LIBERI V TAITZ (APPEAL - 3rd CIRCUIT) - Motion Filed by Appellants For Sanctions and Costs and To Strike Appellees' Brief - Transport Room

Case: 10-3000 Document: 003110349784 Page: 1 Date Filed: 11/17/2010
No. 10 3000
UNITED STATES COURT OF APPEALS
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 for for Sanctions and Costs and Motion to Strike Appellees’
Brief by Appellees Orly Taitz and Defend Our Freedoms re: Appellant’s
Motion to Dismiss Appeal
__________________
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
I. INTRODUCTION
Dr. Taitz and Defend Our Freedoms Foundation (hereinafter referred to as
Appellants) bring a Motion to Strike the Appellee’s Response Brief as well as to
sanction Appellees’ attorney Berg under 28 USC § 1927 for attorney fees and
penal sanctions.
The underlying case in this matter involves an incomprehensible and totally
frivolous and extortionate lawsuit for nearly a billion dollars in damages by a
politically motivated Pennsylvania attorney, his legal assistant who is a convicted
felon and other accomplices. The instant appeal deals in the main with the matter
of diversity jurisdiction and in particular whether district judge Eduardo Robreno
erred in creating a new standard, mainly assuming jurisdiction in a case based on
Diversity of Citizenship without any identifying documents of state citizenship of
the lead plaintiff, even though the standard is to provide proof of the citizenship by
preponderance of evidence. Whether Despite filing over 900 pages of largely
irrelevant exhibits in their so called appendix – that question remains unanswered
because nothing was ever submitted to the District Court to support the District
Court’s erroneous finding nor provided in the Response brief. Case at hand was
filed on May, 4, 2009 by Pennsylvania Attorney Philip J. Berg (hereinafter Berg)
as a plaintiff and an attorney for plaintiffs. Lead Plaintiff is one Lisa Liberi, who
has at least 42 criminal charges and at least 10 criminal convictions, which include
convictions of forgery of documents, forgery of an official seal and grand theft.
Liberi's latest conviction was in the state of CA, in 2008, when she received eight
year prison term, which was subsequently reduced to three years probation due to
her medical problems. (case FWV028000, defendant 1608112 Lisa Renee Liberi,
aka Lisa Courville Richardson, aka Lisa Courville Rich, aka Lisa Richardson and
case FSB044914 for Lisa Liberi ) (Appendix 1 Lisa Liberi's mug shot and
summary of above criminal convictions ). According to Berg's own affidavit filed
on 10.07.10 in this case, he employs Liberi as his paralegal and she drafted
pleadings, which he filed with courts. Berg is known as an attorney, who filed
legal actions against Bush administration, claiming, that President Bush was
involved in 9/11 attacks. Berg was also the first attorney to file a legal action
questioning Barack Obama's eligibility to U.S. presidency. His case Berg v Obama
was filed in the Eastern District of PA, this Court and the Supreme Court of the
United States. Berg admitted that Berg v Obama complaint was drafted by Liberi
and filed with the courts by him. Orly Taitz is a president of Defend Our
Freedoms foundation (DOFF). She is licensed as a Doctor of Dental Surgery and
as an attorney in the state of CA. Taitz is very outspoken in regards to the need for
transparency in the government and adherence to the Constitution and made 36
trips all over the country, lecturing about the need for preservation of
Constitutional liberties and consequences of losing such liberties, as she saw in
her youth in her native Soviet Union. Taitz contacted Berg and let him know that
she is concerned about the fact, that he filed with different courts documents and
briefs prepared by a convicted document forger Lisa Liberi. Taitz asked Berg, if
he would allow her and a forensic document expert review the originals of the
affidavits from Africa, attesting to Obama's birth there. Taitz let Berg know, that
while she believes that this constitutional issue needs to be resolved in courts and
original vital records need to be reviewed, use of a document forger does not help
the case. Taitz, also, advised Berg, that Liberi is currently on probation until
March of 2011. She is under supervision of San Bernardino, CA probation
department and according to the terms of her probation she is not allowed to
handle credit cards of others. Berg runs large nationwide donations drives, where
thousands of people donated, since he has cases against both Bush and Obama
administrations. Taitz advised Berg, that he is endangering the public by
continuously working with a convicted thief Liberi. Berg never responded and
never agreed to allow Taitz and her expert to review the original documents from
Africa in question. Taitz posted on the website for her foundation a report
prepared by CA licensed investigator Neil Sankey, which showed lengthy criminal
record of Lisa Liberi. It was done with a proper purpose of warning the public. In
response Berg filed this legal action on 05. 04.09 in the Eastern District of PA
District Court. He listed jurisdiction under diversity and nature of the suit Assault,
Libel, Slander. In this suit he claimed that he and his paralegal were slandered,
because, she is not Lisa Liberi, who was convicted in CA and allowed to reside
only in CA and NM according to her probation, but rather a different Lisa Liberi,
who happens to have the same first, name and the same birth date, but allegedly is
a different woman, an innocent woman, who is residing in PA and working in
Berg's office. Berg never provided Liberi's home address, but rather gave his
business address as her address. Taitz has provided the court with a positive ID
of Liberi's mug shot, as one, who was convicted in CA and also one who appeared
in front of the Presiding Judge Eduardo Robreno in this case, claiming to be a
different woman. Aside from Taitz and her foundation Berg sued a number of
other individuals and entities, all of whom were whistleblowers, exposing to the
public the fact, that Attorney Berg is using a convicted forger and thief Lisa Liberi
as his assistant. Berg filed multiple motions in the District Court and in the Third
Circuit Court of Appeals, requesting this case to be sealed, claiming that Liberi's
life is in danger. Neither the District court nor the Third Circuit Court of Appeals
ever found any value in Berg's claims and never granted his motions. The District
Court case was suspended by Judge Robreno, while Berg filed his appeal. When
the Third Circuit Court of Appeals issued an order to show cause to Berg, to show
why within a period of half a year he never produced a transcript, that he was
appealing, Berg abruptly withdrew his interlocutory appeal. On 06. 04.10 Judge
Robreno issued an order and memorandum, where he assumed jurisdiction over
the case based on Diversity of citizenship and ordered the case severed into two
cases and transferred to TX and CA.
Taitz filed a motion for Reconsideration on 06.14.10, arguing that the court erred
in assuming jurisdiction, as plaintiff Liberi never provided any evidence of her
PA citizenship. On 06.23.10 the court denied defendant's motion as moot. No

