CCCCCCC Special Report - A Briefing On The Litigation History of The Attorneys in Liberi V Taitz (C.D. CA)

Special Report FROM THE C.C.C.C.C.C.C.
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C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY
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A Briefing on the Litigation History of the Attorneys in Liberi v. Taitz, No. 8:11-cv-00485 (C.D. Cal.) Page 3
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C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY HOW MANY CASES HAS BERG FILED IN THE PAST THREE YEARS ON BEHALF OF HIMSELF
Answer: Since August 2008, Berg has, on his own behalf, filed at least four complaints, thirteen appeals (in nine cases), and filed a motion seeking amicus curiae status to protect his personal interest in one other appeal.
COMPLAINTS
1. Berg v. Obama, et al (2008) U.S.D.C., Eastern District of Pennsylvania, Case No. 08-cv-04083-RBS 2. Berg, et al v. Obama, et al (Qui Tam Action) (2008) U.S.D.C., District of Columbia, Case No. 1:08-cv-01933-RWR
3. Liberi, et al v. Taitz, et al (2009) U.S.D.C., Eastern District of Pennsylvania, Case No. 09-cv-01898-ECR. This case was subsequently severed and transferred as follows:
a. Liberi, et al v. Belcher, et al (2011) U.S.D.C. Western District of Texas, Case No. 5:11-cv-00259-OLG, which was then transferred to U.S.D.C., Northern District of Texas Case No. 2:11-cv-00090-J b. Liberi, et al v. Taitz, et al (2011) U.S.D.C., Central District of California, Southern Division, Case No. 8:11-cv00485 AG 4. Berg and Miller v. Weichert Realtors, et al (2009) U.S.D.C., Eastern District of Pennsylvania, Case No. 2:09-cv-00321 LDD Case transferred to: U.S.D.C., District of New Jersey, Case No. 1:10-cv-00353 NHL (2010) (case settled thereafter).
APPEALS
1. Berg v. Obama, et al (2008)
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a. U.S. Court of Appeals for the Third Circuit, Case No. 08-4340 (2008) b. U.S. Supreme Court Application for Injunction, Case No. 08A391(2008) c. U.S. Supreme Court Application for Injunction, Case No. 08A505 (2008)
d. U.S. Supreme Court re Writ of Certiorari, Case No. 08-570 (2008)
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2. Philip J. Berg, et al., v. U.S. Bank National Association, Trustee for Lehman Brothers-Structured Assets Loan Trust Sail 2005-7 a. NJ Superior Court, Case No. A-4696-08T2 (2008)
b. U.S. Supreme Court re Application for Stay, Case No. 08A1140 (2008) 3. Rambo v. Greene (2008) Superior Court of Pennsylvania Case No. 2467 EDA 2008
4. Berg as Relator v. Obama (2009) U.S. Court of Appeals for the District of Columbia, Case No. 09-5362 5. Liberi, et al v. Taitz, et al (2009) U.S. Court of Appeals for the Third Circuit, Case No. 09-3403 (Berg voluntarily dismissed appeal.) 6. Berg v. Akropolis (2009) Superior Court of Pennsylvania, Case No. 3104 EDA 2009 7. In re Berg (2009) 1 Supreme Court of Pennsylvania , Case No. 51 MAP 2009 8. In re Philip Jay Berg (2009)
a. U.S.D.C., Eastern District of Pennsylvania, Case No. 2:09-cv-02803 b. U.S. Court of Appeals for the Third Circuit, Case No. 10-2243
OTHER FILINGS
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1. Hollister v. Soetoro, et al (2009) U.S. Court of Appeals for the D.C. Circuit, Case Nos. 09-5080 and 09-5161 (consolidated) (Mr. Berg filed emergency motion to participate as amicus curiae in appeal, citing personal stake in outcome of case as grounds for appearing as amicus curiae).
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means that Berg failed to include the case in his August 30, 2011 submission.
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C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY IN HOW MANY CASES HAS BERG PERSONALLY BEEN A PARTY IN THE PAST THREE YEARS,
WITH A LIST OF CASE NAMES AND NUMBERS
Answer: Since August 2008, Berg has, on his own behalf, filed at least four complaints, thirteen appeals (in nine cases), and sought to serve as amicus curie in one appeal. Additionally, Berg has been a defendant in approximately six cases (upon information and belief), and has been a party to four appeals (in three cases). In addition to the cases listed in response to Question 1, and upon information and belief, Mr. Berg has personally been a party to the following cases within the past three years.
COMPLAINTS
1. In re Berg (2009) Commonwealth Court of Pennsylvania (Montgomery County), No. 142 MD 2009
3. Capital One Bank v. Philip J. Berg (2009)
(upon information and belief, based on publicly available New Jersey court docket search for Philip J. Berg)
New Jersey Circuit Court (Mercer County), No. DC 001336 09

New Jersey Chancery Court, No. F 004545 09 5. In re Philip J. Berg (2010) Disciplinary Board of Supreme Court of Pennsylvania, Case No. 208 DB 2010
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7. Thomas G. Oakes Assoc. v. Philip J. Berg, (2011)
Although this case was initially filed before August 2008, Berg appealed the decision and that appeal was still pending after 2008. See Holsworth v. Berg, No. 05-4033, 332 Fed. Appx. 143, 2009 WL 1028039 (3rd Cir. 2009). Therefore, it qualifies as a case in which Berg has personally been a party to in the past three years.
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6. Asset Acceptance LLC v. Philip J. Berg (2010)

