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Case: 09-3403 Document: 003110135281 Page: 1 Date Filed: 05/07/2010

U.S. District Court,


Eastern District of Pennsylvania Case Number: 09-cv-01898 ECR
Court of Appeals Case Number: 09-3403

UNITED STATES COURT OF APPEALS


FOR THE THIRD CIRCUIT
_____________ Ο _____________

LISA LIBERI, et al,


Plaintiffs’ – Appellants’,
v.
ORLY TAITZ, et al,
Respondents’ – Appellees’.
____________ Ο _____________

APPELLANTS’ OBJECTIONS and OPPOSITION TO APPELLEES


ORLY TAITZ and DEFEND OUR FREEDOMS FOUNDATIONS, INC.
FRIVOLOUS MOTION TO STRIKE WITH A REQUEST TO STRIKE
APPELLEES MOTION TO STRIKE; and REQUEST FOR ATTORNEY
FEES and SANCTIONS
_____________________

Philip J. Berg, Esquire


555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
(610) 825-3134
Attorney for the Appellants’
Case: 09-3403 Document: 003110135281 Page: 2 Date Filed: 05/07/2010

Appellants’, Lisa Liberi [hereinafter “Liberi”]; Philip J. Berg, Esquire

[hereinafter “Berg”], the Law Offices of Philip J. Berg; Evelyn Adams a/k/a

Momma E [hereinafter “Adams”]; Lisa Ostella [hereinafter “Ostella”]; and Go

Excel Global by and through their undersigned counsel, Philip J. Berg, Esquire,

hereby file the within Objections and Opposition with a Request to Strike and for

Attorney fees and Sanctions to Appellees Orly Taitz and Defend our Freedoms

Foundations, Inc.’s Frivolous Motion to Strike.

Appellees Motion to Strike was filed for an improper purpose and contains

nothing more than conclusions of law; hearsay statements; hearsay documents;

speculation; conclusory statements immaterial, impertinent, and scandalous

statements and material, and are completely irrelevant, impertinent and immaterial

to the within action and therefore, must be stricken.

I. STATEMENT OF FACTS:

Appellants filed a Motion to Withdraw their Appeal or in the Alternative a

Motion to Dismiss their Appeal pursuant to Federal Rules of Appellate Procedure,

[F.R.A.P.] Rule 42(b).

Appellee Orly Taitz [hereinafter “Taitz”] Entered her Appearance on behalf

of herself and her Corporation Defend our Freedoms Foundations, Inc. [hereinafter
Case: 09-3403 Document: 003110135281 Page: 3 Date Filed: 05/07/2010

“DOFF”] on April 26, 2010, five (5) days after Appellants filed their Motion to

Withdraw or in the Alternative to Dismiss their Appeal.

Appellees Taitz and DOFF then filed their Opposition to the Appellants

Motion on April 30, 2010 and raised numerous new issues and a Request for Costs

and Sanctions. Appellants had to reply, but due to the complexity of the Case was

unable to properly reply without exceeding the page limits. Appellants’ have filed

a Motion for Leave to File in Excess of the Ten (10) Page Limit. Appellants filed

their Reply on May 1, 2010 so not to hold up the Court in granting their Motion to

Withdraw their Appeal or in the Alternative to Dismiss their Appeal pursuant to

the Federal Rules of Appellate Procedure [F.R.A.P.] 42(b).

Appellees Taitz and DOFF have now filed a Motion to Strike Appellants’

Reply filed on May 1, 2010 to Appellees Opposition, which appears on the Court

docket on May 5, 2010. Appellees filing is nothing more than an attempted

tactical advantage to prolong dismissal of the within Appeal; to cost Appellants

additional Attorney Fees; to waist Judicial Resources; and Appellees Motion is to

cause delay.

Appellees have used the Motion process to falsely accuse Appellants’ of

crimes; to make unsubstantiated allegations against the Appellants; and now Taitz

screams afoul because Taitz is unhappy that Appellants replied to all of Taitz’s

false allegations and accusations against the Appellants and filed supporting

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evidence. In fact, Taitz’s states the Appellants make “unsubstantiated claims”, so

Appellants provided the evidence to substantiate their claims. The exhibits to

Appellants Reply are authenticated, they were taken directly from Taitz’s website,

which she authored and published. Taitz now claims the documents cannot be

trusted, which is ludicrous as Taitz maintains all the originals; Taitz sent them to

other websites, who posted them; to journalists who wrote about them; went on

radio shows, including but not limited to Satellite, Short Wave, Broadband and

Network and discussed her postings; Taitz provided them to law enforcement; and

filed them in other Federal Courts. Taitz claims the exhibits can’t be trusted

because “the documents and affidavits submitted are prepared and handled by

Berg’s assistant Lisa Renee Liberi (aka Lisa Liberi Richardson), who is a career

forgery with some ten convictions of forgery of documents…” Taitz’s filings are

packed with speculation; hearsay; and unsubstantiated false allegations. It is

important for this Court to note, Appellant Lisa Liberi’s middle name is NOT

“Renee”; nor has her name ever been “Lisa Liberi Richardson”. In addition, in

Taitz’s ramblings, which clearly warrant sanctions, she claims Appellant Lisa

Liberi threatened her sister and then her sister died. In is important for this Court

to note “Cheryl” is NOT and has NEVER been Appellant Liberi’s sister’s name.

It should also be noted that Appellant Lisa Liberi is a paralegal, not an investigator

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and Appellant Lisa Liberi has donated her time to the undersigned since

approximately 2006, not 2008 as Taitz’s claims.

It is apparent Taitz’s anger is directed at Appellant Lisa Liberi, however, the

reasons are unknown as to why, other than her threat to take the undersigned down

and to do so, Taitz stated she would destroy Appellant Lisa Liberi.

The rest of Taitz’s ramblings, again which she must be sanctioned for, are

referring to cases of the undersigned and events the undersigned has planned.

Nothing in Taitz filing has anything to do with the issue before this Court, which

is Appellants Motion to Withdraw or in the Alternative to Dismiss their Appeal

pursuant to the F.R.A.P. 42(b). As this Court can clearly see by using Taitz’s

filing of May 5, 2010 entitled Motion to Strike, and as also explained in

Appellants’ Reply, Appellee Taitz has a known history of falsely accusing her

victims of crimes and inappropriate actions for which she is actually doing, just as

she has done in her Motion to Strike, which clearly speaks for itself.

Unfortunately, the Appellants are victims of Taitz’s and it has been reported to the

proper authorities for full prosecution.

Taitz then cries that she is running for California Secretary of State in a tight

two (2) candidate race which is absolutely absurd. I will point out to this Court

however, just to give another example of how Taitz’s targets people: Damon Dunn

is a Republican candidate for Secretary of State that was endorsed by the

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Republican Party. Taitz did not take kindly to this and has now “targeted” Damon

Dunn. Taitz without any type of permissible purpose has obtained a Lexis

Accurint Report on Dunn, placing the majority of his Social Security number on

her site1. In addition, Taitz has been accusing Damon Dunn of Crimes in

California and even demanded the Orange County District Attorney’s Office to

prosecute Dunn, which they declined as Dunn had not broken any laws. A simple

search on the Internet in Google with “Taitz + Dunn” brings up Taitz’s horrible

posts authored and posted by her, just as she has done to the Appellants herein and

others, including Danny Bickel, a U.S. Supreme Court Clerk.

This Court may recall, in Taitz’s Opposition filed April 30, 2010, she

accused the undersigned for being a “politically motivated Pennsylvania attorney”

[See Taitz April 30, 2010 Opposition, p. 2 second paragraph] and now, Taitz

admits she is the one who is politically motivated.

In Appellants Reply and other filings seeking a Temporary Restraining

Order and/or Injunction against Taitz and the other Appellees’ Taitz had threatened

the undersigned, Appellant Lisa Liberi and the other Appellants, which since the

filing of the within lawsuit, Taitz has admitted in her filings in the lower Court.

Also, to bring to this Court’s attention, Appellants can’t derail a California State

1
http://www.orlytaitzesq.com/?p=10230; and http://www.orlytaitzesq.com

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election, such as for Secretary of State. None of the Appellants reside in the State

of California and therefore cannot vote in California’s state elections.

Taitz had the audacity to claim that www.repubx was not her website;

however, on Taitz’s own Dossier #6, which is on file with this Court, Taitz puts

her website as www.repubx.com. It should also be noted, after filing Appellants’

reply to Taitz frivolous Opposition, Taitz had Dossier #6 removed from

www.repubx.com and http://69.84.25.250/blogger/post/Dossie6.aspx. The

document itself is still available from the cache and Taitz Dossier #6 with

Appellant Lisa Liberi’s full Social Security number is still available on the

Internet2. The Court will note on the Exhibit attached to Appellants Opposition,

Dossier #6 was printed to a PDF format directly from the website itself, which

automatically picked up the website, date and time the document was stored in

PDF. See EXHIBIT “D” to Appellants’ Opposition filed May 1, 2010.

Taitz must be confused; it was during the June 25, 2009 Hearing that Judge

Robreno told Taitz she was not to publish anyone’s Social Security number. Taitz

was present for the June 25, 2009 hearing before Judge Robreno. The August 7,

2009 transcript, as stated many times, the undersigned was not provided the cost

for until April 16, 2010 proof of which was filed in Appellants’ Reply filed May 1,

2010. If Taitz is so concerned about the transcripts, she is capable of ordering

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them from the Court herself. In addition, Taitz attaches a copy of Joan Carr’s

Response to this Court’s Order to Show Cause why she, Joan Carr, should not be

held in contempt for her failure to produce the transcript. However, Taitz fails to

attach a copy of Appellants’ Reply to Joan Carr’s Response, attempts to

misrepresent the fact and mislead this very Court.

Taitz then lies to this Court yet again. Taitz states, “The unauthenticated

Grimm’s fairy tales of Dr. Taitz being submitted by appellants would be almost

laughable were it not for appellant s’ penchant for republishing this muck once it

obtains the court’s file stamp.” None of the Appellants have published any of their

filings in either this Court or the lower Court; it is Taitz’s herself who posts her

filings in the within Action all over the Internet and sends them by mass emailing.

Please see EXHIBIT “1” which is a letter recently sent to Judge Robreno

regarding Taitz sending a letter to Judge Robreno, that was never filed and/or

docketed in the lower Court case. Despite this, Taitz prepared a press release and

sent the letter addressed to Judge Robreno all over the Internet and sent it by mass

emailing for the world to see. In fact, she misquoted this Court’s Order of

February 2010 in her press release and mass emailing. This is not the first time

either, in fact, some of which is still on Taitz’s website 3. However, it appears once

2
See http://www.oilforimmigration.org/facts/?p=1478 and http://www.oilforimmigration.org
3
www.orlytaitzesq.com/?p=8034; www.orlytaitzesq.com/?p=2579;
www.orlytaitzesq.com/?p=1843 (this includes the forged emails of Appellant Lisa Ostella which

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the undersigned files on behalf of Appellants, and attaches copies of Taitz writings

and posts, Taitz has been “scrubbing” (deleting) the posts in question. Copies of

all of Taitz’s posts, which she has authored and posted on her website, are filed in

the lower Court with the direct website address. Taitz’s answers to said posts are

different depending on who she is talking too. Before Judge Robreno at the June

25, 2009 Hearing, Taitz claimed she had a duty, as an Officer of the Court, to

publish all her writings, her false allegations; all of Appellant Lisa Liberi’s private

confidential data, including her Social Security number and false-tales about the

Appellants’, to let the people know.

This very filing of Taitz’s demonstrates and substantiates the reasons

Appellants’ (Plaintiffs’) were forced to bring suit against the Appellees.