explanation was provided, why is it moot. On 07.02.10 Taitz filed a notice of
Appeal and requested transcripts of two hearings held by the court: on 06.25.09
and on 08.07.09. On 07.26.09 Berg filed yet another motion to keep the transcript
of the 08.07.09 hearing under seal. Berg, also, filed a motion with the Third
Circuit Court of Appeals to dismiss the appeal due to lack of jurisdiction. Third
Circuit Court of Appeals denied Berg's motion.
On 07.29.2010 defendants responded in the District Court by pointing out, that the
plaintiffs did not provide a shred of evidence of Liberi's state residency.
On 07.30.10. Plaintiffs filed a reply, where they claimed, that Judge Robreno's
06.04.10. order and memorandum, stating "Liberi is a resident of PA" is based on
vital records, including driver's license, allegedly submitted to Judge Robreno
during 08.07.09 hearing, but such records need to be sealed. Plaintiffs made up an
outrageous accusation, where without a shred of evidence, they claimed that
Attorney and Doctor Orly Taitz tried to hire a hit man to kill Lisa Liberi, and that
is the reason, why Liberi's allegedly existing Pennsylvania driver's license needs
to be sealed and the court needs to decide that she is a resident of PA without
providing the defendants with any proof or any evidence of her residence.
On 08.31.10 the transcript of the 08.07.09 hearing was released to the Third
Circuit Court of Appeals and published on court public terminal. The transcript
showed, that during the hearing the Plaintiff's attorney Berg and Plaintiff Liberi
promised to provide the court Liberi's driver's license, they asked for permission to
file it under seal, however they never filed such Driver's license. The driver's
license is not an exhibit with the transcript of the hearing and is not listed with any
exhibits anywhere on the docket. On 10.28.10 with her motion pleadings Taitz
provided the court with the Affidavits of Caren Hale and Ed Hale (Appendix 3),
who were present at the 08.07.09 hearing and declared under penalty of perjury,
that Attorney Berg did not tend to Judge Robreno any documents, and that Berg
left the courtroom at the same time as they did. They also identified Lisa Liberi, as
the same person, who is depicted on the mug shot as a California convicted felon
and as the same woman, who appeared during the 08.07.09 hearing, claiming to be
a different person, who was not convicted of any crimes and who resides in PA.
Instead of responding to the issue of lack of evidence of Liberi's state
residence, Appellees and their attorney Berg have attempted to hijack these
proceedings and turn them into a little circus of horrors. In the first act of the
drama, they attempt to confuse the issue with an avalanche of irrelevancies. The
second act involves sleight of hand and juggling facts in an attempt to deliberately
obfuscate the issues and mislead the Court. The final act is a barrage of
unsupported and defamatory allegations that Appellant Taitz is a would-be
murderer and kidnapper of women and children and has supposedly hired a hit
man and solicited White Supremacists to carry out her evil plot. Sanctions as
severe as possible under the law are warranted in this case.
Appellant anticipated that Berg would be a problem. In a pending motion
below, Berg has made these same false allegations of murder, mayhem, and
kidnapping against Appellant Taitz. At some expense she hired Third Circuit
counsel Jonathan Levy for the express purpose of meeting and conferring with the
nettlesome Berg pursuant to this Court’s Order that the parties submit a joint
appendix. The affidavit of Jonathan Levy is direct and to the point: 1. Berg would
not cooperate regarding the Court’s wish the parties file a joint appendix; 2. Berg
leveled the allegations of murder and kidnapping to Levy in an aggressive manner
and attempted intimidate Levy by telling him he needs to control his client. See
Affidavit of Levy.
Appellant does not want to repeat these false charges anymore than
necessary except to say they are without a shred of evidence. Appellant is Dr Orly
Taitz, is a licensed Attorney and licensed Dr. of Dental Surgery. She is a mother of
three, she was never convicted of any crimes, she was never charged with any
crimes, she never committed any crimes. Attorney Berg’s antics have finally
crossed the line. This is a far worse situation than the previous frivolous pleadings
by Berg. See In Re Berg, 2008 Bankr. LEXIS 322 (ED PA 2008); Holsworth v.
Berg, 2005 U.S. Dist. LEXIS 15393 (ED PA 2005). Attorney Berg is a menace to
the profession and must be stopped. Berg and his clients without a shred of
evidence have accused Appellant of a capital crime when Appellant’s only wish is
to get as far away from Berg, Liberi and the others as possible.
II LEGAL ARGUMENT 28 USC § 1927
28 USC § 1927 states:
§ 1927. Counsel's liability for excessive costs

