LIBERI v TAITZ (C.D. CA) - 190.17 - Plaintiffs Exhibits 84-90 to Amended Complaint.190.17

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.17 - Plaintiffs Exhibits 84-90 to Amended Complaint.190.17

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Dr. Orly Taitz Esquire

Defend Our Freedoms Foundation 29839 Santa Margarita Pkwy, ste 100, RanchoSanta Margarita CA, 92688 Copyright 2010

World's Leading Obama Eligibility Challenge Web Site

Your donations to the cause are much appreciated.

WHEN THE PEOPLE FEAR THEIR GOVERNMENT,

THERE IS TYRANNY.

WHEN THE GOVERNMENT FEARS THE PEOPLE,

THERE IS LIBERTY.

- Thomas Jefferson

The articles posted represent only the opinion of the writers, do not necessarily represent the opinion of Dr. Taitz, ESQ, and Dr. Taitz, ESQ has no means of

checking the veracity of all the claims and allegations in the articles.

Did they ever meet?

Posted on | October 16, 2010 | 1 Comment

Far left rag, called Fogbow, that kept attacking me for a while reported the following: Three development

companies have been developing locations in Albuquerque. Tricor Southwest Co. of Phoenix is the largest,

with contracts to build seven Eckerds in Albuquerque and one in Santa Fe.

Chad Hagle, (Damon Dunns partner) a principal in Tricor, refused to answer questions Monday and did not

return phone calls Tuesday.

As recently as October, Hagle said there were plans to build as many as 20 Eckerd stores in Albuquerque and

Santa Fe.

Ok, it is probably just coincidence, but I found the following.

Philip J Berg is working with an assistant Lisa Liberi, who was convicted of 10 counts of forgery and theft in

Rancho Cucamonga CA. She is allowed to reside only in CA or NM according to her probation. (she has

hey ever meet? | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

http://www.orlytaitzesq.com/?p=14824

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family in Santa Fe and Albuquerque)

Berg filed a law suit, claiming that I defamed him and his paralegal, when I published her criminal record and

her mug shot, that she is a different Liberi, an innocent woman in PA. When I asked for PA drivers license

for Liberi, claiming that it needs to be sealed, because she is afraid for her life because she thinks that

attorney Orly Taitz tried to hire a hit man to kill her. Of course, as always with their accusations, there was

not a shred of evidence. Strangely enough, I noticed that Dunn did his development in Chino Hills CA and in

NM, both places of residence of Liberi. I wonder if they ever met, if all of this is coordinated.

Similarly, when I served Dunn with the deposition subpoena, his attorney kept playing games, refusing toshow up at the deposition. Since the judges are obviously refusing to do anything before the election, I

decided to wait and see, what happens in the election and depose him after the election. Bottom line, if he has

nothing to hide, why not show up for deposition? Maybe because he knows that he committed fraud and did

not provide in his voter registration card mandatory prior voter registration. He has addresses in three other

states: AZ, TX, FL. We know that he registered to vote in at least two of them and that he registered as a

Democrat in FL and tried to have those records deleted. Current sec of state Bowen is complicit in

obfuscating those records, just as she was complicit in obfuscating Obamas records.

They all need to go.

Category:Uncategorized

Comments

One Response to Did they ever meet?

Yephora

October 16th, 2010 @ 6:12 pm

There is a big discussion about Dunn over at Breitbart. It seems most of the conservatives are being

taken in by his so-called conservative credentials, believing he is one of them. Comments are still

open so people here with facts should start setting the record straight over there. Breitbart is widely

read and so far Dunn has been getting a free ride.http://www.breitbart.tv/meet-damon-dunn-gop-candidate-for-ca-sec-of-state/

1.

!! IMPORTANT NOTICES PLEASE READ !!

NEW! CA REP CENTRAL COMMITTEE LIST

CAMPAIGN FLIERfor Orly Taitz as CA SOS

CAMPAIGN FLIERfor Orly Taitz as CA SOS, 2 Per Page

How to contact public Integrity unit

See The PDF File HereUS Department of Justice has a special unit in their Criminal Division called the

PUBLIC INTEGRITY SECTION

Contact Orly!

email: [email protected] Urgent? Call: 949-683-5411

Recent Posts

hey ever meet? | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

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THERE IS TYRANNY.


THERE IS LIBERTY.

- Thomas Jefferson




The revision 7/65 on the form filed in 1959 by Stanley Ann Dunham, that Dr. Orly Taitz sees is at lower

left, but when you compare it to an image of an SS-5 filed a year earlier in 1958, which is a bit clearer, you

find not revision 7/65 but revision 7/55.

A closer look:I need your help to figure out one detail.

Aside from the fact, that Obama does not have a valid Social Security number and is using a number

042-68-4425, issued in CT to another individual, born in 1890, there is a question regarding his mothers

social security.

a. for some reason according to databases the same number 5 35-40-8522 was used by another person,

Phylis Albriktson in WA.

Orly Taitz Esquire http://www.orlytaitzesq.com/?


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I Checked with Phylis, she has a different number. Someone created a record, which is a combination of Ann

Dunhams social and Phyliss name. I need to find out, who created this record, when, for what purpose.

Keep in mind, that Obamas memoirs dont tell the truth. Ann Dunham did not reside with her husband in Hi.

right after Obamas birth she resided in WA, she was enrolled in the university of Seattle WA from August

1961-till Spring semester 1962. Her and Phylis Albriktsons paths mightve crossed somewhere.

2. Even though Ann Dunham passed away in 1995, he social was shown as active until around 2005.

3. 2005 is important, as the year of an executive order from Pres Bush, which required to show on the docs,whether the social security number used was active or not. (meaning if a person is deceased). It was done to

cut on fraud and use of SS numbers of deceased individuals.