Taitz’s Motion to Strike Appellants Reply speaks for itself and is more than

sufficient proof that Taitz filed it for improper reasons, and therefore, she must be

Sanctioned and ordered to pay Four Thousand [$4,000.00] Dollars to Philip J.

was forged by Appellees Taitz and Sankey, proof of which is filed in the lower Court);
www.orlytaitzesq.com/?p=1648;
http://www.plainsradio.com/PLAINS~1/forum.html#bn-forum-1-1-
3764075825/6712/1121534/show; and
http://pub44.bravenet.com/forum/static/show.php?usernum=3764075825&frmid=6712&msgid=
1121538&cmd=show (When you go to these websites on Plains Radio and download the actual
files, click on the properties of the document and it shows Orly Taitz as the author of the
documents. Since Appellees Ed Hale and Orly Taitz scrub (delete) their postings when
Appellants’ file them with the Court, a copy is also attached hereto as EXHIBIT “2”).

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Berg, Esquire for Appellants Attorney fees in responding to Taitz’s frivolous

Motion and Taitz’s frivolous Opposition.

II. TAITZ’S MOTION FOR SANCTIONS IS IMPROPERLY PLED


and FAILS TO CITE ANY TYPE OF SUPPORTING LAW:

Appellants’ Object and ask this Court to Strike Taitz and DOFF’s entire

“Motion to Strike” electronically filed by Taitz on May 5, 2010. Taitz’s Motion to

Strike fails to cite any law or legal authority to support the striking of a pleading;

and contains nothing more than conclusions of law; hearsay statements; hearsay

documents; speculation; conclusory statements immaterial, impertinent, and

scandalous statements and material, and are completely irrelevant, impertinent and

immaterial to the within action; and fails to embark upon or even address

Appellants’ Opposition filed May 1, 2010. Taitz simply filed this nonsense to

prejudice the Appellants’ and to reflect falsely on the moral character of the

undersigned and Appellants’ Lisa Liberi, Lisa Ostella and Evelyn Adams.

Taitz raised issues in her Opposition that Appellants’ had to address.

Appellants attached proof to all of the statements made by attaching the items as

Exhibits.

“Scandalous" generally refers to any allegation that unnecessarily reflects on

the moral character of an individual or states anything in repulsive language that

detracts from the dignity of the Court. Courts will typically strike so-called

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scandalous material only if it is irrelevant and immaterial to the issues in

controversy. See Moore's for proposition that statement may be stricken as

"scandalous" only when it contains allegation "that unnecessarily reflects on the

moral character of an individual or states anything in repulsive language that

detracts from the dignity of the Court"). This Court has the inherent power to

"strike from any pleading any insufficient or any redundant, immaterial,

impertinent or scandalous matter.” See Geruschat v. Ernst Young LLP (In re Seven

Fields Dev. Corp.), 505 F.3d 237, 248 (3d Cir. Pa. 2007).

Taitz filing was spiteful; unprofessional; malicious; impertinent; redundant;

scandalous; and done with malice. Again, this filing by Taitz is the exact reason

Appellants (Plaintiffs) were forced to file action. Taitz only filed her nonsense to

waist judicial resources and to delay the proceedings to dismiss Appellants

Appeal so the Case against Appellees can move forward. See Farid v. Murphy,

945 F.2d 394 (3d Cir. 1991) (The Court sua sponte strikes as scandalous and

impertinent the second paragraph under the heading "plaintiff" at page 10 of the

brief for Appellees. The Court deems the inclusion of that paragraph in the brief to

be unprofessional, and deems footnote 7, by which counsel apparently sought to

justify the inclusion of the material, to be disingenuous.). The Court must strike

Taitz Motion to Strike filed May 5, 2010.

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For the aforementioned reasons, Taitz Motion to Strike Appellants

Opposition must be denied; Taitz Request for Sanctions and Costs must also be

denied. Taitz’s Motion to Strike filed May 5, 2010 must be stricken from the

record.

III. SANCTIONS AGAINST TAITZ and the AWARD OF


ATTORNEY FEES IN FAVOR OF APPELLANTS COUNSEL
MUST BE GRANTED:

Taitz’s also requests Sanctions against the undersigned in her frivolous

Motion to Strike filed May 5, 2010. Taitz request for Sanctions is also frivolous

and filed for an improper purpose. In fact, her entire pleading and Exhibits filed

May 5, 2010 are frivolous, incompetent; fail to cite any authority; was only filed to

further delay the within Appeal; and to waist judicial resources. Taitz is also

attempting to prolong the dismissal of this Appeal so the case in the lower Court

cannot proceed forward. The Exhibits Taitz attached includes Motions that were

Dismissed in the lower Court. Taitz raised issues in her Opposition that Appellants

were required to respond to and now she is screaming because Appellants

responded and filed supporting evidence substantiating their pleadings and

showing this Court that Taitz lies and has lied to this Court again. Now Taitz is

having a temper tantrum because she is not happy with the truth coming out.

Therefore, Taitz’s Request for Sanctions must be denied; Taitz Pleadings must be

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Stricken as they are conclusions of law; hearsay statements; hearsay documents;

speculation; conclusory statements immaterial, impertinent, and scandalous

statements and are completely irrelevant, impertinent and immaterial to the within

action; and fails to embark upon the issue before this Court, which is Appellants’

Motion to Withdraw or Dismiss their Appeal. Taitz and DOFF must be Sanctioned

and Ordered to pay Attorney Fees for her frivolous filings; her attempts to waist

judicial resources; to cost Appellants additional Attorney Fees; and her prolonging

the Dismissal of Appellants’ Appeal so their case in the lower Court stays at a

stand still and cannot move forward.

Taitz has been sanctioned before in October 2009, for this very exact thing

See Rhodes v. MacDonald, 670 F. Supp. 2d 1363 (M.D. Ga. 2009). Judge Land

increased the Sanctions against Taitz from Ten Thousand [$10,000.00] Dollars to

Twenty Thousand [$20,000.00] Dollars in attempts to deter her from her frivolous

filings. Judge Land’s Sanction Order and Opinion was upheld by the United States

Court of Appeals for the Eleventh Circuit. See Rhodes v. MacDonald, 2010 U.S.

App. LEXIS 5340 (11th Cir. Ga. Mar. 15, 2010). Unfortunately, Judge Land’s

Sanctions were not persuasive, as Taitz continues her disrespect for our Court’s,

Court Rules and continues her barrage of frivolous filings. Taitz will continue

filing her frivolous papers, if this Court does not put a stop to it. Taitz is currently

under investigation by the California State Bar, according to Taitz’s own

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admissions and website postings in the public forums, as a result of Judge Land’s

Sanction Order and other complaints that were filed against her.

As stated in Walsh v. Schering-Plough Corp., 758 F.2d 889, 895 (3d Cir.

1985):

“Undoubtedly, it was just such considerations that gave rise to the


recent amendment to Fed.R.Civ.P. 11. That Rule, promulgated to
keep attorneys "honest" in their pleading practice, now authorizes
sanctions to be imposed when an attorney violates his certificate
that good grounds support his pleading and that the pleading is not
interposed for delay. Moreover, our own Fed.R.App.P. 46(c)
provides for action being taken by us in the event that an attorney
who practices before us exhibits conduct unbecoming a member
of the bar or fails to comply with any rule of the court.4”

“Federal Rule of Civil Procedure 11 provides:”

“Every pleading, motion, and other paper of a party


represented by an attorney shall be signed by at least one
attorney of record in his individual name, whose address shall be
stated. A party who is not represented by an attorney shall sign his
pleading, motion or other paper and state his pleading, motion or
other paper and state his address…The signature of an attorney or
party constitutes a certificate by him that he has read the pleading,
motion, or other paper; that to the best of his knowledge,
information, and belief formed after reasonable inquiry it is well
grounded in fact and is warranted by existing law or a good faith
argument for the extension, modification, or reversal of existing
law, and that it is not interposed for any improper purpose, such

4
Federal Rule of Appellate Procedure 46(c) provides:

“c) Disciplinary Power of the Court over Attorneys. A court of appeals may, after
reasonable notice and an opportunity to show cause to the contrary, and after hearing, if
requested, take any appropriate disciplinary action against any attorney who practices
before it for conduct unbecoming a member of the bar or for failure to comply with
these rules or any rule of the court.”

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as to harass or to cause unnecessary delay or needless increase


in the cost of litigation. If a pleading, motion, or other paper is
not signed, it shall be stricken…If a pleading, motion, or other
paper is signed in violation of this rule, the court, upon motion
or upon its own initiative, shall impose upon the person who
signed it, a represented party, or both, an appropriate
sanction, which may include an order to pay to the other party
or parties the amount of the reasonable expenses incurred
because of the filing of the pleading, motion, or other paper,
including a reasonable attorney's fee.” [emphasis added]

“It is evident to me that unfortunately there are some counsel who


abuse the judicial process and by doing so make our task and the
tasks of our colleagues far more difficult. Historically, attorneys
have been reluctant to "blow the whistle" on their colleagues or to
seek sanctions against their opponents. Perhaps as Professor
Miller notes in a recent article written in a discovery context,5 they
are mindful of a variation on the golden rule "Do not seek
sanctions against what is done to you today, for it may be what
you will try on your opponent tomorrow."

This is Taitz’s third (3rd) frivolous Motion/Request for Sanctions based on

her own frivolous filings. Appellants’ filed their Appeal in good faith. Appellants’

incorporate all their filings, outlined on this Court’s docket, as if fully set forth

herein. Every filing by Appellants’ pertained to the issues presented to the Court

and were done so in good faith. Appellee Taitz on the other hand, continues to file

frivolous pleadings; has made false allegations against the undersigned and his

clients; has made false statements to this Court; has misrepresented the Court’s

Rulings; has misrepresented to this Court what Appellants’ filings actually say; and

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has failed to address the issues before the Court. It should also be noted, Appellee

Orly Taitz’s anger in her pleadings filed May 5, 2010 is clearly directed at

Appellant Lisa Liberi. This clearly is demonstrated on the proof of service

wherein Taitz put “Philip Berg, Esq.” and “Lisa Liberi c/o Law Offices of Philip

Berg”. Taitz did this even after Appellants brought this to the Court’s attention in

their Reply filed May 1, 2010. Once again, there are six (6) Appellants’, that the

undersigned represents in this Appeal. As this Court is well aware, Taitz is a

licensed attorney, and she knows she is not to contact the Appellants’ directly as

they are represented. It should also be noted that Taitz did not properly serve the

undersigned again. Taitz states on her proof of service that she served Philip Berg

electronically at philjberg@gmail.com on May 4, 2010 but dates her signature

April 29, 2010. The only email received from Taitz on May 5, 2010 was a forward

of the ECF filing notice.

Proper service was also a problem for Taitz in other cases. See Barnett v.

Obama, 2009 U.S. Dist. LEXIS 101206 (C.D. Cal. Oct. 29, 2009).

The Court in Walsh v. Schering-Plough Corp., 758 F.2d at 896-897 went on

further stating:

“If we take no steps to resolve the issue which these affidavits


have now presented to us, we run the risk not only of losing the
respect of the bar, but of damaging the professional standards that

5
Miller, The Adversary System: Dinosaur or Phoenix, 69 Minn.L.Rev. 25 (1984).

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lawyers look to us to uphold. Every member of the bar has had his
character and fitness tested and reviewed before obtaining a
license to practice. We, together, with other courts, are charged
with maintaining at least that level of honesty and professionalism
in the conduct of those who, once having obtained the right to
practice, continue to exercise that right before us.”

