LIBERI v TAITZ (C.D. CA) - 190.18 - Plaintiffs Exhibits 91-95 to Amended Complaint.190.18

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.18 - Plaintiffs Exhibits 91-95 to Amended Complaint.190.18

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EXHIBIT 91

Case 8:11-cv-00485-AG -AJW Document 190-18 Filed 05/20/11 Page 1 of 51 Page ID#:5184


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Dr. Orly Taitz Esquire

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

Margarita CA, 92688 Copyright 2010

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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.

Why is Lisa Liberi not back in prison? Why is District

Attorney not scheduling a hearing for revocation of

probation? Answer below will shed some light into

why the system is not workingPosted on | November 6, 2010 | Comments Off

s Lisa Liberi not back in prison? Why is District Attorney not schedu... http://www.orlytaitzesq.com/?

http://www.orlytaitzesq.com/?p=15376

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LIBERI , LISA

Case FWV028000 Defendants

Seq Defendant Next Court Date Status Agency /

DR Number

Arrest Date Count 1 Charge Violation Date

1 LIBERI , LISA RRA110013759

05/18/2001 PC 115(A) 05/18/2001

ALIAS: LIBERI, LISA R

ALIAS: COURVILLERICHARDSON, LISA

ALIAS: LIBERI, LISA A

ALIAS: RICHARDSON, LISA C

ALIAS: COURVILLERICH, LISA

ALIAS: LIBERI, LISA RENEE

ALIAS: LIBERI, LISA

ALIAS: RICHARDSON, LISA RENEE

Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE Status

Custody N/A

Filing Type Held to Answer Filing Date 05/09/2003

Ordered Bail$0.00 Posted Bail $0.00

D.A. James R. Secord Defense Dean Pitcl (Court Appointed)

Next Action: Deputy Report #: RA-RC 110013759

Warrant Type Status Issued Affidavit

NONE N/A N/A

ProbationType Granted Expiration

Formal 03/21/2008 03/21/2011

Sentence Convicted Date County Jail CTS

01/25/2008 26 Days 26 Days

State Prison Max Sentence

N/A N/A

Fine and Penalty Restitution Fine Restitution to Victim

0 N/A

Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE Charges

Arrest Charges

Count Charge Severity DescriptionViolation

DatePlea Status

1 PC 459 F BURGLARY 05/18/2001

Filed Charges


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DatePlea Status

1 PC 487(A) FGRAND THEFT: PROPERTY/ETC OVER

$40005/18/2001 HTA

2 PC 470(D) F FORGERY 05/18/2001 HTA

3 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 HTA

4 PC 115(A) F OFFER/ETC FALSE/FORGEDINSTRUMENT TO FILE

05/18/2001 HTA


$40005/18/2001 HTA

6 PC 470(D) F FORGERY 05/18/2001 HTA

7 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 HTA

8 PC 115(A) FOFFER/ETC FALSE/FORGED

INSTRUMENT TO FILE05/18/2001 HTA

9 PC 487(A) FGRAND THEFT: PROPERTY/ETC OVER$400

05/18/2001 HTA

10 PC 487(A) FGRAND THEFT: PROPERTY/ETC OVER$400 05/18/2001 HTA

11PC487(D)(1)

FGRAND THEFT:AUTOMOBILE/ANIMAL/ETC

05/18/2001 HTA


05/18/2001 HTA

13PC487(D)(1)


05/18/2001 HTA


05/18/2001 HTA

15PC

487(D)(1)

FGRAND THEFT:

AUTOMOBILE/ANIMAL/ETC

05/18/2001 HTA


05/18/2001 HTA


$40005/18/2001 HTA

Infor Charges


DatePlea Status


05/18/2001 GUILTY CONVICTED

2PC476A(A)

F NONSUFFICIENT FUNDS: CHECKS 05/18/2001 GUILTY CONVICTED

3 PC 470(D) F FORGERY 05/18/2001 DISMISSED

4 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 DISMISSED

5 PC 115(A) FOFFER/ETC FALSE/FORGEDINSTRUMENT TO FILE





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7 PC 476 FMAKING, POSSESSING, UTTERINGFICTIOUS INSTRS

05/18/2001 DISMISSED


9 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 GUILTY CONVICTED




$400




13PC487(D)(1)





15PC487(D)(1)





17 PC487(D)(1)

F GRAND THEFT:AUTOMOBILE/ANIMAL/ETC







INSTRUMENT TO FILE05/18/2001 GUILTY CONVICTED




Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE Probation

Probation Type: FORMAL Granted: 03/21/2008 Expire: 03/21/2011

SUPERVISED PROBATION GRANTED FOR A PERIOD OF 36 MONTHS ON FOLLOWING TERMS ANDCONDITIONS:

1)

SERVE 26 DAYS IN A SAN BERNARDINO COUNTY JAIL FACILITY, WITH CREDIT FOR TIMESERVED, A MATTER OF 26 DAYS, PLUS CONDUCT CREDIT PURSUANT TO 1-PC4019 ND

ABIDE BY ALL RULES AND REGULATIONS OF THE FACILITY WITHOUT THE POSSIBILITYOF COUNTY PAROLE.

2) VIOLATE NO LAW.

3)

REPORT TO THE PROB OFFICER IN PERSON IMMEDIATELY 0- ND THEREAFTER ONCEEVERY FOURTEEN (14) DAYS OR AS DIRECTED. REPORT TO THE PROB OFFICER INPERSON IMMEDIATELY 0- ND THEREAFTER ONCE EVERY FOURTEEN (14) DAYS OR ASDIRECTED.

4)COOPERATE WITH THE PROBATION OFFICER IN A PLAN OF REHABILITATION ANDFOLLOW ALL REASONABLE DIRECTIVES OF THE PROBATION OFFICER.


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5)SEEK AND MAINTAIN GAINFUL EMPLOYMENT, OR ATTEND SCHOOL, AND KEEP THEPROBATION OFFICER INFORMED OF STATUS OF EMPLOYMENT, OR SCHOOL.

6)

KEEP THE PROBATION OFFICER INFORMED OF PLACE OF RESIDENCE AND COHABITANTSAND GIVE WRITTEN NOTICE TO THE PROBATION OFFICER TWENTY-FOUR (24) HOURSPRIOR TO ANY CHANGES. PRIOR TO ANY MOVE PROVIDE WRITTEN AUTHORIZATION TOTHE POST OFFICE TO FORWARD MAIL TO THE NEW ADDRESS. PERMIT VISITS ANDSEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THE PROBATION DEPT. AND/ORLAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCE WITH PERMIT

VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THE PROBATION DEPT.AND/OR LAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCE WITHPERMIT VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THEPROBATION DEPT. AND/OR LAW ENFORCEMENT FOR THE PURPOSE OF ENSURINGCOMPLIANCE WITH THE TERMS AND CONDITIONS OF PROBATION; NOT DO ANYTHINGTO INTERFERE WITH THIS REQUIREMENT, OR DETER OFFICERS FROM FULFILLING THISREQUIREMENT, SUCH AS THE TERMS AND CONDITIONS OF PROBATION; NOT DOANYTHING TO INTERFERE WITH THIS REQUIREMENT, OR DETER OFFICERS FROMFULFILLING THIS REQUIREMENT, SUCH AS ERECTING ANY LOCKED FENCES/GATES THATWOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE ANY ANIMALS ON THEPREMISES THAT WOULD REASONABLY DETER, ERECTING ANY LOCKED FENCES/GATES

THAT WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE ANY ANIMALS ON THEPREMISES THAT WOULD REASONABLY DETER, THREAT THREATEN THE SAFETY OF, ORINTERFERE WITH, OFFICERS ENFORCING THIS TERM. EN THE SAFETY OF, OR INTERFEREWITH, OFFICERS ENFORCING THIS TERM.

7)NEITHER POSSESS NOR HAVE UNDER YOUR CONTROL ANY DANGEROUS OR DEADLYWEAPONS OR EXPLOSIVE DEVICES OR MATERIALS TO MAKE EXPLOSIVE DEVICES.