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4. Fed. Natl. Mtg. v. Paula Berg et al (2009)
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2. Holsworth v. Berg (2005)2 U.S.D.C., Eastern District of Pennsylvania, No. 05-CV-01116
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C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY APPEALS
1. Holsworth v. Berg (2005)3 U.S. Court of Appeals for the Third Circuit, Case No. 05-4033 2. Liberi, et al v. Taitz, et al (2010) U.S. Court of Appeals for the Third Circuit, Case No. 10-3000 3. Liberi, et al v. Taitz, et al (2011)
a. U.S. Court of Appeals for the Ninth Circuit, Case No. 11-56079
b. U.S. Court of Appeals for the Ninth Circuit, Case No. 11-56164
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Although this appeal was initially filed before August 2008, the appeal was still pending after August 2008. See Holsworth v. Berg, No. 05-4033, 332 Fed. Appx. 143, 2009 WL 1028039 (3rd Cir. 2009). Therefore, it qualifies as a case in which Berg has personally been a party to in the past three years.
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C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY HOW MANY SANCTION ORDERS HAVE BEEN ISSUED AGAINST BERG IN EITHER A PRO SE OR REPRESENTATIVE CAPACITY IN THE PAST THREE YEARS, IN WHAT AMOUNT OR OTHER FORM, AND IN WHICH CASES
Answer: At least four sanction orders (in four cases and/or appeals) have been issued against Berg in the past three years: 1. Shecktor v. Louisville Ladder, No. 4:09-cv-01570 (M.D. Pa. 2009)
Sanction: Mr. Berg was sanctioned $1,000 as attorney fees payable to Defense Counsel by Judge John E. Jones, III for a discovery issue. See Order Granting Motion to Compel (M.D. Pa. Jun. 23 2011). 2. Holsworth v. Berg, No. 05-4033 (3rd. Cir. 2005)
3. In re Philip Jay Berg, No. 2:09-cv-02803 (E.D. Pa 2009)
4. In re Philip Jay Berg, No. 10-2243 (3rd Cir. 2011) Sanction: Mr. Bergs appeal of the Eastern District of Pennsylvanias dismissal of his appeal of a bankruptcy order was also dismissed as a sanction for failing to follow court rules. See CLERK ORDER dismissing case, pursuant to F.R.A.P. 3(a) and LAR 11.1 and LAR Misc. 107.1(b), for failure to make financial arrangements for payment of the transcript. (Mar. 17, 2011). (Note: LAR Misc. 107.1 permits the court to impose the sanction of dismissal against a party who fails to pay the required court fees).
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Sanction: Mr. Bergs appeal of a bankruptcy order was dismissed as a sanction for failing to follow court rules. See Order Dismissing Appeal for Reasons Stated on the Record (Mar. 25, 2010).
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Sanction: After affirming a pre-2008 Rule 11 Sanction against Mr. Berg, the Court ordered Mr. Berg to pay $15,849.00 in attorneys fees to appellees under Fed. R. App. Proc 38 for filing frivolous appeal. See Holsworth et al v. Berg et al, No. 05-4033, Order Granting Appellees Motion for Reimbursement of Fees Pursuant to FRAP 38 (3rd Cir. Oct. 15, 2009).
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C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY HOW MANY TIMES HAS A COURT (A) DIRECTLY ADMONISHED, (B) DENIED OR REVOKED PRIVILEGED, AND/OR (C) THREATENED BERG WITH SANCTIONS IN THE PAST THREE YEARS?
Answer: In addition to the sanctions identified above, Berg has been admonished, had privileges denied or revoked, and/or been threatened with sanctions in written orders4 at least fourteen times in at least five cases during the past three years: 1. Liberi et al v. Taitz et al, No. 2:09-cv-01898 (E.D. Pa)
a. Court Action/Admonishment: Court revoked Bergs right to file motions without prior leave of the court. See Order (Imposing Filing Restrictions) (Jun. 26, 2009). b. Court Action/Admonishment: The Court devoted a section of its Memorandum to discussing the parties behavior: VII. BEHAVIOR OF THE PARTIES
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2. Liberi et al v. Taitz et al, No. 09-3403 (3rd. Cir.) Court Action/Admonishment: Court admonished the parties as follows: Counsel are admonished to avoid further invective and to confine themselves to civil and appropriately focused filings in any further appeal. See Liberi v. Taitz, No. 09-3403, Order Dismissing Appeal (3rd Cir. May 3, 2010).
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There were no winners at the hearing but surely there was one loserthe search for truth in an environment of decorum. For this sorry episode, both Taitz and Berg bear much of the blame. See Liberi v. Taitz, 759 F.Supp.2d 573, 579 (E.D. Pa. 2010)
Court admonishments during hearings as reflected in transcripts are not included.
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During the hearing the Court reminded Berg and Taitz that sanctions may be ordered under Rule 11, 28 U.S.C. 1927, and the inherent power of the Court. ... *** Additionally, very serious accusations were made during this hearing, such as: the hiring of a hit-man to kill a party, the stealing a party's donation funds, and attempting to kidnap a child of one of the party's to the lawsuit. The Court will remind the lawyers that they were warned by the Court that making such serious accusations without proof to back them up could result in their referral to the disciplinary board.
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3. Hollister v. Soetoro, No. 1:08-cv-02254-JR (D.D.C) Outcome: Bergs client lost; Bergs local counsel sanctioned.
a. Court Action/Admonishment: Court declined to issue Rule 11 show cause order against Berg, even though he found that Berg had filed frivolous case, in order to prevent Berg from further misusing public and private resources: Mr. Berg and Lawrence J. Joyce, an attorney who lives in Tucson, Arizona, signed the complaint in this case. (They have been filing electronically although they have not been admitted pro hac vice, see [# 10].) They are agents provocateurs-and any attempt to sanction them for misuse of the public and private resources that have had to be devoted to this case would only give them a forum to continue their provocation. See Memorandum Opinion, 601 F.Supp.2d 179 (D.D.C. 2009). b. Court Action/Admonishment: In memorandum order imposing sanctions on local counsel, the Court described the complaint drafted and signed by Berg (who was not admitted pro hac vice) as follows: The case offered no hope whatsoever of success, and plaintiffs' attorneys surely knew it.). Memorandum Order, 258 F.R.D. 1 (D.D.C. 2009). The court imposed a minimal sanction against the local counsel, noting that [o]thers similarly situated the people who put Mr. Hemenway up to filing this foolish suit [referencing, via footnote, Berg] are unlikely to be deterred, except by a penalty that would be unreasonable to impose on Mr. Hemenway alone. Id. and n.4. 4. Lincoln v. Daylight Chemical Info. Sys. Inc., et al, No. 8:10-cv-01573-AG PLA ( C.D. Cal.) Court Action/Admonishment: Court denied Bergs motion for pro hac vice admission after a hearing. See Order Denying Application of Non-resident Attorney to Appear in a Specific Case (Mar. 3, 2011). 5. Liberi, et al v. Taitz, et al, No. 8:11-cv-00485 (C.D. Cal.)
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a. Court Action/Admonishment: Court admonished Berg as follows: [T]he Court will keep a close eye on the filings by all parties and may choose to implement [restrictions on filing without leave of court] as the case progresses in this Court. See Order Denying Ex Parte Application (May 2, 2011). a. Court Action/Admonishment: Court noted that Bergs proposed draft amended complaint with its exhibits is hundreds of pages long, and reflects a poor pleading style that does not follow the charge to provide a short and plain statement. FED. R. CIV. P. 8(a). The Court has concern that the voluminous filings in this case are filling court files with unnecessary and scurrilous documents. ... Thus, Plaintiff may only file a first amended complaint that with no exhibits and no reference to exhibits within the body of the complaint. Before
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filing such an amended complaint, Plaintiff must review the PFAC to remove references to exhibits which are not to be attached. If Plaintiffs disregard these instructions, the Court may strike the amended complaint, which may leave Plaintiffs without an operative complaint. See Order Granting Motion for Leave to Amend, Denying Motion to Strike and Motion to Dismiss, and Imposing Restriction on Filing at 7-8 (Jun. 14, 2011). b. Court Action/Admonishment: Court admonished the parties as follows:
c. Court Action/Admonishment: Court admonished Berg as follows: The Court imposed a pre-filing restriction on the parties in this matter. In the Order imposing the requirement, the Court stated: Failure to comply with the letter and spirit of this order may result in sanctions, including the summary denial of improperly requested motions, or other sanctions such as dismissal or striking of the answer. (Dkt. # 227) (emphasis in original). The pre-filing restriction does NOT include the right to reply to a request. Plaintiff and counsel Philip J. Berg has filed a reply letter to a request by Defendant Orly Taitz. Such a filing is in violation of the spirit of the pre-filing restriction. Any future violations of the pre-filing restriction will likely result in sanctions.
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See Order Regarding Prefiling Requirement (Jun. 29, 2011) (all caps in original).
d. Court Action/Admonishment: Court admonished Berg as follows:
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See Order Granting Motion for Leave to Amend, Denying Motion to Strike and Motion to Dismiss, and Imposing Restriction on Filing at 9 (Jun. 14, 2011) (emphasis in original).
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The Court previously warned the parties that it might impose restrictions on filing in this case. (Dkt. # 183.) The Court finds that such a restriction is appropriate at this time ... given the flood of filings before the Court. The Court now ORDERS all parties to seek leave of Court before filing any motions or other documents in this case. A party seeking leave to file a motion or other document may do so by letter to the Court, with copies to all parties. The letter shall be no more than two pages and shall set forth the nature of the motion or document and good cause for its filing. The letter shall have no attachments or exhibits. Upon a showing of good cause, the Court may grant leave to file. Failure to comply with the letter and spirit of this order may result in sanctions, including the summary denial of improperly requested motions, or other sanctions such as dismissal or striking of the answer.
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Many of the requests from the parties, and in particular from Orly Taitz, include unnecessary rehashing of disputed facts. The Court is familiar with the background of this case and need not be reminded of, for example, the alleged criminal history of plaintiff Lisa Liberi or Taitzs characterization of this cases procedural history. The unnecessary inclusion of facts and arguments irrelevant to a particular request may weaken a partys showing of good cause. Concerning this Courts June 14, 2011, Order, ALL FUTURE REQUESTS MUST BE FOCUSED, CLEAR, AND CONCISE, WITH NO UNNECESSARY MATERIAL. See Order Granting In Part And Denying In Part Requests For Leave To File (Jul. 26, 2011) (allcaps in original). e. Court Action/Admonishment: Court admonished Berg as follows:
1) How many cases they have filed in the past three years on behalf of themselves or affiliated entities with a list of case names and numbers; 2) How many cases they have personally been a party to in the past three years (including cases they filed), with a list of case names and numbers; and 3) How many sanction orders have been issued against them in either a pro se or representative capacity in the past three years, in what amount or other form, and in which cases.
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See Order to Submit Information (Aug. 12, 2011) (underlining in original).
f. Court Action/Admonishment: Court admonished Berg as follows: The parties have submitted numerous new requests to file motions and other documents. The parties will increase their likelihood of prompt ruling by limiting themselves to thoughtful requests and avoiding unnecessary submissions to the Court. See Order Granting and Denying Requests to File (Aug. 12, 2011) g. Court Action/Admonishment: Court admonished Berg as follows: The Court concludes that the provisions of the 2009 Stipulation applied to Yosef Taitz regarding the FAC and that Plaintiffs failed to comply with those provisions. It does not appear that the Court was notified by any party about the 2009
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The Court is aware that some parties to this case have been involved in numerous lawsuits and the Court has ongoing concerns about the litigation history and behavior of certain parties here. The Court must therefore ORDER that Plaintiff Philip J. Berg and Defendant Orly Taitz file a document with the Court by September 2, 2011, answering the following about themselves:
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Stipulation before the Court granted Plaintiffs motion to file a first amended complaint. That information would have been helpful to this transferee Court in making a proper ruling on the motion for leave to amend. Plaintiffs failure to inform the Court about the 2009 Stipulation demonstrates a worrisome lack of candor. See Order Granting Motion to Dismiss at 4-5 (Aug. 23, 2011)
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C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY HOW MANY TIMES HAS A COURT EXPRESSLY CRITICIZED BERG FOR (A) FAILING TO FOLLOW THE RULES OR (B) FILING FRIVOLOUS PLEADINGS UNSUPPORTED BY LAW OR FACT IN AN ORDER?
Answer: In addition to the sanctions identified above and the multiple court admonishments/ actions identified above, Bergs failure to follow the rules and/or repeated filing of frivolous pleadings with no factual or legal support criticized by the courts in written orders5 at least ten times (in eight cases) during the past three years: 1. Berg v. Obama, No. 08-cv-04083-RBS (E.D. Pa.)
Court found several of Bergs standing arguments frivolous and not worthy of discussion. See Memorandum Opinion, 574 F.Supp.2d 509, 521 (E.D. Pa. 2008).6 2. Berg v. Obama, No. 08-4340 (3rd Cir.)
3. Berg v. Obama, 1:08-cv-01933-RWR (D.C. Cir.) See Memorandum Opinion, 656 F.Supp.2d 107, 110 (D.D.C. 2009) (criticizing Berg for provid[ing] absolutely no legal support for his argument).
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See also id. at 514 n.6 (noting that after defendants filed a motion to dismiss, Berg filed five different Motions, including a Motion for Summary Judgment but no opposition to the motion to dismiss); id. at 519 (*Berg+ ventures into the unreasonable with arguments based on a number of federal statutes); id. at 524 (...Plaintiff relies on generalized arguments about political corruption and the purpose of the Campaign Act.); Berg v. Obama, 656 F.Supp.2d 107 (E.D. Pa. 2009) (in denying motion for reconsideration, Court noted that Berg provides absolutely no legal support for [one of his claims]. Nor has he cited any authority [for a second claim+). See also id. at 240-41 (3rd Cir. 2009) (in rejecting Bergs 10th Amendment claim, the court held that the clause has no apparent relevance to this case and Berg's citation to [case law] is not helpful.); see also id. at 241 (characterizing Bergs citation to other authority as baffling).
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Court criticisms during hearings as reflected in transcripts are not included.
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b. Court affirmed the lower court ruling, noting the obvious lack of any merit in Bergs contentions. See Berg v. Obama, 586 F.3d 234, 239 (3rd Cir. 2009); see also id. at 242 (finding Bergs First Amendment and Due Process arguments to be frivolous); id. at 242, n.6 (Bergs arguments that the District Court ignored some of his voluminous motions and other pleadings not only suffer from fatal defects in their reasoning, but are irrelevant).7
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a. Court denied motion, noting that Berg utterly failed to address lower courts ruling in his motion. See Oct. 24, 2008 Order.
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4. Berg et al v. Weichert Realtors et al, No. 2:09-cv-00321 (E.D. Pa. 2009).
Court criticized Berg because he merely make[s] a conclusory allegation that Defendants do not present meritorious defenses and fail[s] to contest the merit of the defenses ... Plaintiffs have failed to oppose or otherwise respond to Defendants personal jurisdiction defense. This Court also advised Plaintiffs that they had to address this issue in their documents, but Plaintiffs did not do so. See Order Denying Motion for Default at 6 (E.D. Pa. Nov. 15, 2009); see also); but see Dec. 16, 2009 Order (setting aside portion of order dismissing case and transferring the case to New Jersey).8 5. Liberi et al v. Taitz et al, No. 2:09-cv-01898 (E.D. Pa)
6. Liberi, et al v. Taitz, et al, No. 8:11-cv-00485 (C.D. Cal.) Court: This case is roiled by in-fighting, petty history, and an apparent disregard for accuracy and fair play. Thus, the discernment of truth is a constant difficulty for the Court. As Judge Robreno of the transferor court stated in an order dated December 23, 2010, regarding the outcome of a hearing on requests for temporary restraining orders, There were no winners at the hearing but surely there was one loser the search for truth in an environment of decorum. See Order Granting Motion for Leave to Amend, Denying Motion to Strike and Motion to Dismiss, and Imposing Restriction on Filing at 5 (Jun. 14, 2011).
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After transfer (and dismissal of two defendants), the case was apparently settled. See Docket for Berg et al v. Weichert Realtors et al, No. 1:2010-cv-00353 (D.N.J..), filed Jan. 20, 2010.
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b. See also Memorandum Opinion 759 F.Supp.2d 573, 579 (E.D. Pa. Dec. 23, 2010) (providing litany of factual claims for which Berg failed to provide any credible evidence).
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a. Court: This litigation involves an intramural dispute among persons who have, at times jointly, challenged the legitimacy of President Barack Obamas presidency.... The instant case is just one piece of this far flung litigation, which is now pending in at least three federal courts. As an initial matter, the Court notes that Plaintiffs filed the instant motion without first seeking leave of the Court, in violation of the Courts explicit order, dated June 25, 2009 (doc. no. 78). Although Plaintiffs assert that, pursuant to Rule 8 of the Federal Rules of Appellate Procedure, their filing is proper, the Court disagrees. See Order Denying Motion for TRO (Aug. 25, 2009) .
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7. In re Philip Jay Berg, No, 05-39380-bif (E.D. Pa.)
The courts blistering opinion excoriates Berg repeatedly for obfuscation and other improper behavior in the proceeding in passages too long to include in this summary. See Memorandum Opinion, 407 B.R. 167, 174-75 (Bankr. E.D. Pa. Apr. 1, 2009).9 8. In re Berg, No. 142 M.D. 2009 (Pa. Cmwlth.)
Court: In ordering removal of Bergs name from judicial ballot for violation of Notary Public law when he notarized his own judicial nomination petition, the court noted that it would be difficult to conclude that Berg acted with due diligence because, when Berg took the oath of office as a notary public, he was legally charged with knowing the requirements of acting as a notary under the Notary Public Law. See In re Berg, 973 A.2d 447 (Pa.Cmwlth. 2009), aff'd 601 Pa. 85, 971 A.2d 486 (Pa. 2009). 9. U.S. Bank Natl Assoc. v. Berg, No. F-1888-07 (N.J. Super. A.D. unpublished disposition, 2010 WL 3932984 (N.J. Super. A.D. Oct. 5, 2010) Court affirmed lower courts entry of foreclosure default (after determining that Berg had filed a nononforming answer to complaint), and rejected Bergs arguments on appeal because, among other reasons, he did not move to vacate judgment within a reasonable time. See U.S. Bank Natl Assoc. v. Berg, unpublished disposition, 2010 WL 3932984 (N.J. Super. A.D. Oct. 5, 2010)
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See, e.g., 407 B.R. 167 at 175 (*Bergs+ challenge ... is contrary to his testimony and in any event, too little, too late); id. at 177 (characterizing Bergs testimony as general and conclusory. While he repeatedly affirmed the accuracy and fairness of the deductions he took, he gave me no basis to confirm that was so. He failed to corroborate any expens ..... While he asked for and was given extra time to locate his records which he claimed were available in storage, he made only the most meager effort to find them. ... Until the end, he was seeking to avoid the hearing....); id. at 175 (characterizing Bergs arguments as a red herring); id at 177 (noting that none of three cases cited by Berg supported his argument); id. at 180-81 (*Berg+ is a litigation attorney and is aware more than most of the need to support a position that is being challenged. He did nothing to locate his business records .... He did nothing to segregate the records at the time he vacated his office space even though he knew of the IRS's determination. He continued to do nothing to locate his business records after he objected to the proof of claim and put the amount of those deductions at issue. Once the Claim Objection was scheduled for hearing, he made, by his own admission, little effort to locate the records in his storage bins. The only effort that the Debtor made was to secure continuancesfirst allegedly to search for documents in storage, then to find the missing accountant who he claimed had the records that he previously said were in storage, then to have his mother testify, even though she would only state that they were in storage or with the accountant.)
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C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY BERG TABLE OF CASES

