Escolar Documentos
Profissional Documentos
Cultura Documentos
[hereinafter “Berg”], the Law Offices of Philip J. Berg; Evelyn Adams a/k/a
Excel Global by and through their undersigned counsel, Philip J. Berg, Esquire,
hereby file the within Objections and Opposition with a Request to Strike and for
Attorney fees and Sanctions to Appellees Orly Taitz and Defend our Freedoms
Appellees Motion to Strike was filed for an improper purpose and contains
statements and material, and are completely irrelevant, impertinent and immaterial
I. STATEMENT OF FACTS:
of herself and her Corporation Defend our Freedoms Foundations, Inc. [hereinafter
Case: 09-3403 Document: 003110135281 Page: 3 Date Filed: 05/07/2010
“DOFF”] on April 26, 2010, five (5) days after Appellants filed their Motion to
Appellees Taitz and DOFF then filed their Opposition to the Appellants
Motion on April 30, 2010 and raised numerous new issues and a Request for Costs
and Sanctions. Appellants had to reply, but due to the complexity of the Case was
unable to properly reply without exceeding the page limits. Appellants’ have filed
a Motion for Leave to File in Excess of the Ten (10) Page Limit. Appellants filed
their Reply on May 1, 2010 so not to hold up the Court in granting their Motion to
Appellees Taitz and DOFF have now filed a Motion to Strike Appellants’
Reply filed on May 1, 2010 to Appellees Opposition, which appears on the Court
cause delay.
crimes; to make unsubstantiated allegations against the Appellants; and now Taitz
screams afoul because Taitz is unhappy that Appellants replied to all of Taitz’s
false allegations and accusations against the Appellants and filed supporting
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Appellants Reply are authenticated, they were taken directly from Taitz’s website,
which she authored and published. Taitz now claims the documents cannot be
trusted, which is ludicrous as Taitz maintains all the originals; Taitz sent them to
other websites, who posted them; to journalists who wrote about them; went on
radio shows, including but not limited to Satellite, Short Wave, Broadband and
Network and discussed her postings; Taitz provided them to law enforcement; and
filed them in other Federal Courts. Taitz claims the exhibits can’t be trusted
because “the documents and affidavits submitted are prepared and handled by
Berg’s assistant Lisa Renee Liberi (aka Lisa Liberi Richardson), who is a career
forgery with some ten convictions of forgery of documents…” Taitz’s filings are
important for this Court to note, Appellant Lisa Liberi’s middle name is NOT
“Renee”; nor has her name ever been “Lisa Liberi Richardson”. In addition, in
Taitz’s ramblings, which clearly warrant sanctions, she claims Appellant Lisa
Liberi threatened her sister and then her sister died. In is important for this Court
to note “Cheryl” is NOT and has NEVER been Appellant Liberi’s sister’s name.
It should also be noted that Appellant Lisa Liberi is a paralegal, not an investigator
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and Appellant Lisa Liberi has donated her time to the undersigned since
reasons are unknown as to why, other than her threat to take the undersigned down
and to do so, Taitz stated she would destroy Appellant Lisa Liberi.
The rest of Taitz’s ramblings, again which she must be sanctioned for, are
referring to cases of the undersigned and events the undersigned has planned.
Nothing in Taitz filing has anything to do with the issue before this Court, which
pursuant to the F.R.A.P. 42(b). As this Court can clearly see by using Taitz’s
Appellants’ Reply, Appellee Taitz has a known history of falsely accusing her
victims of crimes and inappropriate actions for which she is actually doing, just as
she has done in her Motion to Strike, which clearly speaks for itself.
Unfortunately, the Appellants are victims of Taitz’s and it has been reported to the
Taitz then cries that she is running for California Secretary of State in a tight
two (2) candidate race which is absolutely absurd. I will point out to this Court
however, just to give another example of how Taitz’s targets people: Damon Dunn
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Republican Party. Taitz did not take kindly to this and has now “targeted” Damon
Dunn. Taitz without any type of permissible purpose has obtained a Lexis
Accurint Report on Dunn, placing the majority of his Social Security number on
her site1. In addition, Taitz has been accusing Damon Dunn of Crimes in
California and even demanded the Orange County District Attorney’s Office to
prosecute Dunn, which they declined as Dunn had not broken any laws. A simple
search on the Internet in Google with “Taitz + Dunn” brings up Taitz’s horrible
posts authored and posted by her, just as she has done to the Appellants herein and
This Court may recall, in Taitz’s Opposition filed April 30, 2010, she
[See Taitz April 30, 2010 Opposition, p. 2 second paragraph] and now, Taitz
Order and/or Injunction against Taitz and the other Appellees’ Taitz had threatened
the undersigned, Appellant Lisa Liberi and the other Appellants, which since the
filing of the within lawsuit, Taitz has admitted in her filings in the lower Court.
Also, to bring to this Court’s attention, Appellants can’t derail a California State
1
http://www.orlytaitzesq.com/?p=10230; and http://www.orlytaitzesq.com
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election, such as for Secretary of State. None of the Appellants reside in the State
Taitz had the audacity to claim that www.repubx was not her website;
however, on Taitz’s own Dossier #6, which is on file with this Court, Taitz puts
document itself is still available from the cache and Taitz Dossier #6 with
Appellant Lisa Liberi’s full Social Security number is still available on the
Internet2. The Court will note on the Exhibit attached to Appellants Opposition,
Dossier #6 was printed to a PDF format directly from the website itself, which
automatically picked up the website, date and time the document was stored in
Taitz must be confused; it was during the June 25, 2009 Hearing that Judge
Robreno told Taitz she was not to publish anyone’s Social Security number. Taitz
was present for the June 25, 2009 hearing before Judge Robreno. The August 7,
2009 transcript, as stated many times, the undersigned was not provided the cost
for until April 16, 2010 proof of which was filed in Appellants’ Reply filed May 1,
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them from the Court herself. In addition, Taitz attaches a copy of Joan Carr’s
Response to this Court’s Order to Show Cause why she, Joan Carr, should not be
held in contempt for her failure to produce the transcript. However, Taitz fails to
Taitz then lies to this Court yet again. Taitz states, “The unauthenticated
Grimm’s fairy tales of Dr. Taitz being submitted by appellants would be almost
laughable were it not for appellant s’ penchant for republishing this muck once it
obtains the court’s file stamp.” None of the Appellants have published any of their
filings in either this Court or the lower Court; it is Taitz’s herself who posts her
filings in the within Action all over the Internet and sends them by mass emailing.