SUBMIT TO A SEARCH AND SEIZURE OF YOUR PERSON, RESIDENCE AND/OR PROPERTYUNDER YOUR CONTROL AT ANY TIME OF THE DAY OR NIGHT BY ANYLAW-ENFORCEMENT OFFICER, WITH OR WITHOUT A SEARCH WARRANT, AND WITH ORWITHOUT CAUSE (PEOPLE -V- BRAVO).

9)NEITHER USE NOR POSSESS ANY CONTROLLED SUBSTANCE WITHOUT MEDICALPRESCRIPTION. A PHYSICIANSS WRITTEN NOTICE IS TO BE GIVEN TO THE PROBATION

OFFICER.

10)SUBMIT TO A CONTROLLED SUBSTANCE TEST AT DIRECTION OF PROBATION OFFICER.EACH TEST IS SUBJECT TO AN $11.00 FEE, TO BE COLLECTED BY CENTRAL COLLECTIONS

11) NOT POSSESS ANY TYPE OF DRUG PARAPHERNALIA, AS DEFINED IN H&S11364.5(D)

12)

PARTICIPATE IN A COUNSELING PROGRAM AS DIRECTED BY THE PROBATION OFFICER,SUBMIT MONTHLY PROOF OF ATTENDANCE AND/OR SUCCESSFUL COMPLETION TO THEPROBATION OFFICER AS DIRECTED AND BE RESPONSIBLE FOR PAYMENT OF ALLPROGRAM FEE(S).

13)NOT ASSOCIATE WITH KNOWN CONVICTED FELONS OR ANYONE ACTIVELY ENGAGED INCRIMINAL ACTIVITY B-OR CODEFENDANT(S) OR VICTIM(S).

14)

NOT ASSOCIATE WITH KNOWN ILLEGAL USERS OR SELLERS OF CONTROLLED

SUBSTANCES,

15)NOT MAINTAIN A CHECKING ACCOUNT OR COMPLETE OR ENDORSE ANY CHECKSUNLESS MADE PAYABLE TO YOU AND NOT HAVE ANY BLANK CHECKS IN YOURPOSSESSION WITHOUT PERMISSION OF THE PROBATION OFFICER.

16)SUBMIT A RECORD OF INCOME AND EXPENDITURES TO THE PROBATION OFFICERQUARTERLY.

17)NEITHER POSSESS NOR USE ANY CREDIT CARD WITHOUT PERMISSION OF THEPROBATION OFFICER.


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18)NOT DRIVE OR POSSESS KEYS OR DOCUMENTATION TO ANY MOTOR VEHICLE UNLESSLEGALLY REGISTERED TO YOU OR AN IMMEDIATE FAMILY MEMBER, EXCEPT IN THECOURSE OF EMPLOYMENT.

19)REPORT ALL MOTOR VEHICLES REGISTERED TO YOU TO THE PROBATION OFFICERWITHIN SEVEN (7) DAYS OF ACQUISITION.

20)SUBMIT TO AND COOPERATE IN A FIELD INTERROGATION BY ANY PEACE OFFICER ATANY TIME OF THE DAY OR NIGHT.

21)

CARRY AT ALL TIMES A VALID DRIVERS LICENSE OR DEPARTMENT OF MOTOR VEHICLES

IDENTIFICATION CARD AND DISPLAY SUCH IDENTIFICATION UPON REQUEST BY ANYPURPOSE WITHOUT FIRST NOTIFYING THE PO. CONTAINING YOUR TRUE NAME AGE ANDCURRENT ADDRESS

22)ENROLL IN THE DRUG TREATMENT PROGRAM AT THE DIRECTION OF THE PROBATIONOFFICER, AND SHOW PROOF OF ENROLLMENT TO THE PROBATION OFFICER WITHINSEVEN (7) DAYS.

23)MAKE RESTITUTION TO THE VICTIM(S) (SEE PROBATION REPORT) IN THE AMOUNT OF$9223.77 PLUS A 10% ADMINISTRATIVE FEE, TO BE PAID THROUGH CENTRAL

COLLECTIONS

24)

MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORT) IN THE AM OUNT OF

$35000.00 PLUS A 10% ADMINISTRATIVE FEE, TO BEPAID THROUGH CENTRAL

COLLECTIONS

25)MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORT) IN THE AMO UNT OF$66951.08 PLUS A 10% ADMINISTRATIVE FEE, TO BE PAID THROUGH CENTRALCOLLECTIONS

26)PAY A RESTITUTION FINE IN THE AMOUNT OF $200.00, PLUS A TEN PERCENT (10%)ADMINISTRATIVE FEE THROUGH CENTRAL COLLECTIONS.

27)THE DEFENDANT IS NOT TO FILE ANY LAWSUIT/LEGAL ACTION WITHOUT PRIORCONTACT WITH PROBATION OFFICER.

28)DO NOT APPLY FOR CREDIT OR A LOAN WITHOUT PRIOR CONTACT WITH PROBATIONOFFICER.

29) COMPLY WITH ANY COURT-ORDERED PAYMENT SCHEDULE.

30) MAKE RESTITUTION TO VICTIM (SEE PROBATION REPORT) IN AN AMOUNT TO BEDETERMINED BY PROBATION.

31)MAKE RESTITUTION TO VICTIM (SEE PROBATION REPORT) IN AN AMOUNT TO BEDETERMINED BY PROBATION.

32)PROBATION MAY BE SERVED THROUGH INTER STATE COMPACT AGREEMENT IN THESTATE OF NEW MEXICO UPON APPROVAL FROM PROBATION.

UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA (Eastern Division Riverside)CIVIL DOCKET FOR CASE #: 5:05-cv-00309-UA l

Lisa Liberi v. West Valley Detention Center et al

Assigned to: Judge UnassignedDemand: $280,000,000Cause: 18:1961 Racketeering (RICO) Act

Date Filed: 04/15/2005

Date Terminated: 04/28/2005Jury Demand: PlaintiffNature of Suit: 470 Racketeer/CorruptOrganizationJurisdiction: Federal Question

Plaintiff

Lisa Liberi represented by Michelle D StricklandMichelle D Strickland Law OfficesP O Box 2238Colton, CA 92324


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951-782-8555LEAD ATTORNEY

ATTORNEY TO BE NOTICED

V.

Defendant

West Valley Detention Center

Defendant

San Bernardino County Sheriffs

Department

Defendant

Gary PenrodSan Bernardino County Sherif f

Defendant

Paul Morrison

Defendant

Doe Deputiesassigned to West Valley Detention Center

Defendant

Doe Nursesassigned to West Valley Detention Center

Defendant

Dr Shin Yin LiongMD

Defendant

Doe Contractorsassigned to West Valley Detention Center

Defendant

John HearyNursing Supervisor

Defendant

Brian FrattDeputy


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Defendant

County of San Bernardino

Defendant

San Bernardino County District

Attorneys Office

Defendant

James SecordDeputy District Attorney

Defendant

Mike Leiberich

Defendant

V L Hamilton

Defendant

Michael A RamosDistrict Attorney

Defendant

Joan Borba

Judge

Defendant

Craig Wyatt Zibellindividually and

doing business as

Allways Allways 4U Bail Bondsalso known as

Allways For-U Bail Bonds

Defendant

Angelo Michael Verlingo

Defendant

Bar Triangle Bail Bonds Incdoing business as

Boones Bail Bonds


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Defendant

Seneca Insurance Company Inc

Defendant

John Mark Allen

Defendant

US Federal Credit Unionalso known as

United Services of America

Defendant

Melinda Rosas Wevely

Defendant

Julie Misleh

Defendant

Houts & Associates

Defendant

Randolph C Houts

Defendant

Rob Henderson

Defendant

DOES1 through 10 inclusive

Date Filed # Docket Text

04/15/2005 LODGED COMPLAINT submitted by plaintiff fwd to Duty Magistrate Judge: (SGL)., filedby plaintiff Lisa Liberi.(am, ) (Entered: 04/27/2005)

04/15/2005 1 REQUEST to Proceed In Forma Pauperis, Declaration in Support filed by plaintiff LisaLiberi. (am, ) (Entered: 04/27/2005)

