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EXHIBIT “113Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 1 of 37 Page ID #:5339

LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

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8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

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EXHIBIT “113”

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 1 of 37 Page ID#:5339

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 2/37

Exhibit "113"

Pg. 815

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 2 of 37 Page ID#:5340

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

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VIDEOSHome

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.

More on ex-attorney, who goes by pseudonim

“Foggy”, who has been organizing vicious attacks

on mePosted on | January 29, 2011 | 10 Comments

I redacted the name of the person, whosent these links to me.

Re: this article…

http://blogs.ocweekly.com/navelgazing/2011/01/obama_orly_taitz_birther_foggy.phpFoggy is this person (100% sure):

http://members.calbar.ca.gov/search/member_detail.aspx?x=117084

on ex-attorney, who goes by pseudonim “Foggy”, who has been orga... http://www.orlytaitzesq.com/?

http://www.orlytaitzesq.com/?p=18459

5/2/2011

Exhibit "113"

Pg. 816

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 3 of 37 Page ID#:5341

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 4/37

Here is a link to the CA bar with information on William Littel Bryan, who used to be licensed as an attorneyin Ca. As you can see, he was suspended from the bar several times and finally he resigned amid charges

of abandoning clients, drug addiction and maniac depressive psychiatric disorder.If you recall, I wrote on my site that this man Foggy must be suffering from a psychiatric disorder. He is aleftist, he has a psychiatric disorder and at least in the past he had a drug addiction. He hates me, because heis an Obama lover, I exposed ObamaFraudGate. He might be angry and maybe jealous because he was

suspended by the bar several times and finally had to resign.By the way, he wrote that once he came to my office. I checked the database. Indeed between 1995-1998 a

 person with this first , last name and the same year of birth as listed on the bar complaint against William(Bill) Bryan came to my office for limited dental treatment, but I don’t remember him at all. I have 29,000 patient charts in my office, I had my practice for 22 years since 1989, I don’t remember him at all.This Fogbow character bragged that he filed complaints against me with CA bar. He also bragged that he

incited Phil Berg to file his frivolous law suit against me. When I found out and made public that Berg’sassistant Liberi is a document forger, convicted in CA, Berg claimed that she is a different person, residing inPA. It looks like this Foggy baited Berg to file a law suit and prove what he says. Berg thought that he canintimidate me with a law suit. Now Liberi admitted that she is indeed a convicted felon, she admitted on thestand that she was convicted in 2008 in CA. Now PA disciplinary board is investigating Berg. CA DA and

Probation department are investigating Liberi and her actions.Bottom line, people like Foggy might be dangerous. Patriots, who are seeking transparency in the

government, are not dangerous. One good thing is that it was reported by several people, that Foggy now livesin Raleigh NC, he owns a flower shop there, I don’t believe he will be back in Ca. If someone is trying to usehim as a patsy, be advised that I know that he is not here now.I would advise attorneys, who are members of his web site FogBow to disassociate themselves from this

 person. He clearly has problems, and they will end up with problems from this association. It does not reflectwell on licensed attorneys.I noticed that most of the people, who are attacking me, are either disbarred as attorneys and they areangry, or they are convicted felons. I already identified four document forgers, some have psychiatricdisorders. This gives you an idea, who Obama supporters are, why are they attacking law abidding citizens.One person, who viciously attacked me, is still licensed as an attorney. His name is Scott J. Tepper. He has an

office in Santa Monica. He is a big Obama supporter and I saw that he gave Obama some $2,000 donation to

his campaign. I am not sure, why he is so vicious against me. Maybe, he is paid. A number of people believethat he posts under the name Sternguard (something like that). I am not sure. Can anyone find out if he was paid to attack me? Why is he so vicious against me? Can someone check under what name he posts. From

what I understand, he posted on Politijab and Fogbow.Yet another question, I am trying to answer, is who paid this insane artist Dan Lacy to pay inappropriate

 paintings of me. He admitted that he was paid, but I don’t know by whom.I, also, wanted to know if someone paid this comi rag OC Weekly to write nasty articles about me, photo-shopmy picture to make me unrecognizable. I saw that a guy, who started this insanity, Spencer Kornhaber, nolonger writes his nasty article, but they found another brainwashed jerk. I wrote to heir editor Mr. Moxley,

and asked to provide truthful info, but he never wrote any truthful info.Bottom line, ObamaFraudGate is unraveling. Now 11 states are changing their laws in order to stop Obama

run in 2012. We are getting closer in FOIAs, in different actions against different governmental agencies.More Constitutionalist congressmen are organizing. I am confident that sooner or later all of the players inObamaFraudGate not only will lose their office, but they will be criminally prosecuted for their role in thismassive fraud and treason for their part in aiding and abetting this fraud and treason by attacking attorneys,

who brought ObamaFraudgate to courts and demanded answers.PS Does anyone know if Siddharth Velamoor is still working as a clerk for Judge Carter? If not, where is he

now, what is he doing. Is this other clerk Nicole still there? There was a report of Gov Abercrombie making payments (I believe a total was around $67,000) to Obama’s Law Firm, Perkins Coie. He made payments totheir Seattle Wash office, where Velamoor used to work. Why did Abercrombie, who was a U.S. rep from HIat a time need to hire a firm in Seattle WA. Typically you would expect him to work with a law firm in Hi or 

on ex-attorney, who goes by pseudonim “Foggy”, who has been orga... http://www.orlytaitzesq.com/?

5/2/2011Exhibit "113"Pg. 817

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 4 of 37 Page ID#:5342

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 5/37

DC.If you have answer, write to me to [email protected] 

Category: Uncategorized

Comments

10 Responses to “More on ex-attorney, who goes by pseudonim “Foggy”, who has been organizing vicious

attacks on me”

 jcm52

January 29th, 2011 @ 8:03 am

Seriously? You’re actually telling people the name of someone who came to your dental practice?

As a lawyer, surely you realize that is illegal?

1.

Politijabber January 29th, 2011 @ 9:24 am

You better be damn sure.

2.

Politijabber January 29th, 2011 @ 9:30 am

From the Bar’s website:

CAUTION!!

 Nearly 161,090 attorneys are eligible to practice law in California. Many attorneys share the same

names.

3.

meJanuary 29th, 2011 @ 12:55 pm

Is this the same Bill Bryan aka PJFoggy that claims that he took down GretaWire’s forum with his ugly

and racist hatebaiting foul postings along with his alter ego Rikker?

4.

[email protected] 29th, 2011 @ 1:50 pm

I don’t know if rikker and foggy is the same

5.

Me

January 29th, 2011 @ 2:40 pm

Foggy is Foggy, and not riker, to my knowledge. Foggy is more foul than you could possibly imagine. Ihave info that would drive any “Christian” patrons at his flower shop away for good. I wonder how he

might feel about that.

