Lisa Liberi ET AL Request For Injunction Third Circuit Appeals Court

U.S.
District Court,
Eastern District of Pennsylvania Case Number: 09-cv-1898-ECR
Court of Appeals No. __________
UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT
_____________ Ο _____________
LISA LIBERI, et al,
Petitioner – Appellant,
v.
ORLY TAITZ, et al,
Respondents – Appellee.
_____________ Ο _____________
EMERGENCY MOTION FOR AN IMMEDIATE INJUNCTION

PENDING RESOLUTION OF THE PETITIONER’S APPEAL
_____________________
Counsel: PHILIP J. BERG, ESQUIRE

LAW OFFICES OF PHILIP J. BERG
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
(610) 825-3134
Identification No. 09867
NOW COMES Petitioners, by and through their undersigned Counsel,
Philip J. Berg, Esquire, hereby make this Motion for an Emergency Injunction to
Enjoin Respondent, Orly Taitz, et al from publication and distribution of Petitioner
Lisa Liberi’s Social Security number and private information, harassment of the
Petitioners’; invading Petitioners’ Privacy, including but not limited to Intrusion
upon One’s Seclusion; Public Disclosure of Private Facts; Use of Another’s Name
or Likeness; False Light in the Public Eye; Slander; Libel and many others in
violation of Pennsylvania Privacy Acts 74 Pa. Stat. Ann. § 201 (West 2006);
violation of California Privacy Laws, California Civil Code 1798 et sequitur,
amongst many others and to enjoin Respondent’s Edgar Hale, Caren Hale and
Linda Sue Belcher from any further threats or threatening statements veered at
Petitioners’ witnesses. Threatening witnesses or witness intimidation is in
violation of 18 U.S.C. §1512; Pennsylvania Statute 18 Pa.C.S. § 4951.
Intimidation and/or threatening of Petitioners’ witnesses and potential witnesses is
a felony in the first degree, see 18 Pa.C.S. § 4952; Texas. Penal Code § 36.06, in
Texas threatening a witness is a felony in the third degree.
I. REQUEST FOR EMERGENCY RELIEF
1. In or about February 2009, Respondent, Orly Taitz, et al [hereinafter
“Taitz”] made the threat to take Petitioner Philip J. Berg, Esquire [hereinafter
“Berg”] down and to do so she would destroy his Paralegal, Petitioner Lisa Liberi
[hereinafter “Liberi”] and get rid of her. It should be noted, Taitz is a licensed
Attorney in the State of California.
2. Taitz then accused Liberi and her husband, all over the internet and by mass
emailing, of having accounts set up on Berg’s foundation website and were
diverting funds from Berg. Berg immediately made a public statement that no one
had stolen from him and he was not a foundation.
3. Shortly thereafter, Taitz put out a criminal record claiming it to belong to
Liberi and stated that Liberi had been convicted of, just to name a few, Identity
Theft; Manufacturing or altercation of Police Reports; Manufacturing or Altering
credit Reports; that Liberi was stealing money from Berg to pay her Twenty-One
Thousand [$21,000.00] Restitution Payments; that Liberi had a long lengthy
criminal record going back to the 1990’s; that Liberi and Petitioner Lisa Ostella
[hereinafter “Ostella”] had “hacked” her website and her PayPal Account stealing
donations; that Ostella had “hijacked” her [Taitz] website; filed false police reports
against Liberi and Ostella attempting to have them arrested on her false and
unfounded allegations; filed falsified criminal reports against Liberi and Ostella
with the Federal Bureau of Investigations [FBI]; Taitz falsely told law enforcement
that she and Berg worked together and fundraised together; Taitz put out that
Petitioners’ were all Obama Supporters calling them “Obots” and then stated that
President Obama and his Supporters [Obots] needed to be “purged”, all the time
knowing her statements were false and dangerous..
4. On or about April 17, 2009, Taitz put out what she called her “Dossier #6”.
Taitz Dossier #6 was all about Liberi. In fact, in Dossier #6 Taitz put Liberi’s full
Social Security number; date of birth; and other private personal information.
Dossier #6 is attached hereto as EXHIBIT “A” first two (2) pages are screen
shots showing Liberi’s full social security number is in two (2) locations of
Taitz’s website and blog area as of August 15, 2009, dossier 6 begins with page
three (3) and Liberi’s full social security number located in dossier 6 is on the
last page of the Exhibit. It should be noted, dossier #6 appears on four (4)
separate web links of Taitz website and blog, http://www.orlytaitzesq.com/blog1/?p=8;
http://orlytaitzesq.com/dossier-006.htm; http://www.orlytaitzesq.com/blog1/?cat=29; and
http://orlytaitzesq.com/drorlytaitzesq/documentation/Dossier6.doc
5. Taitz had this Dossier #6 sent out all over the internet requesting all websites
to post her Dossier #6, emailed to in excess of One Hundred and Forty Thousand
[140,000] individuals and businesses including internationally by her own
admission, and mailed to various law enforcement agencies, military officers, etc.
In this Dossier #6, is an email from a licensed private investigator, Respondent
Neil Sankey [hereinafter “Sankey”] who emailed Liberi’s full Social Security
number and other personal identifying information to Taitz and also a reporter with
World Net Daily.
6. Thereafter, Taitz had posted on her website and all over the internet for
everyone to call the Santa Fe Probation Department because Liberi was on
probation and not allowed around credit cards. Taitz supplied the phone number
for this location.
7. In or about the end of April early May 2009, Taitz began accusing Ostella of
locking her [Taitz] out of her website; hijacking her website; and stealing
donations coming into her company, Defend our Freedoms Foundations, Inc., all of
which she again knew was false. Ostella owned the domain names and Ostella was
paying for the server the website was sitting on, which was her [Ostella’s] account.
8. Petitioners’ filed suit on May 4, 2009, which Taitz was served with on May
5, 2009; Respondent Linda S. Belcher [hereinafter “Belcher”] on May 5, 2009 and
Respondent Edgar Hale [hereinafter “Hale”] on or about May 6, 2009. Along with
service of the Summons and Complaint was a Motion for an Emergency Injunction
or Restraining Order.
9. From April 17, 2009 through June 27, 2009, Taitz has placed on her blog
approximately twenty [20] articles regarding Liberi, Berg, Adams and Ostella,
which are degrading, harassment of the Petitioners’; invading Petitioners’ Privacy,
including but not limited to Intrusion upon Petitioner’s Seclusion; Public

Disclosure of Private Facts; Use of Another’s Name or Likeness; False Light in the
Public Eye; Slander; Libel and many others in violation of Pennsylvania Privacy
Acts 74 Pa. Stat. Ann. § 201 (West 2006); violation of California Privacy Laws,
California Civil Code 1798 et sequitur. See EXHIBITS “A-V”.
10. Taitz failed to answer the complaint on May 26, 2009 as set by the Court
and when she did respond late only stated, “Taitz and Defend our Freedoms
Foundations, Inc. deny all allegations,” therefore waiving all their affirmative
defenses. All the other Respondents did the same thing and filed an Answer
stating they objected to venue and denied all the allegations, also, waiving all their
affirmative defenses.
11. The Court set a Status Hearing and Scheduling Conference for June 25,
2009. Meanwhile, Petitioners’ filed again for their Motion for an Emergency
Injunction or Restraining Order.
12. On June 22, 2009 Taitz published Liberi’s mother’s maiden name, where
Liberi was born and other personal identifying information. See EXHIBIT “T”.
13. On June 25, 2009, the Hearing took place where the Court denied
Petitioners’ Motion for an Emergency Injunction or Restraining Order and gave
Taitz, who was present and the other Respondents’ Attorney very strong words.
The Court stated Taitz was not to continue the publication or republication of
Liberi’s Social Security number or other personal identifying information and gave
guidelines in which the Respondents were to conduct themselves. The Court then
issued an Order with a footnote stating that Respondents were to conduct
themselves as discussed in Court. In addition the Court Ordered that no one was to
file a Motion without Leave of Court and Leave of Court could be sought by letter
format and the Court issued Rules upon Petitioners’ to Show Cause why the Case
Should Not be Transferred or Split Up and Transferred and Petitioners’ were to
support their Responses with Affidavits.
14. The evening of June 25, 2009, Hale and Belcher had a radio show on Hale’s
radio program, Plains Radio. During this show Hale and Belcher began making
threatening remarks to Petitioners’ witnesses and statements that were considered
intimidating our witnesses. Belcher and Hale stated the following: Please note:
Linda Starr is an a/k/a of Linda Sue Belcher
Linda Starr: “Well I feel like the Judge threw Berg a bone today.
Because he said, ok, you made all of these allegations and I'm gonna
wait and give you a chance to support the allegations you made with
proof and evidence. And sworn affidavits with real identities. Not
fake IDs. They are gonna have to put their real identities out
there.” [emphasis added]
Ed Hale: “Yeah and I'm gonna tell you something. When these
affidavits come in that they claim that they have. These people's
names are gonna be known. Their addresses are gonna be known.
And you know something, we are gonna know who they are. And
you know what; we will go after them with a vengeance. And prove
that they are liars also.” [emphasis added]
Caryn: “Who are you talking about?”

Ed Hale: “All of these affidavits that Berg claims he has. We are
talking about...”
Caryn: “From just?...”
Linda Starr: “Caryn here is the deal. They are not going to be
allowed to use usernames. In order to produce sworn affidavits in
court they are gonna be notarized they are gonna have to use their real
names.”
Caryn: “Ok.”
Ed Hale: “Yeah, there is no more hiding.”
Linda Starr: “Then we can identify them.”
Caryn: “And these are people that are using their user names that are
making all of these statements.”
Ed Hale: “That's correct.”
Linda Starr: “That's right”.
Caryn: “Ok.”
Ed Hale: “But now they have to come out from behind the
anonymity of the internet. And they have to come out and face us.
And you know something...?”
Caryn: “And they will probably refuse to do it for Berg, huh?”
Ed Hale: “Let me tell you something. It’s easy as hell...”
Linda Starr: “Ron Polarik's ID is gonna be exposed.”
Ed Hale: “Let me tell you something...”
Linda Starr: “All these people that want to know who he is, it's
gonna come out who he is.”
Ed Hale: “Let me tell you something and listen to this.”
Caryn: “We're listen...”
Ed Hale: “This is what is hilarious in a way. The people that have

told Berg, on the Internet, oh let's just use Chilieman for an example.
That Ed Hale wanted him to give him money so he can give it to Berg.
Well let me tell you something. Chilieman, you can't hide no
more. You're gonna have to come out and say who you are and
where you are.” [emphasis added]
Linda Starr: “Oh we know who he is. We know...” [emphasis

added]
15. Several of Petitioners’ witnesses heard the above radio show and sent
Petitioners’ counsel letters and email stating they would not do an Affidavit or
Testify until the Court took action to protect the Petitioners’ and their witnesses
from danger and from the harassment Liberi and the other Petitioner’s have
endured.
16. Two [2] days later, on June 27, 2009, Taitz put a new post on her website
inferring Liberi had placed a “hit” or a “contract” on her sister and a year later she
was dead. Taitz further stated it is not inconceivable that Liberi would put a “hit”
or “contract” on an Attorney and her family, meaning her, who “outed” Liberi.
Taitz went on further calling for a Pathologist and asking for people who resided in
New Mexico to contact the Santa Fe Police Department, Detective Lopez, the
Santa Fe Probation Department, San Bernardino County District Attorney, and
gave all the phone numbers. See EXHIBIT “V”.

17. On July 16, 2009 the republication of Liberi’s Social Security number and
personal identifying information as well as Hale and Belcher’s threats to
Petitioner’s witnesses were sent to the Judge requesting leave to file another
Motion for an Emergency Injunction or Restraining Order.
18. A few days later, Berg’s witness in another case, who used a false name on
the internet to protect himself and his family, full name, his college degrees and
where he resided was placed on Edgar Hale’s website at www.plainsradio.com and
then Belcher placed this information on her own website at
www.obamacitizenshipdebate.org, following up with her threat that “Polarik”
would be exposed. On July 17, 2009, this information was also sent to the Court.
19. On or about July 27, 2009, Taitz set up a brand new website where under
“supporting documents” she again published Dossier #6 with Liberi’s full Social
Security number. Taitz also set her website and blog to refresh every three [3]
hours through the RSS feed which means the dossier #6 with Liberi’s full Social
Security number and other personal identifying information is republished on the
internet and appears at the top of the search engines when searches are performed
and resends to all the websites located on her RSS feed.
20. On July 27, 2009, the Court Ordered Petitioners’ Motion for an Emergency
Injunction or Restraining Order to be filed. The Court set Response dates of
August 3, 2009 and a Hearing date of August 7, 2009 at 10:30 a.m.

21. On August 3, 2009 Taitz filed a Response to the Emergency Injunction
claiming she would be out of the Country and requested a continuance. At the
same time, without Leave of Court as ordered by Judge Robreno, Taitz filed a
Motion for Sanctions against Petitioners’ and Petitioners’ counsel.
22. On or about July 30, 2009, Mr. Hoppe, Counsel for Hale,Defendants
Belcher, et al, Sankey, et al sent a letter to the Judge requesting a continuance and
raising the issue of personal jurisdiction. Counsel for the Plaintiffs’ responded and
cited out how the Court has personal jurisdiction over the Defendants’. Attached
to Counsel’s response was two (2) emails which Counsel for the Plaintiffs’
received regarding the witnesses concerns and fear after hearing the threats made
by Belcher and Hale. See EXHIBIT “W”. The Court denied Mr. Hoppe’s request
for the continuance.
23. Present at the Hearing on August 7, 2009 was Edgar Hale and his wife
Caren, Liberi, Ostella, Petitioner Evelyn Adams [hereinafter “Adams”], Berg’s
webmaster, and K. Strebel.
24. The Judge Ordered that the witnesses must give their names when testifying
however; their addresses could be supplied “Under Seal” to the Court. The Court
also Ordered the Hearing and all documents presented at the Hearing “Under
Seal.” The Hearing began at 10:30 a.m. and did not conclude until 1:15 p.m. Berg
did not put all witnesses on the stand due to the amount of Court time he was
permitted. Ostella and Liberi testified they were in fear for their lives and the lives
of their children and family. Liberi testified another woman has now begun using
her Social Security number in Houston, Texas and a copy of a lexis printout was
provided; Liberi explained to the Court that she was in the “Safe at Home”
program as a result of her and her son being the victims of severe domestic
violence crimes. The Court asked Liberi if that is when her Social Security
number was changed and Liberi testified yes, but that is all ruined now since Taitz
published her Social Security number, date of birth, mother’s maiden name, where
she was born and other personal identifying information. Liberi also testified that
it was against the law to publish a party’s Social Security number and a crime,
summary offense in the Commonwealth of Pennsylvania. Liberi also testified that
she never worked or applied for work with Taitz; did not give authorization for
Taitz to obtain her private confidential information, including but not limited to
Social Security number, date of birth, mother’s maiden name, etc.; and was
unaware until April 17, 2009 that Taitz had illegally obtained her private
confidential information. Taitz nor Sankey did not have any permissible purpose.
25. Berg informed the Court that Taitz had violated the Court’s Orders by re-
publishing Liberi’s Social Security number and other personal identifying
information; refusing to remove it and continuing to send it out.

26. The Court took the matter under advisement. On August 10, 2009, the Court
denied Petitioners’ Emergency Injunction, which is currently under appeal with
this very Court.
27. Testimony was also given in Court by Ostella that a Taitz follower, Pamela
Feldman has been posting threats against all Petitioners’ on her blog and tracing
Pamela Feldman led to a criminal conviction for “Murder.” Feldman was let off
early due to her psychiatric conditions, which followed with further violent crimes.
A. Petitioners’ Meet the Burden for this Court to Issue the

Emergency Injunction or Restraining Order:
28. The traditional standard for granting a Preliminary Injunction requires the
Petitioner to show that in the absence of its issuance he will suffer irreparable
injury and also that he is likely to prevail on the merits. It is recognized, however,
that a district court must weigh carefully the interests on both sides, Doran v.
Salem Inn, Inc., 422 U.S. 922, 925 (U.S. 1975), Adams v. Freedom Forge Corp.,
204 F.3d 475, 482 (3d Cir. Pa. 2000); AT&T v. Winback & Conserve Program,
Inc., 42 F.3d 1421, 1427 (3d Cir. 1994); Acierno v. New Castle Cty., 40 F.3d 645,
653 (3d Cir. 1994); In re Arthur Treacher's Franchisee Litig., 689 F.2d 1137, 1143
(3d Cir. 1982). If relevant, the Court should also examine the likelihood of
irreparable harm to the nonmoving party and whether the injunction serves the
public interest. See AT&T v. Winback, 42 F.3d at 1427. Petitioners are clearly
entitled to an Emergency Injunction or Restraining Order, pursuant to Rule 65 of
the Federal Rules of Civil Procedure, to halt the dangerous and illegal behaviors of
the Respondents’.
29. Specifically, this Court must grant Petitioners Injunction or Restraining
Order because: (1) there is reasonable probability that Petitioners will succeed on
the merits; (2) the Petitioners will suffer irreparable harm in the absence of relief;
(3) there will be little or no harm to the Respondents’ if relief is granted; and (4)
the public interest demands a grant of relief. See, e.g. Swartzwelder v. McNeilly,
297 F.3d 228, 234 (3rd Cir. 2002); Prison Health Servs., Inc. v. Umar, Civil Action
No. 02-2642, 2002 U.S. Dist. LEXIS 12267 (E.D. Pa. May 8, 2002). The
standards for a preliminary injunction and a TRO are the same. Mertz v. Houstoun,
155 F. Supp.2d 415, 425 n.12 (E.D. Pa 2001); Bieros v. Nicola, 857 F. Supp. 445,
446-47 (E.D. Pa. 1994). While the degree of probability of success on the merits
required to obtain such relief varies among Federal Courts of Appeals, the U.S.
Court of Appeals for the Third Circuit requires only a “reasonable likelihood” of
success. See Johnson & Johnson Orthopedics, Inc. v. Minnesota Mining & Mfg.
Co., 715 F. Supp. 110, 112 n.1 (D. Del. 1989). Petitioners easily meet each of the
requirements for an Injunction or Restraining Order.
30.
B. Standards to Be Applied on A Request for an Injunction:
31. This Court has jurisdiction and the inherent power to issue an Injunction to
enjoin Taitz from publication and distribution of Petitioner Lisa Liberi’s Social
Security number and private information, harassment of the Petitioners’; invading
Petitioners’ Privacy, including but not limited to Intrusion upon One’s Seclusion;
Public Disclosure of Private Facts; Use of Another’s Name or Likeness; False
Light in the Public Eye; Slander; Libel and many others and to enjoin
Respondent’s Edgar Hale, Caren Hale and Linda Sue Belcher from any further
threats or threatening statements veered at Petitioners’ witnesses. pending
Petitioners the outcome of their Appeal.
32. The standard to be applied in regards to an Emergency Injunction requires
the Court to consider: (1) the threat of irreparable harm if the stay is not granted;
(2) the absence of harm to opposing parties if the stay or temporary injunction is
granted; (3) the likelihood of success, and (4) whether there was any prior ruling
on the application by another judge of a lower court. Rosker v. Goldberg, 448 U.S.
1306, 1308 (1980).
33. The lower Court in this case simply denied Petitioners’ request for an
Injunction or Restraining Order. The lower Court even denied Petitioner Liberi’s
request for an Order to obtain a new Social Security number in attempts to give her
some type of protection, see EXHIBIT “X”.

C. Likelihood of Success on the Merits of the Writ:
34. Of the four (4) considerations, the likelihood of success is arguably the most
important. Here Petitioners’ have a great probability of succeeding on the Merits
of the Case.
35. First, all of the Respondents waived any affirmative defenses, thus no issues
remain for the trial Court. For these reasons, the consideration – a likelihood of
success on the merits – is strongly in favor of the Petitioner. Moreover, just to
name a few things, according to the tort standards, Petitioners’ will clearly be
successful on the merits of the case pertaining to the following:
i. Public Disclosure of Private Facts:
One who gives publicity to the private life of another is subject to

liability for invasion of his privacy if the matter publicized is of a kind
that would be highly offensive to a reasonable person and is not of
legitimate concern to the public. RESTATEMENT (SECOND) OF
TORTS § 652D (1977).
The key elements of this form of invasion of privacy are: (1)

publicity (2) of a highly objectionable kind (3) given to private facts
about another. Publicity is defined as a communication to the public
at large, or to so many persons that the matter is substantially certain
to become one of public knowledge.
Finally, the matter that is communicated must be such that a

reasonable person would feel justified in feeling seriously aggrieved
by its dissemination.
36. The above is clearly met. Liberi and all citizens of the United States expect
that their Social Security number, mother’s maiden name and place of birth are
maintained confidential. Taitz clearly violated and is responsible for this Tort as
Taitz published Liberi’s Social Security number, mother’s maiden name and where
she was born. Taitz also had Ostella’s mother’s maiden name, address, parents’
address, business associates, etc. all published by another party on her behalf.
Taitz further violated this when she published information pertaining to Liberi’s
sister’s death, which the family maintained confidential. See the Affidavit of
Shirley Waddell attached as EXHIBIT “Y”, all of which is be highly offensive to
a reasonable person. McNemar v. Disney Store, 91 F.3d 610, 616 (3d Cir. Pa.
1996) citing Bisbee v. John C. Conover Agency, Inc., 186 N.J. Super. 335, 452
A.2d 689, 691-92 (N.J. App. Div. 1982) (adopting 3 Restatement (Second) of Torts
§ 652D)
ii. False Light in the Public Eye:
One who gives publicity to a matter that places another before the
public in a false light is subject to liability for invasion of that person's
privacy. However, the false light in which the person was placed must
be highly offensive to a reasonable person, and it must have been
publicized either with knowledge that it was false or with a reckless
disregard concerning its truth or falsity. Id. at § 652E (1977).
37. Taitz placed Liberi, Ostella, Adams and Berg in a false light in the Publics
eye. Taitz falsely accused Liberi and Ostella of “hacking” her website and stealing
and diverting funds from her; inferred Liberi murdered her own sister; falsely
claimed Liberi had a criminal record going back to the 1990’s; falsely accused
Liberi of being convicted of amongst other things, Identity theft, Manipulating

Police Reports; Manipulating Credit Reports; Real Estate Fraud, etc; falsely
accused Berg and Adams of being “Obots” and calling for the purging of President
Obama and his supporters; Falsely accused Berg of lying to the Courts; falsely
accused Adams of diverting funds from her; etc. All of which was done with
malice and knowledge the information she (Taitz) was publicizing was completely
false and Taitz did so with a reckless disregard concerning its truth. All of which
is be highly offensive to a reasonable person.
iii. Intruding Upon Another's Seclusion:
One who intentionally intrudes upon either the solitude or private

affairs of another is subject to liability to the other for invasion of his
privacy if the intrusion would be highly offensive to a reasonable
person. Restat 2d of Torts, § 652B (1977).
38. Taitz had no permissible purpose to have a private investigator dig into
Liberi’s private and confidential affairs. Sankey had absolutely no right to illegally
obtain her Social Security number and send it out over the internet especially to a
reporter with World Net Daily. Taitz sent Liberi’s Social Security number and
other private confidential information across the internet, had it posted on other’s
websites, has it posted on her website in three (3) locations; sent it out by mass
email to over One Hundred and Forty Thousand [140,000] individuals and
businesses including Internationally by her own admission. Taitz also violated the
lower Court with the publishing of Ostella and Adams’ personal information.
Taitz further violated this when she published information pertaining to Liberi’s
sister’s death, which the family maintained confidential, all of which is be highly
offensive to a reasonable person. Kline v. Sec. Guards, Inc., 386 F.3d 246, 258 (3d
Cir. Pa. 2004) citing Harris v. Easton Publishing Co., 335 Pa. Super. 141, 483
A.2d 1377, 1383 (Pa. Super. Ct. 1984) (citing Marks v. Bell Tel. Co., 460 Pa. 73,
331 A.2d 424 (Pa. 1975); Vogel v. W.T. Grant Co., 458 Pa. 124, 327 A.2d 133, 136
(Pa. 1974)). At no time did Liberi give authorization to Taitz or Sankey to obtain
her private social security number, mother’s maiden name, date of birth, place of
birth, etc. and was unaware of what Taitz and Sankey were doing until the
publication of Taitz dossier #6.
39. As state in Summers v. Bailey, 55 F.3d 1564 (11th Cir. Ga. 1995) at 1566
”personal liberty includes not only freedom from physical restraint, but also the
legal right "to be let alone." Pavesich v. New England Life Ins. Co., 122 Ga. 190,
50 S.E. 68, 71 (1905).”
40. The Restatement recognizes that conduct that is repeated with such
persistence and frequency as to amount to a "course of hounding the plaintiff, [and]
becomes a substantial burden to his existence" may constitute an invasion of
privacy. § 652B, comment d. Pennsylvania courts, moreover, have specifically
refused to recognize a separate tort of harassment on the ground that an action for
invasion of privacy will ordinarily be an adequate remedy for highly offensive
conduct which unreasonably interferes with another's right to be left alone."

DeAngelo v. Fortney, 357 Pa. Super. 127, 515 A.2d 594, 596 (Pa. Super. 1986);
Speight v. Personnel Pool of America, Inc., 1993 U.S. Dist. LEXIS 9974, 1993
W.L. 276859 at 4-5 (E.D.Pa. July 20, 1993) (Padova, J.) (repeated harassment that
amounts to hounding and becomes a substantial burden to a plaintiff may be an
intrusion upon seclusion). Other courts including Florida also recognize this
general principle. See, e.g., Tucker v. American Employers' Insurance, 171 So. 2d
437 (Fla. Dist. Ct. Ap. 2nd 1965) (genuine issue of material fact existed as to
whether defendant's shadowing of plaintiff constituted invasion of privacy);
Summers v. Bailey, 55 F.3d 1564, 1567 (11th Cir. 1995) (conduct constituting
offensive, frightening and unreasonable surveillance of plaintiff's private affairs
supports cause of action for intrusion into seclusion).
41. In defamation cases involving commercial speech by non-media Defendants
about private individuals, even when that speech touches on matters of public
concern, the speech is not entitled to elevated levels of First Amendment
protection, and therefore proof of falsity is not required, Fanelle v. LoJack Corp.,
2000 U.S. Dist. LEXIS 17767 (E.D. Pa. Dec. 7, 2000) at *28.
42. “In Pennsylvania, the right to privacy is the qualified right to be left alone,
the violation of which is an actionable tort when the alleged invasion of that right
is unlawful or unjustifiable. See Harris by Harris v. Easton Pub. Co., 335 Pa.
Super. 141, 152, 483 A.2d 1377, 1383 (1984). "'The gist of privacy is the sense of
seclusion, the wish to be obscure and alone, and it is a trespass to abuse these
personal sensibilities.'" Id. (quoting Bennett v. Norban, 396 Pa. 94, 99, 151 A.2d
476, 479 (1959)). An action for invasion of privacy is not one tort but is instead
comprised of the following four separate torts: (1) intrusion upon seclusion; (2)
appropriation of name or likeness; (3) publicity given to private life; and (4)
publicity placing a person in false light. See id. "The Restatement [(Second) of
Torts §§ 652A-652E (1977)] most ably defines the elements of invasion of privacy
as that tort has developed in Pennsylvania." Id.” Speight v. Personnel Pool of Am.,
Inc., 1993 U.S. Dist. LEXIS 9974, 15-19 (E.D. Pa. July 20, 1993) at *18, *19
43. Petitioners’ will continue to suffer irreparable injury that the Court cannot
fully compensate should Petitioners’ prevail. The damages done with Liberi’s
Social Security number and other personal information will not stop because this
Court case concludes. Instead, it can take Liberi years to re-establish herself, even
if this Court Orders a new Social Security number for her. The identity theft and
security damages being suffered by Liberi cannot be undone nor can it be
prevented or fully rectified by final judgment after trial. Therefore, an Injunction
or Restraining Order is imperative. See International Bhd. of Teamsters v. Local,
810, 19 F.3d 786, 794 (2d Cir. 1994); Deerfield Med. Ctr. v. City of Deerfield
Beach, 661 F.2d 328, 338 (5th Cir. 1981) (injury is irreparable if it cannot be
undone by monetary damages). Roland Mach. Co. v. Dresser Indus., Inc., 749 F.2d
380, 386 (7th Cir. 1984) (irreparable harm is harm that cannot be prevented or fully
rectified by final judgment after trial).
44. Thus, the likelihood of success weighs heavily in favor of the Petitioners’.
45. All of the Respondents’ illegal behaviors have been substantial and would be
highly offensive to the ‘the ordinary reasonable person’. In addition, the intrusion
into the private affairs and privacy of the Petitioners’ have caused the Petitioners’
mental suffering, shame and humiliation, as it would cause to any person of
ordinary sensibilities.
D. Irreparable Harm if the Injunction is NOT Granted:
46. The irreparable harm requirement is met if a Petitioner demonstrates a
significant risk that he or she will experience harm that cannot adequately be
compensated after the fact by monetary damages. See Frank's GMC Truck Center,
Inc. v. General Motors Corp., 847 F.2d 100, 102-03 (3d Cir. 1988).
47. The mere fact Taitz through Defend our Freedoms Foundations, Inc.,
without Liberi’s knowledge or authorization, publicized Liberi’s Social Security
number and other personal identifying information, outlined above indicates
irreparable harm. Liberi has already fallen victim to identity theft by another her
Social Security number in another state. Liberi will continue to be at serious risk
of individuals using her information, illegally obtaining credit and assuming
Liberi’s identity. This must be stopped. Liberi has already fallen victim to identity
theft as a result. See Lisa Liberi’s Verification attached as EXHIBIT “Z.” It is
apparent Taitz has absolutely no regard to the laws of our states or any respect for
the Honorable Court. Taitz is on a mission to destroy Liberi and each time she is
allowed to get away with her wrong doings, Taitz actions intensify.
48. Although the Court warned Taitz and an Order was issued that the
Respondents were to conduct themselves as discussed in Court, Taitz has simply
ignored the Court and continued spreading Liberi’s Social Security number and
other private confidential information and posting it on the internet. Taitz had
another individual put on the internet Ostella’s maiden name, address, address of
her family members, business associates, requests for people to contact the police
department where Ostella resides, etc.
49. As also stated above, Taitz is clearly out to destroy Liberi and has already
destroyed Liberi’s reputation, caused serious emotional distress to Liberi and her
parents by maliciously bringing up Liberi’s sister’s death and then inferring Liberi
“murdered” her sister.
50. All of the Respondents behaviors and illegal actions have been extremely
humiliating, embarrassing, and have caused Petitioners severe emotional distress.
51. Liberi, and all the Petitioners’ live in fear every day. Petitioners’ are afraid
that Taitz, Hale or Belcher’s followers are going to harm their families or
themselves.
52. As this Court is aware, Disclosure of confidential information is a basis for
the issuance of an Injunction or Restraining Order. See JAK Prod., Inc. v. Wiza,
986 F.2d 1080, 1084 (7th Cir. 1993). Moreover, when the harmful actions are
repeated, as they have been in this case, this is another basis for the issuance of an
immediate Injunction or Restraining Order. See, e.g., Louis W. Epstein Family
P'ship v. K-mart Corp., 828 F. Supp. 328, 338-39 (E.D. Pa. 1993) (stating that
there is "no adequate remedy at law if the injury is of a repeated or continuing
character"), aff’d in part and rev'd in part, 13 F.3d 762 (3d Cir. 1994); Northeast
Women's Ctr., Inc. v. McMonagle, 665 F. Supp. 1147 (E.D. Pa. 1987) (noting that
irreparable harm is a component of adequacy of the legal remedy and stating, "the
legal remedy is inadequate if the Petitioner's injury is a continuing one, where the
best available remedy would relegate the Petitioner to filing a separate claim for
damages each time it is injured anew"), aff'd in part and remanded, 868 F.2d 1342
(3d Cir. 1987).
53. All the Petitioners’ have lost their good will based on the actions outlined
above with Taitz. Losses incapable of measurement may be irreparable harm. See
Western Holding Group, Inc. v. Mayaguez Port Comm'n., 611 F. Supp. 2d 149,
189 (D.P.R. 2009) (It is sufficient for Petitioner to show that injury is not
accurately measurable, given that irreparable harm is a natural sequel) quoting
Multi-Channel TV Cable Co. v. Charlottesville Quality Cable Operating Co., 22

F.3d 546, 551-552 (4th Cir. 1994) (loss of goodwill constituted irreparable harm,
warranting preliminary injunction). Rent-A-Center, Inc. v. Canyon Television &
Appliance Rental, Inc., 944 F.2d 597, 603 (9th Cir. 1991).
54. Hale and Sankey have already announced over Plains Radio’s radio show
that Liberi took out a loan, which was true. Hale also admitted on his radio
program that he received the documents with Liberi’s personal information from
Sankey, which Sankey substantiated on the air. There are only two (2) ways they
could have known this. One, illegally accessing Liberi’s credit reports; or two
applying and obtaining credit in Liberi’s name. It can takes months to learn of new
accounts opened illegally. In addition, Belcher is manufacturing documents using
Liberi’s name, Belcher now has every bit of personal identifying information of
Liberi’s and Belcher has a criminal record of theft and fraud type crimes. Liberi is
scared to death of what she will learn a year from now that her Social Security
number and personal identifying information has been used for/by Taitz, Hale,
Sankey, Belcher and other’s who have Liberi’s information, which is in the
hundreds of thousands if not millions.
55. In addition and as serious, Respondent’s Hale and Belcher have been
threatening Petitioners’ witnesses and potential witnesses. As a result, two (2) of
the Petitioners’ most important witnesses are in fear to provide “Affidavits” or
testify until this Court intervenes and provides some safety mechanism’s to protect
the witnesses of the Petitioners’ from the Respondent’s threats. Petitioners’ have
been Ordered to respond to the Court’s Rules to Show cause and support their
response with affidavits. Unless some protection measures by the Court are taken,
Petitioners’ will not be able to comply with the Affidavits. Petitioners’ witnesses
are in fear they too will be destroyed by the Respondents’ as Liberi has been and
continues to be and as the other Petitioners’ have been and continue to be harmed
and injured by the Respondents’ illegal behaviors. See EXHIBIT “AA.”
56. Plus, without the issuance of the within Emergency Injunction, Petitioners’
will be deprived of their due process rights and equal protection of the laws
guaranteed by the United States Constitution to provide and bear witnesses to
testify on their behalf; Petitioners’ will be deprived of their due process rights and
equal protection of the laws in seeking redress for the damages they have suffered
as a result of the Respondents wrong doings. Petitioners’ will continue to suffer
harassment and emotional distress.
57. It should also be noted, although the hearing on August 7, 2009 was placed
“Under Seal” as with all documents presented to the Court at this Hearing, Hale
has read Affidavits filed during Court on his radio program, Plains Radio, since the
Hearing. In addition, as you can see from the attached exhibits, Belcher has posted
her manufactured evidence which she had provided to the Court on her website.
58. Moreover, Belcher prepared an Affidavit with two [2] documents she
presented to the U.S. District Court as evidence. The first document was a
“supposed” email Liberi had sent to her in December 2008 and the second
document was a “supposed” chat log she had with Liberi on AOL, January 3, 2009.
Both of these documents were found to be fabricated and forged documents. The
“chat log” Belcher posted on her website at obamacitizenshipdebate.org, appears
she emailed this document to herself on August 4, 2009, as it was sent to and from
Newwomensparty, which is Belcher’s screen name on AOL. It should also be
noted: Liberi has not spoken to Belcher or had any “chat sessions” on AOL with
Belcher since March 5, 2009 and has not emailed Belcher since March 6, 2009.
Liberi has been on AOL for approximately seven [7] years, her screen name has
always been Llisaliberi, which is always present on AOL “chat sessions” and her
AOL email address Llisaliberi@aol.com, which appears on all emails sent. Liberi
did not have this chat with Linda and the Chat is clearly a manufactured document
as it has Liberi’s screen name as “Lisa.” Attached as EXHIBIT “BB” is a screen
print (similar to a picture) of Belcher’s website showing the manufactured “chat
session”; and AOL chat boxes showing Liberi’s screen name as Llisaliberi and
NOT “Lisa”.
59. Belcher also has posted another “supposed” email sent from Liberi to Berg.
This too is a manufactured email, if you look at the time zone it says “Central
Time” which is Texas where Belcher resides. Liberi’s emails have never shown
“Central” time zone. This particular email shows from Llisaliberi to
Philjberg@gmail.com. Llisaliberi is not a proper email address. Attached as
EXHIBIT “CC” is a screen shot of Belcher’s website which shows this fabricated
email; screen shots of Berg’s email box for Jan. 3, 2009 showing he never received
any emails from Liberi on Jan. 3, 2009; an email to and from Belcher and Liberi
showing the email header; and an email to and from Berg and Liberi also showing
the email header. You will notice Liberi’s emails show coming to and going from
Llisaliberi@aol.com, not Llisaliberi.
60. Belcher not only committed criminal offenses in forging and creating
documents in Liberi’s name, she also pulled a fraud upon the Court and perjured
herself.
61. The above forgeries and fabricated document in Liberi’s name by Belcher
and the fact Hale and Sankey along with an unknown amount of other individuals
have illegally accessed and obtained Liberi’s credit reports or they are obtaining
credit in Liberi’s name, it can take six [6] months or longer before a person learns
credit has been obtained by others fraudulently and then it is truly a mess and very
difficult to clean up. Identity theft is rampant in our society today, not to mention
individuals outside the country who also received Liberi’s Social Security number
and other private information from Taitz via email.