04/15/2005 2 MOTION for Leave to Proceed in forma pauperis, waiver of filing fees, costs and service ofprocess by the US Marshall filed by plaintiff Lisa Liberi. Lodged Lodged Orders. (am, )

(Entered: 04/27/2005)


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04/25/2005 PLACED IN FILE NOT USED re Order for leave to proceed in forma pauperis andservice of process by the US Marshal submitted by plaintiff Lisa Liberi. (am, ) (Entered:04/28/2005)

04/28/2005 3

NOTICE OF CLERICAL ERROR: Case number has been corrected. The correct casenumber is CV 05-3015 VAP (SGLx). All previosly filed documents under ED CV 05-309 willbe docketed and housed under case number CV 05-3015 VAP (SGLx). This case is closed.Case opening clerk assigned this to Magistrate Judge Larson in error. (la, ) (Entered:

04/29/2005)

You can see, that Lisa Liberi harassed the county, the judge, the DA office , policemen, correctional institution,where she was incarcerated, and other with a frivolous law suit, demanding 280 million dollars from all of the

county officials. Her case was dismissed, for failure to prosecute, but it looks like this harassment was enoughfor the DA and the judge to ultimately reduce her 8 year prison term for 10 counts of forgery and theft to 3 yearsprobation. Now Liberi with the help of her attorney Philip J. Berg is slandering and defaming multiple innocentindividuals. They filed yet another frivolous law suit in PA claiming her to be an innocent woman residing in PA.and not the same Liberi, who was convicted in CA. The judge got the mug shot and could see, that it is the sameperson. The witnesses identified her as the same person. When Liberi and Berg were asked to produce her PAdrivers license, they came up with an insane an slanderous accusation that her PA drivers license cannot beproduced because Attorney Orly Taitz tried to hire a hit man to kill her. Even though Liberi is the one who is

a convicted forger and thief, Liberi and Berg accused multiple individuals, who never committed any crimes ofmultiple acts of forgery and theft. District Attorneys office was supposed to revoke her probation long time ago

and send her back to prison to serve her 8 year prison term. They were supposed to prosecute Philip J. Bergfor aiding and abetting felon on probation to violate terms of her probation, for filing a legal action with thepurpose of harassment. It has been a year and a half and they were not prosecuted yet.

You may ask why? The reason is simple: we have now the criminals telling the government what to do by virtue offiling RICO law suits against governmental officials as Liberi filed her RICO suit against everyone in the county in

2005. The end result is that such officials dont want to bother with such criminals and let them get away withmurder. Please, help end this nightmare and this enormous waste of my time and money, that I should be using forbetter purposes. Please demand from the San Bernardino District Attorneys office and San Bernardino county

Grand Jury to finally do their job and prosecute Liberi and Berg. There has to be an end to this. You can nowunderstand, why others are not prosecuted for commission of crimes. If a common criminal like Liberi is allowed todo what she wants, you can understand, how they are intimidated of others. We have to end this. Please, demandthat the San Bernardino, CA District Attorney do his job. If he is intimidated by common criminals and not willingto do his job, then he needs to resign and a new DA has to be appointed. Our government should be there to protectus from criminals, not aiding and abetting criminals and their unscrupulous attorneys in terrorising innocentindividuals, who happen to be whistle blowers.

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




THERE IS TYRANNY.


THERE IS LIBERTY.

- Thomas Jefferson



Lisa Liberi mug shot

Posted on | November 6, 2010 | Comments Off

s Lisa Liberi not back in prison? Why is District Attorney not schedu... http://www.orlytaitzesq.com/?attachment_

http://www.orlytaitzesq.com/?attachment_id=15377

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THERE IS TYRANNY.


THERE IS LIBERTY.

- Thomas Jefferson



Why it is important to go after criminals

Posted on | November 7, 2010 | 4 Comments

[email protected]

67.159.56.162

Submitted on 2010/11/06 at 5:25pm

I agree with you that having a convicted felon help a lawyer is a bad

thing. But what should Lisa Liberi be in jail now? What has she done

since she was put on parole? Complained that you were harassing her?

Is that a crime?

explanation from Orly:

Liberi and Berg did not just complain, they filed a law suit in

Philadelphia for nearly a billion dollars against me, investigator

Why is LisaLiberi not

back in

prison? Why

is District

Attorney not

scheduling a

hearing for

revocation of

probation?

t is important to go after criminals | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?


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Sankey, owner of a Christian publishing house James Sundquist, talk

show host Ed Hale, his wife, his radio station, Mr.Sankeys firm and so

on.

The basis of their law suit was slander and defamation of character.

they claimed that Lisa Liberi , working for Berg does not send

information to Berg from out of state, but rather lives in PA. they said

that she is a different woman, who was never convicted of any crimes

and I defamed them by posting a criminal record of Liberi. They

claimed, that though she has the same first, middle and last name andthe same birth date she is a different person. I produced her mug shot.

The judge could see, that the woman, who appeared before him is the

same woman, who was convicted in CA. In spite of the fact, that I

provided her mug shot, identical signature from CA,

information, pointing out the same first, middle, last name, same birth

dates, these criminals are still claiming, that she is not the same woman

and continue harassing me with the same law suit. They are committing

perjury, fraud on the court and they committed a number of other

crimes, which I will not list at the moment. Violation of law is grounds

for revocation of her probation

Not only they filed a frivolous law suit based on perjury and fraud, Berg

and Liberi viciously defamed multiple individuals in order to cover up

the fact, that a convicted forger and thief Lisa Liberi is employed by

attorney Philip J. Berg. They are refusing to provide her PA drivers

license to prove, that she is indeed a resident of PA. They are trying to

justify this refusal by claiming that she is afraid for her life because I

tried to hire a hit man to kill her. Berg is acting like a criminal. He is

accusing an innocent person of crimes in order to cover up a fact, that

he is working with a criminal, that he is conducting a Nation wide

donation drive by using a convicted thief on probation as his assistant.

He should be disbarred for doing this. Just as he accused me, heaccused multiple individuals of stalking, perjury, forgery and so on.

People like this should not be allowed to practice law. It is true, that

sometimes people of questionable character contact public figures and

volunteer their help. It happened to me and it happens to everybody,

however, after it is found, that such person is doing illegal things, it is

up to the lawyer to disassociate himself from such individuals. that what

I did. that is what Berg was supposed to do a year and a half ago.

Instead he and Liberi engaged in cover up and have been harassing me

and many others with a frivolous law suit for nearly a billion dollars,

they slandered and defamed multiple innocent individuals. Their

behavior was criminal. This is not about one woman saying something.

this is about a criminal behavior. My question is, why are the courts

allowing this to go on? Presiding Judge Eduardo Robreno was supposed

to get a verification of her PA citizenship for the purpose of diversity. If

a party refuses to provide her prove of citizenship, a law suit based on

diversity cannot go on. It is supposed to be dismissed. If this would be

allowed, any criminal would commit any crimes and claim that he is a

different person.

Why didnt Robreno demand her prove of PA citizenshio immediately?

Answer

below will

shed some

light into why

the system is

not working

t is important to go after criminals | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

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THERE IS TYRANNY.


THERE IS LIBERTY.

- Thomas Jefferson



Submitted yesterday in the Third Circuit Court of

Appeals

Posted on | November 23, 2010 | 1 Comment

No. 10-3000

UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT

____________________

itted yesterday in the Third Circuit Court of Appeals | Dr. Orly Taitz... http://www.orlytaitzesq.com/?


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LISA LIBERI, et al.,

Plaintiffs-Appellees,

vs.

ORLY TAITZ, et al.,

Defendant-Appellants.

__________________

District Court No. 09_cv_01898_ECR

Eastern District of Pennsylvania

__________________

APPELLANTS REPLY TO APPELLEES BRIEF

DR. ORLY TAITZ, ESQ.

CSB #223433

Attorney Pro Se &

Attorney for Defend Our Freedoms Foundation

29839 S. Margarita Pkwy. Rancho Santa Margarita CA 92688

ph. 949-683-5411

fax 949-766-7603

TABLE OF CONTENTS


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TABLE OF AUTHORITIESp31.