Please see EXHIBIT “1” which is a letter recently sent to Judge Robreno
regarding Taitz sending a letter to Judge Robreno, that was never filed and/or
docketed in the lower Court case. Despite this, Taitz prepared a press release and
sent the letter addressed to Judge Robreno all over the Internet and sent it by mass
emailing for the world to see. In fact, she misquoted this Court’s Order of
February 2010 in her press release and mass emailing. This is not the first time
either, in fact, some of which is still on Taitz’s website 3. However, it appears once
2
See http://www.oilforimmigration.org/facts/?p=1478 and http://www.oilforimmigration.org
3
www.orlytaitzesq.com/?p=8034; www.orlytaitzesq.com/?p=2579;
www.orlytaitzesq.com/?p=1843 (this includes the forged emails of Appellant Lisa Ostella which
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the undersigned files on behalf of Appellants, and attaches copies of Taitz writings
and posts, Taitz has been “scrubbing” (deleting) the posts in question. Copies of
all of Taitz’s posts, which she has authored and posted on her website, are filed in
the lower Court with the direct website address. Taitz’s answers to said posts are
different depending on who she is talking too. Before Judge Robreno at the June
25, 2009 Hearing, Taitz claimed she had a duty, as an Officer of the Court, to
publish all her writings, her false allegations; all of Appellant Lisa Liberi’s private
confidential data, including her Social Security number and false-tales about the
Taitz’s Motion to Strike Appellants Reply speaks for itself and is more than
sufficient proof that Taitz filed it for improper reasons, and therefore, she must be
was forged by Appellees Taitz and Sankey, proof of which is filed in the lower Court);
www.orlytaitzesq.com/?p=1648;
http://www.plainsradio.com/PLAINS~1/forum.html#bn-forum-1-1-
3764075825/6712/1121534/show; and
http://pub44.bravenet.com/forum/static/show.php?usernum=3764075825&frmid=6712&msgid=
1121538&cmd=show (When you go to these websites on Plains Radio and download the actual
files, click on the properties of the document and it shows Orly Taitz as the author of the
documents. Since Appellees Ed Hale and Orly Taitz scrub (delete) their postings when
Appellants’ file them with the Court, a copy is also attached hereto as EXHIBIT “2”).
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Appellants’ Object and ask this Court to Strike Taitz and DOFF’s entire
Strike fails to cite any law or legal authority to support the striking of a pleading;
and contains nothing more than conclusions of law; hearsay statements; hearsay
scandalous statements and material, and are completely irrelevant, impertinent and
immaterial to the within action; and fails to embark upon or even address
Appellants’ Opposition filed May 1, 2010. Taitz simply filed this nonsense to
prejudice the Appellants’ and to reflect falsely on the moral character of the
undersigned and Appellants’ Lisa Liberi, Lisa Ostella and Evelyn Adams.
Appellants attached proof to all of the statements made by attaching the items as
Exhibits.
detracts from the dignity of the Court. Courts will typically strike so-called
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detracts from the dignity of the Court"). This Court has the inherent power to
impertinent or scandalous matter.” See Geruschat v. Ernst Young LLP (In re Seven
Fields Dev. Corp.), 505 F.3d 237, 248 (3d Cir. Pa. 2007).
scandalous; and done with malice. Again, this filing by Taitz is the exact reason
Appellants (Plaintiffs) were forced to file action. Taitz only filed her nonsense to
Appeal so the Case against Appellees can move forward. See Farid v. Murphy,
945 F.2d 394 (3d Cir. 1991) (The Court sua sponte strikes as scandalous and
impertinent the second paragraph under the heading "plaintiff" at page 10 of the
brief for Appellees. The Court deems the inclusion of that paragraph in the brief to
justify the inclusion of the material, to be disingenuous.). The Court must strike
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Opposition must be denied; Taitz Request for Sanctions and Costs must also be
denied. Taitz’s Motion to Strike filed May 5, 2010 must be stricken from the
record.
Motion to Strike filed May 5, 2010. Taitz request for Sanctions is also frivolous
and filed for an improper purpose. In fact, her entire pleading and Exhibits filed
May 5, 2010 are frivolous, incompetent; fail to cite any authority; was only filed to
further delay the within Appeal; and to waist judicial resources. Taitz is also
attempting to prolong the dismissal of this Appeal so the case in the lower Court
cannot proceed forward. The Exhibits Taitz attached includes Motions that were
Dismissed in the lower Court. Taitz raised issues in her Opposition that Appellants
showing this Court that Taitz lies and has lied to this Court again. Now Taitz is
having a temper tantrum because she is not happy with the truth coming out.
Therefore, Taitz’s Request for Sanctions must be denied; Taitz Pleadings must be
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statements and are completely irrelevant, impertinent and immaterial to the within
action; and fails to embark upon the issue before this Court, which is Appellants’
Motion to Withdraw or Dismiss their Appeal. Taitz and DOFF must be Sanctioned
and Ordered to pay Attorney Fees for her frivolous filings; her attempts to waist
judicial resources; to cost Appellants additional Attorney Fees; and her prolonging
the Dismissal of Appellants’ Appeal so their case in the lower Court stays at a
Taitz has been sanctioned before in October 2009, for this very exact thing
See Rhodes v. MacDonald, 670 F. Supp. 2d 1363 (M.D. Ga. 2009). Judge Land
increased the Sanctions against Taitz from Ten Thousand [$10,000.00] Dollars to
Twenty Thousand [$20,000.00] Dollars in attempts to deter her from her frivolous
filings. Judge Land’s Sanction Order and Opinion was upheld by the United States
Court of Appeals for the Eleventh Circuit. See Rhodes v. MacDonald, 2010 U.S.
App. LEXIS 5340 (11th Cir. Ga. Mar. 15, 2010). Unfortunately, Judge Land’s
Sanctions were not persuasive, as Taitz continues her disrespect for our Court’s,
Court Rules and continues her barrage of frivolous filings. Taitz will continue
filing her frivolous papers, if this Court does not put a stop to it. Taitz is currently
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admissions and website postings in the public forums, as a result of Judge Land’s
Sanction Order and other complaints that were filed against her.
As stated in Walsh v. Schering-Plough Corp., 758 F.2d 889, 895 (3d Cir.
1985):
4
Federal Rule of Appellate Procedure 46(c) provides:
“c) Disciplinary Power of the Court over Attorneys. A court of appeals may, after
reasonable notice and an opportunity to show cause to the contrary, and after hearing, if
requested, take any appropriate disciplinary action against any attorney who practices
before it for conduct unbecoming a member of the bar or for failure to comply with
these rules or any rule of the court.”
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her own frivolous filings. Appellants’ filed their Appeal in good faith. Appellants’
incorporate all their filings, outlined on this Court’s docket, as if fully set forth
herein. Every filing by Appellants’ pertained to the issues presented to the Court
and were done so in good faith. Appellee Taitz on the other hand, continues to file
frivolous pleadings; has made false allegations against the undersigned and his
clients; has made false statements to this Court; has misrepresented the Court’s
Rulings; has misrepresented to this Court what Appellants’ filings actually say; and
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has failed to address the issues before the Court. It should also be noted, Appellee
Orly Taitz’s anger in her pleadings filed May 5, 2010 is clearly directed at
wherein Taitz put “Philip Berg, Esq.” and “Lisa Liberi c/o Law Offices of Philip
Berg”. Taitz did this even after Appellants brought this to the Court’s attention in
their Reply filed May 1, 2010. Once again, there are six (6) Appellants’, that the
licensed attorney, and she knows she is not to contact the Appellants’ directly as
they are represented. It should also be noted that Taitz did not properly serve the
undersigned again. Taitz states on her proof of service that she served Philip Berg
April 29, 2010. The only email received from Taitz on May 5, 2010 was a forward
Proper service was also a problem for Taitz in other cases. See Barnett v.