62. Petitioners’ are being deprived their constitutional rights to bear and present
witnesses. With the threats and intimidation of any witness who supplies an
Affidavit, Petitioners’ have four [4] witnesses who have severe concerns and until
the Court takes appropriate action to ensure their safety and privacy of their
information they will not submit an Affidavit. Deprivation of constitutional rights
by the Respondents is reason for the grant of an Emergency Injunction or
Restraining Order. See Pittsburgh League of Young Voters Educ. Fund v. Port
Auth., 2009 U.S. Dist. LEXIS 65885 (W.D. Pa. July 30, 2009); Elrod v. Burns, 427
U.S. 347, 373, 96 S. Ct. 2673, 49 L. Ed. 2d 547 (1976); AIDS Action Comm. v.
Massachusetts Bay Transp. Auth., 42 F.3d 1, 12 (1st Cir. 1994).
63. The Respondents have simply ignored the Court’s rulings and failed to abide
by the Court’s Orders. Without the Injunction, Petitioners’ have absolutely NO
protection.
E. Harm to Opposing Party:
64. Granting Petitioners’ Motion for an Emergency Injunction or Restraining
Order will not result in any harm to the Respondents’ as Petitioners’ are merely
attempting to protect their private confidential information; their privacy; false
information being sent out, etc.
65. Consideration of the relative harm to the Respondent and the public interest
also weighs heavily in favor of Petitioners’. See Adams v. Freedom Forge Corp.,
204 F.3d 475 (3d Cir. Pa. 2000) at 484 (noting district court should consider these
two elements where relevant). First, the irreparable harm Petitioners’ would suffer
in the absence of a preliminary injunction substantially outweighs the harm to the
Respondents’. Issuing a preliminary injunction against the Respondents’ will not
adversely affect the public interest. To the contrary, the prevention of First and
Fourteenth Amendment violations; illegal disclosure of a person’s Social Security
number, date of birth, mother’s maiden name, where one was born, etc. weighs in
favor of protecting the general public interest. Even events affecting only private
citizens, is in the general public interest." F.T. Int'l, Ltd. v. Mason, 2000 U.S. Dist.
LEXIS 14979 (E.D. Pa. Oct. 11, 2000), at *2. See also United States ex rel.
Rahman v. Oncology Assocs., 198 F.3d 489, 496-97 (4th Cir. 1999).
F. Risk to the Public Interest:
The risk to the public interest is huge, just as the risk to the Petitioners. If
the Respondents’ are allowed to continue their illegal activities, then none of the
citizens of the United States are safe from having their privacy invaded; Intrusion
upon their Seclusion; Public Disclosure of Private Facts; being placed in a False
Light in the Public Eye; Slander; Libel and many others. The risk to the public
will be great if the Respondents are not enjoined from their illegal behaviors.
WHEREFORE, for good cause shown, Petitioners’, Lisa Liberi; Philip J.
Berg, Esquire; Evelyn Adams; Lisa Ostella; Law Offices of Philip J. Berg; and Go
Excel Global respectfully requests this Honorable Court for an emergency
Injunction or Restraining Order against Respondent’s Orly Taitz, et al; Edgar Hale;
Caren Hale; Linda Sue Belcher and anyone acting on their behalf pending the
resolution of Petitioners’ Appeal. Petitioner Lisa Liberi further requests this Court
for an Order to obtain a new social security number from the Social Security
Administration.
Respectfully submitted,
Dated: August 17, 2009

Philip J. Berg, Esquire
Attorney in Pro Se
(610) 825-3134
EXHIBIT “A”
http://orlytaitzesq.com/drorlytaitzesq/documentation/Dossier6new2.doc
http://orlytaitzesq.com/dossier-006.htm
NOTE: This dossier #6 is posted on four (4) locations of Taitz website. Liberi’s SSN is
located on the last page.
http://www.orlytaitzesq.com/blog1/?p=8;
http://orlytaitzesq.com/dossier-006.htm; and
http://orlytaitzesq.com/drorlytaitzesq/documentation/Dossier6.doc
http://www.orlytaitzesq.com/blog1/?cat=29
Dr. Orly Taitz Esquire

Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691 Copyright
2009
« Dr. Orly Taitz Esquire

Videos on You Tube »
Dossier #6
Dossier #6
Dr. Orly Taitz, ESQ

26302 La Paz ste 211
Mission Viejo CA 92691
ph 949-683-5411
fax 949-586-2082
dr_taitz@yahoo.com
www.repubx.com
04.08.09.
Attorney General Eric Holder;

Solicitor General Elena Kagan;
Director of FBI Robert Mueller;
FBI Cyber Crime division, Orange County CA,
Officer Nathan Le
Director of Secret Service Mark Sullivan;
Chief of Security of the Supreme Court,
Officer Christine Giaccio;
Chief Justice of the Supreme Court John Roberts;
Legal Counsel to the Chairman of Joint
Chiefs of Staff Admiral Mullen, Captain Crawford
Via Certified mail, return receipt, restricted delivery addressee only

Dossier #6 in the form of
open letter posted on the internet and forwarded to 26,000 outlets of US and international media
Dossier #6 Further evidence of forgery; more questioned raised in regards to illegal
campaign contributions; efforts to undermine fundraising of dissidents, criminal element
used; more cyber crimes, defamation of character, identity theft; false leaders of the
dissident constitutional movement.
Please see in attachment affidavit of licensed private investigator Jorge Baro and forensic
document examiner Sandra Ramsey Lines. Both are stating that Certification of Live Birth
posted by Obama on internet cannot be viewed as genuine and original birth certificate from the
vault in Hawaii needs to be produced to verify his place of birth and citizenship.
Further you can see a statement by Suzie Murzinski in regards to fundraising by Obama in
Senegal, using Western Union. Fundraising abroad for the presidential election is illegal and this
statement is consistent with prior reports of Obama illegally getting campaign contributions from
abroad, mostly from Arabic Muslim countries.
Further you can see receipts showing diversion of campaign contributions. I have received e-
mails from donors, stating that they had problems with pay-pal. I described these problems in
dossier #5, specifically that the e-mail address in my blog for pay-pal was changed, which
prevented me from raising funds. My web master Lisa Ostella stated that such a report gives her,
as a web master. bad name and demanded that I take the hacking report back. She stated that she
was convinced that the changing of the e-mail address was done by a volunteer moderator Fran,
she stated that she locked Fran from the blog and that should solve the problem. I felt that the
matter needs to be investigated by the FBI and I felt that they should draw their own conclusions.
Ms. Ostella stated that if I do not take back my complaint to FBI, she will no longer host my
foundation on her server. When I found a new web master to host my foundation, Ms. Ostella
instead of transferring the access codes and the domain, has locked me and another volunteer
moderator out of the blog, posted a bizarre defamatory statement, that I supposedly authorized
hacking into my own account and further defamatory comments about me were placed under
different names and aliases. Moreover, there were comments posted supposedly under my name,
even though I was locked out of the account and couldn’t respond. I got reports that some
defamatory comments were made under alias usually used by Lisa Liberi, assistant for Attorney
Phillip Berg, who filed similar legal actions. I started receiving statements and copies of pay -pal
receipts, showing instead of my e-mail address, an e-mail address of Lisa Ostella. Originally, I
thought that maybe her address showed on the receipt, since she was a web master on the
account, however, when I checked the names and dates on the receipts against the names on the
roster, that I downloaded earlier, I could see that those were not received by the foundation,
those donations were missing.
A couple of weeks ago I have received a phone call, providing information that Lisa Liberi, a
paralegal, assisting Mr. Berg, has an extensive criminal record. I decided to verify that.
According to Mr. Neil Sankey, licensed private investigator with 20 years of experience in
Scotland Yard and over 12 years of experience in US, those statements were correct. Lisa Liberi
aka Lisa Richardson aka Lisa Courville and other aliases had an extensive criminal record going
back to 1990s, that included Grand Theft, forgery, forgery of seals “From 2000 to 2004, Liberi
engaged in a complex fraud involving falsification of police reports, manipulation of credit
bureau reports, loan fraud, and counterfeiting of court documents resulting in hundreds of
thousands of dollars in losses to banks and credit unions.” (see attachment). Please see the
report attached and reports relating to criminal conviction in San Bernardino California.
Interesting fact is that Lisa Liberi was convicted recently, in March of 2008, she was supposed to
serve 8 years in jail. Miraculously this 8 year jail term was reduced to probation and an order to
repay the victims. When I added up all the restitutions in the conviction, it added up to 21,000
per month. Where is this money coming from? Who is paying it? And paying to do what? I have
sent an e-mail to Philip Berg, alerting him to this matter, however I did not hear from him back.
After I raised my concerns to other parties and they confronted Liberi, she tried to claim that it is
not her, but another Liberi, that she lives in PA and the one convicted lives in NM, however
several sources confirmed that she indeed lives in NM, they confirmed her date of birth and
appearance as matching the ones on file with the San Bernardino, CA district attorney. I tried to
analyze the instances when Liberi was the most vicious in her attacks towards me and found two
distinct areas:
a. Obama’s Natural Born status and definition of it
b. my efforts to conduct investigation of illegal, criminal activity and my efforts to have FBI and
attorney generals of different states involved.
In regards to the Natural Born status, she claimed that she has written pleadings for Phil Berg
and that the citizenship of Obama’s father is of no importance. This was repeated time and again
when she appeared together with Phil Berg at different radio programs. In reality definition of
Natural Born citizen is, that it is one, who is born in the country, with both parents citizens of
the country, one that does not have allegiance to any other sovereignty at birth. It appears that it
was an effort to sway the public and redirect attention from the most obvious, the fact that
Obama’s father was not a citizen of the US and therefore he does not qualify, no matter where he
was born. Did someone help Liberi avoid 8 year jail term here in CA in exchange for her efforts
to cloud the issue?
Second issue dealt with criminal activities surrounding Obama and his supporters. I have been
the only one investigating those issues. Why?
Another interesting fact. Plains radio had a legal action against a blog radio talk show host
Evelyn Adams aka momma E. Momma E is represented in this action by attorney Philip Berg.
When Lisa Ostella locked me out of my own foundation, due to the fact that she has registered
the domain before I had an opportunity to do so; she created several diversionary blogs and
posted links to Momma E and a few other parties that are rumored to be plants, meaning false
leaders of the movement.
I am not a historian and not a theologist, however this whole situation reminds me of a story of
Shabtai Zvi. A few centuries ago there was a false leader in Europe, his name was Shabtai Zvi.
He claimed to be a Masaya and thousands followed him until he was summoned by a sultan, who
has given Zvi two choices:
First- if you are really a Masaya, you will be executed, but you will be resurrected as a Masaya.
Second - if you are not a Masaya and want to live, you have to convert to Islam.
Within about five minutes Shabtai Zvi put on a Muslim garb and converted and that was the end
of the false Masaya, false leader and false movement.
Similarly here, a leader is judged by his willingness to go all the way, regardless of hardships
and risks or financial problems. You can’t talk only about the birth certificate and not see an
elephant in the room, which is Obama’d British citizenship at birth, based on his father’s
citizenship. You can’t talk about his birth certificate only and not demand immediate
investigation of his numerous reported social security numbers, reported forgery of the Selective
Service Certificate, perjury on the Illinois Bar application, all the evidence of campaign
contributions fraud, charitable foundations fraud, tax fraud and numerous reports of his
supporters being engaged in cyber crimes, intimidation, harassment, identity theft and all the
other related crimes
Due to the above I renew my demand upon all the law enforcement agencies listed in this dossier
to conduct immediate criminal investigator, I demand on behalf of my clients Quo Warranto
proceedings to resolve those issues once and for all.
Sincerely,
Dr. Orly Taitz, ESQ
NOTE: EXHIBIT “A” REDACTED DUE TO LENGTH OF DOCUMENT
> From: nsankey@thesankeyfirm.com

> To: lisaostella@hotmail.com; dr_taitz@yahoo.com
> Subject: FW: >>>>>>>>>>Urgent IMPORTANT INFO SAME SUBJECT<<<<<
> Date: Mon, 16 Mar 2009 14:57:13 -0700
>
>
>
> PLEASE NOTE THE LAST LINE!
>
> Thursday, April 10, 2008
>
>
> New Mexico Woman Sentenced in Identity Theft and Real Estate Fraud
>
>
> Lisa Liberi, aka Lisa Richardson, 42, New Mexico, was sentenced in
> connection with felony charges involving identity theft and forged
> documents. Liberi appeared in San Bernardino County, Rancho Cucamonga,
> Superior Court, on March 21, 2008. She was sentenced to a state prison term
> of 8 years, imposed but stayed, and placed on supervised probation for 3
> years as part of a plea agreement. Liberi was sentenced on ten felony
> counts ranging from Grand Theft, Forgery, and Filing False Documents.
>
> From 2000 to 2004, Liberi engaged in a complex fraud involving falsification
> of police reports, manipulation of credit bureau reports, loan fraud, and
> counterfeiting of court documents resulting in hundreds of thousands of
> dollars in losses to banks and credit unions.
>
> In 2002, San Bernardino County Sheriff’s Department personnel arrested
> Liberi on theft by false pretense charges. In July 2004, Investigators from
> the San Bernardino County District Attorney’s Real Estate Fraud Unit
> arrested Liberi at the Ontario International Airport for additional felony
> charges while she was out on bail.
>
> She has an extensive criminal record going back to the 90’s.
From: Neil SANKEY <nsankey@thesankeyfirm.com>

Subject: FW: LISA LIBERI etc
To: dr_taitz@yahoo.com
Date: Monday, April 13, 2009, 7:04 PM
Here is the Liberi stuff you requested. This is also what I sent to Bob Unruh
From: Neil SANKEY [mailto:nsankey@thesankeyfirm.com]

Sent: Friday, April 10, 2009 10:01 AM
To: Bob Unruh
Subject: LISA LIBERI etc
Bob here are some bare facts about Berg’s assistant. See below and attachments
I don’t know how much of the story you have already, but is essentially about WHO she really is
and the questions that unfortunately brings up about Berg.
Call, if you need to, at your convenience.

Neil Sankey
Investigator & Consultant.
THE SANKEY FIRM
Simi Valley, California 93063

nsankey@thesankeyfirm.com
805 520 3151

818 212 7615 cell
(Addendum)
LISA RENEE LIBERI. Bn 5/28/1965. 462-45-xxxx, 622-19-4312 (& others)
According to the Police she was born COURVILLE and married a Richardson (Possible Alan
Douglas Richardson, currently residing in Las Vegas .) IF it was the other way around, then the
Courville is Bill Marshall Courville 11/10/61 of Houston , Tx. 457-71-x I have several SS#’s for
her and a LOT of AKA’s. Her real SS# is probably 462-45-xxxx. Most prominent otherwise are
563-60-xxxx, 572-17-x, 622-19-x She went BK in 2002 Her brother is probably Lawrence E
Morris of Fontana and Rancho Cuc , CA . He was born 1/16/64 Her Husband, Brent J, a Parolee,
I have not researched that. Is probably Brent J McCormack 563-77, also uses 331-02-x
There is also a Jerry HELLER and Douglas Cramer look interesting, but where do you stop?.
From: Neil SANKEY <nsankey@thesankeyfirm.com>

Subject: Bergs Paypal
To: dr_taitz@yahoo.com
Date: Monday, April 13, 2009, 7:15 PM
It comes as no surprise to learn that the link to a Visa donation to Berg, (as opposed to Paypal)
has been removed
Neil
This report came from volunteer Sarah redacted
NOTE: ATTACHED PRINT-OUT WAS REDACTED DUE TO LENGTH

EXHIBIT “B
http://www.orlytaitzesq.com/blog1/?p=36

2009
« KY secretary of state
Million Patriots march »
Follow up on Lisa Liberi, paralegal to Phil Berg
In regards to Lisa Liberi, assistant to Phil Berg. As I stated, she has an extensive criminal record
of forgery, forgery of seal, grand theft and so on. Lisa Liberi was stating that it is not her, that it
is another Lisa Liber, and that she lives in PA and not NM, however this is not true. She lives in
NM, her home phone number and address is in NM and this can be verified with the probation
officer Joanne Martinez fax 505-476-2368, phone 505-827-8627.
I corresponded with John Hemenway ESQ, who filed Hollister v Soetoro case in DC for Phil
Berg and he stated that Lisa Liberi, who works for Berg lives in NM. When his son was buying a
truck in NM, she told him, that she lives there and can assist.
One of former volunteers for Phil Berg has written a statement and went with me to FBI in San
Antonio and reported that Lisa Liberi, who works for Berg lives in Santa Fe, NM and she sent
Christmas presents to Lisa to NM. Today many employees and volunteers work from home and
correspond via e-mails and phone calls. This volunteer stated that Lisa Liberi corresponds via e-
mails and phone. A person will not make a report with FBI and risk going to jail unless
she provides a truthful statement. She also recorded this statement on video.
I had three confirmations from 3 independent sources of the findings of licensed investigator Mr.
Sankey Before I posted dossier #6. After all the revelations the name of Lisa Liberi in Mr. Berg’s
site was changed to Agent88.
I believe, that when non-profit organizations are involved and donations are collected, one
should not employ people that are questionable and particularly people that have a lengthy
criminal record that includes forgery, forgery of seals and grand theft.
I have closed the pay pal account, when I saw that Lisa Ostella has redirected the the Defend
Our Freedoms blog and redirected the pay pal. Now there is no pay-pal for this foundation and
there will not be any more questions. I will be setting a direct visa/credit card donation button ,
where donations will go directly to the foundation, so there will not be a problem of someone
redirecting donations by changing the e-mail address on the pay pal button.
Yet another important matter. So far none of Obama eligibility matters have gone to trial and we
all are working hard to change it. But let’s say one such case goes to trial. We don’t want to be
impeached by Obama’s attorneys saying that we knowingly employed shady characters,
who might’ve supplied us with incorrect information. Just like the country needs to be purged of
Obama and his clique, that are in power by virtue of forgery, fraud and consealment of vital
records, the patriots of this country need to purge their ranks.
This entry was posted on Saturday, April 18th, 2009 at 2:29 pm and is filed under Other Criminal or Suspicious
Activities. You can follow any responses to this entry through the RSS 2.0 feed. Both comments and pings are
currently closed.
EXHIBIT “C”

2009
« Key witness in presidential passport case fatally shot

from Field McConnell »
Every day I get such evidence of missing or misdirected funds

Every day I get such receipts, showing that my former web master Lisa Ostella (posts under name
Calpernia) has redirected donations to herself, to her e-mail address. Currently, as this was uncovered,
she created new web sites Defend our freedoms .org, .net and continues the scheme by making those
sites similar to my old ones and using the foundation name to steal more donations. She created a visa
donation site with her e-mail account Go Excell Global, underneath she posted a paypal button showing
my foundation Defend Our Freedoms (without my consent) and my e-mail address (without my
consent) to look as if she is still connected to me and my foundation, even though all ties with her were
severed a couple of weeks ago, when I found out about this scheme and I closed the Pay Pal account
completely. Any person, whose donations were stolen by Lisa Ostella aka Lisa Current aka Calpernia is
asked to report this to his local police or sheriff’s department. As I found out, she appears to be
connected to Lisa Liberi, who is still working for attorney Phillip Berg. Please see my dossier #6, Lisa
Liberi aka Lisa Richardson aka Lisa Courvelle has a long criminal record, that includes grand theft,
forgery of documents, forgery of seal, falsification of police reports and credit statements, where financial
institutions were defrauded out of thousands of dollars. She claims to be a different Lisa Liberi, living in
PA, however she lives in NM and her probation officers are Joanne Martinez 505-827-8627 and Dawn
Helling (not sure about spelling) 505-476-2359.
Hi Dr. Taitz,
Just to let you know that I donated to your cause on 1/19/09 thru PAYPAL. I copied the transaction that
was provided to me by PAYPAL, please see the following:
Dear Joseph Iadarola,
This email confirms that you have donated $25.00 USD to Defend Our Freedoms
(lisaostella@hotmail.com) using PayPal.
Donation Details
Confirmation number: 0MT49606HT922673B
Donation amount: $25.00 USD
Total: $25.00 USD
Purpose: For being a great American!
Contributor: Joseph Iadarola
Recipient information
Donations coordinator: Defend Our Freedoms

Contact email: lisaostella@hotmail.com
Contact Phone Number: 866-954-5625
This entry was posted on Sunday, April 19th, 2009 at 8:32 am and is filed under Other Criminal or Suspicious
Activities. You can follow any responses to this entry through the RSS 2.0 feed. Both comments and pings are
currently closed.
EXHIBIT “D”

2009
« Supporting Documents, Downloads.

Upcoming appearances »
Update on Lisa Ostella and Lisa Liberi

TUE APR 21st
Dear Dr. Taitz;
I have been following your activities to force Barack Obama to comply with the
requirements of our Constitution, but was floored this morning when I read what
the Webmaster Ms. Ostella had done to you.
This is so obviously a crime. You should ask law enforcement to bring criminal
charges for stealing you good name and donations intended exclusively for you.
You in turn should file a civil suit suing her for theft and ask for large punitive
damages. You certainly have proof of damages if what you wrote is true and it
sounds plausible. Please keep up your work. God bless America!
Good luck,
Al Barrs
albarrs@wfeca.net
Greenwood, FL
Dear Mr. Barrs,
I have reported the matter to the Sheriff’s department and FBI . See below the
receipt for the police report with the name and phone number of the detective.
The name of the FBI agent is John Haas- supervisor of the cyber crimes unit 714-
542-8825. Please spread the word and give everybody the new web address for
the Defend Our Freedoms Foundation, which is http://www.OrlyTaitzEsq.com
Please post this web address in as many blogs and sites as you can, so it will be
picked up quickly by different search engines and can be seen by all my readers. I
have closed my pay pal account and did not receive any pay pal or visa donation
since 04.11.09. If you or anybody else has given any donations after this
date, using pay-pal, visa, MasterCard, American Express and so on, believing
that these donations were received by the Defend Our Freedoms foundation,
please demand a refund and report it to the Sheriffs department, FBI and IRS as
funds stolen from the non profit organization. I have sent a Cease and Desist
letter to Ms. Lisa Ostella, demanding that she forward to me the access codes for
the domains and the e-mail address list of the readers and stop fraudulently
operating under the name DefendOurFreedoms and stop drawing financial profit
from the Defend Our Freedoms name. I have also sent a Cease and Desist letter
to Evelyn Adams aka Momma E, talk show host David Levin and other parties
who are fraudulently advertising on the foundation website and drawing profit
from it or from reader lists given or sold to them by Ms. Ostella. Ironically Ms.
Ostella has accused me of collecting information on the readers. In reality I did
not have any such information and could not reach most of the readers, aside
from ones whose names were in my dr_taitz@yahoo.com e-mail account. Ms.
Lisa Ostella is the one, who collected names and e-mail addresses and she is
currently fraudulently sending e-mails to these readers using
DefendOurFreedoms name. If you get such e-mail, please demand that she
immediately stop this practice and forward the list to me, as the president of the
foundation.
My primary goal is to expose all the fraud committed by Obama and removing
him out of office as an usurper, litigation against Ms. Ostella is secondary. I also
need to get full information in regards to full damage to the foundation and me,
stemming from actions of Ms. Ostella and parties that patronage her site and
are aiding and abetting her.
I, also, sent an e-mail with dossier #6 to Mr. Phil Berg, advising him of lengthy
criminal record of grand theft, forgery, forgery of seal and other related crimes,
committed by Ms. Lisa Liberi, his paralegal and assistant, who reportedly was
managing his fund raising efforts. I believe Mr. Berg should not be using a
person with such past in his fund raising efforts and legal practice and should
issue a statement advising the donors and supporters, that Ms. Lisa Liberi is no
longer employed by him or his foundation and that he is reviewing all donations
and all legal records handled by Ms. Lisa Liberi. I believe the donors to Mr.
Berg foundation should get assurances that their donations were used for
litigation and the cause and not to reimburse victims of Ms. Liberi’s prior
schemes, reported to add to $21,000 per month.
Sincerely,
Dr. Orly Taitz, ESQ
04.21.09.
Tags: Add new tag, Berg litigation, birth certificate, crimes Lisa Ostella, Lisa Liberi, obama
This entry was posted on Tuesday, April 21st, 2009 at 8:29 am and is filed under HOT ITEMS!, LINKS, Legal
Actions, Letters from Readers and Patriots, Other Criminal or Suspicious Activities, Supporting Documentation.
You can follow any responses to this entry through the RSS 2.0 feed. Both comments and pings are currently closed.
EXHIBIT “E”

2009
« Updates on radio shows; Interview at 6:30 PM PDT on No Compromise Radio

From a reader, can someone do it? »
More attacks on me. More indepth research is done in spite of attacks

Recently I got an e-mail advising me on more attacks on me and my family, claiming that I and
my husband spy on people,. What nonsense. Anybody is welcome to check my programs. The
software used is Wordpress, that is used in most blogs, my husband has nothing to do with my
work and all the allegations are without any proof. On the other hand, each and every thing I
publish is backed by evidence. For example: when I reported that Obama’s certification of live
birth has signs of forgery, I presented a statement from a forensic document expert. When I
stated that Lisa Liberi, paralegal for Phil Berg has a lengthy criminal record, I provided the
printout from the DA and private investigator, showing a lengthy record of grand theft,
forgery, forgery of seal and other similar crimes (attachments in dossier #6). These people are
simply attacking me and my family, because I am successful in uncovering illegal and criminal
activities, they get scared and are trying to scare people into not reading this damaging
information that I uncover, they don’t want the public to know the truth.
I am preparing dossier #7 and I need help in research in the following areas:
1. any and all newspaper articles about Baxter pharmaceuticals flu vaccines, infected with live
strain
2. any info on campaign contributions from Baxter to Obama
3. how did Baxter become the company associated to WHO, responsible for coming up with
swine flu vaccine?
4. who are the major shareholders of Baxter?
5 which companies manufacture Tamiflu and similar medications, their contributions to Obama,
their shareholders?
6. who is responsible for entering data at Intelius Jobs.com and removing such data, how is it
done?
7. what investigation was done at 29th palms marine base re the swine flu?
8. were there any other recent suspicious flu outbreaks at military bases?
This entry was posted on Friday, May 1st, 2009 at 10:11 am and is filed under Health & Safety, Help Needed. You
can follow any responses to this entry through the RSS 2.0 feed. Both comments and pings are currently closed.
EXHIBIT “F”

2009
« Proposed quo warranto, to be delivered to Atty. Gen of GA

Visiting the Center for Disease Control and other agencies in Atlanta GA »
Check public records for yourselves, see that I am providing truthful

information
I would like to respond in regards to some allegations that came forward recently.
As you can see in dossier #6 on this blog, I have received verified information from a licenced
CA Private Investigator Mr. Neil Sankey (license 10905) , that Lisa Liberi, working as a
paralegal for Phil Berg has a lengthy criminal record of grand theft and forgery (see dossier #6).
I have sent Mr. Berg this information, he never responded and never denied it. Due to the fact
that Ms. Liberi has access to numerous documents and donations, I was obligated to provide this
information to the public. Information that was provided, is public record and I urge everybody
to call San Bernardino, CA criminal court system as well as NM probation officer (number in
dossier) and verify that all the information is correct. I have urged Mr. Berg to disassociated
himself and his practice and donation efforts from this person and hire a forensic accountant and
forensic document examiner to review all documents and forensic records handled by her. Mr.
Berg did not do so. From what I understand their website was under lockdown and Ms. Liberi
went by name Agent88.
Paperwork filed yesterday was nothing but slander against me, a lot of sand in the eyes, but if
you read carefully, the only thing they are trying to do, is further hide Liberi’s identity, saying
that there is an undisclosed address and asking for a new social security number. They do not and
cannot deny following important points:
1. Lisa Liberi, working for Philip Berg, resides in New Mexico, previously resided in CA and
has a lengthy record of grand theft and forgery of documents.
2. Phil Berg was warned by me and a volunteer, that her continuing association with the Obama
litigation undermines everybody’s work and everybody’s effords, as it puts into question
integrity of fundraising of donations and veracity of any and all documents handled by her.
3. Regardless of what might be financial and other arrangements of Mr. Berg with Ms. Liberi, as
an officer of the court, he had a duty to disassociate his fundraising efforts and legal research
from her. I believe he owes this to all the patriots involved in this effort, particularly people like
me working 24/7. He has an obligation to hire a forensic accountant and forensic document
examiner and check all the records. Imagine, if any of Obama eligibility cases go to trial, Berg
and any and all attorneys will be impeached and reasonable doubt will be in the minds of the
jurors, if they know that the documents presented, were gathered by a person with the record of
forged documents, that the supervising attorney knew about it and made no effort to disasiociate
himself and verify the records by the licensed professional. Rest assured, that if I could obtain
this information about Ms. Liberi, so could Obama’s attorneys, with millions of dollars available
to them. I am wondering if Ms. Liberi’s association with Mr. Berg was mastermind by
somebody, as she had a conviction in March of last year, was supposed to serve 8 years in San
Bernardino CA, but the sentence was reduced to probation and restitution to victims.
4. On the contrary, as the first donors reported to me problems with pay-pal, I have reported this
to the police and FBI immediately. The reports were posted on the blog. When web master Lisa
Ostella has stated that she wants me to take back my complaint, I switched to a different web
master and made sure that with the current web master my e-mail address is listed on the
registration of the domain, in order not to have the same problem. Ms. Ostella’s actions as a web
master in locking me out of my web site, allowing several days of defamatory statements and
later defrauding the donors and my foundation, by sending e-mails and claiming to represent
foundation and soliciting donations for the foundation are inexcusable and will have to be
prosecuted in due time.
5. I did not intent to prosecute this matter at this time, as I felt that Obama eligibility prosecution
and research is more important for the country at large, however I will respond as required to the
filing by Mr. Berg.
6. I wonder in regards to timing of this complaint, as I am making progress in a number of states

and with a number of plaintiffs. If Mr. Berg is really concerned about this country and it’s
future, he should dismiss this outrageous and frivolous complaint immediately, disassociate
himself from both Ms Ostella and Ms. Liberi and not waste my time, that is needed to organize
more citizen grand juries, more meetings with attorney generals of the states, local FBI offices,
US attorneys, grown numbers in resistance movement and turn this country around. All of the
stonewalling that we have observed, indicates that the problem is much bigger, then birth
certificate. I am the only attorney, who has the courage to bring to the forefront all of the
evidence of forgery,perjury, multiple social security numbers, unreported job positions. Judges
are hesitant to decide based on birth certificate only. it is extremely important to push for
criminal investigation of all the issues. This frivolous law suit simply wastes my time and
resources.
Dr. Orly Taitz Esq.
This entry was posted on Tuesday, May 5th, 2009 at 7:57 pm and is filed under Uncategorized. You can follow any
responses to this entry through the RSS 2.0 feed. Both comments and pings are currently closed.
EXHIBIT “G”
http://216.221.102.26/blogger/post/Follow-up-on-the-FBI.aspx
Follow up on the FBI

by orlytaitz April 17, 2009 12:22
I just got of the phone with Mike Haas- supervisor of the Cyber Crimes unit with the Orange
County, CA FBI. He is my point of contact, phone 714-542-8825. He will give the case to the
supervisor of the forgery unit and will get back with me later on today or on Monday.
I need everybody who donated to my foundation and have seen change of the e-mail address,
where instead of my e-mail (orly.taitz@gmail.com or dr_taitz@yahoo.com) to contact the
superviser of the cyber crimes unit 714-542-8825 and report this.
I got an e-mail a while ago, that a gentleman was selling a motorcycle and stated that he would
donate the proceeds to my foundation. I was told that there was bidding as high as 7,500, but I
never got that donation. If you are a person that was selling that bike or you are a person that
bought that bike, please contact me 949-683 -5411.
I received information that Lisa Liberi and her husband had an access to the credit card donations
for Phil Berg. If you have any info on this, please contact me.
If you know of any defamatory or fraudulent statements, any evidence of cyber crimes, fraud,
identity theft made after Lisa Ostella has hijacked my foundation blog, please forward this to the
above number. If you have evidence of any other federal crimes committed in relation to my
case and Obama eligibility case, that I am investigating, please forward it to the same point of
contact, same number.
EXHIBIT “H”
http://216.221.102.26/blogger/post/More-on-Lisa-Liberi-contact-her-probation-officer-in-Santa-
Fe-New-Mexico-505-827-8627-She-is-not-allowed-to-be-anywhere-near-other-peoples-credit-
cards.aspx
More on Lisa Liberi, contact her probation officer in Santa Fe

New Mexico 505-827-8627. She is not allowed to be anywhere
near other people's credit cards
by orlytaitz April 17, 2009 11:01
EXHIBIT “I”

2009
« Update in re to SCOTUS
from reader Penni Basse »
I need two articles and update on Lisa Liberi

First of all, I got a number of questions in re to Lisa Liberi, as through some surrogates
Lisa Liberi was spreading rumors that she is an innocent Lisa Liberi, residing in PA and the one,
I’ve written about is a different Lisa Liberi, residing in New Mexico.
Well, in the pleadings prepared by her and Berg and in their joint radio appearance on the redio
of Momma E aka Evelyn Adams, they admitted that I provided correct and truthful information,
as Liberi stated that after I provided her address, she became fearful of her ex-husband and now
she needs to go into hiding and change her social security number. The only information I
provided, is one of Lisa Liberi, residing in NM. If she would’ve been this woman residing in
PA, she would’ve had no reason to be concerned about me providing an address in NM.
She does reside in NM, she corresponds with Berg via e-mails and phone and Berg needs to
explain to the public and donors, what is his justification for continuing employment of one with
such a serious criminal record of forgery and grand theft.
Initial evidence in Obama eligibility case became a public record in August of 2008. I am not
using a record of affidavits, that they presented, but I would like to confirm this school
registration, that originally was published in a newspaper in Indonesia. Can someone find it?
I am, also, looking for the newspaper article, that has a full press conference with Janet Okubo,
spokesperson for the Director of Health of HI Dr. Chiyome Fukino. Can anyone find this full
press conference?
This entry was posted on Friday, May 8th, 2009 at 12:28 pm and is filed under Dossiers. You can follow any
EXHIBIT “J”

2009
« from another attorneys

Media Blitz »
Information update on both Liberi and Obama

Submitted on 2009/05/09 at 5:09am
His last postings on his site:
THE LATEST
01/02/2009: PRESS RELEASE - Philip J. Berg, Esquire Obtained the Obama 1964
Divorce File
01/02/09: BERG files a lawsuit on behalf of a RETIRED COLONEL The lawsuit is an

“Interpleader” that shifts the burden of proof to OBAMA Further, OBAMA is named as
“BARRY SOETORO” as that is his “real” name when he was legally adopted in Indonesia
01/02/09: The latest in the Berg vs. Obama Case No. 08 - 570 is that there are two
conferences scheduled; one for January 9, 2009 to hear the Petition for Writ of Certiorari
and the other for January 16, 2009 to hear the Petition for Injunction.
I got this information. Beginning of January was the last time there was any info posted on
Berg’s site.
By the way, Berg and Lisa Liberi got Dunham-Soetoro divorce papers from me and they got
Dunham-Obama divorce papers from Ed Hale.
Prior to the electoral vote I tried to file a legal action on behalf of the electors, to get verification
of Obama’s eligibility. I got in touch with some attorneys in Conservative red states and asked
them to file with me and sign Pro Hac Vice- it is a form that allows an out of state attorney to
work together with the in state attorney. I Worked with an attorney in AL, Keith Cornett and
later Ben Dupre, associate of Moral law center, that is ran by former Chief Justice of Al Supreme
Court Rory Moore. I studied all of Al elections statutes and Keith Cornett filed a request in HI to
get Dunham divorce papers. When he couldn’t get them, I got in touch with attorney Jim
Hochberg in HI and he personally went to the court house and got the Dunham -Soetoro papers. I
e-mailed Berg and stated that I got these divorce papers and would like to know if they want
them, since it can help both cases. Berg asked me to e-mail them and later Lisa Liberi called and
asked to mail a hard copy.
Dunham-Obama divorce papers were obtained by Ed Hale, who paid a private investigator to go
to HI and obtain the copy.
I never asked for any credit. Many of you read my blog and you could see that I didn’t even
mention hundreds and hundreds of hours I’ve spent trying to bring an action on behalf of
electors, who would have a better standing. At the end we could not file such action in AL, since
the statutes were amorphous, it wasn’t a strong hook, however Mr. Robert Cusanelli, an elector
from AL, who actually voted in the 2008 electoral college, became one of my plaintiffs. Now
you know how much work was done in conjunction with this one plaintiff, one out of over a
100.
Considering all the work that I have done, the allegations coming from Berg, are just outrageous
and hurtful. I believe a lot of what Berg is doing now is related to some criminal issues involving
Lisa Liberi. I got information from one of the people that worked with Berg and Lisa Liberi,
whereby Lisa Liberi stated that she gets disability payments from social security and those
payments were paid by Berg to her husband, so that she can continue receiving disability
payments. I decided to check this matter and called James Secord-District Attorney of San
Bernardino county in CA, who prosecuted Lisa Liberi, when she got 8 years in jail for grand
theft and forgery and this jail term was stayed and reduced to probation and restitution,
supposedly because of her medical disability. Mr. Secord has confirmed all of the information
in regards to her conviction and stated that she is indeed getting disability payments from the
government. If Berg is paying her for her services and it is done in any form: check or cash or
indirectly through her husband, it is a very serious offense for both of them. I would like to find
as much information, as I possibly can in regards to this matter. If you have donated to Berg,
where did the donation go? I believe, Berg filed this frivolous action to keep everybody quiet
about Lisa Liberi’s past and her current actions. Another matter, that I am trying to ascertain,
where does she get the restitution that she owes to the victims of her felonious activities in CA. If
you read dossier #6, you can see that the total restitution is $21,000 per month. Possibly it was
reduced to 12,000 per month. Where is this money coming from? If she is on disability and her
husband is working at a factory, where do they get this kind of money? This is a catch 22. If she
is not paying restitution, she is supposed to go back to jail and serve her 8 year term. If she is
paying this restitution and she is paid by Berg, then there are two very serious problems:
a. she is working with donations and other people’s credit cards, which means she is violating
her probation and supposed to go back to jail. Berg should not be allowing her to be anywhere
near the donations
b. If she is getting any payments from Berg, while getting disability, that is fraud and she is
supposed to go back to jail and is supposed to be prosecuted on these additional charges.
Her probation officer is Dawn Hellwig. Another officer in the department, who is familiar with
the case is Johanne Martinez. If you have given any donations to the offices of Phil Berg, you
need to contact Dawn Hellwig and demand an answer. I need to know if there are any
volunteers, who live in Santa Fe.
There is another issue. Did somebody arrange for her to be associated with Berg, to get him into
serious legal trouble. Was this arranged to begin with? I discovered an interesting detail and
need your help in getting to the bottom of this.
Liberi was first arrested in Rancho Cucomanga Ca, being involved in financial fraud schemes
going back to 2001-20o2. When I looked at the name of the town, I remembered, that among
130 jobs for Barack Obama and Michelle Obama, there was one notation: Michelle Obama
working for “Muslim World Today” in Rancho Cucomanga, CA. (dossier #1)
I remember being surprised,since Obamas claim to be Christian. As I’ve written in dossier #7,
this current position was recently erased with 110 other positions and I demanded investigation
in this destruction of evidence affair. Of Course Holder did nothing so far.
Another parallel. According to District attorney Secord, Liberi has changed her social security
number several times and now she applied for yet another SS number.
If you recall in dossier #1, I provided 100 addresses around the country for Obama that are
connected to 25 different social security numbers.
Liberi has changed her last name. Her name was Corvelle and Richardson. For some reason she
and her husband suddenly took the name Liberi. According to the private investigator, the
husband’s last name was Brent McCormick.
By the way, her social security number is a public knowledge, not only because of her conviction
for grand theft and forgery, but also because of her bankruptcies. According to the private
investigator, Mr. Sankey, there are 4 bankruptcy filings done by her: one -under Richardson, one
under Corvelle and two under Liberi. This information is readily available to 5 billion people on
the planet, who have access to Internet, which makes Berg’s case for injunction totally frivolous.
I need all the information, that can be found in regards to criminal convictions for her and her
husband. I need to know all of their associations, particularly in Rancho Cucomanga CA.
There are Internet services, that can give you a printout of web sites, as they were a month ago
or a year ago. These are crawlers, that scan the Internet. One of them is “Internet Access
Wayback Machine”. There are other similar services. I need your help in getting info in both
directions:
a. all of the names, addresses, social, associates, convictions, incarcerations for Liberi. Any and
all info on her husband. You can see past recordings on the Wayback machine.
b. any and all info on those 100 addresses and 25 social security numbers for Obama and 130 job
positions for Obamas . When did those appear in databases and when were those erased? Those
addresses and ss numbers and job positions came from Lexis-Nexis, Choice Point, Jobs.com
Intellius.
I was asked, How do they get those addresses? It is all coming from public records: non-profit
organizations, their donations records, county recordings, real estate recordings, probate records
of the deceased (do you remember that Madeline Dunham, Obama’s grandmother was a
volunteer for the probate department of Oahu circuit court), disclosed salaries (if you recall,
recently Washington DC FBI has raided offices of Vivek Kundra, Obama’s chief of computer
security and arrested his assistant amidst allegations of creating bogus job positions and splitting
salaries). We need to find the connections: who and when created those fraudulent units and who
and when erased them.
I need help from patriots, who are in law inforcement, such as Police, Sheriff, FBI, Marshall, DA
, Border Patrol, military police. Most importantly in CA, NM, PA, Il and DC.
Tags: Berg litigation, birth certificate, eligibility, natural born citizen, obama, orly, taitz
This entry was posted on Saturday, May 9th, 2009 at 9:22 am and is filed under Dossiers, HOT ITEMS!, Latest
News, Uncategorized. You can follow any responses to this entry through the RSS 2.0 feed. Both comments and
pings are currently closed.
EXHIBIT “L”