Any attorney or other person admitted to conduct cases in any court of the United
States or any Territory thereof who so multiplies the proceedings in any case
unreasonably and vexatiously may be required by the court to satisfy personally
the excess costs, expenses, and attorneys' fees reasonably incurred because of such
conduct.
Attorney Berg is the poster boy for § 1927. The appeal in the matter is a
relatively simple review of diversity jurisdiction upon which a transfer order was
based. Berg has filed current action based on diversity, claiming, that his client
Lisa Liberi is a resident of Pennsylvania, without providing any evidence of her
Pennsylvania residency. Taitz, and Defend our Freedoms Foundation, both CA
residents, provided the District court with Liberi's mug shot and summary of her
criminal convictions and probation conditions in CA, stating, that Liberi is on
probation until April 23, 2011 and is allowed to serve her probation only in CA or
NM. Liberi is not allowed to reside in PA. Taitz has provided the court with
witness identification of her mug shot, stating that the same Lisa Liberi who
appears on the mug shot as convicted in CA, appeared at the 08.07.09 hearing in
Liberi v Taitz before judge Robreno claiming to be a different person. At the
hearing Berg and Liberi stated, that they will file with the court Liberi's identifying
documents. Without a shred of evidence they claimed that Liberi is afraid for her
life and that the defendant, Dr. Taitz, tried to hire a hit man to kill her. They asked
for the permission of the court to file her PA drivers' license under seal, however
they never filed it at all. The reason for it is catch 22. The whole law suit is filed as
a slander and defamation of character law suit. Berg and Liberi are claiming that
when Taitz published on her web site Liberi, criminal record and warned the
public of the criminal record of Liberi, assistant to attorney Berg, she defamed
them, because Liberi is a different person. She is not Lisa Liberi, who was
convicted in CA and allowed to reside only in Ca or NM, but an innocent different
Lisa Liberi, who resides in PA. Berg knows that if he does not provide Liberi's PA
drivers license, attesting to her PA residence, the case needs to be dismissed due to
lack of jurisdiction, as each party to a diversity case needs to prove her residence
based on diversity of citizenship. Berg will need to be sanctioned for harassing the
defendants with thousands of pages of unrelated inflammatory and defamatory
material instead of taking 1 minute and providing 1 page- a certified copy of
Liberi's PA drivers' license. Taitz agreed to accept a redacted drivers license,
without a street address or even city address. The transcript of the above 08.07.09
hearing and further docket shows, that Berg and Liberi never provided the court
with her driver's license or any other documents, attesting to her PA residence.
The reason they never provided a copy of Liberi's PA drivers license, is because
they committed fraud on the court and perjury, since at the time of filing this legal
action, May 4, 2009, Liberi did not reside in PA and was not allowed to reside in
any other state, but CA or NM. IF Berg and Liberi, were to show her drivers'
license, it would be either CA or NM, which would show that she is indeed the
same Lisa Liberi, who was convicted in CA and allowed to reside in CA or NM
only, she is not a different innocent Lisa Liberi, residing in PA and yet again the
case will need to be dismissed, as it would be crystal clear, that it was filed for
harassment purpose only , based of fraud and perjury by both PA attorney Philip J.
Berg and his assistant Lisa Liberi.
Just as Berg did not provide Liberi's drivers license or ID to the district court, he
equally never provided the Third Circuit Court of Appeals this one page, one
piece of evidence needed for the Federal court to assert jurisdiction in a case based
on diversity of citizenship. Instead of following the Court’s direction and creating
a joint appendix, Berg submitted an astounding 900 page appendix and brief
whose main purpose is to mislead, vex, and harass. After 900 pages of unrelating
material, there is still no PA drivers' license, no PA ID. Berg succeeded in
misleading judge Robreno by simply burying him under thousands of pages of
unrelated material and Berg is trying to pull the same scheme in the Third Circuit
Court of Appeals.
After wading through the 900 plus page appendix it is clear that besides
harassing, vexing, and multiplying the proceedings, Berg is also misleading the
Court. A simple question is put forth the in Appellants’ brief, did or did not Berg
ever submit Liberi’s driver’s license or any other indicia of her state citizenship to
the court as he claimed he did – the simple answer is that he refused to answer that
question and instead launched on a jihad against Appellant in which no accusation
is to far fetched or vulgar to tar her reputation as an attorney, mother, and human
being.
The Fifth Circuit has found that an attorney who maintains an obviously
unwinnable position may be sanctioned under § 1927 for attorney fees incurred.
Edwards v. General Motors, 153 F.3d. 242, 246 (5th Cir. 1994). Accusing
Appellant of murder and kidnapping and wasting the Court’s time on an
unsupportable allegation surely meets these criteria. Before a court may assess
fees under 28 USCS § 1927, the attorney must intentionally file or prosecute a
claim that lacks plausible legal or factual basis. Indianapolis Colts v Baltimore,
775 F2d 177 (7th Cir. 1985).
§ 1927 is applicable to appellate briefs. A penalty of $ 1,000 was imposed
upon counsel under § 1927 for submitting appellate briefs which utilized typo-
graphical techniques to effectively reduce 70-page brief to 50 pages in
contravention of Federal Rules of Appellate Procedure. Westinghouse Electric
Corp. v NLRB, 809 F2d 419 (7th Cir. 1987). Lack of meaningful argument in a
brief filed on behalf of appellant rendered appeal frivolous and needlessly
burdened appellees, thus justifying assessment of costs against appellant's counsel
personally. Lisa v Fournier Marine Corp., 866 F2d 530 (1st Cir. 1989). Attorney
was sanctioned $500 where a brief cited no relevant cases, devoted itself almost
entirely to a non-issue in the case, and failed to make even one citation to record
where relevant. Plattenburg v Allstate Ins. Co., 918 F2d 562 (5th Cir. 1990).
By comparison to the above, the wild accusations, harassments, and
multiplication of the records by Berg seem horrendous indeed and must be
sanctioned.
III. STRIKING THE APPELEE'S RESPONSE BRIEF IS APPROPRIATE