Obama, 2009 U.S. Dist. LEXIS 101206 (C.D. Cal. Oct. 29, 2009).
further stating:
5
Miller, The Adversary System: Dinosaur or Phoenix, 69 Minn.L.Rev. 25 (1984).
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lawyers look to us to uphold. Every member of the bar has had his
character and fitness tested and reviewed before obtaining a
license to practice. We, together, with other courts, are charged
with maintaining at least that level of honesty and professionalism
in the conduct of those who, once having obtained the right to
practice, continue to exercise that right before us.”
For the reasons stated herein, Taitz Motion to Strike; Request for Sanctions;
and Request for Costs must be denied. This Court must Sanction Taitz in attempts
to deter her from inappropriate behavior and frivolous filings. In addition, the
Court must Order Taitz to pay Appellants’ Attorney Fees in the amount of Four
IV. CONCLUSION:
Court to Deny Taitz’s Motion to Strike; Deny Taitz’s Request for Sanctions and
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Costs as there is no basis; and Grant Appellants Motion to Strike Taitz’s Motion to
Strike filed May 5, 2010; Grant Appellants Request for Sanctions and Attorney
Fees and Grant Appellants Motion to Withdraw or Dismiss their Appeal pursuant
to F.R.A.P. 42(b).
Respectfully submitted,
s/ Philip J. Berg
Dated: May 7, 2010 ____________________________
Philip J. Berg, Esquire
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
(610) 825-3134
Attorney for the Appellants’
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EXHIBIT “1”
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LAW OFFICES OF
PHILIP J. BERG
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
PHILIP J. BERG
CATHERINE R. BARONE
BARBARA MAY
(610) 825-3134
Re: Liberi, et al. v. Orly Taitz, et al, Case No. 09-cv-01898 ECR
Defendant Taitz, et al Letter requesting Leave to File a Request for Judicial Notice
I am in receipt of Defendant, Orly Taitz, et al’s Letter to Your Honor dated February 17, 2010
requesting Judicial Notice of the U.S. Court of Appeals for the Third Circuit’s Order denying
Appellant’s request for Judicial Notices; Defendant Taitz’s Motion for Sanctions; Appellants’ Motion
to Expedite, etc. I received Defendant Taitz’s request to Your Honor via email from Defendant Taitz,
et al on February 18, 2010.
Plaintiffs’ herein Object to Defendant Taitz’s request of Your Honor. First, no Motion or any
type of legal authority was attached to Defendant Taitz’s Letter as required by this Court’s Order of
June 25, 2009. Next, Defendant Taitz states the U.S. Court of Appeals for the Third Circuit “denied
all 11 motions…” [emphasis added]. This is a blatant fraud upon this Court. Appellants never filed
eleven [11] Motions with the Court of Appeals. Moreover, the Obama litigation has nothing to do with
the case herein; and Defendant Taitz’s is further using Your Honor and Your Court to further her
slander, libel, false allegations and placing Plaintiff Liberi, Plaintiff Ostella and me in a false light. It
should also be noted, neither Defendant Taitz, nor any of the other Defendants’ responded to Plaintiffs’
(Appellants’) Request for Judicial Notices.
In addition, Defendant Taitz has used Defendants Ed Hale, Caren Hale, Plains Radio Network,
Inc., KPRN and Bar H Farms to post Orly Taitz’s Letter to Your Honor on the Internet1. A copy of
this post on the Internet is attached hereto as EXHIBIT “A”. Defendant Taitz also posted her Letter
to Your Honor at two [2] different Internet Web Addresses on her website. Copies of Defendant
Taitz’s postings on her own website are also attached hereto as EXHIBIT “B”2 and EXHIBIT “C”3.
Moreover, Defendant Orly Taitz, et al sent her Letter to Your Honor by mass emailing to her entire
email database, which includes internationally, on February 18, 2010 at 9:28 a.m. and 12:32 p.m. A
copy of Defendant Taitz’s email sent to me is attached hereto as EXHIBIT “D”. Further, Defendant
Taitz then sent by mass emailing and posted on her website a press release with a copy of the Letter
sent to Your Honor. See EXHIBIT “E’. Defendant, Orly Taitz has publicized this Letter to Your
Honor to further her continued slander, libel, false allegations and placing Plaintiff Liberi, Ostella, and
me in a false light.
In my opinion, this type of behavior from Defendant Taitz, et al should not be permitted.
Defendant Taitz is an Attorney duly licensed to practice law in the State of California. The Court in
the case of Sheehan v. King County, 1998 U.S. Dist. LEXIS 16862 (D. Wash. 1998) outlined this type
of behavior very well. The Court said:
“His counsel offers the spurious argument that the "computer generated evidence"
is inadmissible as hearsay, and that sanctions would violate plaintiff's First
Amendment rights. The printed copies of plaintiff's "website" are not hearsay
because they are clearly not offered to prove the truth of matters asserted
therein (i.e., that plaintiff's accusations about counsels' character are true).
As for the First Amendment, the Court is not enjoining plaintiff's free
speech, but merely exercising its inherent power to sanction bad faith
1
Defendant Ed Hale’s post on his website at:
http://pub44.bravenet.com/forum/static/show.php?usernum=3764075825&frmid=6712&msgid=1107033&cmd=show
2
Taitz post on her website at www.orlytaitzesq.com
conduct by a party to this litigation. Chambers v. Nasco, Inc., 501 U.S. 32, 46,
115 L. Ed. 2d 27, 111 S. Ct. 2123 (1991)” [emphasis added]
“The Court finds that the "website" printouts have been properly authenticated by
counsel, who received them by "facsimile" transmission and also printed them
directly from their computers. Dkt. # 107, 108. The printouts show that as of
May 6, 1998, well after defendants filed their motion for sanctions and gave
notice to plaintiff of their request, plaintiff continued in his sanctionable
conduct. No separate warning from the Court is necessary.” [emphasis added]
Just like the Sheehan Case, Defendant Taitz has done the same sanctionable behavior to
Plaintiff Liberi, a Plaintiff in the within case with the republication of her Social Security number, date
of birth, place of birth, mother’s maiden name and other private identifiable information. Moreover,
Defendant Taitz has also gone after Plaintiff Liberi and the rest of the Plaintiffs’, including me,
Plaintiffs’ Attorney, making false accusations and defamatory statements about us all over the Internet,
by mass emailing, postings on their websites; posting on other websites; sending it to social networks;
on RSS feeds, etc. of defamatory comments/statements, etc. Moreover, just like the Sheehan Case,
Defendants were served with the within lawsuit on or about May 5, 2009, Defendants have continued
their behaviors. Especially Defendant Taitz, et al, she has continued her republication of Plaintiff
Liberi’s Social Security number, against this Court’s Rulings and Orders as well as Plaintiff Liberi’s
date of birth, place of birth, mother’s maiden name and other private information. Your Honor, these
continued actions by Defendant Taitz must be stopped.