2009
« Obama is running a horrific 1.8 trillion dollar deficit this year, leading this country straight into
bankruptcy
Follow up on Muslim World Today »
Update on Obama investigation and Liberi investigation
Case Number Results In Same
New Window
Defendant 1 of 1
Case FSB044914 Defendant 1608112 LIBERI, LISA
Arrest Charges
Violation
Count Charge Severity Description Plea Status
Date
PC OFFER/ETC FALSE/FORGED INSTRUMENT

1 F 11/15/2002
115(A) TO FILE
Filed Charges
Violation
Date

1 F 11/15/2002 HTA
115(A) TO FILE
PC
2 F FORGERY 11/15/2002 HTA
470(D)
PC
3 F FORGERY 11/15/2002 HTA
470(D)
4 PC 472 F FORGE OFFICIAL SEAL 11/15/2002 HTA
Infor Charges
Violation
Date

1 F 11/15/2002 ACTIVE
115(A) TO FILE
PC
2 F FORGERY 11/15/2002 ACTIVE
470(D)
PC
3 F FORGERY 11/15/2002 ACTIVE
470(D)
4 PC 472 F FORGE OFFICIAL SEAL 11/15/2002 ACTIVE
Home
Name Search Results
Party Name Type Case Name Category Case Number Filed

PFF BANK & TRUST - Complaint for
LIBERI, LISA R DEFENDANT RCIRS057001 08/14/2001
V- LISA R LIBERI Money (ltd)
BUSINESS BANK -V- Breach of
LIBERI, LISA R DEFENDANT RCVRS059008 11/06/2001
LISA R LIBERI ETAL Contract
NATIONAL CREDIT
LIBERI, LISA R DEFENDANT ACCEPTANCE-V- Collections (ltd) RCIRS083719 10/27/2004
LISA R LIBERI
LIBERI, LISA LISA R. LIBERI -N- DISSOLUTION
PETITIONER RFLRS031189 09/13/2001
RICHARDSON BRENT J. LIBERI OF MARRIAGE
LIBERI-V-COUNTY
LIBERI, LISA Civil Rights -
PLAINTIFF OF SAN SCVSS98957 01/14/2003
RICHARDSON Discrimination
BERNARDINO
LIBERI-V-J RIVAS ET
LIBERI, LISA PLAINTIFF Quiet Title SCVSS107057 08/25/2003
AL
REDLANDS
Other Civil
LIBERI, LISA DEFENDANT CENTENNIAL BANK SCISS78115 06/05/2001
Contracts
VS. LISA LIBERI
In regards to Obamas, if you recall, they had some 100 addresses in National databases, he had
25 Social security numbers and they both had 130 job positions. Recently most of this info was
erased from National databases, but we have a hard copy in Dossier#1.
One of the job descriptions was for Michelle Obama- with a newspaper “Muslim World Today”
in Rancho Cucomanga, CA. I called the directory, there is no listing for this News Paper. They
do have a large Muslim Community and a Muslim American Society. I tried to call them and
inquire about the News Paper. The Phone number 909-945-5078 is currently disconnected. Do
we have volunteers in that area?
In regards to Liberi she also has several social security numbers and several names. From around
2000 she lived in this small community of Rancho Cucomanga and it looks like she changed her
name around that time. Aside from 8 year prison term, that she got last year, that was reduced to
probation(how and why?) she has another active case, see above, where the charges include
forgery and forgery of seal. She might be looking at additional prison term on those charges, if
convicted at trial. Talking to the arresting officer and DA, I found out, that this woman sues
everybody around her. She makes up charges and slanders people, hoping to intimidate and
harass them and reduce her prison term. You can see among the charges one, where she filed
against the county. I can understand, why she is coming up with all those slanderous charges
against me and everybody around, she wants people quiet, but it is sad that Berg, an attorney, fell
into a trap of a common criminal. I don’t get harassed, I don’t get intimidated, she cannot pull
this garbage with me and I will get to the bottom of it. It seems to me that this woman was
somehow planted to discredit Berg and the whole Obama’s illegibility for presidency litigation.
We don’t need tainted evidence coming from her, we will win without any evidence prepared by
her. There is sufficient evidence against Obama without her. I believe she is a diversion and was
put in place to discredit the effort. I believe Phil Berg needs to distance himself from her, and
cooperate in getting to the bottom of this matter before this issue becomes irreversible for him.
This entry was posted on Monday, May 11th, 2009 at 2:59 pm and is filed under Uncategorized. You can follow any
EXHIBIT “M”
**Note: Scroll past the Name list and you will see Taitz writings about Liberi.

2009
« need PA Fed court attorney

Go NY »
I need to get more answers

Please, look at these records again
Name - DUNHAM, STANLEY ANN
Gender - Male
Street Address - 1617 S BERETANIA ST APT 1008
City, State, Zip - HONOLULU HI 96826-1112
Probable Current Address - No
Telephone -
Telephone Accountholder -
Social Security - 535-40-xxxx
Age - 52
Date of Birth - Nov 29, 1942
Deceased - Yes
Date Record Verified - Mar 87 - Dec 08
*********************************************************************************************************
Name - SUTORO, STA

Gender - Male
Street Address - 1617 S BERETANIA ST APT 1008
Telephone -
Age - 67
Date of Birth - 1942
Deceased - No
Date Record Verified - Mar 87 - Aug 07
******************************************************************************
***************************
Name - DUNHAM, STANLEY A

Gender - Male
Street Address -
City, State, Zip - 96826
Telephone -
Age - 52
Deceased - Yes
Date Record Verified - Nov 95
******************************************************************************
***************************

Gender - Male
Street Address - C O MADELYN DUNHAM
City, State, Zip - HONOLULU HI 96826
Telephone -
Age - 52
Deceased - Yes
Date Record Verified - Oct 95
******************************************************************************
***************************
Name - SUTORO, STA

Gender - Male
Street Address - C O MADELYN DUNHAM
Telephone -
Age - 67
Deceased - No
Date Record Verified - Oct 95
******************************************************************************
***************************

Gender - Male
Street Address - 8 WEST ST APT 4
City, State, Zip - NEW YORK NY 10004-1001
Telephone -
Age - 52
Deceased - Yes
Date Record Verified - Oct 94 - Jan 95
******************************************************************************
***************************
Name - SUTORO, STA

Gender - Male
Street Address - 8 WEST ST APT 4
Telephone -
Age - 67
Deceased - No
Date Record Verified - Oct 94 - Jan 95
******************************************************************************
***************************
Name - SUTORO, STA

Gender - Male
Street Address - 235 E 40TH ST
Telephone -
Age - 67
Deceased - No
Date Record Verified - Apr 93
******************************************************************************
***************************
Name - SUTORO, STA

Gender - Male
Street Address - 1512 SPRECKELS ST STE E402
Telephone -
Age -
Date of Birth -
Deceased - No
Date Record Verified - Dec 92
******************************************************************************
***************************
Name - SUTORO, STA

Gender - Male
Street Address - 1512 S
Telephone -
Age -
Date of Birth -
Deceased - No
Date Record Verified - Jan 90 - Dec 91
******************************************************************************
***************************

Gender - Male
Street Address - 1512 SPRECKELS ST APT 402
Telephone -
Age - 52
Deceased - Yes
Date Record Verified - Jan 87
******************************************************************************
***************************

Gender - Male
Street Address - 235 E 40TH ST APT 8F
Telephone -
Age - 52
Deceased - Yes
Date Record Verified -
******************************************************************************
***************************
Name - ALBRIKTSEN, PHYLISS

Gender - Female
Street Address - 4424 156TH ST SE
City, State, Zip - BOTHELL WA 98012-4718
Telephone - 425-485-8815 - PST
Age -
Date of Birth -
Deceased - No
Date Record Verified –
As you can see somebody used this record of Obama’s mother, Stanley Ann Dunham, in
different fashion. There were records created for her as a female and as a male. Noteworthy is a
fact, that in 1987 she is marked as deceased, and in 1990, three years later, she is alive again.
Now look at this record with the social security number belonging to Stanley Ann Dunham and a
name of Phyliss Albriktsen. Who created this record and why? It has to be somebody, who knew
Dunham’s social and the name of her classmate from WA, Phyliss Albriktsen, who was only a
couple of months older then Dunham. I don’t think Phyliss created this record. Typically people
don’t know the social security numbers of their friends. Could it be Dunham herself? Could it be
“somebody” who was close to Dunham, knew her ss number and probably has seen Phyliss
Albriktsen’s name somewhere in an old year book?
Now look at Obama- see in Dossier #1- 100 addresses with 25 different ss numbers.
Now look at this Lisa Liberi, who prepared the records and the case for Phil Berg. I believe some
of those records were leading into a dead alley and association with her would ‘ve compromised
the case to the point of no return, specifically because of her history of forgery. Was she used to
compromise the whole effort? What is her history? Numerous convictions of grand theft
and forgery. Just like with Obama , her records show numerous social security numbers. I am
trying to ascertain where did she live before CA- all the states, addresses and ss numbers. When
exactly did she change her name to Liberi from Courville or Richardson? When did her husband
or ex-husband Brent change his name to Liberi? She claims to live in PA, but says that I invaded
her privacy by providing her address. The only address I provided was one in NM. How would it
harm a person in PA if an address of somebody in NM was disclosed? What is her real social
security number? Why did she apply for a new ss number in CA in 2000? Did she try to cover up
a prior criminal record? Just a year after she got this ss number in CA (not in PA) she was
arrested on economic crimes in Rancho Cucomanga, CA. For some of these crimes she got 8
year prison term in CA, that was reduced to probation, some are still pending trial. When did Phil
Berg find out about this record? Why did he continue employing her? Why does he still employ
her? Is he being threatened by her or somebody else? Is this a threat of disclosure of facts? What
facts? From what I understand, Momma E aka Evelyn Adams and her husband JD Adams lived
in CA too. Was there any connection between them and Liberi? Did they reside in PA or NJ? Do
they have any record? We really need to get to the bottom of all of this. We don’t want any
surprises in court. We need to know it all before it goes to trial.
This entry was posted on Wednesday, May 13th, 2009 at 7:41 am and is filed under HOT ITEMS!, Help Needed.
You can follow any responses to this entry through the RSS 2.0 feed. Both comments and pings are currently closed.
EXHIBIT “N”

2009
« Previous Post
Political Question Doctrine »
Please write to your congressmen and senators

Submitted on 2009/05/16 at 12:28am
On the news last night a man received a stimulus check for his mother, he told the reporter
that she died in 1967.
The Social Security Administration doesn’t seem to be very worried about it.
I haven’t worked in several years but I don’t qualify for a stimulus check because I didn’t
have income of at least $3,000. last year or the year before.
Please write to the Social Securtiy Administration. This is a real scheme. They need to clean the
records of the social security numbers of the deceased or people having numerous numbers. We
have seen Obama with numerous SS numbers, we have seen Lisa Liberi with numerous ss
numbers. These schemes brake the back of our economy. Demand from your state and US
representatives and senators to clean up SSA schemes, immediate audit of ss rolls, purging of all
ss numbers of the deceased or multiple numbers and vigorous prosecution for the ss fraud and
identity theft. Keep in mind that even theft of the ss number of the deceased is an identity theft
This entry was posted on Saturday, May 16th, 2009 at 5:47 am and is filed under Uncategorized. You can follow
any responses to this entry through the RSS 2.0 feed. Both comments and pings are currently closed.
EXHIBIT “O”

2009
« Who owns the land allocated for the North American Union Superhighway?
From reader Ted on disaster economy »
Voter verification
this is important. look at the link. It shows the states that require paper trail of the electronic
voting.
We need to do a couple of things.
1. Lets check those 100 addresses with 25 social security numbers for Obama, how did they
vote? What I mean: Did they vote? What residences on file?
2. We need to start checking from OH- swing state and SOS Jennifer Brunner was completely
out of control, she was allowing people to vote with the address of park in the bench. Buss loads
of people were coming from out of state, how many of them were bench in the park inhabitants?
3. I was curious about those several ss numbers of Lisa Liberi, any voting? In any states?
Flag this message
Voting issues
Wednesday, May 20, 2009 2:12 AM
From:
“Magnus Johansson”
To:
dr_taitz@yahoo.com
Orly!
Can this site http://www.verifiedvoting.org/index.php be of any help in your investigation

concerning voting fraud?
Regards,
Magnus
This entry was posted on Wednesday, May 20th, 2009 at 6:37 am and is filed under Uncategorized. You can follow
EXHIBIT “P”

2009
« from reader David Rachel

Chicago Protest, Where was all the news media on this one? »
Overview
Follow up on disappearing information and planted information.
I just got an e-mail from a woman by name Sue, I believe she is a lawyer. She is saying
that when she entered my name in the ABA registry, it was not there. Did somebody erase my
name from their on line registry to make me look not credible? Who did it?
What do we have so far:
1 Disinformation was planted one day before the election about a VA judge supposedly checking
Obama’s birth certificate and finding it to be valid and all challenges frivolous. No such case
ever existed, it was a planted fraud to create an illusion of Obama’s legitimacy and discourage
McCain voters one day before the election
2. one day after the election my case Lightfoot v Bowen was erased from the docket of the
Supreme Court. On march 13th I provided this info to chief Justice Roberts and nothing was
done.
3. my blog drorly.blogspot.com was destroyed. As readers tried to make comments, it would

crush. Google Jawa js -kit was blamed for it by the former web master Lisa Ostella, but nobody
knows, what was the reason
4. next blog defendourfreedoms.is went down several times- nobody knows why
5. e-mail address connected to my pay-pal was changed
6. my name is not on the ABA roster,even though it was supposed to be there
7. I discover 100 addresses for Obama, linked to 25 different ss numbers, report it to Holder,
Mueller, Sullivan, Roberts- no response
8. I discover 130 current job positions for Obama, report it - no response (dossier 1)
9. I confront William Chatfield- director of selective service with numerous evidence of forgery
in Obama’s selective service certificate- no response (Dossier4)
10. Forensic document examiner Sandra Ramsey Lines provides information and affidavit that
Obama’sCertificate of Live Birth cannot be relied upon as genuine, I report it- no response
(dossier 1 and 6)
10. Somebody erases from the National databases 110 addresses and job positions for Obama
and Michelle Obama, after those were already reported by me (Dossier 7)
11. somebody creates a a Scott Easterling blog and e-mail to assassinate the character of my
plaintiff active duty officer Scott Easterling and defame me and other plaintiffs- it is reported, no
response (dossier 1)
12. I uncover that Lisa Liberi, assistant for Philip Berg has an extensive criminal record in the
state of CA, including forgery of documents and grand theft. It was reported that Liberi was born
in the state of WA (I am verifying). Liberi has numerous social security numbers. Was she
planted to discredit the whole effort? I report it to Berg and recommend to go together to FBI and
demand investigation and to hire a forensic document examiner to check all the docs handled by
her. Instead Berg is filing a frivolous malicious law suit against me and everybody around, trying
to intimidate me and trying to keep me quite.
13. Berg is trying to obfuscate the truth by posting his office address in the pleadings as hers
even though she lives in Santa Fe NM and corresponds with Berg by e-mails and phone
while she is being supervised by the Santa Fe probation officers.
14. My husband just told me, that somebody posted on the Internet information from our
children’s birth certificates. How could that happen? Here I am working 24/7, trying to unseal
Obama’s BC with a compelling and a legitimate reason and nobody in our corrupt establishment
does a thing, and on the other hand somebody can unseal my children’s BC’s with no legitimate
reason. Why? To intimidate me some more? To threaten my kids? To show me that somebody
can do what ever he …likes and I cannot do a … about it?
15. Last year tampering into passport records of presidential candidates was announced. 3
employees were fired. I talked to one of them, he said nothing wrong was done, he sounded
pretty scared. One of the people involved Lt. Harris was found dead, shot in the head.
Will there be an end to this. I refuse to believe that we don’t have any decent people in our law
enforcement- there has to be somebody in FBI, CiA, police, sheriffs, judges, US attorneys, Atty
generals, DAs, state and US representatives, senators, SOS, governors. We need one person to
sign the …subpoenas.It has to be done Now!!!
In re to FBI, I called recently the cyber crimes detective Nathan Le, who was assigned to my
case, where this banner in Arabic, showing hanging of Saddam Hussein appeared on the site of a
man, who initiated erasing of an article about me from the Wikipedia. Detective Le told me, that
he needs to talk to his supervisor John Haas 714-542-8825. All the info was given to him, but I
believe this man is simply lazy and incompetent. When I talked to him last month, I told him to
look up something on his computer, he said that he is rather new, he has been at this department
only three months and the Internet is not hooked up to his computer yet. when I started laughing,
he didn’t even get the irony, in the fact that the supervisor of the cyber crimes unit is on the job
for three moths and doesn’t have the Internet hooked up yet?!? Guys, we are really in good
hands!
I called the police, Teresa Standiford is assigned to my case. She told me to file a new report
about the threats. The rest should be in Santa Fe as Liberi resides there.
North Brunswick police needs somebody to actually come to the station and file a report there.
Does anybody live close and can go to the station and file?
This nightmare has to end soon. Look the way our economy is being destroyed and our National
Security is being destroyed. We have to find somebody, who would do the right thing. I see that
Cheney started speaking up. He still has a lot of connections. Biden blubbered that Cheney
left Obama’s BC in the desk. Well, Mr. Cheney, it’s time.
This entry was posted on Friday, May 22nd, 2009 at 12:55 pm and is filed under Uncategorized. You can follow any
EXHIBIT “Q”

2009
« Follow up MS+American Family Radio

Service of process to court sent 05.23.09. »
** DUPLICATES AND FEDERAL EXPRESS PICTURES REDACTED**
Berg
UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA
LISA LIBERI §
And §
PHILIP J. BERG, ESQUIRE § CIVIL ACTION NO. 09-1898
And §
THE LAW OFFICES OF PHILIP J. BERG §
And §
EVELYN ADAMS a/k/a MOMMA E §
and §
LISA M. OSTELLA §
And § Assigned to Honorable Eduardo C.
GO EXCEL GLOBAL, § Robreno
§
Plaintiffs §
§
§
Vs. §
§
§
ORLY TAITZ, a/k/a DR. ORLY TAITZ, §
a/k/a LAW OFFICES OF ORLY TAITZ, §
a/k/a WWW.ORLY TAITZESQ.COM a/k/a §
WWW.REPUBX.COM a/k/a ORLY TAITZ §
And §
LINDA SUE BELCHER a/k/a LINDA S. §
BELCHER a/k/a LINDA STARR a/k/a §
NEWWOMENSPARTY a/k/a §
STITCHENWITCH a/k/a EVA BRAUN §
a/k/a WEB SERGEANT a/k/a KATY a/k/a §
WWW.OBAMACITIZENSHIPDEBATE.ORG §
And §
EDGAR HALE a/k/a JD SMITH, §
And §
CAREN HALE, §
And §
PLAINS RADIO NETWORK, §
a/k/a PLAINS RADIO NETWORK, §
INC. a/k/a §
PLAINS RADIO, §
And §
BAR H FARMS; §
And §
KPRN AM 1610; §
And §
DOES 1 through 200 Inclusive §
§
Defendants §
ANSWER
Defendants deny all allegations of wrong doing contained in the complaint.

Dated:
____________________
Dr. Orly Taitz, ESQ

26302 La Paz ste 211
Mission Viejo, CA 92691
Pro se and as the President of Defend our Freedoms Foundation on behalf of Defend Our
Freedoms Foundation.
Certificate of Delivery
I, Orly Taitz, certify that a true and correct copy of the foregoing was mailed to Philip Berg on
this 22 day of May, 2009 via Overnight Federal Express and via ForSure Legal Services Service
of Process, 250 Woodlake Dr. Holland PA 18966
_____________________
Orly Taitz
LISA LIBERI §
And §
PHILIP J. BERG, ESQUIRE § CIVIL ACTION NO. 09-1898
And §
THE LAW OFFICES OF PHILIP J. BERG §
And §
EVELYN ADAMS a/k/a MOMMA E §
and §
LISA M. OSTELLA §
And § Assigned to Honorable Eduardo C.
GO EXCEL GLOBAL, § Robreno
§
Plaintiffs §
§
§
Vs. §
§
§
ORLY TAITZ, a/k/a DR. ORLY TAITZ, §
a/k/a LAW OFFICES OF ORLY TAITZ, §
a/k/a WWW.ORLY TAITZESQ.COM a/k/a §
WWW.REPUBX.COM a/k/a ORLY TAITZ §
And §
LINDA SUE BELCHER a/k/a LINDA S. §
BELCHER a/k/a LINDA STARR a/k/a §
NEWWOMENSPARTY a/k/a §
STITCHENWITCH a/k/a EVA BRAUN §
a/k/a WEB SERGEANT a/k/a KATY a/k/a §
WWW.OBAMACITIZENSHIPDEBATE.ORG §
And §
EDGAR HALE a/k/a JD SMITH, §
And §
CAREN HALE, §
And §
PLAINS RADIO NETWORK, §
a/k/a PLAINS RADIO NETWORK, §
INC. a/k/a §
PLAINS RADIO, §
And §
BAR H FARMS; §
And §
KPRN AM 1610; §
And §
DOES 1 through 200 Inclusive §
§
Defendants §
Motion to Dismiss Due to Lack of Jurisdiction

Here come the defendants Orly Taitz, pro se and Orly Taitz, President of Defend
Our Freedoms Foundation on behalf of Defend Our Freedoms Foundation and
allege the following:
1. Current action has no nexus to the State of Pennsylvania and no subject
matter jurisdiction. The defendants do not reside within this jurisdiction
within the meaning of 28 U.S.C.A. § 1391 (b) and the claim for which
this action arose is outside of this jurisdictional district. No federal
question is alleged in the complaint. Notwithstanding the above, the
defendants deny every allegation of the Plaintiff’s claim.
2. Above legal action stems from fraudulent use of name and Good Will of
Defend Our Freedoms foundation by web master Lisa Ostella,
(hereinafter Ostella) plaintiff in this action, resident of New Jersey and
financial benefit drawn by other plaintiffs in this action as a result of
Ostella’s activities.
3. Defend Our Freedoms foundation is registered in the state of California
by Orly Taitz, ESQ (Taitz, hereinafter), president of the foundation, resident
of the state of California as well. Initial registration form, State of
California, Office of the Attorney General, Registry of Charitable Trusts
submitted on December 17, 2008, Recorded in Orange County,
California 12.23.08
4. Orly Taitz never went by the name www.repubx.com and it is not an
a/k/a of Orly Taitz. Repubx.com is a web site/blog, owned by another
party, with no relation to this action.
5. www.orlytaitzesq.com is not a legal entity and not an a/k/a for Orly Taitz.
www.orlytaitzesq.com is a name of a blog/website run by Orly Taitz.
6. Orly Taitz, inc is not an a/k/a for Orly Taitz. It is a name of a dental
practice in California, incorporated and separate legal entity, with no
relation to current dispute.
7. Law offices of Orly Taitz are not an a/k/a for Orly Taitz. It is a name of a
law office with no relation to the dispute.
8. Plaintiff Lisa Liberi (hereinafter Liberi) is a Resident of the State of New
Mexico. Plaintiff’s attorney Philip Berg (Hereinafter Berg) has listed Liberi‘s
address to be an address of his office in Pennsylvania, however Liberi
does not reside in the state of Pennsylvania nor physically work in Berg’s
office in the state of Pennsylvania. Liberi is an assistant, who has some
legal background related to her own criminal convictions and who assists
Berg occasionally via e-mails, phone and mail sent from her residence in
New Mexico. Berg has improperly asserted her residence in Pennsylvania,
due to the fact that this is a state where he is licensed to practice law, in
order to try to obfuscate her real residence in New Mexico and
improperly bring a legal action in the state of Pennsylvania. Liberi claims
that she was defamed by Orly Taitz, disclosing to the public, Court
printout of Liberi’s convictions of forgery and grand theft. Taitz denies all
allegations and assets that all of the information provided was truthful
and convictions in question were in the state of California, (addendum 1

Printout of Liberi convictions in San Bernardino county, California) Liberi’s
prosecuting district Attorney James Secord is in San Bernardino County,
California; arresting officer and all of the detectives are in the state of
California, numerous victims of her criminal activity and potential
witnesses in this action are in the state of California, therefore a proper
jurisdiction for this action and forthcoming counter complaint is in the
state of California.
9. Liberi got an eight year term in January 2008 in California, she is currently
on probation and would be extradited back to California to serve her
term, if she indeed violated the conditions of her probation.
10. When Ostella fraudulently represented herself as Defend Our Freedoms
foundation and solicited donations for the Defend Our Freedoms
Foundation, Taitz has written a cease and desist letter to Ostella, Berg
and Adams, who were benefiting from Ostella’s activities.
11. When the above activity did not cease and desist, Taitz has filed a police
report, describing donations fraudulently misdirected from Defend our
freedoms foundation. The report 09-068339 was filed in the city of
registration of the foundation, Mission Viejo in the state of California,
which would be a proper jurisdiction in this action. (Addendum 2- Orange
County, California Recording for Defend Our Freedoms Foundation,
Addendum 3 Police report 09-068339)
12. Liberi, had developed a modus operandi of filing malicious and frivolous
law suits against victims of her criminal behavior, law enforcement and
judiciary in order to gain some advantage in her criminal prosecution
and in fact she has filed so many frivolous complaints and legal actions
against the District Attorney, District Attorney’s office, Presiding Judge,
police officers, detectives, her own defense attorneys, San Bernardino
County in California and even hospital, where she was treated, that as a
condition of her probation, she is obligated to properly clear with her
probation department any legal action she is planning to file. If Liberi did
not fulfill her obligation, probation will be revoked and she will be
extradited from New Mexico to California to serve her eight year prison
term, which makes California a proper Jurisdiction. (addendum 1 )
13. Most of victims of Liberi’s malicious and frivolous law suits reside in the
state of California, which would be a proper jurisdiction.
14. Liberi has gotten a reduction of her prison term to probation due to her
claim of being sick and disabled. Taitz has called District Attorney of San
Bernardino County James Secord and verified, that Liberi is on disability
and receiving disability payments from Social Security Administration. In
current case Berg states that Liberi is employed at his office. If indeed
Berg is paying or was paying Liberi a salary or any other payment directly
or indirectly through her husband Brent Liberi, while Liberi was receiving
social security payments for disability, that would constitute Social
Security fraud, violation of her probation and would be grounds for her
extradition to California to serve her eight year prison term, which makes
the state of California a proper Jurisdiction.
15. Due to the fact, that Liberi was convicted of economic crimes and
forgery of documents, as a condition of her probation, she is not allowed
to have any access to credit cards belonging to others or bank accounts
belonging to others. Berg’s office was handling a large donations drive. If

indeed Liberi directly or indirectly was handling credit cards or credit
card accounts of others, she will be in violation of her probation and will
be extradited to California, a proper jurisdiction in this case.
16. Due to the above, Berg, an attorney for Ostella, Liberi and Adams being
concerned that upon completion of the police investigation in California,
Taitz will file a legal action against his clients and him personally,
improperly filed a legal action in Pennsylvania with no nexus to the
dispute at hand, with the sole purpose of harassing and intimidating Taitz
and other defendants and trying to denigrate Taitz in anticipation of trial.
Due to the above defendants respectfully request dismissal of the current action
in the state of Pennsylvania due to lack of subject matter jurisdiction and
personal jurisdiction. Venue was improperly under 28 U.S.C.A. §1391 (b)
Wherefore, defendants demand judgment that the complaint be dismissed,

together with the costs and disbursements of this action.
Dated 05.21.09.
Dr. Orly Taitz ESQ
26302 La Paz, ste 211
Pro Se and on behalf of Defend our Freedoms Foundation and as a president of

Defend Our Freedoms Foundation
Addendum 1 Case FWV028000 - Defendants
Seq Defendant Next Court Date Status Agency / Arrest Date Count 1 Charge Violation Date
DR Number
1 LIBERI , LISA R RA 05/18/2001 PC 115(A) 05/18/2001

110013759
ALIAS: LIBERI, LISA R

ALIAS: COURVILLERICHARDSON, LISA
ALIAS: LIBERI, LISA A
ALIAS: RICHARDSON, LISA C
ALIAS: COURVILLERICH, LISA
ALIAS: LIBERI, LISA RENEE
ALIAS: LIBERI, LISA
ALIAS: RICHARDSON, LISA RENEE
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE - Status
Custody N/A
Filing Type Held to Answer Filing Date 05/09/2003
Ordered Bail $0.00 Posted Bail $0.00
D.A. James R. Secord Defense Dean Pitcl (Court Appointed)
Next Action: Deputy Report #: RA-RC 110013759
Warrant Type Status Issued Affidavit
NONE N/A N/A
Probation Type Granted Expiration
Formal 03/21/2008 03/21/2011
Sentence Convicted Date County Jail CTS
01/25/2008 26 Days 26 Days
State Prison Max Sentence
N/A N/A
Fine and Penalty Restitution Fine Restitution to Victim
0 N/A
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE - Charges
Arrest Charges
Count Charge Severity Description Violation Plea Status

Date
1 PC 459 F BURGLARY 05/18/2001
Filed Charges

Date
1 PC 487(A) F GRAND THEFT: PROPERTY/ETC 05/18/2001 HTA

OVER $400
2 PC 470(D) F FORGERY 05/18/2001 HTA
4 PC 115(A) F OFFER/ETC FALSE/FORGED 05/18/2001 HTA

INSTRUMENT TO FILE

OVER $400
6 PC 470(D) F FORGERY 05/18/2001 HTA

INSTRUMENT TO FILE

OVER $400

OVER $400
11 PC F GRAND THEFT: 05/18/2001 HTA
487(D)(1) AUTOMOBILE/ANIMAL/ETC

OVER $400


OVER $400


OVER $400

OVER $400
Infor Charges

Date
1 PC 487(A) F GRAND THEFT: PROPERTY/ETC 05/18/2001 GUILTY CONVICTED

OVER $400
Case FWV028000 - Defendants
Seq Defendant Next Court Date Status Agency / Arrest Date Count 1 Charge Violation Date
DR Number
1 LIBERI , LISA R RA 05/18/2001 PC 115(A) 05/18/2001

110013759

ALIAS: LIBERI, LISA
Custody N/A
NONE N/A N/A
Formal 03/21/2008 03/21/2011
01/25/2008 26 Days 26 Days
N/A N/A
0 N/A

Arrest Charges

Date
1 PC 459 F BURGLARY 05/18/2001
Filed Charges

Date

OVER $400
2 PC 470(D) F FORGERY 05/18/2001 HTA

INSTRUMENT TO FILE

OVER $400
6 PC 470(D) F FORGERY 05/18/2001 HTA

INSTRUMENT TO FILE

OVER $400

OVER $400


OVER $400

OVER $400


OVER $400

OVER $400
Infor Charges

Date

OVER $400
2 PC F NONSUFFICIENT FUNDS: CHECKS 05/18/2001 GUILTY CONVICTED

476A(A)
3 PC 470(D) F FORGERY 05/18/2001 DISMISSED
4 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 DISMISSED
5 PC 115(A) F OFFER/ETC FALSE/FORGED 05/18/2001 GUILTY CONVICTED

INSTRUMENT TO FILE

OVER $400
7 PC 476 F MAKING, POSSESSING, UTTERING 05/18/2001 DISMISSED

FICTIOUS INSTRS
9 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 GUILTY CONVICTED
10 PC 115(A) F OFFER/ETC FALSE/FORGED 05/18/2001 DISMISSED

INSTRUMENT TO FILE
OVER $400

OVER $400
13 PC F GRAND THEFT: 05/18/2001 DISMISSED

14 PC 487(A) F GRAND THEFT: PROPERTY/ETC 05/18/2001 DISMISSED

OVER $400

16 PC 487(A) F GRAND THEFT: PROPERTY/ETC 05/18/2001 DISMISSED

OVER $400


OVER $400

OVER $400
20 PC 115(A) F OFFER/ETC FALSE/FORGED 05/18/2001 GUILTY CONVICTED

INSTRUMENT TO FILE
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE - Probation
Probation Type: FORMAL Granted: 03/21/2008 Expire: 03/21/2011
SUPERVISED PROBATION GRANTED FOR A PERIOD OF 36 MONTHS ON FOLLOWING TERMS

AND CONDITIONS:
1) SERVE 26 DAYS IN A SAN BERNARDINO COUNTY JAIL FACILITY, WITH CREDIT FOR
TIME SERVED, A MATTER OF 26 DAYS, PLUS CONDUCT CREDIT PURSUANT TO 1-
PC4019 ND ABIDE BY ALL RULES AND REGULATIONS OF THE FACILITY WITHOUT
THE POSSIBILITY OF COUNTY PAROLE.
2) VIOLATE NO LAW.
3) REPORT TO THE PROB OFFICER IN PERSON IMMEDIATELY 0- ND THEREAFTER

ONCE EVERY FOURTEEN (14) DAYS OR AS DIRECTED. REPORT TO THE PROB
OFFICER IN PERSON IMMEDIATELY 0- ND THEREAFTER ONCE EVERY FOURTEEN
(14) DAYS OR AS DIRECTED.
4) COOPERATE WITH THE PROBATION OFFICER IN A PLAN OF REHABILITATION AND

FOLLOW ALL REASONABLE DIRECTIVES OF THE PROBATION OFFICER.
5) SEEK AND MAINTAIN GAINFUL EMPLOYMENT, OR ATTEND SCHOOL, AND KEEP THE
PROBATION OFFICER INFORMED OF STATUS OF EMPLOYMENT, OR SCHOOL.
6) KEEP THE PROBATION OFFICER INFORMED OF PLACE OF RESIDENCE AND

COHABITANTS AND GIVE WRITTEN NOTICE TO THE PROBATION OFFICER TWENTY-
FOUR (24) HOURS PRIOR TO ANY CHANGES. PRIOR TO ANY MOVE PROVIDE
WRITTEN AUTHORIZATION TO THE POST OFFICE TO FORWARD MAIL TO THE NEW
ADDRESS. PERMIT VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGENTS
OF THE PROBATION DEPT. AND/OR LAW ENFORCEMENT FOR THE PURPOSE OF
ENSURING COMPLIANCE WITH PERMIT VISITS AND SEARCHES OF PLACES OF
RESIDENCE BY AGENTS OF THE PROBATION DEPT. AND/OR LAW ENFORCEMENT
FOR THE PURPOSE OF ENSURING COMPLIANCE WITH PERMIT VISITS AND
SEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THE PROBATION DEPT.
AND/OR LAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCE WITH
THE TERMS AND CONDITIONS OF PROBATION; NOT DO ANYTHING TO INTERFERE
WITH THIS REQUIREMENT, OR DETER OFFICERS FROM FULFILLING THIS
REQUIREMENT, SUCH AS THE TERMS AND CONDITIONS OF PROBATION; NOT DO
ANYTHING TO INTERFERE WITH THIS REQUIREMENT, OR DETER OFFICERS FROM
FULFILLING THIS REQUIREMENT, SUCH AS ERECTING ANY LOCKED FENCES/GATES
THAT WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE ANY ANIMALS ON
THE PREMISES THAT WOULD REASONABLY DETER, ERECTING ANY LOCKED
FENCES/GATES THAT WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE
ANY ANIMALS ON THE PREMISES THAT WOULD REASONABLY DETER, THREAT
THREATEN THE SAFETY OF, OR INTERFERE WITH, OFFICERS ENFORCING THIS
TERM. EN THE SAFETY OF, OR INTERFERE WITH, OFFICERS ENFORCING THIS
TERM.
7) NEITHER POSSESS NOR HAVE UNDER YOUR CONTROL ANY DANGEROUS OR

