(Filed March 2nd, 2000)

Alan R. Adaschik
and CIVIL ACTION NO. 00-6307
Registered Voters of the United States AS AMENDED
Of America, as a class.
(Plaintiffs) CIV-JORDAN
MAGISTRTE BANDSTRA

versus

William Jefferson Clinton,
President of the United States
and
The United States Congress
(Defendants)

UNCONSTITUTIONAL GOVERNMENTAL ACTION COMPLAINT

I, Alan R. Adaschik, who resides at 11484 SW 10 Court, Davie, Broward County, Florida 33325-4099, and the Citizens of the United States of America as a class, plaintiffs in the above styled cause, sues defendants; William Jefferson Clinton, President of the United States and the United States Congress.

Addresses of defendants:

JURISDICTION

The jurisdiction of this civil action is conferred by Article III, Section 1, of the Constitution which establishes that the judicial Power of the U.S. shall be vested in one Supreme Court and in such inferior Courts as established by Congress. The U.S. District Court for the Southern District of Florida is an inferior court established by Congress. Article III, Section 2, of the Constitution establishes the judicial power of the Courts shall extend to all Cases , in Law and Equity, arising under the Constitution, including Laws of the United States and Treaties made. The Supreme Court has declined to address the issue of the constitutionality of GATT and our participation in the WTO as members under its authority of "Original Jurisdiction". An official of the Supreme Court has instructed the Plaintiffs that the proper course of action is to file a complaint in a District Court. The Attorney Pro Se of the Plaintiffs resides in geographical area of the U.S. District Court of the Southern District of Florida. This legal action has been filed in said District Court

CLASS ACTION

In accordance with rule 23, (a)(b), Fed.R.Civ.P. the following is true:

a. The member of this class number in the millions.

b. It is self-evident that the questions of law raised in this action are common to the class.

c. It is self-evident that the claims of the representative party to this class is typical of the claims of the class.

d. The representative party of this class will fairly and adequately protect the interests of the class for the following reasons.

1. The Attorney Pro Se is a citizen of the United States.

2. The Attorney Pro Se is a registered voter.

3. The Attorney Pro Se educated to the Masters Degree level.

4. The Attorney Pro Se is and honorably discharge Naval Officer and Fighter Pilot.

5. The Attorney Pro Se is a Public servant and has been one for 19 years.

6. The Attorney Pro Se record of achievement as a public Servant is exemplary and extraordinary.

7. The Attorney Pro Se is a member of the class, the question of law raised in this action apply to him, and has experienced the same harm and injury as other members of the class.

e. The Plaintiffs hold that it is self-evident that the Defendant's have acted on grounds applicable to all of the Plaintiffs, thus making final injunctive and declaratory relief appropriate to the class as a whole.

APPLICABLE CONSTITUTIONAL LAWS

This action is filed under the following Articles of our Constitution:

Article I, Section 1. All legislative powers herein granted shall be vested in a Congress of the United States, which shall consist of a Senate and House of Representatives.

Article I, Section 2. The House of Representatives shall be composed of members chosen every second year by the people of the several states.

Article I, Section 8. The Congress shall have the power to regulate commerce with foreign nations and to make all laws necessary and proper for carrying into Execution this power.

Article III, Section 1. The judicial power of the United States shall be vested in One Supreme Court and in such inferior courts as the Congress may from time to time ordain and establish.

Article III, Section 2. The judicial power shall extend to all cases, in law and equity, arising under this Constitution, the laws of the United States, and treaties made, or which shall be made, under their authority; to all cases affecting ambassadors, other public ministers and consuls; to all cases of admiralty and maritime jurisdiction; to controversies to which the United States shall be a party; to controversies between two or more States; between a state and citizens of another State; between citizens of different states, between citizens of the same state claiming lands under grants of different states, and between Citizens of the same State claiming lands under Grants of different States, and between a State, or the citizen thereof, and foreign States, citizens or subjects.

Article V. The Congress, whenever two thirds of both house shall deem it necessary, shall propose Amendments to this Constitution, or, on the application of the Legislatures of two thirds of the several states, shall call a Convention for proposing Amendments, which, in either Case, shall be valid to all Intents and Purposes, as Part of this Constitution, when ratified by the Legislatures of three fourths of the several states, or by Conventions in three fourths thereof, as the one or the other Mode of Ratification may be proposed by Congress.