I sent Your Honor a Letter seeking Leave on behalf of Plaintiff Liberi to file a Motion to hold
Defendant Taitz, et al in Civil and/or Criminal Contempt; for actual damages; sanctions; and attorney
3
Taitz post on her website at http://www.orlytaitzesq.com/?p=8034
fees on February 9, 2010. Of course, Plaintiff Liberi’s Motion was attached thereto. I am therefore,
renewing my request for Leave to file Plaintiff Liberi’s Motion for Contempt against Defendant Taitz
for her continued republication of Plaintiff Liberi’s Social Security number, as well as other personal
identifying information, which was in violation of Your Court’s June 25, 2009 Rulings and Order.
It should also be noted, none of the Defendants, including Defendant Taitz, has opposed the
filing of the Motion for Civil and/or Criminal Contempt against Defendant Taitz.
In the alternative, Plaintiffs Request this Court to issue an Order to Show Cause upon
Defendant Taitz, et al as to Why She Should Not be Held in Civil and/or Criminal Contempt for her
continued republication of Plaintiff Liberi’s Social Security number in violation of this Court’s Rulings
and Orders; and why she (Defendant Taitz, et al) should not be Ordered to Reimburse Plaintiff Liberi
for the damages she has suffered as a result; impose Sanctions; and for Attorney Fees.
Thank you.
Respectfully,
Philip J. Berg
PJB:jb
Enclosures
Neil Sankey
The Sankey Firm, Inc. a/k/a The Sankey Firm
Sankey Investigations, Inc.
2470 Stearns Street #162
Simi Valley, CA 93063
Phone: (805) 520-3151and (818) 366-0919
Cell Phone: (818) 212-7615
FAX: (805) 520-5804 and (818) 366-1491
Email: nsankey@thesankeyfirm.com
Ed Hale
Caren Hale
Plains Radio
KPRN
Bar H Farms
1401 Bowie Street
Wellington, Texas 79095
Phone: (806) 447-0010 and (806) 447-0270
Email: plains.radio@yahoo.com and
Email: barhfarms@gmail.com and ed@barhfarms.net
EXHIBIT “A”
Return to Website
Author Comment
02.17.10
Attention Honorable Eduardo Robreno
Request for Leave of Court to file and docket a 02.09.10. Third Circuit Court of
Feb 18, 2010 - 9:50AM Appeals order denying all 11 Motions and requests for judicial notice filed by
Philip Berg on behalf of Appellants/Plaintiffs in Liberi et al v Taitz et al.
Your honor,
Plaintiffs in the above captioned case have bombarded the defendants and the courts
with hundreds and, by now, probably thousands of pages of pleadings of motions and
requests for judicial notices, most of which had absolutely nothing to do with the
case at hand and the order to show cause that was directed towards the plaintiffs. I
am asking for a judicial notice of one page only. The attached one page order from
the Third Circuit Court of Appeals denying all 11 motions and requests for judicial
notice, shows that the Third Circuit Court of Appeals does not see any emergency,
that the plaintiffs claim and does not see any relevance in all of those voluminous
filings. It is consistent with the findings of this court and it is an indication,
that if the Court of Appeals didn’t see any emergency now, it is reasonable to
believe that there was no emergency half a year ago, when your Honor denied
plaintiffs request for the temporary restraining order
against the defendants. It strengthens the defendant’s position that indeed, there
was no emergency or damages to the plaintiffs, rather Attorney Philip Berg has
filed this legal action with an improper purpose of harassing and trying to silence
the defendants, when I posted on my web site true printout from the San Bernardino
division of the Superior Court in CA of ten felony convictions of forgery and
grand theft committed by Berg’s assistant Lisa Liberi. This publication was done
with a proper purpose of alerting the public that any piece of evidence, any
document coming out of Berg’s office is suspect of forgery, due to Liberi’s
background and particularly in light of the fact that Mr. Berg has filed Affidavits
of Kenyan birth of Barack Obama in Eastern District of PA, Third Circuit Court of
Appeals and the Supreme Court of the United States and refused to show the original
documents to me or to a forensic document expert. While the
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Case: 09-3403 Document: 003110135281 Page: 27 Date Filed: 05/07/2010
media has named me the “Queen of the Birthers” or the leader of the Birther
movement, due to my legal actions to unseal the original vital records of Mr. Obama
and get a declaratory relief on the meaning of the term Natural born citizen, as it
applies to the article 2, section 1 requirement for presidency, I am concerned that
Mr. Berg’s actions in using a convicted document forger as a legal assistant, and
refusing to provide original documents, does not help the cause or the underlying
legal action, but rather undermines and muddies it and will destroy it, when it
will be heard on the merits. It is also an indication, that as an attorney and
president of the Defend Our Freedoms Foundation, I was justified in alerting the
public regarding the fact that on 04.11.09 my former volunteer web master Lisa
Ostella has changed the passwords and locked me out of the original
DefendOurFreedoms website, and from that date any and all donations
received on that old web site did not benefit my foundation, but rather benefit
Ostella personally, as well as Attorney Philip Berg, indirectly his assistant Lisa
Liberi, as well as talk show host Evelyn Adams, all of whom Ostella started
promoting on the web site for my foundation after locking me out.
While most of the plaintiffs are lay persons, Berg is a licensed attorney and his
actions were direct violation of rules of professional ethics.
Respectfully submitted,
02/09/2010
ORDER (MCKEE and RENDELL, Circuit Judges) denying Motion by Appellants for
Expedited
Ruling or to File a Restraining Order, requests Appellants for Judicial Notice,
Emergency Motion by Appellants to Expedite Interlocutory Appeal and Expedite
Ruling
on Appellants Pending Motion, filed. Panel No.: BCO-039-E. McKee, Authoring Judge.
State Texas
Quote:
Feb 18, 2010 - 10:53AM
Originally Posted by rosemary1
BobH? Any opinion on this filing by the "Queen of the Birthers"?
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Case: 09-3403 Document: 003110135281 Page: 28 Date Filed: 05/07/2010
My opinion is it means absolutely nothing. Without going into specific detail in the
letter, Orly seems to avoid the fact that one of her motions was also denied by the
appeals court in that Order that came down. She mentions Berg is an attorney. She
also has a license to practice law.
Nothing in the letter has any bearing on the appeal or the case in the the lower court
in PA which is actually not even open at this time, and has not been since 12/11/09,
pending the decision of the appeals court, as evidenced here:
Quote:
In short, it's nothing more than her usual ramblings with nothing of merit contained
therein.
State NM
Index
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Case: 09-3403 Document: 003110135281 Page: 29 Date Filed: 05/07/2010
EXHIBIT “B”
The articles posted represent only the opinion of the writers, do not necessarily represent the opinion of Dr. Taitz, ESQ, and Dr. Taitz, ESQ has no means of
checking the veracity of all the claims and allegations in the articles.