Case Caption
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Disclosed?
Disposition?
Criticized?
Asset Acceptance LLC v. Philip J. Berg, No. DC 011880 10 (N.J. Cir. Ct. (Mercer) 2010)11 Berg and Miller v. Weichert Realtors, et al, No. 2:09-cv00321 LDD (E.D. Pa. 2009) Berg v. Obama, et al, No. 08-cv-04083-RBS (E.D. Pa. 2008) Berg v. Obama, et al, No. 08-4340 (3rd. Cir. 2008) Berg v. Obama, et al, No. 08A391 (U.S. Application for Injunction 2008) Berg v. Obama, et al, Case No. 08A505 (U.S. Application for Injunction 2008)
Settled
Berg v. Obama, et al, No. 08-570 (U.S. Petition for Writ of Certiorari 2008)
Berg as Relator v. Obama, No. 1:08-cv-01933-RWR (D.C.D. 2008) (Qui Tam Action)
Berg as Relator v. Obama, No. 09-5362 (D.C. Cir. 2009) (Qui Tam Action) Berg v. Akropolis, No. 3104 EDA 2009 (Pa. Super. Ct. 2009)
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Disclosed? Y=N= -- -- Disposition? Win Loss Pending -- -- Criticized? Y= -- -- Admonished? Y= -- -- Sanctioned: Y= Listed upon information and belief, based on publicly available New Jersey court docket search for Philip J. Berg.
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Admonished?
Sanctioned?
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Case Caption Disclosed? Disposition? Criticized?
Capital One Bank v. Philip J. Berg, No. DC 001336 09 (N.J. Cir. Ct. (Mercer) 2009)12 Fed. Natl. Mtg. v. Paula Berg et al, No. F 004545 09 (N.J. Chanc. Ct. 2009)13 Hollister v. Soetoro, No. 1:08-cv-02254-JR (D.D.C) Hollister v. Soetoro, et al, Nos. 09-5080 and 09-5161 (consol.) (D.C. Cir. 2009).14 Holsworth v. Berg, No. 05-CV-01116 (E.D. Pa. 2005)15 Holsworth v. Berg, No. 05-4033 (3rd Cir. 2005)16 In re Berg, No. 142 MD 2009 (Pa. Commw. Ct. (Montgomery) 2009) (Notary Case) In re Berg, No. 51 MAP 2009 (Pa. Supreme Ct. 2009)