Amendment XVII. The Senate of the United States shall be composed of two Senators from each State, elected by the people thereof.

BACKGROUND

On April 1, 1994, representatives from one-hundred thirteen nations of the world, including those from the United States, met in Marrakech, Morocco to sign the "Final Act Embodying The Results Of The Uruguay Round of Multilateral Trade Negotiations commonly known as GATT (General Agreement on Tariffs and Trade). By signing the Final Act, our representatives agreed:

• To submit, as appropriate, the WTO Agreement for consideration of their respective competent authorities with a view to seeking approval of the Agreement in accordance with their procedures; and
• To adopt the Ministerial Declarations and Decisions.

On December 1, 1994, Congress enacted the Final Act of the Uruguay round of GATT. Shortly thereafter, President Clinton signed this bill and GATT with all its Agreements, including the one establishing the World Trade Organization, became United States Law.

This legal action is based upon the following Articles of "The Agreement Establishing The World Trade Organization, presented in List #1, and upon the Articles of Annex 2, to that Agreement, "Understanding On Rules and Procedures Governing the Settlement Of Disputes", presented in List #2.

List #1. Articles from the Agreement Establishing the World Trade Organization

Article I. The World Trade Organization (hereafter referred to as "the WTO") is hereby established.

Article II, Paragraph 1. The WTO shall provide the common institutional framework for the conduct of trade relations among its Members in matters related to the agreements and associated legal instruments included in the Annexes to this Agreement.

Article II, Paragraph 2. The agreements and associated legal instruments included in Annexes 1, 2 and 3 (hereafter referred to as "Multilateral Trade Agreements") are integral parts of this Agreement, binding on all Members.

Article III, Paragraph 3. The WTO shall administer the Understanding on Rules and Procedures Governing the Settlement of Disputes (hereafter referred to as the "Dispute Settlement Understanding" or "DSU") in Annex 2 to this Agreement.

Article XVI, Paragraph 4. Each Member shall ensure the conformity of its laws, regulations and administrative procedures with its obligations as provided in the annexed Agreements."

Article XVI, Paragraph 5. No reservations may be made in respect of any provision of this Agreement.

List #2. Articles from Annex 2 of the Agreement Establishing the World Trade organization, "Understanding on Rules and Procedures Governing the Settlement of Disputes.

Article 1, Paragraph 1. The rules and procedures of this Understanding shall also apply to consultations and the settlement of disputes between Members concerning their rights and obligations under the provisions of the Agreement Establishing the World Trade Organization (referred to in this Understanding as the "WTO Agreement") and of this Understanding taken in isolation or in combination with any other covered agreement.

Article 2, Paragraph 1. The Dispute Settlement Body (DSB) is hereby established to administer these rules and procedures.

Article 6, Paragraph 1. If the complaining party so requests, a panel shall be established at the DSB meeting following that at which the request first appears as an item on the DSB's agenda.

Article 7, Paragraph 7. Where the parties to the dispute have failed to develop a mutually satisfactory solution, the panel shall submit its findings in the form of a written report to the DSB.

Article 16, Paragraph 4. Within 60 days after the date of circulation of a panel report to the Members, the report shall be adopted at a DSB meeting unless a party to the dispute formally notifies the DSB of its decision to appeal or the DSB decides by consensus not to adopt the report. If a party has notified its decision to appeal, the report by the panel shall not be considered for adoption by the DSB until after completion of the appeal.

Complaint #1. Wrongful Assignment of the Legislative Power of Congress

The Uruguay Round of GATT, according to the Articles in List #1, establish the WTO, establish that the Multilateral Trade Agreements, including those in Annexes 1, 2, & 3, are binding upon member nations, and establish that WTO member nations, will without reservation, ensure their laws, regulations, and administrative procedures conform to the obligations as agreed. The Articles in List #2, taken from Annex 2 to the Agreement establishing the WTO, establish a procedure, whereby, if member nations are unable to negotiate a mutually satisfactory solution to a dispute or controversy, then the (DSB) may adopt a solution as recommended by a Panel. This adopted ruling, as agreed without reservation, is legally binding upon the disputing parties and all other member nations of the WTO. Therefore, when a Panel ruling is adopted by the DSB, the DSB has performed a legislative act.