6.

[email protected] 29th, 2011 @ 5:03 pm

7.

on ex-attorney, who goes by pseudonim “Foggy”, who has been orga... http://www.orlytaitzesq.com/?

5/2/2011

Exhibit "113"

Pg. 818

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 5 of 37 Page ID#:5343

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

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EXHIBIT “114”

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 6 of 37 Page ID#:5344

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

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Exhibit "114"

Pg. 819

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 7 of 37 Page ID#:5345

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 8/37

VIDEOS

Home

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.

I need your help in identifying IP addresses of the

employees of the federal and state government, who

engaged in slander, obstruction of justice,tampering with evidence

Posted on | January 30, 2011 | 3 Comments

Itchik 

Submitted on 2011/01/30 at 9:19am

Sounds more to me like she is full of s#!t. Apparently she is NOT aware of the

law. If she were, she would know that if she chooses to slander or threaten

I need your help in

identifying a thug

going by pseudonim

“Butterfly

d your help in identifying IP addresses of the employees of the federal... http://www.orlytaitzesq.com/?

http://www.orlytaitzesq.com/?p=18523

5/2/2011

Exhibit "114"

Pg. 820

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 8 of 37 Page ID#:5346

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 9/37

another person, that person has the right to identify him/her and make that

information public. I would bet my career that IF she is working with an agency

that allows her to use a pseudonym for personal safety, the policy also states

that abusing this privilege to gain anonymity in personal attacks or slander 

would be a terminable offense and most probably a criminal offense. I would

also be interested to know if his/her email(s) originated from company

computers. Also a terminable offense.

Comment from Orly

I need your help in identifying attorneys, judges, court reporters and other 

employees of the Federal and state government, who engaged in obstruction of 

 justice and slander and derailing my cases.

I am still waiting for a decision from the 9th circuit court of appeals on my case

of Barnett, Keyes et al v Obama et al. There was an undue influence there. One

of Obama’s defense attorneys was allowed to take over as an attorney- law

clerk on the case. All of my complaints about it were ignored by judge Carter.

Despicable slander was included in the final order. When I demanded to strike it

from the record or have a hearing on the matter, he ignored it it yet again. It wasa clear case of judicial misconduct.

These attorneys from Politijab and Facebow gloated that they used their contact

in GA to destroy my cases there. I need to know the names of these attorneys

and the names of their contacts and have them all criminally prosecuted. Maybe

we can get one to start talking in exchange for immunity.

In PA in Judge Robreno’s court room repeatedly documents provided by me

were not docketed. Court Reporter Dona Anders removed from the certified

transcript the whole cross examination of Lisa Ostella, which was incriminating

to Ostella, Liberi and Berg and which should have Berg disbarred and all threeof them criminally prosecuted. I need help in investigation, who told this court

reporter to remove the whole cross examination from the certified transcript

and to neatly arrange the examination of the next witness, so as to create an

appearance that there was no cross examination at al. This looks like

obstruction of justice done by the court itself. I forwarded complaints and

demand for investigation to the judiciary committee of Congress, public

integrity unit, inspector general, Chief Judge of that district and the chief judge

of the circuit, as well as the judicial conduct board.

Recently a judge in Ohio was criminally indicted for knowingly accepting

 perjured testimony of an informant. If it was done in Ohio, it can be done inother jurisdictions as well. We need prosecution of what is going on in different

courts: from district courts to the Supreme Court. We need everyone involved

 being held accountable. we are seeing an enormous corruption in the

government and courts. People all over the World are rising against the

corruption. It is time for us to rise against the corruption of our government and

corruption in our courts.

Bilderberg” and

demanding action by

her superiors in

terminating her 

employment

Category: Uncategorized

Comments

d your help in identifying IP addresses of the employees of the federal... http://www.orlytaitzesq.com/?

5/2/2011

Exhibit "114"

Pg. 821

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 9 of 37 Page ID#:5347

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 10/37

EXHIBIT “115”

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 10 of 37 Page ID#:5348

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 11/37

Exhibit "115"Pg. 822

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 11 of 37 Page ID#:5349

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 12/37

VIDEOS

Home

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.

A good conversation with a former member of 

Fogbow

Posted on | February 1, 2011 | 16 CommentsI got a phone call from an attorney, Theresa Lalogia Rowlin, who used to post on Fogbow. She no longer is a

member of that forum. She stated that her comments before were on the issues and that she does not feel

animosity to anyone on this forum. She stated that a woman by name Patricia, who said that she saw her at

one of my hearings is wrong, that she did not attend any hearings.

She stated that she does not agree with inflammatory and defamatory and inappropriate comments made by

some. She also stated, that though she is a Democrat and not a Republican, and though she supported Obama

during the election, she believes in clean elections and she has nothing against a bill, requiring candidates to

 provide a certified copy of their original birth certificate. She, also, shares my concern regarding electronic

d conversation with a former member of Fogbow | Dr. Orly Taitz Es... http://www.orlytaitzesq.com/?

http://www.orlytaitzesq.com/?p=18607

5/2/2011

Exhibit "115"

Pg. 823

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 12 of 37 Page ID#:5350

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

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 ballot counting machines and believes in paper ballots.

I have to say that all in all it was a peaceful and a non-confrontational conversation. I hope that other 

members of Fogbow and Politijab, particularly attorneys will follow her example. Unless people are paid to

attack, there is no reason to attack, unless someone is paid to obstruct justice and hide evidence, there is no

reason to do it. A lot of damage was done to me and to my family and my children. Nasty letters were sent to

 people I work with, to my husbands co-workers and clients. This has to end. Scott J. Tepper, William Bryan,

Rae Diane Shirer and other attorneys or former attorneys should let go. If I will be wrong in my legal actions,

so be it. If I succeed, so be it. At the end truth comes out. We saw this with Berg and Liberi and Ostella.

Originally they filed their frivolous action, but at the end Liberi admitted on the stand that she is a convictedfelon from CA, Ostella admitted that she locked me out from the web site of my foundation and replaced my

 paypal account with her own. The judge issued an order, saying there was no basis for any of their allegations

and all of them were evasive on the stand and not believable as witnesses. Berg is facing a disciplinary

hearing, so bottom line, there is no reason for attacks, nothing good comes out of it. So, I am calling on all

attorneys from those web sites: Politijab and Fogbow to join me, get to the truth, let’s get Obama’s papers,

let’s resolve in a court of law the issue of the meaning of the “Natural Born citizen” and let have a clean

election with paper ballots and real transparency next time.