DEADLY WEAPONS OR EXPLOSIVE DEVICES OR MATERIALS TO MAKE EXPLOSIVE
DEVICES.
SUBMIT TO A SEARCH AND SEIZURE OF YOUR PERSON, RESIDENCE AND/OR

PROPERTY UNDER YOUR CONTROL AT ANY TIME OF THE DAY OR NIGHT BY ANY
LAW-ENFORCEMENT OFFICER, WITH OR WITHOUT A SEARCH WARRANT, AND WITH
OR WITHOUT CAUSE (PEOPLE -V- BRAVO).
9) NEITHER USE NOR POSSESS ANY CONTROLLED SUBSTANCE WITHOUT MEDICAL

PRESCRIPTION. A PHYSICIANS’S WRITTEN NOTICE IS TO BE GIVEN TO THE
PROBATION OFFICER.
10) SUBMIT TO A CONTROLLED SUBSTANCE TEST AT DIRECTION OF PROBATION
OFFICER. EACH TEST IS SUBJECT TO AN $11.00 FEE, TO BE COLLECTED BY
CENTRAL COLLECTIONS
11) NOT POSSESS ANY TYPE OF DRUG PARAPHERNALIA, AS DEFINED IN H&S11364.5(D)
12) PARTICIPATE IN A COUNSELING PROGRAM AS DIRECTED BY THE PROBATION

OFFICER, SUBMIT MONTHLY PROOF OF ATTENDANCE AND/OR SUCCESSFUL
COMPLETION TO THE PROBATION OFFICER AS DIRECTED AND BE RESPONSIBLE
FOR PAYMENT OF ALL PROGRAM FEE(S).
13) NOT ASSOCIATE WITH KNOWN CONVICTED FELONS OR ANYONE ACTIVELY

ENGAGED IN CRIMINAL ACTIVITY B-OR CODEFENDANT(S) OR VICTIM(S).
14) NOT ASSOCIATE WITH KNOWN ILLEGAL USERS OR SELLERS OF CONTROLLED

SUBSTANCES,
15) NOT MAINTAIN A CHECKING ACCOUNT OR COMPLETE OR ENDORSE ANY CHECKS

UNLESS MADE PAYABLE TO YOU AND NOT HAVE ANY BLANK CHECKS IN YOUR
POSSESSION WITHOUT PERMISSION OF THE PROBATION OFFICER.
16) SUBMIT A RECORD OF INCOME AND EXPENDITURES TO THE PROBATION OFFICER

QUARTERLY.
17) NEITHER POSSESS NOR USE ANY CREDIT CARD WITHOUT PERMISSION OF THE
PROBATION OFFICER.
18) NOT DRIVE OR POSSESS KEYS OR DOCUMENTATION TO ANY MOTOR VEHICLE

UNLESS LEGALLY REGISTERED TO YOU OR AN IMMEDIATE FAMILY MEMBER,
EXCEPT IN THE COURSE OF EMPLOYMENT.
19) REPORT ALL MOTOR VEHICLES REGISTERED TO YOU TO THE PROBATION OFFICER
WITHIN SEVEN (7) DAYS OF ACQUISITION.
20) SUBMIT TO AND COOPERATE IN A FIELD INTERROGATION BY ANY PEACE OFFICER

AT ANY TIME OF THE DAY OR NIGHT.
21) CARRY AT ALL TIMES A VALID DRIVERS LICENSE OR DEPARTMENT OF MOTOR

VEHICLES IDENTIFICATION CARD AND DISPLAY SUCH IDENTIFICATION UPON
REQUEST BY ANY PURPOSE WITHOUT FIRST NOTIFYING THE PO. CONTAINING
YOUR TRUE NAME AGE AND CURRENT ADDRESS
22) ENROLL IN THE DRUG TREATMENT PROGRAM AT THE DIRECTION OF THE

PROBATION OFFICER, AND SHOW PROOF OF ENROLLMENT TO THE PROBATION
OFFICER WITHIN SEVEN (7) DAYS.
23) MAKE RESTITUTION TO THE VICTIM(S) (SEE PROBATION REPORT) IN THE AMOUNT
OF $9223.77 PLUS A 10% ADMINISTRATIVE FEE, TO BE PAID THROUGH CENTRAL
COLLECTIONS
24) MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORT) IN THE AM OUNT OF
$35000.00 PLUS A 10% ADMINISTRATIVE FEE, TO BEPAID THROUGH CENTRAL
COLLECTIONS
25) MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORT) IN THE AMO UNT OF
$66951.08 PLUS A 10% ADMINISTRATIVE FEE, TO BE PAID THROUGH CENTRAL
COLLECTIONS
26) PAY A RESTITUTION FINE IN THE AMOUNT OF $200.00, PLUS A TEN PERCENT (10%)
ADMINISTRATIVE FEE THROUGH CENTRAL COLLECTIONS.
27) THE DEFENDANT IS NOT TO FILE ANY LAWSUIT/LEGAL ACTION WITHOUT PRIOR
CONTACT WITH PROBATION OFFICER.
28) DO NOT APPLY FOR CREDIT OR A LOAN WITHOUT PRIOR CONTACT WITH
PROBATION OFFICER.
29) COMPLY WITH ANY COURT-ORDERED PAYMENT SCHEDULE.
30) MAKE RESTITUTION TO VICTIM (SEE PROBATION REPORT) IN AN AMOUNT TO BE

DETERMINED BY PROBATION.
31) MAKE RESTITUTION TO VICTIM (SEE PROBATION REPORT) IN AN AMOUNT TO BE

DETERMINED BY PROBATION.
32) PROBATION MAY BE SERVED THROUGH INTER STATE COMPACT AGREEMENT IN

THE STATE OF NEW MEXICO UPON APPROVAL FROM PROBATION.
Tags: birth certificate, crimes Lisa Ostella, eligibility, Lisa Liberi, natural born citizen
This entry was posted on Thursday, May 28th, 2009 at 2:36 am and is filed under Supporting Documentation,
Uncategorized. You can follow any responses to this entry through the RSS 2.0 feed. Both comments and pings are
currently closed.
EXHIBIT “R”
** Note, the below emails are fabricated and altered emails all proof of which has been
filed in the lower Court in different pleadings **

2009
« From reader Bob S. Did anyone see Hank Paulson coming out of his house lately?
Re Keyes v Obama »
I am trying to stay away from Liberi-Berg issue, but i got more

questions and here is more info.
I was asked by a number of people to explain why the name of Lisa Ostella is on the dossier #4.
When I was in Washington DC, I did not have an access to the Internet, as I was visiting the
Director of the Selective Service William Chatfield and offices of several senators and was on
the phone with the assistant and legal counsel for Admiral Malin. A lot of people asked me for
an update and I called Lisa Ostella, the web master ,and asked her to post it on the Internet. As
you can see, the fact that she signed DefendOurfFeedomsFoundations, and she put her name as
an assistant to me, clearly shows that she knew it is my foundation, under my name and
she could sign as an assistant only as long as she was helping me. The moment I transferred to
another webmaster, she had and has no right to advertise on behalf of the DefendOurFreedoms
foundation, solicit donations and pocket the money.
You can also see (in the attachment) that she was the one that contacted the private investigator
Mr. Sankey, and provided him the information that Lisa Liberi , assistant to Phil Berg, has a
criminal record. Based on her report Mr. Sankey has investigated and confirmed this
information, that indeed Lisa Liberi has this lengthy record of forgery of documents and forgery
of an official seal and grand theft. Lisa Ostella changed her tune only after this whole issue with
pay-pal came out. At first she and the rest of the plaintiffs came out with an outrageous lie that
my husband was spying on people. Now they dismissed their law suit against my husband- and
everybody knows that it was a manufactured charge.
As you can see, she was well aware about Liberi’s criminal record, as was Berg and Liberi
herself. Their legal action is nothing but perjury and an attempted obstruction of justice. I have
written in the pleadings that the only address that Liberi provided, was Berg’s office address
and the reason is that she indeed resides in NM and is the Lisa Liberi with the criminal record. I
received an e-mail recently that in the last couple of days Lisa Liberi has gotten a PA drivers
license. If she got one in the last couple of days, that doesn’t change the fact that she resided in
NM and that all of them committed perjury. If anything, getting a PA drivers license now is
yet another attempt to obstruct justice.
As I have said before, I don’t get intimidated by either Obama or by Berg. One cannot file a
fraudulent and malicious legal action against me and expect to shut me up and make me stop
reporting on illegal and criminal activity. All that these people are doing, is adding counts of
fraud, perjury and obstruction of justice. The only thing Berg can do, is come clean, disassociate
himself from Lisa Liberi, who has a record of forgery and he needs to hire a forensic document
examiner to check all the records handled by Lisa Liberi. We cannot win in court with forged
records. This information was already on the blogs before I got it and it will be on the blogs, his
continuing denial of clear evidence has no merit and undermines everybody in the resistance
movement, everybody who wants to get to the truth. The only way to win, is by clean evidence,
unsealing the vital records and letting the Supreme Court decide the issue of the Natural Born
Citizen.
> From: nsankey@thesankeyfirm.com

> To: lisaostella@hotmail.com
> Subject: RE: HELLO ??? (again)
> Date: Sun, 15 Mar 2009 17:02:00 -0700
>
> Indeed it would. If you would pass this on to Dr.O, I will go out to San Bdo
> this week and have a look at the 2002 file, dontcha think?
>N
>
> —–Original Message—–
> From: Lisa Ostella [mailto:lisaostella@hotmail.com]
> Sent: Sunday, March 15, 2009 4:49 PM
> To: Neil Sanky
> Subject: RE: HELLO ??? (again)
>
> Hmm, if the forged documents actually came out of Phil Berg’s office, well,
> filing lawsuits would be an excellent cover, huh?
>
> Factcheck is in Pennsylvania.
>
> As is Phil Berg.
>
>
> Lisa Ostella
> Defend Our Freedoms Foundation
> http://defendourfreedoms.org <http://defendourfreedoms.org/>
> Peace through Strength
> http://www.barofintegrity.com <http://www.barofintegrity.com/>
>
>
>
>
>
>
>
>
> > From: nsankey@thesankeyfirm.com
> > To: lisaostella@hotmail.com
> > Subject: RE: HELLO ??? (again)
> > Date: Sun, 15 Mar 2009 16:35:46 -0700
>>
> > Yes but a SEAL !!, and HOW MANY aliases?
>>
> > —–Original Message—–
> > From: Lisa Ostella [mailto:lisaostella@hotmail.com]
> > Sent: Sunday, March 15, 2009 3:46 PM
> > To: Neil Sanky
> > Subject: RE: HELLO ??? (again)
>>
> > Insight, such as, Lisa Liberi (Phil Berg’s assistant) really being Lisa
> > Richards, with a police record for ID theft?
>>
> > Mighty convenient talent to have when there are multiple identities flying
> > around.
>>
> > I’ve not researched that insight yet. I didn’t have a warm and fuzzy
> > interaction with (redacted name of volunteer )So I don’t know if this is planted info
droppings
> > or not.
>>
>>
> > Lisa Ostella
> > Defend Our Freedoms Foundation
> > http://defendourfreedoms.org <http://defendourfreedoms.org/>
> > Peace through Strength
> > http://www.barofintegrity.com <http://www.barofintegrity.com/>
>>
This entry was posted on Sunday, May 31st, 2009 at 2:19 pm and is filed under Uncategorized. You can follow any
EXHIBIT “S”
http://www.orlytaitzesq.com/blog1/?m=200906&paged=7

2009
Monday, June 15th, 2009
Update on Berg
I really tried to stay away from the frivolous action by Philip Berg, as I think it is just a
distraction and a waste of my time, however since he filed a legal action and he issues
frequent press releases with outrageous slanderous statements about me, I have to
respond.
This is not the first time Berg brings an action with manufactured allegations. Please
see an attachment below showing Berg being sanctioned by the court and fined over
$10,000 for bringing a frivolous baseless law suit with the sole purpose of harassing the
other party.
In regards to his legal actions- the one that he called a law suit under seal, was actually
not a law suit but a request for Atty. General to file a law suit. It was stating that Obama
is not only not a Natural Born Citizen, but not a citizen at all, which is harder to prove, as
he could’ve become a citizen at any time. The request, filed by Berg, was asking the
Attorney General to take back Obama’s salary of the senator, whereby Berg were to get
a certain percentage of it, as a whistleblower. I was just skeptical about the viability of
such a request.
In regards to two other legal actions he filed, they were dismissed and from January
Berg was saying that he has an oral argument scheduled for May. The month of May
came and went and there was no argument and nobody could find any such argument
scheduled on the docket. Now he is saying that there is an argument scheduled for
September-October, but again nobody can find anything scheduled.
The only law suit he has going, is one with slanderous allegations against me and his
only occupation as of late has been issuing outrageous press releases about me and
asking for money so he can slander me some more and can file more law suits against
me. It is just despicable that Berg, who was sanctioned by the court and fined for
bringing frivolous action with the sole purpose of harassment is calling to have me
disbarred, that Berg, who is employing Lisa Liberi, a convicted criminal, with 10 felony
convictions of grand theft, forgery of documents and forgery of seal (see record
attached), is accusing others of forgery and fraud, including a licensed investigator with
20 years of experience in Scotland Yard and over 15 years of experience, Mr. Sankey,
a Christian minister and editor of Christian publishing Pastor James Sundquist, a radio
station, a talk show host, the wife of a talk show host and even their own volunteer. I
have attached a copy of the second amended motion to dismiss due to lack of
jurisdiction. I was asked –what does it mean. You are supposed to file such a motion
first, as if there is no jurisdiction the case is dismissed right then and there before it
goes any further. I hope Eastern District Court of Pennsylvania judge Eduardo Robreno
will dismiss this case shortly.
Since my foundation Defend Our Freedoms Foundation (DOFF) is registered in

California, I have filed a complaint with the Attorney General of California, Orange
County FBI and Mission Viejo, Orange County Police, asking them to investigate
actions by Lisa Ostella, Lisa Liberi, Evelyn Adams and Philip Berg, whereby Lisa Ostella
is fraudulently diverting donations from DOFF to her own pocket and Liberi, Adams and
Berg are being unjustly enriched by her actions and their own actions.
I have also included a list of legal actions and initiatives I am currently spearheading. I
am asking for your support and follow up with governmental officials. I firmly believe that
unsealing of Obama’s records is only a first step in the direction of the true transparency
in government, that there is a long way ahead in turning around this economy. It will not
improve with empty slogans of hope and change and wasting billions of dollars on un-
stimulating stimulus, which stimulates only the printing press, that prints funny money,
which soon will be less valuable then money from Toys R Us. This economy will not
change and improve by giving billions to the thugs from Acorn, the thugs from Hamas
and the crooks from AIG transferring 59% of the stimulus to stimulate foreign banks.
We will achieve true economic growth and improvement, when we realize that the free
market economy benefitted only a few billioners, It bankrupted this whole country. We
need to go back to sanity, we need balanced trade, we need balanced budget for each
and every state and the country in general, we need to fight governmental corruption,
we need to start producing again. This is a monumental task. It will take more then one
or two lawyers to make a difference. It will take each and every one of you working 24/7
to turn this country around. Please go through the list. I need a couple of volunteers to
go through the earlier posts and insert the contact info for the officials. Please, form
lobbying groups and don’t take no for an answer. We need to reach each and every law
enforcement and governmental official and we need to make all of them accountable.
Any official, who violates the Constitution and his oath of office and allows fraud and
treason, will be held accountable by the citizens of this country. Please join 4th of July
tea parties and September 12-13 Nation Renewal million men march on Washington. I
will be speaking there.
Lawyer Slapped With $10K in Sanctions for ‘Laundry List of Unethical Actions’
Shannon P. Duffy
The Legal Intelligencer
July 25, 2005
Printer-friendly Email this Article Reprints & Permissions
Finding that a Pennsylvania lawyer had committed a “laundry list of unethical actions,” a federal
judge has imposed more than $10,000 in sanctions and ordered the lawyer to complete six hours
of ethics training.
U.S. District Judge J. Curtis Joyner’s 10-page opinion in Holsworth v. Berg is packed with
criticism of the conduct of attorney Philip Berg of Lafayette Hill, Pa.
“Other attorneys should look to Mr. Berg’s actions as a blueprint for what not to do when
attempting to effectively and honorably perform the duties of the legal profession,” Joyner wrote.
“This court has grown weary of Mr. Berg’s continuous and brazen disrespect toward this court
and his own clients. Mr. Berg’s actions … are an enormous waste of judicial time and resources
that this court cannot, in good conscience, allow to go unpunished,” Joyner wrote.
In the suit, Berg is accused of legal malpractice by former clients who claim his failure to
respond to an ERISA claim against them led to a default judgment.
But the sanctions against Berg stem from his decision to file a third-party counterclaim of fraud
against a pension fund that had sued his former clients, according to court papers.
Joyner blasted Berg for filing the fraud claim, calling it an “irresponsible decision” because the
claim was “utterly barren of any scintilla of legal principles.”
In the ERISA suit, Berg’s former clients — Richard Holsworth and his company, Richard’s
General Contracting — were sued by a group of pension funds led by the Carpenters Health and
Welfare Fund of Philadelphia and Vicinity.
Carpenters Health claimed that Holsworth and his company had failed to make required payment
of fringe benefit contributions.
According to court papers, Joyner found that Berg “neglected to file a response to [Carpenter
Health's] claim or provide any legal defense whatsoever for his client.”
Even after a default judgment was entered against Holsworth, Joyner found that Berg “remained
silent.”In April 2002 — two months after the default judgment was granted and 11 months after
the suit was first filed — Joyner found that Berg “broke his silence” by filing a petition to strike
the judgment or to open the default judgment.
Berg’s motion was rejected and a default judgment of more than $5,300 was entered against his
clients.The judgment swelled to more than $10,000 when Carpenters Health later successfully
moved for a supplemental judgment to recover more than $4,700 in attorney fees for its efforts in
responding to Berg’s untimely motions.
Holsworth and his wife later filed a legal malpractice suit against Berg in the Philadelphia
County Court of Common Pleas, alleging that Berg negligently failed to represent them in the
Carpenters Health case.
A year later, in February 2005, Berg moved to join Carpenters Health as a third-party defendant
in the malpractice suit, demanding more than $20,000 in damages.
In his counterclaim, Berg alleged that the ERISA suit filed by Carpenters Health in 2001, which
led to the malpractice claim against him, was “a fraud upon the court and a fraudulent taking
from the Holsworths.”
Carpenter Health’s lawyers removed the case to federal court and filed a motion to dismiss the
claim.Joyner agreed, finding that Berg’s fraud claim was “frivolous” and was motivated by an
intent “to harass Carpenters Health and the Holsworths, as well as to delay and disrupt the
administration of justice.”
The claim was fatally flawed, Joyner found, because Berg had no standing to bring suit against
Carpenters Health and had “failed to conduct even a minimally reasonable inquiry before filing
his complaint.”
Granting summary judgment in favor of Carpenters Health, Joyner said he found it “wholly
unnecessary” even to consider the facts of the ERISA case because it was “abundantly clear” that
Carpenters Health was entitled to a judgment as a matter of law.
Joyner invited Carpenters Health to file a motion for Rule 11 sanctions. When it did, Joyner
found that Berg “continued his trend of unprofessional conduct by, once again, failing to file a
timely response.”
In a footnote, Joyner said Berg’s response to the sanctions motion was due on May 26. In a
phone call to chambers on May 31, Joyner said, Berg’s assistant requested permission to move
for an extension of time, saying Berg had been out of town for two or three weeks and would not
be returning until June 9.
Joyner said he agreed to accept such a request if it were filed the next day, but none was.
Instead, Joyner said, a letter signed by Berg’s assistant was faxed to chambers on June 2,
requesting that the deadline be extended until June 27.
Joyner said he refused because “in light of Mr. Berg’s persistent and repeated neglect of his
professional obligations, this court was not inclined to permit Mr. Berg to further delay the
review of Carpenters Health’s ripe motion.”
In a June 2 opinion, Joyner found that Berg had violated Rule 11 by “filing a complaint
completely devoid of any basis in fact or law, as would be apparent to any reasonable attorney
after the slightest inquiry.”
Berg’s fraud claim, Joyner said, was “inadequately pled, not grounded in fact, time-barred, and
utterly irrelevant to the pending malpractice action against him.”
In his sanctions order, Joyner ordered Berg to reimburse Carpenters Health the $10,668 in
attorney fees and costs it incurred in defending the claim. He also ordered Berg to complete six
credits of ethics courses certified by the Pennsylvania Board of Continuing Legal Education, and
recommended that Berg be investigated by the Pennsylvania Bar Association’s Committee on
Legal Ethics and Professional Responsibility.
On June 16, Berg filed a motion for reconsideration urging that the sanctions imposed on him
should be forgiven due to “extenuating circumstances,” including health problems, a three-week
European business trip and financial difficulties.
Berg conceded in his brief that “there were numerous procedural errors, untimely responses and
omissions,” but said he “did not do so with intention or defiance.”
Joyner flatly rejected the motion, saying “in no way, shape or form do the ‘extenuating
circumstances’ proffered by Mr. Berg even begin to justify, excuse, or explain his unprofessional
and unethical course of conduct throughout this matter. These transparent excuses are not only
patently insufficient to meet the legal standard for a motion for reconsideration, they are
insulting to this court and demeaning to the legal profession.”
Berg, reached in his office, declined to comment on Joyner’s decision except to say that he is
considering whether to file an appeal.
Carpenters Health was represented by attorneys Sanford G. Rosenthal and Eric B. Meyer of
Jennings Sigmond.
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Dr. Orly Taitz, pro se
Orly Taitz Law Offices
26302 La Paz, Suite 211
Mission Viejo, California 92691
(949) 683-5411
dr_taitz@yahoo.com
UNITED STATES DISTRCT COURT

Lisa Liberi, et al., §

Plaintiffs, §
§
v. § Civil Action No. 2:09-cv-01898-ER
§
Orly Taitz, et al. §
Defendants §
SECOND AMENDED MOTION TO DISMISS COUNTS ONE-SIX FOR 12(b)(1)
LACK OF SUBJECT MATTER JURISDICTION &
JUDGMENT ON THE PLEADINGS
It has long been the case that the jurisdiction of the Court depends upon the state
of things at the time of the action brought.” Mollan v. Torrance, 22 U.S. 537, 9
Wheat. 537, 539, 6 L. Ed. 154 (1824). This time-of-filing rule is hornbook law
(quite literally) [*571] taught to first-year law students in any basic course on
federal civil procedure. It measures all challenges to subject-matter jurisdiction
premised upon diversity of citizenship against the state of facts that existed at the
time of filing–whether the challenge be brought shortly after filing, after the trial,
or even for the first time on appeal. (Challenges to subject-matter jurisdiction can
of course be raised at any time prior to final judgment. See Capron v. Van
Noorden, 6 U.S. 126, 2 Cranch 126, 2 L. Ed. 229 (1804).
Grupo Dataflux v. Atlas Global Group, L.P., 541 U.S. 567 at 570-71; 124 S.Ct. 1920 at 1924;
158 L.Ed.2d 866 at 872 (2004).
Without wishing to minimize the appearance created by the volume of paperwork filed to
date in this above-entitled-and-numbered civil action, the case ends here or it ought to. Count
One is labeled as and would apparently pretend to be a federal cause of action, in its title only,
but it is at best a California statutory suit for violation of privacy, and must accordingly be
evaluated, for subject matter jurisdiction, under the same diversity of citizenship analysis applied
to the state-labeled Counts Two through Six.
The only colorable basis for Federal Court subject matter jurisdiction over the state-law
“substance” (without conceding, in fact, that there is any substance) of Counts Two (Complaint
p. 66 ¶¶158-166: “Defemation[sic], per se, Slander and Libel”), Three (Complaint p. 69, ¶¶167-
173: False-Light Invasion of Privacy), Four (Complaint p. 72, §§174-181: “Harassment”), Five
(Complaint p. 75, ¶¶182-189: “False Designations and Descriptions of Facts”), and Six
(Complaint p. 78, ¶¶190-196: “Injunctive Relief” as to “defamation,” “false allegations,”
“misrepresentations of their character” and “false light”) would be diversity of citizenship, as is
alleged in paragraph 1 on page 4 of the original (and only) Complaint, filed in this case on May
4, 2009.
All of these “Counts” are woefully insufficient as a matter of competent federal practice
and pleading, but none of these counts contain even the suggestion of a conceivable much less
plausible cause of action arising under Federal Law, so diversity is the only imaginable basis for
jurisdiction and the federal standards for diversity are neither novel nor difficult to apply: the
Complaint reveals on its face that “complete diversity of citizenship” between Plaintiffs and
Defendants simply does not exist, and cannot be cured by amendment because jurisdiction is
established by the case initial “snapshot” of the parties, not later changes.
Dr. Orly Taitz admits that she is a dentist, by primary profession, and although admitted
to practice in the State of California and several federal courts, she is not primarily a litigator.
Defendant also admits that “ignorance of the law is no excuse,” but would nevertheless submit
that “A party cannot inadvertently or intentionally (e.g. by agreement) waive its right to object to
the Court’s lack of subject matter-jurisdiction.” Insurance Company of Ireland, Ltd., v.
Compagnie des Bauxites de Guinee, 456 U.S. 694 at 702, 102 S.Ct. 2099 at 2104 (1982). And
since Strawbridge v. Curtiss, 7 U.S. 267, 3 Cranch 267, 2 L.Ed. 435 (decided February 13,
1806), the United States Supreme Court has read the statutory formulation “between . . . citizens
of different States,” 28 U.S.C. § 1332(a)(1), to require complete diversity between all plaintiffs
and all defendants. So, every other objection and contention the parties have made up to this
point set aside, the case ends here, for the following reasons which Defendant Dr. Orly Taitz
inadvertently failed to raise in her previous motions and answer:
On the first (title) page of Philip J. Berg’s Complaint for Damages, with Jury Trial
Demanded, filed on May 4, 2009, and never amended or otherwise superceded, Lisa M. Ostella
and Go Excel Global are identified as Plaintiffs while James Sundquist and Rock Salt Publishing
are identified as Defendants. In paragraphs 8 and 9 on page 5 of the May 4, 2009, complaint,
Lisa M. Ostella is identified as residing at 2227 US Highway 1, #245, North Brunswick, New
Jersey 08902-4402 with her principal place of business at the offices of Plaintiff Go Excel
Global, also in North Brunswick, New Jersey 08902-4402.
On page 6 of the May 4, 2009, complaint, in paragraphs 16-17, a Defendant James
Sundquist and his principal place of business Rock Salt Publishing are identified as having a
business address of 551 Valley Road, Suite 123, Upper Montclair, New Jersey 07043.
The undersigned Defendant has previously argued and submitted evidence that Plaintiff
Lisa Liberi should be deemed a citizen of California for purposes of diversity, on account of her
long-time residence and criminal history and multiple convictions and status as a probationer in
Defendant Orly Taitz’ home state[1]. While Defendant still contends that her analysis of Lisa
Liberi’s citizenship for purposes of Strawbridge v. Curtiss “complete diversity” analysis is
correct, it is upon reflection mere surplusage, at this point, because the paired Plaintiffs Lisa
Ostella and her Go Excel Global, when paired against the paired Defendants James Sundquist
and his Rock Salt Publishing, as identified and described expressly and explicitly ON THE
FACE OF PLAINTIFFS’ OWN COMPLAINT, completely and effectively destroy any
contention of “complete diversity.” Even if Defendants Dr. Orly Taitz and her “Defend Our
Freedoms Foundations, Inc.” should be deemed to have defaulted so egregiously as to have
confessed the well-pled allegations (if any) of the Plaintiffs’ Complaint, such a default is not and
cannot be taken as a waiver of objections to subject matter jurisdiction. Without subject matter
jurisdiction, which can only be established by the well-pled allegations of Plaintiffs’ Complaint,
this United States District Court is entirely without power to proceed, to entertain any part of
Plaintiffs’ Complaint, or to afford to Plaintiffs’ any relief whatsoever.
FAILURE TO IDENTIFY FEDERAL QUESTION CAUSES OF ACTION
(FRCP RULES 12(b)(6) & 12(c) JUDGMENT ON THE PLEADINGS)

For purposes of the present motion, Defendant Dr. Orly Taitz submits that the Plaintiffs
have failed even to identify any actual or conceivable Federal question Causes of Action in their
May 4, 2009, Complaint, and are thus subject to Judgment on the Pleadings pursuant to Rule
12(c). Much less have the Plaintiffs actually pled any plausible Federal Causes of Action with
anything approaching the specificity required by Rule 12(b)(6) as construed and applied under
the Supreme Court’s latest evaluation Bell Atlantic v. Twombly, 550 U.S. 544; 127 S. Ct. 1955 at
1964-65; 167 L.Ed.2d 929 (2007). In fact, it is fair to say, paraphrasing the language of
Twombly, that the Plaintiffs Liberi et al. have not even made the conclusory allegations, or
sufficient factual allegations to identify the “labels and conclusions” necessary to constitute a
“formulaic recitation of the elements of any causes of action” arising under Federal statutes or
jurisprudence, whatsoever. Count One, as noted above, is basically a “sham” based on a content-
free title including two Constitutional Amendments not mentioned again in any paragraph.
In relation to Counts Two through Six, which bear state court “labels” and little else
suggesting any theory of recovery at all, there are repeated but vague references to Defendants’
“posting and distributing Liberi’s social security number” and then, on page 73, ¶180, that
“Defendants have acted unlawfully and in violation of” several federal statutes without more in
the way of material factual allegations. Such sloppy “pleading” was not permitted in Federal
Court prior to Twombly, but it is clearly frivolous and sanctionable now after the Supreme
Court’s decision in that case.
This leaves COUNT ONE of Plaintiffs’ May 4, 2009, Complaint, at page 60, ¶¶ 144-157
for analysis. “COUNT ONE” is entitled “VIOLATION OF THE FIRST AND FOURTEENTH
AMENDMENT OF THE UNITED STATES CONSTITUION [sic] and ILLEGAL
DISCLOSURE OF AN INDIVIDUAL’S SOCIAL SECURITY NUMBER AND PERSONAL
IDENTIFYING INFORMATION”. While the First and Fourteenth Amendments of the United
States Constitution would appear to frame federal issues, no federal civil rights (nor any other)
statutes are cited until paragraph 157. In fact, no statutes or case law authorities are cited until
paragraph 151, and the subsequent paragraphs focus exclusively on California Civil Code
§§1798.81-1798.85” along with vague reference to (other?) “California privacy laws” as
providing possible grounds or factual frameworks for liability or recovery. Accordingly the
mere recitation of two constitutional amendments in the FEDERAL CONSTITUTIONAL
TITLE of Count One should be disregarded, and judgment entered on the pleadings in this case
pursuant to Rule 12(c) of the Federal Rules of Civil Procedure, or in the alternative under
12(b)(6) because no conceivable Federal law theories of recovery are stated or even identified in
Count One.
As in paragraph 180 on page 73, discussed above, paragraph 157 on pages 63-64 contains
random citations to several federal laws, but the factual allegations of this paragraph are so
vague, conclusory, and general, without reference to any specific outline of any causes of action
recognized or established by federal law, that there is no substantial basis for the exercise of
federal question jurisdiction. Count One may contain more “Federal Words” in its title than the
other counts of Plaintiffs’ May 4, 2009 complaint, but it does not contain more “Federal
Substance” and should be dismissed along with Counts Two through Six as an attempt to utilize
federal diversity jurisdiction to sue and impose liability under what is, at the absolute most,
examining the Complaint in the light most favorable to the Plaintiffs, as nothing more nor less
than an extremely poorly pled California state cause of action.
PRAYER FOR RELIEF

Judgment should accordingly be entered in favor of all the Defendants dismissing the May 4,
2009, Complaint for Want of Subject Matter Jurisdiction pursuant to Rule 12(b)(1), Failure
to State a Claim upon which Relief can be Granted pursuant to Rule 12(b)(6), or in the
alternative for Judgment on the Pleadings pursuant to Rule 12(c). The scattered references to
federal statutes or constitutional amendments do not add up to any cognizable theory of
recovery under federal law, and since complete diversity of citizenship between the Plaintiffs
and Defendants is lacking, the May 4, 2009, Complaint in this case should be dismissed with
prejudice to the refiling of the same in any federal court anywhere, for any purposes.
Defendants Dr. Orly Taitz and Defendant our Freedoms Foundations, Inc., accordingly move
and pray for complete dismissal of the Complaint filed by Lisa Liberi, Philip J. Berg, the
Law Offices of Philip J. Berg, Evelyn Adams a/k/a Momma E, Lisa M. Ostella, and Go
Excel Global, and ask that all Defendants be released from further liability to appear or
answer in this case, and that all proceedings in this case be adjourned sine die.
Respectfully submitted,
Wednesday, June 10, 2009
By:________________________________
Defendant, in propia persona and on behalf
of Defend Our Freedoms Foundations, Inc..
Dr. Orly Taitz, President,
Telephone (949) 683-5411

E-Mail: dr_taitz@yahoo.com
This report came from volunteer Sarah redacted

Case FWV028000 - Defendants
Seq Defendant Next Court Status Agency / Arrest Date Count 1 Violation Date
Date DR Number Charge
1 LIBERI , LISA RA 05/18/2001 PC 115(A) 05/18/2001
R 110013759
ALIAS: LIBERI, LISA
Custody N/A

NONE N/A N/A
Formal 03/21/2008 03/21/2011
01/25/2008 26 Days 26 Days
N/A N/A
0 N/A
Arrest Charges
Date
1 PC 459 F BURGLARY 05/18/2001

Filed Charges
Date

487(A) PROPERTY/ETC OVER $400
2 PC F FORGERY 05/18/2001 HTA
470(D)
4 PC F OFFER/ETC FALSE/FORGED 05/18/2001 HTA
115(A) INSTRUMENT TO FILE
6 PC F FORGERY 05/18/2001 HTA
470(D)
8 PC F OFFER/ETC FALSE/FORGED 05/18/2001 HTA
Infor Charges
Date
1 PC F GRAND THEFT: 05/18/2001 GUILTY CONVICTED

2 PC F NONSUFFICIENT FUNDS: 05/18/2001 GUILTY CONVICTED
476A(A) CHECKS
3 PC F FORGERY 05/18/2001 DISMISSED
470(D)
5 PC F OFFER/ETC FALSE/FORGED 05/18/2001 GUILTY CONVICTED
7 PC 476 F MAKING, POSSESSING, 05/18/2001 DISMISSED
UTTERING FICTIOUS INSTRS
470(D)
9 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 GUILTY CONVICTED
10 PC F OFFER/ETC FALSE/FORGED 05/18/2001 DISMISSED
20 PC F OFFER/ETC FALSE/FORGED 05/18/2001 GUILTY CONVICTED
470(D)
470(D)
List of initiatives and legal actions spearheaded by Orly Taitz
1. Keyes et al v Obama et al filed in Central District of CA.