CERTIFICATION OF COMPLIENCEp42.

SUMMARY OF THE ARGUMENT..p43.

LEGAL ARGUMENT..p64.

A. DECISION TO ASSUME JURISDICTION IN DIVERSITY WITHOUT VERIFICATION OF THE STATE

CITIZENSHIP GOES AGAINST PRIOR RULINGS OF THE THIRD CIRCUIT COURT OF APPEALS.p6

B.APPELLEES ATTACKS ON THE JURISDICTION OF THE THIRD CIRCUIT COURT OF APPEALS ISFRIVOLOUSp12

C. STATE CITIZENSHIP IS AT THE CORE OF THE CASE..p13

D. APPELLEES COMMITTED FRAUD ON THE COURT AND PERJURY BY CLAIMING THAT THEY

PROVIDED LIBERIS DRIVERS LICENSE TO JUDGE

ROBRENO..p17

E. APPELLEES DISCUSSION OF VENUE IS IRRELEVANT AND WAS DONE IN ORDER TO CREATE

CONFUSION, AS AT ISSUE IS THE FACT, THAT THERE WAS NO JURISDICTION FOR FEDERAL

COURT TO SIT IN DIVERSITY, REGARDLESS OF VENUEp18

F. PUBLIC POLICY CONSIDERATIONS..p19

G. APPELLEES ARE MISREPRESENTING THE ISSUES ON APPEAL IN RELATION TO THE

DISMISSAL OF THE DEFENDANTS JAMES SUNDQUIST AND SALT ROCK

PUBLISING..p20

H. FRAUD ON THE COURT BY BERG AND LIBERI COMMITTED, AS NO IDENTIFICATION

DOCUMENTS WERE ROVIDED...p22

I. JUDGE ROBRENOS FINDINGS WENT TO THE CORE OF THE CASE AND WERE IMPROPER TO

BE MADE WITHOUT THE EVIDENCEp25

J. APPELLANTS REQUEST FOR SANCTIONS IS PROPER AND SUPPORTED BY FACT AND LAW

AND NECESSARY TO STOP EGREGIOUS MISCONDUCT BY BERG AND THE PLAINTIFFS..p26

CONCLUSIONp301.

CERTIFICATE OF SERVICE. p312.

TABLE OF AUTHORITIES

1.Packard v Provident National Bank, 994 F. 2d 1039, 1045 (3d Cir. 1993)p8

2. Gould Electronics, inc v United states, 220 F. 3d 169, 176 (3d Cir.2000)p 8

3. J& R Ice cream Corp. v. California Smoothie Licensing, 31 F. 3d 1259, 1265 n.3 (3rd

Cir

1994)..p8

4. 5C. Wright & A. Miller, Federal Practice and Procedure 1206, at 78-79 (1969 & Supp.

2005)..p8


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5. Thomas v Board of Trustees, 195 U.S. 207, 210 (1904).p8

6. Joiner v. Diamond M Drilling Co., 677 F. 2d 1035, 1039 (5th

Cir 1982).p9

7.Weight v Kawasaki Motors Corp. (1985, ED Va) 604 F Supp 968.p9

8. McMann v Doe (2006, DC Mass) 460 F Supp 2d..p10

9. Bautista v Pan American World Airlines, Inc. (1987, CA9 Cal) 828 F2d 546, 126 BNA LRRM 2559, 107CCH LC P 10159.p10

10. Roche v Lincoln Prop. Co. (2004, CA4 Va) 373 F3d 610.p9

11.Olsen v Quality Continuum Hospice, Inc. (2004,DC NM) 380 F Supp 2d

1225....p10

12.Filla v Norfolk & Southern Ry. (2003, CA8 Mo) 336 F3d 806.p11

13.Jeter v Jim Walter Homes, Inc. (1976, WD Okla) 414 F Supp 791.259..p11

14. Shahmoon Industries, Inc. v Imperato (1964, CA3 NJ) 338 F2d 449, 9 FR Serv 2d 12B.22, Case

2p11

CERTIFICATION

Reply brief does not exceed allowed 7,000 words

Hard paper copy of the reply brief is identical to the electronic copy

SUMMARY OF THE REPLY

This appeal revolves around the fact, that presiding Judge Eduardo Robreno erred, showed bias and abuse of

judicial discretion in assuming jurisdiction over this case and entering an order to sever and transfer the

case, with the notation that the plaintiff Lisa Liberi is a resident of Pennsylvania without a shred of

evidence of state residence of the lead plaintiff Lisa Liberi. During 08.07.09 hearing before Judge Robreno

Lisa Liberi and her attorney and Co-plaintiff Phil Berg promised to provide Liberis address and identifying

documents and file them under seal, however,- they defrauded the court and they never provided any

identifying documents. Transcript of the hearing in question and the docket show, that there are no

identifying documents submitted. The Plaintiffs/Appellees could resolve this matter by providing just one

page- a certified copy of Liberis PA drivers license, they could resolve it by submitting it to the Third CircuitCourt of Appeals under seal. They never did it. Instead, they submitted over 900 pages of irrelevant,

inflammatory and defamatory material in order to obfuscate the fact, that they committed fraud, that Liberi

did not reside in PA at the time the law suit was filed, that PA attorney Philip J. Berg is employing as his

paralegal a convicted document forger and thief , Lisa Liberi, who was convicted in 2008 in CA, who is

currently on probation and not allowed to reside in any state aside from CA and NM. Berg yet again violated

the rules of professional discipline and filed this whole case with the purpose of harassing and

intimidating the defendants, who were whistle blowers and exposed Berg and Liberi to the public.

Actions of Judge Robreno represent error of fact and law and abuse of judicial discretion, in that he refused

to rule on the defendants multiple motions to dismiss due to lack of jurisdiction, he refused to take into


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consideration any and all identifying evidence, presented by the defendants, who are out of state defendants,

instead he ruled in favor of the Plaintiff and Plaintiffs attorney Berg, who is a local Philadelphia attorney,

even though Berg did not provide a shred of evidence of Liberis PA residence. Judge Robreno, also, under

the color of authority, violated the Constitutional rights of due process of out of state pro se defendant Linda

Belcher, who repeatedly complained, that she was not served with the pleadings. Judge Robreno simply

ignored all of her letters and complaints, did not docket her letters and did not rule on her complaints.

(Appendix, Affidavit by Linda Belcher ) Additionally, District Court repeatedly did not docket important

exhibits and pleadings provided by the defendants, particularly ones, that were incriminating Berg and Liberi,

whereby showing bias.

LEGAL ARGUMENT

A. DECISION TO ASSUME JURISDICTION IN DIVERSITY WITHOUT VERIFICATION OF THE

STATE CITIZENSHIP GOES AGAINST PRIOR RULINGS OF THE THIRD CIRCUIT COURT OFAPPEALS

Appellees did not provide any response to the main question, why should the jurisdiction be asserted in

diversity without any evidence of the lead plaintiffs state citizenship. Appellees argument can be

summarized to 2 points:

Decision to severe the case was proper in relation to venue1.

Precedents cited by the Appellants, who are CA residents, come from other circuits, mostly CA and not

Third Circuit Court of Appeals cases.

2.

In response, the Appellants are stating, that Venue is not being appealed. Before the Venue is in play, the

Federal Court system as a whole is supposed to have jurisdiction over the case. This case was filed based on

Diversity jurisdiction, where the Appellees claim, that the lead plaintiff is a resident of PA, while the

defendants were residents of CA, TX and NJ. Appellees stated at 08.07.09. hearing that they will submit the

plaintiff Lisa Liberis identifying documents, however they defrauded the court and never submitted those

documents. Presiding Judge Eduardo Robreno, might have thought that those were submitted at some point,

however the docket shows, that at no time within a year and a half those were ever submitted. As such, the

Plaintiffs never established Liberis state citizenship for purposes of diversity.

In regards to the second point questioning the position of the- Third Circuit Court of Appeals in regards to

the state citizenship, it repeatedly ruled that it is upon the party, claiming diversity to show that it exists. It

has to be shown by the preponderance of evidence.