Category: Uncategorized

Comments

16 Responses to “A good conversation with a former member of Fogbow”

Redd

February 1st, 2011 @ 1:27 pm

Those sites, politijabo and fagbow are communist group think sites. Now that they have been exposed,

they are becoming civil??? bwahahhahahahaha!!!!!!!!!!!!

1.

Politijabber 

February 1st, 2011 @ 1:34 pm

You are such a fucking LIAR. You received no call from the real Tes because she does not hold those

 beliefs. She is one of my best friends, so I know that she did NOT call you.

2.

Itchik 

February 1st, 2011 @ 2:15 pm

Very good, Orly. Good for you being able to rise above this. You are correct; what is wrong with getting

to the truth? Let’s see the papers. Anybody with ANY integrity would want this. The ONLY reason

anybody would be against discovery is that they have something to hide. It’s that simple. This is NOT

an issue of privacy. The people have the right to know whether or not their president is morally,intellectually and legally fit to serve.

3.

Veritas

February 1st, 2011 @ 3:59 pm

She sounds rather repentant…perhaps even some of those on the Left who cheered Obama realize that

the 2008 “victory” is his “conquest” over them as well as all Freedom Loving Americans who cherish

the Constitution!

4.

[email protected].

d conversation with a former member of Fogbow | Dr. Orly Taitz Es... http://www.orlytaitzesq.com/?

5/2/2011

Exhibit "115"

Pg. 824

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 13 of 37 Page ID#:5351

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

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EXHIBIT “116”

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 14 of 37 Page ID#:5352

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

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Exhibit "116"

Pg. 825

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 15 of 37 Page ID#:5353

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 16/37

VIDEOS

Home

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.

Docketted today

Posted on | February 2, 2011 | 4 Comments

Dr. Orly Taitz, EsqAttorney 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

etted today | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

http://www.orlytaitzesq.com/?p=18633

3 5/2/2011

Exhibit "116"

Pg. 826

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 16 of 37 Page ID#:5354

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

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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

) 59 E and 60 B motions to correct errors in 12.23.2010 ruling,

) Motion to dismiss due to lack of subject matter jurisdiction

) Motion for sanctions against the plaintiffs and plaintiffs’

attorney

Plaintiffs ) Phlip J. Berg

v. )

)

ORLY TAITZ, et al., )

Defendants. )

59 E MOTION TO AMEND OR ALTER RULING and 60 B motion

Defendants Dr. Orly Taitz ESq and Defend Our Freedoms foundation, hereinfter “Defendants” are properly

filing this 59 E motion to correct a flagrant error of fact in the 12.23.2010 order issued after 12.20.2010TRO hearing, which was instigated by the plaintiffs as well as provide new evidence, a letter from Michael

Ramos, District Attorney of San Bernardino county, California, verifying that indeed Lisa Liberi is currently

on probation, under the supervision of San Bernardino CA probation Department .

Rule 60 B Motion

Rule 60. Relief from Judgment or Order

etted today | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

3 5/2/2011

Exhibit "116"

Pg. 827

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 17 of 37 Page ID#:5355

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

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(b) Mistakes; Inadvertence; Excusable Neglect; Newly Discovered Evidence; Fraud, Etc. On motion and

upon such terms as are just, the court may relieve a party or a party’s legal representative from a final

 judgment, order, or proceeding for the following reasons: (1) mistake, inadvertence, surprise, or excusable

neglect; (2) newly discovered evidence which by due diligence could not have been discovered in time to

move for a new trial under RCFC 59(b); (3) fraud (whether heretofore denominated intrinsic or extrinsic),

misrepresentation, or other misconduct of an adverse party; (4) the judgment is void; (5) the judgment has

 been satisfied, released, or discharged, or a prior judgment upon which it is based has been reversed or 

otherwise vacated, or it is no longer equitable that the judgment should have prospective application; or (6)

any other reason justifying relief from the operation of the judgment. The motion shall be made within a

reasonable time, and for reasons (1), (2), and (3) not more than one year after the judgment, order, or  proceeding was entered or taken. A motion under this subdivision (b) does not affect the finality of a

 judgment or suspend its operation. This rule does not limit the power of a court to entertain an independent

action to relieve a party from a judgment, order, or proceeding, or to set aside a judgment for fraud upon the

court.

On 12.23. 2010 this court entered a ruling in relation to the TRO hearing held on 12.20.2010. Unfortunately

yet again without a shred of documentary evidence this court erroneously entered in its’ order a statement

“Lisa Liberi is a resident of PA” . Defendants believe that a clerk simply copied this part of the order from a

 prior order. It is possible, that the court was confused before, while making a prior order on 06.04.2010,

however at the hearing on 12.20.2010 plaintiff Liberi conceded that she is indeed a convicted felon from

California. She admited that she was convicted in 2008. Defendants repeatedly submitted to this court a

summary of Liberi’s 2008 conviction, which included 23 charges and conviction of 10 felonies of forgery,

forgery of an official seal and theft. Summary of conditions of her probation contains a condition, whereby

from March 23 2008 until March 23 2011 Liberi is allowed to reside only in Ca or with her family in NM

. Sheis not allowed to reside in PA and she never resided in PA.

In your order Your Honor stated that Liberi admitted that she was convicted in 2008 in CA. Your Honor has

also stated that it is “alleged” that she is on probation, which lead the defendant to believe that your Honor 

erroneously believes that Liberi is no longer on probation. Defendants are providing to your Honor a letter 

sent by the Probation department of the San Bernardino CA Exhibit 1 and from Mike Ramos, District

Attorney of the San Bernardino CA district Attorney’s office, stating that Lisa Liberi is indeed under 

supervision of the San Bernardino CA probation department. (Exhibit 2). While the probation department is

not ready to revoke her probation and return her to incarceration yet and investigation of her actions in thiscourt continues, it is clearly stated that she is on probation with the San Bernardino, California probation

department.

Your Honor has stated that the plaintiffs, including Liberi were evasive and not believable as witnesses on

the stand. Your honor did not find any basis for the allegations made by the plaintiffs. Similarly the claims of 

the plaintiffs of Liberi being resident of PA are not true either, as demonstrated by the letter from the San

Bernardino, California district attorneys’ office .

On the stand Liberi continued defrauding Your Honor. Liberi stated that she was convicted of tax evasion

only. In reality the summary of her convictions shows that she was convicted of 10 felonies, which included

forgery of documents and theft. Similarly, the letter sent to you and to the defendants by Co-plaintiff and

attorney for plaintiffs Berg provides an admission against interest by Berg himself, where he admits to the fact

that Liberi is a convicted felon and he admits to his knowledge of this fact. Exhibit 3. Yet again Berg

continues defrauding your honor by claiming that Liberi has only one conviction, while the official record

shows conviction of 10 felonies. Berg continues denigrating defendants and a number of attorneys, who are

 posting on the web site Fogbow.com. While Defendants have disagreements with above mentioned attorneys

from Fogbow as well, Berg’s letter was sent with malice, with intent to defraud your Honor further and to try

to silence, to intimidate any whistle blowers: both Taitz and other attorneys, reporting on the fact that Berg is

employing a convicted document forger and convicted thief Lisa Liberi and submitting to this court, as well as

etted today | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

3 5/2/2011

Exhibit "116"

Pg. 828

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 18 of 37 Page ID#:5356

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 19/37

the Third Circuit Court of Appeals and the Supreme Court of the United States documents and pleadings

 prepared by this recently convicted forger on probation.