4. Her application shows on the bottom of the form a revision date, that looks like 7-65, even though it was

filed out in 1959

5. There is a pro-Obama thugs site called Oh for goodness sake. What is peculiar about those brown shirts,

is the fact that they viciously attack me, while supporting Berg and his career criminal, convicted felon on

probation Paralegal Lisa Liberi. Why would a pro Obama site support Bergs assistant, particularly in light

of the fact, that she has a lengthy record of forgery of documents and official seals. ( I previously posted her

mug shot and official criminal record from San Bernardino county CA)

6. Lastly, when I raised the issue of inconsistancy of Ann Dunhams application, they posted on their site an

application, that they got from somewhere. It is not clear, if it is a real application or created, (like many other

documents). They are trying to say, that Ann Dunhams application has the revision date 7-55 not 7-65. The

problem with this, is that if you look closely, you can see, that the numbers are different. You would imagine,

that on an official governmental form both fives in 7-55 would have the same font and the same size. When

you look closely, you can tell, that the first 5 is significantly larger, than the second 5. I am not a forensic

document expert, I cant give an answer to this conundrum. Can someone, who is an expert, give me an

opinion, why are the digits so different?

7. Please, check your applications and applications of your relatives. I am looking for ss-5 application with

the revision date 7-55 or 7-65. I need to check the fonts and the size of the letters. If those are different, it

might mean that this site Oh for goodness sake is posting forgeries. I, also, need to know, who owns this

site, who posts all the garbage about me, and if this person is connected to some people we already know. We

have to solve all these mysteries. the law enforcement is not doing anything, the judges are not doing

anything, National security is at stake. We have to solve it, we have to find all the answers.

Category:HOT ITEMS!, Help Needed, Latest News

Comments

One Response to

Jim

October 19th, 2010 @ 10:49 pm

That 7/55 on the Hamilton is not a 55, but a 65. It is a result of a bad scan. If it were a 55, both 5s

would be the same height and width. The first 5 is wider and longer than the second 5. They are

clearly not the same numbers. If you go to the bottom of the page at this site :

http://www.dunhamfraud.cjb.net

1.

Orly Taitz Esquire http://www.orlytaitzesq.com/?

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THERE IS TYRANNY.


THERE IS LIBERTY.

- Thomas Jefferson



Amended pleadings demanding sanctions against

Attorney Philip J. Berg, Plaintiffs and witness

Shirley Waddell for repeated acts of perjury andfraud on the court and for filing a frivolous legal

action with a purpose to cover up the fact, that

Attorney Berg employes as his paralegal Lisa

Liberi, a convicted document forger and thief,

nded pleadings demanding sanctions against Attorney Philip J. Berg, ... http://www.orlytaitzesq.com/?


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currently on probation.

Posted on | October 21, 2010 | 13 Comments

Orly Taitz, Esq

Attorney Pro Se & Attorney

For Defend Our Freedoms Foundation

29839 Santa Margarita Parkway, Suite 100

Rancho Santa Margarita CA 92688

Tel: (949) 683-5411; Fax (949) 766-7603

E-Mail: [email protected]

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LISA LIBERI, et al., ) Case # 09-1898 Hon Eduardo Robreno presiding

) Amended Reply to 10.07.10 motion by the Plaintiffs

) Defendants request for the court to use its inherent power to sanctionthe plaintiffs,

) Attorney Philip J. Berg and witness Shirley Waddell for

Plaintiffs ) repeated acts of fraud on the court and perjury

)

v. ) Request to expedite production of Lisa Liberis

) Pennsylvania drivers License, allegedly provided to court

ORLY TAITZ, et al., ) during the emergency hearing on 08.07.09.


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from jail.

Exhibit 7 Is a sworn statement by the web master Jeff Staples, attesting to the fact that Liberi handled creditcard information of the donors. This is the motif for the law suit, as according to her probation, she is not

allowed to handle credit card information of others due to the fact, that she committed economic crimes.

While none of the defendants have any criminal records, Liberi is a career criminal with at least 42 criminalcharges and at least 10 criminal convictions of forgery and theft. Plaintiffs accusations are nothing but

malicious slander, brought forward to cover up for the fact that Attorney Philip J Berg is indeed employing aconvicted document forgery as his paralegal, and according to his own admission, she was the one, who

drafted multiple pleadings, including pleadings in Berg v Obama. They are also committing fraud on the courtand perjury to cover up for the fact, that attorney Berg is aiding and abetting a convicted felon on probationto violate terms of her probation. Defendants are asking this court to use its inherent powers to sanctionPlaintiffs, witness Shirley Waddell and attorney Philip J. Berg $200,000 estimated in time and expenses in

defending this case brought for improper purpose of defrauding the court.

In cases in which jurisdiction is based on diversity of citizenship, plaintiff has burden to show, first, thatapplicable statute confers jurisdiction, and, second, that assertion of jurisdiction is consonant with

constitutional limitations of due

process. Weight v Kawasaki Motors Corp. (1985, ED Va) 604 F Supp 968.

Partys mere allegation of diversity cannot satisfy its burden of establishing district courts jurisdiction;

citizenship of each real party in interest must be established by preponderance of evidence.Roche v Lincoln

Prop. Co. (2004, CA4 Va) 373 F3d 610.

Complaint alleging that defendants corporate citizenship was in a state other than California but failing to

allege that plaintiffs were all citizens of California was not sufficient to give District Court jurisdiction sincepleadings did not otherwise resolve

issue of citizenship.Bautista v Pan American World Airlines, Inc. (1987, CA9 Cal) 828 F2d 546, 126 BNALRRM 2559, 107 CCH LC P 10159.

Court lacked jurisdiction over patients claims because he failed to establish diversity jurisdiction because attime he filed complaint both he and hospice were citizens of State; also patient only sought $ 10,000 in costand unspecified amount for other damages, which did not meet amount in controversy.Olsen v QualityContinuum Hospice, Inc. (2004,DC NM) 380 F Supp 2d 1225.