Not within scope
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Listed upon information and belief, based on publicly available New Jersey court docket search for Philip J. Berg. Listed upon information and belief, based on publicly available New Jersey court docket search for Philip J. Berg. Mr. Berg filed emergency motion to participate as amicus curiae in appeal, citing personal stake in outcome of case as grounds,
Although this case was initially filed before August 2008, Berg appealed the decision and that appeal was still pending after 2008. See Holsworth v. Berg, No. 05-4033, 332 Fed. Appx. 143, 2009 WL 1028039 (3rd Cir. 2009). Therefore, it qualifies as a case in which Berg has personally been a party to in the past three years. Note, however, that the sanction order was issued long before August 2008, so it is not responsive to the courts request for information.
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Although this appeal was initially filed before August 2008, the appeal was still pending after August 2008. See Holsworth v. Berg, No. 05-4033, 332 Fed. Appx. 143, 2009 WL 1028039 (3rd Cir. 2009). Therefore, it qualifies as a case in which Berg has personally been a party to in the past three years.
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Admonished?
Sanctioned?
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Case Caption Disclosed? Not within scope17 Disposition? Criticized?
In re Philip Jay Berg, No, 05-39380-bif (E.D. Pa. Bankr. 2005) (IRS) In re Philip Jay Berg, No. 2:09-cv-02803 (E.D. Pa. 2009) (appeal of bankr. order) In re Philip J. Berg, No. 10-2243 (3rd Cir. 2010) In re Philip J. Berg, No. 208 DB 2010 (Disciplinary Board of Pa. Supreme Ct 2010) Sup. Ct. of Pa. Pennsylvania, Case Liberi, et al v. Taitz, et al, No. 09-cv-01898-ECR (E.D. Pa. 2009) Liberi, et al v. Taitz, et al, No. 09-3403 (3rd. Cir. 2009) (Berg appeal).
Liberi, et al v. Taitz, et al, No. 10-3000 (3rd Cir. 2010) (Taitz appeal). Liberi, et al v. Belcher, et al (N.D. Tex. 2011)18
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Case was not within scope of Courts inquiries.
Case transferred from E.D. Pa to W.D. Texas (No. 5:11-cv-00259-OLG), and then to N.D. Texas.
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Dismissed / Lack of Jurisdiction

Case Caption Disclosed? Disposition? Criticized?
Liberi, et al v. Taitz, et al, No. 8:11-cv-00485 AG (C.D. Cal. 2011) Liberi, et al v. Taitz, et al, No. 11-56079 (9th Cir. 2011) (Taitz Parties appeal) Liberi, et al v. Taitz, et al, No. 11-56079 (9th Cir. 2011) (Taitz Parties appeal) Lincoln v. Daylight Chemical Info. Sys. Inc., et al, No. 8:10cv-01573-AG PLA (C.D. Cal. 2010). Philip J. Berg, et al., v. U.S. Bank Natl Assoc., Trustee for Lehman Brothers-Structured Assets Loan Trust Sail 2005-7, No. A-4696-08T2 (NJ Super. Ct. 2008) Philip J. Berg, et al., v. U.S. Bank Natl Assoc..., No. 08A1140 (U.S. Application for Injunction 2008) Rambo v. Greene, No. 2467 EDA 2008 (Pa. Super. Ct. 2008) Shecktor v. Louisville Ladder, No. 4:09-cv-01570 (M.D. Pa. 2009)