“...So too, as each instance of charged professional misconduct is


ignored by us or deemed unworthy of our attention, our
professional tapestry will imperceptibly, but surely, lose its form,
its structure and its shape.”

“Thus, in my opinion it is no answer to characterize the issue


before us as one not worth our consideration. If we do not require
strict adherence to principles which mandate candor and
truthfulness, and if we refuse to decide and enforce claimed
violations of those fundamental precepts, we will have only
ourselves to blame if intolerable and proscribed practices of the
bar become the rule rather than the exception.”

For the reasons stated herein, Taitz Motion to Strike; Request for Sanctions;

and Request for Costs must be denied. This Court must Sanction Taitz in attempts

to deter her from inappropriate behavior and frivolous filings. In addition, the

Court must Order Taitz to pay Appellants’ Attorney Fees in the amount of Four

Thousand [$4,000] Dollars.

IV. CONCLUSION:

For all the aforementioned reasons, Appellants respectfully request this

Court to Deny Taitz’s Motion to Strike; Deny Taitz’s Request for Sanctions and

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Costs as there is no basis; and Grant Appellants Motion to Strike Taitz’s Motion to

Strike filed May 5, 2010; Grant Appellants Request for Sanctions and Attorney

Fees and Grant Appellants Motion to Withdraw or Dismiss their Appeal pursuant

to F.R.A.P. 42(b).

Respectfully submitted,

s/ Philip J. Berg
Dated: May 7, 2010 ____________________________
Philip J. Berg, Esquire
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
(610) 825-3134
Attorney for the Appellants’

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EXHIBIT “1”

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LAW OFFICES OF
PHILIP J. BERG
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
PHILIP J. BERG
CATHERINE R. BARONE
BARBARA MAY
(610) 825-3134

FAX (610) 834-7659

NORMAN B. BERG, Paralegal [Deceased] E-Mail: philjberg@gmail.com

February 22, 2010

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.....................................................................................................29 Pages

Re: Liberi, et al. v. Orly Taitz, et al, Case No. 09-cv-01898 ECR
Defendant Taitz, et al Letter requesting Leave to File a Request for Judicial Notice

Dear Judge Robreno:

I am in receipt of Defendant, Orly Taitz, et al’s Letter to Your Honor dated February 17, 2010
requesting Judicial Notice of the U.S. Court of Appeals for the Third Circuit’s Order denying
Appellant’s request for Judicial Notices; Defendant Taitz’s Motion for Sanctions; Appellants’ Motion
to Expedite, etc. I received Defendant Taitz’s request to Your Honor via email from Defendant Taitz,
et al on February 18, 2010.

Plaintiffs’ herein Object to Defendant Taitz’s request of Your Honor. First, no Motion or any
type of legal authority was attached to Defendant Taitz’s Letter as required by this Court’s Order of
June 25, 2009. Next, Defendant Taitz states the U.S. Court of Appeals for the Third Circuit “denied
all 11 motions…” [emphasis added]. This is a blatant fraud upon this Court. Appellants never filed
eleven [11] Motions with the Court of Appeals. Moreover, the Obama litigation has nothing to do with
the case herein; and Defendant Taitz’s is further using Your Honor and Your Court to further her
slander, libel, false allegations and placing Plaintiff Liberi, Plaintiff Ostella and me in a false light. It
should also be noted, neither Defendant Taitz, nor any of the other Defendants’ responded to Plaintiffs’
(Appellants’) Request for Judicial Notices.

Z:\Liberi Ltr to Judge Robreno Feb. 22, 2010 1


Case: 09-3403 Document: 003110135281 Page: 21 Date Filed: 05/07/2010

Honorable Eduardo C. Robreno February 22, 2010


United States District Court
for the Eastern District of Pennsylvania
Page Two of Five

In addition, Defendant Taitz has used Defendants Ed Hale, Caren Hale, Plains Radio Network,
Inc., KPRN and Bar H Farms to post Orly Taitz’s Letter to Your Honor on the Internet1. A copy of
this post on the Internet is attached hereto as EXHIBIT “A”. Defendant Taitz also posted her Letter
to Your Honor at two [2] different Internet Web Addresses on her website. Copies of Defendant
Taitz’s postings on her own website are also attached hereto as EXHIBIT “B”2 and EXHIBIT “C”3.
Moreover, Defendant Orly Taitz, et al sent her Letter to Your Honor by mass emailing to her entire
email database, which includes internationally, on February 18, 2010 at 9:28 a.m. and 12:32 p.m. A
copy of Defendant Taitz’s email sent to me is attached hereto as EXHIBIT “D”. Further, Defendant
Taitz then sent by mass emailing and posted on her website a press release with a copy of the Letter
sent to Your Honor. See EXHIBIT “E’. Defendant, Orly Taitz has publicized this Letter to Your
Honor to further her continued slander, libel, false allegations and placing Plaintiff Liberi, Ostella, and
me in a false light.

In my opinion, this type of behavior from Defendant Taitz, et al should not be permitted.
Defendant Taitz is an Attorney duly licensed to practice law in the State of California. The Court in
the case of Sheehan v. King County, 1998 U.S. Dist. LEXIS 16862 (D. Wash. 1998) outlined this type
of behavior very well. The Court said:

“This publication of personal information and defamatory comments about


opposing counsel is directly related to this litigation, and cannot be tolerated.
Attorneys are officers of the court, and this type of public, personal attack in
relation to pending litigation constitutes an abuse of judicial process.”
[emphasis added]

“His counsel offers the spurious argument that the "computer generated evidence"
is inadmissible as hearsay, and that sanctions would violate plaintiff's First
Amendment rights. The printed copies of plaintiff's "website" are not hearsay
because they are clearly not offered to prove the truth of matters asserted
therein (i.e., that plaintiff's accusations about counsels' character are true).
As for the First Amendment, the Court is not enjoining plaintiff's free
speech, but merely exercising its inherent power to sanction bad faith

1
Defendant Ed Hale’s post on his website at:
http://pub44.bravenet.com/forum/static/show.php?usernum=3764075825&frmid=6712&msgid=1107033&cmd=show
2
Taitz post on her website at www.orlytaitzesq.com

Z:\Liberi Ltr to Judge Robreno Feb. 22, 2010 2


Case: 09-3403 Document: 003110135281 Page: 22 Date Filed: 05/07/2010

Honorable Eduardo C. Robreno February 22, 2010


United States District Court
for the Eastern District of Pennsylvania
Page Three of Five

conduct by a party to this litigation. Chambers v. Nasco, Inc., 501 U.S. 32, 46,
115 L. Ed. 2d 27, 111 S. Ct. 2123 (1991)” [emphasis added]

“The Court finds that the "website" printouts have been properly authenticated by
counsel, who received them by "facsimile" transmission and also printed them
directly from their computers. Dkt. # 107, 108. The printouts show that as of
May 6, 1998, well after defendants filed their motion for sanctions and gave
notice to plaintiff of their request, plaintiff continued in his sanctionable
conduct. No separate warning from the Court is necessary.” [emphasis added]

“The Internet publication of social security numbers, home addresses and


telephone numbers, and defamatory statements regarding opposing counsel
has no justification. From the tone of the "website", it is clearly presented as
an invitation for others to harass, threaten, or even attack these people.”
[emphasis added]

Just like the Sheehan Case, Defendant Taitz has done the same sanctionable behavior to
Plaintiff Liberi, a Plaintiff in the within case with the republication of her Social Security number, date
of birth, place of birth, mother’s maiden name and other private identifiable information. Moreover,
Defendant Taitz has also gone after Plaintiff Liberi and the rest of the Plaintiffs’, including me,
Plaintiffs’ Attorney, making false accusations and defamatory statements about us all over the Internet,
by mass emailing, postings on their websites; posting on other websites; sending it to social networks;
on RSS feeds, etc. of defamatory comments/statements, etc. Moreover, just like the Sheehan Case,
Defendants were served with the within lawsuit on or about May 5, 2009, Defendants have continued
their behaviors. Especially Defendant Taitz, et al, she has continued her republication of Plaintiff
Liberi’s Social Security number, against this Court’s Rulings and Orders as well as Plaintiff Liberi’s
date of birth, place of birth, mother’s maiden name and other private information. Your Honor, these
continued actions by Defendant Taitz must be stopped.

I sent Your Honor a Letter seeking Leave on behalf of Plaintiff Liberi to file a Motion to hold
Defendant Taitz, et al in Civil and/or Criminal Contempt; for actual damages; sanctions; and attorney

3
Taitz post on her website at http://www.orlytaitzesq.com/?p=8034

Z:\Liberi Ltr to Judge Robreno Feb. 22, 2010 3


Case: 09-3403 Document: 003110135281 Page: 23 Date Filed: 05/07/2010

Honorable Eduardo C. Robreno February 22, 2010


United States District Court
for the Eastern District of Pennsylvania
Page Four of Five

fees on February 9, 2010. Of course, Plaintiff Liberi’s Motion was attached thereto. I am therefore,
renewing my request for Leave to file Plaintiff Liberi’s Motion for Contempt against Defendant Taitz
for her continued republication of Plaintiff Liberi’s Social Security number, as well as other personal
identifying information, which was in violation of Your Court’s June 25, 2009 Rulings and Order.

It should also be noted, none of the Defendants, including Defendant Taitz, has opposed the
filing of the Motion for Civil and/or Criminal Contempt against Defendant Taitz.

In the alternative, Plaintiffs Request this Court to issue an Order to Show Cause upon
Defendant Taitz, et al as to Why She Should Not be Held in Civil and/or Criminal Contempt for her
continued republication of Plaintiff Liberi’s Social Security number in violation of this Court’s Rulings
and Orders; and why she (Defendant Taitz, et al) should not be Ordered to Reimburse Plaintiff Liberi
for the damages she has suffered as a result; impose Sanctions; and for Attorney Fees.

Thank you.

Respectfully,

Philip J. Berg

PJB:jb

Enclosures

cc: Orly Taitz, et al and


Defend our Freedoms Foundation, Inc.
26302 La Paz Ste 211
Mission Viejo, CA 92691
Ph: (949) 683-5411
Fax: (949) 766-7603
By Email: dr_taitz@yahoo.com
Counsel in pro se
Defend our Freedoms Foundations, Inc. is unrepresented

Z:\Liberi Ltr to Judge Robreno Feb. 22, 2010 4


Case: 09-3403 Document: 003110135281 Page: 24 Date Filed: 05/07/2010

Honorable Eduardo C. Robreno February 22, 2010


United States District Court
for the Eastern District of Pennsylvania
Page Five of Five

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

Z:\Liberi Ltr to Judge Robreno Feb. 22, 2010 5


Case: 09-3403 Document: 003110135281 Page: 25 Date Filed: 05/07/2010

EXHIBIT “A”

Z:\Liberi Ltr to Judge Robreno Feb. 22, 2010 6


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Case: 09-3403 Document: 003110135281 Page: 26 Date Filed: 05/07/2010

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Index February 18, 2010 - 10:58:31 AM

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Author Comment

Ed Hale Liberi v Taitz - new information Quote Reply


Dr. Orly Taitz ESQ
29839 S. Margarita PKWY, ste 100
Rancho Santa Margarita CA 92688

02.17.10
Attention Honorable Eduardo Robreno

Request for Leave of Court to file and docket a 02.09.10. Third Circuit Court of
Feb 18, 2010 - 9:50AM Appeals order denying all 11 Motions and requests for judicial notice filed by
Philip Berg on behalf of Appellants/Plaintiffs in Liberi et al v Taitz et al.