In the recent unpublished case of S. Freedman and Company, Inc v Marvin Raab, 180 Fed. Appx. 316 (3rd

Cir. 2006) not cited here as precedent,Third Circuit Court Judges Honorable Barry, Smith and Aldisert found

that under the precedent of Gould Electronics, Inc v United states, 220 F. 3d 169, 176 (3d Cir. 2000) the

Third Circuit court of Appeals had jurisdiction to review under 28 U.S.C. 1291 the issue of subject matter

jurisdiction as a basis for dismissal of the case. Third Circuit Court of Appeals also found that a District

Court has a duty to raise doubts about its jurisdiction at any time, and that the party asserting

jurisdiction bears the burden of showing that the case is properly before the court at all stages oflitigation. See Packard v Provident National Bank, 994 F. 2d 1039, 1045 (3d Cir. 1993) and similarly J& R

Ice cream Corp. v. California Smoothie Licensing, 31 F. 3d 1259, 1265 n.3 (3rd

Cir 1994).

In its opinion in Freedman v Raab theThird Circuit proceeded to expand and reiterate that the basis upon

which jurisdiction depends must be alleged affirmatively and distinctly and cannot be established

argumentatively or by mere inference See 5C. Wright & A. Miller, Federal Practice and Procedure 1206, at

78-79 (1969 & Supp. 2005); Thomas v Board of Trustees, 195 U.S. 207, 210 (1904) (holding that diversity

jurisdiction, or the facts upon which, in legal intendment, it rests, must be distinctly and positively averred in


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the pleadings, or should appear affirmatively and with equal distinctness in other part of the record); Joiner

v. Diamond M Drilling Co., 677 F. 2d 1035, 1039 (5 th Cir 1982) (In order to adequately establish diversity

jurisdiction, a complaint must set forth with specificity a corporate partys state of incorporation and its

principal place of business). Fedcos bald allegations that the corporate parties are citizens of certain states

are insufficient to carry its burden of pleading the diversity of the parties.

In cases in which jurisdiction is based on diversity of citizenship, plaintiff has burden to show, first, that

applicable 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 BNA LRRM 2559, 107 CCH LC P 10159.

In Olsen v Quality Continuum Hospice, Inc. (2004,DC NM) 380 F Supp 2d 1225

Court lacked jurisdiction over patients claims because he failed to establish diversity jurisdiction because at

time he filed complaint both he and hospice were citizens of State.

In McMann v. Doe (2006, DC Mass) 460 F Supp 2d complaint against John Doe defendant alleging

Internet defamation was dismissed for lack of subject matter jurisdiction because there was risk that ifJohn Does identity were discovered there could have been no diversity, and courts jurisdictional

authority would have disappeared; court declined to read amended language of28 USCS 1441into 28

USCS 1332 because it would have accomplished much broader result of allowing case with only one party

and only state law claims to proceed initially in federal court Olsen v Quality Continuum Hospice, Inc.

(2004,DC NM) 380 F Supp 2d 1225.

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, resolvedambiguity (lack of state law 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.


6 5/2/2011

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Exhibit "94"

Pg. 706



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court, sua sponte, at any time.Jeter v Jim Walter Homes, Inc. (1976, WD Okla) 414 F Supp 791.259.

decided by a preponderance of evidence.

In this case the 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. If the Federal court does

not have jurisdiction to hear the case, it is supposed to be dismissed. The court has no jurisdiction to

transfer to another Federal Court a case, where it did not have jurisdiction in the first place, as otherFederal Courts equally will not have jurisdiction.

B. APPELLEES ATTACKS ON THE JURISDICTION OF THE THIRD CIRCUIT COURT OFAPPEALS ARE FRIVOLOUS

Before the Appellants filed their opening brief, the Appellees filed a Motion to dismiss the Appeal, claiming

that this court has no jurisdiction to hear the appeal. Their motion was denied. Now, in their Appellees

response, the Appellees did not address the appeal itself and are engaged yet again in attacking the

jurisdiction of this court. This is frivolous, as the issue of the Jurisdiction of the Third Circuit Court of Appeals

to hear this brief was already decided and established. The Appellees did not bring one single case as a

precedent, supporting their position, that the District court could properly assert jurisdiction inDiversity without the Plaintiff/Appellee submitting her identification documents, showing her state

citizenship. They did not provide any such precedents, because they simply do not exist. Instead, Appellees

are trying to confuse the court by discussing irrelevant issues and bringing precedents on irrelevant issues,

which are not on Appeal, such as Jurisdiction of the Third Circuit Court of Appeals and Venue. Similarly,

venue is not at issue, as without the jurisdiction in Federal Court system venue is irrelevant.

C. STATE CITIZENSHIP IS AT THE CORE OF THE CASE

As stated in the opening brief, the state citizenship of plaintiff Liberi is at the core of the case, as this case

was filed in the beginning of May 2009 after Defendants/Appellants published on the web site/blog of DOFF

foundation a copy of the verified criminal record of Lisa Liberi, assistant to attorney Philip J Berg, showing

that she was charged in CA in 23 counts of forgery of documents and grand theft and in 2008 was convicted

of 10 charges of forgery of documents, of forgery of the official seal and grand theft and she is currently on

probation, allowed to reside in CA or NM only. On May 4, only a few days after the publication of Liberis

criminal record, Berg and Liberi responded by filing their complaint, where they claimed that Lisa Liberi is a

different woman, who resides in PA, who is innocent and who was slandered and defamed by this publication.

As such, her state residence is extremely important not only for the purposes of diversity, but for the

resolution of the case. Plaintiffs cannot hide it. Taitz properly demanded to see Liberis PA drivers license.

Without any shred of evidence Liberi and Berg accused Taitz, the rest of the defendants and multiple other

individuals of committing multiple crimes, including stalking, forgery and attempt to hire a hit man to kill

Liberi. They claimed, that because of danger to her life Liberis drivers license cannot be shown. JudgeRobreno gave them an opportunity to file Liberis PA drivers license under seal, Taitz agreed to accept a

redacted PA drivers license without the street address, with only the state information. That shows, that

nobody ever tried to hurt them. They never filed any drivers license with the court. The reason for not

providing Liberis PA drivers license, is not in the imaginary threats, but rather in the fact, that she does not

possess a PA drivers license, her PA residence was fraud on the court and perjury on part of Berg and Liberi,

and if they will have to provide her actual drivers license, it will show it to be either CA or NM license,

making it clear, that it is indeed the same Lisa Liberi, who was convicted in CA and allowed to reside only in

CA or NM. Additionally, Appellants filed a motion to strike and motion for sanctions against Appellees and

their attorney Berg, as without a shred of evidence Appellees repeatedly accused the Appellants of multiple


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crimes, whereby Berg showed egregious violation of the Code of professional ethics and egregious

misconduct by an attorney. Not only Berg was knowingly working with a convicted forger and thief, he

defamed innocent people and accused them of multiple serious crimes in order to cover his involvement with

a forger.

Additionally, Berg is trying to confuse this court and perpetrate his fraud further by making ambiguous

statements. P5 of the Appellees brief Liberi has not been convicted in, nor charged in, ten (10) separate

criminal cases. At first glance it might look like she is an innocent woman, who was defamed. In reality Berg

is simply twisting the truth and the facts. As the Appendix (Appellants Appendix Liberis mug shot andcriminal record) shows, in 2008 a plea bargain was reached, where she was convicted of 10 felony counts out

of 23 charges against her in CA. Berg is saying that she was not convicted in 10 separate criminal cases,

creating an illusion that she was defamed, but it simply means, that there were 10 felony convictions within 1

case in CA. Docket document #136, also includes a transcript of a prior hearing in CA, where Detective

Liebricht testified regarding Liberis prior 19 criminal charges, mostly in TX.