Complaint against John Doe defendant alleging Internet defamation was dismissed for lack of subject matterjurisdiction because there was risk that if John Does identity were discovered there could have been nodiversity, and courts jurisdictional authority would have disappeared; court declined to read amended

language of28 USCS 1441

into 28 USCS 1332 because it would have accomplished much broader result of allowing case with only oneparty and only state law claims to proceed initially in federal court. McMann v Doe (2006, DC Mass) 460 F


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Supp 2d

In motorists personal injury lawsuit against, inter alia, owners of property adjacent to private railroad-track

crossing where car-train accident occurred, pursuant to 28 USCS 1447(d), appellate court lacked

jurisdiction to review remand that implicitly was based on lack of subject matter jurisdiction; district court

clearly was addressing jurisdictional issuesdiversity of citizenship, 28 USCS 1332, and fraudulent

joinderand when doing

so, it properly declined to decide doubtful question of state law and, instead, resolved ambiguity (lack of statelaw directly on point) in motorists favor.Filla v Norfolk & Southern Ry. (2003, CA8 Mo) 336 F3d 806.

Where record creates doubt as to jurisdiction, trial court must determine whether there are adequate grounds

to sustain its jurisdiction over subject matter. Shahmoon Industries, Inc. v Imperato (1964, CA3 NJ) 338 F2d

449, 9 FR Serv 2d 12B.22, Case 2.

Court has duty to look to its own jurisdiction and lack of subject matter jurisdiction may be asserted by court,

sua sponte, at any time.Jeter v Jim Walter Homes, Inc. (1976, WD Okla) 414 F Supp 791.259. decided by apreponderance of evidence.

Plaintiffs did not present any evidence, not a shred of evidence, showing Liberi to be a resident of PA.

Defendants have shown that according to her probation she can reside only in CA or NM, she is subject to the

jurisdiction of CA, therefore the case at hand has to be dismissed as citizenship of Liberi was not provided to

resolve the issue of diversity to allow it to proceed in Federal court. Defendants have a right to get a copy of

such PA license, as it is material in this case. If indeed Liberi did not produce a PA drivers license or

produced a forged PA drivers license, than this court made an error of fact, it had no jurisdiction and the case

has to be dismissed due to lack of jurisdiction. Decision made based on fraud is a valid ground for 60 B

reconsideration. All of Liberis allegations, that her license is supposed to be sealed due to the fact that she is

being threatened are not based on any facts, are not based on any evidence. Plaintiff provided nothing exceptslander, defamation of character and insane tall tales. Liberi claims, that Taitz boxed her in. In reality Taitz did

not box her in, Liberis own lies caught up with her. If she refuses to provide her license, the case needs to be

dismissed as the court has no jurisdiction to sit in diversity without proof of citizenship. If she produces a

valid license, it will show her residing in CA or NM and will show that she is indeed the same Lisa Liberi,

who committed 10 counts of forgery and fraud in CA and allowed to reside only in Ca or NM under the

supervision of the probation department. It will show the court that the whole case for slander and

defamation, that she filed by claiming to be resident of PA and an innocent victim of slander, is frivolous and

represents fraud on the court, which would be grounds for the dismissal of the case and sanctions against the

plaintiffs and their attorney Berg for the egregious fraud on the court. As of today the documents on the

docket, that were provided to the defendants and to the Third Circuit Court of Appeals as a certified docket,

show zero evidence of any current threats to Liberi from either the defendants or her ex husband or her ex

boyfriend. On the contrary, a letter from web master Geoff Staples and letters and affidavits from volunteer

political researcher Linda Belcher, who knew Berg for over 10 years, show that Liberi was engaged in

violation of the terms of her probation by handling credit card numbers of others, that Attorney Berg knew

about it and filed this legal action with the goal of harassing the whistle blowers and by fraudulently stating

that Liberi is a resident of PA and not the same Liberi, who was convicted in CA and currently on probation.

When defendants demanded proof of this allegation, Berg and Liberi committed further fraud on the court by

claiming that Liberis PA drivers license is supposed to be sealed, because she is in fear of her life and by

falsely accusing defendants of crimes or intent to commit crimes. Without any shred of evidence they falsely

accused of multiple crimes a number of individuals: Desert Storm veteran, mother and wife Pamela Barnett,


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Licensed investigator Sankey, veteran and retired engineer Neil Turner, retired engineer Norman Murray andTaitz, who is a licensed attorney and licensed doctor of Dental Surgery. Neither one of these individuals ever

committed any crimes. It is beyond egregious fraud on the court, it is a depraved heart criminal behavior , fora licensed attorney Berg to make such outrageous accusations of attempts to hire a hit man, kidnap children,murder for hire without any shred of evidence, with the only goal to cover up his prior criminal behavior ofaiding and abetting a felon on probation, Lisa Liberi, to violate terms of her probation. This type of behavior

is beyond sanctionable, it is a type of behavior, that is grounds for disbarment and criminal prosecution.

Wherefore:

1.the defendants move this court to grant their motion and provide to the defendants and include in therecord on appeal to be forwarded to the Third Circuit Court of Appeals (case #10-3000) Plaintiff LisaLiberis PA drivers License, which was allegedly submitted to this court by Liberis attorney Philip Bergduring the 08.07.09 motion hearing, but was not included in the transcript, and which was the basis of this

courts decision to deny the Defendants motion to dismiss this case due to lack of jurisdiction and to includein the 06.04.10 order a finding that Liberi is a resident of PA

2. If no PA drivers license for Liberi is available, Defendants are moving this court to dismiss current action

09-1898 Liberi et al v Taitz et al due to lack of jurisdiction, due to the fact that Liberi never provided proof

of her PA residence, and without proof of state residence no federal district court can assert diversityjurisdiction.