While FRCP Rule 11 is not directly applicable to the appellate court since it
has not been incorporated by reference or otherwise in appellate rules of court, its
requirements help to define conduct becoming to member of bar, and sanctions
may be imposed for conduct inconsistent with its standards. In re Kelly, 808 F.2d
549 (7th Cir. 1986). Berg by putting his signature on the frivolous and deceptive
Reply Brief with its false factual allegations against Dr. Taitz has opened himself
up to sanctions should this Court wish to impose them sua sponte.
Further FRAP Rule 38 is also available to this Court and Appellants have
gone to the trouble to file this motion. Appellees’ counsel is responsible for the
content of the frivolous brief which is a waste of judicial resources and is without
merit and therefore is potentially sanctionable under FRAP Rule 38. See Maier v.
Orr, 758 F.2d 1578, 1584 (Fed. Cir. 1985); Meeks v. Jewel Cos., 845 F.2d 1421
(7th Cir. 1988). Striking the Appellee's Response Brief is both appropriate and
warranted under the circumstances.
IV CONCLUSION
The Appellee's Response brief is incompetent, frivolous and vexatious. No
reasonable attorney could put his signature on such a pleading after examining the
so called evidence. But this is exactly what Berg has done in his position as
appellees’ attorney. Even a cursory reading of the brief indicates a disconnect
between reason, fact and reality. Appellees are attempting to deceive the court
about the issues and facts.