On 08.07.2009 during yet another frivolous TRO hearing instigated by the Plaintiffs, Your Honor ordered the

Plaintiffs to file with the court a copy of Liberi’s identifying documents. Examination of the docket and

documents filed in this case shows that Liberi and Berg never complied and never filed her drivers’ license or 

any other documentary evidence of her residence in PA. Taking into consideration Liberi’s admission to

felony conviction in Ca in2008 and summary of her probation conditions, it is clear that she is not a resident

of PA.

The Defendants respectfully move this court to correct an error in the memorandum and order and delete

statement “Liberi is a resident of Pennsylvania”. Defendants move the court to make a correct

determination, that “the Plaintiffs never filed with this court any documentary evidence of Liberi’s residence

in PA or any other state and cannot maintain a legal action in diversity without providing proof of state

residence. The defendants provided the court with the documentary evidence, showing that Liberi is under 

supervision of the San Bernardino California probation department allowed to reside only in California or 

 New Mexico, but not Pennsylvania.”

B. JURISDICTION IS ALWAYS BEFORE THE COURT AND THE COURT HAS A DUTY TO

DISMISS A CASE, WHERE IT HAS NO JURISDICTION

In a recent case of S. Freedman and Company, inc v Marvin Raab et al # 05-1138 (from NJ #04-cv-01119)

Third Circuit court judges Honorable Barry, Smith and Aldisert found that under precedent of Gould

Electronics, inc v United states, 220 F. 3d 169, 176 (3d Cir.2000) 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 the party asserting jurisdiction “bears the burden of showingthat the case is properly before the court at all stages of litigation”. 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 Third 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 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

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 (5th

Cir 1982)

(“In order to adequately establish diversity jurisdiction, a complaint must set forth with specificity a corporate

 party’s state of incorporation and its principal place of business). “Fedco’s 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.

 

etted today | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

3 5/2/2011

Exhibit "116"Pg. 829

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 19 of 37 Page ID#:5357

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 20/37

Party’s mere allegation of diversity cannot satisfy its burden of establishing district court’s 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 defendant’s 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 since

 pleadings 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 patient’s claims because he failed to establish diversity jurisdiction because at

time 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

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 if 

John Doe’s identity were discovered there could have been no diversity, and court’s jurisdictional

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

USCS § 1332 because it would have accomplished much broader result of allowing case with only one partyand 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 motorist’s 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 courtclearly was addressing jurisdictional issues–diversity of citizenship, 28 USCS § 1332, and fraudulent

 joinder–and when doing so, it properly declined to decide doubtful question of state law and, instead, resolvedambiguity (lack of state law directly on point) in motorist’s 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 a preponderance of evidence.

For a year and a half the Plaintiffs used this court as a tool to harass the Defendants/whistle blowers. Untilnow this court might have believed Liberi and Berg’ s allegations, however at the last hearing Liberi admitted

that she is a felon, convicted in California in 2008. Her admission in combination with the evidence presented by the defendants in the form of Liberi’s probation record and a letter from the San Bernardino

California DA Mike Ramos show that Liberi could not possibly reside in PA, as according to her current probation she can reside only in Ca or NM. As such the court has a duty to dismiss this case due to lack of subject matter jurisdiction.

etted today | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

3 5/2/2011

Exhibit "116"

Pg. 830

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 20 of 37 Page ID#:5358

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 21/37

 

C. An error in Liberi’s state citizenship goes to the ultimate question in this case and cannot be made

without any documentary evidence

This is the case of defamation of character and slander. The Plaintiffs state that Lisa Liberi, paralegal to

attorney Berg and Berg himself were slandered when Taitz published a summary of Liberi’s 2008 conviction

of 10 felonies. Liberi and Berg claim, that she is a different Lisa Liberi, who resided in PA and was

slandered. On 12.20.2010 Liberi admitted that she is a convicted felon, that she was convicted in 2008 inCalifornia of theft. Taitz provided her probation record, showing that she is not allowed to live in PA.

If notation in 12.23.2010 order, stating that Liberi is a resident of PA is not stricken from the record and the

case is not properly dismissed due to total lack of subject matter jurisdiction, if this case is transferred

somewhere else, a new judge might issue a summary judgment based on this erroneous finding and

Appellants will suffer even more damages.

D. NOT STRIKING AN ERRONEOUS NOTATION IS AGAINST PUBLIC POLICY AND WILL GIVE

GREEN LIGHT TO OTHER FELONS ON PROBATION, LIKE LIBERI, TO DEFRAUD MULTIPLECOURTS.

In this case a felon on probation Lisa Liberi and her attorney Philip J Berg committed fraud on the court and perjury, claiming that Liberi is a resident of PA and that she was defamed by the publication of criminal

record of Lisa Liberi, as they claimed that she is a different person, a different Lisa Liberi, resident of PA. If 

erroneous finding is not corrected by this court and the court continues to allow Liberi and Berg to maintain

this case in diversity without filing a shred of documentary evidence of Liberi’s state citizenship, than it will

 be a most dangerous precedent, a green light for any criminal, any felon to simply assume another identity,

find an attorney, who would violate code of professional ethics and file frivolous law suits to harass innocent

individuals and whistle blowers.

E MOTION FOR SANCTIONS AGAINST THE PLAINTIFFS AND ATTORNEY PHILIP J BERGFOR FILING A FRIVOLOUS LEGAL ACTION WITH MALICE AND FOR MAKING

OUTRAGEOUS MALICIOUS ACCUSATIONS OF CAPITAL CRIMES AGAINST THEDEFENDANTS WITH THE PURPOSE OF COVERING UP PRIOR FRAUD AND SILENCING THEWHISTLE BLOWERS.

This is the case, where the defendants are the true victims.

While your Honor has written in his order on 12,23.2010, that there were no winners during the 12.20.2010

hearing, in reality there was a winner. This winner was the Truth, as the defendant and an attorney for the

defendants Taitz during her cross examination of the Plaintiffs was able to uncover the truth and open the

eyes of this court to simple facts, that this court did not seem to see for some reason before.