3. Defendants request sanctions and damages in the amount of $200,000 awarded to them due to egregiousfraud on the court by the Plaintiffs and their attorney Philip J. Berg

Respectfully submitted,

/s/ Dr. Orly Taitz, ESQ

10.21.10.

I certify under penalty of perjury, that I served above pleadings on following parties and authorities:

Philip Berg

555 Andorra Glen Court, ste 12

Lafayette Hill PA 19444-2531

Neil Sankey

2470 Stearns str #162

Simi Valley, CA 93063

Linda Belcher

201 Paris

Castroville TX 78009

Ed and Caren Hale

1401 Bowie Str


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Wellington TX 79095

Philadelphia District Attorneys office

3 South Penn square

Philadelphia, PA

US Attorneys office

Eastern District of PA

615 Chestnut str, ste 1250

Philadelphia PA 19106-4100

Social Security Administration

6401 Security Blvd

Baltimore, MD 21235

James Secord

Assistant District attorney

San Bernardino County

316 North Mountain view

San Bernardino CA 92415-0004

909-387-8309

www.co.san-bernardino.ca.us/da

San Bernardino County, CA

Probation Department

175 w. Fifth str. 4th floor

S. Bernardino, CA

Audrey B. Collins

Chief Judge

US District Court

411 W. Fourth str

Santa Ana CA 92701

Judge David O. Carter


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USDC Central District of CA

411 West Fourth Str

Santa Ana CA 92701

Public Integrity Section

Department of Justice

950 Pennsylvania Ave, NW

Washington DC 20530-0001

Office of the United Nations High Commissioner for Human Rights (OHCHR)

Special Rapporteur on the Situation of Human Rights Defenders

The Honorable Mrs. Margaret Sekaggya

Palais des Nations

CH-1211 Geneva 10, Switzerland

International Criminal bar Hague

United Nations Commission for

Civil Rights Defenders

Orsolya Toth (Ms)

Human Rights Officer

Civil and Political Rights Section

Special Procedures Division

Office of the High Commissioner for Human Rights

tel: + 41 22 917 91 51

email: [email protected]

/s/ Orly Taitz

10.21.10.

Proposed order

Law offices of

Dr. Orly Taitz, ESQ

29839 Santa Margarita CA 92688


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Pro se and for Defend Our Freedoms Foundation

UNITED STATES DISTRICT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Lisa Liberi, et al ) Case # 09-cv-01898-ECR

Plaintiffs ) Assigned to Honorable Eduardo C. Robreno

)

V )

Orly Taitz et al )

Defendants

ORDER

AND NOW, this________ day of October 2010 after consideration of Defendants motion-request for

documents missing from August 7, 2009 transcript and 60 B Motion for Reconsideration of this courts June 4

and July 13, 2010 order.

Defendants Motion is granted. Plaintiffs 10.07.10 motion is denied.

Plaintiffs, witness Shirley Waddell and attorney for plaintiffs Philip J Berg is ordered to show cause, why they

should not be sanctioned for repeated acts of perjury, fraud on this court as well as on the Third Circuit Court

of Appeals and for filing a frivolous legal action not based on fact and law.

IT IS SO ORDERED

_______________________________________

Eduardo C. Robreno, J

Affidavit of Dr. Orly Taitz ESQ

I, Orly Taitz, am an at torney, licensed in the State of California, 9th

circuit court of appeals, Third Circuit

Court of Appeals and admitted to practice before the Supreme Court of the United States. In the above action

I represent myself and Defend Our Freedoms Foundation, where I serve as the president. I am over 18 years

old, do not suffer from any mental impairment, have personal knowledge of the foregoing facts and declare

under penalty of perjury:

In and around April of 2009 I was alerted by my supporters that an e-mail address connected to the

pay-pal on my old web site Defend Our Freedoms was changed.

1.

I immediately reported that fact to FBI and police.2.

My former volunteer web master Lisa Ostella demanded that I take back my complaint, as it looks bad

for her as a web master. She threatened, that if I do not take back my complaint, she will not serve as

my web master. I refused to take back my complaint and announced to Ostella, that I will be looking

for a new web master.

3.

Ostella locked me out of my web site and continued soliciting donations, using the web site for my4.


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foundation and redirected the donations to her private pay pal account. At the same time Ostella started

working with Phil Berg and used the web site of my foundation, not only to divert funds but also to

denigrate me and promote Berg. This information was reported to the FBI and police as well.

In and around the same time I was contacted by Linda Belcher, who stated that she knew Berg for

some 10 years, that she was a volunteer researcher for him. She recently found out that one, Lisa

Liberi, who serves as Bergs paralegal and manages his web site and pay pal account, is actually is a

convicted document forger and thief on probation. Belcher believed that my recent problems were

connected to Liberi.

5.

I asked Licensed Investigator Neil Sankey to check this information.6.Sankey provided a detailed report that confirmed that Liberi indeed was a convicted document forger

and thief and was currently on probation.

7.

Believing that attorney Berg does not know about Liberis past, I e-mailed him and advised him and

forwarded to him a transcript of Liberis felony convictions and advised him, that he should not submit

to court documents, prepared by a convicted forger and should not do fundraising while working with a

convicted thief.

8.

Berg never responded and filed current legal action against me and a number of other individuals and

plaintiffs, claiming that he and Liberi and Ostella were defamed, and that she is not a convicted felon,

who assists him via e-mail and phone, but an innocent woman, a different Lisa Liberi, who resides in

PA and physically works in his office.

9.

10. On June 6 2010 Judge Robreno ordered the case severed and transferred to TX and CA.

11. In my subsequent motion to dismiss I argued that the court did not have jurisdiction over the case, as the

case was filed based on diversity. For diversity each party needs to prove its state residence based on

evidence and facts. Liberi never provided any evidence, to prove her allegations, that she is a resident of PA,

as such the case needs to be dismissed.