Article I, Section 1, of our Constitution states that the legislative powers of our Nation will be vested in Congress. If rulings adopted by the DSB are legislative acts legally binding upon member nations, then a part of the legislative power granted to Congress by the Constitution, is no longer vested in Congress, but instead, has been assigned to the WTO. Nowhere in the Constitution is Congress given authority to assign any part of its legislative powers to a second party. The wording of Article I, Section 1, is clear, "All legislative powers shall be vested in Congress". If, as has been demonstrated, a portion of the legislative power of Congress is now vested in the WTO, then Article I, Section 1 of the Constitution has been violated. For this reason, GATT and our participation in the WTO as members is repugnant to our Constitution and unconstitutional.

Complaint #2. Wrongful Abridgment of the Voting Rights of Citizens

Article I, Sections 1 & 2, of the Constitution provide that the people of each state shall directly elect those who represent them in Congress; our national Legislature. In Complaint #1, it has been established that under the Uruguay Round of GATT, Congress has wrongfully assigned part of its legislative power to the WTO. If the legislative power vested in Congress is divided between Congress and the WTO and, as is the case, United States citizens do not directly vote for WTO representatives, then it follows that the voters of this Nation do not vote for those who exercise the assigned portion of legislative power. If the voting citizens of this Nation no longer vote for those who establish "all" of our laws, then the voting rights of Americans have been abridged in violation of Article I, Sections 1 & 2 of our Constitution. For these reasons, the enactment of GATT and our membership in the WTO, is repugnant to our Constitution and unconstitutional.

Complaint #3. Wrongful Assignment of the Power to Regulate Commerce with Foreign Nations.

The Uruguay Round of GATT, Article II, Paragraph 1, states that, "The WTO shall provide the common institutional framework for the conduct of trade relations among its Members in matters related to the agreements and associated legal instruments included in the Annexes to this Agreement". In contrast, Article I, Section 8, of our Constitution states that, "The Congress shall have the power to regulate commerce with foreign nations and to make all laws necessary and proper for carrying into execution this power". Nowhere in our Constitution is Congress given authority to assign its power to regulate commerce with foreign nations to a second party or to bestow authority upon that second party to make their own laws, legally binding upon Americans, to carry out execution of their assigned powers. For these reasons, the enactment of GATT and membership in the WTO, is repugnant to our Constitution and unconstitutional.

Complaint #4. Wrongful Assignment of the Judicial Power of the Supreme Court.

The Uruguay Round of GATT, through the Articles listed in Item #2, establish a procedure, whereby, if a member nation of the WTO is offended by an existing United States law, that nation can bring this issue or controversy before the DSB for resolution. If the DSB adopts a panel report in favor of the offended Nation, we have agreed, without reservation, to nullify the offending law. Therefore, DSB adopted rulings result in the repeal of United States law. Article III, Section 1, of our Constitution, provides that the judicial power of this Nation shall be vested in our Supreme Court or other inferior courts. Furthermore, Article III, Section 2, of our Constitution provides that the judicial power of this Nation shall in all cases in law and equity arising under the Constitution, including the Laws of the United States and treaties made or which shall be made; to Controversies to which the United States shall be a Party, and to Controversies between foreign States, Citizens, or Subjects. Under GATT, these provisions of Article III, Sections 1 & 2, no longer are effective. The Articles listed in Item #2, establish that the DSB of the WTO now retains some of the judicial power vested, by our Constitution, in our Supreme Court. Nowhere in the Constitution is Congress given authority to assign the judicial power of the Supreme Court to a second party. For these reasons, the enactment of GATT and our membership in the WTO, is repugnant to our Constitution and unconstitutional.

Complaint #5. Wrongful Change in Primary Governmental Functions by A Simple Legislative Act

A constitution is sacred to a Nation because of its three fundamental purposes; it establishes government, establishes how government will function, and protects the rights of citizens. All Constitutions include a procedure for amending its provisions. This amendment procedure is rigorous to preclude frivolous change and demands a higher level of passage than a simple legislative act. Therefore, changing any Constitution through a simple legislative act is unconstitutional because it bypasses the more demanding amendment process and the protections included therein.

If a fundamental purpose of our Constitution is to establish how our government functions and two prime functions of our government are to establish and review laws, then it follows that any significant change to our legislative or judicial review processes, must be made by amendment. This truth is fundamental and self-evident. Clearly, it is wrong to allow a lower level procedure established by the Constitution to change procedures provided for in the Constitution, when a higher level procedure is included for that expressed purpose. Therefore, any ordinary legislative act which results in a change to how our government functions is unconstitutional because it trivializes the amendment process and by extension, the Constitution itself.