2. Easerling et al v Obama et al submitted to SCOTUS
3. Lightfoot et al v Bowen was filed in the Supreme Court of CA and later in SCOTUS. It
was referred by Chief Justice Roberts for conference on January 23, however it did not go
to oral argument.
4. Co-authored Keyes et al v Bowen.
5. James et al v Obama demand for Quo Warranto submitted to the US attorney for the DC
Jeffrey a Taylor, who has resigned. Demand for the new acting US attorney for the DC to
file Quo Warranto against Obama
6. Quo Warranto demand was submitted to Atty gen. Eric Holder. A phone call was
received stating that the Dossiers were forwarded to the Criminal division of the DOJ.
7. Pro Hac Vice appearance was made on behalf of Jody Brockhausen and a complaint was
filed with the US attorney for the western District of TX for criminal Matters Richard
Durbin and assistant US atty Chris Peel.
8. 8 dossiers describing suspected illegal activity perpetrated by Obama and his supporters
was submitted to Holder
9. Request for criminal investigation of Obama’s Selective Service Certificate and
Certification of Live Birth with numerous signs of perjury was forwarded to the
Beaumont police (Obama campaigned in Beaumont) on behalf of a number of clients.
10. After the chief of Beaumont police told officer Dischler not to investigate, due to the fact
that it is a political issue and after the officer was threatened that the Chief of Police will
investigate him, a criminal complaint was forwarded to the US attorney for the Eastern
District of TX Rebeccah Gregory. Ms. Gregory resigned, the complained will be handled
by the successor.
11. Copy of the complaint was forwarded to Governor Perry on May 5th. On May 6th the
legal counselor for the governor referred us to the DA of Jefferson County Tom Manness.
12. All of the dossiers and the complaint were forwarded to DA Manness and Chief
investigator Rose as well as the San Antonio DA Susan Reed.
13. Dossiers were either hand delivered by me or sent by certified mail to each and every
member of the Senate Judicial committee, as well as Senator Thune of Armed Services
Committee and Senator Grassley of Finance Committee and Senator Feinstein, who was
the chair of Intelligence committee.
14. Dossiers were forwarded to Robert Mueller –director of FBI
15. Dossiers were forwarded to Mark Sullivan, Director of Secret service
16. Dossiers were forwarded to Captain James Crawford, legal counselor for Admiral Mike
Mallin, chairman of the Joint Chiefs of staff (response is expected shortly)
17. Dossiers were forwarded to Steven Whitlock, director of the whistle blower office of the
IRS
18. Dossiers were forwarded to the SSA, a phone call was received in April, advising that
the analyst is working on the matter and a response will be arriving in 2 weeks. It was not
received yet.
19. Addressed the issue with Justice Scalia on March 9th.
20. Addressed the issue with Chief Justice Roberts on March 13th.
21. 15 trips were made to lobby elected and appointed officials in different states to review
the issue of Obama’s eligibility for presidency
22. Over a 100 radio shows and numerous TV shows, documentaries and newspaper and
magazine articles were done to bring awareness to the issue of lack of eligibility of
Obama for the presidency of the US.
23. During the meeting with the KY assistant secretary of state a letter was written by the
assistant secretary of state to the Attorney General of the state, requesting to verify
Obama’s eligibility
24. 4 TN state representatives joined the legal action to unseal Obama’s eligibility
25. 3 MO state representatives joined the legal action
26. 2 NH state representatives joined the legal action
27. Over a 100 members of the US military including high ranked officials such as major
General joined the action
28. A request for Quo warranto investigation was made, on behalf of the WY Guardsman
Matthew Michael Edwards upon the Governor and attorney general of WY.
29. Meetings were conducted with 9 state representatives and state senators in the State of
WA, as well as WA assistant Atty Gen. and WA FBI
30. FBI field offices were visited in a number of states.
31. A meeting was conducted with the National director of the selective service William
Chatfield.
32. Case presentation was done to a number of citizen’s common law grand juries, which
indicted Barack Hussein Obama with fraud and in some states treason.
33. Meetings with volunteers were conducted in San Antonio, TX during April 15 tea party.
34. Pleadings and dossiers were hand delivered to the office of the Governor of GA Sonny
Purdue, Atty Gen of GA, elections committee and US Atty Nahmias. First citizen’s grand
jury was organized by the foreman Mr. Carl Swenssen.
35. Meetings were conducted with the speaker of the House of OK Chric Benge, state
senator and current candidate for Gov of OK Randy Brangdon, st. rep Dr. Mike Ritz.
36. Met with current leading candidate for governor of Al Judge Moore and one of Al
electors Robert Cusanelli became one of the plaintiffs.
[1] Lisa Liberi remains under the continuing jurisdiction of the Superior Court of the State of California for the
County of San Bernardino in connection with her probation or parole status in Case No: FSB-044914 (Judge John
M. Pachecho), and whether this is determinative of her citizenship for diversity purposes or not, it seems more than
casually significant that Judge John M. Pacheco, in allowing Lisa Liberi to post bail bonds and be released from
custody stated on the record, in open court on August 4, 2004:
“Having said all that, Ms. Liberi, if you don’t come back here [“here” meaning to California Superior Court
whenever required by the terms of her probation] the mud is going to be on my face that I allowed all this to
happen.” Defendant Lisa Liberi responded “I will be here, your Honor. I have made every court appearance.” The
issue concerning the citizenship of parolees and probationers is not well-settled, but would seem to favor “last
residence prior to sentencing” as the residence of the probationer/parolee, which in this case would definitely be
California.
Under the diversity jurisdiction statute, the federal courts have original jurisdiction to decide a plaintiff’s state-
law lawsuit if the dispute “is between . . . citizens of different States.” See 28 U.S.C. § 1332(a)(1). A party’s
“citizenship” for purposes of federal jurisdiction is determined by looking to the person’s domicile. See Crowley v.
Glaze, 710 F.2d 676, 678 (10th Cir. 1983). Domicile, in turn, is determined by finding the last place where a person
resided with an intention of remaining there indefinitely. See Mississippi Band of Choctaw Indians v. Holyfield, 490
U.S. 30, 48, 104 L. Ed. 2d 29, 109 S. Ct. 1597 (1989) (”For adults, domicile is established by physical presence in a
place in connection with a certain state of mind concerning one’s intent to remain there.”); Crowley, 710 F.2d at 678
(”To effect a change in domicile, two things are indispensable: First residence in a new domicile, and second, the
intention to remain there indefinitely.”).
It is obviously true that an adult can freely and intentionally change her residence for purposes of diversity
jurisdiction as a matter of fundamental right, but prisoners, probationers, and parolees ordinarily lose the right to
determine their own citizenship. Lisa Liberi does not have complete freedom to sever her ties to California, and in
fact she has promised NOT to do so, as shown in the above quoted lines from the Reporter’s Transcript of the
August 4, 2004, hearing in San Bernardino Superior Court Case No.: FSB-44914. page 122, to which this Defendant
Some courts have recognized that the restrictions on the liberty of a prisoner affect the determination of the
prisoner’s domicile because domicile is a voluntary status. See Sullivan v. Freeman, 944 F.2d 334, 337 (7th Cir.
1991). As a result, courts have applied a presumption that when a prisoner has been moved out-of-state by prison
officers, the prisoner’s citizenship for diversity purposes is the state where he was domiciled before he was
imprisoned. See id.; see also Ferrer v. Dailey, 1996 U.S. App. LEXIS 33322, No. 96-3155, 1996 WL 731618, at *1
(10th Cir. Dec. 20, 1996) (unpublished Order & Judgment) (”For purposes of diversity jurisdiction, when an
inmate has been forcibly incarcerated in another state, the state of citizenship ’should be the state of which he was
a citizen before he was sent to prison unless he plans to live elsewhere when he gets out, in which event it should be
that state.‘”) (quoting Singletary v. Continental Ill. Nat’l Bank & Trust Co., 9 F.3d 1236, 1238 (7th Cir. 1993)). This
presumption, however, is rebuttable upon a showing of sufficient facts to indicate that a prisoner has both residence
and present intent to remain indefinitely in a new state. See Sullivan, 944 F.2d at 337.
Posted in Uncategorized | 12 Comments »

EXHIBIT “T”

2009
« Previous Post
Ties to Everett, need help with research

,
You mentioned Everett, Wash. connection with Barack Obama’s mother’s family. Just
wondering if you knew that connection went back for over a century…
http://www.heraldnet.com/apps/pbcs.dll/article?AID=/20081026/NEWS01/710269867
Plus a bit more about the Wolfleys: http://www.santacruzsentinel.com/world/ci_12517525
So with a POTUS with a Muslim father and German roots mother, why shouldn’t Israelis be
worried?
If you do post this info, please don’t mention my name or email.
Cheers
Response
I am really concerned about several coincidences
1. a man who threatened to shoot me and burn my body for the world to see was tracked to a
computer server in Everett WA. Another person that threatened me was traced to Chauhelis WA
and yet another one to Canada (from what I understand not far from the border with WA state).
A few days after the threat there was a clamp missing and a disconnected fumes emissions hose
in my car and my husbands car died, suddenly a fuse was missing.
2. Obama does not talk about it, but his mother wasn’t in HI when he was a baby, she was
enrolled in the U of Seattle WA from August 1961-till June 1962, which means that as a baby he
lived in WA.
3. Lisa Liberi, assistant for Berg, who has a lengthy criminal record of grand theft, forgery
of documents and forgery of official seal doesn’t talk about it, but according to records she
was born in WA state. From what I recall Bellview WA. (her name at birth was Lisa
Richardson. From what I recall father -Jack Richardson, mother Shirley Wadell)
4. Obama, Liberi and Obama’s mother Stanley Ann Dunham- all have multiple social
security numbers according to databases.
5. Liberi was convicted of forgery of documents and according to experts, there are
multiple signs of forgery in Obama’s documents.
6. Stanley Ann Dunham also went by the name Shirley Ann Dunham.
We found a Dunham organization, owned by Shirley Ann Dunham; one location was in
Seattle another in Bellview WA. They dealt with insurances, lawyers, mortgages- you can
get ss numbers from all of these records.
7. From what I recall, there was a discrepancy between Intellius records and Secretary of state
records. According to the sec. of state a man owned that co. One of our volunteers pulled court
records in Bellview for the Dunham organization. This man, Mr. Dunham (don’t remember first
name) kept changing his middle initial in several court cases, which was suspicious by itself.
8. There was a very strange newspaper article in WA (I believe Seattle), from what I recall, when
Obama supposedly was in Columbia. It stated that one, Roman Obama studied at the university
of Patrice Lumumba in Moscow, Russia, and had some financial difficulties.
9. When grandma Dunham got sick, a reporter from WA (I believe Seattle) has writen an
interview with Charles Payne, saying the grandma got a broken hip. She was dead of cancer a
few days later. I was wondering, why did it come out in WA, and not HI or IL?
10. Based on all of the above, I have a nagging feeling, that there is somebody there in WA,
some relative of Obama, somebody who we might think is no longer with us.
This entry was posted on Monday, June 22nd, 2009 at 3:35 pm and is filed under Uncategorized. You can follow
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[emphasis added]
EXHIBIT “U”

2009
« Update MI
I am back from PA. Very Important. »
Unfortunately I have to spend more time on Berg’s latest motion, I

have to provide a response

Orly Taitz Law Offices
(949) 683-5411
dr_taitz@yahoo.com
UNITED STATES DISTRCT COURT

Lisa Liberi, et al., §

Plaintiffs, §
§
v. § Civil Action No. 2:09-cv-01898-ER
§
Orly Taitz, et al. §
Defendants §
DEFENDANT’S OPPOSITION TO EMERGENCY MOTION FOR THE ISSUANCE OF

PLAINTIFFS’ INJUNCTION OR RESTRAINING ORDER
.
Defendants Orly Taitz and Defend Our Freedoms Foundation hereby file their opposition
and objections to Plaintiffs’ motion for injunctions for following reasons:
1. The First Amendment provides that “Congress shall make no law… abridging the
freedom… of the press,” and it is “no longer open to doubt that the liberty of the press, and of
speech, is within the liberty safeguarded by the due process clause of the Fourteenth Amendment
from invasion by state action.” Near v. Minnesota ex rel. Olson, 283 U.S. 697, 707 (1931). See
also Grosjean v. American Press Co., 297 U.S. 233, 244 (1936). The United States Supreme
Court has interpreted these guarantees to afford special protection against orders that prohibit the
publication or broadcast of particular information or commentary - orders that impose a
“previous” or “prior” restraint on speech. None of the Supreme Court’s decided cases on prior
restraint involved restrictive orders entered to protect a convicted forger’s history of convictions
for forgery, but the opinions on prior restraint have a common thread relevant to this case.
2. “Prior restraints on speech and publication are the most serious and the least tolerable
infringement on First Amendment rights.” Pittsburgh Press Co. v. Pittsburgh Comm’n on
Human Relations, 413 U.S. 376, 390, 37 L.Ed. 2d 669, 93 S.Ct. 2553 (1973): a prior restraint
should not “sweep” any “more broadly than necessary”. As such, the Constitution forbids prior
restraint on freedom of publication in the press, media, all together. See Carroll v. President and
Comm’rs of Princess Anne, 393 U.S. 175, 183-184, 21 L.Ed.2d 325, 89 S.Ct. 347 (1968).
3. Any “order” issued in “the area of First Amendment rights” must be “precise” and
narrowly “tailored” to achieve the “pin-pointed objective” of the “needs of the case”. Tory v.
Cochran, 544 U.S. 734, 738 125 S. Ct. 2108, 2111; 161 L.Ed.2d 1042, 1048 (2005); see
also Board of Airport Comm’rs of Los Angeles v. Jews for Jesus, Inc., 482 U.S. 569, 575, 577,
96 L.Ed.2d 500, 107 S.Ct. 2568 (1987) (regulation prohibiting “all ‘First Amendment activities’”
substantially overbroad).
4. The Plaintiffs’ June 23, 2009, proposed order in this case is laughably unspecific and
substantially overbroad, and would basically impose a “Plaintiffs’ standard” censorship on
Defendants’ commentary on the world-wide web, with the Court enrolled as enforcing referee.
5. Nearly two months have passed since the filing of Plaintiffs’ complaint, and both the title
and substance of Philip J. Berg’s latest “ex-parte” motion confirm, demonstrate, and reaffirm that
there are no recently developing emergencies or exigent circumstances which compel action at
the present time, if any action were ever warranted at all (cf., e.g., Tory v. Cochran, 544 U.S.
734 (supra).
6. Plaintiffs’ requests for injunctions when aligned and evaluated against their somewhat
lame and insubstantial recitations of alleged past misconduct are non-sensical, because Plaintiffs
Liberi, Berg, et al. make no allegations and offer no evidence of any ongoing defamation or
publication of private facts, and in particular, none that have arisen since the initiation of their
present Suit to Limit Access to Public Proceedings (e.g. “SLAPP”) filed May 4, 2009.
7. Historically, defamatory speech and disclosure of private facts of adults are immunized
from legislative or executive censorship, as well as judicial injunctive relief (known as “prior
restraint”) in the United States. If false statements are made, which result in injury, damages are
the sole and exclusive remedy.
8. All of the substantive requests, including but not limited to the key phrase in the proposed
order submitted to this Court on June 23, 2009, “Defendants’ Orly Taitz … Defend our
Freedoms Foundation… [….and] …all parties acting on their behalf are enjoined from
airing and/or publishing any defamatory or false statements”, and 100% of Defendants’
request for injunctive relief concerns expressive activity, specifically Defendants’ activities as
purveyors of truthful information through the electronic media communications over the “world-
wide web” or “internet.”

9. As the United States Supreme Court articulated 33 years ago this month (June 30, 1976)
in Nebraska Press Association v. Stuart, 427 U.S. 539; 96 S.Ct. 2791; 49 L.Ed.2d 683, 697-98
(1976):
A prior restraint, by contrast and by definition, has an immediate and irreversible

sanction. If it can be said that a threat of criminal or civil sanctions after
publication “chills” speech, prior restraint “freezes” it at least for the time. … The
damage can be particularly great when the prior restraint falls upon the
communication of news and commentary on current events. Truthful reports of
public judicial proceedings[1] have been afforded special protection against
subsequent punishment. See Cox Broadcasting Corp v. Cohn, 420 U.S. 469, 492-
493 (1975); see also, Craig v. Harney, 331 U.S. 367, 374 (1947). For the same
reasons the protection against prior restraint should have particular force as
applied to reporting of criminal proceedings, whether the crime in question is a
single isolated act or a pattern of criminal conduct.
10. In that same case (Nebraska v. Stuart) the Supreme Court set out an analytical and
procedural test for prior restraint on expressive activities which has been widely followed
throughout the United States. Under this test, a prior restraint on expression is presumptively
unconstitutional. With this concept in mind, the court adopts the following test: a [injunctive]
order in civil judicial proceedings will withstand constitutional scrutiny only where there are
specific findings supported by evidence that (1) an imminent and irreparable harm to the judicial
process will deprive litigants of a just resolution of their dispute, and (2) the judicial action
represents the least restrictive means to prevent that harm. See, for example, the Texas Supreme
Court’s Analysis in Davenport v. Garcia, 834 S.W.2d 4, 10 (1992).
11. Defendants suggest that this Court specifically adopt the Texas four part rendition of the
Nebraska v. Stuart test, in that several of the Defendants in this case are in fact from Texas and
would be entitled to such protection if they had been sued “at home”:
Concerned that public prejudice could prevent impanelling of a jury, a trial judge
issued an order restraining the news media from publishing any information about
a murder suspect in Nebraska Press Ass’n v. Stuart, 427 U.S. at 542-43. The
United States Supreme Court invalidated the order as an unconstitutional prior
restraint, noting that: (1) the underlying basis was too speculative; (2) less
restrictive alternatives were not investigated; (3) no evidence was presented that
the prior restraint would have in fact achieved its purpose; and (4) the order was
overbroad. Id. at 562-69. These conclusions are quite fact specific, id. at 569, and
thus only serve to reinforce a presumption that prior restraints, including those
directed at media publication, are unconstitutional.
Davenport v. Garcia, supra, at 10.
12. “A responsible press has always been regarded as the handmaiden of effective judicial
administration, especially in the criminal field. Its function in this regard is documented by an
impressive record of service over several centuries. The press does not simply publish
information about trials but guards against the miscarriage of justice by subjecting the police,
prosecutors, and judicial processes to extensive public scrutiny and criticism.” Sheppard v.
Maxwell, 384 U.S. 333 at 350 (1966).
13. Censorship of the press was, quite simply, one of the primary and central evils brought
over the water from monarchical and ecclesiastical domination in Europe against which the First
Amendment was enacted and adopted by Congress and the original 13 states. As the Court
recited in its historical summary in Nebraska Press Ass’n v. Stuart, supra: in Patterson v.
Colorado ex rel. Attorney General, 205 U.S. 454, 462 (1907): “[T]he main purpose of [the First
Amendment] is ‘to prevent all such previous restraints upon publications as had been practiced
by other governments.’” Defendant Dr. Orly Taitz was born in a country, the Soviet Union, in
which restraints on freedom of expression were ubiquitous and constituted a constant feature of
everyday life.
14. All content-based prior restraints on the dissemination of information by and through the
free media or “press” by judicial injunction constitute a form of “censorship” of free expression
which are subject to strict scrutiny and a very important series of safeguards outlined by the
Supreme Court for this central, core of First Amendment Protections. Lisa Liberi and Philip
Berg completely and callously ignore, in their memorandum, the fact that the entire thrust of the
injunctive relief they seek is focused on the suppression of freedom of speech and
communication about a topic of general public interest in the free press and open media. They
do not cite in their memorandum of law a single First Amendment case nor any other authority
which would show them entitled to any relief of any kind whatsoever.
15. All of the pleadings filed by the plaintiffs in this case were done with the sole reason to
harass Defendant Dr. Orly Taitz and other defendants and try to keep them silent about the fact
that Berg’s assistant Liberi has a criminal record, specifically criminal record of forgery of
documents, which casts doubt on documents Berg has submitted to this honorable court as well
the Supreme court, as the documents were prepared or at least handled by a convicted document
forger. This is a matter of public concern and public interest as well as a legitimate topic of press
reporting and is entitled to full First Amendment protection.
16. Lisa Liberi has (in California Courts) demonstrated a pattern of filing frivolous legal
actions and motions, having filed groundless actions against police officers, district attorney, the
judge and the county solely to obtain leverage in her own criminal actions, or for other improper
purposes.
17. Philip J. Berg has shown the same pattern of filing frivolous and fraudulent actions and
was fined by US District Judge J. Curtis Joyner more then $10,000 for bringing legal actions
“utterly barren of any scintilla of legal principles”. In his opinion Judge Joyner has stated “This
court has grown weary of Mr. Berg’s continuous disregard and brazen disrespect toward this
court and his own clients. Mr. Berg’s actions …are an enormous waste of judicial time and
resources that this court cannot, in good conscience, allow to go unpunished”. In this action Berg
has filed hundreds of pages of pleadings without a scintilla of proof or legal theory upon which
he can possibly proceed against the defendants.
18. This opposition to motion for emergency injunction and or restraining order is filed with
full reservation of rights, as the defendants are awaiting the ruling on their second amended
motion to dismiss due to lack of jurisdiction.
19. Due to the fact that not one but several serious questions concerning the existing either of
Federal Question or Diversity jurisdiction over this case, Defendants reserve their right to plead
further in opposition to Plaintiffs’ request for “emergency injunctive relief” if this Court should
decide it does indeed possess jurisdiction.
20. However, the question of the Court’s power to proceed does and should indeed precedes
any other issues of litigation and due to the fact that the defendants were harassed by hundreds
and hundreds of pages of pleadings and premature demands for discovery, even though the
defendants are waiting for the ruling on jurisdiction, the defendants respectfully request a stay on
all other proceedings and filing of subsequent motions and pleadings until there is a ruling on
jurisdiction.
Respectfully submited
Wednesday, June 24, 2009

By:________________________________
Defendant, in propia persona and on behalf
of Defend Our Freedoms Foundations, Inc..
Dr. Orly Taitz, President,
Telephone (949) 683-5411

E-Mail: dr_taitz@yahoo.com
[1] Such as Defendant Orly Taitz’ reports on the CLOSED (not ongoing) legal proceedings
involving Lisa Liberi.
This entry was posted on Wednesday, June 24th, 2009 at 12:19 am and is filed under Uncategorized. You can follow
EXHIBIT “V”

2009
« Unfortunately I have to spend more time on Berg’s latest motion, I have to provide a response
Next Post »
I am back from PA. Very Important.

I appreciate everybody calling and e-mailing and texting to make sure I am OK. I am OK….I
had to go to PA to appear at the hearing in the garbage law suit filed by Philip Berg. My wireless
connection didn’t work there, I couldn’t blog.
I returned yesterday at 12:30 and and was doing a radio show in VA with Chuck Chrismayer.
You can reach him at 800-754-1822 or 804-677-2783, he will have archives of the show.
I had to work from 1-5:30 and later wanted to have dinner and spend some time with my family.
In regards to Berg things are going well. Judge denied all of his motions for default judgment
against me and clerical default was lifted, he gave me a pro hac vice to represent my foundation,
denied all of Berg’s motions for injunction against me and, what is most important he ordered
Berg to show cause, why his case should not be dismissed due to lack of jurisdiction. For those
of you, who are not attorneys, it is a very good sign that the judge is very inclined to dismiss
Berg’s case due to lack of jurisdiction. I would like to explain that if the case is filed out of state,
the first thing that is being reviewed, is jurisdiction. It doesn’t mean that the case has any merit
aside from jurisdiction, it means that this court cannot hear it. I believe Berg filed it in PA to
simply cause me to waste time and money, going to Philly. At any rate, I am not concerned about
this frivolous law suit, I am though concerned about something else.
On the plane to Philly I read hundreds of pages of transcripts in criminal case hearings of Liberi.
Keep in mind that recently I had threats “to shoot me and burn my body for the world to see”.
Later a clamp was missing and fumes emissions hose was disconnected in my car, that lead to
the fumes accumulating around the engine, which is extremely dangerous.
As I read August 4, 2004 transcript, I found a testimony of detective Liebreich. He testified in

regards to recording of phone calls Lisa Liberi made from jail to her husband Brent Liberi. She
was telling him that she was upset with her sister Cheryl Richardson. Cheryl cooperated with the
police and told them about 19 prior criminal investigations of Liberi. Liberi told Brent (see
copies of the transcripts attached) that she will get her sister in jail and will spread the word that
she is a rat. She was telling Brent “do you know what they do in prison to rats?”
At that time DA James Secord asked the detective to explain. The detective stated that a contract
will be issued on such person, a green light and such person will be attacked and/ or killed. He
mentioned that 5 people were killed last year alone. I got concerned, if this woman could plan
a hit, a contract on her own sister, it would not be inconceivable that she would plan a hit on an
attorney and her family, if this attorney outed her. I kept reading and found out that indeed less
then a year later her sister was dead. Official cause of death, from what I understand, is drug
overdose. However, drug overdose can be self inflicted or inflicted by others.
At this time I would like to know if there are any pathologists among the readers of this blog?
Can someone go to the police department and probation department in Santa Fe NM and show
them all this info.
According to detective Teresa Standiford from Orange County economic crimes unit, my report
and the whole file was transferred to Santa Fe, as Lisa Liberi lives there. I tried to find out the
status, but it is very hard to reach anybody in the police department there. The phone number of
detective Teresa Standford in CA 714-647-7486, 714-647-7038. Case # 09-068339.
Liberi’s prosecuting DA in Ca is James Secord 909-387-8309
In Santa Fe I was given a number for detective Martin Lopez 505-955-5010, General number for
the Santa Fe police is 505-955-5038. Investigations unit- 505-955-5038
The supervisor of her probation department is Joan Martinez 505-476-2359 Regional probation
officer is Rose Bobchack 505-476-2363.
After the hearing on Thursday I talked to Phil Berg and I have shown him the transcripts of
Liberi’s prior hearings. I put him on notice in regards to her dangerous propensities and let him
know that if he continues with this law suits and continues denying, what is clearly a public
record, he endangers me and my whole family. If something happens and Liberi is involved, he
will be held accountable as an accomplice.
This entry was posted on Saturday, June 27th, 2009 at 3:52 pm and is filed under Events, Uncategorized. You
can follow any responses to this entry through the RSS 2.0 feed. Both comments and pings are currently closed.
EXHIBIT “W”
LAW OFFICES OF
PHILIP J. BERG
PHILIP J. BERG
CATHERINE R. BARONE
BARBARA MAY
(610) 825-3134
FAX (610) 834-7659
NORMAN B. BERG, Paralegal [Deceased] E-Mail: philjberg@gmail.com
July 30, 2009
Honorable Eduardo C. Robreno

United States District Court
for the Eastern District of Pennsylvania
11614 U.S. Courthouse
601 Market Street
Philadelphia, PA 19106-1797
Sent via Fax to (267) 299-7428...................................................................................................18 Pages
Re: Liberi, et al. v. Orly Taitz, et al, Case No. 09-cv-01898 ECR
Plaintiffs Opposition to Defendants’ Request for a Thirty [30] day Extension of Time
Dear Judge Robreno:
I am in receipt of Mr. Hoppe’s letter dated July 28, 2009. There are several problems with
Mr. Hoppe’s request for an Extension of Time as well as statements pertaining to Mr. Hale and Linda
Belcher. Unless this Court issues Plaintiffs’ request for an Emergency Injunction or Restraining Order
pending any Hearings, Plaintiffs are OPPOSED to any continuance of the Hearing pertaining to the
Plaintiffs’ Motion for an Emergency Injunction or Restraining Order as outlined herein.
Mr. Hoppe’s Continuance Request:
Mr. Hoppe was served with the letter that I sent on July 16, 2009 with Plaintiffs’ attached
motion and letters provided from two [2] witnesses who are not a party to this litigation. In my July
16, 2009 letter to Your Honor was also information regarding the actions of Defendant, Orly Taitz.
Mr. Hoppe was also served with my letter that I sent to Your Honor with further actions of Ms. Taitz
pertaining to Plaintiff Lisa Liberi’s Social Security number and other confidential information. Mr.
Hoppe was again served with my July 22, 2009 letter which was sent to Your Honor wherein I again
was requesting Leave to file the Plaintiffs’ Motion for an Emergency Injunction or Restraining Order;
and finally on July 24, 2009, a letter I sent to Your Honor with two [2] emails received from two [2]
additional witnesses who are not parties to this litigation, other than being witnesses for the Plaintiffs’.
Z:\Liberi Ltr to Judge Robreno July 30, 2009 1

Yesterday, July 29, 2009 is the first response we have received from Mr. Hoppe regarding
this matter. Furthermore, Plaintiffs’ request for the thirty [30] day extension of time was to allow this
Court to take appropriate action to protect the Plaintiffs’ and their witnesses so we could properly
respond to Your Honor’s Rules to Show Cause, wherein Your Honor specifically asked for Affidavits.
Plaintiffs’ Response and Affidavits in support thereto are now due on August 26, 2009.
If this Court allows this continuance, which Plaintiffs’ completely oppose, then Plaintiffs’ are
again placed at a disadvantage and deprived of their Constitutionally protected rights to “due process”;
“equal protection of the laws”; their right to “bear and present witnesses”; their rights “for redress”,
etc., as they will be in the same position as their witnesses are, that being afraid to furnish Affidavits,
until this Court takes appropriate action to protect the parties, as a result of Defendant’s Belcher and
Hale’s threats
Mr. Hoppe has been aware of Plaintiffs’ request since July 16, 2009 and failed to assert
anything until now. In fact, he sent Mr. Hale a copy of my letter dated July 16, 2009, which Mr. Hale
immediately posted parts of on his internet site. This is exactly what the Plaintiffs’ witnesses fear, that
Mr. Hale and Ms. Belcher will purposely put their confidential information out on the internet and
incite their people to go after the witnesses to follow through with their threats towards the Plaintiffs
witnesses. Again, Ms. Belcher and Mr. Hale made it known to all witnesses of the Plaintiffs that they
(Ms. Belcher and Mr. Hale) will know who they are; where they reside; where they are located and
stated, “and we will go after them with a vengeance”. If Mr. Hoppe’s request for an extension of time
is granted, Plaintiffs’ will be unable to meet this Court’s Orders to reply to this Honor’s Rules to Show
Cause and support their responses with Affidavits. Mr. Hoppe is well aware of this and this simply is a
tactic to further ensure Plaintiffs’ will be deprived of their right to properly respond.
If true what Mr. Hoppe states, that Defendants Belcher and Sankey (no mention of Sankey
Investigations, Inc. or The Sankey Firm, Inc. a/k/a the Sankey Firm) are hiring a Texas Attorney to
litigate in Pennsylvania, they could have waited to do this until after Friday, August 7, 2009.
Mr. Hale interrupted Ken Dunbar’s radio show on Plains Radio to make a quick
announcement. Mr. Hale stated that one of Mr. Berg’s big supporters paid David Carlton Hughes, the
attorney all the Defendants’ wanted, twenty-five [$25,000.00] dollars to represent the Defendants’. Mr.
Hale also stated Mr. Hoppe sent an attorney to see the Judge to ask for a continuance, if the Judge
denied the continuance then Caren, Linda and he would be at Court on Friday, August 7, 2009. Mr.
Hale also stated he was having ten [10] CD’s transcribed which will be sent out federal express on
Friday so his Honor will have them by the deadline on Monday. See EXHIBIT “1”. Based on Mr.
Hale’s statements, there is no need for the continuance.
Mr. Hoppe’s Statements Regarding Jurisdiction:
This Court has personal jurisdiction over the Defendants’ as will be addressed in more detail
in Plaintiffs’ Responses to this Court’s Rules to Show Cause. However, since this Court Ordered
Plaintiffs’ to respond to this Court’s Rules to Show Cause regarding the Jurisdictional issues and back
up their responses with Affidavits; and the fact Defendant’s Belcher and Hale have now threatened any
witness who provides an Affidavit for the Plaintiffs’, this Court clearly has jurisdiction as the
Defendants’ have targeted the Plaintiffs’ in Pennsylvania; any witnesses planning to supply an
Affidavit or testify on behalf of Plaintiffs’ in Pennsylvania; and this case is currently in Pennsylvania;

in attempts to ensure Plaintiffs’ are unable to comply with this Court’s Order that Plaintiffs’ are to
respond to this Court’s Rules to Show Cause due August 26, 2009.
Federal Courts may exercise personal jurisdiction over a non-resident of the forum "to the
extent permissible under the law of the state where the district court sits." Pennzoil Prods. Co. v.
Colelli & Assocs., 149 F.3d 197, 200 (3d Cir. 1998) (citation omitted.) In turn, Pennsylvania's long-
arm statute authorizes the exercise of jurisdiction over a non-resident "to the fullest extent allowed
under the Constitution of the United States." 42 Pa. Cons. Stat. Ann. § 5322 (b); see also O'Connor v.
Sandy Lane Hotel, 496 F.3d 312, 316 (3d Cir. 2007), noting that Pennsylvania's long-arm statute
"provides for jurisdiction based on the most minimum contact with the Commonwealth allowed under
the Constitution of the United States" (internal citations omitted.) That is, as long as the requirements
of the Due Process Clause of the Fourteenth Amendment to the United States Constitution have been
satisfied, jurisdiction will lie over non-resident Defendants in Pennsylvania. Pennzoil Prods., id.
All the Defendants’ meet the minimum contact standards, which gives this Court jurisdiction
and venue over them; their illegal, unethical and injurious behaviors and actions, which were activities
purposefully directed towards residents of this state. In so doing, Defendants’ were provided "fair
warning" that they may be subject to suit in this forum. Burger King Corp, v. Rudzewicz, 471 U.S. 462
at 472. Again, Taitz is a licensed Attorney and is aware of the laws of our land. Moreover, Taitz
through DOFF have several military clients; has formed a group of Pennsylvania residents to work
with her in having Arlen Spector, U.S. Senator Pennsylvania recalled.
It is more than obvious; Belcher and Hale directed their threats towards the Plaintiffs’ witnesses
who would be supplying Affidavits and appearing in this Court in Pennsylvania. Ms. Taitz clearly
continued her illegal behaviors of publishing Plaintiff Liberi’s Social Security number and other
personal identifying information despite this Court’s warnings. On June 25, 2009, this Court plainly
stated that the continued behaviors would weight in favor of the Plaintiffs’.
As stated in JNA-1 Corp. v. Uni-Marts, LLC (In re Uni-Marts, LLC), 404 B.R. 767 (Bankr. D.
Del. 2009 @ *9:
“Where a non-resident defendant "purposefully directed his activities at residents of the

forum," his contacts with the forum are sufficient to support personal jurisdiction in any
"litigation [that] results from alleged injuries that arise out of or relate to those activities."
Burger King Corp. v. Rudzewicz, 471 U.S. 462, 472, 105 S. Ct. 2174, 85 L. Ed. 2d 528
(1985) (quotations omitted). A single transaction with the forum by the plaintiff will
suffice. See McGee v. Int'l Life Ins. Co., 355 U.S. 220, 223, 78 S. Ct. 199, 2 L. Ed. 2d 223
(1957). The defendant's activity need not take place within the forum so long as it is
"intentional conduct . . . calculated to cause injury" to the plaintiff within the forum.
Calder v. Jones, 465 U.S. 783, 791, 104 S. Ct. 1482, 79 L. Ed. 2d 804 (1984). See also
Burger King, 471 U.S. at 476 ("[W]e have consistently rejected the notion that an absence
of physical contacts can defeat personal jurisdiction . . . .")”
Mr. Hoppe is now claiming for the first time that the Defendants’ coming to Pennsylvania is a
hardship because they are located in California and Texas. This was never raised in the Defendants’
Motions to Dismiss, filed with this Court on May 26, 2009, which was denied, or in the alternative
transferred. The California Defendants’ are willing to travel to Texas, but now they are unwilling to
travel to Pennsylvania because it is a hardship? If true, then why would these Defendant’s be hiring an

out of state Attorney, who is not licensed in Pennsylvania, to travel to Pennsylvania, which would
severely increase the cost of litigation? As stated above in the transcription of Mr. Hale on his radio
show July 29, 2009, the Hale Defendant’s; the Sankey Defendants and Linda Sue Belcher, et al were
given the money by one of my supporters to hire their attorney and pay for their travel expenses. Thus,
there is absolutely no hardship.
Moreover and most importantly, if the Defendants’ did not want to travel to Pennsylvania, then
the Defendants’ should not have gone out of their way after the June 25, 2009 Hearing with Your
Honor and continue their illegal behaviors, which has severely hampered Plaintiffs’ ability to comply
with this Court’s Orders. Threatening witnesses is illegal as pointed out in Plaintiffs’ Motion and
letters to Your Honor. Defendant’s Belcher and the Hales through Defendant Plains Radio
intentionally set out, just hours after the June 25, 2009 hearing, to make extremely difficult if not
impossible for the Plaintiffs’ to respond to Your Honor’s Rules to Show Cause and support their
Responses with Affidavits.
Mr. Hoppe’s Inaccurate Explanation of Defendant’s Belcher and Hale’s Threats and Plaintiffs’
Witnesses concerns:
Mr. Hoppe claims Mr. Berg did not put out the full statement by his clients. Mr. Hoppe states,
“…is a blatant misrepresentation of what was said. Mr. Berg intentionally left out part of the
statement in an effort to justify his request.” This is completely absurd. The concerning threat, which
was outlined by six [6] parties who heard the actual radio show, four [4] of which are witnesses for the
Plaintiffs.’ As clearly pointed out in the witnesses letters provided to the Court in Plaintiffs’ Motion
on July 16, 2009: K. Strebel’s Affidavit; Lisa Liberi’s Verification; and two [2] emails provided to this
Court on July 24, 2009 where the witnesses stated their concerns and fears and included “[excerpt]
June 25th show Ed Hale to Linda (Belcher) Starr: "Let me tell you something, when these affidavits
come in that they claim they have, these people's names are gonna be known, their addresses are
gonna be known, and you know something? We're gonna know who they are, and you know what?
We will go after them with a vengeance..." Mr. Hoppe appears to have only read what Edgar Hale
sent him, as Mr. Hale is notorious for spelling the word “liars” as “lairs.” Mr. Hoppe states, “and
prove that they are lairs” [sic] is not accurate. First off, “go after them with a vengeance” “and prove
them a liar also” are clearly two different events. Plaintiffs’ were not concerned with Ms. Belcher and
Mr. Hale’s statements of their attempts to try and prove their witnesses as liars as Plaintiffs’ witnesses
are not lying. Plaintiffs’ and their witnesses are concerned with the statements the Defendants’ made
known that, “These peoples names are gonna be known”; “Their addresses are gonna be known”;
“And you know something, we are gonna know who they are…we will go after them with a
vengeance.” Mr. Hoppe may wish to listen to the actual radio show recording, not the altered version
he received from his clients.
What was said in totality regarding the threats was:
Linda Starr: “Well I feel like the Judge threw Berg a bone today. Because he said, ok,
you made all of these allegations and I'm gonna wait and give you a chance to support
the allegations you made with proof and evidence. And sworn affidavits with real
identities. Not fake IDs. They are gonna have to put their real identities out there.”
[emphasis added]

Ed Hale: “Yeah and I'm gonna tell you something. When these affidavits come in that
they claim that they have. These people's names are gonna be known. Their addresses
are gonna be known. And you know something, we are gonna know who they are. And
you know what, we will go after them with a vengeance. And prove that they are liars
also.” [emphasis added]
Caryn: “Who are you talking about?”
Ed Hale: “All of these affidavits that Berg claims he has. We are talking about...”
Caryn: “From just?...”
Linda Starr: “Caryn here is the deal. They are not going to be allowed to use
usernames. In order to produce sworn affidavits in court they are gonna be notarized
they are gonna have to use their real names.”
Caryn: “Ok.”
Ed Hale: “Yeah, there is no more hiding.”
Linda Starr: “Then we can identify them.”
Caryn: “And these are people that are using their user names that are making all of
these statements.”
Ed Hale: “That's correct.”
Linda Starr: “That's right”.
Caryn: “Ok.”
Ed Hale: “But now they have to come out from behind the anonymity of the internet.
And they have to come out and face us. And you know something...?”
Caryn: “And they will probably refuse to do it for Berg, huh?”
Ed Hale: “Let me tell you something. It’s easy as hell...”
Linda Starr: “Ron Polarik's ID is gonna be exposed.”
Ed Hale: “Let me tell you something...”
Linda Starr: “All these people that want to know who he is, it's gonna come out who
he is.”
Ed Hale: “Let me tell you something and listen to this.”

