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Case 2:09-cv-01898-ER Document 146-1 Filed 10/07/10 Page 1 of 12


Z:\Liberi, et al, Taitz, et al, Plaintiffs’ Motion for Sanctions; Atty Fees; and Motion to Strike
Case 2:09-cv-01898-ER Document 146-1 Filed 10/07/10 Page 2 of 12

Law Offices of:

Philip J. Berg, Esquire
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
Identification No. 09867
(610) 825-3134 Attorney for Plaintiffs


LISA LIBERI, et al, :
Plaintiffs, :
vs. : Case No.: 09-cv-01898-ECR
ORLY TAITZ, et al, :
Defendants. :


I, Philip J. Berg, am an attorney licensed to practice law in the Commonwealth of

Pennsylvania, and represent the Plaintiffs herein and am also a Plaintiff in the within action. I

am over the age of eighteen (18) and have personal knowledge of the facts herein. If called to do

so, I could and would competently testify under oath:

I declare as follows:

1. Lisa Liberi volunteers her time to me as an Assistant/Paralegal and has since

approximately the end of 2006, early 2007. I do not pay any wages to Mrs. Liberi or her

husband Brent, as falsely accused by Defendants Taitz and Belcher.

2. I have reviewed the newest filing by Defendant Orly Taitz, which was filed on

September 28, 2010 and appears on this Court’s Docket as Entry Number 145, “Reply to

Motion”. I was not served with Defendant Taitz’s filing.

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3. Defendant Orly Taitz’s filing contains nothing truthful. Instead, she has falsified,

manipulated, twisted, and maliciously misquoted all the events surrounding this case and

contains documents which were forged with Mrs. Liberi’s email address. Defendant Taitz’s

tactics and actions are a disgrace to the Legal Profession.

4. Taitz, Belcher and Geoff Staples falsely accuse Lisa Liberi of handling credit

cards, processing credit cards, setting up my Linkpoint account, having full control of my

Linkpoint and PayPal accounts and many other falsified accusations. None of this is true.

5. Lisa Liberi had nothing to do with the setup of my Linkpoint account. Dave

Williams, a third party contractor for Linkpoint, opened my account and Geoff Staples took

control of my Linkpoint account thereafter. Lisa Liberi did not have anything to do with my

Linkpoint or PayPal accounts. Lisa Liberi never handled any donations or credit cards,

never processed any credit cards, never stole from me, and never had access to my financial


6. The attachments filed with Defendant Taitz’s Reply have been altered and Mrs.

Liberi’s email address was fraudulently added to the documents. This is not the first time

that my clients’ names and email addresses have been forged on documents filed with this

Court by the Defendants.

7. Geoff Staples attachments in Exhibit 2 of Orly Taitz filing on September 28,

2010, appearing as Docket Entry No. 145, have been altered to reflect that Mrs. Liberi sent

the emails. The header information presented by Mr. Staples in his attachments to Taitz’s

filing, were presented as if Lisa Liberi was forwarding them to Geoff Staples. The header

information does not show routing from Mrs. Liberi’s email, instead it shows being routed

from Hostricity (Geoff Staples Company), which is an account on, see

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EXHIBIT “A“. Hostricity is a local host of, as shown in his own

routing. The mail client Geoff Staples is using is, which appears in the header

information supplied by Geoff Staples purportedly sent by Mrs. Liberi. According to Geoff

Staples attachments, his I.P. assigned by Reflexion is

8. I pulled the header information from an email I received from Geoff Staples on

October 21, 2008, ironically, the header information reflects coming from Geoff Staples,

using as the mail client with an assigned I.P., see EXHIBIT

“B”. As you can see, Geoff Staples attachments show in the header information, that the

emails were actually sent from Geoff Staples and not Lisa Liberi.

9. I have pulled the header information from an email I received from Geoff Staples on

October 21, 2008, to show that Hostricity which is a local host of megawebservers, appears

as does his mail client Reflexion with IP in his mail headers, which matches the

header, supplied by Geoff Staples in his attachments, filed by Taitz, of the email supposedly sent

by Mrs. Liberi. This proves that the email was sent from Geoff Staples and not Mrs. Liberi.