When Congress passed the General Agreement on Tariffs and Trade (GATT), thereby establishing this Nation as a member of the World Trade Organization (WTO), it did so through a simple majority vote on a trade bill. Unfortunately, WTO membership entails far more than just a trade agreement because the organization was constituted to govern world trade through a dispute settlement process. This dispute settlement process, supersedes and replaces the legislative and legislative review processes established by our Constitution and therefore as demonstrated in Complaints 1, 2, 3, & 4, constitutes a fundamental and significant change in how our government functions and operates. These fundamental and significant changes are as follows:

Before GATT:

• Subject to final approval by the President, Congress enacted all laws governing this Nation and its people.
• The people of this Nation voted directly for those who made our laws.
• Congress, alone, regulated commerce with foreign nations.
• The Supreme Court was the final and only authority over United States law.
• The criteria for the nullification of a law was the test of constitutionality.

After GATT:

• The power to enact laws has been divided between Congress and the WTO. Furthermore, The president does not have veto power over laws established by the WTO.
• The people of this Nation no longer vote directly for those who make our laws.
• Congress no longer regulates commerce with foreign nations and this authority now resides with the WTO.
• The judicial review authority of our Supreme Court has been divided between the Supreme Court and WTO. Furthermore, the situation is such that our Supreme Court cannot overrule a WTO ruling without violating our agreement with that organization.
• Our laws can now be voided because a group of foreign nationals view them as being unfair to trade.

It is self-evident that these changes wrought by the enactment of GATT, are significant and fundamental such that they constitute a significant change in the nature and form of our government. This being true, the Congressional vote for the Uruguay Round of GATT, a simple legislative act of Congress, is repugnant to our Constitution because such significant and fundamental change to governmental functions must be made by Constitutional Amendment. For these reasons, GATT and our membership in the WTO is unconstitutional.

PRECEDENT

The central issue to the complaints in this legal action is whether or not an act repugnant to the Constitution can become United States Law. This issue was addressed in 1803 by Chief Justice John Marshall in his opinion written in the case of Marbury v. Madison. The words of Chief Justice Marshall that apply to this legal action are as follows:

The question whether an act, repugnant to the Constitution, can become law of the land is a question deeply interesting to the United States but, happily, not of an intricacy proportioned to its interest. It seems only necessary to recognize certain principles, supposed to have been long and well established, to decide it.

That the people have an original right to establish, for their future government, such principles as in their opinions shall most conduce to their own happiness, is the basis on which the whole American fabric has been erected. The exercise of this original right is a very great exertion; nor can it, nor ought it to be frequently repeated. The principles, therefore, so established are deemed fundamental. And as the authority from which they proceed is supreme and can seldom act, they are designed to be permanent.

This original and supreme will organizes the government and assigns to different departments their respective powers. It may either stop here or establish certain limits not to be transcended by those departments.

The government of the United States is of the latter description. The powers of the legislature are defined and limited; and that those limits may not be mistaken or forgotten, the Constitution is written. To what purpose are powers limited, and to what purpose is that limitation committed to writing, if these limits may, at any time, be passed by those intended to be restrained? The distinction between a government with limited and unlimited powers is abolished if those limits do not confine the persons on which they are imposed and if acts prohibited and acts allowed are of equal obligation. It is a proposition too plain to be contested that the Constitution controls any legislative act repugnant to it or that the legislature may alter the Constitution by an ordinary act.

Between these alternatives there is no middle ground. The Constitution is either a superior paramount law, unchangeable by ordinary means, or it is on a level with ordinary legislative acts and, like other acts, is alterable when the legislature shall please to alter it.

If the former part of the alternative be true, then a legislative act contrary to the Constitution is not law; if the latter part be true, then written constitutions are absurd attempts on the part of the people to limit a power, in its own nature, illimitable.

Certainly, all those who have framed written constitutions contemplate them as forming the fundamental and paramount law of the nation and consequently, the theory of every such government must be that an act of the legislature repugnant to the Constitution is void.

This theory is essentially attached to a written constitution and is, consequently, to be considered, by this court, as one of the fundamental principles of our society. It is not, therefore, to be lost sight of in the further consideration of this subject.