Not within scope
Voluntarily Dismissed
Thomas G. Oakes Assoc. v. Philip J. Berg, No. DC 004054 11 (N.J. Super. Ct. (Mercer) 2011)19
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Listed upon information and belief, based on publicly available New Jersey court docket search for Philip J. Berg.
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C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY
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C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY HOW MANY CASES HAS TAITZ FILED IN THE PAST THREE YEARS ON BEHALF OF HERSELF?
Answer: Since August 2008, Taitz has, on her own behalf, filed at least eight complaints, sought to intervene in two cases, and filed six appeals (in two cases).
COMPLAINTS
1. Taitz v. Obama (2010) U.S.D.C. District of Columbia, Case No. 1:10-cv-00151
2. Taitz v. Dunn (2010) Cal. Superior Ct (Orange County), Case No. 30-2010-00381664-CU-FR-CJC
3. Medical Dental Dev. LLC v. Pierson (2010) Cal. Superior Ct (Orange County), Case No. 30-2010-00367447-CU-BC-CJC
5. Taitz v. Astrue (2011) U.S.D.C. District of Columbia, Case No. 1:11-cv-00402 6. Taitz v. Ruemmler (2011) U.S.D.C. District of Columbia, Case No. 1:11-cv-01421 7. Taitz v. Astrue (2011) U.S.D.C. Hawaii, Case No. 1:11-mc-00158 (HID) 8. Taitz v. Fuddy (2011) First Circuit Court of Hawaii. Case No. 1CC11-1-001731
1. Rhodes v. MacDonald (2009-10)
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APPEALS
a. 11th Circuit Court of Appeals, Case No. 09-15418 (2009) b. U.S. Supreme Court Application for Injunction, Case No. 10A56 (2010) c. U.S. Supreme Court Petition for Writ of Certiorari, Case No. 10-541 (2010)
means that Taitz failed to include the case in her September 2, 2011 submission.
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4. Taitz v. 21 Century Insurance Co. (2010) 20 Ca. Super. Ct. (Orange County), Small Claims Court, Case No. 2010-00381664-CUFR-CJC
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2. Liberi, et al v. Taitz, et al (2010)
a. U.S. Court of Appeals for the Third Circuit, Case No. 10-3000 (2010)
b. U.S. Court of Appeals for the Ninth Circuit, Case No. 11-56079 (2011) c. U.S. Court of Appeals for the Ninth Circuit, Case No. 11-56164 (2011) 3. Taitz v. Bowen California Supreme Court, Case No. S184384 (2010)
MOTIONS TO INTERVENE
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2. Florida et al. v. U.S. Dep. of Health & Human Svs. (2010) (Motion to Intervene) Northern District of Florida, Case No. 3:10-cv-91-RV/EMT (Taitzs motion to intervene in lawsuit challenging the Patient Protection and Affordable Care Act as unconstitutional on the grounds that President Obama is not a natural born citizen was denied).
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1. Hornbeck Offshore Services, L.L.C. v. Salazar et al (2010) (Motion to Intervene) U.S.D.C. Eastern District of Louisiana, Case No. 2:10-cv-01663-MLCF-JCW (Taitzs motion to intervene in lawsuit challenging one of the Obama Administrations post-oil spill drilling moratorium as unconstitutional on the grounds that President Obama is not a natural born citizen was denied).
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C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY IN HOW MANY CASES HAS TAITZ PERSONALLY BEEN A PARTY IN THE PAST THREE YEARS,
WITH A LIST OF CASE NAMES AND NUMBERS
Answer: Since August 2008, Taitz has, on her own behalf, filed at least eight complaints, sought to intervene in two cases, and filed six appeals (in two cases). Additionally, Taitz has been a defendant in at least three cases (upon information and belief), and has been a party to eight appeals or other filings. In addition to the cases listed in response to Question 1, and upon information and belief, Ms. Taitz has personally been a party to the following cases within the past three years.
COMPLAINTS
1. Liberi et al v. Taitz et al (2009) U.S.D.C. Eastern District of Pennsylvania, Case No. 2:09-cv-01898 This case was subsequently severed and case involving Taitz was transferred to: Liberi, et al v. Taitz, et al (2011) U.S.D.C., Central District of CA, Southern Division, Case No. 8:11-cv-00485
3. Lincoln v. Daylight Chem. Info. Sys. Inc. et al (2010) U.S.D.C. Central District of California, Case No. 8:10-cv-01573-AG PLA
APPEALS
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1. Liberi, et al v. Taitz, et al (2009) U.S. Court of Appeals for the Third Circuit, Case No. 09-3403
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2. Fazel v. Taitz (2010) Ca. Super. Ct. (Orange County), Small Claims Court, Case No. 30-2010-00405406-SCSC-HLH
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C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY OTHER FILINGS (EXCLUDING TRAFFIC COURT CASES21)
1. Rivernider et al v. U.S. Bank National Association (2009) U.S.D.C. Southern District of Florida, Case No. 9:09-cv-81255
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According to California Superior Court Orange County Criminal & Traffic Court records available online, Dr.. Taitz received at least seven traffic tickets, all but one of which was resolved against her: 1. 2. 3. 4. 5. 6. 7. Traffic Court Case No. SH673916 - Ca. Superior Ct (Orange County), (disp. Sep. 15, 2008) Traffic Court Case No. SH713463 (disp. Jun. 26, 2009) Traffic Court Case No. No.. SJ026342PEB (disp. Sep. 30, 2009) Traffic Court Case No. 14852LC (disp. Jan 15, 2010) Traffic Court Case No. SH749328 (disp. Dec. 21, 2009) Traffic Court Case No. SH753526 (disp. May 12, 2010) Traffic Court Case No. disp. Apr. 19, 2011)
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C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY HOW MANY SANCTION ORDERS HAVE BEEN ISSUED AGAINST TAITZ IN EITHER A PRO SE OR REPRESENTATIVE CAPACITY IN THE PAST THREE YEARS, IN WHAT AMOUNT OR OTHER FORM, AND IN WHICH CASES
Answer: At least two sanction orders (in two cases) have been issued against Taitz in the past three years: 1. Rhodes v. MacDonald et al, No. 4:09-cv-00106 (M.D. Ga.)22
Sanctions: Court imposed $20,000.00 sanction on Taitz due to attorney misconduct. See Order Imposing Sanctions, 670 F.Supp.2d 1363 (Oct. 13, 2009), affd, 368 Fed.Appx. 949, 2010 WL 892848 (11th Cir. Mar. 15, 2010). Selected excerpts from the Order include:
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The Court finds that counsels conduct was willful and not merely negligent. It demonstrates bad faith on her part. As an attorney, she is deemed to have known better. She owed a duty to follow the rules and to respect the Court. Counsels pattern of conduct conclusively establishes that she did not mistakenly violate a provision of law. She knowingly violated Rule 11. Her response to the Courts show cause order is breathtaking in its arrogance and borders on delusional. She expresses no contrition or regret regarding her misconduct. To the contrary, she continues her baseless attacks on the Court. Defiantly defending the position of the patriots, she scoffs at the notion that a federal court would consider sanctioning her when she is on the side of such freedom fighters as the late Justice Thurgood Marshall, a comparison that, if accepted, would disgrace Justice Marshalls singular achievements. Counsels bad faith warrants a substantial sanction.
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In her submission, Dr. Taitz contends that this sanction is currently being reviewed by the United Nations Commission for Civil Right Defenders. (Doc. 365, filed Sept. 2, 2011) No such UN Commission exists.
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The absolute absence of any legitimate legal argument, combined with the political diatribe in her motions, demonstrates that Ms. Taitzs purpose is to advance a political agenda and not to pursue a legitimate legal cause of action. Rather than citing to binding legal precedent, she calls the President names, accuses the undersigned of treason, and gratuitously slanders the Presidents father. As the Court noted in an earlier order, counsels wild accusations may be protected by the First Amendment when she makes them on her blog or in her press conferences, but the federal courts are reserved for hearing genuine legal disputes, not as a platform for political rhetoric and personal insults. Simply put, no reasonable basis existed for counsel to believe that her legal cause of action was legitimate under existing law or under a reasonable extension or modification of existing law. Thus, counsels Complaint on behalf of Captain Rhodes was frivolous. (Order (Slip Opinion) at 28.)
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Counsels misconduct was not an isolated event; it was part of a pattern that advanced frivolous arguments and disrespectful personal attacks on the parties and the Court. This pattern infected the entire proceeding, not just an isolated pleading. Her initial Complaint was legally frivolous. Upon being so informed, counsel followed it with a frivolous motion for reconsideration. In response to the Courts show cause order, she filed a frivolous motion to recuse. In all of counsels frivolous filings, she hurled personal insults at the parties and the Court. Rather than assert legitimate legal arguments, counsel chose to accuse the Court of treason and of being controlled by the Obama Machine. She had no facts to support her claimsbut her diatribe would play well to her choir. This pattern of conduct reveals that it will be difficult to get counsels attention. A significant sanction is necessary to deter such conduct. (Order (Slip Opinion) at 32-33.) Although the Court has not thoroughly researched counsels record to find similar instances of misconduct in other cases, the Court is aware of at least two other cases related to this one where counsel engaged in similar conduct. First, counsel filed the very same case on behalf of Captain Rhodes in the Western District of Texas and then refiled it here upon the Texas courts finding that she had no reasonable possibility of success on the merits. Counsel filed another similar action here on behalf of Major Cook in which she insisted on pursuing the case even though the Army had revoked the deployment order. Then, counsel filed another action on behalf of Major Cook in the Middle District of Florida. That action was summarily dismissed, and upon losing there, counsel filed a motion to recuse that judge; that motion to recuse was found to be frivolous. Counsels similar conduct in other actions demonstrates that substantial sanctions are necessary to deter future misconduct. (Order (Slip Opinion) at 34-35.) 2. Liberi et al v. Taitz et al, No. 8:11-cv-00485-AG AJW (C.D. Cal.) Sanctions: Court imposed $250.00 penalty as sanction for failing to follow court orders (i.e., filing at least three pleadings without obtaining prior leave as required by court order). See Order Striking Motions and Imposing Sanctions (Jul. 21, 2011).
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C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY HOW MANY TIMES HAS A COURT (A) DIRECTLY ADMONISHED, (B) DENIED OR REVOKED PRIVILEGED, AND/OR (C) THREATENED TAITZ WITH SANCTIONS IN THE PAST THREE YEARS?
Answer: In addition to the sanctions identified above, Taitz has been admonished, had privileges denied or revoked, and/or been threatened with sanctions in written orders23 at least seventeen times (in seven cases) during the past three years: 1. Rhodes v. MacDonald et al, No. 4:09-cv-00106 (M.D. Ga.) Outcome: Taitzs client lost, then fired her as counsel.
2. Barnett Keyes et al v Obama et al, No. 8:09-cv-00082-DOC-AN (C.D. Cal.) a. Court Action/Admonishment: Court admonished Taitz as follows: Counsel Taitz refused to sign the substitution of attorney form presented to her by Plaintiffs Robinson and Drake. This action was improper because a client has the right to fire a lawyer at any time, with or without cause. Fracasse v. Brent, 6 Cal.3d 784 (Cal. 1972). Counsels actions became even more objectionable when Counsel, apparently with full knowledge that Plaintiffs wished to remain in the present litigation with different counsel, chose to take further action on behalf of those clients and have them dismissed from the action. Plaintiffs Counsel should not let personal differences with the attorney who Plaintiffs desired to be her substitute further delay or interfere with these proceedings. Order ... Granting Ex Parte Application for Order Vacating Voluntary Dismissal at 5 (Sep. 8, 2009)
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b. Court Action/Admonishment: The Court devoted a section of its Memorandum to discussing Taitzs behavior: Plaintiffs arguments through Taitz have generally failed to aid the Court. Instead, Plaintiffs counsel has favored rhetoric seeking to arouse the emotions
Court admonishments during hearings as reflected in transcripts are not included.
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a. Court Action/Admonishment: Court found complaint frivolous and notified Orly that filing of future similar actions in that court will result in sanctions. See Order Denying Motion for TRO at 1 (Sept. 16, 2009) (After conducting a hearing on Plaintiffs motion, the Court finds that Plaintiffs claims are frivolous.... Furthermore, Plaintiffs counsel is hereby notified that the filing of any future actions in this Court, which are similarly frivolous, shall subject counsel to sanctions); see also id at 9 (Plaintiffs complaint is not plausible on its face. To the extent that it alleges any facts, the Complaint does not connect those facts to any actual violation of Plaintiffs individual constitutional rights. Unlike in Alice in Wonderland, simply saying something is so does not make it so.
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and prejudices of her followers rather than the language of a lawyer seeking to present arguments through cogent legal reasoning. .... This Court exercised extreme patience when Taitz endangered this case being heard at all by failing to properly file and serve the complaint upon Defendants and held multiple hearings to ensure that the case would not be dismissed on the technicality of failure to effect service. While the original complaint in this matter was filed on January 20, 2009, Defendants were not properly served until August 25, 2009. Taitz successfully served Defendants only after the Court intervened on several occasions and requested that defense counsel make significant accommodations for her to effect service. Taitz also continually refused to comply with court rules and procedure. Taitz even asked this Court to recuse Magistrate Judge Arthur Nakazato on the basis that he required her to comply with the Local Rules. .... Taitz also attempted to dismiss two of her clients against their wishes because she did not want to work with their new counsel. See id.
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3. Liberi et al v. Taitz et al, No. 2:09-cv-01898 (E.D. Pa) a. Court Action/Admonishment: Court revoked Taitzs right to file motions without prior leave of the court. See Order Imposing Filing Restrictions (Jun. 26, 2009).
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While the Court seeks to ensure that all interested parties have had the opportunity to be heard, the Court cannot condone the conduct of Plaintiffs counsel in her efforts to influence this Court. See Order Regarding Defendants Motion to Dismiss, --- F.Supp.2d ----, 2009 WL 3861788 (Oct. 29, 2009).
b. Court Action/Admonishment: Court admonished Taitz as follows: Defendants [including Taitz] are to conduct themselves according to the parameters
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Additionally, the Court has received several sworn affidavits that Taitz asked potential witnesses that she planned to call before this Court to perjure themselves. This Court is deeply concerned that Taitz may have suborned perjury through witnesses she intended to bring before this Court.
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Taitz encouraged her supporters to contact this Court, both via letters and phone calls. It was improper and unethical for her as an attorney to encourage her supporters to attempt to influence this Court's decision. Despite these attempts to manipulate this Court, the Court has not considered any outside pleas to influence the Court's decision.
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discussed today in open court. See Order Dismissing Multiple Motions, n.1 (Jun. 26, 2009). c. Court Action/Admonishment: The Court devoted a section of its Memorandum to discussing Taitzs behavior: VII. BEHAVIOR OF THE PARTIES
See Liberi v. Taitz, 759 F.Supp.2d 573, 579 (E.D. Pa. 2010) 4. Liberi et al v. Taitz et al, No. 09-3403 (3rd. Cir.) Court Action/Admonishment: Court admonished the parties as follows: Counsel are admonished to avoid further invective and to confine themselves to civil and appropriately focused filings in any further appeal. See Liberi v. Taitz, No. 09-3403, Order Dismissing Appeal (3rd Cir. May 3, 2010).
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5. Liberi, et al v. Taitz, et al, No. 8:11-cv-00485 (C.D. Cal.) a. Court Action/Admonishment: Court admonished Taitz as follows: [T]he Court will keep a close eye on the filings by all parties and may choose to implement [restrictions on filing without leave of court] as the case progresses in this Court. See Order Denying Ex Parte Application (May 2, 2011).
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There were no winners at the hearing but surely there was one loserthe search for truth in an environment of decorum. For this sorry episode, both Taitz and Berg bear much of the blame.
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During the hearing the Court reminded Berg and Taitz that sanctions may be ordered under Rule 11, 28 U.S.C. 1927, and the inherent power of the Court. See In re Cendant Corp., 260 F.3d 183, 199 (3d Cir.2001) (citing Chambers v. NASCO, Inc., 501 U.S. 32, 4344, 111 S.Ct. 2123, 115 L.Ed.2d 27 (1991)) (The Supreme Court recently reaffirmed that a district court has inherent authority to impose sanctions upon those who would abuse the judicial process.) *** Additionally, very serious accusations were made during this hearing, such as: the hiring of a hit-man to kill a party, the stealing a party's donation funds, and attempting to kidnap a child of one of the party's to the lawsuit. The Court will remind the lawyers that they were warned by the Court that making such serious accusations without proof to back them up could result in their referral to the disciplinary board.
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b. Court Action/Admonishment: Court admonished Taitz as follows:
The Court previously warned the parties that it might impose restrictions on filing in this case. (Dkt. #183.) The Court finds that such a restriction is appropriate at this time ... given the flood of filings before the Court. The Court now ORDERS all parties to seek leave of Court before filing any motions or other documents in this case. A party seeking leave to file a motion or other document may do so by letter to the Court, with copies to all parties. The letter shall be no more than two pages and shall set forth the nature of the motion or document and good cause for its filing. The letter shall have no attachments or exhibits. Upon a showing of good cause, the Court may grant leave to file. Failure to comply with the letter and spirit of this order may result in sanctions, including the summary denial of improperly requested motions, or other sanctions such as dismissal or striking of the answer. See Order Granting Motion for Leave to Amend, Denying Motion to Strike and Motion to Dismiss, and Imposing Restriction on Filing at 9 (Jun. 14, 2011) (emphasis in original). c. Court Action/Admonishment: Court admonished Taitz as follows: Many of the requests from the parties, and in particular from Orly Taitz, include unnecessary rehashing of disputed facts. The Court is familiar with the background of this case and need not be reminded of, for example, the alleged criminal history of plaintiff Lisa Liberi or Taitzs characterization of this cases procedural history. The unnecessary inclusion of facts and arguments irrelevant to a particular request may weaken a partys showing of good cause. Concerning this Courts June 14, 2011, Order, ALL FUTURE REQUESTS MUST BE FOCUSED, CLEAR, AND CONCISE, WITH NO UNNECESSARY MATERIAL.
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See Order Granting In Part And Denying In Part Requests For Leave To File (Jul. 26, 2011) (allcaps in original).
d. Court Action/Admonishment: Court admonished Taitz as follows: The Court is aware that some parties to this case have been involved in numerous lawsuits and the Court has ongoing concerns about the litigation history and behavior of certain parties here. The Court must therefore ORDER that Plaintiff Philip J. Berg and Defendant Orly Taitz file a document with the Court by September 2, 2011, answering the following about themselves:
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1) How many cases they have filed in the past three years on behalf of themselves or affiliated entities with a list of case names and numbers; 2) How many cases they have personally been a party to in the past three years (including cases they filed), with a list of case names and numbers; and 3) How many sanction orders have been issued against them in either a pro se or representative capacity in the past three years, in what amount or other form, and in which cases. See Order to Submit Information (Aug. 12, 2011) (underlining in original).
e. Court Action/Admonishment: Court admonished Taitz as follows: The parties have submitted numerous new requests to file motions and other documents. The parties will increase their likelihood of prompt ruling by limiting themselves to thoughtful requests and avoiding unnecessary submissions to the Court. See Order Granting and Denying Requests to File (Aug. 12, 2011) f. Court Action/Admonishment: Court admonished Taitz as follows: The Court is continually frustrated by the extraneous information that OTI and other parties include in their requests for leave to file. For example, in this request, the Court fails to see how it is relevant that Orly Taitz has purportedly not filed any lawsuits against the plaintiffs here. The Court also fails to see how Taitzs crusade against President Barack Obama has any relevance to this request. The Court may impose sanctions for extraneous arguments and statements in future requests, including references to President Obama, who appears to have no direct relationship to the August 23 request. See Order Denying Request (Aug. 23, 2011) (bolding in original) 6. Lincoln v. Daylight Chemical Info. Sys. Inc., et al, No. 8:10-cv-01573-AG PLA ( C.D. Cal.).
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a. Court Action/Admonishment: ... Defendants seek to strike three documents. All three documents address motions that the Court has already resolved, and in fact the Court ruled almost entirely in Defendants favor on those motions. ... ... The Court ORDERS the parties to consider carefully the merits of any future motions to strike. The Court also ORDERS the parties to consider withdrawing any future motions to strike if they become obsolete, as did this Motion. In the future, the Court will be considering remedies it may employ to insure the just, speedy, and inexpensive determination of this action. Fed. R. Civ. P. 1. See Order Denying Motion to Strike (Mar. 7, 2011).
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b. Court Action/Admonishment:
RESTRICTIONS ON FUTURE FILINGS: For these three pending motions and others, the Court has spent valuable time reviewing and denying one motion to strike three documents (including a motion to strike), one unspecified and unjustified sanctions, and a motion apparently asking this Court to extend sanctions from another district. And one business day before the hearing, Defendants filed a Conditional Request to Vacate Motion for Sanctions. *** The Court now considers how best to secure the just, speedy, and inexpensive determination of this case, as the Court is charged to do under Federal Rule of Civil Procedure 1. The Court now ORDERS [parties including Taitz] to seek leave of Court before filing any motions or other documents in this case. ... A party seeking leave to file a motion or other document may do so by letter to the Court, with copies to all parties. The letter shall be no more than two pages and shall set forth the nature of the motion or document and good cause for its filing. The letter shall have no attachments or exhibits. Upon a showing of good cause, the Court may grant leave to file. Failure to comply with this order may result in sanctions. See Order Denying Motion to Strike and Motions For Sanctions at 3-4 (Mar. 23, 2011).24 7. Taitz v. Astrue, No. 1:11-cv-00402 (D.D.C.) a. Court Action/Admonishment: Court ordered that Taitz filings must not be docketed or placed in public record because they contain information in violation of Fed. R. Civ. P. 5.2(a)(1), but filings must be retained for consideration of possible sanctions against Taitz). See Order (Jul. 25, 2011)
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See also id. at 2(Both sides in this case [i.e., including Taitz] have been responsible for filing redundant and immaterial and at times nonsensical documents. The Court can use its own judgment to determine how much weight to give to various filings.), id. at 2-3 (Defendants *i.e., Taitz and affiliated parties] Motion for Sanctions is a 9-page jumble of allegations, arguments, and discussions of another case pending in the Eastern District of Pennsylvania.)
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b. Court Action/Admonishment: Court warned Taitz that it would not tolerate repeated violations of [rule regarding redaction of social security numbers). See Order at 1 (Jul. 25, 2011); see also id at 3 (Plaintiff is either toying with the Court or displaying her own stupidity. She made the correct redactions when she refiled her Complaint and Amended Complaint. There is no logical explanation
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she can provide as to why she is now wasting the Court's time, as well as staffs time, with these improper redactions .)
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MANY TIMES HAS A COURT EXPRESSLY CRITICIZED TAITZ FOR (A) FAILING TO FOLLOW THE RULES OR (B) FILING FRIVOLOUS PLEADINGS UNSUPPORTED BY LAW OR FACT IN AN ORDER?
HOW
Answer: In addition to the sanctions identified above and the multiple court admonishments/ actions identified above, Taitzs failure to follow the rules and/or repeated filing of frivolous pleadings with no factual or legal support criticized by the courts in written orders25 at least seventeen times (in eight cases) during the past three years: 1. Cook v. Simtech, Inc. et al, No. 8:09-cv-01382-RAL-EAJ (M.D. Fla.)
a. Court: Plaintiff's Application is not accompanied by a complaint and, therefore, fails to comply with the requirements of Local Rules 4.05(b)(2) and 4.06(b)(1). Furthermore, as the Eleventh Circuit Court of Appeals has observed, [t]here is no such thing as a suit for a traditional injunction in the abstract. See Order Denying Motion for TRO (Jul. 23, 2009). b. Court: The Court would observe, however, that Plaintiffs complaint is the quintessential shotgun pleading that has been condemned on numerous occasions by the Eleventh Circuit Court of Appeals. See Order Denying Motion to Reinstate Original Verified Application for TRO and Dismissing Case at 3, n.1 (Jul. 27, 2009). c. Order Denying Motion for Recusal as frivolous and wholly without merit (Aug. 6, 2009). d. Order Denying Motion to Alter Judgment and Motion for Rehearing as frivolous and wholly without merit (Aug. 6, 2009).
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3. Rhodes v. MacDonald et al, No. 4:09-cv-00106 (M.D. Ga.) Outcome: Taitzs client lost, then fired her as counsel.
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2. Rhodes v. Gates, No. 5:09-cv-00703 (W.D. Tex.) Outcome: Taitzs client lost. Court: Noting that Taitz failed to meet FRCP filing requirements filing and, with respect to the substance of her motion, "Plaintiff presents nothing but conjecture and subjective belief to substantiate the basis for her claims, citing, for example, 'opinion' and 'doubt.' ... A review of Plaintiff's verified complaint shows that it presents speculation and vague claims ..." See Order Denying Motion for TRO (Aug. 28, 2009).
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a. Court: A spurious claim questioning the Presidents constitutional legitimacy may be protected by the First Amendment, but a Courts placement of its imprimatur upon a claim that is so lacking in factual support that it is frivolous would undoubtedly disserve the public interest. See Order Denying Motion for TRO at 10, n.1 (Sep. 16, 2009). b. Court: [F]inding that Taitzs claims and legal contentions asserted in the present motion are not warranted by existing law and that no reasonable basis exists to conclude that Plaintiffs arguments would be accepted as an extension, modification, or reversal of existing law. Simply, put the motion is frivolous. Moreover, the Court further finds that Plaintiffs motion is being presented for the improper purpose of using the federal judiciary as a platform to espouse controversial political beliefs rather than as a legitimate forum for hearing legal claims. See Order Denying Motion for Reconsideration and Issuing Show Cause Order re: Sanctions (Sep. 18, 2009). 4. Barnett Keyes et al v Obama et al, No. 8:09-cv-00082-DOC-AN (C.D. Cal.)
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b. Court: The Court finds no factual, legal, or bias grounds upon which to grant the motion for reconsideration. Counsel largely repeats the same arguments made in her briefing and oral argument on the Motion to Dismiss, which is prohibited. To the extent that she does present new argument, it is without merit and does not meet the standard for reconsideration. See Order Denying Amended Motion for Reconsideration (Dec. 4, 2009).
5. Taitz v. Obama, No. 1:10-cv-00151 (D.D.C.) Court: This is one of several such suits filed by Ms. Taitz in her quixotic attempt to prove that President Obama is not a natural born citizen as required by Constitution. ... This Court is not willing to go tilting at windmills with her. See Memorandum Opinion at 2, 707 F.Supp.2d 1 (Apr. 14, 2010).
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a. Court: Plaintiffs have encouraged the Court to ignore these mandates of the Constitution; to disregard the limits on its power put in place by the Constitution; and to effectively overthrow a sitting president who was popularly elected by We the Peopleover sixty-nine million of the people. Plaintiffs have attacked the judiciary, including every prior court that has dismissed their claim, as unpatriotic and even treasonous for refusing to grant their requests and for adhering to the terms of the Constitution which set forth its jurisdiction. Respecting the constitutional role and jurisdiction of this Court is not unpatriotic. Quite the contrary, this Court considers commitment to that constitutional role to be the ultimate reflection of patriotism. See Order Regarding Defendants Motion to Dismiss at 29-30, --- F.Supp.2d ----, 2009 WL 3861788 (Oct. 29, 2009)
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6. Liberi et al v. Taitz et al, No. 2:09-cv-01898 (E.D. Pa)
a. Court: This litigation involves an intramural dispute among persons who have, at times jointly, challenged the legitimacy of President Barack Obamas presidency.... The instant case is just one piece of this far flung litigation, which is now pending in at least three federal courts. See Order Denying Motion for TRO (Aug. 25, 2009). b. Court: Defendant Taitzs response does not substantively address Plaintiff Bergs motion for leave to file a motion for reconsideration, thus it is inapposite to the issues at bar. See Memorandum Opinion (Jun. 22, 2010) c. Court: Court denied Taitzs motion to stay transfer on grounds that court already issued rule to show cause as to why the case should not be severed and transferred, and thereafter ruled to sever and transfer the case under applicable law. All of Defendant Taitz's other arguments are frivolous. See Order Denying Taitzs Motions (Jul. 14, 2010). 7. Liberi, et al v. Taitz, et al, No. 8:11-cv-00485 (C.D. Cal.) a. Court: This case is roiled by in-fighting, petty history, and an apparent disregard for accuracy and fair play. Thus, the discernment of truth is a constant difficulty for the Court. As Judge Robreno of the transferor court stated in an order dated December 23, 2010, regarding the outcome of a hearing on requests for temporary restraining orders, There were no winners at the hearing but surely there was one loser the search for truth in an environment of decorum. See Order Granting Motion for Leave to Amend, Denying Motion to Strike and Motion to Dismiss, and Imposing Restriction on Filing at 5 (Jun. 14, 2011): b. Court: The Court has concern that the voluminous filings in this case are filling court files with unnecessary and scurrilous documents. In this regard, Defendant Taitz has filed documents listing personal information such as credit card numbers, which the Court must address in yet another Order. See Order Granting Motion for Leave to Amend, Denying Motion to Strike and Motion to Dismiss, and Imposing Restriction on Filing at 5 (Jun. 14, 2011). Court: Defendant Orly Taitz submitted a request seeking leave of court for this court to comply with an outstanding order by the Third Circuit Court of Appeals to hear all of the outstanding motions, that were not heard in this case for two years now, followed by two pages of stream-of-consciousness statements that are difficult to relate to the request. ... The request is DENIED. See Order Denying Request (Jun. 28, 2011).
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8. Rivernider et al v. U.S. Bank Natl Assn, No. 9:2009-cv-81255 (S.D. Fla.)
a. Court: [T]he voluminous filings by Dr. Taitz and plaintiff ... attacking one anothers credibility will not be discussed or considered because any connection they may have to the issues are too tenuous and remote to be considered. See Order Declining to Issue Sanctions (Feb. 9, 2011) at-11, n.1. b. See also Order Denying Without Prejudice Motion to Substitute Counsel and Motion For Additional Time (Oct. 26, 2009) (denying motion to substitute Taitz as counsel due to her failure to follow applicable rules).
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C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY HOW

