liberi v taitz (appeal - 3rd circuit) - appellants' opening brief - transport room

8/8/2019 LIBERI v TAITZ (APPEAL - 3rd Circuit) - Appellants' Opening Brief - Transport Room

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Appellant's Opening Brief on behalf of Defend Our Freedoms Foundation and Orly Taitz 1

No. 10-3000

UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT____________________

LISA LIBERI, et al.,

Plaintiffs-Appellees,

vs.

ORLY TAITZ, et al.,

Defendant-Appellants.__________________

District Court No. 09_cv_01898_ECR

Eastern District of Pennsylvania

__________________

APPELLANT'S OPENING BRIEF

DR. ORLY TAITZ, ESQ.CSB #223433

Attorney Pro Se &Attorney for Defend Our Freedoms Foundation

29839 S. Margarita Pkwy. Rancho Santa Margarita CA 92688ph. 949-683-5411

fax 949-766-7603

Case: 10-3000 Document: 003110335655 Page: 1 Date Filed: 11/02/2010


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TABLE OF CONTENTS

Table of Authorities....p 2

Jurisdiction..p.3.

Summary of the casep 4.

Legal argumentp 9

A.The Court erred in assuming jurisdiction over the case in diversity, whenthe lead plaintiff did not provide any evidence of her state citizenship.p9

B. District Court showed bias in refusing to take into consideration anyevidence provided by the Defendants..p13

C. COURT SHOWED BIAS AND ABUSE OF JUDICIAL DISCRETION INASSUMING JURISDICTION IN DIVERSITY WITHOUT ANY

EVIDENCE OF STATE CITIZENSHIP OF THE LEAD PLAINTIFF

LISA LIBERI AND BY IGNORING ALL EVIDENCE, PRODUCED BYTHE DEFENDANTS, SHOWING THAT LIBERI COMMITTED

FORGERY AND FRAUD ON THE COURTBY LYING ABOUT BEING

A RESIDENT OF PENSYLVANIA. p13

D. JUDGE ROBRENO ERRED IN HIS ORDER #76 TO DISMISSDEFENDANT SUNDQUIST WITHOUT PREJUDICE .p19

E. ACTIONS BY JUDGE ROBRENO WERE AGAINST THE PUBLIC

POLICY..P21

E. JUDGE ROBRENO ERRED, SHOWED BIAS AND ABUSE OF JUDICIALDISCRETION IN NOT DOCKETING LETTERS FROM THE DEFENDANT



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BELCHER AND RULING AND NOT PROVIDING ANY ANSWERS TO

BELCHER . .p23

F. CONCLUSION....p25TABLE OF AUTHORITIES

1.Weight v Kawasaki Motors Corp. (1985, ED Va) 604 F Supp 968.p10

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

3. Bautista v Pan American World Airlines, Inc. (1987, CA9 Cal) 828 F2d

546, 126 BNA LRRM 2559, 107 CCH LC P 10159p10

4. Roche v Lincoln Prop. Co. (2004, CA4 Va) 373 F3d 610.p10

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

1225...p11

6.Filla v Norfolk & Southern Ry. (2003, CA8 Mo) 336 F3d 806...p12

7.Jeter v Jim Walter Homes, Inc. (1976, WD Okla) 414 F Supp 791.259.p12

8. Shahmoon Industries, Inc. v Imperato (1964, CA3 NJ) 338 F2d 449, 9 FR

Serv 2d 12B.22, Case 2p12

9, In re Kelly, 808 F.2d 549 (7thCir. 1986)..p23

10,Maier v. Orr, 758 F.2d 1578, 1584 (Fed. Cir. 1985);Meeks v. Jewel Cos., 845

F.2d 1421 (7thCir. 1988)p25



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Certification

The appeal does not exceed the allowed number of pages or words

JURISDICTION

Jurisdiction is proper, as the case in question 09-1898 Liberi et al v Taitz et al

comes from the United District Court for the District of Pennsylvania. The appeal

deals with the issue of lack of jurisdiction for the federal courts to hear the case,

due to the fact that the case was filed in diversity, however the lead plaintiff never

provided any evidence of her state citizenship. Without such evidence, no federal

court has jurisdiction to hear the case and the case needs to be dismissed, which

would be a final determination in the case.

