Honorable Eduardo C.

Robreno
United States District Court
for the Eastem District of Pennsytvanla
11614 U.S. Courthouse
601 Market Street
Philadelphia, PA 19106-1797
Fax: 267-~7"2e

U.S. District Court.

Eastern District of Pennsylvania Case Number: 09..cv-01898 ECR

USA LIBERI, et .1,

Plaintiffs'
~.

ORLY TAf1Z, et .1,

Respondents

cc: Dr OrIy Tlitz

Via fax 949-766-7603

June 23, 2010

Your Honor,

I am Unda S. &eIcher, appearing Pro Se in this a ction. Finl. I wont to alert

Your Honor Ihat as of this dote, I HAVE NOT RfCflVED ANY CO"'ES OF
IfRG'S FIUNGS WITH ANY COURT SINCE THE WITHDUWAl OF OUIl FORME.
ATTORNEY, flO Hor,r, LA5T YEAR. I have Nltle knov...1edge of what has
been filed by Berg since that lime.

8efg previovsly slated 10 me that his compuler has been damaged many
limes due to moIwore. trojans. etc. Therefore, I wI1 NOT acc ept any
electronic moll from him, e spedoUy attachments. He has been ..,Iomled
severai limes defendonts wDI not accept lmpropef electronic service that
could Infect our computen. &erg w.. knows I t.ave not recehl.ct Copiel of
his fIingI o. evidenced by his own .worn aII\davIts flied In thb court. Your
Honor, hrg stated In on .... krdocument that he I. blocked from MfldIng
me any etec:tI'ontc maIIngs. Thfief0f8 he knows he dkt not pfavlde me
copes of any of hlI pteodlng • •

Your Honor. 'have not agreed to anything by omlssJon 0' I om told Berg
suggests. Berg has creotftd a serious con/liet of Interest In represenHng
other plaintiff's. at the.some time he represents hlmself, when he sween
OG / U J 2010 U : 34 FAX ...
caples were sent to 0/1 defendants especially when he stands 10 profit In
potential financial rewords by causing defaUlt. Berg was not required to
produce basic documentation to this court thOt 0/1 poriies wele property
served and nolified. which gives Berg on additional untalr advantage
over d efendants appearing Pro Sel Berg benefits materially at my/our
e)(pense in failure of this court to ensure oN defendants have been
notified, 'O~Ufe to award financial damages to us tor attomey 's fees,
failure to ensure a Just process denying defendants equal protection
under th e rules of dv/l procedure and /he Conslilution, failure to prevent
harassme nt of defendants by Berg et 01. failure to prevent undue me ntal
ond emotional stress. raNUIe to dismiss this suit when Berg kne w it was
Improper venue, as weN as the shock , received a couple of days ago
aHer the lotest ruling was mode on Of about June 2, 2010. I sent a letter to
Your Honor before that ruling, but it apparently disappearedl Berg has
knowingly violated his oath as on officer of the court by making false
sworn statements to the court in every document he hos submiHed to
YOlX Honor and should rece ive significant sancfiom. He has knowingly
UfO to this court In every possible way and preve nted me from the luxury
of making a proper response to his ongoing smears and lies.

I am requesHng that Your Honor', rvlfng on or about JUM 2, 2010 and any
othef 'ubs.quenl rulngl tNt voc:at.d 10 that I may obtain copa.. of hfg'.
~d1ng. and make proper r.spon.. 10 hi. many Fal.. ~ •.
Failure to vocate creates an untenable lltuaHon for d.r~ant/' and
Impo... unrepre..nted defendanll wtth an additional burd.n by th.laek
of '<*n••• and glv•• the Impressfon thl. covrt I. giving a local attorney
unfair advantage ov. out of Jtote ~anh. I IeeIIt I. particularly unfair
allerg was alloWed to wfthdraw hi. aefton, again" KIm. ct.t.ndanll and
not oR to Impoct dlv.1Ity wtth ,..pect to the other ctet.ndants.