Berg states, that Liberis middle name is not Renee, trying to put doubt in the minds of the Judges, to make

them believe, that she is a different person. In reality, the same criminal record shows that Liberi used 9

different aliases, where she used her prior married name Courville or maiden name Richardson or short for

Richardson- Rich or combination thereof as a middle name instead of her middle name Renee, sometimes

she used only letter R. Berg is trying to create an illusion of Liberi being a different person, while he knowsthat she is indeed the same person, who was convicted in CA, and who is not allowed to reside in PA, he is

continuously and egregiously violating the requirement of candor before the tribunal and continuously and

repeatedly is defrauding the court. On the other hand

Defendants/ Appellants provided witness identification (Appendix to the opening brief, Affidavits of Ed Hale

and Caren Hale), stating that Lisa Liberi, who appeared in PA before judge Robreno, is indeed the same Lisa

Liberi, who is shown on the attached mug shots of Lisa Liberi, convicted in CA.

.Appellants, provided transcripts from CA, showing that Liberis mother, Shirley Waddell, who was filing

hundreds of pages of affidavits in PA in Liberi v Taitz, in support of her daughters legal action for defamation

and slander, claiming that her daughter is an innocent woman who was defamed and slandered by thismonster Attorney Orly Taitz, was actually the same Shirley Waddell, who paid bail bond premium to bail her

daughter out of prison in CA. (Appendix to Appellants opening brief, 2004 Superior Court of CA, San

Bernardino County transcript of the bail bond hearing of Lisa Liberi). Additionally, Taitz provided signature

samples from CA, showing that the same signature was used by Liberi to sign her motions in her criminal case

in CA. (Document 145, reply to opposition to Motion). Considering the fact, that Liberis state citizenship is

at the core of the case, the court had a heightened obligation to make sure that the Appellees provide Liberis

drivers license and prove her state citizenship. The court erred in not demanding such compliance and in

ignoring all the evidence, provided by the defendants.

D. APPELLEES COMMITTED FRAUD ON THE COURT AND PERJURY BY CLAIMING THATTHEY PROVIDED LIBERIS DRIVERS LICENSE TO JUDGE ROBRENO

a. In his response attorney Berg claims that he showed Judge Robreno Liberis Drivers license, that Judge

Robrenos decision to assume jurisdiction is based on the drivers license, submitted to court on 08.07.09.

This statement constitutes fraud on this court. Transcript of 08.07.09 hearing states, that Berg asked Judge

Robreno, if he can provide Liberis license under seal, however the transcript does not state, that Berg

actually ever provided it.

b. Examination of the transcript shows, that there are no documents attached to it at all. There is no license


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under seal or not under seal. There is no notation from a court reporter, stating, that any documents were

given by Liberi or Berg to judge Robreno, there is only a promise by Liberi to provide her identifying

documents at some later time.

c. Affidavit of Ed Hale (Appellants appendix) states, that the plaintiffs did not provide Judge Robreno with

any documents and that they left the court room the same time as the defendants. He also states, that Lisa

Liberi, who appeared at the hearing in PA in front of Judge Robreno, is the same Lisa Liberi, as depicted on

the mug shot from CA.

d. . Affidavit of Caren Hale (Appellants appendix) states, that the plaintiffs did not provide Judge Robreno

with any documents and that they left the court room the same time as the defendants. He also states, that

Lisa Liberi, who appeared at the hearing in PA in front of Judge Robreno, is the same Lisa Liberi, as depicted

on the mug shot from CA

e. If arguendo Berg, who is a PA attorney, went to Judge Robreno at some later time and showed him some

document, some drivers license, it would be an impermissible ex-parte communication and it violated the

rights of the defendants for an impartial hearing, particularly in light of the fact that Lisa Liberi has multiple

convictions for forgery of documents, and it is more likely than not that if Berg ever showed any document to

judge Robreno, it was a forged document. The defendants were entitled to see any documents provided by

Berg to Judge Robreno, examine those documents and make sure those documents were not forged. Asstated, there are no identifying documents anywhere on the docket. Berg, also, refers to statements by Kelly

Strebel, who is an unemployed truck driver in Utah and Evelyn Adams, aka Momma E, a retiree in OK, who

are claiming, that Liberi does not reside in CA or TX. No foundation was ever provided, as to how do they

know, where Liberi resides. Anybody can state anything. Their statements do not satisfy the best evidence

rule. Adams is a party to this action, Strebel is Liberis and Bergs supporter and volunteer. State residence

needs to be established by proper identifying documents such as a drivers license. Judge Robreno requested it

during 08.07.09 hearing, Liberi and Berg promised to submit it and file under seal, but never submitted it.

There are no identifying documents anywhere in the file of this case, therefore the case has to be dismissed,

as Liberis state citizenship was never established.

E. APPELLEES DISCUSSION OF VENUE IS IRRELEVANT AND WAS DONE IN ORDER TOCREATE CONFUSION, AS AT ISSUE IS THE FACT, THAT THERE WAS NO JURISDICTION FOR

FEDERAL COURT TO SIT IN DIVERSITY, REGARDLESS OF VENUE

Berg is trying to simply confuse this court by discussing venue. The venue is not at issue. Before venue is

discussed, at issue is jurisdiction. Did the federal court have any jurisdiction to sit in diversity and hear this

case. For purpose of diversity the plaintiffs had to provide evidence of citizenship of each and every party

and show it by preponderance of evidence. The Plaintiffs did not provide one single document, that it

evidentiary of Plaintiff Liberis state citizenship. The docket shows no evidence: there is no Pennsylvania

drivers license anywhere in this docket. In order to cover up the fact, that there is no drivers license,

plaintiffs made up outrageous slanderous accusations and committed fraud on the court and perjury by

accusing defendant Taitz of trying to hire a hit man to kill Liberi. This is an outrageous behavior by alicensed attorney Berg. Taitz filed a separate motion to sanction attorney Berg for filing with court

accusations of capital crimes with the sole purpose of harassment of defendants. As no evidence of state

residence was ever provided, venue is irrelevant. the federal court system has no jurisdiction over this case

regardless of venue.

F. PUBLIC POLICY CONSIDERATIONS

This issue is so important, that it has to be decided by the court of Appeals and even Supreme Court, if need


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be. It is simply insane to believe, that a criminal can make up a story, harass whistle blowers with a frivolous

law suit, make up outrageous allegations, that the victims are threatening this criminal , that any and all

evidence needs to be sealed because of an imaginary accusation, and based upon that, a judge makes a

decision without any shred of evidence. If this standard is allowed to stand, than it is de facto the end to the

system of Justice. It means, that any time anyone can accuse anybody of crimes and demand that the court

make a finding of fact based on such insane allegations of imaginary threats. Additionally, in this case Berg

has filed multiple motions, seeking a temporary restraining order to keep the case sealed. All of such motions

were denied by both the District court and the Third Circuit Court of Appeals. If the courts did not find any

value in Appellees claims of threats, than it was an error for Judge Robreno not to demand Lisa Liberis PAdrivers license and not to provide it to the defendants in order to show Liberis citizenship for the purposes of

diversity.

G. APPELLEES ARE MISREPRESENTING THE ISSUES ON APPEAL IN RELATION TO THEDISMISSAL OF THE DEFENDANTS JAMES SUNDQUIST AND SALT ROCK PUBLISING.

James Sundquist in his pleadings and during 06.25.09 hearing before Judge Robreno repeatedly demanded to

have his motion to dismiss to be decided with prejudice. Both Appellants, who are CA residents, and James

Sundquist, NJ resident, in their pleadings and during the hearing requested for the court to ascertain the

residency of each party and to rule with prejudice. Judge Robreno never demanded proof of Liberis PA

residence and refused to rule with prejudice. Instead, during the hearing, he repeatedly applied pressure onJames Sundquist to agree to be dismissed without prejudice. Defendants already incurred expenses in

preparing responsive pleadings and traveling to PA. If Judge Robreno were to demand proof of Liberis state

residence on June 25, 2009, the case would have ended then and there, as Liberi and Berg had nothing to

show. Instead, Judge Robreno dismissed James Sundquist without prejudice and left him unable to collect

from Berg and plaintiffs and he left Sundquist exposed to further harassment form Berg, if Sundquist were to

speak up the truth about Berg and Liberi. Additionally, Judge Robreno allowed Berg to continuously terrorize

all of the defendants with slander by the Plaintiffs and Berg for a year and a half. The Appeal does not state

that judge Robreno had no discretion, it stated, that he acted with bias in favor of local attorney Berg and his

clients, even though Berg and his clients were clearly committing fraud on the court and perjury, the Appeal

states that judge Robreno abused his judicial discretion. Dismissal of Sundquist is part and parcel of the

issue of diversity, that was brought back by Judge Robreno after he lifted his order of suspension onJune 4, 2010. Additionally, Taitz was waiting resolution of Bergs appeal, which he filed in August of 2009

with the Third Cicuit Court of Appeals and which he withdrew only in April of 2010, after an order to show

cause was issued by the Third Circuit Court of Appeals, and she was subject to order of suspension of the

case imposed by judge Robreno on 12.11.09 and lifted only on 06.04.10. Therefore, her appeal was timely

and proper.