If an act of the legislature repugnant to the Constitution is void, does it, not withstanding its invalidity, bind the courts and oblige them to give it effect? Or, in other words, though it be not law, does it constitute a rule as operative as if it was a law? This would be to overthrow, in fact, what was established in theory and would seem, at first view, an absurdity too gross to be insisted on. It shall, however, receive a more attentive consideration.

It is, emphatically, the province and duty of the judicial department to say what the law is. Those who apply the rule to particular cases must of necessity expound and interpret that rule. If two laws conflict with each other, the courts must decide on the operation of each.

So if a law be in opposition to the Constitution, if both the law and the Constitution apply to a particular case so that the court must either decide that case conformably to the law, disregarding the Constitution, or conformably to the Constitution, disregarding the law, the court must determine which of these conflicting rules govern the case. This is of the very essence of judicial duty. If then, the courts are to regard the Constitution and the Constitution is superior to any ordinary act of the legislature, the Constitution and not such ordinary act, must govern the case to which they both apply.

Those then, who controvert the principle that the Constitution is to be considered, in court, as a paramount law are reduced to the necessity of maintaining that courts must close their eyes on the Constitution and see only the law.

This doctrine would subvert the very foundation of all written constitutions. It would declare that an act which, according to the principles and theory of our government is entirely void, is yet in practice, completely obligatory. It would declare that if the legislature shall do what is expressly forbidden, such act, notwithstanding the express prohibition, is in reality ineffectual. It would be giving to the legislature a practical and real omnipotence, with the same breath which professes to restrict their powers within narrow limits. It is prescribing limits and declaring that those limits may be passed at pleasure.

That it thus reduces to nothing what we have deemed the greatest improvement on political institutions, a written constitution would of itself be sufficient, in America, where written constitutions have been viewed with so much reverence, for rejecting the construction. But the peculiar expressions of the Constitution of the United States furnish additional arguments in favor of its rejection.

The judicial power of the United States is extended to all cases arising under the Constitution. Could it be the intention of those who gave this power to say that, in using it, the Constitution should not be looked into? That a case arising under the Constitution should be decided without examining the instrument under which it arises. This is too extravagant to be maintained.

Thus, the particular phraseology of the Constitution of the United States confirms and strengthens, that a law repugnant to the Constitution is void and that the courts, as well as other departments (Congress) are bound by that instrument. The (repugnant) rule must be discharged (repealed).

In his opinion, Chief Justice Marshall clearly establishes that any act in contradiction to the provisions of our Constitution is repugnant to the Constitution. Furthermore, Chief Justice Marshall goes on to establish that any act repugnant to our Constitution is unconstitutional and must be repealed. So it is with GATT and our membership in the WTO, established as follows:

• GATT is an ordinary legislative act passed by Congress.
• GATT establishes the WTO, an organization constituted to govern world trade.
• The Agreements of the WTO provide that the decisions of its DSB are final and legally binding upon WTO members.
• The Constitution states that the legislative power of the United States shall be vested in Congress.
• The WTO provision that decisions of the DSB are legally binding upon members is in contradiction with the Constitutional provision that the legislative power of the United States shall be vested in Congress.
• The Constitution states that the judicial power of United States shall be vested in the Supreme Court.
• The WTO provision that decisions of the DSB are legally binding upon members is in contradiction with the Constitutional provision that the judicial power of the United States shall be vested in our Supreme Court.

Therefore, GATT, being an ordinary legislative act passed by Congress, is repugnant to the Constitution. If GATT is repugnant to the Constitution, then GATT is not law, is void, is not binding upon the American people, and must be discharged (repealed).

Other Supporting Arguments

President George Washington, our first President and the father of our Nation, in his farewell address given on September 19, 1796, said:

It is important, likewise, that the habits of thinking in a free Country should inspire caution in those entrusted with its administration, to confine themselves within their respective Constitutional spheres; avoiding in the exercise of the Powers of one department to encroach upon another. The spirit of encroachment tends to consolidate the powers of all the departments in one, and thus to create whatever form of government, a real despotism. A just estimate of that love of power and proneness to abuse it, which predominates in the human heart is sufficient to satisfy us the truth of this position.

The necessity of reciprocal checks in the exercise of political power; by dividing and distributing it into different depositories and constituting each the Guardian of the public weal against invasions by the others, has by experiments ancient and modern; some of them in our country and under our own eyes. To preserve them must be as necessary as to institute them.