2/18/2010 2:42 PM
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/
Case: 09-3403 Document: 003110135281 Page: 31 Date Filed: 05/07/2010
02.17.10
Your honor,
Plaintiffs in the above captioned case have bombarded the defendants and the courts with hundreds and, by
now, probably thousands of pages of pleadings of motions and requests for judicial notices, most of which had
absolutely nothing to do with the case at hand and the order to show cause that was directed towards the
plaintiffs. I am asking for a judicial notice of one page only. The attached one page order from the Third
Circuit Court of Appeals denying all 11 motions and requests for judicial notice, shows that the Third Circuit
Court of Appeals does not see any emergency, that the plaintiffs claim and does not see any relevance in all of
those voluminous filings. It is consistent with the findings of this court and it is an indication, that if the Court
of Appeals didn’t see any emergency now, it is reasonable to believe that there was no emergency half a year
ago, when your Honor denied plaintiffs request for the temporary restraining order against the defendants. It
strengthens the defendant’s position that indeed, there was no emergency or damages to the plaintiffs, rather
Attorney Philip Berg has filed this legal action with an improper purpose of harassing and trying to silence the
defendants, when I posted on my web site true printout from the San Bernardino division of the Superior
Court in CA of ten felony convictions of forgery and grand theft committed by Berg’s assistant Lisa Liberi.
This publication was done with a proper purpose of alerting the public that any piece of evidence, any
document coming out of Berg’s office is suspect of forgery, due to Liberi’s background and particularly in
light of the fact that Mr. Berg has filed Affidavits of Kenyan birth of Barack Obama in Eastern District of PA,
Third Circuit Court of Appeals and the Supreme Court of the United States and refused to show the original
documents to me or to a forensic document expert. While the media has named me the “Queen of the
Birthers” or the leader of the Birther movement, due to my legal actions to unseal the original vital records of
Mr. Obama and get a declaratory relief on the meaning of the term Natural born citizen, as it applies to the
article 2, section 1 requirement for presidency, I am concerned that Mr. Berg’s actions in using a convicted
document forger as a legal assistant, and refusing to provide original documents, does not help the cause or the
underlying legal action, but rather undermines and muddies it and will destroy it, when it will be heard on the
merits. It is also an indication, that as an attorney and president of the Defend Our Freedoms Foundation, I
was justified in alerting the public regarding the fact that on 04.11.09 my former volunteer web master Lisa
2/18/2010 2:42 PM
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/
Case: 09-3403 Document: 003110135281 Page: 32 Date Filed: 05/07/2010
Ostella has changed the passwords and locked me out of the original DefendOurFreedoms website, and
from that date any and all donations received on that old web site did not benefit my foundation, but rather
benefit Ostella personally, as well as Attorney Philip Berg, indirectly his assistant Lisa Liberi, as well as talk
show host Evelyn Adams, all of whom Ostella started promoting on the web site for my foundation after
locking me out.
While most of the plaintiffs are lay persons, Berg is a licensed attorney and his actions were direct violation of
rules of professional ethics.
Respectfully submitted,
02/09/2010 ORDER (MCKEE and RENDELL, Circuit Judges) denying Motion by Appellants for Expedited
Ruling or to File a Restraining Order, requests Appellants for Judicial Notice, Emergency Motion
by Appellants to Expedite Interlocutory Appeal and Expedite Ruling on Appellants Pending
Motion, filed. Panel No.: BCO-039-E. McKee, Authoring Judge. (SLC)
Cc Philip Berg
Cc Neil Sankey
Cc Linda Belcher
2/18/2010 2:42 PM
Case: 09-3403 Document: 003110135281 Page: 33 Date Filed: 05/07/2010
EXHIBIT “C”
The articles posted represent only the opinion of the writers, do not necessarily represent the opinion of Dr. Taitz, ESQ, and Dr. Taitz, ESQ has no means of
checking the veracity of all the claims and allegations in the articles.
2/18/2010 2:43 PM
Important. Third Circuit Court of Appeals has denied all 11 motions and r... http://www.orlytaitzesq.com/?p=8034
Case: 09-3403 Document: 003110135281 Page: 35 Date Filed: 05/07/2010
02.17.10
Your honor,
Plaintiffs in the above captioned case have bombarded the defendants and the courts with hundreds and, by
now, probably thousands of pages of pleadings of motions and requests for judicial notices, most of which had
absolutely nothing to do with the case at hand and the order to show cause that was directed towards the
plaintiffs. I am asking for a judicial notice of one page only. The attached one page order from the Third
Circuit Court of Appeals denying all 11 motions and requests for judicial notice, shows that the Third Circuit
Court of Appeals does not see any emergency, that the plaintiffs claim and does not see any relevance in all of
those voluminous filings. It is consistent with the findings of this court and it is an indication, that if the Court
of Appeals didn’t see any emergency now, it is reasonable to believe that there was no emergency half a year
ago, when your Honor denied plaintiffs request for the temporary restraining order against the defendants. It
strengthens the defendant’s position that indeed, there was no emergency or damages to the plaintiffs, rather
Attorney Philip Berg has filed this legal action with an improper purpose of harassing and trying to silence the
defendants, when I posted on my web site true printout from the San Bernardino division of the Superior
Court in CA of ten felony convictions of forgery and grand theft committed by Berg’s assistant Lisa Liberi.
This publication was done with a proper purpose of alerting the public that any piece of evidence, any
document coming out of Berg’s office is suspect of forgery, due to Liberi’s background and particularly in
light of the fact that Mr. Berg has filed Affidavits of Kenyan birth of Barack Obama in Eastern District of PA,
Third Circuit Court of Appeals and the Supreme Court of the United States and refused to show the original
documents to me or to a forensic document expert. While the media has named me the “Queen of the
Birthers” or the leader of the Birther movement, due to my legal actions to unseal the original vital records of
Mr. Obama and get a declaratory relief on the meaning of the term Natural born citizen, as it applies to the
article 2, section 1 requirement for presidency, I am concerned that Mr. Berg’s actions in using a convicted
document forger as a legal assistant, and refusing to provide original documents, does not help the cause or the
underlying legal action, but rather undermines and muddies it and will destroy it, when it will be heard on the
merits. It is also an indication, that as an attorney and president of the Defend Our Freedoms Foundation, I
was justified in alerting the public regarding the fact that on 04.11.09 my former volunteer web master Lisa
2/18/2010 2:43 PM
Important. Third Circuit Court of Appeals has denied all 11 motions and r... http://www.orlytaitzesq.com/?p=8034
Case: 09-3403 Document: 003110135281 Page: 36 Date Filed: 05/07/2010
Ostella has changed the passwords and locked me out of the original DefendOurFreedoms website, and
from that date any and all donations received on that old web site did not benefit my foundation, but rather
benefit Ostella personally, as well as Attorney Philip Berg, indirectly his assistant Lisa Liberi, as well as talk
show host Evelyn Adams, all of whom Ostella started promoting on the web site for my foundation after
locking me out.
While most of the plaintiffs are lay persons, Berg is a licensed attorney and his actions were direct violation of
rules of professional ethics.