12. On July 30 2010 Liberi and Berg filed an opposition to my motion, where they stated that Judge

Robrenos statement Liberi is a resident of Pennsylvania in his June 6, 2010 order was based on vital

records, that she submitted to judge Robreno during 08.07.09 emergency hearing. Liberi specifically stated

that they provided her drivers license and other documents.

13. I filed a response and demanded to see that Liberis PA drivers license, as it was not included with the

transcript of the hearing.

14. Liberi and Berg filed a motion to have Liberis drivers license sealed, as they claimed that she is afraid

for her life and without a shred of evidence they claimed that Liberi believed that I tried to hire a hit man to

kill her and her family and that is the reason, why she should not provide her drivers license to show her state

residence.

15. I declare under penalty of perjury, that I did not attempt to hire any hit men. This is a totally

preposterous, malicious accusation made without a shred of evidence. I demand sanctions against theplaintiffs and attorney Berg for maliciously filing with court accusations of capital crimes without any

evidence and for improper purpose of covering up the fact, that Licensed PA attorney Philip Berg is

continuously working with a convicted document forger and thief who is currently on probation.

I previously submitted to this court Liberis photograph with sworn affidavit of investigator Sankey and

sworn affidavits by Caren and Ed Hale, who Identified Liberi as the woman, who appeared before

judge Robreno on 08.07.09 in Liberi v Taitz and the same photograph was identified by Liberis

arresting officer Morrison, as one convicted in CA. I am additionally submitting Liberis recent mug

shot, which clearly shows that it is the same person, who appeared before judge Robreno on 08.07.09

and I am submitting an e-mail from her prosecuting district Attorney James Secord, assistant District

1.


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Attorney of the San Bernardino County CA, verifying that this is indeed the mug shot of Lisa Liberi,

Convicted in CA and not allowed to reside in any other state, but CA and NM according to terms of her

probation. I forwarded Liberis Mug shot to ED and Caren Hale, who signed sworn affidavits, that the

woman on this mug shot is indeed Lisa Liberi, who appeared before judge Robreno on 08.07.09 for

emergency hearing in Liberi et al v Taitz et al, claiming that she is an innocent woman residing in PA,

who was never convicted of any crimes, who was defamed by the defendants and who cannot unseal

her PA drivers license because she is afraid for her life .

17. I filed the motion, demanding release of Liberis license with the proper purpose to ascertain Liberisstate residence at the time of filing this action. As evidentiary proof of residence is the basis to assume

jurisdiction, I am entitled to obtain such evidence.

18. I provided a letter from Jeff Staples and Affidavit from Linda Belcher with the proper purpose of

showing that the plaintiffs and Liberi are refusing to provide Liberis proof of Pennsylvania residence not

because of their baseless and malicious accusations of fear for her life, but because they have a guilty mind,

because Berg knowingly worked and continuous to work with the convicted document forger and thief,

and because Liberi knows, that proof of her fraud on the court and perjury, as well as access to the

credit cards of others will serve as grounds for revocation of her probation and incarceration to serve

her eight year prison term. Berg knows, that proof of the fact that Liberi did not and could not have a valid

Pennsylvania drivers license will not only serve as grounds for dismissal of this case, but also as grounds forsevere sanctions against Berg for egregious fraud on the court, perjury, use of court for improper purpose to

defraud the probation department, US District Court for the Eastern District of Pennsylvania, Third Circuit

Court of Appeals, California Superior Court, slander, defamation and intentional infliction of severe

emotional distress to the plaintiffs.

19. This court received hundreds of pages of affidavits from Liberis mother Shirly Waddell, where she

swears that her daughter is an innocent woman, who was defamed by me, when I provided her criminal

record to public. I am providing with this affidavit a true and correct copy of the transcript from San

Bernardino County CA, Superior Court case FSB-044914. It show, that Shirley Waddell not only knew about

her daughters criminal record, but she also was the one who paid for the bail bond. This transcript is brought

for the proper purpose of showing that the plaintiffs witness Shirley Waddell committed fraud on the courtand perjury and needs to be severely sanctioned for it.

20. On numerous prior occasions Berg and Liberi demanded her records sealed and repeatedly this court, as

well as the court of Appeals refused to do so. I suffered enormous emotional distress and financial hardship

having to respond to thousands of pages of malicious slander by Plaintiffs and Berg, whereby they maliciously

without any shred of evidence accused me of attempting to hire a hit man, of forgery and alteration of

documents. None of those allegations are true and I demand severe sanctions against the plaintiffs and Berg

for maliciously accusing me of crimes.

21. Liberi and Berg showed a pattern of accusing a number of innocent people of crimes. They accused a

decorated police officer and licensed investigator Neil Sankey of braking into the computer of Liberi, and ofstalking her, they accused Desert storm veteran Pamela Barnett of forging document, they accused researcher

Linda Belcher of having a criminal record, they accused Ed and Caren Hale of stealing and forging

documents. None of those malicious accusations is true. I submitted to this court sworn affidavits of all the

above individuals, attesting to that.

22. The only known criminal in this action is Lisa Liberi, who masterminded this frivolous and malicious

legal action, in order to intimidate the whistle blower and avoid revocation of her probation.

I declare under the penalty of perjury, and under the laws of the state of CA that all of the above is true and

correct and to the best of my knowledge


12 5/2/2011 1

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Signed

Dr. Orly Taitz, ESQ

10.20.10

Category:Latest News, Legal Actions

Comments

13 Responses to Amended pleadings demanding sanctions against Attorney Philip J. Berg, Plaintiffs and

witness Shirley Waddell for repeated acts of perjury and fraud on the court and for filing a frivolous legal

action with a purpose to cover up the fact, that Attorney Berg employes as his paralegal Lisa Liberi, a

convicted document forger and thief, currently on probation.