MANY TIMES HAS A COURT EXPRESSLY CRITICIZED PURPORTED EVIDENCE?
Answer: In addition to the sanctions identified above and the multiple court admonishments/ actions identified above, and the multiple written criticism noted above, Taitzs submission of questionable evidence has been criticized by the courts in written orders26 at least five times in three cases during the past three years: 1. Rhodes v. MacDonald et al, No. 4:09-cv-00106 (M.D. Ga.)
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b. Court: In support of this accusation, counsel submits the affidavit of Robert D. Douglas. Mr. Douglas states that on the day of the hearing in the Cook case, he saw in the coffee shop across the street from the federal courthouse someone whom he recognized as Eric Holder, the Attorney General. Mr. Douglass identification is based upon what he describes as the Attorney Generals distinguishing features: his trim upper lip mustache, not large of stature and general olive complexion. (Douglas Aff., Sept. 26, 2009.) The affidavit further states that Mr. Douglas new [sic] instantly that it was none other than Eric Holder, the current Attorney General of the United States. (Id.) Mr. Douglas has apparently never seen the Attorney General in person, but Mr. Douglas states that he recognized the Attorney General because he had seen Mr. Holder on television. . . . What the Court can say is that no reasonable attorney would rely upon this affidavit in support of a legal argument in a court of law. See, e.g., Fox v. Prudential Fin., 178 F. Appx 915, 919 (11th Cir. 2006) (per curiam) (finding that reasonable person would not find partiality based on bare allegations and unsupported conclusory statements that secret discussions took place between defendant and court). To use this evidence in support of a false and misleading accusation that a judge had an ex parte conversation with someone whom the
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a. Court: One piece of evidence Plaintiffs counsel relies upon deserves further discussion. Counsel has produced a document that she claims shows the President was born in Kenya, yet she has not authenticated that document. She has produced an affidavit from someone who allegedly obtained the document from a hospital in Mombasa, Kenya by paying a cash consideration to a Kenyan military officer on duty to look the other way, while [he] obtained the copy of the document. (Smith Decl. 7, Sept. 3, 2009.) Counsel has not, however, produced an original certificate of authentication from the government agency that supposedly has official custody of the document. Therefore, the Court finds that the alleged document is unreliable due to counsels failure to properly authenticate the document. See Fed. R. Evid. 901. See Order Denying Motion for TRO at 10, n.1 (Sept. 16, 2009).
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TAITZ
FOR SUBMITTING