Respectfully submitted,
02/09/2010 ORDER (MCKEE and RENDELL, Circuit Judges) denying Motion by Appellants for Expedited
Ruling or to File a Restraining Order, requests Appellants for Judicial Notice, Emergency Motion
by Appellants to Expedite Interlocutory Appeal and Expedite Ruling on Appellants Pending
Motion, filed. Panel No.: BCO-039-E. McKee, Authoring Judge. (SLC)
Cc Philip Berg
Cc Neil Sankey
Cc Linda Belcher
Contact Orly!
email: dr_taitz@yahoo.com Urgent? Call: 949-683-5411
Recent Posts
Important. Third Circuit Court of Appeals has denied all 11 motions and requests for judicial notice filed
by Attorney Philip Berg in his attacks on Attorney Orly Taitz and others
8032
8030
8027
8025
2/18/2010 2:43 PM
Case: 09-3403 Document: 003110135281 Page: 37 Date Filed: 05/07/2010
EXHIBIT “D”
02.17.10
Request for Leave of Court to file and docket a 02.09.10. Third Circuit Court of
Appeals order denying all 11 Motions and requests for judicial notice filed by Philip Berg
on behalf of Appellants/Plaintiffs in Liberi et al v Taitz et al.
Case: 09-3403 Document: 003110135281 Page: 39 Date Filed: 05/07/2010
Your honor,
Plaintiffs in the above captioned case have bombarded the defendants and the courts
with hundreds and, by now, probably thousands of pages of pleadings of motions and
requests for judicial notices, most of which had absolutely nothing to do with the case at
hand and the order to show cause that was directed towards the plaintiffs. I am asking for
a judicial notice of one page only. The attached one page order from the Third Circuit
Court of Appeals denying all 11 motions and requests for judicial notice, shows that the
Third Circuit Court of Appeals does not see any emergency, that the plaintiffs claim and
does not see any relevance in all of those voluminous filings. It is consistent with the
findings of this court and it is an indication, that if the Court of Appeals didn’t see any
emergency now, it is reasonable to believe that there was no emergency half a year ago,
when your Honor denied plaintiffs request for the temporary restraining order against the
defendants. It strengthens the defendant’s position that indeed, there was no emergency
or damages to the plaintiffs, rather Attorney Philip Berg has filed this legal action with
an improper purpose of harassing and trying to silence the defendants, when I posted on
my web site true printout from the San Bernardino division of the Superior Court in CA
of ten felony convictions of forgery and grand theft committed by Berg’s assistant Lisa
Liberi. This publication was done with a proper purpose of alerting the public that any
piece of evidence, any document coming out of Berg’s office is suspect of forgery, due to
Liberi’s background and particularly in light of the fact that Mr. Berg has filed Affidavits
of Kenyan birth of Barack Obama in Eastern District of PA, Third Circuit Court of
Appeals and the Supreme Court of the United States and refused to show the original
documents to me or to a forensic document expert. While the media has named me the
“Queen of the Birthers” or the leader of the Birther movement, due to my legal actions to
unseal the original vital records of Mr. Obama and get a declaratory relief on the meaning
of the term Natural born citizen, as it applies to the article 2, section 1 requirement for
presidency, I am concerned that Mr. Berg’s actions in using a convicted document forger
as a legal assistant, and refusing to provide original documents, does not help the cause or
the underlying legal action, but rather undermines and muddies it and will destroy it,
when it will be heard on the merits. It is also an indication, that as an attorney and
president of the Defend Our Freedoms Foundation, I was justified in alerting the public
regarding the fact that on 04.11.09 my former volunteer web master Lisa Ostella has
changed the passwords and locked me out of the original DefendOurFreedoms website,
and from that date any and all donations received on that old web site did not benefit my
foundation, but rather benefit Ostella personally, as well as Attorney Philip Berg,
indirectly his assistant Lisa Liberi, as well as talk show host Evelyn Adams, all of whom
Ostella started promoting on the web site for my foundation after locking me out.
While most of the plaintiffs are lay persons, Berg is a licensed attorney and his actions
were direct violation of rules of professional ethics.
Case: 09-3403 Document: 003110135281 Page: 40 Date Filed: 05/07/2010
Respectfully submitted,
02/09/2010
ORDER (MCKEE and RENDELL, Circuit Judges) denying Motion by Appellants for
Expedited Ruling or to File a Restraining Order, requests Appellants for Judicial Notice,
Emergency Motion by Appellants to Expedite Interlocutory Appeal and Expedite Ruling
on Appellants Pending Motion, filed. Panel No.: BCO-039-E. McKee, Authoring Judge.
(SLC)
Cc Philip Berg
Cc Neil Sankey
Cc Linda Belcher
Thanks Lisa! I smelled a rat. I suspect you have seen her misleading Press Release. Do
I have your permission to use your remarks or will you or Phil make a statement that
refutes her story?
~~~~~~~~~~~~~~~~~~~~
02.17.10
Request for Leave of Court to file and docket a 02.09.10. Third Circuit Court of Appeals
order denying all 11 Motions and requests for judicial notice filed by Philip Berg on
behalf of Appellants/Plaintiffs in Liberi et al v Taitz et al.
Your honor,
Plaintiffs in the above captioned case have bombarded the defendants and the courts with
hundreds and, by now, probably thousands of pages of pleadings of motions and requests
for judicial notices, most of which had absolutely nothing to do with the case at hand and
the order to show cause that was directed towards the plaintiffs. I am asking for a judicial
notice of one page only. The attached one page order from the Third Circuit Court of
Appeals denying all 11 motions and requests for judicial notice, shows that the Third
Case: 09-3403 Document: 003110135281 Page: 42 Date Filed: 05/07/2010
Circuit Court of Appeals does not see any emergency, that the plaintiffs claim and does
not see any relevance in all of those voluminous filings. It is consistent with the findings
of this court and it is an indication, that if the Court of Appeals didn’t see any emergency
now, it is reasonable to believe that there was no emergency half a year ago, when your
Honor denied plaintiffs request for the temporary restraining order against the defendants.
It strengthens the defendant’s position that indeed, there was no emergency or damages
to the plaintiffs, rather Attorney Philip Berg has filed this legal action with an improper
purpose of harassing and trying to silence the defendants, when I posted on my web site
true printout from the San Bernardino division of the Superior Court in CA of ten felony
convictions of forgery and grand theft committed by Berg’s assistant Lisa Liberi. This
publication was done with a proper purpose of alerting the public that any piece of
evidence, any document coming out of Berg’s office is suspect of forgery, due to Liberi’s
background and particularly in light of the fact that Mr. Berg has filed Affidavits of
Kenyan birth of Barack Obama in Eastern District of PA, Third Circuit Court of Appeals
and the Supreme Court of the United States and refused to show the original documents
to me or to a forensic document expert. While the media has named me the “Queen of the
Birthers” or the leader of the Birther movement, due to my legal actions to unseal the
original vital records of Mr. Obama and get a declaratory relief on the meaning of the
term Natural born citizen, as it applies to the article 2, section 1 requirement for
presidency, I am concerned that Mr. Berg’s actions in using a convicted document forger
as a legal assistant, and refusing to provide original documents, does not help the cause or
the underlying legal action, but rather undermines and muddies it and will destroy it,
when it will be heard on the merits. It is also an indication, that as an attorney and
president of the Defend Our Freedoms Foundation, I was justified in alerting the public
regarding the fact that on 04.11.09 my former volunteer web master Lisa Ostella has
changed the passwords and locked me out of the original DefendOurFreedoms website,
and from that date any and all donations received on that old web site did not benefit my
foundation, but rather benefit Ostella personally, as well as Attorney Philip Berg,
indirectly his assistant Lisa Liberi, as well as talk show host Evelyn Adams, all of whom
Ostella started promoting on the web site for my foundation after locking me out.