Toto Tew

October 21st, 2010 @ 7:02 pm

Isnt this case on appeal. And transferred? How does the district court still have jurisdixion?

1.

[email protected]

October 22nd, 2010 @ 3:01 am

they need to include all the documents for the transcript for the Court of Appeals. Berg claimed, that he

provided the court with her drivers license, but it was not included in the documents provided to the

defendants. I filed a motion last month, demanding to provide the defendants the license, that was not

provided. If there was no proof of state residency, the court did not have jurisdiction in diversity, it had

no jurisdiction to transfer to another district court either, it had an obligation to dismiss due to lack of

jurisdiction. The Court of Appeals gave me an extention, so that the district court can provide that

non-esistant drivers license or dismiss the case, which will make the appeal moot.

2.

Europeandesigner

October 22nd, 2010 @ 5:45 am

I might have a bombshell in this case attesting to the fact that much ethical dishonesty is coming from

your adversaries..

3.

BJ SmartAzz

October 22nd, 2010 @ 6:37 am

Aww, Europeandesigner, do you mean the letter you were asked to send (but didnt) to a

*Ms. Katrina Ray CHASE Loss Mitigation* ??

Where Mr. Berg lied and asked you to perjure yourself that a

*Payment to Mr. Berg in the amount of Two Hundred and Fifty Thousand dollars*

has been approved and is scheduled to go out to Mr. Berg September 2008?

YIKES!

4.

Legal Matters5.


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EXHIBIT 87



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VIDEOS

Home






THERE IS TYRANNY.


THERE IS LIBERTY.

- Thomas Jefferson



from reader Kathy M.


KathyM

Submitted on 2010/10/23 at 6:22am

Keep up the Great Work!!

As far as Berg is concerned, ask

yourself just what is his end

game? What is in this for Berg;

why is he participating in this facade

with Liberi against you?

Answer, follow the money. From

Amended pleadings demanding sanctions against Attorney Philip

J. Berg, Plaintiffs and witness Shirley Waddell for repeated acts

of perjury and fraud on the court and for filing a frivolous legal

action with a purpose to cover up the fact, that Attorney Berg

employes as his paralegal Lisa Liberi, a convicted document

forger and thief, currently on probation.

reader Kathy M. | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?


5/2/2011

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26/40

WHOM is Berg being paid? (his

expenses cost money)

It sounds like this whole thing is

simply set up as a distraction to you,

to detract your time and attention

from the Obama case. The FBI

needs to investigate them also.

God bless

I was asked, why I am at odds with Berg, considering the fact that we both filed eligibility cases. I dont

disagree with the point of Obamas illegitimacy. As you know, I have currently three cases: in Washington

DC, Judge Lamberth, latest motion was filed about two months ago and I await determination, one case in the

Ninth Circuit and one case in the Supreme Court of the United States. Nobody can accuse me of not doing

enough on Obama illegitimacy front. I am probably doing more than most. I did not file any law suits against

Berg. Berg attacked me with a law suit. Berg is working with a convicted forger and thief Lisa Liberi. Hefiled a law suit against me and others, seeking hundreds of millions of dollars, claiming that he and Liberi

were defamed, that she is a different Lisa Liberi, not the forger, who was convicted in CA, and allowed to

reside while on probation, only in CA and NM. They claimed, that she is an innocent woman residing in PA

and physically working in Bergs office. When asked to produce her PA drivers license, Berg and Liberi

without any shred of evidence made a horrific accusation, that they cannot show her PA drivers license,

claiming that her PA drivers license needs to be sealed , because she believes that attorney Orly Taitz tried to

hire a hit man to kill her. They want the judge to make a determination that she lives in PA only based on her

word and Bergs word, without any evidence. They also accused a licensed investigator Sankey of braking

into her computer and stalking her, they accused Captain Pamela Bernett of forgery, they accused a computer

consultant Jeff Staples of forgery, they accused Captain Neil Turner of being a white supremacist militia

member, who is staking Liberi, they accused a retired engineer Mr Murray of forgery, they accused LindaBelcher of committing crimes and forgery of seal, they accused Ed and Caren Hale of forgery and

theft. Convicted career forger Lisa Liberi is measuring everyone by her own standards and Berg just submits

to court those accusations. According to a sworn statement by the computer consultant Geoff Staples, Liberi

has access to Bergs merchant account and pay pal account therefore Berg is endangering donors by allowing

a forger and thief access to their information. He is undermining Obama eligibility issue by continuously

working with a convicted forger and by making despicable accusations against innocent people and by

continuously wasting time and resources of so many innocent people by continuing with his law suit. His

behavior was beyond unethical, it is criminal. I hope, that the Disciplinary Board of the Supreme court of PA

will shortly take action against Berg for these actions. I hope, that the probation department of San

Bernardino County, CA, which put Lisa Liberi on probation, will shortly take action on revocation of her

probation. EStrangely enough Berg and Liberi are doing the same thing, that Obama is doing- hiding vitalrecords. It is time for the Justice system to start working again and hold people accountable.


Comments

One Response to from reader Kathy M.

Redd

October 24th, 2010 @ 5:27 pm

1.

reader Kathy M. | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

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VIDEOS

Home






THERE IS TYRANNY.


THERE IS LIBERTY.

- Thomas Jefferson



From Captain Pamela Barnett


CPTPamela

Barnett

Submitted on 2010/10/27 at 4:20pm

Thank you for all of your hard work as my attorney Orly. The appeal will show if

yet another level of judges are corrupt. I pray not.

From Orly:

Not too many people know, who Pamela is.