I can 0110 provide e xtensive evidence proving pialnttfl Ubeff Dv•• In HM,
not P'A 01 .Iatltd In Your Honor'. last fUIng, which Is the bas" for thb .mh
case. Uberi did not reside In PA os alleged prior to filing this suit. Adorns,
Berg and Uberl hOve each repeatedly stated during radio appearances
the NM Uberi is a convicted felon ond tllat we hav~ defamed plaintiffs by
insisling she Is the same Usa Uberi, living in Santo Fe, NM. 7he /(Jnguage of
Yo,"" Honor', lUlIng Ihat Uberl reJlde./n PA uphold. the fraud ltJey are
".,-petuoHng on donon and the court, and Uling thll potflcukJt language,
Iobel. defendonts Iiors and dltfomen OM couIG co,, In furlh., damage,
giving fUf'ttte1 untofr advomag. #0 IeIg and in HI. procell, malte. Your
Honor an un'lflfffnfl porlnerl. fhb fraudulent ,chern. OQOIn,t the public,

Yaur Honor made a ruling without requiring proof Uberi lives In PA and
suggests serious implications that such a finding hod been documented.
011 2411010 U : H FAl

Berg, Uberl and Adams willlJSe this rvIing to sIal. to the world that Uberl
does not reside In NM. but fA when It Is a blatant froooiMnt fabricatlonl
As a result of the language used In slating Uberi rives in PA we also face
possible financial consequencltsl This gives another unfair advanlage to
plaintiff's afler Berg /led 10 creote a d efouH by lhis defendant.

Berg and I were online friends since 1998, but hod on irrevernble rill on or
about March .0411'1, 2009. We never met In person, nor have I ever been to
PA. ~ and a.rg knew I would be an oppoafKon wttn.u to expo. . their
fal . . .wom afIktavfI1 mode against the other d.,enc!OMs and Included me
In a bIatont ohmpf to dbc:recIt and harou me. Berg has perpetuated a
gross fraud on this court and also monlpvloled Your Honor In order to
smear IJ$ and aggravate our variov1 health issues. Berg, UberI and Adams
hove exac erbated my grief and paIn as muc h and as o ften as possible.

The history leodjng up /0 the fiUng of this suit Is as foTlows. When I was
banned on March 6, 2009: 1efV'. bIog IHtgon dyfng and.upporl tot htg
wan.d ~ .upporiw1 (who donatftd Iarge.umt offundJ 10 htg)
Ncome up'" when" WGai ,.v.oMd by Obgmg IUQpQffllrJ rhot UberI, a
convlct.d felon, WOI handling donan cIWdIt card Informolion, rtad acc...
to thes. donatioN: ond"""'erg kn_1.Jberi hod on extensive felony
criminal lecard InvotAng theftt, Ifnottdal emn.s and ~j. SUpport
shifted toward others, but esp&ciolly towards Dr loin.. Berg, Uberi and
Adams blamed me lor nollylng about Uber1l1vlng In NM, Insteod of PA os
they falsely allege. In retaliation for warnings by Dr laltz, the Hole's and
myself publicly to dooors !we hod no other way to worn d a noo 0$ we
didn' t hove their con tact info or names) that their info was compromised
by Berg employing 0 convicted telon os his pcroIegol; &erg, Libert Adams
and their agenb (used as \"IItnenes In this suit) began 0 maficious smear
campaign against me/us and then this suit was filed as revenge.

I believe this suit was initially motivated by Uber1's Jeolovsy of Or loilz.. and
Berg, in retaliotion for the lass of h.xther donations and media attention,
which othen ~ke Ed and Coren Hole, PRN and Dr. laitz received. The river
01 money also dried up Your Honor because Ierg Itcq ,-.luI" fa Decou",
fot hundreds oIlhowandl 01 dolors In doncIffoM ".ot I WOI loki h. hod
NC-'ved prior 10 I\4C1Kh 6, 2009, An accounting MUST be mode to ensure
donors were not sokffed for funds under false pretenses and rn.I5di'ected
for other uses. I believe Berg gov~ Uberi permission to Improperly misdrect
SOrTIe' of the funds for her- own personal benefl/, possibly to pay htK court
ordered fines/restitullon as par/ of her probatfon since the $12,000 she
stoted to me Berg owed in bills that were coming d ue on Februoly I, 2009
and March J. 2009 equaled the amount Uberi was ordered to pay each
month. I also be/ietVet there may hove been other pions for the funds by

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Berg a nd/or Uberl toon w oot dOflOfS were given to believe w ere needed
to fIOonce Berg's legal chclenge to Obamo'l efglbllty, llasf of foith and
beJef In Berg's integity.

t ve"'m.m#y oppoIe any moHon by 1eIg" 01 01 ANY ,ancHon. ~

ogohut Of' TafIr. who to my know", hOi obeyed 011 court OI~. The
Incidents Berg cited. falsely ofeging violations by Dr TOitL J undfHSfond
were PRIOR to the Initlol hearing and court orders by Your Honor. Dr Toitz
actions. 0$ weN as 011 co-defendanh were motivated by intent to worn
and protect donOtS w"en Berg KNEW Uberl, a convicted felon. hod
access to confidential financlol Information and was handling vast
fJl'lOnciol transactions. In ekect violation of the terms of"er proboffon. f
can produce evidence of alf this YOlK Honor with a little lime.