Appellees made another fraudulent statement, claiming, that James Sundquist did not respond in writing.

Docket entry No 68 clearly shows, that on 06.24.09 James Sundquist together with Taitz filed a response in

opposition to Plaintiffs ex Parte motion to leave to dismiss, to drop defendants James Sundquist and

Rock Salt Publishing without prejudice. This is only one very vivid example, demonstrating how attorney

Berg continuously commits fraud on the court and simply enters in his pleadings fraudulent statements.

H. FRAUD ON THE COURT BY BERG AND LIBERI COMMITTED, AS NO IDENTIFICATION

DOCUMENTS WERE PROVIDED.

In their 11. 07.10 pleadings Appellees stated, that they simply showed judge Robreno Liberis drivers license

and the finding that Liberi is a resident of PA was made based on the fact, that Liberi and her attorney Berg

showed her drivers license during the hearing. This is a complete fraud on the court and is contradicted by

sworn affidavits of ED and Caren Hale and by the transcript itself. The transcript on page 19

Mr. Berg: her actual address I think would be detrimental


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The Court: Well, the actual address we could do without it.

Mr. Berg: Okay. could that be on other people, too, or just on Miss Liberi?

The court: Well you could disclose it and file it with the court under seal.

on page 47 of the transcript of the same hearing during direct examination of Liberi by Berg:

Q. You heard my statement before. You will supply your correct address and identifying information whichwe will give the court under seal, is that correct?

A Yes, sir.

So both the sworn affidavits of Ed and Caren Hale and the transcript of the hearing show, that Liberi and

Berg did not show Judge Robreno any documents during the hearing. They both stated, that at some later time

they would provide Liberis identifying information under seal, however the transcript and the docket

(Appellants appendix) do not show any identifying information ever provided to the court, neither with the

transcript, nor at any time later. Berg and Liberi simply defrauded the court. They wanted her information

hidden, as they knew, that she was not residing in PA and this whole lawsuit was filed with the sole purpose to

harass. Judge Robreno denied Bergs motion for temporary restraining order. Berg appealed to the Third

Circuit Court of Appeals and filed multiple emergency motions and requests for judicial notices. All were

denied by this court. The Third Circuit court of Appeals issued an order to show cause to Berg, why he did

not provide the copy of the transcript of the above hearing, that he was appealing. Berg knew, that his fraud

on the court is about to be discovered, the Third Circuit Court of Appeals will see, that Berg and Liberi

promised to file Liberis identifying documents, but never did it, so Berg abruptly withdrew his appeal of the

08.07.09 ruling. He demanded to transfer the case to CA. By that time, it was a year since the case was

originally filed, and ten months since 08.07.09 hearing, there were thousands of pages filed by Berg, so quite

possibly Judge Robreno did not remember or did not notice, that Berg never filed Liberis identifying papers,

so Judge Robreno issued an order to sever and transfer the case and noticed in his memorandum, that Liberi is

a resident of PA, probably believing that Berg was telling the truth and at some point filed the documents,

which of course was never done. At that point Taitz filed an appeal, as she knew, that no identifying

documents were ever filed. On 09.04.10. Taitz filed a motion with Judge Robreno Motion-request for

missing documents. Taitz was specifically asking for Liberis identifying documents. On 10.29.10 Judge

Robreno issued an order That all future motions need to be addressed to the Third Circuit. Request for

missing documents was denied without prejudice. As such the transcript and the docket clearly show, that

Berg and Liberi were supposed to supply Liberis correct address and identifying information and provide it

to the court under seal, however they never did it. They defrauded the District Court and the Third Circuit

court of Appeals. They wasted hours and hours of time of two courts, they inflicted enormous financial

damage and enormous emotional distress, however, they knew full well, that they never provided any

identifying information. They acted in an egregious manner, accusing numerous innocent individuals of

multiple serious crimes, they caused an elderly individual Ed Hale to suffer a heart attack and they brought

many others to the brink of a heart attack, yet they knew all along, that they are committing an egregiousfraud.

This is the reason, why the Defendants/Appellants are asking not only for a dismissal of the case, but also for

severe sanctions against the plaintiffs and Attorney Berg.

I. JUDGE ROBRENOS FINDINGS WENT TO THE CORE OF THE CASE AND WERE IMPROPER

TO BE MADE WITHOUT THE EVIDENCE

As stated previously, the core of the case, is Liberis claim, that she is a different Liberi, not one convicted in

CA, but one residing in PA. When Judge Robreno included in his 06.04.10 order and memorandum a


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36/51

conduct even a minimally reasonable inquiry before filing his complaint. Granting summary judgment infavor of Carpenters Health, Joyner said he found it wholly unnecessary even to consider the facts of the

ERISA case because it was abundantly clear that Carpenters Health was entitled to a judgment as a matterof law. Joyner invited Carpenters Health to file a motion for Rule 11 sanctions. When it did, Joyner found thatBerg continued his trend of unprofessional conduct Bergs fraud claim, Joyner said, was inadequatelypled, not grounded in fact, time-barred, and utterly irrelevant to the pending malpractice action against

him.In his sanctions order, Joyner ordered Berg to reimburse Carpenters Health the $10,668 in attorneyfees and costs it incurred in defending the claim. He also ordered Berg to complete six credits of ethics

courses certified by the Pennsylvania Board of Continuing Legal Education, and recommended that Berg beinvestigated by the Pennsylvania Bar Associations Committee on Legal Ethics and ProfessionalResponsibility.

At the same time, in 2005-2006, when Liberi was incarcerated, she filed a frivolous RICO law suit for $280million against the San Bernardino County, CA, West Valley Correctional facility, district attorneys, policeofficers, police detectives, numerous law enforcement officials Lisa Liberi v West Valley Center et al 2:05-cv-03015-VAP-SGL. In a similar modus operandi she accused multiple innocent individuals of committing

crimes. Her legal action was dismissed. Both Liberi and Berg have a history and modus operandi of filingmultimillion dollar law suits for the sole purpose of harassment. They caused immeasurable financial and

emotional damage to the defendants and they need to be stopped now. This court has inherent powers to

punish egregious misconduct by an attorney and Appellees. Dismissal of underlying legal action, sanctions,award of attorneys fees and costs to the Appellants are appropriate. Sanctions in the form of reporting PhilipJ Berg to the Disciplinary Board of the PA Supreme Court for sanctions or disbarment, as well as reporting of

Lisa Liberi to the San Bernardino, CA probation department for revocation of her probation and her returnto incarceration to serve her eight year prison term, will be appropriate in this case.

CONCLUSION

Appellees never provided any proof of Appellee Liberis PA state residency that they claim, that she had. TheCourt erred, and abused its judicial discretion in assuming jurisdiction over the case without any evidence ofState Citizenship of Plaintiff Liberi. The Court also erred in refusing James Sundquist opposition-motion.

Court erred in completely ignoring multiple letters fromDefendant Belcher, where she stated, that she was not served with pleadings by the Plaintiffs.

As the State citizenship of the lead Plaintiff was never established by the court, the District Court had no

jurisdiction in diversity and the case needs to be dismissed due to lack of subject matter jurisdiction.

DATED: November 21, 2010

__/s/ Dr. Orly Taitz, ESQ_______

Dr. Orly Taitz, ESQ Appellant in Pro Se and asCounsel for Appellant Defend Our Freedoms Foundation

ATTORNEYS CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the:

APPELLANTS REPLY

was served by ECF and ELECTRONIC MAIL on November 22,, 2010, on the following parties:


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Neil Sankey

The Sankey Firm, Inc. a/k/a The Sankey Firm

Sankey Investigations, Inc.