Sanctions are called for here under FRAP Rule 38, § 1927, or the Court’s
inherent powers - something must be done. A Reply Brief on the issue of diversity
jurisdiction is not the time or place to fabricate allegations of attempted murder
and kidnapping of children! Attorney Berg never produced any identification
documents for his client Lisa Liberi, a lead plaintiff, to substantiate his claim, that
she is a resident of PA. He never responded to the simple question, why should the
Federal court assert jurisdiction in diversity without any evidence of the state
citizenship. Instead, Berg and Liberi continued committing perjury, fraud on the
court, and multiplying proceedings with the only purpose of harassment. They
have done it for a year and a half. It is time to stop this behavior and to sanction
this egregious conduct and egregious violation of the code of professional ethics
by a licensed PA attorney Philip J. Berg.
DATED: NOV 16, 2010
__/s/ Dr. Orly Taitz, ESQ__________

Dr. Orly Taitz, ESQ
Appellant in Pro Se and as
Counsel for Appellant
Defend Our Freedoms
Foundation
Exhibit 1
Affidavit of Member of the Third Circuit Court of Appeals Bar Attorney Jon Levy
ATTORNEY’S CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the:
APPELLANTS’ MOTION TO SANCTION AND STRIKE
was served by ECF or electronic mail on NOV 16, 2010, on the following parties:
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
Philip Berg, Esq.

Lisa Liberi c/o Law Office of Philip Berg
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444_2531

(610) 825_3134
FAX (610) 834_7659
E_Mail: philjberg@gmail.com
Public Integrity Section
Department of Justice
950 Pennsylvania Ave, NW
Washington DC 20530-0001
/s/ Orly Taitz

___________________________
Dr. Orly Taitz, Esq
11.16. 2010
I]NITED STATES COI]RT OF APPEALS
FOR THE THIRD CIRCINT
LisaLiberi et al,
Plainitffs Apellees,
No. 10-3000
Dr. Orly Taitz,et al.,

Defendants-Appellants,
Affidavit in SuDDortof Motion
Levy,declareasfollows:
l, Jonathan
I am an attomeyin good standingwith the Third Circuit Coult ofAppeals. I am not an

attomeyofr€cordin this matterbut did contactMr. PhilipBerg,plaintiffandattomeyfor
plaintiffs, on behalfof Dr. Taitz. Dr. Taitz wasextremelyrcluctantto contactMr. Berg
because ofseriouscriminalaccusations Mr. Bergis makingaboutDr. Taitz
I contactedMr. B€rgin regardsto theCourt'sorderofseptember9, 2009whichordered

the to delivera JointAppendixto theCout on or beforeOctober19,2010.Mr.
parties
Bergindicatedhe wouldnot bejoiningDr. Taitzin filing a JointAppendixbut woulddo
his own.
Secondly, thereis a F.R,C.P.Rule60 Motionpendingin thetrial courtin theEastem

DistrictofPennsylvania regardingthis case.I askedMr. Bergifhe wouldstipulateto a
continuanceto await the outcomeofthe Rule 60 motion, he answeredin the negative.
Also of seriousconcemis that Mr. Berg repeatedlyaccusedDr. Taitz of att€mpted

murderfor hire ofplaintiffLiberi andattemptingto anangethe kidnappingofplaintiff
Ostella'schildren.Mr. BergstatedI wassomehowresponsible for my client'salleged
acuons.
I declarcthat the aboveis true andconect underpenaltyofperjury at Bluffton, South

Carolinathis 14'ndayofNovember2010.
Le\T
Jonathan

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Case: 10-3000 Document: 003110349784 Page: 1 Date Filed: 11/17/2010

UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT

LISA LIBERI, et al.,

ORLY TAITZ, et al.,

District Court No. 09_cv_01898_ECR

DR. ORLY TAITZ, ESQ.