judge has never spoken to or even met is additional proof of a pattern of frivolous and outrageous conduct on the part of Ms. Taitz. See Order Imposing Sanctions at 16-17, 670 F.Supp.2d 1363 (Oct. 13, 2009), affd, 368 Fed.Appx. 949, 2010 WL 892848 (11th Cir. Mar. 15, 2010). 2. Barnett Keyes et al v Obama et al, No. 8:09-cv-00082-DOC-AN (C.D. Cal.)
Court: Fed. R. Civ. P. 5.2 requires that individual's social-security numbers, taxpayer identification number, birth date, a minor's name, a minor's birth date, or a financial-account number be redacted. In addition, Local Rule 795.4 requires parties to redact social security numbers; names of minor children; dates of birth; financial account numbers; and home addresses.
3. Taitz v. Astrue, No. 1:11-cv-00402 (D.D.C.) a. Court removed First Amended Complaint from public record and filed under seal, and ordered Taitz to refile properly redacted documents. See Order Granting Motion to Strike (Jun. 2, 2011).
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b. Court stuck Taitz filing for failure to properly redact social security numbers contained in filing. See Order Granting Motion to Strike (Jul. 14, 2011). c. Court: Plaintiff submits the Selective Service registration acknowledgment form associated with security number xxx-xx-4425, which apparently is readily available on the world wide web. She argues that this form establishes that the President is fraudulently using social security number xxx-xx-4425, and that the Selective Service and the SSA are engaged in a cover up of his fraud. The Selective Service does not release registration acknowledgment forms to the public; only a registrant himself can request proof of his registration. See Registration Information, http://www.sss.gov/ack.htm. The Court can only
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See Order Sealing Document Requiring Plaintiffs to Refile Opposition to Motion to Dismiss to Comply with Fed. R. Civ. P. 5.2 (Sep. 30, 2011)
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Plaintiffs' filing contains, among other identifiers, Lisa Liberi's birth date and partially redacted social security number that is redacted in a way that does not comport with the Local Rule instructions. Because Plaintiffs have included the first five numbers of several persons' social security numbers, and the Court's rule directs that only the last four numbers should be included, the Court is concerned that requiring the last four numbers would allow a person who had seen the improperly redacted original exhibit to deduce the entire social security number. As such, all social security numbers shall be fully redacted and no numbers shall be shown.
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conclude that plaintiff has submitted a form that some individual obtained through a false request and subsequently posted online. Plaintiff also submits a verification results page from the Social Security Number Verification System (SSNVS) indicating that social security number xxx-xx-4425 is not in file (never issued). She argues that this page is further evidence that the SSA is covering up the Presidents use of social security number xxx-xx-4425. The SSA uses the SSNVS to provide employers with a means of verifying the names and social security numbers of employees. See SSNVS Handbook, http://www.ssa.gov/employer/ssnvshandbk/ssnvsHandbook.pdf. Anyone who knowingly and willfully uses SSNVS to request or obtain information from SSA under false pretenses violates Federal law and may be punished by a fine, imprisonment or both. Id. at 5. As with the registration acknowledgement form discussed above, the Court can only conclude that plaintiff has submitted a page that some individual obtained under false pretensesthat is, by representing himself as the Presidents employer. The Court notes that both documents submitted by plaintiff are incomplete; the address on the registration acknowledgment form and the employer identification number on the SSNVS page have been blacked out, further confirming the documents fraudulent origins. For all of these reasons, the Court will disregard both documents as well as any arguments made in reliance on them. See Memorandum Opinion at 7-8, n.1 (Aug. 30, 2011) (internal citations to record omitted).
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C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY TAITZ TABLE OF CASES
Case Caption
27
Disclosed? Not within scope Not within scope
Disposition
Criticized?
Barnett et al v Obama et al, No. 8:09-cv-00082-DOC-AN (C.D. Cal.) Cook v. Simtech, Inc. et al, No. 8:09-cv-01382-RAL-EAJ (M.D. Fla.) Fazel v. Taitz, No. 30-2010-00405406-SC-SC-HLH (Ca. Super. Ct. (Orange) 2010) Florida et a. v. U.S. Dep. of Health & Human Svs., No.. 3:10-cv-91-RV/EMT(N.D. Fla. 2010 (motion to intervene) Hornbeck Offshore Services, L.L.C. v. Salazar et al, No. 2:10cv-01663-MLCF-JCW (E.D. La. 2010) Liberi, et al v. Taitz, et al, No. 09-cv-01898-ECR (E.D. Pa. 2009)
Liberi, et al v. Taitz, et al, No. 09-3403 (3rd. Cir. 2009) (Berg appeal).
Liberi, et al v. Taitz, et al, No. 10-3000 (3rd Cir. 2010) (Taitz appeal).
27
Disclosed? Y=N= -- -- Disposition? Win Loss Pending -- -- Criticized? Y= -- -- Admonished? Y= -- -- Sanctioned: Y=
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Unknown
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Admonished?
Sanctioned?
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Transferred Voluntarily Dismissed Dismissed / Lack of Jurisdiction