Your honor,
Plaintiffs in the above captioned case have bombarded the defendants and the courts
with hundreds and, by now, probably thousands of pages of pleadings of motions and
requests for judicial notices, most of which had absolutely nothing to do with the
case at hand and the order to show cause that was directed towards the plaintiffs. I
am asking for a judicial notice of one page only. The attached one page order from
the Third Circuit Court of Appeals denying all 11 motions and requests for judicial
notice, shows that the Third Circuit Court of Appeals does not see any emergency,
that the plaintiffs claim and does not see any relevance in all of those voluminous
filings. It is consistent with the findings of this court and it is an indication,
that if the Court of Appeals didn’t see any emergency now, it is reasonable to
believe that there was no emergency half a year ago, when your Honor denied
plaintiffs request for the temporary restraining order
against the defendants. It strengthens the defendant’s position that indeed, there
was no emergency or damages to the plaintiffs, rather Attorney Philip Berg has
filed this legal action with an improper purpose of harassing and trying to silence
the defendants, when I posted on my web site true printout from the San Bernardino
division of the Superior Court in CA of ten felony convictions of forgery and
grand theft committed by Berg’s assistant Lisa Liberi. This publication was done
with a proper purpose of alerting the public that any piece of evidence, any
document coming out of Berg’s office is suspect of forgery, due to Liberi’s
background and particularly in light of the fact that Mr. Berg has filed Affidavits
of Kenyan birth of Barack Obama in Eastern District of PA, Third Circuit Court of
Appeals and the Supreme Court of the United States and refused to show the original
documents to me or to a forensic document expert. While the

http://pub44.bravenet.com/forum/static/show.php?usernum=3764075825&frmid=6712&msgid=1107...
This forum can be accessed via plainsradio.com - Window Title
Case: 09-3403 Document: 003110135281 Page: 27 Date Filed: 05/07/2010

media has named me the “Queen of the Birthers” or the leader of the Birther
movement, due to my legal actions to unseal the original vital records of Mr. Obama
and get a declaratory relief on the meaning of the term Natural born citizen, as it
applies to the article 2, section 1 requirement for presidency, I am concerned that
Mr. Berg’s actions in using a convicted document forger as a legal assistant, and
refusing to provide original documents, does not help the cause or the underlying
legal action, but rather undermines and muddies it and will destroy it, when it
will be heard on the merits. It is also an indication, that as an attorney and
president of the Defend Our Freedoms Foundation, I was justified in alerting the
public regarding the fact that on 04.11.09 my former volunteer web master Lisa
Ostella has changed the passwords and locked me out of the original
DefendOurFreedoms website, and from that date any and all donations
received on that old web site did not benefit my foundation, but rather benefit
Ostella personally, as well as Attorney Philip Berg, indirectly his assistant Lisa
Liberi, as well as talk show host Evelyn Adams, all of whom Ostella started
promoting on the web site for my foundation after locking me out.
While most of the plaintiffs are lay persons, Berg is a licensed attorney and his
actions were direct violation of rules of professional ethics.

Respectfully submitted,

Dr. Orly Taitz ESQ

02/09/2010

ORDER (MCKEE and RENDELL, Circuit Judges) denying Motion by Appellants for
Expedited
Ruling or to File a Restraining Order, requests Appellants for Judicial Notice,
Emergency Motion by Appellants to Expedite Interlocutory Appeal and Expedite
Ruling
on Appellants Pending Motion, filed. Panel No.: BCO-039-E. McKee, Authoring Judge.

State Texas

rosemary1 Re: Liberi v Taitz - new information Quote Reply


BobH? Any opinion on this filing by the "Queen of the Birthers"?

Feb 18, 2010 - 10:38AM

Damm Paige Re: Liberi v Taitz - new information Quote Reply


Okay, I'm confused. Judge Robreno signed an order in December placing the District
Court case in suspense until further order. Why is Orly writing to Judge Robreno?
Feb 18, 2010 - 10:48AM Does she think that the Third Circuit has disposed of the appeal?

State of Legal Knowledge

BobH Re: Liberi v Taitz - new information Quote Reply

Quote:
Feb 18, 2010 - 10:53AM
Originally Posted by rosemary1
BobH? Any opinion on this filing by the "Queen of the Birthers"?

http://pub44.bravenet.com/forum/static/show.php?usernum=3764075825&frmid=6712&msgid=1107...
This forum can be accessed via plainsradio.com - Window Title
Case: 09-3403 Document: 003110135281 Page: 28 Date Filed: 05/07/2010

My opinion is it means absolutely nothing. Without going into specific detail in the
letter, Orly seems to avoid the fact that one of her motions was also denied by the
appeals court in that Order that came down. She mentions Berg is an attorney. She
also has a license to practice law.

Nothing in the letter has any bearing on the appeal or the case in the the lower court
in PA which is actually not even open at this time, and has not been since 12/11/09,
pending the decision of the appeals court, as evidenced here:

Quote:

12/11/2009 115[RECAP] ORDER THAT THE CLERK OF COURT MARK THIS


ACTION CLOSED FOR STATISTICAL PURPOSES AND PLACE THE MATTER IN THE
CIVIL SUSPENSE FILE UNTIL FURTHER ORDER OF THE COURT.. SIGNED BY
HONORABLE EDUARDO C. ROBRENO ON 12/9/2009. 12/11/2009 ENTERED
AND COPIES MAILED TO PRO SE AND UNREPS, E-MAILED TO COUNSEL.(tomg, )
(Entered: 12/11/2009)

In short, it's nothing more than her usual ramblings with nothing of merit contained
therein.

State NM

Index

http://pub44.bravenet.com/forum/static/show.php?usernum=3764075825&frmid=6712&msgid=1107...
Case: 09-3403 Document: 003110135281 Page: 29 Date Filed: 05/07/2010

EXHIBIT “B”

Z:\Liberi Ltr to Judge Robreno Feb. 22, 2010 7


Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/
Case: 09-3403 Document: 003110135281 Page: 30 Date Filed: 05/07/2010
www.orlytaitzesq.com
Home
Appeal of Carter Case
Comments are disabled
Quo Warranto Filed and Served

Dr. Orly Taitz Esquire


Defend Our Freedoms Foundation – 29839 Santa Margarita Pkwy, ste 100, Rancho
Santa Margarita CA, 92688 – Copyright 2009

World's Leading Obama Eligibility Challenge Web Site


Your donations to the cause are much appreciated.

The articles posted represent only the opinion of the writers, do not necessarily represent the opinion of Dr. Taitz, ESQ, and Dr. Taitz, ESQ has no means of
checking the veracity of all the claims and allegations in the articles.

Important. Third Circuit Court of Appeals has


denied all 11 motions and requests for judicial
notice filed by Attorney Philip Berg in his attacks
on Attorney Orly Taitz and others
Posted on | February 18, 2010 |

2/18/2010 2:42 PM
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/
Case: 09-3403 Document: 003110135281 Page: 31 Date Filed: 05/07/2010

Posted on | February 18, 2010 |

Dr. Orly Taitz ESQ


29839 S. Margarita PKWY, ste 100

Rancho Santa Margarita CA 92688

02.17.10

Attention Honorable Eduardo Robreno


Request for Leave of Court to file and docket a 02.09.10. Third Circuit Court of Appeals order denying all 11
Motions and requests for judicial notice filed by Philip Berg on behalf of Appellants/Plaintiffs in Liberi et al v
Taitz et al.

Your honor,

Plaintiffs in the above captioned case have bombarded the defendants and the courts with hundreds and, by
now, probably thousands of pages of pleadings of motions and requests for judicial notices, most of which had
absolutely nothing to do with the case at hand and the order to show cause that was directed towards the
plaintiffs. I am asking for a judicial notice of one page only. The attached one page order from the Third
Circuit Court of Appeals denying all 11 motions and requests for judicial notice, shows that the Third Circuit
Court of Appeals does not see any emergency, that the plaintiffs claim and does not see any relevance in all of
those voluminous filings. It is consistent with the findings of this court and it is an indication, that if the Court
of Appeals didn’t see any emergency now, it is reasonable to believe that there was no emergency half a year
ago, when your Honor denied plaintiffs request for the temporary restraining order against the defendants. It
strengthens the defendant’s position that indeed, there was no emergency or damages to the plaintiffs, rather
Attorney Philip Berg has filed this legal action with an improper purpose of harassing and trying to silence the
defendants, when I posted on my web site true printout from the San Bernardino division of the Superior
Court in CA of ten felony convictions of forgery and grand theft committed by Berg’s assistant Lisa Liberi.
This publication was done with a proper purpose of alerting the public that any piece of evidence, any
document coming out of Berg’s office is suspect of forgery, due to Liberi’s background and particularly in
light of the fact that Mr. Berg has filed Affidavits of Kenyan birth of Barack Obama in Eastern District of PA,
Third Circuit Court of Appeals and the Supreme Court of the United States and refused to show the original
documents to me or to a forensic document expert. While the media has named me the “Queen of the
Birthers” or the leader of the Birther movement, due to my legal actions to unseal the original vital records of
Mr. Obama and get a declaratory relief on the meaning of the term Natural born citizen, as it applies to the
article 2, section 1 requirement for presidency, I am concerned that Mr. Berg’s actions in using a convicted
document forger as a legal assistant, and refusing to provide original documents, does not help the cause or the
underlying legal action, but rather undermines and muddies it and will destroy it, when it will be heard on the
merits. It is also an indication, that as an attorney and president of the Defend Our Freedoms Foundation, I
was justified in alerting the public regarding the fact that on 04.11.09 my former volunteer web master Lisa

2/18/2010 2:42 PM
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/
Case: 09-3403 Document: 003110135281 Page: 32 Date Filed: 05/07/2010
Ostella has changed the passwords and locked me out of the original DefendOurFreedoms website, and
from that date any and all donations received on that old web site did not benefit my foundation, but rather
benefit Ostella personally, as well as Attorney Philip Berg, indirectly his assistant Lisa Liberi, as well as talk
show host Evelyn Adams, all of whom Ostella started promoting on the web site for my foundation after
locking me out.

While most of the plaintiffs are lay persons, Berg is a licensed attorney and his actions were direct violation of
rules of professional ethics.
Respectfully submitted,

Dr. Orly Taitz ESQ

02/09/2010 ORDER (MCKEE and RENDELL, Circuit Judges) denying Motion by Appellants for Expedited
Ruling or to File a Restraining Order, requests Appellants for Judicial Notice, Emergency Motion
by Appellants to Expedite Interlocutory Appeal and Expedite Ruling on Appellants Pending
Motion, filed. Panel No.: BCO-039-E. McKee, Authoring Judge. (SLC)

Cc Philip Berg

Cc Neil Sankey

Cc Linda Belcher

Cc Ed and Karen Hale

2/18/2010 2:42 PM
Case: 09-3403 Document: 003110135281 Page: 33 Date Filed: 05/07/2010

EXHIBIT “C”

Z:\Liberi Ltr to Judge Robreno Feb. 22, 2010 8


Important. Third Circuit Court of Appeals has denied all 11 motions and r... http://www.orlytaitzesq.com/?p=8034
Case: 09-3403 Document: 003110135281 Page: 34 Date Filed: 05/07/2010
www.orlytaitzesq.com/?p=8034
Home
Appeal of Carter Case
Comments are disabled
Quo Warranto Filed and Served

Dr. Orly Taitz Esquire


Defend Our Freedoms Foundation – 29839 Santa Margarita Pkwy, ste 100, Rancho
Santa Margarita CA, 92688 – Copyright 2009

World's Leading Obama Eligibility Challenge Web Site


Your donations to the cause are much appreciated.