Taitz has proven to this court that

1. Liberi is indeed a convicted felon from CA. The court stated in its’ order that Liberi conceded that she was

a convicted in CA in2008 and that Liberi is evasive and not believable as a witness.

2. Plaintiff Ostella A. THE MOST EGREGIOUS ARE MULTIPLE VIOLATIONS BY ATTORNEY

PHILIP J. BERG OF THE PENNSYLVANIA RULES OF PROFESSIONAL CONDUCT

 

etted today | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

3 5/2/2011

Exhibit "116"Pg. 831

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 21 of 37 Page ID#:5359

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 22/37

Adopted by Order of the Supreme Court of Pennsylvania dated October 16, 1987

effective April 1, 1988

Text contains recent revisions & amendments which became

effective January 1, 2005, January 6, 2005, March 17, 2005, April 23, 2005 and July 1, 2006

 

A. MULTIPLE COUNTS OF EGREGIOUS ATTORNEY MISCONDUCT AND VIOLATIONS OFRULES 3.3, 4.1 AND 8.4

Rules 3.3 Candor Toward the Tribunal

Rule 4.1 Truthfulness in Statements to Others

Rule 8.4 Misconduct (Exhibit Rules of professional conduct Adopted by the Supreme Court of PA

Rules 3.3, 4.1, 8.4)

 

Philip J. Berg by his own admission employed Lisa Liberi as his legal assistant and paralegal from end of 2006/begining of 2007 until now. By his own admission Berg submitted to court pleadings drafted by Liberi,specifically in Berg v Obama 2:08-cv-04083-RBS, which he submitted to the Eastern District of PA, ThirdCircuit Court of Appeals and the Supreme Court of the United States. In his 12.22.2010 letter to Your Honor and cc-ed to the defendants, Berg states ”It is true that Plaintiff Liberi was convicted of a felony, in one case,not multiple cases, however Miss Liberi worked extremely hard putting her life together.” So, after a year and

a half of harassment of Taitz with a frivolous $800 million dollar law suit for defamation and slander, claimingthat Liberi was an innocent victim of defamation, Berg and Liberi admitted that she is indeed a recently

convicted felon. Berg claims that she is putting her life together, but how does she do it? She did it byaccusing attorney Taitz of capital crimes of attempting to hire a hit man to kill her and doing this for the sole

 purpose of hiding her drivers’ license, which would show that she did not reside in Pennsylvania. She is putting her life together by defrauding this court for a year and a half. Her attorney Berg is right there,

committing this egregious fraud on the court together with her. This is a flagrant violation of rule 3.3, 4.1 and8.4

 Count 2

In and around mid April 2009 Taitz published on the web site of her foundation an official summary of Liberi’s convictions, which is available for public review on the official website for the San Bernardino

County, Ca Superior Court. This printout showed Liberi’s 2008 convictions of 10 counts of forgery, forgeryof an official seal and theft. Taitz did it with a proper purpose of warning the public at large, that nothing

submitted to court by Philip J. Berg can be considered as genuine in light of his assistant’s conviction and inlight of the fact, that Berg was conducting a Nationwide fundraising and on the pages of his web siteObamaCrimes.com was asking the donors to provide their credit card information, their address and other  personal information, which became available to Lisa Liberi, who was recently convicted of multiple counts

of theft. Only a few days after Taitz published such record, Berg filed a $800 million dollar legal action for Slander and Defamation of character, where he claimed that he and his assistant were defamed by an

etted today | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

3 5/2/2011

Exhibit "116"

Pg. 832

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 22 of 37 Page ID#:5360

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 23/37

accusation of Liberi committing crimes. Berg claimed that Liberi is a resident of PA and both of them were

defamed. At that time Berg clearly knew that Liberi does not reside in PA and filed a frivolous legal action for 

defamation and slander with the only purpose of harassment and intimidation of the defendants and in order 

to defraud the tribunal, whereby he violated Rule 3.3, 4.1 and 8.4

 

COUNT 3

When Taitz demanded proof of Liberi’s residence in PA and proof, that she is a different person, Berg

committed yet another act of egregious fraud on the court and without a shred of evidence stated that Liberi’s

drivers license needs to be sealed because attorney Orly Taitz tried to hire a hit man to kill Liberi. Berg is an

attorney and without a drop of conscience, without a drop of honesty and integrity he accused a fellow

attorney of a capital crime, knowing full well, that he does not have any evidence to substantiate such an

outrageous accusation. Additionally, he accused a career police officer and a licensed investigator Neil

Sankey of hacking Liberi’s computer and stalking her, he accused a veteran Pamela Barnett of forging a letter 

from Linda Belcher, he accused his former assistant and researcher Linda Belcher of forging Liberi’s e-mails

and forging an official seal, as well as of having a criminal record, he accused a retired veteran and engineer 

 Neil Turner of being a White Supremacist Militiaman, who is stalking Liberi, he accused a talk show host Ed

Hale of stalking and stealing a document. All along Berg knew, that he is working with a convicted forger,that nobody ever threatened them, he knew that all the crimes, that he is making up are a repertoire of his

assistant Lisa Liberi, he knew that all the individuals that he is accusing are simply whistleblowers, who blew

the whistle on him and Liberi, he knew that none of these individuals ever committed any crimes, were never 

convicted of any crimes, yet Berg went to the extent of assassinating good name of multiple innocent

individuals with the sole purpose of covering up for a fact that he continuously submits to courts documents

 prepared by a convicted document forger and for the fact that he does fundraising with a convicted thief.

Berg filed thousands of pages of pleadings with such accusations in the Eastern District of PA as well as the

Third Circuit Court of Appeals. By doing so Berg violated rule 3.3, 4.1, 8.4

COUNT 4

As Berg claimed that Liberi’s life is in danger, at the 08.07.09 hearing Judge Eduardo Robreno allowed Berg

to file Liberi’s PA drivers license under seal

The transcript on page 19

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

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 which

we will give the court under seal, is that correct?

A Yes, sir.”

Berg and Liberi promised to file Liberi’s drivers’ license under seal. Berg and Liberi defrauded the court yet

again and did not file Liberi’s drivers license or any identifying documents. The docket of the case shows, that

etted today | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

3 5/2/2011

Exhibit "116"

Pg. 833

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 23 of 37 Page ID#:5361

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 24/37

no identifying documents were ever filed. When Taitz properly filed her motion to dismiss due to the fact, thatLiberi never provided any documents, showing her state citizenship, and that the case at hand filed based on

diversity has to be dismissed, Berg and Liberi continued defrauding the District court and the Third CircuitCourt of Appeals, claiming that they provided necessary documents and continuously accusing defendants of crimes in order to confuse both courts. Wherefore, Berg violated rule 3.3, 4.1 and 8.4.

Taitz submits an article from “Legal Intelligencer’, showing that Berg repeatedly engages in such conduct.