Caryn: “We're listen...”
Ed Hale: “This is what is hilarious in a way. The people that have told Berg, on the
Internet, oh let's just use Chilieman for an example. That Ed Hale wanted him to give
him money so he can give it to Berg. Well let me tell you something. Chilieman, you
can't hide no more. You're gonna have to come out and say who you are and
where you are.” [emphasis added]
Linda Starr: “Oh we know who he is. We know...” [emphasis added]
Linda Belcher a/k/a Linda Starr, as this Court can see, stated “Ron Polarik’s ID is gonna be
exposed…All these people that want to know who he is, it's gonna come out who he is.” Ron Polarik
is a witness for me in another case and has provided forensic analysis. Mr. Polarik has maintained
confidentiality of his legal name to protect him and his family from people like the Defendants’ herein.
It is apparent Ms. Belcher and Mr. Hale believed Mr. Polarik was going to supply an affidavit in favor
of the Plaintiffs’. As of yesterday, July 29, 2009, Ms. Belcher has carried out her threat towards Mr.
Polarik. A post was placed on Edgar and Caren Hale’s website located at www.plainsradio.com at
9:00 a.m. which states Ron Polarik, Mr. Berg’s forensic document expert’s, legal name is Ronald Jay
Polland and he resides in Florida. See EXHIBIT “2”.
To further carry out their threats, Linda Belcher a/k/a Linda Starr also had Mr. Polarik’s
information posted on her website at http://obamacitizenshipdebate.org/2009/07/meet-ronald-jay-
polland.html which states:
Meet Ronald Jay Polland

By CaptainAstro on July 29, 2009 6:38 PM | No Comments | No TrackBacks
This is Dr. Ronald Jay Polland. He received a BA in Psychology from Florida State
University in 1970, a Masters in Educational Research from FSU in 1972, and a
Doctorate in Instructional Systems from FSU in 1978. His curriculum vitae lists the
other accomplishments he finds noteworthy. He holds himself out as an expert on
surveys and market research.
Ron Polland is Ron Polarik.
http://barackryphal.blogspot.com/2009/07/meet-ronald-jay-polland.html
Again, Mr. Hale and Ms. Belcher are carrying out their threats made against Plaintiffs’ and
their witnesses. With Mr. Hale and Ms. Belcher putting out my expert witnesses name, I may have lost
my expert which could cause my case to be dismissed. As stated herein, Defendants’ threats have
become a reality in regards to Mr. Polarik; Orly Taitz threats to bring me down, destroy my paralegal
and anyone associated with us and to destroy my active cases. Since the threat against Polarik has
been a reality, it went from a threat to it happening, the fear is if your Honor does not stop the
Defendants, then it will also become a reality regarding the threats made against the Plaintiffs’ and
their witnesses.
Defendant’s Belcher and Hale are carrying out there threats made on June 25, 2009 and
carrying out the threats made by Defendant Orly Taitz to bring me down and to do so destroy my
paralegal, Lisa Liberi and get rid of her. All the Defendants’ joined forces early on to carry out

Defendant Taitz’s threats towards me, my paralegal and anyone associated with us. The intentions of
the Defendants’ speak for themselves.
This is further proof to this Court as to why Plaintiffs’ Motion for an Emergency Injunction or
Restraining Order must be immediately issued. It should be noted, not only was this post located by
Plaintiff Lisa Liberi, I also received the posts located on the Hale’s website from two [2] of the
Plaintiffs’ witnesses who will not supply an affidavit or testify until this Court takes protective
measures. Plaintiffs’ again request this Court to forward this information to the State’s Attorney
General pertaining to the threats made by the Defendant’s to all of Plaintiffs’ witnesses, for immediate
investigation and prosecution.
Mr. Hoppe further claims in his letter, “Mr. Berg has not produced any evidence that anyone
has in fact been so intimidated that they have refused to provide affidavits.” This is completely false.
In my letter to Your Honor on July 16, 2009, I reference two [2] of our witnesses who are very
important. In fact, in my letter I state, “Our witnesses were further instructed by the attorney’s in their
local area that until this Court acts, they were not to file any “Affidavits” or testify in this action for
their own protection.” [My letter of July 16, 2009, p. 2, ¶3]. Attached to my July 16, 2009 letter was
Plaintiffs’ Motion for the Emergency Injunction or Restraining Order, attached to the Motion as
EXHIBIT “D” is a letter dated June 29, 2009 from these two [2] particular witnesses outlining the
threats by Defendant’s Linda S. Belcher and Edgar Hale, which they heard and recorded from
Defendant Hale’s radio program. Attached as EXHIBIT “E” to Plaintiffs’ Motion is an Affidavit of
K. Strebel who was afraid to place his full name and address as a result of the threats made by
Defendant’s Linda S. Belcher and Edgar Hale and who also heard the threats by Belcher and Hale; and
attached as EXHIBIT “F” is another letter from the two [2] witnesses of ours who state they were
advised by their attorney’s until this Court takes protective action, they are not to provide affidavits
and EXHIBIT “G” the verification of Lisa Liberi who also listened to Mr. Hale and Linda Belcher’s
radio show of June 25, 2009, just hours after our Court hearing where this very Court had discussions
regarding the behaviors of the Defendants and issued an Order with a footnote stating, “Defendants’
are to conduct themselves as discussed in Court.” See EXHIBIT “3”. A couple of hours later is when
Mr. Hale and Ms. Belcher did the above radio show. In addition, attached to my letter to Your Honor
of July 24, 2009, which Mr. Hoppe was served with, were two emails from two [2] additional
witnesses of the Plaintiffs’ who heard the threats made by Mr. Hale and Ms Belcher and are concerned
for their safety and well being as a result of the threats made by Ms. Belcher and Mr. Hale. Contrary
to Mr. Hoppe’s statements, Ms. Belcher and Mr. Hale have undoubtedly made known what their
intentions are towards any witness who submit an affidavit for the Plaintiffs’, see above. As this
Court can see, I have supplied documentation received from witnesses for the Plaintiffs’.
It appears Mr. Hale forgot to mention to Mr. Hoppe, that when he received Your Honor’s
Order and copies of the Plaintiffs’ Motion for the Emergency Injunction or Restraining Order on July
27, 2009, Mr. Hale immediately posted it on his website and encouraged his supporters and followers
to review it. As this Court is aware, K. Strebel’s Affidavit was attached as well as the letters provided
by two [2] of Plaintiffs’ witnesses and this is exactly why addresses were omitted and I “blacked-out”
the other two [2] witnesses names and addresses.

For the above aforementioned reasons, unless this Court issues Plaintiffs’ Emergency
Injunction or Restraining Order pending the Hearing on Plaintiffs’ Request, the Plaintiffs’ and I hereby
oppose Mr. Hoppe’s request for a thirty [30] day extension of time and respectfully request this Court
to deny Mr. Hoppe’s request for the continuance.
Thank you.
Respectfully,
Philip J. Berg
PJB:jb
Enclosures
cc: Orly Taitz, et al and

Defend our Freedoms Foundation, Inc.
26302 La Paz Ste 211
Ph: (949) 683-5411
Fax: (949) 586-2082
By Email: dr_taitz@yahoo.com
Counsel in pro se
Defend our Freedoms Foundations, Inc. is unrepresented
Mr. Ted Hoppe, Esquire

Hoppe & Martin
423 McFarlan Road, Suite 100
Kennett Square, PA 19348
Phone: (610) 444-2001
Fax: (610) 444-5819
By e-mail: thoppe@hoppemartin.com
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

Linda Sue Belcher
201 Paris
Castroville, Texas 78009
Home Phone: (830) 538-6395
Cell Phone: (830) 931-1781
Email: Newwomensparty@aol.com and
Email: starrbuzz@sbcglobal.net
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

NOTE - Since this Court advised Plaintiffs' Counsel to maintain the original Dossier #6 containing Plaintiff Lisa Liberi's social security number,
Counsel has also maintained this original letter without redactions to produce to the Court to ensure the confidentiality of the parties names
and address for the parties safety and protection.
From: Redacted
Date: Mon, Jul 20, 2009 at 2:33 AM
Subject: June 25 Plains Radio Show
Since Ed Hale made direct threats on his show against anybody who submits an affidavit on
behalf of the Plaintiffs, is there any way that the judge can keep personal identifying
information confidential or suppressed?
I know Ed is full of hot air, but his and Orly's followers are loose cannons, and in my opinion...
dangerous. My mom and I are still going to give our statements, affidavits, and testify in court
if needed, because it's the right thing to do. And if we have to, we will petition the judge
ourselves. My mom is elderly. I am concerned for her safety, and the court needs to take
every legal measure to ensure her safety.
Please let me know, ok? Do me a favor and Ask Phil what he thinks is a good course of
action. Ed is trying to intimidate witnesses and there's got to be a way to make the judge
aware of this.
(name redacted)
[excerpt] June 25th show

Ed Hale to Linda (Belcher) Starr: "Let me tell you something, when these affidavits come in
that they claim they have, these people's names are gonna be known, their addresses are
gonna be known, and you know something? We're gonna know who they are, and you know
what? We will go after them with a vengeance..."

From: Redacted
Date: Wed, Jul 22, 2009 at 3:16 AM
Subject: affidavit/ (name redacted) mom
I am prepared to submit my affidavit. However, I am concerned as to my safety due to the

threats that Ed Hale and Linda Belcher made on his show on June 25, 2009.
I truly fear for my life, if my personal identifying information is disclosed to these individuals.
I know it is intimidation but these individuals, and their followers, don’t appear to care or
respect the law. I believe them when they announce that they will go after me with a
vengeance. I would appreciate it if Mr. Berg would ask the judge not to disclose my identity
and address.
Thank You
Mary (last name redacted)

EXHIBIT “1”

Plains Radio Network, Host: Ken Dunbar, July 29, 2009 at 6:00 – 8:00 p.m. CST
at 126:20 through 131.57 into the show, Ed Hale comes on
126:20
Ed Hale: “There is a letter that was written by Ted Hoppe, who was our attorney that he sent to the
Judge and it’s on our website and go to www.plainsradio.com/linda.html and you can see that letter in
PDF file. Also I want to announce, thanks to Linda Starr we have a benefactor, who has paid David
Carlton Hughes, the Attorney in Dallas that we originally wanted the twenty five thousand dollars to
defend us. I want to personally thank Linda for all her hard work she has done to help us out on this
matter. Now, Plains Radio is going to stay on the air. Now all the money you guys donated to us were
going to use that for plane tickets for me, Caren and Linda so when our Attorney appears in that
Courtroom we will be there also to look Berg in the eyeball and tell him he is falsifying information
and manufactured evidence, Ed can’t use that word anymore. But anyway that is what I got to say
about that, okay.”
Ken Dunbar: “Now what date is that Ed?”
Ed Hale: “It’s supposed to be August 7, now this lawyer that Ted Hoppe sent to the Judge telling him
that we had changed attorney’s, he is asking for a thirty [30] day continuance, however, the back up
plan is if the Judge does not grant us that thirty [30] day extension, Caren, Linda and I will be in
Philadelphia to defend ourselves on August 7 at 10:30 a.m. so what we are doing now is just sitting
there waiting to see what the Judge is going to say.”
Ken Dunbar: “Very good, that is just 9 days away Ed, not this Friday but the next.”
Ed Hale: “That’s why we are going to have all our cd’s transcribed, which we never got them all
transcribed, and we will fed ex them out Friday to the Judge so he will have them by the deadline on
Monday. He didn’t give us but a week to get all this done. We have ten [10] cd’s we have to
transcribe.”
Ken Dunbar: “But the good news is Ed is that you don’t have a show to do yourself so you’re not
scrambling to get a guest or what have you, your just scrambling now to work on for the lawsuit”
Ed Hale: “Well, this is true Ed has all, he has all the audio tapes now on cd’s, actually they are called
a high quality like a recording studio did it. We have several of the great patriots here at plains radio
network who are transcribing these discs for us. And, let me tell you something, when we present this
and if you will read that letter that Mr. Hoppe sent I want to tell you something that is a dynamite letter
because in that he basically said Berg you are lying to the Judge.”
Ken Dunbar: “Judges don’t like to be lied at, do they Ed?”
Ed Hale: “No, I don’t think so and you know we just got this thing going and what’s funny about this
donor is that he is a former major supporter of Phil Berg and when he seen that Phil Berg was lying
about or there I go using that word again I aint supposed to, manufacturing that evidence that was not
true against us he told or she told Berg or who ever it was to take a hike and that person then called

Linda up and said can I help you. Linda then explained the situation with this attorney and he called
this David Carlton Hughes up in Dallas and said what is it going to take, David said it will take twenty-
five thousand dollars, a wire transfer was completed this morning. That was money that was gonna go
to support Berg, but he aint gonna get it now.”
Ken Dunbar: “So you can’t use the words, don’t say it again, but can you instead say he was making
allegations.”
Ed Hale: “He was making false allegations”
Ken Dunbar: “So certain false allegations that have been proven to be false per the audio record.”
Ed Hale: “That is correct, and it is like one of the people transcribing said I don’t know why we need
this, a spoken word is heavy and I said because the Judge wants to read it He said he’s gotta listen to
these tapes because he said it just proves that what Mr. Berg said was false.”
Ken Dunbar: There you go.
Ed Hale: “Alright I’m getting off of here, go ahead Ken I’m sorry for butting in here but I thought
people need to know.”
131:57

EXHIBIT “2”

Plains Radio Network - Voice of the People - Window Title
Plains Radio Network - Voice of the People
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Index > General > General Forum > PJer Outs Ron Polarik as a Fraud July 29, 2009 - 11:59:28 AM
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rikker PJer Outs Ron Polarik as a Fraud Quote Reply
PJ member Loren has been tracking down Ron Polarik, Phil

Berg's forensic document expert. It turns out that Polarik is a
Jul 29, 2009 - 9:00AM far right Israel supporter who agreed with IsraeliInsider's
original fears about Obama's muslim ties. None of his claims
about document expertise are borne out by his actual resume.
ANd that's why he'll never testify about Obama's "forged" COLB
in any American court.
http://barackryphal.blogspot.com/2009/07/meet-ronald-jay-
polland.html
Polarik's real name is Ronald Jay Polland. And he lives in MY

city!! Oh, joy!!!
For those of you that don't know Ron Polarik, here is his
analysis of Obama's COLB:
http://www.freerepublic.com/focus/bloggers/2136816/posts?
http://pub29.bravenet.com/forum/static/show.php?usernum=2442810129&frmid=8&msgid=1040553...
page=321#321.
State: FL
Civis Naturaliter Natus Re: PJer Outs Ron Polarik as a Fraud Quote Reply
I see no evidence that one is the other. Merely a gratuitous

assertion.
Jul 29, 2009 - 9:36AM
Aslo, what this guy who does the outing does not understand, is
that even if this fellow does not have the expertise, he could
have been collaborating with other document experts and
posted their collective work under the Pollark name...
So who he is proves nothing.
Look,
If an anonymous fellow gives you the mathematical solutoin to

the
Integral
(x-3)^.1-(x^2+3x)^2=y, for y=1 to 5,
It does not matter what his credentials are, if the truth of the
answer he gives you can be independently determined.
So the real "proof" will be a document expert who critiques

Pollarks work.
But in one sense it is a wast of time, because the JPG is not a

document, and so no disproof is necessary, since it is not
admissable in Court.
So when Obots claim the BC is on the net; their claim is

rediculous and inadmissable evidence.
It is illogical for them to hunt down someone who calls that

evidence into doubt, because it is not evidence admissable in
court in the first place!
rikker Re: PJer Outs Ron Polarik as a Fraud Quote Reply
Civis,
Jul 29, 2009 - 9:47AM Do you know anything about establishing and impeaching
subject matter experts in a court of law? The first thing that
impeaches a subject matter expert is "I hang around with
people who are experts."
The second thing that impeaches a SME is to have a written

record of lies. Polarik claimed that HE possessed doctorate level
forensic document analysis skills. He does not. He has lied in
writing. Any lawyer who puts him on the stand is a fool.
State: FL
Rebel Rose Re: PJer Outs Ron Polarik as a Fraud Quote Reply
Quote:
Jul 29, 2009 - 11:10AM
Originally Posted by rikker
Civis,
Do you know anything about establishing and impeaching

subject matter experts in a court of law? The first thing
that impeaches a subject matter expert is "I hang around
with people who are experts."
The second thing that impeaches a SME is to have a

written record of lies. Polarik claimed that HE possessed
doctorate level forensic document analysis skills. He does
not. He has lied in writing. Any lawyer who puts him on
the stand is a fool.
I see Civis drank the Kool-Aid on this one, too.
Polarik's research meant SQUAT from day one, and anyone who
wasted time on his claims of "fraud" and "forgery" regarding
the COLB clearly lacked knowledge of what constitutes proof in
a court of law and what doesn't.
Recently, he's tried to get the spotlight to shine on his study yet
again--obviously seeking more publicity for himself--and some
blogs are even foolish enough to publish it. Others are even
gullible enough to believe one word he says.
Despite all of his ramblings, the online version was never

acceptable proof of ANYTHING. It was NOT the original, it was
NOT the vault form that was needed to prove citizenship--
digitized image or not, irregular borders or not, "seal" or not, so
there was absolutely no value in paying any attention
whatsoever to any of his claims.
I put him in my "hoax" file a long time ago. Focus on the long
form--period.
State: Tennessee
Index > General > General Forum > PJer Outs Ron Polarik as a Fraud
EXHIBIT “3”

IN THE UNITED STATES DISTRICT COURT
LISA LIBERI et al., : CIVIL ACTION

: NO. 09-1898
Plaintiffs, :
:
v. :
:
ORLY TAITZ et al., :
:
Defendants. :
O R D E R
AND NOW, this 25th day of June, 2009, it is hereby
ORDERED that Plaintiffs’ emergency motions for an injunction
and/or a temporary restraining order (doc. nos. 3 & 66) are
DENIED without prejudice.1
IT IS FURTHER ORDERED that Defendants' motions to
dismiss (doc. nos. 23, 24, 25, 35, 50, 53 & 59) are DENIED
without prejudice.
IT IS FURTHER ORDERED that Plaintiffs' motions to
strike (doc. nos. 58 & 64) are DENIED without prejudice.
IT IS FURTHER ORDERED that Defendant Taitz's motion to
strike (doc. no. 61) is DENIED without prejudice.
AND IT IS SO ORDERED.
s/Eduardo C. Robreno
EDUARDO C. ROBRENO, J.
1
Defendants are to conduct themselves according to the
parameters discussed today in open court.
EXHIBIT “X”
Case 2:09-cv-01898-ER Document 96 Filed 08/10/2009 Page 1 of 1


: NO. 09-1898
Plaintiffs, :
:
v. :
:
:
Defendants. :
O R D E R
AND NOW, this 10th day of August, 2009, it is hereby
ORDERED that Plaintiffs’ motion for an injunction or a temporary
restraining order (doc. no. 83) is DENIED.1
S/Eduardo C. Robreno
1
“‘It is frequently observed that a preliminary
injunction is an extraordinary and drastic remedy, one that
should not be granted unless the movant, by a clear showing,
carries the burden of persuasion.’” Mazurek v. Armstrong, 520
U.S. 968, 972 (1997) (quoting 11A Wright, Miller & Kane, Federal
Practice and Procedure § 2948 p.129-30 (1995)). To obtain a
preliminary inunction, Plaintiffs must demonstrate that “(1) that
they are reasonably likely to prevail eventually in the
litigation and (2) that they are likely to suffer irreparable
injury without relief.” Tenafly Eruv Ass’n, Inc. v. Borough of
Tenafly, 309 F.3d 144, 157 (3d Cir. 2002). If these two
threshold requirements are met, the Court should then consider
“(3) whether an injunction would harm the [Defendants] more than
denying relief would harm the plaintiffs and (4) whether granting
relief would serve the public interest.” Id.
Here, following a hearing, Plaintiffs have not made a

threshold showing of a reasonable likelihood of success on the
merits, or irreparable harm. Thus, a preliminary injunction is
not appropriate in this instance.

: NO. 09-1898
Plaintiffs, :
:
v. :
:
:
Defendants. :
O R D E R
AND NOW, this 25th day of June, 2009, it is hereby
ORDERED that Plaintiffs’ emergency motions for an injunction
and/or a temporary restraining order (doc. nos. 3 & 66) are
DENIED without prejudice.1
IT IS FURTHER ORDERED that Defendants' motions to
dismiss (doc. nos. 23, 24, 25, 35, 50, 53 & 59) are DENIED
without prejudice.
IT IS FURTHER ORDERED that Plaintiffs' motions to
strike (doc. nos. 58 & 64) are DENIED without prejudice.
IT IS FURTHER ORDERED that Defendant Taitz's motion to
strike (doc. no. 61) is DENIED without prejudice.
s/Eduardo C. Robreno
1
Defendants are to conduct themselves according to the
parameters discussed today in open court.
EXHIBIT “Y”
Law Offices of:
PHILIP J. BERG, ESQUIRE
Lafayette Hill, PA 19444-2531 Attorney for: Plaintiffs
(610) 825-3134

LISA LIBERI, et al, :

Plaintiffs, :
vs. : Assigned to Honorable Eduardo C. Robreno
:
ORLY TAITZ, et al, :
: Case No.: 09-cv-01898-ECR
Defendants.
:
:
:
:
:
:
AFFIDAVIT OF SHIRLEY WADDELL
I, Shirley Waddell am over the age of eighteen (18) and not a party to the within
action. I have personal knowledge of the facts herein and if called to do so, I could and
would competently testify under oath.
I declare as follows:
1. Lisa Liberi is my daughter.
2. August 2008, Phil Berg, Esq. filed his lawsuit “Berg v. Obama” questioning
the citizenship status and constitutional eligibility of Barack H. Obama to run for and
serve as President of the United States. Approximately November 2008, Orly Taitz,
Esq, filed her lawsuit Lightfoot v. Bowen.
1
Affidavit of Shirley Waddell
3. Orly Taitz, Esq. wanted to be a part of Mr. Berg, Esq. and Lisa Liberi’s
working relationship. However, Mr. Berg, Esq. and Lisa Liberi did not want to be a
part of Orly Taitz, Esq. due to Taitz’s business tactics. Orly Taitz continued to
advertise on a daily basis for attorneys, paralegals and legal secretaries to help her.
Mr. Berg, Esq. knew that Taitz had plagiarized his and Liberi’s hard work.
However, Mr. Berg said he did not care that Taitz had stolen from him if it helped to
settle the Obama issue. I believe Taitz’s campaign to destroy Liberi and Berg was
retaliation due to what Taitz viewed as “rejection”, intolerance to differing view
points of Liberi, and getting rid of what she considered “competition.”
4. While doing a search on the internet, I learned of another that had
experienced the attacks of Orly Taitz. I identified with McKinnion’s experiences and
agreed with his insight of Taitz. He says it much better than I could. This article was
written by Patrick McKinnion of “Yes to Democracy” on February 16, 2009: 1
“Hatriots and Pinheads”. Mr. McKinnion wrote as follows:
“And the fun continues, now with Dr. Orly Taitz and her Cavity Creeps
trying to harass, defame smear, and attack the people here at ‘Yes To
Democracy’, all because someone DARED to point out the truth about Dr.
Orly, her behavior and claims, and ask “do you really want to be
associated with her??”.(In the case of one far-right State Representative
from Oklahoma, the answer seems to be ‘yes’. His choice. And his
dishonour.)”
“However, what it means is that Dr. Orly’s behavior is being challenged.

And like most bullies, she can’t handle it. Its patriotism: when they flood
peoples mail and email boxes with their spam, but ‘harassment’ when
someone points out the Empress has No Clothes.”
1
http://www.yestodemocracy.com/yes_to_democracy_no_to_pu/2009/02/hatriots-and-pinheads-birther-
update.html
2
“Now I called Dr. Orly a “bigot” when she called her opponents “Nazis”,
“Communists”, and ‘Radical Muslims’. I see absolutely no reason why I
should change that claim. Except to add a new one.”
“Coward”.
“Dr. Orly sends her minions to harass her opponents, collect personal info
on them, post addressees and emails. Rather than prove her claims, she
hides behind baseless insults and cowardly attacks on her critics.”
“This is not the actions of a ‘Brave Defender of the Constitution’”
“This is the action of a coward and a bully.”
“She tells her supporters to mail and email the slightest speck of anything
to the FBI, CIA, INS, US Attorney’s Office, Secret Service, Supreme
Court, etc. She sends reams of bogus claims, false statements, and
paranoid conspiracies to anyone she thinks will listen. But if someone
dares challenge her on it, and she becomes unhinged. Like she recently
did when someone asked her about the money they donated to her and she
replied that the donation didn’t give the donor the right to question her.”
“I’m not kidding about that either. Example:”
“2/12/2009 1:21 PM Defend Our Freedoms Foundation wrote:

…You are also on my site. Paid for by me. None of your donations have
paid for you to come on here and question me.”
“Again, a bully. Don’t dare question, don’t dare challenge, just hand over
your lunch money and do what you’re told.”
“If she does harass and attack you, the answer is simple. Defend yourself.
You have the facts, the evidence, and the truth on your side. Don’t lower
yourself to the level or her or her supporters. They’re not worth it.
If you feel she has crossed a line, then the answer is simple.”
“California Legal Ethics can be found here. Conduct of California

attorneys is governed by the California Constitution (art. VI, §9); the State
Bar Act (Cal. Bus. & Prof. Code §state and local ethics opinions; and state
and local rules of court. California State Bar handles disciplining of
attorneys and illegal solicitation of clients. If you feel that Dr. Orly Taitz’s
behaviour as an attorney warrants it, her California Bar Number is
223433, (information available to the public via the California Bar
Association’s website). Complaints can be filed here with the California
Bar Association.”
3
“This information is provided in the event you feel her behaviour warrants
such an action being taken. Do not lower yourself to her level and use it
to harass her or others with.”
5. A complaint was filed against Orly Taitz with the California Bar
Association by an anonymous person. The person filed anonymously due to
retaliation. People began to post questions regarding the Bar Complaint for Taitz on
her blog, approximately the middle of April 2009. Other blogs had also posted this
State Bar Complaint.
6. April 8, 2009, Taitz posted Dossier #6 on her website at repubx2, which was
her new blog name. Orly Taitz wrote that the open letter posted on the internet was
forwarded to 26,000 outlets of U. S. and international media. Later she (Orly Taitz)
commented on Dossier #6 being sent to approximately 36,000 outlets on four
occasions. Within Dossier #6, Taitz wrote that Lisa Liberi had an extensive criminal
record going back to the 1990’s. Taitz incorrectly refers to Liberi’s middle name as
RENEE. Taitz wrote that Liberi’s restitution payments added up to $21,000.00 per
month. Taitz asked where the money was coming from; who was paying it; and did
someone help Liberi avoid jail time here in CA in exchange for her efforts to cloud
the issue? Taitz posted Liberi’s name, birth date and 2 Social Security Numbers, one
of which was the full social security number of Liberi. Taitz told the readers that
there were more Social Security Numbers.
PLEASE NOTE: Liberi went through Identity Theft and is the victim of
domestic violence crimes. Liberi was given a confidential address and the Social
Security Administration issued her another Social Security Number. These are
2
http://216.221.102.26/blogger/post/Dossie6.aspx
4
the only Social Security numbers that Liberi has ever had. Liberi does not have
extensive criminal record going back to 1990”s. There is an article that Taitz
posted with Dossier #6 regarding Real Estate Fraud from a website called
mortgagefraudblog.com.3 I found an original copy of this article and noticed
that what Taitz posted had been altered. Liberi does not pay $21,000.00 a month
in restitution.
7. Saturday, April 18th, 2009, Orly Taitz wrote and posted
http://drorly.blogspot.com/: “The Defend Our Freedoms blog/site hijacked! Please
go to Dr. Orly Taitz Esquire’s New OFFICIAL Blog at: http://www.orlytaitzesq.com/
Taitz also updated the February 3rd, 2009 posting on drorlytaitz.com to read: NOTE:
this post is updated because the defendourfreedoms.us and defendourfreedoms.org
were hijacked. More info on this matter is on the new site that should be more
secure. http://www.orlytaitzesq.com.
8. April 18th, 2009, Orly Taitz wrote and posted on her website located at
www.orlytaitzesq.com/blog1/?p=36 - “Follow up on Lisa Liberi, paralegal to Phil
Berg”. Taitz posted probation officer’s fax and phone numbers in Santa Fe, New
Mexico. She wrote that before she posted dossier #6 that she had 3 independent
sources of the findings of licensed investigator Mr. Sankey. Taitz wrote that after the
revelations about the name Lisa Liberi, then Liberi changed her name to Agent88 on
Mr. Berg’s site. Taitz wrote in part:
“I believe, that when non-profit organizations are involved and donations

are collected, one should not employ people that are questionable and
particularly people that have a lengthy criminal record that includes
forgery, forgery of seals and grand theft.”
3
http://www.mortgagefraudblog.com
5
Taitz went on to say that she had closed her pay pal account. Taitz wrote in Part:
“Yet another important matter. So far none of Obama eligibility matters

have gone to trial and we all are working hard to change it. But let’s say
one such case goes to trial. We don’t want to be impeached by Obama’s
attorneys saying that we knowingly employed shady characters, who
might‘ve supplied us with incorrect information. Just like the country
needs to be purged of Obama and his clique, that are in power by virtue of
forgery, fraud and consealment of vital records, the patriots of this country
need to purge their ranks.”
PLEASE NOTE: Of course Taitz is wrong about Agent 88, and I definitely
challenge whether or not she had 3 independent sources of the findings of Mr.
Sankey. There are too many untrue statements and assumptions in his report.
There was also an article that Mr. Sankey published on real estate fraud. I
found this article, and it has been altered from the original web posting.
Regarding Orly Taitz comments of “working with shady characters who might
have supplied incorrect information, and patriots need to purge their ranks”, lets
take a good look at Taitz. This would probably be a good place to start the
purge. As I mentioned before, Taitz was advertising daily for help from an
attorney, paralegal, or legal secretary. Taitz plagiarized Mr. Berg’s and
Liberi’s work. Taitz now has (or always had) Charles Edward Lincoln, III to
assist her. They are now officially a legal team. Mr. Lincoln #171793 was
admitted to California State Bar in 1994, and disbarred January 11, 2004. The
Florida Bar disbarred Mr. Lincoln July 1, 2002, and Texas Bar disbarred Mr.
Lincoln in approximately 2000. As stated in the California State Bar4:
4
http://members.calbar.ca.gov/search/member_detail.aspx?x=171793
6
California Bar Journal Discipline Summaries
“January 11, 2004

CHARLES EDWARD LINCOLN [#171793], 44, of Cedar Park, Texas was
disbarred Jan. 11, 2004, and was ordered to comply with rule 955.
In 2000, Lincoln was convicted in Texas on a federal charge of falsely

representing his Social Security number, a felony. As a result, he gave up his
license to practice in the state.
Originally charged with five felonies, the case resulted from Lincoln applying for a
checking account using a false Social Security number.
In a second matter, he was disbarred from U.S. District Court for the Western
District of Texas after a federal judge requested an investigation of Lincoln
because two of his clients had a falsified receipt. The receipt purported to be
from the federal court clerk and represented funds the clients had given Lincoln.
The clients believed Lincoln was depositing their money in an escrow account
related to their case.
Two days before a hearing by the federal court’s admissions committee, Lincoln
went to his clients’ home, instructed them not to tell the judge that he gave them
the receipt, which he asked them not to produce, and he gave the clients a
cashier’s check for $6,000. He did not appear at the hearing.
In a previous lawsuit, the same judge determined that Lincoln was involved in
discovery abuse and filed duplicative motions. The judge issued sanctions and
dismissed the lawsuit with prejudice.
The State Bar Court determined that Lincoln’s misconduct in Texas amounted to
violations of California law as well.”
“March 19, 2002