The articles posted represent only the opinion of the writers, do not necessarily represent the opinion of Dr. Taitz, ESQ, and Dr. Taitz, ESQ has no means of
checking the veracity of all the claims and allegations in the articles.

Important. Third Circuit Court of Appeals has


denied all 11 motions and requests for judicial
notice filed by Attorney Philip Berg in his attacks
on Attorney Orly Taitz and others
Posted on | February 18, 2010 |

2/18/2010 2:43 PM
Important. Third Circuit Court of Appeals has denied all 11 motions and r... http://www.orlytaitzesq.com/?p=8034
Case: 09-3403 Document: 003110135281 Page: 35 Date Filed: 05/07/2010

Posted on | February 18, 2010 |

Dr. Orly Taitz ESQ


29839 S. Margarita PKWY, ste 100

Rancho Santa Margarita CA 92688

02.17.10

Attention Honorable Eduardo Robreno


Request for Leave of Court to file and docket a 02.09.10. Third Circuit Court of Appeals order denying all 11
Motions and requests for judicial notice filed by Philip Berg on behalf of Appellants/Plaintiffs in Liberi et al v
Taitz et al.

Your honor,

Plaintiffs in the above captioned case have bombarded the defendants and the courts with hundreds and, by
now, probably thousands of pages of pleadings of motions and requests for judicial notices, most of which had
absolutely nothing to do with the case at hand and the order to show cause that was directed towards the
plaintiffs. I am asking for a judicial notice of one page only. The attached one page order from the Third
Circuit Court of Appeals denying all 11 motions and requests for judicial notice, shows that the Third Circuit
Court of Appeals does not see any emergency, that the plaintiffs claim and does not see any relevance in all of
those voluminous filings. It is consistent with the findings of this court and it is an indication, that if the Court
of Appeals didn’t see any emergency now, it is reasonable to believe that there was no emergency half a year
ago, when your Honor denied plaintiffs request for the temporary restraining order against the defendants. It
strengthens the defendant’s position that indeed, there was no emergency or damages to the plaintiffs, rather
Attorney Philip Berg has filed this legal action with an improper purpose of harassing and trying to silence the
defendants, when I posted on my web site true printout from the San Bernardino division of the Superior
Court in CA of ten felony convictions of forgery and grand theft committed by Berg’s assistant Lisa Liberi.
This publication was done with a proper purpose of alerting the public that any piece of evidence, any
document coming out of Berg’s office is suspect of forgery, due to Liberi’s background and particularly in
light of the fact that Mr. Berg has filed Affidavits of Kenyan birth of Barack Obama in Eastern District of PA,
Third Circuit Court of Appeals and the Supreme Court of the United States and refused to show the original
documents to me or to a forensic document expert. While the media has named me the “Queen of the
Birthers” or the leader of the Birther movement, due to my legal actions to unseal the original vital records of
Mr. Obama and get a declaratory relief on the meaning of the term Natural born citizen, as it applies to the
article 2, section 1 requirement for presidency, I am concerned that Mr. Berg’s actions in using a convicted
document forger as a legal assistant, and refusing to provide original documents, does not help the cause or the
underlying legal action, but rather undermines and muddies it and will destroy it, when it will be heard on the
merits. It is also an indication, that as an attorney and president of the Defend Our Freedoms Foundation, I
was justified in alerting the public regarding the fact that on 04.11.09 my former volunteer web master Lisa

2/18/2010 2:43 PM
Important. Third Circuit Court of Appeals has denied all 11 motions and r... http://www.orlytaitzesq.com/?p=8034
Case: 09-3403 Document: 003110135281 Page: 36 Date Filed: 05/07/2010
Ostella has changed the passwords and locked me out of the original DefendOurFreedoms website, and
from that date any and all donations received on that old web site did not benefit my foundation, but rather
benefit Ostella personally, as well as Attorney Philip Berg, indirectly his assistant Lisa Liberi, as well as talk
show host Evelyn Adams, all of whom Ostella started promoting on the web site for my foundation after
locking me out.

While most of the plaintiffs are lay persons, Berg is a licensed attorney and his actions were direct violation of
rules of professional ethics.
Respectfully submitted,

Dr. Orly Taitz ESQ

02/09/2010 ORDER (MCKEE and RENDELL, Circuit Judges) denying Motion by Appellants for Expedited
Ruling or to File a Restraining Order, requests Appellants for Judicial Notice, Emergency Motion
by Appellants to Expedite Interlocutory Appeal and Expedite Ruling on Appellants Pending
Motion, filed. Panel No.: BCO-039-E. McKee, Authoring Judge. (SLC)

Cc Philip Berg

Cc Neil Sankey

Cc Linda Belcher

Cc Ed and Karen Hale

Category: Dossiers, Legal Actions


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Recent Posts
Important. Third Circuit Court of Appeals has denied all 11 motions and requests for judicial notice filed
by Attorney Philip Berg in his attacks on Attorney Orly Taitz and others
8032
8030
8027
8025

2/18/2010 2:43 PM
Case: 09-3403 Document: 003110135281 Page: 37 Date Filed: 05/07/2010

EXHIBIT “D”

Z:\Liberi Ltr to Judge Robreno Feb. 22, 2010 9


Case: 09-3403 Document: 003110135281 Page: 38 Date Filed: 05/07/2010

---------- Forwarded message ----------


From: Jawara King <jawaraking@yahoo.com>
Date: Thu, Feb 18, 2010 at 6:38 PM
Subject: Fw: Third Circuit Court of Appeals denied al 11 motions and requests for
judicial notice filed by Attorney Philip Berg in his attacks on Attorney Orly Taitz and
others
To: philjberg@gmail.com
Cc: Jawara King <jawaraking@yahoo.com>

----- Forwarded Message ----


From: Dr. Orly Taitz ESQ <dr_taitz@yahoo.com>
Sent: Thu, February 18, 2010 12:32:23 PM
Subject: Fw: Third Circuit Court of Appeals denied al 11 motions and requests for
judicial notice filed by Attorney Philip Berg in his attacks on Attorney Orly Taitz and
others

-- On Thu, 2/18/10, Dr. Orly Taitz ESQ <dr_taitz@yahoo.com> wrote:

From: Dr. Orly Taitz ESQ <dr_taitz@yahoo.com>


Subject: Third Circuit Court of Appeals denied al 11 motions and requests for judicial
notice filed by Attorney Philip Berg in his attacks on Attorney Orly Taitz and others
To: "Orly Taitz" <dr_taitz@yahoo.com>
Date: Thursday, February 18, 2010, 9:28 AM

Dr. Orly Taitz ESQ

29839 S. Margarita PKWY, ste 100

Rancho Santa Margarita CA 92688

02.17.10

Attention Honorable Eduardo Robreno

Request for Leave of Court to file and docket a 02.09.10. Third Circuit Court of
Appeals order denying all 11 Motions and requests for judicial notice filed by Philip Berg
on behalf of Appellants/Plaintiffs in Liberi et al v Taitz et al.
Case: 09-3403 Document: 003110135281 Page: 39 Date Filed: 05/07/2010

Your honor,

Plaintiffs in the above captioned case have bombarded the defendants and the courts
with hundreds and, by now, probably thousands of pages of pleadings of motions and
requests for judicial notices, most of which had absolutely nothing to do with the case at
hand and the order to show cause that was directed towards the plaintiffs. I am asking for
a judicial notice of one page only. The attached one page order from the Third Circuit
Court of Appeals denying all 11 motions and requests for judicial notice, shows that the
Third Circuit Court of Appeals does not see any emergency, that the plaintiffs claim and
does not see any relevance in all of those voluminous filings. It is consistent with the
findings of this court and it is an indication, that if the Court of Appeals didn’t see any
emergency now, it is reasonable to believe that there was no emergency half a year ago,
when your Honor denied plaintiffs request for the temporary restraining order against the
defendants. It strengthens the defendant’s position that indeed, there was no emergency
or damages to the plaintiffs, rather Attorney Philip Berg has filed this legal action with
an improper purpose of harassing and trying to silence the defendants, when I posted on
my web site true printout from the San Bernardino division of the Superior Court in CA
of ten felony convictions of forgery and grand theft committed by Berg’s assistant Lisa
Liberi. This publication was done with a proper purpose of alerting the public that any
piece of evidence, any document coming out of Berg’s office is suspect of forgery, due to
Liberi’s background and particularly in light of the fact that Mr. Berg has filed Affidavits
of Kenyan birth of Barack Obama in Eastern District of PA, Third Circuit Court of
Appeals and the Supreme Court of the United States and refused to show the original
documents to me or to a forensic document expert. While the media has named me the
“Queen of the Birthers” or the leader of the Birther movement, due to my legal actions to
unseal the original vital records of Mr. Obama and get a declaratory relief on the meaning
of the term Natural born citizen, as it applies to the article 2, section 1 requirement for
presidency, I am concerned that Mr. Berg’s actions in using a convicted document forger
as a legal assistant, and refusing to provide original documents, does not help the cause or
the underlying legal action, but rather undermines and muddies it and will destroy it,
when it will be heard on the merits. It is also an indication, that as an attorney and
president of the Defend Our Freedoms Foundation, I was justified in alerting the public
regarding the fact that on 04.11.09 my former volunteer web master Lisa Ostella has
changed the passwords and locked me out of the original DefendOurFreedoms website,
and from that date any and all donations received on that old web site did not benefit my
foundation, but rather benefit Ostella personally, as well as Attorney Philip Berg,
indirectly his assistant Lisa Liberi, as well as talk show host Evelyn Adams, all of whom
Ostella started promoting on the web site for my foundation after locking me out.

While most of the plaintiffs are lay persons, Berg is a licensed attorney and his actions
were direct violation of rules of professional ethics.
Case: 09-3403 Document: 003110135281 Page: 40 Date Filed: 05/07/2010

Respectfully submitted,

Dr. Orly Taitz ESQ

02/09/2010

ORDER (MCKEE and RENDELL, Circuit Judges) denying Motion by Appellants for
Expedited Ruling or to File a Restraining Order, requests Appellants for Judicial Notice,
Emergency Motion by Appellants to Expedite Interlocutory Appeal and Expedite Ruling
on Appellants Pending Motion, filed. Panel No.: BCO-039-E. McKee, Authoring Judge.
(SLC)

Cc Philip Berg

Cc Neil Sankey

Cc Linda Belcher

Cc Ed and Karen Hale

Dr. Orly Taitz ESQ


29839 Santa Margarita Pkwy ste 100
Rancho Santa Margarita Ca 92688
ph. 949-683-5411
fax 949-766-7603
orlytaitzesq.com
drtaitz.com
taitzofficesuites.com
Case: 09-3403 Document: 003110135281 Page: 41 Date Filed: 05/07/2010

From: Sam Sewell <sams@bestselfusa.com>


Date: Mon, Feb 22, 2010 at 1:55 AM
Subject: RE: Can anyone validate this or is it just wishful thinking on Orly's part?
To: Lisa Liberi <lisaliberi@gmail.com>