While most of the plaintiffs are lay persons, Berg is a licensed attorney and his actions
were direct violation of rules of professional ethics.
Respectfully submitted,
02/09/2010
Case: 09-3403 Document: 003110135281 Page: 43 Date Filed: 05/07/2010
ORDER (MCKEE and RENDELL, Circuit Judges) denying Motion by Appellants for
Expedited Ruling or to File a Restraining Order, requests Appellants for Judicial Notice,
Emergency Motion by Appellants to Expedite Interlocutory Appeal and Expedite Ruling
on Appellants Pending Motion, filed. Panel No.: BCO-039-E. McKee, Authoring Judge.
(SLC)
Cc Philip Berg
Cc Neil Sankey
Cc Linda Belcher
On Mon, Feb 22, 2010 at 1:11 AM, Sam Sewell <sams@bestselfusa.com> wrote:
Third circuit court of Appeals denied all 11 motions and requests for judicial notice filed
by Attorney Philip Berg in his relentless attacks on Attorney Orly Taitz and others
EXHIBIT “E”
The articles posted represent only the opinion of the writers, do not necessarily represent the opinion of Dr. Taitz, ESQ, and Dr. Taitz, ESQ has no means of
checking the veracity of all the claims and allegations in the articles.
2/21/2010 12:46 AM
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/
Case: 09-3403 Document: 003110135281 Page: 46 Date Filed: 05/07/2010
orlytaitzesq.com
newsletter@orlytaitzesq.com
Fax: 949-766-7603
Phone: 949-683-5411
RSM, CA 92688
29839 Santa Margarita
Dr. Orly Taitz, ESQ.
CONTACT INFO:
Home
02/09/2010 ORDER (MCKEE and RENDELL, Circuit Judges) denying Motion by Appellants for
Expedited Ruling or to File a Restraining Order, requests Appellants for Judicial
Notice, Emergency Motion by Appellants to Expedite Interlocutory Appeal and
Expedite Ruling on Appellants Pending Motion, filed. Panel No.: BCO-039-E.
McKee, Authoring Judge. (SLC)
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/
Case: 09-3403 Document: 003110135281 Page: 47 Date Filed: 05/07/2010
02.17.10
Attention Honorable Eduardo Robreno
Request for Leave of Court to file and docket a 02.09.10. Third Circuit Court of
Appeals order denying all 11 Motions and requests for judicial notice filed by
Philip Berg on behalf of Appellants/Plaintiffs in Liberi et v Taitz et al.
Your honor,
Plaintiffs in the above captioned case have bombarded the defendants and the
courts with hundreds and, by now, probably thousands of pages of pleadings of
motions and requests for judicial notices, most of which had absolutely nothing to
do with the case at hand and the order to show cause that was directed towards the
plaintiffs. I am asking for a judicial notice of one page only. The attached one page
order from the Third Circuit Court of Appeals denying all 11 motions and
requests for judicial notice, shows that the Third Circuit Court of Appeals does
not see any emergency, that the plaintiffs claim to have and does not see any
relevance in all of those voluminous filings. It is consistent with the findings of this
court and it is an indication, that if the Court of Appeals didn’t see any emergen!
cy now, it is reasonable to believe that there was no emergency half a year ago,
when your Honor denied plaintiffs request for the temporary restraining order
against the defendants. It strengthens the defendant’s position that indeed, there
was no emergency or damages to the plaintiffs, rather Attorney Philip Berg has
filed this legal action with an improper purpose of harassing and trying to silence
the defendants, when I posted on my web site true printout from the San
Bernardino division of the Superior Court in CA of ten felony convictions of
forgery and grand theft committed by Berg’s assistant Lisa Liberi. This
publication was done with a proper purpose of alerting the public that any piece
of evidence, any document coming out of Berg’s office is suspect of forgery, due to
Liberi’s background and particularly in light of the fact that! Mr. Berg has filed
in Ea stern District of PA, Third Cicuit Court of Appeals and the Supreme Court
of the United States affidavits of Kenyan birth of Barack Obama and refused to
show the original documents to me or to a forensic document expert. While the
media has named me the “Queen of the Birthers” or the leader of the Birther
movement, due to my legal actions to unseal the original vital records of Mr.
Obama and get a declaratory relief on the meaning of the term Natural born
citizen, as it applies to the article 2, section 1 requirement for presidency, I am
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/
Case: 09-3403 Document: 003110135281 Page: 48 Date Filed: 05/07/2010
concerned that Mr. Berg’s actions in using a convicted document forger as a legal
assistant, and refusing to provide original documents, does not help the cause or
the underlying legal action, but rather undermines and muddies it and will
destroy it, when it will be heard on the merits. It is also an indication, that as an
attorney and president of the Defend Our Freedoms Foundation, I was justified in
alerting the public regarding the fact ! that on 04.11.09 my former volunteer web
master Lisa Ostella has changed the passwords and locked me out of the original
DefendOurFreedoms website, and from that date any and all donations received
on that old web site did not benefit my foundation, but rather benefit Ostella
personally, as well as Attorney Philip Berg, indirectly his assistant Lisa Liberi, as
well as talk show host Evelyn Adams, (Momma E) all of whom Ostella started
promoting on the web site for my foundation after locking me out.
While most of the plaintiffs are lay persons, Berg is a licensed attorney and his
actions were direct violation of rules of professional ethics.
Respectfully submitted,
Cc Philip Berg
Cc Neil Sankey
Cc Linda Belcher
Cc Ed and Karen Hale
Category: Uncategorized
Case: 09-3403 Document: 003110135281 Page: 49 Date Filed: 05/07/2010
EXHIBIT “2”
19
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Author Comment
Ed Hale Dr Taitz trun the tables on Berg - Read this Quote Reply
No. 09 3403
UNITED STATES COURT OF APPEALS
May 6, 2010 - 12:33AM FOR THE THIRD CIRCUIT
____________________
LISA LIBERI, et al.,
Plaintiffs-Appellants,
vs.
ORLY TAITZ, et al.,
Defendant-Appellee.
__________________
District Court No. 09_cv_01898_ECR
Eastern District of Pennsylvania
__________________
Motion to Strike and/or Extension of Time to File Sur Reply by
Appellees in Response to Appellants’Reply
__________________
DR. ORLY TAITZ, ESQ.