CHARLES EDWARD LINCOLN [#171793], 42, of Cedar Park, Texas was placed
on interim suspension March 19, 2002, following a conviction for false
representation of a Social Security number. He was ordered to comply with rule
955.”
9. On April 19th, 2009, Orly Taitz wrote and posted an article entitled “Every
day I get such evidence of missing or misdirected funds.”
www.orlytaitzesq.com/blog1/?p=119, see EXHIBIT “A”. Orly Taitz states “Lisa
Ostella, aka Lisa Current aka Calpernia is stealing donations. Also connected to Lisa
Liberi aka Lisa Richardson aka Lisa Courville.” A person that posts on Taitz’s blog,
7
by the name of “wow!”, wrote in part: “Why not just file a lawsuit against this Lisa
Ostella aka Lisa Current, aka Lisa Liberi aka Lisa Richardson aka Lisa Courvelle
aka Lisa Calpernia.” Taitz had previously inferred that Lisa Ostella and Lisa Liberi
were the same person.
10. Article posted April 20th,2009, www.orlytaitzesq.com/blog1/?p=177 Taitz
posted an E-Mail she had written to John Ziegler, Hon. Alan Keyes, Gary Kreep,
Arlen Williams, Phil J. Berg, Esq, and with a cc: to Bob Unruh, Joseph Farah,
Chelsea Shilling of WND. Taitz sent a copy of Dossier #6 (Obama & Liberi) and
accuses Ostella of stealing donations and Taitz’s foundation. Taitz wrote that Ostella
had recently posted links to sites, and pictures of the recipients of this e-mail. Taitz
wrote that this act creates an impression in the eyes of the public and law enforcement
that “you all” are part of this scheme. She urged all recipients of e-mail to publicly
disassociate themselves from Ms. Ostella and her fraudulent and outrageous actions.
11. On Tuesday, April 21st, Orly Taitz writes and publishes on her website at
http://www.orlytaitzesq.com/blog1/?p=195 a post entitled “Update on Lisa Ostella
and Lisa Liberi”. Al Barrs of albarrs@wfeca.net posted a comment about how
shocked he was to read what the Webmaster Ms. Ostella had done to Taitz. He said
that it was obviously a crime; Taitz should have law enforcement to bring criminal
charges for stealing Taitz’s good name and donations. Taitz responded to Al Barrs
that she had reported the matter to the Sheriff’s department and FBI. She told him to
spread the word and give everybody the new web address for the Defend Our
Freedoms Foundation, which is http://www.orlytaitzesq.com. She told him to post
the web address in as many blogs and sites as he could, so it will be picked up quickly
8
by different search engines and can be seen by all my readers. She told him RE:
Ostella: “I have sent a Cease and Desist letter to Ms. Lisa Ostella, demanding that
she forward to me the access codes for the domains and the e-mail address list of the
readers and stop fraudulently operating under the name DefendOurFreedoms….
Ironically Ms. Ostella has accused me of collecting information on the readers… Ms.
Lisa Ostella is one, who collected names and e-mail addresses and she is currently
fraudulently sending e-mails to these readers using DefendOurFreedoms name.”
Taitz went on further telling Mr. Barrs RE: LISA LIBERI: stating she (Taitz) sent an
e-mail with dossier #6 to Phil Berg advising him of the lengthy criminal record of
Liberi who reportedly was managing his fund raising efforts, and Berg should get rid
of her. Taitz inferred that Berg was giving donations to Liberi to pay $21,000.00 a
month in criminal restitution, instead of Obama litigation.
PLEASE NOTE: Lisa Liberi does not have a lengthy criminal record dating
back to the 1990’s. She does not pay $21,000.00 in restitution per month. Lisa
Liberi was not a volunteer or employee of Taitz. Liberi volunteers for Philip
Berg, Esq. as Mr. Berg’s paralegal and has never had anything to do with
donations taken in by Mr. Berg or any type of fundraising.
12. On Friday, May 1st, 2009, Orly Taitz writes and posts on her website
www.orlytaitzesq.com/blog1/?p=513 “More Attacks on me. More indepth research is
done in spite of attacks”. Taitz said in this post that she “recently received an e-mail
claiming that she and her husband spy on people with software”. Taitz goes on to
write that she is so successful in uncovering illegal and criminal activities that they
get scared and are trying to scare people into not reading the damaging information
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that she uncovers. She writes that they don’t want the public to know the truth.
Taitz does not mention who THEY are.
13. On May 4th, 2009, the Plaintiffs’ filed a Law suit against Orly Taitz, and
other Defendants.. Shortly thereafter, on or about May 6, 2009, I learned the
Probation Department in Santa Fe, New Mexico received a bomb threat. Remember
that during the month of April onward, Taitz was posting the telephone numbers of
Santa Fe, N.M., Probation Department and telling everyone to call regarding my
daughter Lisa Liberi. This was also posted on other websites. Of course any one
could have called in the bomb threat, however, when someone is posting on the
internet for everyone to make telephone calls to the same number, the probability
goes up that it was someone within “this mass” that made the bomb threat.
14. On May 9th, 2009 at 5:09 a.m. Orly Taitz writes and posts on her website
at http://www.orlytaitzesq.com/blog1/?p=834 entitled “Information update on both
Liberi and Obama.” Taitz mentions Press Release of Philip J. Berg, Esq. in January
2nd, 2009. Taitz claimed credit for Dunham-Soetoro divorce papers, and gave credit
to Ed Hale for Dunham-Obama divorce papers. In particular Taitz says “By the way,
Berg and Lisa Liberi got Dunham-Soetoro divorce papers from me and they got
Dunham-Obama divorce papers from Ed Hale.” Taitz talks about outrageous and
hurtful allegations from Berg but does not mention what they are. Taitz then tried to
cleverly blame everything on what Berg was now doing (whatever that is) on the
criminal issues of Lisa Liberi. She started bashing Liberi again. She said that Liberi
was collecting disability payments from social security, and getting paid by Berg.
However, Linda Belcher who goes by the screen name of Linda Starr and Taitz had
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referred to Liberi as a volunteer on other occasions. Taitz continues claiming Liberi
was committing fraud against Social Security. Taitz raises the question to her readers
“Where does she get the restitution of $21,000 per month owed to victims” referring
to Liberi. Taitz tells readers to get out Dossier 6 again, and claims perhaps
restitution is now reduced to $12,000 per month. Taitz points out that Liberi is
violating her probation because she is working with donations. Taitz asked if there
were any volunteers who live in Santa Fe? Taitz then mentioned Dossier #1
(Dossier #1 is about President Obama and supposed crimes of his). Taitz told her
readers that there is another issue, did somebody arrange for Liberi to be associated
with Berg, to get him into serious legal trouble.” Taitz goes on stating Liberi was
in Rancho Cucomanga [sic], and Michelle Obama was working for “Muslim World
Today” in Rancho Cucomanga [sic]. Taitz continues stating Liberi has changed her
Social Security several times and now she applied for yet another SS number. Obama
names are connected to 25 different social security numbers. Taitz smells a
conspiracy here.
PLEASE NOTE: Liberi is a volunteer for Philip Berg, Esq. Liberi does not
pay $21,000.00 a month for restitution, nor does she pay $12,000.00. Liberi is
not in conspiracy with President Obama and First Lady Michelle Obama.
Liberi has not changed her Social Security number several times. Social
Security Administration changed her Social Security Number once (1) due to
domestic violence and identity theft.
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15. On May 28, 2009 Linda Belcher a/k/a Linda Starr wrote and posted on her
website at www.obamacitizenshipdebate.org/2009/05/may-28th-happy-birthday.html,
which was posted at 8:08 AM “Today is Lisa Liberi’s 44th birthday!” Within the
article Linda Belcher states “We want to be sure she knows we all send very special
birthday wishes to her, especially those of us who Lisa personally banned.” referring
to Liberi. Anyone can see that this is vindictive, and another way of giving Liberi’s
birthdate. Linda did not mention who WE or US were. She talked about Mr. Berg
claiming that she stole his (supporters) people. Linda wrote in part: “I was not the
one who wrote the invitation that was sent out to others. I did “tweak” it though,
(LOL).” Linda continues, “since I was a volunteer, we didn’t have any sort of signed
contract, or even a verbal, non-compete agreement. I can’t wrap my mind around the
fact that he thinks he owns people. Wasn’t slavery outlawed?” The above written
and published comment about Mr. Berg and my daughter does give one an insight
into Linda Starr aka Linda Belcher’s questionable character. There were other
comments about Lisa’s Birthday, one from a person posting as Constitutionalist said
“Birthdays are always filled with surprises”. Linda Starr replied to a comment from
Constitutionalist at 2:44PM: “Yes, they are! I have it on good authority that there
is a surprise Lisa may be getting, however, it might be delayed a few days. On
second thought, it will be a surprise, but probably not a happy one for any of the
plaintiff’s, though it will definitely be a huge shock to Phil.” Since Liberi was Mr.
Berg’s assistant, the comments sounded like these animals were going to physically
harm Liberi and/or her family so she would be out of the picture completely and
permanently. This caused quite a bit of concern for our family.
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16. The night of May 28th, 2009 Orly Taitz private investigator, Defendant
Neil Sankey, went on Defendant Ed Hale’s radio show located at plainsradio.com. I
guess this was the vindictive birthday surprise from Linda Starr, Orly Taitz and Neil
Sankey had previously distributed material about Ostella and Liberi. Hale was one
of the many recipients of this material. Hale, his wife, Caren and people in the chat
room were asking questions. Sankey said that Liberi had a criminal record under the
name of Richards, and there were 200 counts against her. He said Liberi had bought 5
brand new cars for friends, and Liberi had cheated businesses out of $350,000 to
$400,000.00. He said that in 2004 Liberi was arrested and charged with 4 counts for
selling and reselling a house. Sankey also said that he had obtained Lisa’s Driver’s
License and Social Security from Bankruptcy court, took this to San Bernardino. He
said that Liberi had filed bankruptcy 4 times. Sankey said that they had a right to
Liberi’s SS# to post because there was fraud. Ed Hale then said that he had posted
information on Liberi. Hale said that Liberi was a pathetic liar, and strongly implied
that he had plenty on Mr. Berg. Hale said that Liberi had applied for another loan.
He also said that Liberi was working for Obama trying to get a pardon. Neil Sankey
then claims Lisa Ostella was the one who hired him, but didn’t pay him. However,
Taitz mentioned Neal Sankey as providing addresses to her on January 9th,2009
www.drorly.blogspot.com/2009_01_04_archive.html. She also thanked him for his
help on January 17th, 2009 www.drorly.blogspot.com/2009_01_11_archive.html. He
also mentioned approximately in March 2009, that he had been working for about 6
months on gathering information on Obama (not president at this time).
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PLEASE NOTE: I do not know how Sankey obtained Liberi’s Drivers
License and new SS card information. However, the above given information
by Sankey is false regarding Richards being her name, cheating businesses out of
close to $350-400 thousand dollars, filing bankruptcy 4 times, and she was not
arrested in 2004, on 4 counts of selling and reselling her house. I have no idea
what Sankey meant when he said that they had a right to Liberi’s SS# to post
because there is fraud. I would also like to know what Hale meant by his
statement that Liberi had recently taken out a loan. Did Hale and Sankey
illegally obtain my daughter’s credit reports and/or are they out applying for
credit in my daughter’s name and social security number? I reside in the State
of California where it is illegal for any company or individual to disclose, send
via email and/or post any third parties social security number, see California
Civil Code 1798.
17. On May 31st, 2009, Orly Taitz writes and posts on her website at
www.orlytaitzesq.com/blog1/?p=1843 a post entitled “I am trying to stay away from
Liberi-Berg issue, but I got more questions and here is more info.” In this posting
Taitz talks about Ostella. Blaming Ostella for contacting the private investigator,
Neil Sankey and providing Sankey with information that Liberi had a criminal record.
Taitz attached e-mails supposedly between Ostella and Sankey dated March 15th,
2009. Taitz said that Ostella changed her tune after the issues with pay-pal came out.
Taitz also claimed that Liberi had obtained a Pennsylvania Driver’s License which is
another attempt to obstruct justice. Taitz accuses Liberi of forging records for Berg.
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PLEASE NOTE: I have no idea what Taitz is talking about regarding my
daughter and the Pennsylvania driver’s license issue. I can assure you Liberi
does not and would not forge documents for Mr. Berg, Esq. or anyone else.
Furthermore, Mr. Berg would never ask her too. Perhaps the Taitz and
Lincoln “legal team” have this arrangement of forging documents, but not the
Liberi and Berg “legal team”.
18. On Monday, June 22nd, 2009 Orly Taitz writes and posts on her website at
www.orlytaitzesq.com/blog1/?p=2522 a post entitled “Ties to Everett, need help with
research”. Taitz said that she was threatened by two people from Washington State
and one in Canada. A few days later she had car trouble, and her husband had car
trouble. She called this “coincidences.” Taitz goes on stating the other coincidences
involved the following: President Obama’s mother went to University of Seattle,
Washington, so President Obama lived in Washington as a baby. Lisa Liberi was
born in Bellview, Washington. Lisa Liberi has lengthy criminal record of grand theft,
forgery of documents and forgery of official seal. Her name at birth was Lisa
Richardson, and her mother is Shirley Wadell (sic), father is Jack Richardson.
Obama, Liberi and Obama’s mother Stanley Ann Dunham – all have multiple social
security numbers. Liberi was convicted of forgery of documents and according to
experts; there are multiple signs of forgery in Obama’s documents. Stanley Ann
Dunham also went by the name Shirley Ann Dunham. A Dunham organization,
owned by Shirley Ann Dunham; one location was in Seattle, another in Bellview
WA. They dealt with insurances, lawyers, mortgages – you can get ss numbers from
all of these records.
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PLEASE NOTE: No coincidences here, just another way to post sensitive
information of Liberi, her mother’s maiden name and father due to the fact that
the judge didn’t shut Taitz and other Defendants down earlier. She continued to
post name, birth name, birth place, birth date, Social Security Number, mother’s
maiden name, father’s name, plus untrue statements because she could.
19. On June 27th, 2009, after the Court appearance in this matter, Orly Taitz
wrote and posted on her website at http://www.orlytaitzesq.com/blog1/?p=2585 a
post entitled “I am back from PA. Very Important.” Taitz had returned from a
Court appearance in Pennsylvania regarding Liberi and other Plaintiffs’ v. Orly Taitz
and other Defendants’. Orly Taitz refers to Liberi, et al v. Taitz, et al as a frivolous
law suit, and she is not worried, claiming the Judge ruled in favor of her (Taitz).
Taitz started in on Liberi again by posting page 115 and 116 of a transcript, which
was completely out of context. Taitz inferred that Liberi was trying to do harm to
her by disconnecting a “fumes emissions hose in her car”. Taitz also accused Liberi
of “killing” her sister, Cheryl (not sister’s name), who died 4 years ago. Orly Taitz
asked people in Santa Fe, New Mexico to take what she had posted (page 115 and
116 out of context) to the police and probation department, and she furnished names
and telephone numbers at the law enforcement agencies. See EXHIBIT “B”.
19. Losing a loved one is very hard and even harder when it is a child. This
will be our fourth year without my daughter, and the family is still grieving. My
daughter’s birthday, holidays, and anniversary of death are difficult to get through.
Orly Taitz has caused our pain to intensify. I was shocked when I read what Taitz
had sadistically written and maliciously posted June 27th, 2009, on the internet about
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Liberi murdering her sister. My heart began to race, and my stomach knotted up. I
have PSVT (para supra ventricular tachycardia), I took my medication to slow my
heart rate. Then the tears started to flow. After I gained some control of my
emotions, I contacted my daughter Lisa Liberi. Lisa also has heart problems, along
with long term Diabetes related illnesses. Both of my children had juvenile diabetes.
Lisa has been a diabetic and on insulin since she was 14 months old. She had open
heart surgery at age of 38 which tragically failed. She is on a host of medications, is
to rest, and avoid as much stress as possible.
20. On July 3rd, 2009 Orly Taitz wrote and posted on her blog at
http://www.orlytaitzesq.com/blog1/?p=2716 a response to an article entitled
"Smoking Gun" In Orly Taitz posted response Orly Taitz instructs her reader, Mr.
Fitzgerald at 8:49a.m., to send out Dossier #6 and Dossier #1. As you know, Dossier
#6 is mostly about Ostella stealing from Taitz, and publishing Liberi's name, address,
Social Security #, and date of birth. Taitz also posted altered documents. As of the
date of this Affidavit, Orly Taitz still has posted on her blog site at
http://www.orlytaitzesq.com/blog1/?p=8 her Dossier #6 which contains my daughter,
Liberi’s full social security number, date of birth, and other personal identifying
information for anyone to access.
21. Orly Taitz thinks that the U.S. Constitution applies only to her rights and
freedom. She has deliberately invaded the privacy of other lives for the sole purpose
to cause pain and harm. She has fabricated documents, plagiarized, and spread lies to
ruin lives for the purpose of achieving world wide attention for herself, and more
donations. This woman is greedy and unscrupulous. She is definitely paranoid with
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EXHIBIT “A”
20

Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691
Copyright 2009
« Key witness in presidential passport case fatally shot

from Field McConnell »
Every day I get such evidence of missing or misdirected funds

Every day I get such receipts, showing that my former web master Lisa Ostella (posts
under name Calpernia) has redirected donations to herself, to her e-mail address.
Currently, as this was uncovered, she created new web sites Defend our freedoms .org,
.net and continues the scheme by making those sites similar to my old ones and using
the foundation name to steal more donations. She created a visa donation site with her
e-mail account Go Excell Global, underneath she posted a paypal button showing my
foundation Defend Our Freedoms (without my consent) and my e-mail address (without
my consent) to look as if she is still connected to me and my foundation, even though all
ties with her were severed a couple of weeks ago, when I found out about this scheme
and I closed the Pay Pal account completely. Any person, whose donations were stolen
by Lisa Ostella aka Lisa Current aka Calpernia is asked to report this to his local police
or sheriff’s department. As I found out, she appears to be connected to Lisa Liberi, who
is still working for attorney Phillip Berg. Please see my dossier #6, Lisa Liberi aka Lisa
Richardson aka Lisa Courvelle has a long criminal record, that includes grand theft,
forgery of documents, forgery of seal, falsification of police reports and credit
statements, where financial institutions were defrauded out of thousands of dollars. She
claims to be a different Lisa Liberi, living in PA, however she lives in NM and her
probation officers are Joanne Martinez 505-827-8627 and Dawn Helling (not sure about
spelling) 505-476-2359.
Hi Dr. Taitz,
Just to let you know that I donated to your cause on 1/19/09 thru PAYPAL. I copied the
transaction that was provided to me by PAYPAL, please see the following:
Dear Joseph Iadarola,
This email confirms that you have donated $25.00 USD to Defend Our Freedoms (lisaostella@hotmail.com) using PayPal.
Donation Details
Confirmation number: 0MT49606HT922673B
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Donation amount: $25.00 USD
Total: $25.00 USD
Purpose: For being a great American!
Contributor: Joseph Iadarola
Recipient information
Donations coordinator: Defend Our Freedoms

Contact email: lisaostella@hotmail.com
Contact Phone Number: 866-954-5625
This entry was posted on Sunday, April 19th, 2009 at 8:32 am and is filed under Other Criminal or
Suspicious Activities. You can follow any responses to this entry through the RSS 2.0 feed. Both comments
and pings are currently closed.
One Response to “Every day I get such evidence of missing or

misdirected funds”
1. wow! says:
April 21, 2009 at 4:35 pm
Why not just file a lawsuit against this Lisa Ostella aka Lisa Current aka Lisa Liberi aka Lisa Richardson aka
Lisa Courvelle aka Lisa Calpernia? It seems she has done this case irreparable damage in regards to trust.
How can anyone trust who anyone or any site is in this case?
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EXHIBIT “B”
23

Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691
Copyright 2009
« Unfortunately I have to spend more time on Berg’s latest motion, I have to provide a
response
Next Post »
I am back from PA. Very Important.

I appreciate everybody calling and e-mailing and texting to make sure I am OK. I am OK….I had
to go to PA to appear at the hearing in the garbage law suit filed by Philip Berg. My wireless
connection didn’t work there, I couldn’t blog.
I returned yesterday at 12:30 and and was doing a radio show in VA with Chuck Chrismayer.
You can reach him at 800-754-1822 or 804-677-2783, he will have archives of the show.
I had to work from 1-5:30 and later wanted to have dinner and spend some time with my family.
In regards to Berg things are going well. Judge denied all of his motions for default judgment
against me and clerical default was lifted, he gave me a pro hac vice to represent my foundation,
denied all of Berg’s motions for injunction against me and, what is most important he ordered
Berg to show cause, why his case should not be dismissed due to lack of jurisdiction. For those of
you, who are not attorneys, it is a very good sign that the judge is very inclined to dismiss Berg’s
case due to lack of jurisdiction. I would like to explain that if the case is filed out of state, the first
thing that is being reviewed, is jurisdiction. It doesn’t mean that the case has any merit aside from
jurisdiction, it means that this court cannot hear it. I believe Berg filed it in PA to simply cause
me to waste time and money, going to Philly. At any rate, I am not concerned about this frivolous
law suit, I am though concerned about something else.
On the plane to Philly I read hundreds of pages of transcripts in criminal case hearings of Liberi.
Keep in mind that recently I had threats “to shoot me and burn my body for the world to see”.
Later a clamp was missing and fumes emissions hose was disconnected in my car, that lead to the
fumes accumulating around the engine, which is extremely dangerous.
As I read August 4, 2004 transcript, I found a testimony of detective Liebreich. He testified in

regards to recording of phone calls Lisa Liberi made from jail to her husband Brent Liberi. She
was telling him that she was upset with her sister Cheryl Richardson. Cheryl cooperated with the
police and told them about 19 prior criminal investigations of Liberi. Liberi told Brent (see copies
24
of the transcripts attached) that she will get her sister in jail and will spread the word that she is a
rat. She was telling Brent “do you know what they do in prison to rats?”
At that time DA James Secord asked the detective to explain. The detective stated that a contract
will be issued on such person, a green light and such person will be attacked and/ or killed. He
mentioned that 5 people were killed last year alone. I got concerned, if this woman could plan
a hit, a contract on her own sister, it would not be inconceivable that she would plan a hit on an
attorney and her family, if this attorney outed her. I kept reading and found out that indeed less
then a year later her sister was dead. Official cause of death, from what I understand, is drug
overdose. However, drug overdose can be self inflicted or inflicted by others.
At this time I would like to know if there are any pathologists among the readers of this blog?
Can someone go to the police department and probation department in Santa Fe NM and show
them all this info.
According to detective Teresa Standiford from Orange County economic crimes unit, my report
and the whole file was transferred to Santa Fe, as Lisa Liberi lives there. I tried to find out the
status, but it is very hard to reach anybody in the police department there. The phone number of
detective Teresa Standford in CA 714-647-7486, 714-647-7038. Case # 09-068339.
Liberi’s prosecuting DA in Ca is James Secord 909-387-8309
In Santa Fe I was given a number for detective Martin Lopez 505-955-5010, General number for
the Santa Fe police is 505-955-5038. Investigations unit- 505-955-5038
The supervisor of her probation department is Joan Martinez 505-476-2359 Regional probation
officer is Rose Bobchack 505-476-2363.
After the hearing on Thursday I talked to Phil Berg and I have shown him the transcripts of
Liberi’s prior hearings. I put him on notice in regards to her dangerous propensities and let him
know that if he continues with this law suits and continues denying, what is clearly a public
record, he endangers me and my whole family. If something happens and Liberi is involved, he
will be held accountable as an
accomplice.
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This entry was posted on Saturday, June 27th, 2009 at 3:52 pm and is filed under Events, Uncategorized.
You can follow any responses to this entry through the RSS 2.0 feed. Both comments and pings are
currently closed.
5 Responses to “I am back from PA. Very Important.”
1. sillyhaha says:
June 27, 2009 at 5:57 pm
I am thrilled that all went well for you and the other defendants on Thur! Seems like the Judge feels that this
case is a complete waste of time and unfair to all the defendants. It is a frivolous case.
Interesting info on Lisa Liberi. Sounds like she may be looking at more legal problems as a result of going
after you and Linda Starr. Serves her right…and I hope Berg gets sanctioned for this nonsense.
Well done, Dr. Taitz!!!
2. sillyhaha says:
June 27, 2009 at 6:22 pm
Dr. Taitz,
Please be careful. This Lisa Liberi woman is dangerous. Thank God she doesn’t live near you.
Somewhere someone talked about escorting you to the courthouse on the 13th…he would be carrying a gun.
This concerns me. He won’t be allowed in with the gun. And, I wouldn’t want anything to damage your
reputation. I personally would leave all guns at home. Peaceful protesters can assist you to and from the
building. After the von Brunn incident, I would hate to see further linking of guns/violence and the
citizenship issue.
3. tainler says:
June 27, 2009 at 8:20 pm
I am VERY concerned for Orly and her family. Lisa liberi doesnt have to live close to Orly to attempt
anything. If she has connections to “get rid of someone” then all she needs is a phone or computer. Is there a
way to investigate her computer or tap her phone lines that would be legal? A very frightening situation. I am
starting to wonder if Lisa L. has any deep ties with obama and his clan. I’m sure she does. Anyway,
remember AirFrance flight 447 that just crashed in the ocean? I read there there were people of “status” that
maybe were or could expose anything government wise and suspiciously enough the plane went down. Orly
should not announce any travel plans, flight information and should not leave her car at the airport. Is there
any way that police could be notified ahead of time and have the area checked out at the location of the
hearing on the 13th…. looking for snipers, a “so-called” drunk driver that could run up on a sidewalk and kill
anyone with their car and make it look like an accident? I personally feel every act of protection should be
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high priority for Orly and her family’s safety. They know she will be gone on this trip…will her house,
family, personal property be safe? Is it possible to have a neighborhood watch while she is gone or have the
police do frequent checks at her house while not there? I know Orly is smart but she probably is the most
hated person by Obama and his corrupt thugs. I just want Orly and her family to be safe. The electrical wires
to her house should be checked too as well as air conditioning units. Anything can be done to those things to
make them malfunction and overheat. Not sure if this should be posted as long as Orly reads it.
4. Granny Watching says:
June 27, 2009 at 8:30 pm
http://sfbay.craigslist.org/eby/rnr/1236944772.html claims to have the document number on the BC from Fact

check. LOL
5. live oak says:
June 27, 2009 at 10:03 pm
It’s really good to have you back Orly! I’m so sorry that you’ve had to spend time away from your family
with this mess that Berg has caused you, and I hope the good people that did donate to Berg can get their
money back. Mr. Berg should have to pay all your court costs and expenses as well. What he has done to you
and to the profession is beyond despicable!
Please be careful Orly. We all love you and have you in our prayers. Have a peaceful and relaxing weekend
with your family. No worries. Monday is a big day. I pray that this will be over soon while America is still
recognizable.
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EXHIBIT “Z”
Law Offices of:
PHILIP J. BERG, ESQUIRE
Lafayette Hill, PA 19444-2531 Attorney for: Plaintiffs
(610) 825-3134

LISA LIBERI, et al, :

Plaintiffs, :
vs. :
: Case No.: 09-cv-01898-ECR
:
:
:
ORLY TAITZ, et al, : Assigned to Honorable Eduardo C. Robreno
Defendants. :
:
VERIFICATION OF LISA LIBERI
I, Lisa Liberi am over the age of eighteen (18); am a Plaintiff in the within action and
verify that the statements made in the foregoing are true and correct to the best of my knowledge,
information and belief. The undersigned understands that the statements therein are made subject
to the penalties of 18 Pa. C.S. Section 4904 and the laws of the United States relating to
unsworn falsification to authorities. I have personal knowledge of the facts herein and if called
to do so, I could and would competently testify under oath.
I, Lisa Liberi, declare as follows:
1. I am filing this verification in lieu of an Affidavit as for safety measures, I will not
place my address or have notarized, until there is some form of protection against the
Defendants’ behaviors on a document which will be publicized. Due to the fact Ms. Taitz,
Linda Belcher and Neil Sankey, etc. have placed private personal information, thanks to Mr.
Sankey and Ms. Taitz, on the internet including but not limited to my name, date of birth,
social security number, mother’s maiden name, where I was born, etc. As I do not need to
publicize where I actually reside.
2. I have been providing paralegal services to Mr. Philip J. Berg and his Law Firm since
the end of 2006, early 2007.
3. I do not fundraise or have anything to do with any type of donations taken in by Mr.
Berg or his website, obamacrimes.com; I do not moderate or Administrate Mr. Berg’s
website, nor am I Agent 88 on the Blogging Board.
4. In or about November 2008, Linda had called Mr. Berg and offered to donate her
time to work for Mr. Berg and Administrate and moderate his blog. Mr. Berg agreed.
5. Also in or about November 2008, Orly Taitz, a Defendant herein began calling the
office. Ms. Taitz was seeking another attorney to work with her and needed paralegal
assistance. Both Mr. Berg and I refused to work with Ms. Taitz as we did not agree with her
ethics.
6. In or about January 2009, I received numerous phone calls stating Orly Taitz had
threatened Mr. Berg and me. I was told Orly stated she was going to bring Phil Berg down
and to accomplish this she was going to destroy me and get rid of me. I informed Mr. Berg
and we agreed it was best just to ignore Ms. Taitz’s threats. See, this was around the same
time Ms. Taitz was threatening the U.S. Supreme Court Justices to have them charged with
Treason, making false allegations against U.S. Supreme Court Clerk, Danny Bickell and
several other individuals.
7. In or about March 2009 Ms. Taitz began putting out statements that I had been
convicted of amongst other things, identity theft, falsifying police reports, manipulating
police reports and credit reports, that I had a criminal record going back to the 1990’s, etc.
Again, I felt it best just to ignore Ms. Taitz and not feed into her and her false allegations
and/or give her any type of attention.
8. Shortly thereafter, Ms. Taitz blatantly and falsely accused my husband of being on
parole and having accounts set up on Mr. Berg’s website deterring donations from Mr.
Berg’s website. My husband, to this date, has never been on Mr. Berg’s website much less
diverting funds from Mr. Berg or anyone. Mr. Berg went on radio shows and publicly
announced that no one was stealing money from him.
9. Also during this time, Ms. Belcher began sending mass emailing to our entire
database which she took from our blog and website stating I was a liar, I couldn’t be trusted,
I deleted Mr. Berg’s emails, I deleted Mr. Berg’s calls that I didn’t want him to hear, Mr.
Berg did not have integrity, Ms. Belcher was falsely accusing me of sending nasty emails out
about her and posting nasty comments about her. Ms. Belcher even sent an unverified untrue
article from Mortgage Fraud Blog which had the name Lisa Liberi, telling everyone it was
me. Blog All the time knowing her statements were lies. Ms. Belcher is well aware I do not
post on blogs and in fact did not even know what a blog was when Mr. Berg allowed one to
be set up on his website. I did not know at this time that Linda Belcher had teamed up with
Orly Taitz. I later learned that Linda joined forces with Orly Taitz in or about January 2009.
10. On or about April 17, 2009, I received an urgent call from Plaintiff, Evelyn Adams
informing me that Orly Taitz had submitted a document called Dossier #6 which contained
my full social security number, date of birth and other personal identifying information.
11. When I returned home, I had received several emails from individuals with Ms.
Taitz Dossier #6 attached. I could not believe what I was reading, and Ms. Taitz, a licensed
attorney sent this to over 140,000 businesses and individuals by her own admissions. Ms.
Taitz sent this Dossier #6 to media, websites asking them to post it, individuals, and even
internationally.
12. This was extremely concerning to me. Ms. Taitz and/or Neil Sankey had never had
any type of authorization to pull my personal identifying information, including my social
security number, nor did they have any type of a permissible purpose and I was unaware until
Ms. Taitz dossier #6 was emailed to me and published all over the internet. By Ms. Taitz
own admission, she sent this document to over one hundred and forty thousand [140,000]
individuals and businesses including internationally.
13. Thereafter Orly Taitz was posting things on her blog or website about me on average
once every three (3) days. I was now being accused of diverting and stealing funds from Ms.
Orly Taitz, which was ludicrous as at that time I had never been on Ms. Taitz website, any of
them or ever had anything to do with Orly Taitz.
14. I began watching her www.orlytaitzesq.com blog forum daily. At this time, Mr. Berg
decided it was time to file suit and seek injunctive relief immediately. Our suit was filed
May 4, 2009. Ms. Taitz continues to state I am a resident of California. I am NOT a resident
of California. In one breath Ms. Taitz claims I live in one state and then in the next breath
she claims I live in another. Again, Ms. Taitz is an attorney licensed to practice laws, she
knows what she is doing is extremely illegal. Furthermore, in the State of California for
every person Ms. Taitz sent my social security number, name, address, date of birth,
mother’s maiden name and where I was born too, Ms. Taitz, her company Defend our
Freedoms Foundations, Inc.; Neil Sankey; Sankey Investigations, Inc; and the Sankey Firm,
Inc. is liable separately pursuant to California Civil Code 1798 et sequitur for a $3,000 civil
penalty to each and every person the information went to.
15. Ms. Taitz then posted on her website that she had filed a police report against me and
Lisa Ostella. Ms. Taitz also stated that Lisa Ostella and I were the same person, the entire
time knowing her statements were false.
16. I contacted the Orange County Sheriff’s Department and spoke to Investigator Lora
Ashley. I learned Ms. Taitz filed a police report against me stating I was also Lisa Ostella
and I had hacked her website and paypal account and had stolen money from her (Ms. Taitz).
I also learned that Ms. Taitz was falsely stating to law enforcement agencies that she and Mr.
Berg worked together and fund raised together, ALL of which were complete lies and
falsified stories by Ms. Taitz. Ms. Taitz knew this information to be false and did it
maliciously. Lora Ashley did tell me that they did not find any merit to the allegations
presented by Ms. Taitz.
17. My next call was to Nathan Lee, the FBI agent in Los Angeles, California whom took
a report from Ms. Taitz. This time I had Lisa Ostella on the phone with me. Ms. Ostella and
I were pretty much told the same that I was told by Lora Ashley. Mr. Lee stated he never
said he was opening an investigation and that Ms. Taitz jumped the gun and placed his phone
number on the internet for everyone to call. Mr. Lee told Lisa Ostella and me that they did
not find any merit in Ms. Taitz allegations.
18. After Ms. Taitz issued the Dossier #6 on April 17, 2009, she posted it on her website
and did more email blasts on April 22, 2009, she sent them to every law enforcement agency
you can imagine, she handed it out to individuals and asked them to distribute them, etc. My
home phone and cell phone than began receiving non-stop calls from voice over I.P. internet
phone services. If I attempted to call the number back, it would state it was disconnected. I
have reported all of the above to the FBI, my local authorities, the Orange County Sheriff’s
Department and the California Attorney General, Division of Law Enforcement and Special
Intelligence and provided copies of everything posted about me by Ms. Taitz on her website.
19. At NO time did I ever have knowledge of this “investigation” Ms. Taitz claims she
began on me; I have NEVER given authorization to anyone including Ms. Taitz or Mr. Neil
Sankey to ever obtain my social security number; and Ms. Taitz and Mr. Sankey NEVER
had any permissible purpose to dig into my private affairs. I always believed your personal
identifying information, social security number, mother’s maiden name, place of birth, date
of birth were maintained confidential. I expected my private information would remain private.
20. On April 14, 2009, Ms. Taitz went on a radio program call the Dame Truth. Ms.
Taitz spent a good majority of the time on this radio appearance, slandering and gossiping
about me, see EXHIBIT “1”.
21. Ms. Taitz in numerous of her mass emailing and her postings on her web blog,
amongst other things, has called for people in the area she believes I reside; has quietly
incited violence against myself and the other Plaintiffs’; has filed false law enforcement
reports against Lisa Ostella and myself; called for people in the area Lisa Ostella resides; has
called for people to look into mine and Evelyn Adams husbands, associations, business
associates, everywhere we have lived, our voting records, etc; and has stated Ms. Ostella’s
children were going to be kidnapped by professionals. I reported Ms. Taitz crimes to my
local law enforcement authorities as well as the FBI. Both entities informed me I need to
obtain an immediate Injunction or Restraining Order.

22. On May 28, 2009, Defendant, Neil Sankey was on Ed Hale’s radio Show with all
kinds of falsified stories about me, Evelyn Adams, Lisa Ostella and Mr. Berg. The
concerning part was Neil Sankey gave additional documents to Mr. Hale which contained my
social security number, date of birth and other personal identifying information. Ed Hale
stated Neil Sankey gave them to him and Neil Sankey agreed that he gave them to Mr. Hale.
Mr. Hale then stated “Lisa Liberi just took out a loan”. Being I had just taken out a loan in
or about March 2009 for my child’s college, the only way Mr. Hale and Mr. Sankey would
have know this is if they illegally accessed my credit reports or obtained a loan in my name
fraudulently.
23. Thereafter, on June 22, 2009 Ms. Taitz posted my mother’s maiden name and where I
was born. Ms. Taitz even went as far as implying that Stanley Ann Dunham was in the city
and state where I was born and thus, I must have something to do with the Obama scandal. If
Ms. Taitz would have stopped long enough to look at dates, I was not even born yet, which
Ms. Taitz was aware of as she illegally obtained my personal identifying information and
posted it all of my personal identifying information on the internet, see EXHIBIT “2”.
24. June 25, 2009, there was a hearing on this case, including a Motion for an Emergency
Injunction or Restraining Order which was originally filed May 4, 2009 and reviewed in June
2009. Although I was not present, it is my understanding the Court gave very detailed
warnings about the publication of my social security number and other personal identifying
information. The Court’s Order of June 25, 2009 also has a foot note at the bottom
reminding Defendants’ they were to conduct themselves as discussed in your Courtroom.
Unfortunately, Defendant’s Orly Taitz, Edgar Hale and Lind Sue Belcher failed to listen to
the Court and/or respect the Court’s rulings. The Court also denied Plaintiffs’ Motion for an
emergency injunction or restraining order and denied me an Order to obtain a new social
security number.
25. On June 25, 2009, Edgar Hale had his radio show on Plains Radio Network, Inc. Mr.
Hale’s guest was Linda Sue Belcher a/k/a Linda Starr. The purpose of Mr. Hale’s show was
so he and Linda could falsify information pertaining to this Court’s rulings on June 25, 2009
and to threaten and intimidate any witnesses or potential witnesses of the Plaintiffs’.
26. I listened to this awful show. Mr. Hale stated your honor denied the Plaintiffs’
Injunction because you stated Plains Radio had a first Amendment right to say the things
they had been saying. Linda Belcher then stated that “we” meaning she and all the
Defendants’ would have to give their true identities if they submit an affidavit and then
“they” meaning all the Defendants’ would know who each person was and where they were
located. Edgar Hale then stated “If you do an affidavit, we will know your name and where
you live and I tell you what, we will come after you with a vengeance”. After all the
threatening Linda Belcher continued saying I resided in New Mexico, that I had to be
licensed in the State of New Mexico to be a paralegal, I’m practicing law without a license,
even though I am working under Phil Berg, an Attorney, and continued slandering Mr. Berg
and me.
27. On June 27, 2009, I received a call from our webmaster and another Plaintiff in this
action. I was instructed to look at Ms. Taitz website, which I did. Ms. Taitz posted
information about my deceased sister claiming I placed a “hit” or “contract” on my sister and
a year later she was dead. Ms. Taitz further inferred I had placed a “hit” or “contract” on her
and her family. Ms. Taitz was calling for a Pathologist and individuals to take her statements
to the New Mexico Police Department, to call a specific Detective in the Santa Fe Police
Department, call a prosecuting District Attorney in California; call the Santa Fe Probation
Office and gave the numbers. Ms. Taitz even placed with this post two pages of what appear
to be from a court proceeding transcript, in order to manipulate the reader to believe a “hit”
or “contract” was placed on my sister. Just to let this court know, my sister’s name is NOT
Cheryl. Just like my middle name is NOT Renee.
28. All through-out this time, Ms. Taitz and Mr. Sankey were also publicly accusing me
of being convicted of amongst other things, identity theft, manipulating police reports,
manipulating credit reports, real estate fraud by selling my house to several different people,
I was paying twelve [$12,000] dollars in restitution then it changed to twenty-one thousand
[$21,000] dollars, knowing it was untrue. Ms. Taitz and Mr. Sankey made these statements
and publicized this information maliciously and with malice to carry out Ms. Taitz threats,
which as of today’s date, August 15, 2009, Linda S. Belcher continues on Ed Hale’s radio
show chat page. In fact, Ms. Belcher cannot state more than two (2) sentences without
slandering, libeling and placing Mr. Berg and myself in the public’s false light, she just can’t
refrain from talking about us.
29. Unfortunately though, my sister did pass-away of a self inflicted methamphetamine
over-dose four years ago July, 2005. My sister had been “partying” with some friends and
apparently took too much in. According to the Coroner who performed the autopsy, when an
individual over-doses from shooting up methamphetamines, as my sister did, it stops their
heart immediately. The death of my sister was extremely hard on my now 80 year old father,
my retired mother and step mother as well as myself. My entire family had kept my sister’s
death confidential out of respect for her.