Your Honor. hrg hoi pre~ oct.<:t In the capoc:tty 01 my allomey,

providing legal advice to me, and representation of me severol yeOl'S ago
ond promlsed confidentiality of my Identity to protect me and my fa mily
from corrvpt politica l operatives wtlom I hove exposed in the post 10 plus
years. Berg knew II was o n improper conflict of interest to represent other
plaintiff' s against me, yet d id it 10 retallote agalmf me for nof covering up
for him about UberI's aIminoIl"istory. Berg shovld be permanently barred
and sanctioned from ony further representation of third parties against
me. In lX. It is on obsokJte offirmotive defense ogalnst allegations of
defamation when speaking the truth, We spoke only lhe lrulh wllh a
proper and legitimate Inlenl . There Is no defama tion of pIoinliH's.

Further. Berg Jcnew of a friend of mine who wrote a book obout a

preskientlal candidate and used some of my research and ultimately
died as a result of the f&ve lotlons In this boolc. .4J a dfttct resutt cI 8erg',
'~..maffon 01 me 01 attomey, he (and IaIw Uberl) ..... ,If!d my Irw
IdenfIy and reveal. d It In r.venge and re#aIIaffon. knowing" mig'" co.'
my llfel

, InfCNmed Berg In mid March 2009 that I intended to file a complaint

agolnst him with Ihe PA Bar Association fOf his defamatory actions aQOltuf
me, IIfoIatlng attorney·client privilege and other dishonest acts. but that I
was wafting until he had exhausted his Jaw$uSts against Oboma, hrg
oIIefed legal f.j)N"rWotIon of me agoln'" wllII..g as fKentty a. March
2009, In wttat I come to ~ WOI on attempt to extort me Into ...nee
about Uberi'. lengttty cilll~ hbtoiy. When I dd not accept his offefond
0QfM to keep Heret UberI', criminal record and COmpromiM of donors
credit card lri'a, "g exacted ntv.ng8 by Including me ." this ",",
revealing my ldentfty, YIoIatIng confklentlollty and defaming rM.
 ••

Your Hooor, at no time did Libert.ver Jtote to me her oddle" WOt

c:onftdentlal. I provided to the court lost Aug 2009 the emo~ which Llberi
sent to me with her address 10 Ship a box of Xmas presents in December
2008. Her nickname Is ~llsa" on my buddy list and thot is what shows in
chats I saved. Her email address Is LRsallberfot col.com, which is the exacl
same as MUisoWbetl" as seen by ony member of 001. There Is no difference.
Berg and Uberi tied when they claimed it was not UberI, Of thol it WO$
somehow manufactured evidence.

Uberi supplied at leosl two 01 he!' several SocIal Security numbers to

bankruptcy coLKts and other places in sworn affidaVits which we found
bled In public records, available 10 anyone with Internet occess. NO ONE
violated her privacy. When I confronted Berg about Ubet1's erlmlna!
histocy in our Iosl convElI'SCltlon, I told him Ilell compeUed 10 worn donors
thot their account nvmb6rs were seriously compromised. hfg dfd noI
deny her crtmlnal hb'oq 10 me, or to this courl beCCWI. he c an ", Uberl
wtret.d no 1osJ.. or domoge. as I4Hg did nof,.,. h., and Ubed I. SJJlL
worldng M HrM a.Ietg'. patal.gat (often wClfttmg more Htan.fO floIN'
wHkJ) while ft'olldu'-nHy colledfng SJ dIIcm.y~,