SUMMARY OF THE APPEAL

Case at hand was filed on May, 4, 2009 by Pennsylvania Attorney Philip J. Berg

(hereinafter Berg) as a plaintiff and an attorney for plaintiffs, who are Appellees

herein. Lead Plaintiff is one Lisa Renee Liberi, (hereinafter Liberi), who has at

least 42 criminal charges and at least 10 criminal convictions, which include

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

Liberi's latest conviction was in the state of CA, in 2008, when she received eight

year prison term, which was subsequently reduced to three years probation due to



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her medical problems. (case FWV028000, defendant 1608112 Lisa Renee Liberi,

aka Lisa Courville Richardson, aka Lisa Courville Rich, aka Lisa Richardson and

case FSB044914 for Lisa Liberi ) (Appendix 1 Lisa Liberi's mug shot and

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

on 10.07.10 in this case, he employs Liberi as his paralegal and she drafted

pleadings, which he filed with courts. Berg is known as an attorney, who filed

legal actions against Bush administration, claiming, that President Bush was

involved in 9/11 attacks. Berg was, also, the first attorney to file a legal action

questioning Barack Obama's eligibility to U.S. presidency. His case Berg v Obama

was filed in the Eastern District of PA, this Court and the Supreme Court of the

United States. Berg admitted that Berg v Obama complaint was drafted by Liberi

and filed with the courts by him. Appellant Orly Taitz is a president of Defend

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

and as an attorney in the state of CA. Taitz is very outspoken in regards to the

need for transparency in the government and adherence to the Constitution. Taitz

contacted Berg and let him know that she is concerned about the fact, that he filed

with different courts documents and briefs prepared by a convicted document

forger Liberi. Taitz asked Berg, if he would allow her and a forensic document

expert review the originals of the affidavits from Africa, attesting to Obama's birth

there. Taitz let Berg know, that while she believes that this constitutional issue

needs to be resolved in courts and original vital records need to be reviewed, use

of a document forger does not help the case. Taitz, also, advised Berg, that Liberi



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is currently on probation until March of 2011. She is under supervision of San

Bernardino, CA probation department and according to the terms of her probation

she is not allowed to handle credit cards of others. Berg runs large nation wide

donations drives, where thousands of people donated, since he has cases against

both Bush and Obama administrations. Taitz advised Berg, that he is endangering

the public by continuously working with a convicted thief Liberi. Berg never

responded and never agreed to allow Taitz and her expert to review the original

documents from Africa in question. Taitz posted on the website for her foundation

a report prepared by licensed investigator Neil Sankey, which showed lengthy

criminal record of Lisa Liberi. It was done with a proper purpose of warning the

public. Berg filed this legal action on 05. 04.09 in the Eeastern District of PA

District Court. He listed jurisdiction under diversity and nature of the suit Assault,

Libel, Slander. In this suit he claimed that he and his paralegal were slandered,

because, she is not Lisa Renee Liberi, who was convicted in CA and allowed to

reside only in CA and NM, according to her probation, but rather a different Lisa

Renee Liberi, who happens to have the same first, middle and last name and the

same birth date, but allegedly is a different woman, an innocent woman, who is

residing in PA and physically working in Berg's office. Berg never provided

Liberi's home address, but rather gave his business address as her address. Taitz

has provided the court with a positive ID of Liberi's mug shot, as one, who was

convicted in CA and also one who appeared in front of the Presiding Judge

Eduardo Robreno in this case, claiming to be a different woman. Aside from



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Third Circuit Court of Appeals to dismiss the appeal due to lack of jurisdiction.

Third Circuit Court of Appeals denied Berg's motion.

On 07.29.2010 defendants responded in the District Court by pointing out, that the

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

On 07.30.10. Plaintiffs filed a reply, where they claimed, that Judge Robreno's

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

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

during 08.07.09 hearing, but such records need to be sealed. Plaintiffs made up an

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

Attorney and Doctor Orly Taitz tried to hire a hit man to kill Lisa Liberi, and that

is the reason, why Liberi's "allegedly existent" Pennsylvania driver's license needs

to be sealed, and the court needs to decide that she is a resident of PA without

providing the defendants with any proof or any evidence of her residence.