Thanks Lisa! I smelled a rat. I suspect you have seen her misleading Press Release. Do
I have your permission to use your remarks or will you or Phil make a statement that
refutes her story?

~~~~~~~~~~~~~~~~~~~~

From: Dr. Orly Taitz ESQ <dr_taitz@yahoo.com>


Subject: Third Circuit Court of Appeals denied al 11 motions and requests for judicial
notice filed by Attorney Philip Berg in his attacks on Attorney Orly Taitz and others
To: "Orly Taitz" <dr_taitz@yahoo.com>
Date: Thursday, February 18, 2010, 9:28 AM
Dr. Orly Taitz ESQ

29839 S. Margarita PKWY, ste 100

Rancho Santa Margarita CA 92688

02.17.10

Attention Honorable Eduardo Robreno

Request for Leave of Court to file and docket a 02.09.10. Third Circuit Court of Appeals
order denying all 11 Motions and requests for judicial notice filed by Philip Berg on
behalf of Appellants/Plaintiffs in Liberi et al v Taitz et al.

Your honor,

Plaintiffs in the above captioned case have bombarded the defendants and the courts with
hundreds and, by now, probably thousands of pages of pleadings of motions and requests
for judicial notices, most of which had absolutely nothing to do with the case at hand and
the order to show cause that was directed towards the plaintiffs. I am asking for a judicial
notice of one page only. The attached one page order from the Third Circuit Court of
Appeals denying all 11 motions and requests for judicial notice, shows that the Third
Case: 09-3403 Document: 003110135281 Page: 42 Date Filed: 05/07/2010

Circuit Court of Appeals does not see any emergency, that the plaintiffs claim and does
not see any relevance in all of those voluminous filings. It is consistent with the findings
of this court and it is an indication, that if the Court of Appeals didn’t see any emergency
now, it is reasonable to believe that there was no emergency half a year ago, when your
Honor denied plaintiffs request for the temporary restraining order against the defendants.
It strengthens the defendant’s position that indeed, there was no emergency or damages
to the plaintiffs, rather Attorney Philip Berg has filed this legal action with an improper
purpose of harassing and trying to silence the defendants, when I posted on my web site
true printout from the San Bernardino division of the Superior Court in CA of ten felony
convictions of forgery and grand theft committed by Berg’s assistant Lisa Liberi. This
publication was done with a proper purpose of alerting the public that any piece of
evidence, any document coming out of Berg’s office is suspect of forgery, due to Liberi’s
background and particularly in light of the fact that Mr. Berg has filed Affidavits of
Kenyan birth of Barack Obama in Eastern District of PA, Third Circuit Court of Appeals
and the Supreme Court of the United States and refused to show the original documents
to me or to a forensic document expert. While the media has named me the “Queen of the
Birthers” or the leader of the Birther movement, due to my legal actions to unseal the
original vital records of Mr. Obama and get a declaratory relief on the meaning of the
term Natural born citizen, as it applies to the article 2, section 1 requirement for
presidency, I am concerned that Mr. Berg’s actions in using a convicted document forger
as a legal assistant, and refusing to provide original documents, does not help the cause or
the underlying legal action, but rather undermines and muddies it and will destroy it,
when it will be heard on the merits. It is also an indication, that as an attorney and
president of the Defend Our Freedoms Foundation, I was justified in alerting the public
regarding the fact that on 04.11.09 my former volunteer web master Lisa Ostella has
changed the passwords and locked me out of the original DefendOurFreedoms website,
and from that date any and all donations received on that old web site did not benefit my
foundation, but rather benefit Ostella personally, as well as Attorney Philip Berg,
indirectly his assistant Lisa Liberi, as well as talk show host Evelyn Adams, all of whom
Ostella started promoting on the web site for my foundation after locking me out.

While most of the plaintiffs are lay persons, Berg is a licensed attorney and his actions
were direct violation of rules of professional ethics.

Respectfully submitted,

Dr. Orly Taitz ESQ

02/09/2010
Case: 09-3403 Document: 003110135281 Page: 43 Date Filed: 05/07/2010

ORDER (MCKEE and RENDELL, Circuit Judges) denying Motion by Appellants for
Expedited Ruling or to File a Restraining Order, requests Appellants for Judicial Notice,
Emergency Motion by Appellants to Expedite Interlocutory Appeal and Expedite Ruling
on Appellants Pending Motion, filed. Panel No.: BCO-039-E. McKee, Authoring Judge.
(SLC)

Cc Philip Berg

Cc Neil Sankey

Cc Linda Belcher

Cc Ed and Karen Hale

Dr. Orly Taitz ESQ


29839 Santa Margarita Pkwy ste 100
Rancho Santa Margarita Ca 92688
ph. 949-683-5411
fax 949-766-7603
orlytaitzesq.com
drtaitz.com
taitzofficesuites.com

On Mon, Feb 22, 2010 at 1:11 AM, Sam Sewell <sams@bestselfusa.com> wrote:

· Can anyone validate this or is it just wishful thinking on Orly’s part?

Third circuit court of Appeals denied all 11 motions and requests for judicial notice filed
by Attorney Philip Berg in his relentless attacks on Attorney Orly Taitz and others

FOR IMMEDIATE RELEASE

Third circuit court of Appeals agrees with Taitz


Case: 09-3403 Document: 003110135281 Page: 44 Date Filed: 05/07/2010

EXHIBIT “E”

Z:\Liberi Ltr to Judge Robreno Feb. 22, 2010 10


Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/
Case: 09-3403 Document: 003110135281 Page: 45 Date Filed: 05/07/2010
http://www.orlytaitzesq.com/

Dr. Orly Taitz Esquire


Defend Our Freedoms Foundation – 29839 Santa Margarita Pkwy, ste 100, Rancho Santa Margarita CA, 92688 – Copyright 2009

World's Leading Obama Eligibility Challenge Web Site


Your donations to the cause are much appreciated.

The articles posted represent only the opinion of the writers, do not necessarily represent the opinion of Dr. Taitz, ESQ, and Dr. Taitz, ESQ has no means of
checking the veracity of all the claims and allegations in the articles.

Posted on | February 20, 2010 | 1 Comment


Flag this message

Third circuit court of Appeals denied all 11 motions


and requests for judicial notice filed by Attorney
Philip Berg in his relentless attacks on Attorney
Orly Taitz and others

2/21/2010 12:46 AM
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/
Case: 09-3403 Document: 003110135281 Page: 46 Date Filed: 05/07/2010

FOR IMMEDIATE RELEASE

Third circuit court of Appeals agrees with Taitz

orlytaitzesq.com
newsletter@orlytaitzesq.com
Fax: 949-766-7603
Phone: 949-683-5411
RSM, CA 92688
29839 Santa Margarita
Dr. Orly Taitz, ESQ.
CONTACT INFO:

Home

Dr. Orly Taitz Esquire


Defend Our Freedoms Foundation – 29839 Santa Margarita Pkwy, ste 100,
Rancho Santa Margarita CA, 92688 – Copyright 2009

World’s Leading Obama Eligibility Challenge Web


Site
Your donations to the cause are much appreciated.

Law Offices of Dr. Orly Taitz, Esq.

02/09/2010 ORDER (MCKEE and RENDELL, Circuit Judges) denying Motion by Appellants for
Expedited Ruling or to File a Restraining Order, requests Appellants for Judicial
Notice, Emergency Motion by Appellants to Expedite Interlocutory Appeal and
Expedite Ruling on Appellants Pending Motion, filed. Panel No.: BCO-039-E.
McKee, Authoring Judge. (SLC)
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/
Case: 09-3403 Document: 003110135281 Page: 47 Date Filed: 05/07/2010

Dr. Orly Taitz ESQ


29839 S. Margarita PKWY, ste 100
Rancho Santa Margarita CA 92688

02.17.10
Attention Honorable Eduardo Robreno

Request for Leave of Court to file and docket a 02.09.10. Third Circuit Court of
Appeals order denying all 11 Motions and requests for judicial notice filed by
Philip Berg on behalf of Appellants/Plaintiffs in Liberi et v Taitz et al.

Your honor,
Plaintiffs in the above captioned case have bombarded the defendants and the
courts with hundreds and, by now, probably thousands of pages of pleadings of
motions and requests for judicial notices, most of which had absolutely nothing to
do with the case at hand and the order to show cause that was directed towards the
plaintiffs. I am asking for a judicial notice of one page only. The attached one page
order from the Third Circuit Court of Appeals denying all 11 motions and
requests for judicial notice, shows that the Third Circuit Court of Appeals does
not see any emergency, that the plaintiffs claim to have and does not see any
relevance in all of those voluminous filings. It is consistent with the findings of this
court and it is an indication, that if the Court of Appeals didn’t see any emergen!
cy now, it is reasonable to believe that there was no emergency half a year ago,
when your Honor denied plaintiffs request for the temporary restraining order
against the defendants. It strengthens the defendant’s position that indeed, there
was no emergency or damages to the plaintiffs, rather Attorney Philip Berg has
filed this legal action with an improper purpose of harassing and trying to silence
the defendants, when I posted on my web site true printout from the San
Bernardino division of the Superior Court in CA of ten felony convictions of
forgery and grand theft committed by Berg’s assistant Lisa Liberi. This
publication was done with a proper purpose of alerting the public that any piece
of evidence, any document coming out of Berg’s office is suspect of forgery, due to
Liberi’s background and particularly in light of the fact that! Mr. Berg has filed
in Ea stern District of PA, Third Cicuit Court of Appeals and the Supreme Court
of the United States affidavits of Kenyan birth of Barack Obama and refused to
show the original documents to me or to a forensic document expert. While the
media has named me the “Queen of the Birthers” or the leader of the Birther
movement, due to my legal actions to unseal the original vital records of Mr.
Obama and get a declaratory relief on the meaning of the term Natural born
citizen, as it applies to the article 2, section 1 requirement for presidency, I am
Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/
Case: 09-3403 Document: 003110135281 Page: 48 Date Filed: 05/07/2010

concerned that Mr. Berg’s actions in using a convicted document forger as a legal
assistant, and refusing to provide original documents, does not help the cause or
the underlying legal action, but rather undermines and muddies it and will
destroy it, when it will be heard on the merits. It is also an indication, that as an
attorney and president of the Defend Our Freedoms Foundation, I was justified in
alerting the public regarding the fact ! that on 04.11.09 my former volunteer web
master Lisa Ostella has changed the passwords and locked me out of the original
DefendOurFreedoms website, and from that date any and all donations received
on that old web site did not benefit my foundation, but rather benefit Ostella
personally, as well as Attorney Philip Berg, indirectly his assistant Lisa Liberi, as
well as talk show host Evelyn Adams, (Momma E) all of whom Ostella started
promoting on the web site for my foundation after locking me out.
While most of the plaintiffs are lay persons, Berg is a licensed attorney and his
actions were direct violation of rules of professional ethics.

Respectfully submitted,

Dr. Orly Taitz ESQ

Cc Philip Berg
Cc Neil Sankey
Cc Linda Belcher
Cc Ed and Karen Hale

29839 Santa Margarita PKWY, Suite 100,


Rancho Santa Margarita, Ca 92688
Phone 949-683-5411, fax 949-7667603\
Dr_taitz@yahoo.com orlytaitzesq.com

Category: Uncategorized
Case: 09-3403 Document: 003110135281 Page: 49 Date Filed: 05/07/2010

EXHIBIT “2”

19
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Ed Hale Dr Taitz trun the tables on Berg - Read this Quote Reply

No. 09 3403
UNITED STATES COURT OF APPEALS
May 6, 2010 - 12:33AM FOR THE THIRD CIRCUIT
____________________
LISA LIBERI, et al.,
Plaintiffs-Appellants,
vs.
ORLY TAITZ, et al.,
Defendant-Appellee.
__________________
District Court No. 09_cv_01898_ECR
Eastern District of Pennsylvania
__________________
Motion to Strike and/or Extension of Time to File Sur Reply by
Appellees in Response to Appellants’Reply
__________________
DR. ORLY TAITZ, ESQ.
CSB #223433
Attorney Pro Se &
Attorney for Defend Our Freedoms Foundation
29839 S. Margarita Pkwy. Rancho Santa Margarita CA 92688
ph. 949-683-5411
fax 949-586-2082

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I. INTRODUCTION

Appellees Dr. Taitz and Foundation (hereinafter referred to as


appellees) are aghast at the reply brief by Berg, Office of Berg, Liberi,