Plaintiff's ond their witnesses allege Ed Hole & I threatened them. NO ONE
EVER THREATENED THEM with onything except telling the trvthl I toke
death threats very seriously. Ills not 0 joking matter 10 me. I hove been
wing with death threats for years as a result of my oppositional political
research. Berg cannot produce any evidence against me mak:fng threats
because If does not eXistl Libert Berg and Adoms hove waged a vicious
smear campaign delamlng me on over the Inlemel. We ore ther- vicNmsl I
realized on or about March ...... 2009 that lor many weeks I hod been
syslematically set up lor lalse accusations ot "hocll(ing~ Berg 's website by
UbEll1, Adams and/or their agents. I do no' hav.HIe technlcol compulwr
skill Of ICnowledge to do ANY oIth. things tMy aII. go. I was also banned
two days later. which they pubNcly denied. Berg was mode well aware 01
many horrible lhings done to me. which he dearly condoned and even
encouraged as ptoven by his own actions.

Yovr Honor. I su~ the chat which occurred on or about Jon 2. 20CR
to the court losl August, where Uberi brogged to me hOW She, Marie
McGrew. Adorns and Berg hod conspired to steal the Oboma divorce
documents from Ed Hale, removed the PRN watermark and claimed
credlt for the documents paid for by PRN listeners in a ptess release Issued
by Berg, whk;:h I can produce. The dotes on the different versions of
documents that were posted on thoi" website/s prove it. The tnt one Berg
hod po$led on his website beas the court stamped dole and rnorkiogs of
the one PRN hod boughJ. but with the PRN wotBl'mOO removed. Then

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Berg replaced 11 on his website 'NIfh the second one the PI sent them and
COurt stamped on Jan 2, 20091 Ed Hale con produce these, If he ha, nol
already. In 1he press release by Berg, he falsely accused Ed Hale of
steoling documents and dolmlng cr&dit for the tinct t need some lime to
prOduCe documentation to substanttote my accusations against Adams,
serg, libetI and their agents/witnesses. I neve!' delele anything, but often
saved files ore misplaced on my computer and " tokes lime 10 locale.

Ed Hale recentty I,,'ofll..o me n. wen tOleR to lhut down hli radio

netwof1( beoc:auM of the end.... haraurnent, etweatl and ... by 1I«g• .t
aI. According to Ed Hole; 8erg, plaintiff's, and the.. wltness / agents hove
threatened candidates 104' office (who were guest hosts on PRNl with
incluslon In this suit, for simply appearing on the Plains Radio Networt.. The
people making the threats mode mistakes that show dearly they weI'e
agents of 8erg and/or lIberi. When guests see how Ihls court has aUowed
us to be harassed and legally persecuted by 88fg, Uberl and the.. agents
in on improper venue, violating our rights, vvreaking havoc on our financflS
and destroying any sense 01 peace, of course they flee when threatened
with similar legal harassmentl PRN could no longer gel guests os a result
of these threats.

To the best of my recollection, I spoke to Or lain f!Mee prior 10 my banning

on Morch 6, 2009 from Berg's website and bIog. I hove always freely
supplied my research to anyone who asked rOl It. I waSll't paJd rOl my
research by Berg and om not undtK any obligatiOn to keep It 101 his
exclustve use, although Berg and Uberi shared my research freely with aU
Ihe me n who tNed suits. I didn' t need 10 ask 8erg's permission 10 shore my
own research with Or. Taltz. Berg's accusatlons of my conspiring with Dr
Toilz against him pilar to March 6", 2009 are paranoid labricatlons.

Berg has brought the enli"e 1eg0i profession Into mrepute with his many lies
and corrupl behaviors. 8erg and Libefi hOve been aRowed to haass us in
PA courts lor over a y80r, costing thousands 01 doIcn in attorney' s lees,
and other expenses ond mode numerovs false sworn affidavits defaming
us without requirement 01 production of one slvect of evidence of
wrongdoing. 1Ierg allowed hb palalegal LIla aenee ItIchardton COUf\'We
1Jb<MI, who physically,. . . . . of 2913 I'kna itanca, Santa fe, NM .7507
and whoM home landllne phoM II 505·473· 9115 to matefal..
Ifatemem to tNt court uling hb law omc:e addre.. 01 her own. I called to
appear, ....g and Uberl can not produce PA statets.ued IdentlftcaKon
provtng that In. 1IV«Iln PA when thb luft wal Hied.