If in the opinion of the People, the distribution or modification of the Constitutional powers be in any particular wrong, let it be corrected by an amendment in the way which the Constitution designates. But let there be no change by usurpation; for though this, in one instance, may be the instrument of good, it is the customary weapon by which free governments are destroyed. The precedent must always greatly overbalance in permanent evil any partial or transient benefit which the use can at any time yield.

George Washington was very clear on his feelings about governmental agencies assuming powers not provided for in our Constitution or encroaching upon powers reserved for other governmental departments. He strongly believed that such changes in the distribution of powers should be made only by amendment. If they are not, then the precedent set results in the destruction of our government. GATT, established by an ordinary act of Congress, has resulted in the usurpation of the legislative power of Congress and the judicial power of our Supreme Court by the WTO's Dispute Settlement Body. For whatever good can possible be derived from this state of affairs, from George Washington's perspective, a permanent evil has been introduced into our body politic that will destroy our free government.

INJURY

Concrete and particular injury suffered by the Plaintiffs, as a class, are:

a. Our voting rights as citizens have been diminished as established in Complaint #2 of this civil action.

b. The nature and form of the government that the Plaintiffs live under and pledge allegiance to, has been improperly and wrongfully changed because of the Defendants' actions as established in Complaints #1, #2, #3, #4, & #5, of this civil action. Before GATT, this Nation was a Democratic Republic where the Plaintiffs voted for those who made all of our laws. In this Democratic Republic, it was incumbent for government to abide by our Constitution's Provisions. Subsequent to GATT, the Plaintiffs no longer vote for those who make all our laws and a precedent has been set such that the government is no longer bound by the provisions of our Constitution. Therefore, our Constitution has been rendered dysfunctional and void for primary purpose for which it was written.

Because our Constitution has been rendered dysfunctional and void, and because we now do not vote for the those who make some of our laws, the Plaintiffs hold that this Nation is no longer a Democratic Republic and that recitation of our Pledge of Allegiance is foolish because the Republic we pledge allegiance to no longer exists.

c. The laws of this Nation are made and passed by way of a lengthy and arduous legislative process. All laws so passed are subject to legis-lative review where the only criteria of nullification is constitutionality. Under GATT, the laws of this Nation are now subject to veto by a group of foreign nationals based solely upon what they consider to be fair in matters of trade. Furthermore, rulings of WTO, which are legally binding upon American citizens, are not subject to appeal and review by our Supreme Court. If our laws can be nullified, without due process, by a foreign organization and if laws not of our making can be imposed upon us by that same foreign organization, then the Plaintiffs hold that we are the victims of tyranny.

We, the Plaintiffs, hold that the harm and injury as identified above is real, concrete, and particular and that we have suffered this harm and as individuals and together as class. To those who would hold otherwise, we say: If the harm and injury identified in items a., b., & c., above, were forced upon us by a hostile foreign power, all Americans would hold these injuries to be real, concrete, and particular. The fact that they were imposed upon us by our own President and Legislature, does not change this.

CAUSATION

The Plaintiff's hold that it is self-evident that the harm and injuries, as identified under "INJURIES", was incurred as a direct result out of the passage of GATT and our participation as members of the WTO.

REDRESSABILITY

The Plaintiff's hold that it is self-evident that a if GATT is judged to be unconstitutional for the reasons enumerated in this complaint and injunctive relief is granted by this court as requested, this would terminate our participation in the WTO as members and thereby alleviate the harm and injury, as identified under "INJURIES", that is presently being suffered by the Plaintiffs.

DECLARATORY RELIEF

The plaintiffs request the United States District Court of the Southern District of Florida, rule that the Final Act Embodying The Results of the Uruguay Round of Multilateral Trade Negotiations, the Final Round of the General Agreement on Tariffs and Trade, the Agreement Establishing the World Trade Organization, and our participation in the World Trade Organization as a member of that organization, is repugnant to the provisions of our Constitution and therefore, unconstitutional.

INJUNCTIVE RELIEF

The plaintiffs further request injunctive relief such that the defendants are ordered as follows:

a. To cease and desist participation of the United States in the World Trade Organization and to forgo adherence to its associated Annexes and Agreements.

b. To ensure that all duly constituted laws of this Nation modified or repealed by the action of the WTO's DSB, be restored.

c. To pay all costs and fees associated with this legal action.

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The above filing was amended in accordance with the defendant's motion to dismiss.

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