from a different district, it is persuasive never the less. Moreover, the plaintiffs herein have a stronger standing, as members of Defend Our Freedoms Foundation are alleging violation of their equal protection 5^th and 14^th amendment rights where counting of non-citizens in the census deprives them of equal political and voting rights and equal rights of receipt of federal benefits. In National Parks Conservation Association v Department of Interior id, the plaintiffs were just a Conservation society and Historical society with no loss of any particularized constitutional rights. Further, time is of the essence in this case, as corrected census data is necessary for the upcoming elections.

CONCLUSION

The court should allow this supplemental brief to be included with the pleadings and existing briefing in the case at hand.

Dated this June18, 2028

/s/ Orly Taitz____________

Dr. Orly Taitz, ESQ

Attorney for the Plaintiff Defend Our Freedoms Foundation

29839 Santa Margarita, ste. 100

RSM, CA 92688

Ph. 949 683 5411 fax 949 766 7603DOFF v Lutnick motion for leave to file supplemental brief filed

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