Pamela is a remarkable woman: she fought in Desert Storm, she graduated

from University, she got married, she is a mother of two and a real estate investor

Reply to

Appellees

response in the

9th circuit court

of Appeals.

PDF will be

available

shortly

Captain Pamela Barnett | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

ttp://www.orlytaitzesq.com/?p=15165

5/2/2011

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30/40

and a real estate agent. Pamela is also a remarkable patriot of this country, fighting

for a better future for her children and all of our children.

It is totally sickening, that Philip Berg and his assistant, real forger Lisa Liberi

threw innuendos at Pamela and accused her of forgery of a letter from Bergs

former assistant Linda Belcher. When Pamela wrote to court and stated that she

did not forge any letters and she considers reporting Philip Berg to PA bar for

discipline violations, Berg and Liberi accused Mr. Murray and Captain Turner.

When Belcher wrote yet another letter and stated under oath, that nobody forgedher letter, Berg and Liberi accused Ms. Belcher of forging a seal. San Bernardino

probations department was supposed to revoke Liberis probation long time ago

and send her back to prison. PA disciplinary Board of the PA Supreme Court was

supposed to sanction or disbar Berg long ago for those egregious violations of

professional ethics, however we have no transparency in the government, and

those governmental employees take their sweet time to do anything, while so many

people are being harassed and defamed.


Comments

2 Responses to From Captain Pamela Barnett

Pernelia Jory

October 28th, 2010 @ 5:52 pm

Isnt the brave Captain Pamela Barnett also an African American?

And isnt she bravely fighting the California and U.S. Governments single handedly in Barnett v.,

Bowen?

God bless her and you, Lady Liberty.

1.

[email protected]

October 29th, 2010 @ 5:19 am

she is not African American

2.


NEW! CA REP CENTRAL COMMITTEE LISTCAMPAIGN FLIERfor Orly Taitz as CA SOS

CAMPAIGN FLIERfor Orly Taitz as CA SOS, 2 Per Page

How to contact public Integrity unit

See The PDF File Here

US Department of Justice has a special unit in their Criminal Division called the

PUBLIC INTEGRITY SECTION

Captain Pamela Barnett | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

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VIDEOSHome


Defend Our Freedoms Foundation 29839 Santa Margarita Pkwy, ste 100, Rancho Santa

Margarita CA, 92688 Copyright 2010




THERE IS TYRANNY.


THERE IS LIBERTY.

- Thomas Jefferson

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

New Action Item!

Posted on | October 29, 2010 | Comments Off

Sharron Angle surged in the polls, and she is now leading by 4-6% in NV. Last week I wrote thanks to Obama forbeing such a great cheerleader in fundraising for Sharron. A couple of days ago Sharron sent a thank you card and

flowers to Joy Behar thanking Joy for calling Sharron a bitch, as it gave Sharron additional $200,000 indonations.

Yesterday Obama was on John Stuart show. Stuart was making fun of him saying, you ran on hope and change,

now the Democrats are running on Please, please, give me one more chance. When John Stuart is making fun ofObama and his policies, you know Obama is in deep trouble. Stuart also made some jokes about Larry Summers,Obamas former chief economic advisor.

Now to the Action Item. House of Representatives is safely in the bag. Republicans need to take 10 out of 19Senate seats up for vote. This is harder, than taking the House, as percentage wise it represents about 53% of theseats, while in the House, Republicans need to take only 39 more seats, which represents only 15% of

Action Item! | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?


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the Democrat seats, that are up for vote.

There are 8 Senate races, where Democrats hold seats currently, but Republicans are leading with 4% or more.

That includes Sharron Angle in NV and Mark Steven Kirk in IL. In WA Dino Rossi is ahead, but only by 1-2%. In

WV poll results are flipping, as Republican Raese is running neck in neck with current governor Democrat

Manchin. Residents of WV in general like their governor, but they are apprehensive about sending him to DC, to

be yet another Dem to vote for the insane Obama Agenda.John Raese is a successful businessman, does not

believe in crazy borrowing and spending. Please, call NRA- Raese is a lifelong NRA member. Please, concentrate

on where you can make the most difference. Currently the action items are Dino Rossi in WA and John Raese inWV. Please, dont go through the Republican party or any packs. Call the campaign directly. Raeses info is

below. If you live in WV or in the vicinity and can go to his headquarters, go there and make the calls. With new

automatic systems you can make 75 calls an hour and do more, than by walking the precincts. There is very little

time left. I wish I could fly to WV or WA to help, as I flew to Sharron Angles headquarters last week, but I dont

think I can, it is all expensive and I have to file pleadings soon in the stupid Berg-Liberi harassment case in the

third Circuit court of Appeals. If you are far away, ask for a list of voters to call. If you can, be a precinct

watcher. If you spot any irregularities, please, file an election contest and send a copy to me. When you call,

remind the voters, that Joe Manchin cannot be trusted. He flip-flopped on Obamacare. He supported it before, and

now in order to get elected he is against it.

Same picture is in WA. Patty Murray is a career politician and a Democrat party old hack. She set in the Senate

for 18 years and thanks to hacks like her we are sitting with 13 trillion of foreign debt and 300 trillion of unfundedobligations. Old party hacks like her bankrupted the country. Throw the bums out!!! Dino Rossi and Joe Manchin

are our #9 and 10 to take the Senate and therefore take both houses. We are very close, we can do it. Be very

vigilant about any elections fraud. If you find anything, well deal with it after the election, when well have the

Republican house and when well be able to impeach and or prosecute people committing or allowing elections

fraud.