Ostella, Adams, and Go Excell Global (appellants) totaling 22 pages
with seemingly hundreds of pages of exhibits attached full of horrific
slander. Taitz would like to remind this court that not one single
document, not one word coming out of the office of Philip Berg can be
considered as true and genuine and given full face value without an
analysis of a forensic document expert, simply because all of the
“documents”and “affidavits” submitted are prepared and handled by
Berg’s assistant Lisa Renee
Liberi (aka Lisa Liberi Richardson), who is a career forger with some
ten convictions of forgery of documents, forgery of an official seal and
grand theft. (Exhibit 1 Opposition to request for TRO with exhibit San
Bernardino County, CA Superior Court Convictions Record of Lisa
Liberi). Therefore the only document, that would have any value in
considering this interlocutory appeal would be the transcript of the
08.07.2009 TRO motion hearing in front of judge Robreno, which is at
issue in this appeal . Attorney Berg was told by the clerk of judge
Robreno, that he needs to file a motion to unseal the transcript of the
TRO hearing, at which judge Robreno has denied Berg’s TRO motion.
Upon the order to unseal, Berg could pay for the transcript and submit
it to this Honorable court for Appeals. First of all the pattern of fraud
committed by Berg is easy to trace by
looking at the short reply from Marcia Waldron, clerk of USDC for the
Eastern district of PA. She states clearly “Counsel was also notified
that the proceedings held April 7, 2009 was under seal and an order of
court would be necessary to unseal the proceedings and have a
transcript produced. To date our office has not received payment, a
motion to unseal has not been docketed not has a transcript purchase
order form been submitted to the District Court” For nine month Berg
and the rest of the appellants have harassed this court. District court
and appellees with hundreds of pages of defamatory material, yet
Berg never admitted the fact that he never filed a short motion to
unseal the transcript. Attorney Berg has never truthfully admitted his
failure to file this one page motion to unseal the transcript. Why didn’t
Attorney Berg file one short motion with judge Robreno to obtain the
transcript? Why instead did he bombard both Judge Robreno and this
court with hundreds of pages of garbage, consisting of horrific
slander, perjury, defamation of character, prepared by Appellant
Liberi, (legal assistant of appellant Attorney Berg) who has ten
convictions of forgery of documents, forgery of an official seal and
grand theft (Superior court of CA case FSB-044914, Hon M Pacheco,
Superior Court of CA Case no FWV 028000 Gerard W. Brown People of
the state of CA v Lisa Renee Richardson (aka Liberi)), as well as by
Lisa Ostella, who admitted to forging signature of Appellee attorney
Taitz, falsely claiming that Taitz allowed her to forge her signature
and who diverted funds from the foundation which is run by Taitz; by
Convicted felon Lucas Smith and by Convicted felon and indicted
forger Charles Lincoln? The
answer is simple. If Berg were to provide this court with the

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transcript, it would be clear to this court that judge Robreno has


made a correct decision in denying Berg’s TRO motion, that all of the
allegations were nothing but slander, harassment, perjury and
hearsay. If this court would like to indulge in reading the transcripts
of the hearings of Liberi’s prior criminal proceedings, this court will
see a clear modus operandi, where Liberi takes bits and pieces of
different documents, signatures, seals, pastes them and creates
“documents”of her own, whereby in the state of CA she has stolen
hundred of thousands of dollars from victims using forgery, perjury
and fraud. When apprehended, she has mounted horrible allegations
against everybody in the vicinity, including arresting officers, district
attorney, employees of the correctional institutions, San Bernardino
county and so on. Her right to bring legal actions in Ca was limited
due to her actions. Liberi was convicted recently, in 2008, and her
prison term was reduced to probation due to health reasons. Only a
few months after Liberi plead to ten felony counts, including forgery
of documents, Berg started employing her and submitted to the
Eastern District of PA, as well as this Honorable court and the
Supreme Court of the United States a complaint in a case Berg v
Obama. Shortly after submitting the case Berg and Liberi made
appearances on radio talk shows, including the shows of Appellant
Evelyn Adams and Appellee Ed Hale. On a number of shows Berg
stated that Liberi is his able legal assistant, who prepared the case of
Berg v Obama, where Berg submitted to court affidavits from Kenya
attesting to Barack Obama’s birth there.
Appellee Taitz is a licensed attorney in CA, admitted in the Supreme
Court of the United States, she is a Doctor of Dental Surgery as well
and a candidate on the Ballot running for the position of the Secretary
of State of Ca. Taitz is a president of the Defend Our Freedoms
Foundation. She was contacted by Appellant Lisa Ostella, who offered
her services as a volunteer web master and who routinely volunteers
as a web master for a number of politicians and community leaders.
When Taitz found out that her web site pay-pal account was hacked,
she reported this event to the FBI immediately. Ostella has
threatened, that if Taitz does not withdraw her complaint to FBI, Taitz
will not be allowed to use Ostella’s web server. When Taitz refused to
withdraw her complaint to FBI, Ostella used her privilege of a web
master, locked Taitz from the web site of her foundation and
continued soliciting donations from unsuspecting donors. Later, in the
pleadings submitted to this court she admitted to forging Taitz
signature, but falsely claimed that Taitz permitted her to forge her
signature. When problems with Ostella unfolded, Taitz was contacted
by a former volunteer of Philip Berg, Linda Belcher, appellee in this
case, who related to Taitz, that an assistant for Berg, Lisa Liberi also
might be involved in financial improprieties. Belcher related to Taitz
her knowledge regarding Liberi’s criminal record of forgery and theft.
Taitz has verified this record with the investigator Sankey, appellee in
this case, with District Attorney James Secord, her arresting officer
and her probation officers Dawn Hellwig and Rose Bobchack. Taitz
has contacted Berg and forwarded to Berg excerpts of Liberi’s
criminal convictions. Taitz has related to
Berg that she has legal cases, where she included by reference
information provided by Berg in Berg v Obama, specifically affidavits

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Case: 09-3403 Document: 003110135281 Page: 53 Date Filed: 05/07/2010

from Kenya, regarding Obama’s birth there. Taitz has asked Berg to
allow her and a forensic document expert to examine the originals of
those affidavits, as there was a high likelihood of forgery due to
Liberi’s recent convictions. Taitz has also advised Berg that he may
want to bring an account to review the donations received in light of
Liberi’s recent convictions of grand theft. Any attorney with any
measure of integrity and respect for the law and the system of
justice, with a drop of professional ethics in his blood would have
disassociated himself from an individual of such questionable past
and would advise this court and other courts of a possibility of forgery
in the documents submitted. Instead, Berg has filed an absolutely
frivolous legal action against all of the appellees, seeking to keep
them silent, he filed a ridiculous legal action for nearly a billion
dollars and continued bombarding appellees with hundreds and
hundreds of pages of garbage, with no connection to the case. Berg
teamed up not only with Liberi, but also with Ostella and a couple of
other individuals with past convictions or indictments of forgery and
fraud. Currently Berg and his associates are advertising an eligibility
and anti-healthcare bill march on Washington and soliciting donations
nationwide for that march. While Taitz shares concerns regarding the
eligibility and the Health care bill on Constitutional grounds, she is
concerned about individuals like Berg, Liberi and Ostella causing real
damage to those issues and to the public at large. Taitz simply
became an attorney, who exposed Berg and his associates, their
past and dealings, she is an attorney in the way, and Berg has rubber
stamped pleadings coming from his associates with one goal of
attacking Taitz and taking heat of himself and possible criminal
prosecution of himself, Liberi and Ostella.
Berg is fully aware that Taitz never violated any orders and Berg’s
allegations are nothing but fraud on the court. For example, Berg
knows that Taitz does not own a web site repubex, that she used that
website for a couple of weeks over a year ago, when Ostella locked
her out of her website. Taitz has presented this information a year
ago, (exhibit Motion to dismiss Due to Lack of Jurisdiction exhibit 3)
Berg knows fully well that Taitz had nothing to do with that web site
for over a year and used her own web site OrlyTaitzEsq.com, yet Berg
continues to defraud the court by falsely accusing Taitz of violating
orders. Taitz does not want to waste the time of this court with piles
of documents, but rather submits a couple of documents, that
illustrate the actions of Liberi. Exhibit 1 05.28.2009 Opposition to
TRO, which contains Liberi’s criminal record, showing multiple recent
convictions, and exhibit 4 testimony of officer Liebrich during Liberi’s
bail hearing regarding Liberi’s threats against her sister Cheryl
Richardson. The transcript states that when Cheryl Richardson
started cooperating with police and implicated Liberi in the case
being tried and provided information regarding Liberi’s thirteen prior
criminal charges, Liberi has stated in recorded phone call from jail,
that she wants to have her sister framed, arrested and she wants to
spread the word in the prison population, that her sister is a rat. She
proceeded telling her
husband “you know what they do in prison to rats”. When asked by
the court “what happens when inmates discover that another inmate
is a snitch?”officer Liebrich responded “ There is what is known as a

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contract, a green light on them. Different things; they are attacked


and /or killed. In fact, you brought up L.A. County, in the last year five
have been killed within the jail system”. Taitz has provided Berg with
this information and related to him that his continuous harassment of
Taitz and other appellees puts everybody in danger, particularly in
light of Liberi’s extensive criminal past and violent propensities.
Again, instead of putting an end to his frivolous law suit, Berg went
further and rubber stamped and submitted to this court absolutely
horrific, despicable, false slanderous accusations about Taitz.
Without a shred of evidence Berg accused Taitz of seeking
professional help in kidnapping Ostella’s children. Clearly such insane
horrific accusation could only be concocted in a violent criminal mind
of Liberi, however the bigger problem is the fact that Berg, a licensed
PA attorney has put his name and signature on this slander and
submitted this horrendous defamation of character as a fact. People
like this should not be allowed to practice law. This is an attorney,
who submitted to this very court and the Supreme Court of the US in
Berg v Obama documents prepared by a recently convicted forger,
this is an attorney who is conducting Nationwide donations drive
using a recently convicted thief as his assistant, this is an attorney,
who is hurling accusation with zero evidence to support them. Berg
and his clients, the rest of the appellants, are so dangerous to the
society that Taitz is asking this Honorable court not only to grant
her motion to strike Berg’s latest filing with hundreds of pages of
defamation of character, but she is also asking this court sua sponte
to forward the pleadings presented in this case to the Attorney
General of Pennsylvania and District Attorney of Philadelphia for
purpose of criminal investigation and prosecution of Berg, Liberi,
Ostella and their associates for perjury, forgery, uttering, fraud upon
the court and Liberi’s multiple violations of her probation.
Additionally Berg’s latest motion violates rules of this court.
Appellees seek either that the reply brief be stricken in its entirety or
permission to file a detailed sur reply brief of equal length be granted