10. Mrs. Liberi’s husband, Brent has never had any credit card accounts setup on my

website and has never had his PayPal account accepting donations on my behalf, as falsely

accused by the Defendants. The only person who has ever stolen from me, as better

explained below, is Geoff Staples. And, as explained below, and substantiated with all the

email exchanges between Geoff Staples and myself and screen shots attached as Exhibits, it

was Geoff Staples who was illegally collecting all my supporters’ credit card details,

addresses, names, etc. without my knowledge or permission.

11. In or about August 2008, I received a call from Defendant Linda Belcher who was

using the name “Linda Starr”, asking me if I had heard the issues surrounding, then Senator

Barack H. Obama. Throughout the years, I had spoken to Linda Belcher on occasion. I did

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not even know Linda Belcher’s legal name until I was forced to file the within action to

protect my clients and myself.

12. After researching the issues, Mrs. Liberi drafted a suit on my behalf, which I filed

against then Senator Obama. Said suit was filed on August 21, 2008. I filed two [2]

additional law suits in or about December 2008.

13. I was looking for someone to set-up and maintain a website on my behalf

regarding the recent litigation pertaining to Obama. Linda Belcher stated she had a long time

friend of twenty [20] years, Geoff Staples, who could set-up and maintain the website on my

behalf. As a recommendation from Linda Belcher, I hired Geoff Staples.

14. Geoff Staples set-up my website at on August 21, 2008 and

handled everything pertaining to the website and my donation links. No one except Geoff

Staples had any log-in details or passwords to the website or my domains. I did not even

have the passwords.

15. Geoff Staples asked me for my PayPal details, my log-in and password so he

would be able to set-up the donation button on my website. I gave Geoff Staples the

requested information and Mr. Staples set-up the donation button on my website.

16. In or about the end of September 2008, I began having problems with PayPal. I

had Mr. Staples set-up my fiancé’s PayPal account to use until I obtained my Linkpoint

account. I went ahead and purchased a Linkpoint account from David Williams on or about

October 21, 2008.

17. On October 21, 2008 I received an email from Linkpoint welcoming me to their

services. In this email, it gave my store name, store number, my secure host name and my

user ID. This email did not give any password information. See EXHIBIT “C”. I

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forwarded a copy of this email to Geoff Staples with instructions and a copy to Mrs. Liberi

for a back up.

18. On October 22, 2008, I made several calls to Geoff Staples to inquire whether my

Linkpoint account had been set-up on my website. Instead of receiving a return call from

Mr. Staples, I received an email from Linda Belcher stating she had called Mr. Staples and he

was working on it. See EXHIBIT “D”.

19. At this time, Geoff Staples was the only person with the password to my

Linkpoint account. I did not have access to my own account. To date, I still do not have my

Linkpoint Admin log-in details or password. I only have the user/store level access.

20. On November 2, 2008, I received an email from Geoff Staples at, which was a donation receipt from one of my supporters. I

learned at that time that Geoff Staples had the donation information from my Linkpoint

Merchant account going to his email at See EXHIBIT “E”.

21. On November 2, 2008 I received an email from one of my supporters with a

forwarded email my supporter had received from Geoff Staples regarding his donation. Mr.

Staples was receiving all the donation information when a donation was made on Linkpoint

and emailing receipts to my supporters. See EXHIBIT “F”.

22. Since Mr. Staples had locked me out of my Linkpoint account, I contacted

Linkpoint and had my password reset. Geoff called me upset stating he needed to get into

my Linkpoint account due to issues with my website and gave excuses as to why he had

changed my password. Based on the fact he was my webmaster and had full control of my

website, I emailed him my password. See EXHIBIT “G”. Mrs. Liberi was not copied on

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this email and never had the passwords to my PayPal or Linkpoint accounts. Mr. Staples

and I were the only ones with the passwords.

23. On November 2, 2008, after I had emailed my Linkpoint password to Mr. Staples,

I received an email from Mr. Staples stating we needed to reset my password on my

Linkpoint account. See EXHIBIT “H”. The password was reset and again Mr. Staples and I

were the only ones with the password.

24. On November 3, 2008 I received another email from Mr. Staples. Mr. Staples

stated David Williams was “adding Linkpoint Connect to my Linkpoint account”. Mr.

Staples further explained how he was going to set-up the donation buttons on my website.