On 08.31.10 the transcript of the 08.07.09 hearing was released to the Third

Circuit Court of Appeals and published on court public terminal. The transcript

showed, that during the hearing the Plaintiff's attorney Berg promised to provide

the court Liberi's driver's license, however he committed Fraud on the Court and

never provided such Driver's license. The driver's license is not an exhibit with

the transcript of the hearing and is not listed with any exhibits anywhere on the

docket. On 10.28.10 with her motion pleadings Taitz provided the court with the

Affidavits of Caren Hale and Ed Hale (Appendix Vol 2, #3), who were present at

the 08.07.09 hearing and declared under penalty of perjury, that Attorney Berg did



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not tend to Judge Robreno any documents, and that Berg left the courtroom at the

same time as they did. They also identified Lisa Liberi, as the same person, who is

depicted on the mug shot as a California convicted felon and as the same woman,

who appeared during the 08.07.09 hearing, claiming to be a different person, who

was not convicted of any crimes and who resides in PA. The most egregious error

made by the District court, is a decision to assume jurisdiction in diversity without

any evidence of state residence of the lead plaintiff. Due to this error, the

decision of the District court needs to be reversed and the case needs to be

dismissed upon Motion to Dismiss due to lack of Jurisdiction, filed by the

Defendants on 05.28.09 (Docket Document 35 on the Clerk's record), Motion to

dismiss due to lack of jurisdiction filed on 06.09.2009 (Document 53), Second

Amended Motion to Dismiss for 12(b) lack of Subject Matter Jurisdiction and

Judgment on the Pleadings filed on 06.11. 2009 (Document 59).

LEGAL ARGUMENT

A.The Court erred in assuming jurisdiction over the case in diversity,

when the lead plaintiff did not provide any evidence of her state

citizenship.

Case at hand was filed based on diversity. For diversity parties are required to

provide evidence of their state citizenship. State citizenship is determined based

on the preponderance of evidence. In case at hand Plaintiff Lisa Liberi never

provided any evidence of her state citizenship.



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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.

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.



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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 cost and

unspecified amount for other damages, which did not meet amount in

controversy.Olsen v Quality Continuum Hospice, Inc. (2004,DC NM) 380 F

Supp 2d 1225.

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 of28 USCS 1441

into 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 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



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remand that implicitly was based on lack of subject matter jurisdiction;

district court clearly 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,

resolved ambiguity (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.

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



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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 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 other Federal Courts equally will not have jurisdiction.

B.District Court showed bias in refusing to take into consideration

any evidence provided by the Defendants.

Plaintiffs never provided the court a shred of evidence of Liberis state

citizenship. Plaintiffs filed this complaint, claiming Liberi to be a resident of

Pennsylvania. While Berg stated at the 08.07.09 hearing, that he will provide

the court with Liberis drivers license and other documents, he never provided

any documents. The docket and transcripts do not show any vital records for

Lisa Liberi ever provided.

On the other hand the court refused to consider any and all evidence provided

by the Defendants: The court completely ignored the summary of Liberis

criminal convictions, showing that she is not allowed to reside in any other

state except CA and NM until the end of her probation in March of 2011.



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C. COURT SHOWED BIAS AND ABUSE OF JUDICIAL DISCRETION IN

ASSUMING JURISDICTION IN DIVERSITY WITHOUT ANY

EVIDENCE OF STATE CITIZENSHIP OF THE LEAD PLAINTIFF LISA

LIBERI AND BY IGNORING ALL EVIDENCE, PRODUCED BY THE

DEFENDANTS, SHOWING THAT LIBERI COMMITTED FORGERY

AND FRAUD ON THE COURTBY LYING ABOUT BEING A RESIDENT

OF PENSYLVANIA

Liberi is the lead plaintiff in this case. Her citizenship is at issue for the purpose of

the court assuming jurisdiction in diversity. It is also the linchpin of the case, as

she and her attorney are claiming, that she was defamed and slandered, because,

she is not Lisa Rene Liberi, born in 1965 and convicted in CA, but a different Lisa

Rene Liberi, born in 1965, who was never convicted of forgery and theft and who

is an innocent woman, resident of PA.

Liberi and Berg are refusing to provide her driver's license to prove her PA

citizenship. Without any shred of proof they made up a story, claiming that

attorney Orly Taitz tried to hire a hit man to kill Liberi, and this is the reason, why

the District Court should assume jurisdiction in diversity without any shred of

evidence.



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The District Court showed bias and abuse of judicial discretion in giving

preference to this argument over a mountain of evidence, provided by the

Defendants.

a. Defendant's provided Liberi's mug shot and summary of her criminal record,

showing that Liberi is not allowed to reside in any other state aside from Ca and

NM according to the terms of her probation. Judge Robreno saw Liberi right in

from of him during the 08.07.09 hearing. He could plainly see that the woman

right in front of him, is the same woman, depicted on the mug shot.

b. Judge Robreno disregarded the e-mail from Assistant District Attorney James

Secord, who prosecuted and convicted Liberi of 10 counts of forgery and theft. In

his e-mail Mr. Secord identified Liberi on her mug shot, as one convicted in CA.