Berg was previously repeatedly sanctioned. In Re Berg , 2008 Bankr. LEXIS 322 (ED PA 2008 ); Holsworth

v. Berg , 2005 U.S. Dist. LEXIS 15393 (ED PA 2005). Liberi has engaged in the same conduct as well.

A July 25, 2005 article from The Legal Intelligencer, “Lawyer Slapped With $10K in Sanctions for ‘LaundryList of Unethical Actions’ sums the situation here up:

“Finding that a Pennsylvania lawyer had committed a “ laundry list of unethical actions,” a federal judge hasimposed more than $10,000 in sanctions and ordered the lawyer to complete six hours of ethics training. U.S.District Judge J. Curtis Joyner’s 10-page opinion in Holsworth v. Berg is packed with criticism of the conduct

of attorney Philip Berg of Lafayette Hill, Pa.”Other attorneys should look to Mr. Berg’s actions as a blueprintfor what not to do when attempting to effectively and honorably perform the duties of the legal profession,”

Joyner wrote. “This court has grown weary of Mr. Berg’s continuous and brazen disrespect toward this court

and his own clients. Mr. Berg’s actions … are an enormous waste of judicial time and resources that this courtcannot, in good conscience, allow to go unpunished,” Joyner wrote. In the suit, Berg is accused of legalmalpractice by former clients who claim his failure to respond to an ERISA claim against them led to a default

 judgment. But the sanctions against Berg stem from his decision to file a third-party counterclaim of fraudagainst a pension fund that had sued his former clients, according to court papers. Joyner blasted Berg for 

filing the fraud claim, calling it an “irresponsible decision” because the claim was “utterly barren of anyscintilla of legal principles.” Berg’s motion was rejected and a default judgment of more than $5,300 wasentered against his clients. The judgment swelled to more than $10,000 when Carpenters Health later successfully moved for a supplemental judgment to recover more than $4,700 in attorney fees for its efforts in

responding to Berg’s untimely motions. Holsworth and his wife later filed a legal malpractice suit against Bergin the Philadelphia County Court of Common Pleas, alleging that Berg negligently failed to represent them in

the Carpenters Health case. A year later, in February 2005, Berg moved to join Carpenters Health as athird-party defendant in the malpractice suit, demanding more than $20,000 in damages. In his counterclaim,Berg alleged that the ERISA suit filed by Carpenters Health in 2001, which led to the malpractice claimagainst him, was “a fraud upon the court and a fraudulent taking from the Holsworths.”Carpenter Health’s

lawyers removed the case to federal court and filed a motion to dismiss the claim. Joyner agreed, finding thatBerg’s fraud claim was “frivolous” and was motivated by an intent “to harass Carpenters Health and the

Holsworths, as well as to delay and disrupt the administration of justice.” The claim was fatally flawed,Joyner found, because Berg had no standing to bring suit against Carpenters Health and had “failed toconduct 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 matter 

of 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 “… “Berg’s fraud claim, Joyner said, was “inadequately pled, not grounded in fact, time-barred, and utterly irrelevant to the pending malpractice action againsthim.”…”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 Association’s Committee on Legal Ethics and Professional

Responsibility.”

Similarly Berg demanded disbarment of the Supreme court Justices Sandra Day O’Connor, Antonin Scalia

etted today | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

3 5/2/2011

Exhibit "116"

Pg. 834

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 24 of 37 Page ID#:5362

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 25/37

and Clarence Thomas. http://en.wikipedia.org/wiki/Philip_J._Berg

In October 2004, Berg filed Rodriguez v. Bush 04-4952 Eastern District of PA, accusing the President of theUnited States and 155 other parties of complicity in the 9/11 attacks.

This 237-page civil lawsuit[6][7] included allegations pursuant to the RICO (Racketeer Influenced andCorrupt Organizations Act) against The United States Of America, the Federal Emergency ManagementAgency, the Department of Homeland Security, George Herbert Walker Bush, George Walker Bush, Richard

Cheney, Donald H. Rumsfeld,and numerous others, totaling 156 defendants in the U.S. District Court for theEastern District of Pennsylvania.

This lawsuit made hundreds of allegations “…; that phone calls made by some of the victims, as reported bytheir family members, were not actually made but were “faked” by the government using “voice morphing”technology; that a missile, not American Airlines Flight 77, struck the Pentagon; that United Airlines Flight 93was shot down by the U.S. military; that the defendants had foreknowledge of the attacks and actively

conspired to bring them about; that the defendants engaged in kidnapping, arson, murder, treason, conspiracy,trafficking in narcotics, embezzlement, securities fraud, insider trading, identity and credit card theft,

 blackmail, trafficking in humans, and the abduction and sale of women and children for sex. ”http://en.wikipedia.org/wiki/Philip_J._Berg

Rodriguez v Bush was originally brought in front of the same judge Hon Eduardo Robreno, Eastern District

of PA, it was eventually transferred to NY and dismissed on all counts against all plaintiffs.

At the same time, in 2004-2006, when Liberi was incarcerated, she filed multiple frivolous legal actions. Her first legal action Liberi v Sheriff’s department et al 5:04-cv-01524-VAP was a 30 million dollar case against

multiple individuals, including District attorneys’ office, her prior attorneys, judges, sheriffs’ department, policemen and detectives and many others. It was a frivolous legal action, which caused an enormousemotional distress and financial hardships to many, it was dismissed after her attorney was sanctionedmultiple times and after her attorney dropped Liberi as a client. Not satisfied, Liberi filed pro se yet another 

frivolous RICO law suit for $280 million against the San Bernardino County, CA, West Valley Correctional

facility, district attorneys, police officers, police detectives, numerous law enforcement officials Lisa Liberi vWest Valley Center et al 2:05-cv-03015-VAP-SGL. In a similar modus operandi she accused multiple innocentindividuals of committing crimes. Her legal action was dismissed. As shown in these examples, Both Liberiand Berg have a history and modus operandi of filing multimillion 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 andAppellees. Dismissal of underlying legal action, sanctions, award of attorneys’ fees and costs to the

Appellants are appropriate. Sanctions and reporting Philip J Berg to the Disciplinary Board of the PA SupremeCourt is appropriate. On February 23, 2011 a three member panel is conducting a disciplinary hearing againstPhilip Berg. It will benefit the public at large, if this court sanctions Berg for egregious attorney misconductand forwards the records of these proceedings to the 02.23.2011 Disciplinary hearing for the members of the

 panel to see a full picture of Berg’s misconduct. It will be appropriate for this court to sanction Lisa Liberifor her egregious fraud on the court and forward such findings to San Bernardino, CA probation department.