Dr. Taitz and Defend Our Freedoms Foundation (hereinafter referred to as

Appellants) bring a Motion to Strike the Appellee’s Response Brief as well as to

The underlying case in this matter involves an incomprehensible and totally

frivolous and extortionate lawsuit for nearly a billion dollars in damages by a

politically motivated Pennsylvania attorney, his legal assistant who is a convicted

of diversity jurisdiction and in particular whether district judge Eduardo Robreno

erred in creating a new standard, mainly assuming jurisdiction in a case based on

Diversity of Citizenship without any identifying documents of state citizenship of

preponderance of evidence. Whether Despite filing over 900 pages of largely

irrelevant exhibits in their so called appendix – that question remains unanswered

filed on May, 4, 2009 by Pennsylvania Attorney Philip J. Berg (hereinafter Berg)

convictions of forgery of documents, forgery of an official seal and grand theft.

summary of above criminal convictions ). According to Berg's own affidavit filed

Freedoms foundation (DOFF). She is licensed as a Doctor of Dental Surgery and

transparency in the government and adherence to the Constitution and made 36

Constitutional liberties and consequences of losing such liberties, as she saw in

March of 2011. She is under supervision of San Bernardino, CA probation

administrations. Taitz advised Berg, that he is endangering the public by

prepared by CA licensed investigator Neil Sankey, which showed lengthy criminal

a different woman, an innocent woman, who is residing in PA and working in

in front of the Presiding Judge Eduardo Robreno in this case, claiming to be a

Robreno issued an order and memorandum, where he assumed jurisdiction over

cases and transferred to TX and CA.

in assuming jurisdiction, as plaintiff Liberi never provided any evidence of her

PA citizenship. On 06.23.10 the court denied defendant's motion as moot. No

explanation was provided, why is it moot. On 07.02.10 Taitz filed a notice of

Circuit Court of Appeals denied Berg's motion.

plaintiffs did not provide a shred of evidence of Liberi's state residency.

06.04.10. order and memorandum, stating "Liberi is a resident of PA" is based on

vital records, including driver's license, allegedly submitted to Judge Robreno

outrageous accusation, where without a shred of evidence, they claimed that

Instead of responding to the issue of lack of evidence of Liberi's state

unsupported and defamatory allegations that Appellant Taitz is a would-be

severe as possible under the law are warranted in this case.

Appellant anticipated that Berg would be a problem. In a pending motion

leveled the allegations of murder and kidnapping to Levy in an aggressive manner

II LEGAL ARGUMENT 28 USC § 1927

28 USC § 1927 states:

§ 1927. Counsel's liability for excessive costs

Lisa Liberi is a resident of Pennsylvania, without providing any evidence of her

Pennsylvania residency. Taitz, and Defend our Freedoms Foundation, both CA

criminal convictions and probation conditions in CA, stating, that Liberi is on

Liberi v Taitz before judge Robreno claiming to be a different person. At the

convicted in CA and allowed to reside only in Ca or NM, but an innocent different

defendants with thousands of pages of unrelated inflammatory and defamatory

material instead of taking 1 minute and providing 1 page- a certified copy of

Liberi's PA drivers' license. Taitz agreed to accept a redacted drivers license,

same Lisa Liberi, who was convicted in CA and allowed to reside in CA or NM

Berg and his assistant Lisa Liberi.

on diversity of citizenship. Instead of following the Court’s direction and creating

material, there is still no PA drivers' license, no PA ID. Berg succeeded in

misleading judge Robreno by simply burying him under thousands of pages of

question and instead launched on a jihad against Appellant in which no accusation

Appellant of murder and kidnapping and wasting the Court’s time on an

775 F2d 177 (7th Cir. 1985).

§ 1927 is applicable to appellate briefs. A penalty of $ 1,000 was imposed

/s/ Dr. Orly Taitz, ESQ________