30. My entire family suffers from serious heart problems. My mother found this post on
Orly Taitz website or blog area and became extremely upset. My mother has been having
some difficulties medically since Ms. Taitz postings. These malicious, false, cruel and ugly
statements of Ms. Taitz coupled with all her false accusations against me have had series
mental and medical effects on my entire family. My entire family is in fear of me being
harmed as a result of Ms. Taitz illegal and tortuous behaviors.
31. On July 3, 2009, Ms. Taitz responded to an email she had posted on her front page
and informed the person and all followers of hers to send out Dossier #6 and #1 with
absolutely NO regard for this Court’s statements or rulings pertaining to my social security
number and other personal identifying information. Dossier #6 is the document which
contains my full social security number, date of birth and other personal identifying
information.
32. On or about July 9, 2009 I received a call from our webmaster and another Plaintiff in
this action. I was informed that Ms. Taitz has now set her website up so Dossier #6, which is
still on Ms. Taitz website at http://www.orlytaitzesq.com/blog1/?p=8 and it is set to refresh
every three (3) hours. What this means was explained to me that Dossier #6 updates every
three (3) hours and is resent to all websites through the RSS Feed (an Internet feed); and
refreshed and resent to all the search engines, including but not limited to Yahoo, Google,
AOL, MSN, etc. It is just like publishing it for the first time every three (3) hours, which is
clearly re-distribution. This explains when I do a “google” search for “dossier #6” it always
comes up first showing the web address to Orly Taitz website/blog located at
www.orlytaitzesq.com.
33. On July 16, 2009 Mr. Berg sought leave of Court to file for another emergency
injunction or restraining order on behalf of the Plaintiffs for the republishing of my social
security number and the issues pertaining to the threatening and intimidating our witnesses.
The Court filed Plaintiffs’ Emergency Motion on July 27, 2009 and set dates that the
Defendants’ were to respond by August 3, 2009 and set a hearing for August 7, 2009.
34. On or about July 27, 2009, Ms. Taitz set up a new website on the internet. On the
front page of her website under “supporting documents” she again posted dossier #6
containing my full social security number, date of birth and other personal identifying
information. Again, after the Court’s warnings and Orders. Ms. Taitz continues to repeatedly
re-post and re-send out my social security number and other personal identifying information
in her dossier #6.
35. This Dossier #6 with my full social security number, date of birth and other personal
identifying information is all over the internet and still present on Ms. Taitz website at
http://orlytaitzesq.com/dossier-006.htm. As of 2:21 a.m. on August 15, 2009, this dossier #6
was still posted on Ms. Taitz website with my full social security number and other personal
identifying information. I did a screen capture with the clock next to the posting on her
website; please see EXHIBIT “3”.
36. On or about August 5, 2009, Mr. Hale had a radio show on Plains Radio wherein
Linda Belcher a/k/a Linda Starr was on and in the chat area. Linda Belcher stated that I sent
her an email in December 2008 with my Address. I did not send any emails to Ms. Belcher
with my address or a New Mexico address, as Ms. Belcher claims. Ms. Belcher stated the
email was too old that she had to forward it to herself because it was too old to print. Ms.
Belcher is on AOL as I am. Ms. Belcher stated that AOL does not have header information
which is completely untrue and proof of which was submitted to the Court. Linda Belcher
stated I sent her this email from Llisaliberi, which is not a valid email address. Llisaliberi is
my AOL screen name but not my email address. My AOL email address is
Llisaliberi@aol.com. I have been on AOL for approximately seven (7) years and am very
familiar with the way the email works. Emails will store for thirty [30] days and then expire.
Once the email has expired, you cannot forward the email; you can only view it and print it.
In addition, I provided screen shots of the header information on emails sent and received
from my AOL box. All emails have header information. As provided to the Court were
pictures of my email box showing I never sent an email to Ms. Belcher on the date she stated
and I have every email sent to and received from Ms. Belcher. I even verified this
information with AOL Tech support, see EXHIBIT “4”. This December email was
provided to the Court as evidence by Mr. Hale on behalf of Ms. Belcher with an affidavit by
Ms. Belcher, knowing she was perjuring herself and had illegally manufactured evidence.
This email is a complete MANUFACTURED document by Ms. Belcher. At no time, has
anyone ever had my authorization to alter or manufacture emails using my screen name from
AOL or my other email account. This was submitted by Ms. Belcher through Mr. Hale to
defraud the Court.
37. It should be noted, just as Ms. Belcher has done with attempting to defraud the Court
and committing perjury, Ms. Taitz has also blatantly lied to the Court in her Affidavits, in
particular August 3, 2009. In addition, Ms. Taitz has claimed to be the media, which she is
NOT and has given numerous different statements, reasons and excuses for her illegal
behaviors. However, to date she and Ms. Belcher have NOT stopped.
38. August 7, 2009, the hearing took place, of which I was present. I testified that I was
in a “safe at home” program with a confidential address and and my social security number
was changed and re-issued by the Social Security Administration to protect me as we are the
victims of serious domestic violence. I testified Ms. Taitz has now blown all that. I testified
I was in fear for my family and myself as a result of the Defendants, in particular Ms. Taitz,
Mr. Sankey, Ms. Belcher and the Hale Defendants behaviors. I testified I was concerned
with Ms. Taitz followers as Ms. Taitz has been quietly inciting violence towards me and the
rest of the Plaintiffs’. I testified despite the warnings and Orders issued in the Court, Ms.
Taitz has continued and repeated her illegal, harassing and dangerous actions. Despite the
testimony put on, the Court denied our Motion for an emergency Injunction or Restraining
Order.
39. During the Court hearing a “supposed” chat log was introduced into evidence by
Edgar Hale with an Affidavit from Linda Belcher. I never saw the “supposed” chat log until
I returned home that evening. When I returned home it was emailed to me from a friend.
Ms. Belcher posted this “supposed” chat on her website located at
www.obamacitizenshipdebate.org. This is not a valid chat log. First, she emailed to herself
from herself on August 4, 2009. I have not spoken with or chatted with Linda Belcher since
on or before March 5, 2009 and the last email I sent Ms. Belcher was on March 6, 2009.
Second, she has my screen name showing as “Lisa”, which is NOT my screen name.
Attached to the emergency motion filed herein is a screen shot of several instant message
boxes on AOL “chat sessions” showing my screen name which is Llisaliberi. This too is
another MANUFACTURED document by Linda Belcher. When I went to Linda Belcher’s
website I also found a “supposed” email from me to Philip J. Berg, Esquire. This is yet
another MANUFACTURED document by Linda Belcher. This email shows the time as
central time, which has never been my time zone on any of my email. However, Linda
Belcher resides in Texas and central time is her time zone. In addition, the manufactured
email shows Llisaliberi sent the email to philjberg@gmail.com. Again Llisaliberi is an
invalid email address. Also filed with the within emergency motion as an exhibit is a screen
capture of Mr. Berg’s email box showing on January 3, 2009 he never received any emails
from me. Also are copies of emails sent to and from Linda Belcher to me which shows the
full email addresses as it should. Ms. Belcher manufactured and forged emails and chats
from me which were done without my knowledge and she NEVER had any authorization to
use my screen name on AOL, my name or any of my personal information.
40. Ms. Taitz has continued her stories claiming I have had several social security
numbers. This is untrue. My social security was changed and reissued on ONE occasion
due to the safe at home program. Now that Ms. Taitz has published all of my personal
identifying information, including but not limited to my social security number, date of birth,
mother’s maiden name, place of birth, etc. I will now have to obtain a Court order for the
changing and reissuing of my social security number again. Ms. Taitz has also falsely stated
as has Mr. Sankey and Linda Belcher that I filed bankruptcy four (4) times. This is
completely untrue also.
41. After doing a lexis search, which is filed with the lower Court, I discovered a woman
in Houston, Texas (Harris County) named Sholanda Nash is now using my personal
identifying information, my social security number, which is clearly the result of Ms. Taitz
putting my social security number, date of birth, and other personal identifying information
on the internet.
42. Ms. Taitz explanation to this Court for putting out all my personal identifying
information was the public had a right to know, I was working on the Obama cases, which is
complete hogwash. Ms. Taitz has recently employed Charles Lincoln III, who has been
disbarred from three (3) states; has forged and falsified a Federal Court Clerk’s receipt; paid
off witnesses not to produce the forged receipts and not appear for the hearing; was federally
convicted of using a falsified social security number to open a checking account; was
convicted twice of federal contempt; has been to seven (7) prisons by his own admissions;
has filed three bankruptcies this year within 3 months times; has filed unlimited civil suits
wherein he is the Plaintiff, however, Ms. Taitz fails to disclose any of this information.
43. It is apparent to me that Ms. Taitz motive is to carry out her threats to destroy me to
take Philip J. Berg, Esquire down. All of Ms. Taitz actions have been illegal, malicious,
cruel, done with hate and malice with the intent to harm me and be destroy me. Each time
Ms. Taitz gets away with her illegal actions, she becomes bolder, just as proven by her
actions after appearing before your Honor.
44. Ms. Taitz, Ms. Belcher and the rest of the Defendants’ have, amongst other things,
ruined my reputation; they have caused my phones to ring non-stop; have caused Mr. Berg to
receive emails questioning if he received their donations or if I took them; have caused me to
be the victim of identity theft; have invaded every part of my private and personal life; have
placed my family and I in danger; have had me harassed; have placed me in a false light
before the publics eye; and have disclosed my social security number, date of birth, mother’s
maiden name, my place of birth, which is extremely serious. Identity theft is rampant in the
United States and the fact Ms. Taitz sent my private personal identifying information
internationally she has set me up for illegal aliens to use my information. It can take years, if
it can be done at all, to undue the damage these Defendants have done and continue to do to
me. Moreover, these Defendants’ actions have humiliated me, caused me great
embarrassment and have caused serious emotional distress for myself and family.
45. The Defendants’ actions were cruel, malicious, done with malice, done with hatred
and intent to harm and their actions would shock the consciences of and be highly offensive
to a reasonable person. Without this injunction or restraining order being issued, I have no
other legal remedy at law.
46. I have a right to my privacy; I have a right not to be placed in a false light before the
public; I have a right to be secure from the publication of embarrassing facts and I have a
right to be left alone.
47. For the above aforementioned reasons, I respectfully request this Court to issue an
immediate injunction or restraining Order and also issue an Order so I can obtain a new
social security number in attempts to try and protect myself from the damage Ms. Taitz, Mr.
Sankey, Ms. Belcher and the other Defendant’s have caused. These Defendants’ are not
going to stop these illegal, harassing and improper behaviors, they haven’t to date. Ms. Taitz
is NOT going to respect this Court, as she has already proven that and she will maliciously
continue sending out my social security number, date of birth and other personal identifying
information until she learns she has completely destroyed me.
I declare under the penalty of Perjury of the laws of the United States and subject to the
penalties of 18 Pa. C.S. Section 4904 that the foregoing is true and correct. Executed this
15th day of August, 2009.
____________________________
LISA LIBERI, Plaintiff
EXHIBIT “1”
The Dame Truth 4/14/2009 Guest Dr. Orly Taitz Esq.
Summary:
An April 14, 2009 broadcast that contained Orly Taitz stating that she was acting as an officer of
the court in reporting me to the FBI, Agent Nathan Lee, out of Orange County California. Orly
Taitz also stated in the same interview that she had private investigator, Neil Sankey, also a
defendant in this case, contact FBI Agent Nathan Lee as well as the San Bernardino Police
Department and the District Attorney in regards to the investigation she had initiated on Lisa
Liberi of Phil Berg’s Law Firm.
Time Counter Starting at: 20:27
Hostess:
I think we have a caller now, hello are you there?
Dr. Orly:
Yes, this is Orly, your guest.
Hostess:
Hello Orly.
Dr. Orly:
I tried to call earlier and you couldn't hear me.
Hostess:
Oh, you know blogtalk radio does have it's ups and downs. I'm so glad your here.
Dr. Orly:
yeah ::giggles::
Hostess:
You've had a very hectic couple of months to put it mildly.
Dr. Orly:
::laughs::
The Dame Truth 4/14/2009 Guest Dr. Orly Taitz - page 2
Hostess:
I'm so glad that you came to spend some time with us because it's a great honor in view of what
you have going on. And I'm not sure what to ask you about first I know that um, how about I
give you a choice and you tell me what you would like to talk about first. First of all, I know you
have had some website issues would you like to address that or do you want to move on from
there?.
Dr. Orly:
Yes, I would like to address that. I had problems whereby several of my volunteers and donors
have written to me when they try to send donations to my foundation which is Defend Our
Freedoms Foundation which is registered under owner of the foundation, they had problems
giving donations, it didn't work. Matter of fact I asked my webmaster, Lisa Ostella what
happens she said it looks like everything is fine. And one gentleman, his name is Roger
Beckham, that was actually, thank God he was quite persistent, because I have something now
about 34,000 emails, I get a lot of emails, and I kept missing his emails and he kept emailing me
several times. Finally I saw his email. And I inquired what happened and he stated there was a
problem. He is unable to give me donations. I called PayPal and they didn't know what was the
problem. I called him again and asked what email address he used when he gave me the email
address I saw it was a wrong email address. I had several other donors report the same thing.
First of all I'm an attorney, I'm and officer of the court I have to report these kind of things.
Hostess:
Absolutely
Dr. Orly:
Additionally, it's a foundation, a nonprofit foundation, I can't have those kind of things
happening because it gives a bad name to foundation.
Hostess:
Absolutely
Dr. Orly:
I've reported this to FBI. And uh, my webmaster Lisa Ostella stated that this is something that
would give her, as a webmaster a problem, a bad name. And I said no, I don't think so if
anything it will show we are taking care of the problem we're reporting to authorities, they will
find out who did it. But she kept saying that this gives me a bad name and it's interesting
because right before that she said she doesn't have other clients now because all her time is taken
by this work. But she said no, this is something that will affect my clients that you've reported
hacking and she suspected one of the volunteers doing this. And that she banned this volunteer
from the website. And supposedly that took care of the problem. And I said look you can't
blame a volunteer and crusify somebody without having proof.
Hostess:
Right
Dr. Orly:
I would like FBI to investigate this and let them find out who did it and we go from there. And
she said well, hacking gives bad name to my site and if you don't take back this hacking
complaint then you cannot be on my server anymore. I said fine. I found another webmaster and
asked her to transfer my blogs. And uh, instead of doing the transfer, what she did was she
locked me out of the blog from my own foundation, she locked out other volunteers and she put
a really ridiculous statement about me that I consented to have my own blog hacked. That's
ridiculous why would I consent to that? Why would I consent somebody to and lose donations.
Hostess:
That's absurd.
Dr. Orly:
It makes no sense. And she also written something that uh, I am sending somewhere people's
email addresses and I'm spying on people which is ridiculous I'm not even computer savvy that's
why I needed her help to begin with.
Hostess:
I can identify with that.
Dr. Orly:
Yeah, ::giggles:: and the whole thing if I would have been doing something wrong something
illegal I wouldn't be running to FBI and you can see I've been sending those dossiers to FBI I've
been doing research and sending dossiers and demanding they investigate. And by the way when
authorities investigate the first thing they check is the person that makes the complaint to make
sure the person is legitimate and I have to tell you I am moving in this direction because umm, I
got a phone call from an agent, FBI agent from Orange County, CA his name is Nathan Lee and
he stated he is from Cyber Crimes division and was assigned to him. And also got a phone call
finally from the Department of Justice after all of the phone calls that were made to them by me
and the volunteers, numerous patriots that finally the Department of Justice has transferred my
complaint to the criminal division. I think this is only the 2nd time in U.S. history that there is a
criminal complaint being investigated by the Department of Justice against a sitting President.
The first one I think was Nixon.
Time Counter, Topic Change: 27:06
I had a very successful trip to Kentucky where I went with a group of volunteers and plaintiffs to
the Secretary of State and I posted on the blog ::technical interuption::
Hostess:
Hello?
Dr. Orly:
I posted on the blog a letter from the SOS of Kentucky to the Attorney General of Kentucky that
they investigate eligibility
Hostess:
I did see that
Dr. Orly:
Also a letter was sent from the Office of the Senator of Tennessee Lamar Alexander to FBI
asking that they investigate. So more people investigating, there is a Congressman Bill Posse that
is asking to have a new bill where, this is something that has to be checked. And that is what's
happening.
Time Counter: 28:00
Ah um, so this lady, she locked me out ::giggles:: from my own foundation and she posted a very
negitive message...
Hostess:
I did see this and a couple of people I work with who are very savvy in terms of tech did tell me
that this was kinda unusual that this wasn't necessary to post that kind of information widely. It
looks a little suspicious and it certainly is not the sort of thing one hopes to deal with when one
working so hard at a nonprofit and trying to accomplish patriotic issues. And I want to extend
my sympathies for you because I know how difficult it can be. Now do you have another website
that is up and running now? I'm confused myself.
Dr. Orly:
Right now I have a website, actually it is someone elses website and it is www.repubx.com And
um, we are trying to sort out this problem with Lisa Ostella. Hopefully we will have
defendourfreedoms.us. Ahmm, the original site transferred to this new webmaster who's name is
Jesse Smith. I mean a lot of things are happening.
Time Counter, Topic Change: 29:50
And by the way, when I reported this to FBI, I got an anonymous phone call telling me there is a
lady by the name of Lisa Liberi who is a paralegal working for Phil Berg, an attorney pursuing
the same issue. That she has an extensive criminal record. And that this Lisa Liberi had
convictions of identity fraud and forgery and um, gosh, um and mortgage fraud. So I have asked
a license investigator to check and he did come back with a report and things seem to be
checking out that indeed this woman by the name of Lisa Richardson Liberi that lives in the state
of New Mexico where she actually lives umm, does have a criminal record going back to 1990
and right here in California it states she has a conviction where she was suppose to get 8 years in
prison for fraud, forgery then it was reduced to probation and according to that report she is
suppose to pay $12,000 a month in restitution. I forwarded this to the attorney Phil Berg for
whom she works because she has an access to his blog and his PayPal. And I said look, here is a
report about this Lisa Richardson Liberi resident of New Mexico with a criminal record. She has
an access to your account and as an officer of the court I need to report this and I believe you
should join me in reporting this matter. I have not heard back from him yet. But things happen
and I feel that when people are donating money there has to be transparency and uh, you can't
have somebody, you know, this needs to be checked.
Time Counter: 32:14
Again this is something, I got information from Mr. Neil Sankey who is a licensed private
investigator. This gentleman has 20 years experience with Scotland Yard, he is from England.
He has been in this country, I don't recall, I think 15 years? As a private investigator, when you
have people with access to public funds to donations and a lot of donations you don't want
people with criminal records anywhere that.
Hostess:
Is it possible that there's two different Lisa Liberis?
Dr. Orly:
Well, um, that is what I was checking, but as far as we could find, Liberi is a real name and uh,
and the information I got is her name is Lisa former name Richardson, I also saw a another
former name Courvell and from what we've seen there is only one person that has all those
names Lisa Courvell Richardson Liberi, resident of New Mexico and her conviction was in San
Bernadino CA. We also saw her husband, someone by the name Brent Liberi, according to what
we have seen is on parole. Um, you know, we and the private investigator, Mr. Sankey has talk
to Mr. Nathan Lee, the uh, FBI agent who was suppose to investigate my PayPal tampering and
he reported this as well and he also reported this to the San Bernadino Police Department and I
believe the DA as well. And I have reported this also. Let them investigate it this.
Hostess:
That's about all one can do at this point.
(switches to Studio City Tea party).
Transcription by Lisa Ostella, Go Excel Global, Web Communications, eMarketing and Virtual Assistant Services
Transcription by Lisa Ostella, Go Excel Global, Web Communications, eMarketing and Virtual Assistant Services
EXHIBIT “2”

2009
« Previous Post
Ties to Everett, need help with research

,
You mentioned Everett, Wash. connection with Barack Obama’s mother’s family. Just
wondering if you knew that connection went back for over a century…
http://www.heraldnet.com/apps/pbcs.dll/article?AID=/20081026/NEWS01/710269867
Plus a bit more about the Wolfleys: http://www.santacruzsentinel.com/world/ci_12517525
So with a POTUS with a Muslim father and German roots mother, why shouldn’t Israelis be
worried?
If you do post this info, please don’t mention my name or email.
Cheers
Response
I am really concerned about several coincidences
1. a man who threatened to shoot me and burn my body for the world to see was tracked to a
computer server in Everett WA. Another person that threatened me was traced to Chauhelis WA
and yet another one to Canada (from what I understand not far from the border with WA state).
A few days after the threat there was a clamp missing and a disconnected fumes emissions hose
in my car and my husbands car died, suddenly a fuse was missing.
2. Obama does not talk about it, but his mother wasn’t in HI when he was a baby, she was
enrolled in the U of Seattle WA from August 1961-till June 1962, which means that as a baby he
lived in WA.
3. Lisa Liberi, assistant for Berg, who has a lengthy criminal record of grand theft, forgery
of documents and forgery of official seal doesn’t talk about it, but according to records she
was born in WA state. From what I recall Bellview WA. (her name at birth was Lisa
Richardson. From what I recall father -Jack Richardson, mother Shirley Wadell)
4. Obama, Liberi and Obama’s mother Stanley Ann Dunham- all have multiple social
security numbers according to databases.
5. Liberi was convicted of forgery of documents and according to experts, there are
multiple signs of forgery in Obama’s documents.
6. Stanley Ann Dunham also went by the name Shirley Ann Dunham.
We found a Dunham organization, owned by Shirley Ann Dunham; one location was in
Seattle another in Bellview WA. They dealt with insurances, lawyers, mortgages- you can
get ss numbers from all of these records.
7. From what I recall, there was a discrepancy between Intellius records and Secretary of state
records. According to the sec. of state a man owned that co. One of our volunteers pulled court
records in Bellview for the Dunham organization. This man, Mr. Dunham (don’t remember first
name) kept changing his middle initial in several court cases, which was suspicious by itself.
8. There was a very strange newspaper article in WA (I believe Seattle), from what I recall, when
Obama supposedly was in Columbia. It stated that one, Roman Obama studied at the university
of Patrice Lumumba in Moscow, Russia, and had some financial difficulties.
9. When grandma Dunham got sick, a reporter from WA (I believe Seattle) has writen an
interview with Charles Payne, saying the grandma got a broken hip. She was dead of cancer a
few days later. I was wondering, why did it come out in WA, and not HI or IL?
10. Based on all of the above, I have a nagging feeling, that there is somebody there in WA,
some relative of Obama, somebody who we might think is no longer with us.
This entry was posted on Monday, June 22nd, 2009 at 3:35 pm and is filed under Uncategorized. You can follow
any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.
[emphasis added]
EXHIBIT “3”
http://orlytaitzesq.com/dossier-006.htm
http://orlytaitzesq.com/drorlytaitzesq/documentation/Dossier6new2.doc
EXHIBIT “4”
Session ID:15815067
System
You are successfully connected to AOL Live Help. Please hold for the next available Live Help Agent.
System
AOLTechMRC has joined this session!
System
Connected with AOLTechMRC
System
Hello! My name is Melanie Grace. Welcome to AOL Live Technical Help. I am happy to address any
technical issues you may have with AOL. I will be with you as soon as I finish reviewing your concern.
Thanks for your patience.
Llisaliberi
Thank you.
AOLTechMRC
I am pleased to meet you online. :)
Llisaliberi
Likewise
AOLTechMRC
I understand that you would like to retrieve a copy of your previous chat session. Is this correct?
Llisaliberi
yes, back from January 2009
Llisaliberi
is that possible?
AOLTechMRC
Thank you for bringing this matter to us. I am glad I am the one who received your request as I am
going to do my best to assist you today.
AOLTechMRC
AOL does not keep a history of chat session or instant messages. There is no way to retrieve an instant
message conversation or chat session once it has been closed. However, you can take advantage of
using the Log Manager in the future.
Llisaliberi
Thank you, I have done that already. My next question, can I obtain an email sent on or about January
3, 2009 from AOL?
AOLTechMRC
Mails you sent remain online for 30 days only and then they get automatically deleted. You can only
have access to an e-mail more than 30 days if it has been saved to the Filing Cabinet or Saved on AOL
folder.
Llisaliberi
I understand that part, does AOL keep copies of emails that I have sent and received?
Llisaliberi
if so, do I need a subpoena to retrieve an older email I have sent?
AOLTechMRC
No, AOL does not keep copies of e-mails.
Llisaliberi
can an older email be retrieved from AOL's older equipment, in other words is there anyway to retrieve
an older email that has not been saved on my computer, with a subpoena?
AOLTechMRC
I am sorry, but there is no way to retrieve an older e-mail that was not saved to your computer.
Llisaliberi
I didn't think so, but wanted to ask to make sure. Also, one more question if I may. I have email in my
mailbox that is older and I have found that if the email is 30 days you are not able to forward it or do
anything other than view it or print it, is this correct or is there a way that I can forward older email to
another party?
AOLTechMRC
Where is that older e-mail currently located?
Llisaliberi
in my mailbox under old mail
AOLTechMRC
Could you please open that e-mail and try forwarding again? Then tell me what error you get.
Llisaliberi
It says "That message is no long available for forwarding"
AOLTechMRC
Is that e-mail under your Filing Cabinet?
Llisaliberi
it is in my email box that shows "old", "sent", "mail folders", etc.
AOLTechMRC
Thank you for the information.
Llisaliberi
No, it is not saved on my pc filing cabinent
AOLTechMRC
Are you accessing your mails through the AOL Software?
Llisaliberi
yes I am
AOLTechMRC
Did you switch your mailbox to Unified INBOX previously?
Llisaliberi
No I did not
AOLTechMRC
Thank you for that additional information.
AOLTechMRC
When you attempt to forward an e-mail that has been more than 30 days old and still located in your
OLD MAIL area, you will receive the error message That message is no longer available for forwarding.
It's because it has already expired.
AOLTechMRC
What you can do is to copy and paste the entire message from the e-mail, to a new Write Mail window,
like composing a new one, then send it.
Llisaliberi
Or of course, print it, correct?
AOLTechMRC
Yes, that's right.
Llisaliberi
Thank you very much for your assistance. The information you provided is of great help.
AOLTechMRC
You're most welcome. :) Is there anything else I may assist you with at this time?
Llisaliberi
no ma'am, you took care of all my questions. Again, thank you.
Subject: AOL Member Satisfaction Survey
Date: 8/14/2009 2:25:55 P.M. Eastern Daylight Time
From: AOL Feedback
To: Llisaliberi@aol.com
Dear llisaliberi@aol.com:
As you may recall, on Tuesday Aug 11 you contacted AOL. Our records show
that MelanieGrace, one of our Customer Care Consultants, assisted you
concerning a support issue. We continually strive to improve our customer
service. One way we do this is by asking members like you for an evaluation of
your most recent experience with AOL and the level of service we provided you.
Please take the next few minutes to complete the survey located below.
Click here to take the survey.
Please respond within 7 days of the date this invitation was sent so we may
provide timely feedback to the consultant who assisted you. After 7 days, this
invitation will expire.
However, if the information in the first paragraph of this e-mail does not look
familiar, it means we have sent you this e-mail in error, so please do not take the
survey — and accept our apologies for the inconvenience.
If you have any questions or need additional Technical or Account Service help,
please go to help.aol.com.
Thank you for your time -- and for choosing AOL.
Sincerely,
AOL Member Services

EXHIBIT “AA”
From: Redacted
Date: Mon, Jul 20, 2009 at 2:33 AM
Subject: June 25 Plains Radio Show
Since Ed Hale made direct threats on his show against anybody who submits an affidavit on
behalf of the Plaintiffs, is there any way that the judge can keep personal identifying
information confidential or suppressed?
I know Ed is full of hot air, but his and Orly's followers are loose cannons, and in my opinion...
dangerous. My mom and I are still going to give our statements, affidavits, and testify in court
if needed, because it's the right thing to do. And if we have to, we will petition the judge
ourselves. My mom is elderly. I am concerned for her safety, and the court needs to take
every legal measure to ensure her safety.
Please let me know, ok? Do me a favor and Ask Phil what he thinks is a good course of
action. Ed is trying to intimidate witnesses and there's got to be a way to make the judge
aware of this.
(name redacted)

4
From: Redacted
Date: Wed, Jul 22, 2009 at 3:16 AM
Subject: affidavit/ (name redacted) mom
I am prepared to submit my affidavit. However, I am concerned as to my safety due to the

threats that Ed Hale and Linda Belcher made on his show on June 25, 2009.
I truly fear for my life, if my personal identifying information is disclosed to these individuals.
I know it is intimidation but these individuals, and their followers, don’t appear to care or
respect the law. I believe them when they announce that they will go after me with a
vengeance. I would appreciate it if Mr. Berg would ask the judge not to disclose my identity
and address.
Thank You
Mary (last name redacted)
5
EXHIBIT “BB”
COPY OF CHAT LOG FILED WITH THE U.S. DISTRICT COURT, WHICH WAS MANUFACTURED BY LINDA BELCHER, FROM
BELCHER’S WEBSITE. BELOW THE PICTURE OF BELCHER’S WEBSITE IS A REAL CHAT BOX SHOWING LISA LIBERI’S
SCREEN NAME ON AOL, WHICH IS NOT “LISA” BUT IN FACT IS LLISALIBERI – AGAIN PROVING WHAT BELCHER GAVE
THE COURT WAS MANUFACTURED.
BELCHER ALSO FILED AN “AFFIDAVIT” WITH HER MANUFACTURED DOCUMENTS SUBMITTED INTO EVIDENCE THAT THE
DOCUMENTS WERE GENUINE DOCUMENTS. INSTEAD, IT WAS NOTHING MORE THAN PERJURY AND FRAUD UPON THE COURT
BELOW IS A PICTURE OF AN “INSTANT MESSAGE” WHICH IS A “CHAT” BOX, AGAIN SHOWING LIBERI’S SCREEN NAME ON AOL
AS LLISALIBERI AND NOT “LISA”.
A THIRD “INSTANT MESSAGE” WHICH IS A “CHAT” BOX ON AOL SHOWING LIBERI’S SCREEN NAME ON AOL AS LLISALIBERI
AND NOT “LISA”. ON ALL AOL “CHAT” SESSIONS LIBERI’S NAME APPEARS AS LLISALIBERI AND NOT “LISA”. AGAIN
PROVING THAT LINDA SUE BELCHER MANUFACTURED THE ABOVE CHAT WHICH WAS FILED WITH THE COURT.
EXHIBIT “CC”
NOTE: LIBERI HAS HAD NO CONTACT WITH LINDA BELCHER SINCE MARCH 6, 2009. The below is a email sent from Linda Belcher
to Linda Belcher - NOTICE - CENTRAL DAY LIGHT TIME AND THEN COMPARE WITH THE EMAIL ON THE NEXT PAGE. This proves the
Chat log and email log of Belcher's are manufactured and not legitimate documents.
http://obamacitizenshipdebate.org/2009/08/todays-court-proceedings-in-pa.html
Obama Citizenship Debate
Complete information on the constitutional eligibility of Barack Obama to serve as President of the United States.
Today's Court Proceedings in PA
By Linda Starr on August 7, 2009 7:00 PM | No Comments | No TrackBacks
Please tune in tonight to the www.plainsradio.com chat where Ed will be coming on to
give details of today's court proccedings. I don't want to deprive Ed of the right to tell
this story about events in court today. It is a very amusing story and one everyone will
want to hear.
Adams, Berg, Liberi and Ostella were all proven as having made false sworn affidavits
to Judge Robreno's court. Of the overwhelming mountain of evidence I supplied to Ed
Hale to present in court were two documents accompanied by my sworn affidavit that
these were true copies of the originals saved on my laptop. I am also posting just one
of them...followed by a press release issued by Berg later that day, Jan. 2, 2009
Forwarded Message:
Subj: Lisa Liberi chat 01/02/2009
Date: 8/4/2009 11:02:53 A.M. Central Daylight
Time
From: Newwomensparty
To: Newwomensparty
"Lisa" [2:28 A.M.]: you hung up on me earlier, I was typing away and you were GONE......
Newwomensparty [2:28 A.M.]: the puter froze
"Lisa" [2:29 A.M.]: awwww
"Lisa" [2:29 A.M.]: gotcha
Newwomensparty [2:29 A.M.]: same old same old
"Lisa" [2:29 A.M.]: well at least we are lucky to have these stinking puters. LMAO
Newwomensparty [2:29 A.M.]: listen is it ok to tell people Sarah Palin wanted to use this stuff?
Newwomensparty [2:29 A.M.]: yep
"Lisa" [2:30 A.M.]: I wouldn't say that because we don't know that for sure. We had someone saying they were related, but everything we were told did not pan out,
remember Palin was supposed to call Phil, no call, no response, nothing
Newwomensparty [2:30 A.M.]: hmmm
**Notice, the above email "header" appears to be from Llisaliberi to philjberg@gmail. Llisaliberi is an invalid email address and is not
what appears on actual emails which Liberi sends to Berg as you will see on the next pages. In addition, date has "Central Daylight Time
which is not the time zone that appears on Liberi's emails, again which you will see on the following pages. **
Liberi’s email address has never been “Llisaliberi” it is Llisaliberi@aol.com which shows on all emails sent and received
to and from Linda S. Belcher. The Sent and Received mail will always show my full email address, which proves Linda
Belcher’s “supposed” emails from Lisa Liberi are in fact manufactured.
EMAIL FROM LINDA BELCHER “Newwomensparty@aol.com” TO LISA LIBERI “Llisaliberi@aol.com”
From: Newwomensparty@aol.com [mailto:Newwomensparty@aol.com]
Sent: Saturday, February 21, 2009 12:56 AM
To: kstrebel@msn.com; Llisaliberi@aol.com; obamaissues@yahoo.com; katandbryant@yahoo.com
Subject: Re: New Forum
I don't know how to forward them. It just has a send reply option in the
pm.
axã jÉÅxÇ:á ctÜàç
Feminism: (noun) the radical notion that women are people.
Well behaved women seldom make history!
EMAIL FROM LISA LIBERI “Llisaliberi@aol.com” TO LINDA BELCHER “Newwomensparty@aol.com.
From: Llisaliberi@aol.com
To: Newwomensparty@aol.com
Date: Fri, 6 Mar 2009 18:42:56 EST
Subject: Re: Is the site hacked again or what?
Linda,
I have told Phil I will help him until he can replace me. This is a direct result of your accusations,
calling me a liar, telling the entire web world I'm a liar, I delete the emails which you send Phil and
the ramifications it has had. You have now created a havic which to me is beyond repair and this
includes trust issues involving this cause, Phil and the reputation you have so kindly given me.
You have talked and created more problems Linda and since I'm a reflection of Phil and the world
is aware that I work with Phil this has only hurt Phil and the cause.
You have lied to Phil and others. Including the fact, you called Ray Becker and after you failed at
bashing me to him, you started problems with him accusing him of things that have never been
proven. You have been told never to do this, as it is a liability on Phil. Despite this, you did it
anyway and then after verbally attacking Ray you called Phil and cried to him on how horrible Ray
was to you, when the truth of the matter was you created the havic.
Lisa
Pg. 1 of Berg's email box showing he never received an email from Liberi on January 3, 2009
Pg. 2 of Berg's email box showing he never received an email from Liberi on January 3, 2009
Copies of emails to and from Liberi and Berg showing that Liberi's full email address "Llisaliberi@aol.com" appear on the emails sent
to Berg as well as received from Berg.
U.S. District Court,
Eastern District of Pennsylvania Case Number: 09-cv-1898-ECR
Court of Appeals No. __________
UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT
_____________ Ο _____________
LISA LIBERI, et al,
Petitioner – Appellant,
v.
ORLY TAITZ, et al,
Respondents – Appellee.
_____________ Ο _____________
CERTIFICATE OF SERVICE
_____________________
I, Philip J. Berg, Esquire, hereby certify that Petitioners’ Emergency Request
for an Immediate Injunction or Restraining Order pending the resolution of
Petitioner’s Appeal was served upon the following Respondents via email this 17th
day of August, 2009
Orly Taitz
Defend our Freedoms Foundation, Inc. (unrepresented)
26302 La Paz Ste 211
Email: dr_taitz@yahoo.com
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
Linda Sue Belcher

201 Paris
Castroville, Texas 78009
Email: Newwomensparty@aol.com and
Email: starrbuzz@sbcglobal.net
Ed Hale
Caren Hale
Plains Radio
KPRN
Bar H Farms
1401 Bowie Street
Wellington, Texas 79095
Email: plains.radio@yahoo.com;
barhfarms@gmail.com and ed@barhfarnet

Attorney for Petitioners’
CERTIFICATE OF COMPLIANCE WITH WORD COUNT LIMITATIONS
I, Philip J. Berg, Esquire, Petitioner and a member of the Bar of this Court,
certify that the Application for a Stay of the Presidential election and/or a
temporary Injunction staying the Presidential election contains 7,115 words,
excluding the parts of the Application that are exempted.
Dated: August 17, 2009

Attorney for Petitioners’
(610) 825-3134

Lisa Liberi ET AL Request For Injunction Third Circuit Appeals Court

Diunggah oleh

Informasi Dokumen

Judul Asli

Hak Cipta

Format Tersedia

Bagikan dokumen Ini

Bagikan atau Tanam Dokumen

Opsi Berbagi

Apakah menurut Anda dokumen ini bermanfaat?

Apakah konten ini tidak pantas?

Hak Cipta:

Format Tersedia

Lisa Liberi ET AL Request For Injunction Third Circuit Appeals Court

Diunggah oleh

Hak Cipta:

Format Tersedia

U.S.

Court of Appeals No. __________

UNITED STATES COURT OF APPEALS

LISA LIBERI, et al,

ORLY TAITZ, et al,

EMERGENCY MOTION FOR AN IMMEDIATE INJUNCTION

Counsel: PHILIP J. BERG, ESQUIRE

Enjoin Respondent, Orly Taitz, et al from publication and distribution of Petitioner

Petitioners’; invading Petitioners’ Privacy, including but not limited to Intrusion

violation of California Privacy Laws, California Civil Code 1798 et sequitur,

Petitioners’ witnesses. Threatening witnesses or witness intimidation is in

violation of 18 U.S.C. §1512; Pennsylvania Statute 18 Pa.C.S. § 4951.

Intimidation and/or threatening of Petitioners’ witnesses and potential witnesses is

Texas threatening a witness is a felony in the third degree.

I. REQUEST FOR EMERGENCY RELIEF

1. In or about February 2009, Respondent, Orly Taitz, et al [hereinafter

Attorney in the State of California.

emailing, of having accounts set up on Berg’s foundation website and were

had stolen from him and he was not a foundation.

3. Shortly thereafter, Taitz put out a criminal record claiming it to belong to

Theft; Manufacturing or altercation of Police Reports; Manufacturing or Altering

Thousand [$21,000.00] Restitution Payments; that Liberi had a long lengthy

knowing her statements were false and dangerous..

separate web links of Taitz website and blog, http://www.orlytaitzesq.com/blog1/?p=8;

http://orlytaitzesq.com/dossier-006.htm; http://www.orlytaitzesq.com/blog1/?cat=29; and

[140,000] individuals and businesses including internationally by her own

In this Dossier #6, is an email from a licensed private investigator, Respondent

World Net Daily.

everyone to call the Santa Fe Probation Department because Liberi was on

for this location.

5, 2009; Respondent Linda S. Belcher [hereinafter “Belcher”] on May 5, 2009 and

which are degrading, harassment of the Petitioners’; invading Petitioners’ Privacy,

including but not limited to Intrusion upon Petitioner’s Seclusion; Public

California Civil Code 1798 et sequitur. See EXHIBITS “A-V”.

Injunction or Restraining Order.

Petitioners’ Motion for an Emergency Injunction or Restraining Order and gave

issued an Order with a footnote stating that Respondents were to conduct

Should Not be Transferred or Split Up and Transferred and Petitioners’ were to

support their Responses with Affidavits.

threatening remarks to Petitioners’ witnesses and statements that were considered

Linda Starr is an a/k/a of Linda Sue Belcher

Caryn: “Who are you talking about?”

Caryn: “From just?...”

Ed Hale: “Yeah, there is no more hiding.”

Linda Starr: “Then we can identify them.”

Ed Hale: “That's correct.”

Linda Starr: “That's right”.

Caryn: “And they will probably refuse to do it for Berg, huh?”

Ed Hale: “Let me tell you something. It’s easy as hell...”

Linda Starr: “Ron Polarik's ID is gonna be exposed.”

Ed Hale: “Let me tell you something...”

Caryn: “We're listen...”

Ed Hale: “This is what is hilarious in a way. The people that have

Linda Starr: “Oh we know who he is. We know...” [emphasis

Santa Fe Probation Department, San Bernardino County District Attorney, and

gave all the phone numbers. See EXHIBIT “V”.

personal identifying information as well as Hale and Belcher’s threats to

Motion for an Emergency Injunction or Restraining Order.

where he resided was placed on Edgar Hale’s website at www.plainsradio.com and

then Belcher placed this information on her own website at

www.obamacitizenshipdebate.org, following up with her threat that “Polarik”

Security number and other personal identifying information is republished on the

and resends to all the websites located on her RSS feed.