The same mug shot was identified by Ed and Caren Hale, who attended 08.07.09

hearing of Liberi and identified Liberi on the mug shot as the same woman, who

appeared in front of Judge Robreno and claimed to be a different woman.

c. Judge Robreno disregarded sworn affidavit of a distinguished career police

officer and licensed investigator Neil Sankey, where Sankey produced Liberi's

picture given to him by Liberi's ex-boyfriend and father of her son John Allen.

The same picture was identified by Ed and Caren Hale as the picture of Lisa

Liberi, who appeared in front of Judge Robreno and claimed to be a different

woman.

d. Judge Robreno disregarded evidence, showing that the signature of Lisa Liberi,

that she affixed to the pleadings and affidavits in this case, is the same signature as



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affixed in her petition filed in her criminal case in CA FWV028000, defendant

1608112 Lisa Renee Liberi, aka Lisa Courville Richardson, aka Lisa Courville

Rich, aka Lisa Richardson and case FSB044914 for Lisa Liberi and in her

bankruptcy case in CA 6-02-bk-22845-PC . Not only the issue of the identical

signatures was completely disregarded, but the evidence was deleted from the

electronic docket and is currently unavailable to public.

e. Judge Robreno disregarded the evidence presented by the defendants, showing

that Liberi has a history and pattern of making false accusations of crimes and

harassing and torturing innocent individuals with frivolous law suits. Taitz

provided the court with information, showing that in 2005, while Lisa Liberi was

incarcerated in West Valley Detention Center, CA, she filed a $280,000,000

Racketeering and Corrupt organizations law suit (Appendix Docket of Lisa Liberi

v West Valley Center et al 2:05-cv-03015-VAP-SGL) against multiple individuals

and accused of multiple crimes San Bernardino, CA county, San Bernardino

District Attorney's office, West Valley Detention Center, San Bernardino sheriff's

department, deputies from the West Valley detention center, nurses from the West

Valley Detention Center, deputy District attorney, police detectives, Judge Joan

Borba, bail bonds company, USA Federal Credit Union and many other entities

and individuals. After she harassed and terrorized all of the above individuals she

abandoned the case. Judge Robreno could see, that there is a pattern of behavior of

Liberi falsely accusing multiple individuals of committing crimes and harassing

those individuals with multimillion dollar frivolous law suits. It should have given



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Judge Robreno an indication, that Liberi's and Berg's accusations of multiple

crimes committed by defendants and accusations of threats are frivolous.

f. Judge Robreno showed bias and abuse of judicial discretion in disregarding

excerpts of transcript from the court hearing in The People of the State of

California v Lisa Liberi Richardson Superior Case FSB-044914. While in this

current case of Liberi et al v Taitz et al, Lisa Liberi brought her mother Shirley

Waddell to testify that her daughter is an innocent woman, slandered by the

defendants and in danger for her life, transcript of FSB-044914 shows that

Liberi's mother not only knew, that her daughter was not an innocent woman in

PA but a convicted criminal from CA, but she was the one who paid the premium

for the bail bond to bail her daughter from jail.

g. Judge Robreno exhibited bias and abuse of judicial discretion by refusing to pay

attention to the motifs of behavior of the parties. While neither one of the

defendants had any motif to state anything that was not true or in any was threaten

or harm Liberi, Liberi and Berg had a motif to commit fraud and perjury. Judge

Robreno refused to consider letters from Geoff Staples, computer consultant for

Berg's web site "Obama Crimes.com' Not only Mr. Staples sworn statement was

not considered by the court, it was not even docketed. Without any explanation or

justification Geoff Staples sworn statement was removed from the electronic

docket of the pleadings filed by the defendants on 10.28.10. (document 149,

clerk's record). (Appendix-Amended reply to 10.07.10 motion by the Plaintiffs;

defendants request for the court to use it's inherent power to sanction the plaintiffs,



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attorney Berg and witness Shirley Waddell for repeated acts of fraud on the court

and perjury. Request to expedite production of Lisa Liberi's Pensylvania driver's

license, allegedly provided to court during the emergency hearing on 08.07.09.)