  CONCLUSION

Defendants respectfully request

1. Correction of a material flagrant error in 12.23.2010 memorandum and order. Instead of “LisaLiberi is a resident of PA”, the order needs to state that Liberi provided her attorney’s business address

in PA as her address, however she never filed with court any documentary evidence of her addressin PA or any other state. Liberi admitted that she is a convicted felon and that she was convicted in

1.

etted today | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

13 5/2/2011

Exhibit "116"

Pg. 835

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 25 of 37 Page ID#:5363

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 26/37

2008 in California. Defendants provided a summary of her 2008 conviction of California, which

includes 10 felonies and a provision of her probation, allowing her to reside only in California or with

her relatives in New Mexico. Defendants are residents of California. As the Plaintiffs never filed any

documentary evidence of Liberi’s state citizenship, no federal district court can assert jurisdiction over 

this case in Diversity of state citizenship and the court has no other choice, but to dismiss this action

due to lack of subject matter jurisdiction under FRCP 59 E and 60 B.

Sanctions against the plaintiffs and their attorney Philip J. Berg for acting with malice and filing a

frivolous legal action for the purpose of harassment, for defrauding the court in relation to Liberi’s state

citizenship.

2.

Sanctions against the Plaintiffs and their attorney Philip J. Berg for committing fraud on the court and

filing a legal action claiming that Liberi was a different person, slandered by the defendants’

 publication, while knowing that she is indeed convicted felon from California, and that she did not

reside in Pennsylvania.

3.

Sanctions against the Plaintiff’s attorney Philip J. Berg for acting with malice and making up

allegations accusing the defendants of capital crimes of kidnapping and attempt to hire a hit man to kill

Liberi without any evidence to such allegations and with the goal to attempt to hide non-existent

Pennsylvania drivers license.

4.

ATTORNEY’S CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT A TRUE AND CORRECT COPY OF THE:

59 E, 60 B MOTIONS TO CORRECT ERRORS IN 12.23.2010 MEMORANDUM AND ORDER AND TO

DISMISS THE CASE DUE TO LACK OF SUBJECT MATTER JURISDICTION

MOTION FOR SANCTIONS AGAINST THE PLAINTIFFS AND PLAINTIFFS’ ATTORNEY PHILIP J.

BERG

was served by mail or electronic mail on 01.22.2011, on the following parties:

 Neil Sankey

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

Sankey Investigations, Inc.

2470 Stearns Street #162

Simi Valley, CA 93063

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

Cell Phone: (818) 212_7615

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

Email: [email protected]

Linda Sue Belcher 

201 Paris

Castroville, Texas 78009

etted today | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

13 5/2/2011

Exhibit "116"

Pg. 836

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 26 of 37 Page ID#:5364

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 27/37

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_0270

Email: [email protected] and

Email: [email protected] and [email protected]

Philip Berg, Esq.

Lisa Liberi c/o Law Office of Philip Berg

555 Andorra Glen Court, Suite 12

Lafayette Hill, PA 19444_2531

(610) 825_3134

FAX (610) 834_7659

E_Mail: [email protected]

Public Integrity Section

Department of Justice

950 Pennsylvania Ave, NW

Washington DC 20530-0001

Disciplinary Board

Supreme Court of PA

820 Adams Ave, ste 170

etted today | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

13 5/2/2011

Exhibit "116"

Pg. 837

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 27 of 37 Page ID#:5365

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 28/37

Trooper, PA 19403

/s/ Orly Taitz

 ___________________________ 

Dr. Orly Taitz, Esq

01.22. 2011

Category: Uncategorized

Comments

4 Responses to “Docketted today”

Laptop Batteries

February 2nd, 2011 @ 7:27 pm

 NQ emergency services in lockdown and not responding to calls for assistance as its too dangerous.

They will evaluate at first light.

1.

Cheap Laptop Batteries

February 2nd, 2011 @ 7:42 pm

Shall we try to get the sublime “we have all the time in the world” to number one this week? John

Barry and Louis Armstrong

2.

Chum Lee

February 3rd, 2011 @ 8:05 am

Orly, why did you file this? Seems like you should have taken this to the 3rd Circuit for an emergencyappeal. That is the normal course of action when TROs are denied. I am curious about your strategy – 

whether you intentionally chose to sidestep the normal procedure.

3.

[email protected]

February 3rd, 2011 @ 8:59 am

TRO came from Berg. I wanted to preserve my objection to errors in the ruling. The court of appeals

will hear my appeal on the 9th, however I am concerned about possible bias. Read the pleadings in the

third circuit. e-mail me

4.

!! IMPORTANT NOTICES – PLEASE READ !!

NEW! CA REP CENTRAL COMMITTEE LIST

CAMPAIGN FLIER for Orly Taitz as CA SOS

CAMPAIGN FLIER for 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

etted today | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

13 5/2/2011

Exhibit "116"Pg. 838

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 28 of 37 Page ID#:5366

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 29/37

EXHIBIT “117”

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 29 of 37 Page ID#:5367

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 30/37

Exhibit "117"Pg. 839

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 30 of 37 Page ID#:5368

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 31/37

VIDEOS

Home

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.

victims of Liberi and berg can write to disciplinary

board and probations

Posted on | February 3, 2011 | 1 Comment

Victims of Liberi, Ostella and Berg can write to:

Disciplinary board

Patricia Dugan

610-650-8210

 

Probations

Rene Ford

909-387-5857

ms of Liberi and berg can write to disciplinary board and probations |... http://www.orlytaitzesq.com/?

http://www.orlytaitzesq.com/?p=18681

5/2/2011

Exhibit "117"Pg. 840

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 31 of 37 Page ID#:5369

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 32/37

Category: Uncategorized

Comments

One Response to “victims of Liberi and berg can write to disciplinary board and probations”

Speedee

February 3rd, 2011 @ 2:30 pm

Hi, regards all

1.

!! IMPORTANT NOTICES – PLEASE READ !!

NEW! CA REP CENTRAL COMMITTEE LIST

CAMPAIGN FLIER for Orly Taitz as CA SOSCAMPAIGN FLIER for 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 thePUBLIC INTEGRITY SECTION

Contact Orly!

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

Recent Posts

WND, Alex Jones show quoted the president of Pakistan, stating that Bin Laden was dead for over 7yearsSomething is going on. There is an explosion of 4,500,000 articles under Orly Taitz

thank your Mr. Eldridge for a very generous donation of $300, thank you Dr. Kelso, Mr. Hodge, Ms.Levy

I did this interview same day as about 40 other interviews, I did it remote control from CA and I couldnot see the host and couldn’t hear him wellWho ID-ed Bin Ladin and why they didn’t take him alive to get info on other terrorists?

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ms of Liberi and berg can write to disciplinary board and probations |... http://www.orlytaitzesq.com/?