The plaintiffs are not Innocent victims. Thev are wrongfut octoo In thls suil.
In numerous radio appearances broadcast Intemotionally, /.iberi, Berg

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and Adoms hove oHempted to falsely represent fa the public that Uberlls
not the convicted felon U30 Renee Rldtotdson Courvifle Liberi ~ving in NM.
I do know of a perron who Uberl told about her crimina/ past, leaving out
her guilty convictions and most of the charges and facfs. Thb person is In
dire fear for her wellbeing If she comes {{)(Word. ftspedally foeing the
some degree of legal pers&evtlon anc1/'larossment that we defendants
tace ..
Your Honor. Berg omItted Information thot Ubefl attempted to get me to
do UMeNpuiou. tning. that boI..-ed on crlmlnat and I aIwa)'l reofUMd.
One effort Involved Liberi asking me to file false complaints against tv.ro
attorneys whom Uberi wonted to discredit. The tnt complaint she wanted
me to file was against on aHorney In Al. Teresa LcLoggio, who supported
Obomo and Is licensed to. practice in />.l, PA and DC as well os complain
ogaJnst the low firm, Dickstein Shapi"o, where she Is employed; $Imply
because LOLogglo owned a website challenging Berg's evidence In his
lawsuit against Oboma. I stNl hove the dossier I.iberi sent me 10 use against
her. UbM.o aakltd 1M to,.. a I'GM complalnf wilt",. CA IGr
Auoelcrffon ogoIntt Dr ToItz. 'wom.d Dr Toltz dINs fact ont' a yfKW ago
on 01 obovl April )6, 2009. 1believe 1sli" hove the dossier Uberl sent me
against Dr. Tai!:z:. 1need lime to locate and produce them. I strongly
suspect liberi may be behind complalnh mode against Dr. Totiz by othan
...nth hislory of criminal behaviors, but J have no di'ect knowledge of il .1
did once hear Uberi ask one of the complainants against Dr Toltz. Lony
Sinclai", to file a complaint during a three way phone conversation. I
have never known Dr ToIlz to ael as she has been accused by those with
questlonoble motives and criminal histories who are associates of Llberl.

Berg should be reported to the PA Bar Association for Investigation and

referred 10 state and fedEH'ol low enforcement for InvestlgalJon of felony
crimes such os Berg. UbefI and her husband, 6(enl Uberi conspiing to
commit Social Security froud, as well as Social Security fraud in Berg
paying Liberi's husband. Brent Uberi, Usa Llberi's salary for paralegal work.
I reported this to the SSA's Inspector General's office. Usa Uberl alSo did
nol get prior permission to lite thl! suit from her probation oWcer in NM.
anomer very serious violatiOn of the tem'lS of her probaHon as directed by
the CA couto There ore other acts which need investigating, 100.

Your Honor, hrg 0110 knowingly and ~ pIocN me and my

family In grove dang« by ,..,ftGIIttgmy IdenHty In this suit so that nuts who
support COITUpt politicians thot were previovsly exposed. and who are still
making death threats can eosity locate me. Berg /(new the danger his
actions pol us in and viciously did It anyway. He has hormed me much
more than I COn ever describe. / ive in conslan; lear (Of my (amiy. IetV
oe / U / !OlO !J:U PAl !lIOOI

has u.~ hil education and law license. nol as 10011 for truth and ju.Hcft.
but wrongluly as evil weapons to exoct revenge fOl OIJIlnf~ In
'ftv.oIIng to donors their credit card Into was comptOmls~ by Ubetl
havIng ace... fo It.

Your Honor, I am pleading wtth you, please hoJd a"g oeeol,lntobM for all
th. wrongs he has done to UJ, all the perjured oMdavlb he IUpplied to thl.
eOl,lrt, and 01 the damage he ha, don. to each of 1,1. with publle ,meor..
aerg ha, demoyed my abllty to perform any sort of pollical r. MOI'ch '"
the future to .xpose corrvpHon ond devastated any poulbM .en•• 01
teCurtty and/ or .afety for me or my!amfty In the for....ab.. Mur• . I a,k
Berg be ordered to pay all our ottomey'. 'H' (exceeding $5,00 tor the
Ha~I. Sankey and myleIf) and aft other expenHi and that tN, co .. be
dl,mI.sed with prejudice 10 that he can not conHnue to 1,1. . the coum to
hara .. and damage u. further.

I ~ea under penalty of peJftxV by the lows of tha state 01 T.xas. where I
reside, that the statements mode In this document are true one! cooect 10
the best of mv knowledge,

thank yo.J,