25. I received another email from Mr. Staples on November 3, 2008 informing me

that Dave Williams had placed the order for the Connect service and it would be available

this same date. Mr. Staples also informed me that he should have the server to my website

corrected. See EXHIBIT “J”.

26. On November 4, 2008, Mr. Staples sent me an email stating Linkpoint was up on

my website. Mr. Staples had carbon copied Mrs. Liberi on his email requesting us to make a

small donation and to let him know if we encountered any problems. What was odd is that

Mr. Staples stated, “When it goes over to the Linkpoint site, their page doesn’t match the

website. This is due to a technical problem with Linkpoint, which they claim will be fixed in

the next 24 hours”. See EXHIBIT “K”. I have since learned that Geoff Staples never used

the secure link provided October 21, 2008 by Linkpoint. The problem referred to in Mr.

Staples statement above was not a Linkpoint problem, but instead, Mr. Staples had all the

donation information intended to be processed by Linkpoint going to a form submit page on

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Geoff Staples Hostricity server. See EXHIBIT “L”. With this, Mr. Staples was gathering

and storing all my supporters’ names, addresses, phone numbers, credit card numbers, etc.

Geoff Staples had to manually enter the credit card information as shown in these attached

reports of donations made by individuals, which were processed through Linkpoint by the

same private I.P. address (private IP addresses are not what the normal individual uses, but

webmasters and web host companies have access to private I.P. addresses). The private I.P.

had to have belonged to Geoff Staples, as he was the only one with access. See EXHIBIT

“M”. An unredacted copy of this report will be furnished to the Court “under Seal” upon


27. On November 4, 2008 I received an email from Geoff Staples from his Hostricity

Help Desk email address. Mr. Staples had included numerous

email addresses in this email. This particular email was in response to the email I received

on November 2, 2008 from one of my supporters. Mr. Staples states in his email, “Oops.

That is my fault. It was supposed to be removed. I’ll fix it now. Interesting, no one else

seems to have noticed my mistake.” Mr. Staples was talking about the way he had his email

setup which were going to my supporters that he, Mr. Staples, had received donation

information from. See EXHIBIT “N”.

28. On November 4, 2008, I began receiving calls that my website was down. I put

several calls into Mr. Staples and did not receive a call back. In addition, I was attempting to

pay Mr. Staples web hosting bill and was having difficulties. I sent Mr. Staples an email

informing him that I was having difficulty paying my bill and I needed help from him if he

wanted to be paid by credit card. Otherwise I told him I would mail him a check. In this

same email I asked him if my website was back up. See EXHIBIT “O”.

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29. On November 5, 2008, I received an email from one of my supporters stating my

website was not properly working. I had not heard back from Mr. Staples on my previous

emails, so I sent him another email again asking how long it was going to take to have my

website up. See EXHIBIT “P”.

30. During this time, I had been calling Geoff Staples asking for my passwords to my

domain names and website. Finally out of frustration, I emailed Mr. Staples on November 8,

2008 demanding my passwords. See EXHIBIT “Q”.

31. On November 9, 2008 I finally received an email from Mr. Staples, which clearly

proves that Mrs. Liberi had nothing to do with my Linkpoint or PayPal accounts, any credit

cards or any of the donation information, it was Geoff Staples who did. Mr. Staples stated,

“First I reviewed the transactions in Linkpoint. For Nov. 7th and Nov. 8th you had less

than $100 declined – all in $20 transactions and 1 $100.00 transaction marked ‘fraud’”.

“There was another transaction that was declined, but the person resubmitted it on

another credit card, which went through. I think this is likely due to the change I made

today which provides a message suggesting they try another card.” “On the website: I

have take [sic] a commenting system and made some programming changes to it so that it

will provide what is needed. I will install it in the morning.” See EXHIBIT “R”.

32. I wrote Mr. Staple’s back and stated, “you take me for a complete fool” and I

again demanded my passwords. See EXHIBIT “S”.

33. I decided to change webmasters based on the problems I had been having with

Geoff Staples. To ensure I received my passwords, on December 1, 2008, I sent an email

urgently requesting my passwords to my domain names, and See EXHIBIT “T”.