to refute the libel per se allegations of criminal activity in the reply
brief. Appellees further seek attorney fees in the amount of their
actual costs to be submitted to the court upon resolution of this
matter.
Appellees further request that Berg be referred to the Third Circuit
Court Disciplinary Committee for investigation of ethical breeches in
that he has used an appellate proceeding to make unfounded
desperate criminal accusations against Appellee Dr. Taitz. Those
insane vicious slanderous accusations are a matter of public record,
appellee Taitz is a candidate on the California primary ballot for the
position of California Secretary of State in a tight two candidate race
and appellants are trying to derail that candidacy.

II. THE REPLY BRIEF VIOLATES THE RULES

FRAP Rule 27(a)(4) states “A reply must not present matters that do
not relate to the response.”Appellants’entire reply brief is largely an
attempt to manipulate Rule 27 by claiming anything and everything
including false allegations of kidnapping children and unauthenticated
exhibits of hearsay are relevant to rebut the allegation that

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Case: 09-3403 Document: 003110135281 Page: 55 Date Filed: 05/07/2010

appellants’motions to date and indeed the underlying appeal are


frivolous. The unauthenticated Grimm’s fairy tales of Dr. Taitz being
submitted by appellants would be almost laughable were it not for
appellants’penchant for republishing this muck once it obtains the
court’s file stamp.
Appellants have also ignored page limits, the unauthenticated and
bad faith exhibits not withstanding. A reply brief is limited to 10 pages
under FRAP Rule 27(d)(2) and not the 22 pages plus hundreds of pages
of nonsense exhibits and tall tales about appellees. The reply brief
should be stricken on page limit abuse alone.

III. THE UNAUTHENTICATED EXHIBITS


ARE SCANDALOUS AND SHOULD BE STRICKEN

The exhibits dealing with unauthenticated libelous allegations of


kidnapping, conspiracy to commit murder and other criminal acts
should be stricken in their entirety. Those allegations represent
nothing but vicious slander. They have nothing to do with appellants’
motion to dismiss nor do they respond to appellees’points about
appellants’previous abusive filings or inability to secure a transcript.
See generally USX v. Liberty Mutual, 444 F.3d 192, 202 (3rd Cir. 2006)
for the proposition that a motion to strike is to be granted when a
brief goes beyond the underlying purpose of the proceeding.

IV. A SUR BRIEF SHOULD BE GRANTED IN THE ALTERNATIVE TO A


MOTION TO STRIKE TO PERMIT RESPONSE TO CRIMINAL
ALLEGATIONS AND THE REQUEST FOR SANCTIONS

As noted, appellee Dr. Taitz is horrified and shocked that she is being
accused by appellants including an attorney still in good standing of
conspiracy to kidnap children and commit perjury. Appellees are
entitled to a full response of these hideous allegations if they are not
stricken.

V. SANCTION ARE WARRANTED

This court should sua sponte sanction attorney Berg and appellants.
Berg has put his signature on these horrific slanderous allegations
against Dr. Taitz. Berg has teamed up with felons in slandering Taitz
without any basis with a goal of silencing her. Berg is fully aware that
Taitz never violated any orders, never did anything illegal, never
caused any harm to appellants. Berg and appellants are acting with
depraved indifference to the truth and has harmed Taitz, her
reputation, her family, have caused severe emotional distress and
severe financial damage in having to fly to Philadelphia to the District
Court hearing, having to read thousands of pages of defamation that
they threw at her, having to respond to numerous motions and
requests for judicial notice. In this court alone Berg has filed 11
(eleven) motions and requests for judicial notice with hundreds and
hundreds of pages completely unrelated to the interlocutory appeal
of the decision by judge Robreno made in August of 2009. Berg was
fully aware that what he is filing, is nothing but slander and unrelated
material, yet he did it to harass Taitz into silence and to prejudice the

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court against her.

VI CONCLUSION

The appellants’reply brief goes beyond anything appellee has ever


witnessed before, attorney Berg and the rest of the Appellants have
acted in a totally depraved manner, with total and complete disregard
to the truth and to the rule of law. They have manufactured
allegations without a grain of truth. While this behavior can be
expected from convicted felons like Liberi and Lincoln, actions of PA
licensed attorney Berg are absolutely despicable and diabolical. Berg
knows that Taitz has simply exposed him and his associates, that he
was caught submitting to this very court documents prepared by a
recently convicted forger, he knew that there is a very high likelihood
of forgery, he knows that his law license is in danger and his
associates out of total desperation created all of the above slander to
kill the messenger. The courts should not be used as a free for all to
commit defamation against other parties and accuse them of capital
crimes. Liberi has used the strategy of inventing allegations against
the law enforcement before in order to reduce her sentence and make
a deal. Liberi and Berg are defrauding this court and manufacturing
evidence, simply because they know that if the law is enforced,
Liberi’s probation will be revoked and she will be going back to prison
in California to serve her eight year term. Berg and the rest of the
appellants know that there is a good possibility of them following
Liberi.
Criminals should not be allowed to manufacture horrendous
defamatory allegations in order to harass the victims and harass
attorneys who exposed them. Bottom line, Attorney Berg was told by
the district court to file just one simple motion to unseal the
transcript and submit it to the court of appeals. Berg has never filed
this one simple motion and caused Taitz severe emotional distress
and financial damages by filing hundreds of pages of unrelated
motions, therefore his reply to response should be striken from the
record, the appeal should be dismissed with prejudice and the
appellees should be reimbursed their costs and fees.
DATED: May 4, 2010
/s/ Dr. Orly Taitz, Esq
Orly Taitz, Appellee in Pro Se and as Counsel for Appellee Defend Our
Freedoms Foundation

State Texas

Ed Hale Here are the exhibits Quote Reply

Click on the link below to veiw the evidences

May 6, 2010 - 12:58AM Liberi threatening her sister from jail


http://www.plainsradio.com/PLAINS~1/berg1.html

Letter from the district court clerk


http://www.plainsradio.com/PLAINS~1/berg2.html

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Case: 09-3403 Document: 003110135281 Page: 57 Date Filed: 05/07/2010

State Texas

Little Green Apples Re: Here are the exhibits


Quote Reply

I didn't follow Berg for the simple fact he was goofy after Sept 11th,
always considered him quite the lunatic.
May 6, 2010 - 3:04PM
After reading this I have to say that every single one that seems some
how associated with him are lunatics too?

A billion dollars? Lawsuit? Pleaseee

Kidnap children? What are these people smoking?

Quote:

Originally Posted by Ed Hale


Click on the link below to veiw the evidences

Liberi threatening her sister from jail


http://www.plainsradio.com/PLAINS~1/berg1.html

Letter from the district court clerk


http://www.plainsradio.com/PLAINS~1/berg2.html

State Truth

Ed Hale Berg got caught with his pants down. Quote Reply

Dr. Taitz pointed out the error in Berg filing over the 10 pages and
now Berg want the court to say that it was ok. Here is Berg motions
May 6, 2010 - 3:25PM (after the fact)

1
U.S. District Court,
Eastern District of Pennsylvania Case Number: 09-cv-01898 ECR
Court of Appeals Case Number: 09-3403
UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
_____________ Ο _____________
LISA LIBERI, et al,
Plaintiffs’– Appellants’,
v.
ORLY TAITZ, et al,
Respondents’–Appellees’.
____________ Ο _____________
APPELLANTS’MOTION FOR LEAVE OF COURT TO EXCEED THE PAGE
LIMIT IN THEIR REPLY TO APPELLEES, ORLY TAITZ AND DEFEND
OUR FREEDOMS FOUNDATIONS, INC. OPPOSITION TO APPELLANTS

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MOTION TO WITHDRAW THEIR APPEAL or in the ALTERNATIVE


APPELLANTS MOTION TO DISMISS THEIR APPEAL PURSUANT TO
FEDERAL RULES OF CIVIL PROCEDURE, RULE 42(b) and
APPELLEE’S REQUEST FOR SANCTIONS
_____________________
2
Appellants’, Lisa Liberi [hereinafter “Liberi”]; Philip J. Berg, Esquire
[hereinafter “Berg”], the Law Offices of Philip J. Berg; Evelyn Adams
a/k/a
Momma E [hereinafter “Adams”]; Lisa Ostella [hereinafter “Ostella”];
and Go
Excel Global by and through their undersigned counsel, Philip J. Berg,
Esquire,
hereby files the within Motion to File Pages in Excess of the Ten (10)
Page Limit
on Reply’s pursuant to Federal Rules of Appellate Procedure [F.R.A.P.]
27(d)(2).
Appellees Orly Taitz [hereinafter at times “Taitz”] and Defend our
Freedoms Foundations, Inc. [hereinafter “DOFF”] filed an Opposition
to
Appellants’Motion to Withdraw their Appeal or in the alternative, their
Motion to
Dismiss their Appeal Without Costs pursuant to F.R.A.P. 42(b). In
Taitz’s
Opposition, she raised numerous issues and many false accusations
which
Appellants must address appropriately. Unfortunately, Appellants are
unable to do
so without exceeding the ten (10) page limit in F.R.A.P. 27(d)(2),
complexity of
the matters. In addition, Appellees Taitz and DOFF also request costs
and
sanctions, which also needed to be properly addressed.
Appellants’filed their Reply to Taitz’s Opposition on May 1, 2010,
however, the Reply is twenty-two (22) pages, which exceeds the ten
(10) page
limit. Without Leave of Court to File in Excess of ten (10) pages,
Appellants’are
not able to properly respond to and/or address Taitz’s Opposition and
properly
respond to Taitz’s request for Costs and Sanctions.
3
WHEREFORE, for good cause shown, Appellants respectfully request
this
Court to grant their Motion for Leave to File their Reply, which was
filed May 1,
2010, in excess of ten (10) pages.
Respectfully submitted,
Dated: May 5, 2010 ____________________________
Philip J. Berg, Esquire
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
(610) 825-3134

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Attorney for the Appellants’


s/ Philip J. Berg

Only one problem here for Berg. He states that DR. Taitz lied to the
court and yet he has not presented one ounce of proof other that
shooting off his big mouth claiming all kinds of stuff.
Dr. Taitz laid it on him with proof that he was lying to the court. Berg
need to get out of the lawyer business because he is such a poor one.
Now he is wanting to lead a march to DC. Wonder how much money
will they get for this one?

State Texas

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Ed Hale Here are the exhibits Quote Reply

Click on the link below to veiw the evidences

May 6, 2010 - 12:58AM Liberi threatening her sister from jail


http://www.plainsradio.com/PLAINS~1/berg1.html

Letter from the district court clerk


http://www.plainsradio.com/PLAINS~1/berg2.html

State Texas

Index

2 of 2 5/6/2010 2:05 PM
berg1 - Window Title
Case: 09-3403 Document: 003110135281 Page: 62 Date Filed: 05/07/2010

http://www.plainsradio.com/PLAINS~1/berg1.html - Page URL5/6/2010ate


Case: 09-3403 Document: 003110135281 Page: 63 Date Filed: 05/07/2010

U.S. District Court,


Eastern District of Pennsylvania Case Number: 09-cv-01898 ECR
Court of Appeals Case Number: 09-3403

UNITED STATES COURT OF APPEALS


FOR THE THIRD CIRCUIT
_____________ Ο _____________

LISA LIBERI, et al,


Plaintiffs’ – Appellants’,
v.
ORLY TAITZ, et al,
Respondents’ – Appellees’.
_____________ Ο _____________

CERTIFICATE OF SERVICE
_____________________

I, Philip J. Berg, Esquire, hereby certify that Appellants’ Objections;

Opposition; Request to Strike Taitz Motion to Strike filed May 7, 2010; and

Request for Sanctions and Attorney Fees was served upon Appellees, this 7th day

of May 2010 electronically upon the following:

Orly Taitz
Defend our Freedoms Foundation, Inc. (unrepresented)
26302 La Paz Ste 211
Mission Viejo, CA 92691
Email: dr_taitz@yahoo.com
And by Fax to (949) 766-7603

20
Case: 09-3403 Document: 003110135281 Page: 64 Date Filed: 05/07/2010

CERTIFICATE OF SERVICE, Continued

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;
ed@barhfarnet; and ed@plainsradio.com

________________________
s/ Philip J. Berg
PHILIP J. BERG, ESQUIRE

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