Case Caption Disclosed? Disposition Criticized?
Liberi, et al v. Taitz, et al, No. 8:11-cv-00485 AG (C.D. Cal. 2011) Liberi, et al v. Taitz, et al, No. 11-56079 (9th Cir. 2011) (Taitz Parties appeal) Liberi, et al v. Taitz, et al, No. 11-56079 (9th Cir. 2011) (Taitz Parties appeal) Lincoln v. Daylight Chemical Info. Sys. Inc., et al, No. 8:10cv-01573-AG PLA ( C.D. Cal.). Medical Dental Development LLC v. Todd Pierson, No. 302010-00367447-CU-BC-CJC (Cal. Super. Ct. (Orange) 2010) Rhodes v. Gates, No. 5:09-cv-00703 (W.D. Tex. 2009) Rhodes v. MacDonald et al, No. 4:09-cv-00106 (M.D. Ga. 2009) Rhodes v. MacDonald, No. 09-15418 (11th Cir. 2009)

Not within scope
Voluntarily Dismissed
Rhodes v. MacDonald, No. 10A56 (U.S. Supreme Ct (Application for Injunction) 2010)
Rhodes v. MacDonald, No. 10-541 (U.S. Supreme Ct (Petition for Writ of Certiorari) 2010) Rivernider et al v. U.S. Bank Natl Assn, No. 9:2009-cv81255 (S.D. Fla.)
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Taitz v. 21 Century Insurance Co., No. 2010-00381664-CUFR-CJC (Cal. Super. Ct. (Orange) Small Claims Ct. 2010)
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Not within scope
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Admonished?
Sanctioned?
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Not Applicable Unknown

Case Caption Disclosed? Disposition Criticized?
Taitz v. Astrue, No. 1:11-cv-00402 (D.D.C. 2010) Taitz v. Astrue, No. 1:11-mc-00158 (HID) (D. Haw. 2011) Taitz v. Dunn, No. 30-2010-00381664-CU-FR-CJC (Cal. Super. Ct. (Orange) 2010) Taitz v. Bowen, No. S184384 (Cal. S.Ct. 2010) Taitz v. Fuddy, No. 1CC11-1-001731 (1st Cir. Ct. Haw. 2011) Taitz v. Obama, No. 1:10-cv-00151 (D.D.C.) Taitz v. Ruemmler, No. 1:11-cv-01421 (D.D.C. 2011)
State v. Taitz, No. SH673916 (Cal. Super. Ct. (Orange) Traffic Court) (disp. Sep. 15, 2008; bail forfeiture)
State v. Taitz, No. SH753526 (Cal. Super. Ct. (Orange) Traffic Court) (disp. May 12, 2010; Traffic School) State v. Taitz, No. 12706NC (Cal. Super. Ct. (Orange) Traffic Court) (disp. Apr. 19, 2011; bail forfeiture)
State v. Taitz, No. 14852LC (Cal. Super. Ct. (Orange) Traffic Court) (disp. Jan 15, 2010; case dismissed) State v. Taitz, No. SH713463 (Cal. Super. Ct. (Orange) Traffic Court) (disp. Jun. 26, 2009; bail forfeiture)
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State v. Taitz, No. SH749328 (Cal. Super. Ct. (Orange) Traffic Court) (disp. Dec. 21, 2009; bail forfeiture)
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Not within scope? Not within scope? Not within scope? Not within scope? Not within scope? Not within scope?
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Admonished?
Sanctioned?
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Case Caption Disclosed? Not within scope? Disposition Criticized?
State v. Taitz, No. SJ026342PEB (Cal. Super. Ct. (Orange) Traffic Court) (disp. Sep. 30, 2009; bail forfeiture)
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Admonished?
Sanctioned?
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CCCCCCC Special Report - A Briefing On The Litigation History of The Attorneys in Liberi V Taitz (C.D. CA)

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CCCCCCC Special Report - A Briefing On The Litigation History of The Attorneys in Liberi V Taitz (C.D. CA)

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Special Report FROM THE C.C.C.C.C.C.C.

C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY

1. Berg v. Obama, et al (2008)

d. U.S. Supreme Court re Writ of Certiorari, Case No. 08-570 (2008)

C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY

3. Capital One Bank v. Philip J. Berg (2009)

New Jersey Circuit Court (Mercer County), No. DC 001336 09

7. Thomas G. Oakes Assoc. v. Philip J. Berg, (2011)

6. Asset Acceptance LLC v. Philip J. Berg (2010)

New Jersey Circuit Court (Mercer County), No. DC 011880 10

New Jersey Circuit Court (Mercer County), No. DC 004054 11

4. Fed. Natl. Mtg. v. Paula Berg et al (2009)

2. Holsworth v. Berg (2005)2 U.S.D.C., Eastern District of Pennsylvania, No. 05-CV-01116

C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY APPEALS

3. In re Philip Jay Berg, No. 2:09-cv-02803 (E.D. Pa 2009)

Court admonishments during hearings as reflected in transcripts are not included.

C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY

C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY

d. Court Action/Admonishment: Court admonished Berg as follows:

C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY

See Order to Submit Information (Aug. 12, 2011) (underlining in original).

C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY

Court criticisms during hearings as reflected in transcripts are not included.

C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY

C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY

C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY BERG TABLE OF CASES

C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY

C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY

Case was not within scope of Courts inquiries.

Transferred Voluntarily Dismissed

Dismissed / Lack of Jurisdiction

C7 SPECIAL REPORT PART I: BERG LITIGATION HISTORY

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

1. Taitz v. Obama (2010) U.S.D.C. District of Columbia, Case No. 1:10-cv-00151

1. Rhodes v. MacDonald (2009-10)

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

Court admonishments during hearings as reflected in transcripts are not included.

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY HOW

Court criticisms during hearings as reflected in transcripts are not included.

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

Disclosed? Not within scope Not within scope

Disclosed? Y=N= -- -- Disposition? Win Loss Pending -- -- Criticized? Y= -- -- Admonished? Y= -- -- Sanctioned: Y=

Transferred Voluntarily Dismissed Dismissed / Lack of Jurisdiction

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

Not within scope

Not Applicable Unknown

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

C7 SPECIAL REPORT PART II: TAITZ LITIGATION HISTORY

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