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34. Also during this time, Defendant Taitz continued calling my office. She wanted

assistance from Mrs. Liberi with a Writ of Cert and other legal documents. Mrs. Liberi

refused to assist or have anything to do with Defendant Taitz. I filed a law suit with Mrs.

Liberi shortly thereafter and told Defendant Taitz to stop contacting my office, that she was

unethical and a liar. Next, Defendant Orly Taitz threatened to take me down and to do so she

was going to destroy my Paralegal, Lisa Liberi, and get rid of her. Since this time, Defendant

Taitz has continued illegal behaviors which have escalated to a point I am concerned for the

safety of my clients, Lisa Liberi, Lisa Ostella and their families. Defendant Taitz has

continually attempted to have my clients: Lisa Ostella and Lisa Liberi arrested on false

charges and has been cyber-stalking, harassing, inciting violence, among many other things

against my clients, Lisa Liberi and Lisa Ostella. Defendants Taitz, Belcher and Sankey have

also forged documents in the names of my clients, Lisa Liberi and Lisa Ostella, which is on

file with this Court.

35. On December 1, 2008, I received an email from Geoff Staples stating, “We have

received your request and will respond as soon as possible: Passwords for Domain Names

96-M7-1B” See EXHIBIT “U”. However, Mr. Staples failed to give

me the website and hosting passwords, which would allow my new webmaster to move my


36. On December 2, 2008, I received another email from Mr. Staples with additional

passwords. See EXHIBIT “V”. However, when my new webmaster, Gail Frye, attempted to

log-in, in order to transfer my websites, she discovered Mr. Staples had given the incorrect


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37. After numerous attempts to secure my passwords in order to move my websites

off of Geoff Staples server,, my office and new webmaster, Gail Frye were

forced to contact the Federal Bureau of Investigations (FBI) in Dallas, Texas and obtain their

assistance in obtaining my passwords. The FBI was successful and was able to obtain my

passwords on my behalf. My websites were immediately moved over to a different server.

38. The problems with Mr. Staples did not stop there. On January 28, 2009, Geoff

Staples illegally billed my credit card in the amount of $67.20, even though I never allowed

my credit card to be utilized by Mr. Staples for anything other than the initial setup fees. Due

to my schedule, I asked Mrs. Liberi to please send an email to Mr. Staples regarding his

illegal activities and theft of monies from my credit card. Mrs. Liberi complied and carbon

copied me. See EXHIBIT “W”. This was not the first time this had occurred. Mr. Staples

also illegally charged my credit card in excess of Five Hundred [$500.00] Dollars on

September 22, 2008. See EXHIBIT “X”.

39. Not only was Mr. Staples illegally storing all my supporters private information

and credit data, he released documents, with Mrs. Liberi’s email address forged onto them,

with my supporters credit card numbers, addresses, phone number, email addresses, etc. to

Defendant Orly Taitz illegally, without any type of subpoena or legal process. Defendant

Taitz also failed to notify me that she was seeking private records on my previous web

hosting account. Defendant Taitz took it upon herself and published this information all over

the Internet and sent it by mass emailing. Not only is this theft of my supporter’s data, it is a

serious data breach. For this reason, I need an immediate Court Order issued upon Geoff

Staples to turn over all of my supporters data, which he stole from me, immediately, so I can

notify all my supporters of the Security Breach.

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I declare under penalty of perjury of the laws of the United States of America that the

foregoing is true and correct. Executed this 6th day of October, 2010.

Respectfully submitted,

Date: October~, 2010 /&4/'~

Philip J. Berg, Esquire

Commonwealth of Pennsylvania )
County of Montgomery )

On this ~* day of October, in the year of 20 10, before me !h MMeff /.J;ts.trt!

Notary Public Name
a notary public, personally appeared Philip J. Berg, Esquire, and proved on the basis of

satisfactory evidence to be the person whose name is subscribed to this instrument, and

acknowledged he executed the same. Witness my hand and official seal.

h ;~av.r ilr..
I af/l
Notarial Seal
Margaret Hagan, Notary Public
sIt')~marsh Twp" Montgomery County
i\ify'eommission Expires Dec. 3, 2010
Member, Pennsylvania Association of Notaries
My commission expires: j). ,--J '-II)

Liberi\Affidavit of Philip 1. Berg, Esquire 11