2470 Stearns Street #162

Simi Valley, CA 93063

Phone: (805) 520_3151and (818) 366_0919

Cell Phone: (818) 212_7615

FAX: (805) 520_5804 and (818) 366_1491

Email: [email protected]

Linda Sue Belcher

201 Paris

Castroville, Texas 78009

Home Phone: (830) 538_6395

Cell Phone: (830) 931_1781

Email: [email protected] and

Email: [email protected]

Ed Hale

Caren Hale

Plains Radio

KPRN

Bar H Farms

1401 Bowie Street

Wellington, Texas 79095

Phone: (806) 447_0010 and (806) 447_0270Email: [email protected] and

Email: [email protected] and [email protected]

Philip Berg, Esq.

Lisa Liberi c/o Law Office of Philip Berg


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555 Andorra Glen Court, Suite 12

Lafayette Hill, PA 19444_2531

(610) 825_3134

FAX (610) 834_7659

E_Mail: [email protected]

Disciplinary Board

Supreme Court of Pensylvania

820 Adams Ave, ste 170

Trooper, PA 19403

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

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

Public Integrity Section


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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/ Dr. Orly Taitz, ESQ

___________________________

Dr. Orly Taitz, Esq

11.22.10

Category:Uncategorized

Comments

One Response to Submitted yesterday in the Third Circuit Court of Appeals

F.A. Leonetti

November 23rd, 2010 @ 10:46 am

Some may find this a bit off the wall, but I enjoy reading legal briefs, and quite frankly, this rates and

1.


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EXHIBIT 95



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VIDEOS

Home






THERE IS TYRANNY.


THERE IS LIBERTY.

- Thomas Jefferson



In spite of nearly 500 pages of horrific defamation

of my character by Philip J. Berg, Lisa Liberi, her

mother Dorothy Waddell and the rest of theiraccomplices, Third Circuit Court of Appeals denied

their motion for restraining order against me. I am

free to post this truthful information, showing that

Lisa Liberi, assistant for attorney Philip J. Berg, is

te of nearly 500 pages of horrific defamation of my character by Phil... http://www.orlytaitzesq.com/?


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a convicted document forger and thief, who got 8

year prison term in CA in 2008, and who is

currently on probation. The question remains: why

is licensed attorney Berg continuously working with

a convicted forger Liberi and submitting

documents to multiple courts ans viciously

attacking me and other innocent individuals?

Posted on | December 12, 2010 | 3 Comments


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Case FWV028000 Defendants

Seq Defendant Next Court Date Status Agency /

DR Number

Arrest Date Count 1 Charge Violation Date

1 LIBERI , LISA RRA

11001375905/18/2001 PC 115(A) 05/18/2001

ALIAS: LIBERI, LISA R

ALIAS: COURVILLERICHARDSON, LISAALIAS: LIBERI, LISA A

ALIAS: RICHARDSON, LISA C

ALIAS: COURVILLERICH, LISA

ALIAS: LIBERI, LISA RENEE

ALIAS: LIBERI, LISA

ALIAS: RICHARDSON, LISA RENEE

Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE Status

Custody N/AFiling Type Held to Answer Filing Date 05/09/2003

Ordered Bail$0.00 Posted Bail $0.00

D.A. James R. Secord Defense Dean Pitcl (Court Appointed)

Next Action: Deputy Report #: RA-RC 110013759

Warrant Type Status Issued Affidavit

NONE N/A N/A

ProbationType Granted ExpirationFormal 03/21/2008 03/21/2011

Sentence Convicted Date County Jail CTS

01/25/2008 26 Days 26 Days

State Prison Max Sentence

N/A N/A

Fine and Penalty Restitution Fine Restitution to Victim

0 N/A

Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE Charges

Arrest Charges


DatePlea Status

1 PC 459 F BURGLARY 05/18/2001

Filed Charges


DatePlea Status


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7 PC 476 FMAKING, POSSESSING, UTTERINGFICTIOUS INSTRS



9 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 GUILTY CONVICTED



11 PC 487(A) FGRAND THEFT: PROPERTY/ETC

OVER $40005/18/2001 GUILTY CONVICTED

12 PC 487(A) FGRAND THEFT: PROPERTY/ETCOVER $400


13PC

487(D)(1)F

GRAND THEFT:

AUTOMOBILE/ANIMAL/ETC05/18/2001 DISMISSED



15PC

487(D)(1)F

GRAND THEFT:

AUTOMOBILE/ANIMAL/ETC05/18/2001 DISMISSED


OVER $40005/18/2001 DISMISSED

17PC487(D)(1)




OVER $40005/18/2001 GUILTY CONVICTED




INSTRUMENT TO FILE05/18/2001 GUILTY CONVICTED




Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE Probation

Probation Type: FORMAL Granted: 03/21/2008 Expire: 03/21/2011

SUPERVISED PROBATION GRANTED FOR A PERIOD OF 36 MONTHS ON FOLLOWING TERMSAND CONDITIONS:

1)

SERVE 26 DAYS IN A SAN BERNARDINO COUNTY JAIL FACILITY, WITH CREDIT FOR

TIME SERVED, A MATTER OF 26 DAYS, PLUS CONDUCT CREDIT PURSUANT TO1-PC4019 ND ABIDE BY ALL RULES AND REGULATIONS OF THE FACILITY WITHOUT

THE POSSIBILITY OF COUNTY PAROLE.

2) VIOLATE NO LAW.

3)

REPORT TO THE PROB OFFICER IN PERSON IMMEDIATELY 0- ND THEREAFTER ONCEEVERY FOURTEEN (14) DAYS OR AS DIRECTED. REPORT TO THE PROB OFFICER IN

PERSON IMMEDIATELY 0- ND THEREAFTER ONCE EVERY FOURTEEN (14) DAYS ORAS DIRECTED.


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4)COOPERATE WITH THE PROBATION OFFICER IN A PLAN OF REHABILITATION ANDFOLLOW ALL REASONABLE DIRECTIVES OF THE PROBATION OFFICER.

5)SEEK AND MAINTAIN GAINFUL EMPLOYMENT, OR ATTEND SCHOOL, AND KEEP THE

PROBATION OFFICER INFORMED OF STATUS OF EMPLOYMENT, OR SCHOOL.

6)

KEEP THE PROBATION OFFICER INFORMED OF PLACE OF RESIDENCE ANDCOHABITANTS AND GIVE WRITTEN NOTICE TO THE PROBATION OFFICER

TWENTY-FOUR (24) HOURS PRIOR TO ANY CHANGES. PRIOR TO ANY MOVE PROVIDEWRITTEN AUTHORIZATION TO THE POST OFFICE TO FORWARD MAIL TO THE NEWADDRESS. PERMIT VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGENTS OFTHE PROBATION DEPT. AND/OR LAW ENFORCEMENT FOR THE PURPOSE OF

ENSURING COMPLIANCE WITH PERMIT VISITS AND SEARCHES OF PLACES OFRESIDENCE BY AGENTS OF THE PROBATION DEPT. AND/OR LAW ENFORCEMENT

FOR THE PURPOSE OF ENSURING COMPLIANCE WITH PERMIT VISITS ANDSEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THE PROBATION DEPT.AND/OR LAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCE WITHTHE TERMS AND CONDITIONS OF PROBATION; NOT DO ANYTHING TO INTERFERE

WITH THIS REQUIREMENT, OR DETER OFFICERS FROM FULFILLING THISREQUIREMENT, SUCH AS THE TERMS AND CONDITIONS OF PROBATION; NOT DO

ANYTHING TO INTERFERE WITH THIS REQUIREMENT, OR DETER OFFICERS FROMFULFILLING THIS REQUIREMENT, SUCH AS ERECTING ANY LOCKED FENCES/GATESTHAT WOULD DENY ACCESS TO PROBATION OFFICE

Documents

LIBERI v TAITZ (C.D. CA) - 190.18 - Plaintiffs Exhibits 91-95 to Amended Complaint.190.18