5/2/2011

Exhibit "117"

Pg. 841

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 32 of 37 Page ID#:5370

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 33/37

EXHIBIT “118”

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 33 of 37 Page ID#:5371

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 34/37

Exhibit "118"Pg. 842

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 34 of 37 Page ID#:5372

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 35/37

VIDEOS

Home

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.

I need your help

Posted on | February 4, 2011 | 4 Comments

Lisa Liberi, Paralegal of Philip Berg is currently on probation under the supervision of the San BernardinoCounty CA. You can see my latest pleadings. I will forward her info and summar of her probation conditions.

I need help with going through the probation code and writing down all the codes and violations she

committed and forwarding it to Rene Ford, manager of adult probations ph 909-387-6126 or 909-387-5857,

fax 909-386-5827

[email protected]

 please cc County of San Bernardino

Clerk of the Board of supervisors

d your help | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

http://www.orlytaitzesq.com/?p=18709

5/2/2011

Exhibit "118"

Pg. 843

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 35 of 37 Page ID#:5373

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 36/37

385 N Arrowhead Ave, 2nd floor, San Bernardino CA 92415-0130

www.SBCounty.gov/cob/

Claim adjustor 

Rick Castagnon

Liability adjustor 

909-386-8637

County Attorney 909-386-8655

If you are one of the victims, who was also defamed in the pleadings submitted by Liberi, Ostella, Adams and

Berg,

 please, report it.

Berg will have a disciplinary hearing on 02.23.2011

Staff attorney for the Disciplinary Board of the PA Supreme Court

Patricia Dugan 610-650-8210

 probation code download

InboxX

Reply |Margie Largo to me

show details 9:50 AM (23 minutes ago)

download

http://weblinks.westlaw.com/result/default.aspx?cite=15CAADCT15D3C1R&cnt=DOC&db=1000937&

findtype=L&fmqv=c&fn=_top&n=1&pbc=4BF3FCBE&rlt=CLID_FQRLT6514333421142&rlti=1&

rp=%2FFind%2Fdefault.wl&rs=WEBL11.01&service=Find&spa=CCR-1000&sr=TC&ss=CNT&vr=2.0

1. 15 CCR T. 15, Div. 3, Chap. 1, Refs & Annos, BARCLAYS OFFICIAL CALIFORNIA CODE OF

REGULATIONS TITLE 15. CRIME PREVENTION AND CORRECTIONS DIVISION 3. ADULT

INSTITUTIONS, PROGRAMS AND PAROLE CHAPTER 1. RULES AND REGULATIONS OF ADULT

OPERATIONS AND PROGRAMS

 

TITLE 15. CRIME PREVENTION AND CORRECTIONS

DIVISION 1. CORRECTIONS STANDARDS AUTHORITYDIVISION 2. BOARD OF PRISON TERMS

DIVISION 3. ADULT INSTITUTIONS, PROGRAMS AND PAROLE

CHAPTER 1. RULES AND REGULATIONS OF ADULT OPERATIONS AND PROGRAMS

15 CA ADC T. 15, Div. 3, Chap. 1, Refs & Annos

ARTICLE 1. BEHAVIOR 

ARTICLE 1.5. DNA AND FORENSIC IDENTIFICATION

ARTICLE 2. STATE-ISSUED INMATE CLOTHING AND LINEN

ARTICLE 3. WORK AND EDUCATION

ARTICLE 3.5. CREDITS

d your help | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

5/2/2011

Exhibit "118"

Pg. 844

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 36 of 37 Page ID#:5374

8/6/2019 LIBERI v TAITZ (C.D. CA) - 190.21 - Plaintiffs Exhibits 113-118 to Amended Complaint.190.21

http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-19021-plaintiffs-exhibits-113-118-to-amended 37/37

ARTICLE 4. FOOD SERVICES

ARTICLE 5. PERSONAL CLEANLINESS

ARTICLE 6. CAMP ASSIGNMENT [REPEALED]

ARTICLE 6.1. ALTERNATIVE SENTENCING PROGRAM [REPEALED]

ARTICLE 6.3. THE FAMILY FOUNDATIONS PROGRAM

ARTICLE 6.5. INTAKE, RELEASE AND DISCHARGE OF INMATES

ARTICLE 6.7. TRANSFER OF INMATE ASSESSMENT RESPONSIBILITY

ARTICLE 7. FURLOUGHS AND TEMPORARY LEAVE

ARTICLE 8. APPEALSARTICLE 8.5. WRITTEN REQUEST PROCESS

SUBCHAPTER 2. INMATE RESOURCES

SUBCHAPTER 3. INMATE ACTIVITIES [REPEALED]

SUBCHAPTER 4. GENERAL INSTITUTION REGULATIONS

SUBCHAPTER 5. PERSONNEL

SUBCHAPTER 6. ADULT PAROLE

ARTICLE 1. PAROLE SUPERVISION

ARTICLE 2. PREVENTING PAROLEE CRIME PROGRAM [RESERVED]

ARTICLE 3. ELECTRONIC MONITORING

ARTICLE 4. GLOBAL POSITIONING SYSTEM PROGRAM

ARTICLE 5. SEX OFFENDERS [RESERVED]ARTICLE 6. HIGH RISK SEX OFFENDERS [RESERVED]

ARTICLE 7. PAROLE SEARCHES

ARTICLE 8. FINANCIAL ASSISTANCE

ARTICLE 9. PAROLE OUTPATIENT CLINIC

ARTICLE 10. CIVIL ADDICTS

ARTICLE 11. ILLEGAL ALIENS

ARTICLE 12. PAROLEE FIELD FILES

ARTICLE 13. REGISTRATION

ARTICLE 14. HORMONAL CHEMICAL TREATMENT FOR SEX OFFENDERS [RESERVED]

ARTICLE 15. DISCHARGE

ARTICLE 16. RESTITUTION

ARTICLE 17. REVOCATION OR LIMITED PLACEMENT RELEASES

ARTICLE 18. PAROLE HOLDS [RESERVED]

ARTICLE 19. PAROLE VIOLATIONS AND REPORTS

ARTICLE 20. REVOCATION PROCEEDINGS [RESERVED]

SUBCHAPTER 7. PAROLE HEARINGS DIVISION [REPEALED]

SUBCHAPTER 8. PILOT PROGRAMS

Category: Uncategorized

Comments

4 Responses to “I need your help”

Politijabber 

February 4th, 2011 @ 11:55 am

Maybe she forgot to tell her PO that she has a pet. See People v. Olguin, 45 Cal.4th 375(Cal. Supreme

1.

d your help | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?

Case 8:11-cv-00485-AG -AJW Document 190-21 Filed 05/20/11 Page 37 of 37 Page ID#:5375