CSB #223433
Attorney Pro Se &
Attorney for Defend Our Freedoms Foundation
29839 S. Margarita Pkwy. Rancho Santa Margarita CA 92688
ph. 949-683-5411
fax 949-586-2082
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I. INTRODUCTION
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Case: 09-3403 Document: 003110135281 Page: 53 Date Filed: 05/07/2010
from Kenya, regarding Obama’s birth there. Taitz has asked Berg to
allow her and a forensic document expert to examine the originals of
those affidavits, as there was a high likelihood of forgery due to
Liberi’s recent convictions. Taitz has also advised Berg that he may
want to bring an account to review the donations received in light of
Liberi’s recent convictions of grand theft. Any attorney with any
measure of integrity and respect for the law and the system of
justice, with a drop of professional ethics in his blood would have
disassociated himself from an individual of such questionable past
and would advise this court and other courts of a possibility of forgery
in the documents submitted. Instead, Berg has filed an absolutely
frivolous legal action against all of the appellees, seeking to keep
them silent, he filed a ridiculous legal action for nearly a billion
dollars and continued bombarding appellees with hundreds and
hundreds of pages of garbage, with no connection to the case. Berg
teamed up not only with Liberi, but also with Ostella and a couple of
other individuals with past convictions or indictments of forgery and
fraud. Currently Berg and his associates are advertising an eligibility
and anti-healthcare bill march on Washington and soliciting donations
nationwide for that march. While Taitz shares concerns regarding the
eligibility and the Health care bill on Constitutional grounds, she is
concerned about individuals like Berg, Liberi and Ostella causing real
damage to those issues and to the public at large. Taitz simply
became an attorney, who exposed Berg and his associates, their
past and dealings, she is an attorney in the way, and Berg has rubber
stamped pleadings coming from his associates with one goal of
attacking Taitz and taking heat of himself and possible criminal
prosecution of himself, Liberi and Ostella.
Berg is fully aware that Taitz never violated any orders and Berg’s
allegations are nothing but fraud on the court. For example, Berg
knows that Taitz does not own a web site repubex, that she used that
website for a couple of weeks over a year ago, when Ostella locked
her out of her website. Taitz has presented this information a year
ago, (exhibit Motion to dismiss Due to Lack of Jurisdiction exhibit 3)
Berg knows fully well that Taitz had nothing to do with that web site
for over a year and used her own web site OrlyTaitzEsq.com, yet Berg
continues to defraud the court by falsely accusing Taitz of violating
orders. Taitz does not want to waste the time of this court with piles
of documents, but rather submits a couple of documents, that
illustrate the actions of Liberi. Exhibit 1 05.28.2009 Opposition to
TRO, which contains Liberi’s criminal record, showing multiple recent
convictions, and exhibit 4 testimony of officer Liebrich during Liberi’s
bail hearing regarding Liberi’s threats against her sister Cheryl
Richardson. The transcript states that when Cheryl Richardson
started cooperating with police and implicated Liberi in the case
being tried and provided information regarding Liberi’s thirteen prior
criminal charges, Liberi has stated in recorded phone call from jail,
that she wants to have her sister framed, arrested and she wants to
spread the word in the prison population, that her sister is a rat. She
proceeded telling her
husband “you know what they do in prison to rats”. When asked by
the court “what happens when inmates discover that another inmate
is a snitch?”officer Liebrich responded “ There is what is known as a
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Case: 09-3403 Document: 003110135281 Page: 54 Date Filed: 05/07/2010
FRAP Rule 27(a)(4) states “A reply must not present matters that do
not relate to the response.”Appellants’entire reply brief is largely an
attempt to manipulate Rule 27 by claiming anything and everything
including false allegations of kidnapping children and unauthenticated
exhibits of hearsay are relevant to rebut the allegation that
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Case: 09-3403 Document: 003110135281 Page: 55 Date Filed: 05/07/2010
As noted, appellee Dr. Taitz is horrified and shocked that she is being
accused by appellants including an attorney still in good standing of
conspiracy to kidnap children and commit perjury. Appellees are
entitled to a full response of these hideous allegations if they are not
stricken.
This court should sua sponte sanction attorney Berg and appellants.
Berg has put his signature on these horrific slanderous allegations
against Dr. Taitz. Berg has teamed up with felons in slandering Taitz
without any basis with a goal of silencing her. Berg is fully aware that
Taitz never violated any orders, never did anything illegal, never
caused any harm to appellants. Berg and appellants are acting with
depraved indifference to the truth and has harmed Taitz, her
reputation, her family, have caused severe emotional distress and
severe financial damage in having to fly to Philadelphia to the District
Court hearing, having to read thousands of pages of defamation that
they threw at her, having to respond to numerous motions and
requests for judicial notice. In this court alone Berg has filed 11
(eleven) motions and requests for judicial notice with hundreds and
hundreds of pages completely unrelated to the interlocutory appeal
of the decision by judge Robreno made in August of 2009. Berg was
fully aware that what he is filing, is nothing but slander and unrelated
material, yet he did it to harass Taitz into silence and to prejudice the
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VI CONCLUSION
State Texas
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State Texas
I didn't follow Berg for the simple fact he was goofy after Sept 11th,
always considered him quite the lunatic.
May 6, 2010 - 3:04PM
After reading this I have to say that every single one that seems some
how associated with him are lunatics too?
Quote:
State Truth
Ed Hale Berg got caught with his pants down. Quote Reply
Dr. Taitz pointed out the error in Berg filing over the 10 pages and
now Berg want the court to say that it was ok. Here is Berg motions
May 6, 2010 - 3:25PM (after the fact)
1
U.S. District Court,
Eastern District of Pennsylvania Case Number: 09-cv-01898 ECR
Court of Appeals Case Number: 09-3403
UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
_____________ Ο _____________
LISA LIBERI, et al,
Plaintiffs’– Appellants’,
v.
ORLY TAITZ, et al,
Respondents’–Appellees’.
____________ Ο _____________
APPELLANTS’MOTION FOR LEAVE OF COURT TO EXCEED THE PAGE
LIMIT IN THEIR REPLY TO APPELLEES, ORLY TAITZ AND DEFEND
OUR FREEDOMS FOUNDATIONS, INC. OPPOSITION TO APPELLANTS
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Only one problem here for Berg. He states that DR. Taitz lied to the
court and yet he has not presented one ounce of proof other that
shooting off his big mouth claiming all kinds of stuff.
Dr. Taitz laid it on him with proof that he was lying to the court. Berg
need to get out of the lawyer business because he is such a poor one.
Now he is wanting to lead a march to DC. Wonder how much money
will they get for this one?
State Texas
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berg1 - Window Title
Case: 09-3403 Document: 003110135281 Page: 62 Date Filed: 05/07/2010
CERTIFICATE OF SERVICE
_____________________
Opposition; Request to Strike Taitz Motion to Strike filed May 7, 2010; and
Request for Sanctions and Attorney Fees was served upon Appellees, this 7th day
Orly Taitz
Defend our Freedoms Foundation, Inc. (unrepresented)
26302 La Paz Ste 211
Mission Viejo, CA 92691
Email: dr_taitz@yahoo.com
And by Fax to (949) 766-7603
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Case: 09-3403 Document: 003110135281 Page: 64 Date Filed: 05/07/2010
Neil Sankey
The Sankey Firm, Inc. a/k/a The Sankey Firm (unrepresented)
Sankey Investigations, Inc.
2470 Stearns Street #162
Simi Valley, CA 93063
Email: nsankey@thesankeyfirm.com
Ed Hale
Caren Hale
Plains Radio
KPRN
Bar H Farms
1401 Bowie Street
Wellington, Texas 79095
Email: plains.radio@yahoo.com; barhfarms@gmail.com;
ed@barhfarnet; and ed@plainsradio.com
________________________
s/ Philip J. Berg
PHILIP J. BERG, ESQUIRE
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