John R. Raese (WV)

Office Seeking: U.S. Senate

Party: Republican

Additional Information

>Gender: Male

Family: Wife: Elizabeth

2 Children: Jane, Agnes

Birth Date: 04/10/1950

Birthplace:

Home City: Morgantown, WV

Religion: Presbyterian

Education:

BS, Education, West Virginia University, 1973

Professional Experience:

President/Chief Executive Officer, Greer Industries, present

Vice President, Morgantown Dominion-Post, present

Founder, Pikewood Creative, present

Photo for John R. Raese (WV)

BiographicalIssue Positions

(Political Courage Test)Interest

Group RatingsPosition

PapersSpeeches and Public

StatementsCampaign Finances

Opposing Candidates

Jeff C. Jeff Becker

(Constitution)

Jesse Johnson (Mountain

Party)

Joe Manchin (Democratic)

All candidates


5/2/2011

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Board Chair, West Virginia Radio Corporation, present

Political Experience:

Candidate, United States Senate, 1984, 2006

Chair, West Virginia Republican Party, 1986

Organizations:

Life Member, National Rifle Association (NRA)

Contact Information

Current Office:

>

Background Information

//>

Contact Information

Make a donation to Dr. Orly Taitzfor CA Secretary of State 2010

Campaign

--------------------------------------

--------------------------------------

--------------------------------------


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EXHIBIT 90



37/40


38/40

VIDEOS

Home






THERE IS TYRANNY.


THERE IS LIBERTY.

- Thomas Jefferson



I am trying to find an owner of this site, I got info

below


This person was one of the most vicious attackers of me. What was interesting, was the fact that she (maybe

he) tried to show herself as Obama supporter, but she was targeting me personally, while trying to provide

cover for Philip Berg and Lisa Liberi. If this site was truly pro-Obama site, one would expec,t that they would

attack both.

for example, they were channelling Berg and Liberis point, that bad Orly Taitz is demanding that Liberi

present her records, her PA drivers license, even though poor Liberi is a victim and should not show any of

her records. They were doing it , even though I already presented Liberis mug shot and rap sheet showing her

to be a career criminal, document forger and thief.

rying to find an owner of this site, I got info below | Dr. Orly Taitz E... http://www.orlytaitzesq.com/?


5/2/2011

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It just doesnt make sense. Somebody, who is pro-Obama, would attack both. This site was created to

specifically defame me. What I noticed, that this site has connections to PA,where Berg resides. This might be

a coincidence, maybe not. I saw, that this domain is listed on mazeltough.com .This means good luck in

Hebrew. Which might mean this person is probably Jewish and doing some networking in Jewish

community. Monstercommerce.com might mean that this person is a businessperson, she or he has some type

of business. nailsginjoint.com and holymarylamp.com might might mean some types of sites that promote

certain types of businesses. One thing is clear, this is a site with one of the most vicious vitriol against me-

Alinsky on steroids. Keep in mind, that I am an only attorney, who brought forward Social Security fraud.

This places my arguments appart, as most dangeorus for Obama, it shows him not only covering up hismissing birth certificate, but also engaging in serious crimes, like Social Security fraud. So I am a number one

target for Obama. I am also a number 1 target for Philip Berg and Liberi, because I exposed the fact that Berg

is working with a convicted document forger.

If, arguendo, Bergs case were to go to a jury (it wouldnt, as it was already dismissed by all the courts), it

could have been easily dismissed by Obamas attorneys showing, that those affidavits from Africa were

prepared or handled by a career document forger, Bergs paralegal Lisa Liberi. In my case,I dont use those

affidavits from Africa, prepared by a forger. I use affidavits from 3 licensed investigators: Neil Sankey, Susan

Daniels and John Sampson. Sampson is a recently retired senior deportation officer from the department of

Homeland Security. They cant throw away his testimony.

Lastly, I exposed judicial corruption. So, there are a number of individuals, who have a reason to destroy

me. If you have any information on sites and publications, attacking me, identity of owners, who are they

connected to , let me know. I need to know the connections.

domain Name: OHFORGOODNESSSAKE.COM

Administrative Contact:

LANE, DORIS [email protected] (nameprivacy redirects to NameSecure.com)

DORIS LANE

ATTN:

P.O. Box 430 c/o NameSecure

Herndon, VA 20171-430US

570-708-8782

Doris listed not her address, but that of the server that hosts her website.

The PO Box is for NameSecure.com, apparently a branch of NetworkSolutions.com

This address and phone number is listed in several websites contact info, including MAZELTOUGH.COM,

MONSTERCOMMERCE.COM , NAILSGINJOINT.COM, HOLYMARYLAMP.COM, and others.

The phone number is in PA, possibly someone who has a large block of space on NameSecure and sells

domains for that space.

http://www.intelius.com/results.php?ReportType=33&searchform

Phone Profile

(570) 708-8782

Land Line

Sugarloaf, PA

or Drums, or Luzerne, PA on different search sites. Unpublished number.

____________

Registrant:


5/2/2011

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LLC, NameSecure

NameSecure LLC

13861 Sunrise Valley Dr.

Herndon, VA 20171

US

Domain Name: NAMESECURE.COM

Administrative Contact:LLC, NameSecure [email protected]

NameSecure LLC

13861 Sunrise Valley Dr.

Herndon, VA 20171

US

570-708-8418

________________

Domain Name: MONSTERCOMMERCE.COM

Administrative Contact , Technical Contact :

Network Solutions LLC [email protected] (NameSecureDomains?)

13861 Sunrise Valley Drive, Suite 300

Herndon, VA 20171

US

Phone: 7036684600


Comments

2 Responses to I am trying to find an owner of this site, I got info below

Pernelia Jory

October 30th, 2010 @ 8:06 am

What do you suggest we do to help, Lady Liberty?

1.

Patriot

October 30th, 2010 @ 1:15 pm

Time is running short. We almost have you.

Burn, BITCH, Burn!

2.


NEW! CA REP CENTRAL COMMITTEE LIST



Documents

LIBERI v TAITZ (C.D. CA) - 190.17 - Plaintiffs Exhibits 84-90 to Amended Complaint.190.17