h. Judge Robreno showed bias and abuse of Judicial discretion by ignoring the

fact that Liberi is a convicted criminal with at least 42 criminal charges and at

least 10 criminal convictions, while individuals, that she accused of committing

crimes are indeed innocent individuals who were never convicted or charged with

any crimes. Judge Robreno repeatedly refused to take into consideration multiple

affidavits provided by multiple individuals, attesting to the fact, that they never

committed any crimes, that they were maliciously accused of crimes by Liberi and

Berg. Liberi and Berg claimed that Liberi is in danger and her driver's license

needs to be kept sealed and they accused Licensed investigator Sankey of stalking

Liberi and hacking into her computer, desert storm veteran Pamela Barnett of

forgery of letter from Linda Belcher, volunteer Linda Belcher of forgery of seal,

ED and Caren Hale of stealing an forging a document, Computer Consultant Geoff

Staples of forging Liberi's e-mails, Taitz of trying to hire a hit man to kill Liberi.

This modus operandi is similar to what Liberi exhibited previously, when she was

incarcerated in CA. Judge Robreno allowed this convicted criminal and her

unscrupulous attorney to terrorize innocent victims for a year and a half. All of the

defendants suffered an enormous emotional distress, financial hardships, Ed Hale

suffered a heart attack due to stress inflicted by this law suit. Judge Robreno had a

duty to demand verification of Liberi's citizenship. It was supposed to be done at



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the onset of the case. It was a material matter in the case and essential in

ascertaining jurisdiction. Inexplicably Judge Robreno refused to demand prove of

Pennsylvania citizenship and allowed this case to become a dumping ground for

thousands of pages of slander coming from a career criminal Lisa Liberi. This was

a manifestation of bias and abuse of judicial discretion by judge Robreno.

D.JUDGE ROBRENO ERRED IN HIS ORDER #76 TO DISMISS

DEFENDANT SUNDQUIST WITHOUT PREJUDICE

On 06.09.10 Taitz filed a motion to dismiss due to lack of jurisdiction and on

06.11.10 she filed a second amended motion to dismiss due to lack of jurisdiction.

(Document 59-Clerk's record) In her motion Taitz argued that a motion to dismiss

needs to be granted for several reasons:

1. one of the defendants James Sundquist was a resident of New Jersey. Plaintiffs

Lisa Ostella and GoExcell global were also residents of New Jersey, which

destroyed diversity.

2. Lead Plaintiff Lisa Liberi claimed to be a resident of PA, but never showed a

shred of evidence of PA residence. Taitz provided a summary of her conviction

and probation record, showing, that she is on probation and allowed to reside only

in CA or NM. she was not allowed to reside in PA.

In response Plaintiffs filed a motion to dismiss defendant Sundquist without

prejudice.



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Sundquist filed an opposition, he refused to be dismissed without

prejudice.(Document 54 Clerk's record), he demanded dismissal with prejudice

and attorneys fees.

During the 06.25.09 hearing Judge Robreno continuously pressured defendant

Sundquist to agree with the plaintiff's request to dismiss him without prejudice.

Sundquist repeatedly refused.

On 06.26.10 Judge Robreno granted Plaintiff's motion to dismiss Sundquist

without prejudice. Judge Robreno acted with clear bias and abuse of Judicial

discretion. He did not assist Sundquist in any way, since Berg can continue

harassing Sundquist at any time in the state of New Jersey. On the other hand

Judge Robreno artificially created jurisdiction for the Plaintiffs, where it didn't

exist. He refused to grand a dismissal due to lack of jurisdiction and he refused

to address the fact that the lead plaintiff never provided any evidence of her state

citizenship. By artificially creating jurisdiction, Judge Robreno gave the Plaintiffs,

one of whom is a career criminal and a vexatious plaintiff, green light to harass

and terrorize the defendants with thousands of pages of pleadings, most of which

were nothing but inflammatory and slanderous material about the defendants.

While at a later hearing on 08.07.09. Attorney Berg stated, that he will provide

Liberi's Pennsylvania driver's license, he never did that. Within a year and a half

Judge Robreno never demanded from Berg to actually provide the license and

never responded to all of the requests by the defendants. These actions by the

presiding judge showed bias and abuse of Judicial discretion.



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D.ACTIONS BY JUDGE ROBRENO WERE AGAINST THE PUBLIC

POLICY

There are two main issues, where the actions by the court we against the public

policy.

1. The court went against the established policy of establishing state citizenshipby the preponderance of evidence. In this case judge Robreno created a new

standard of ascertaining state citizenship without any evidence. This gives

green light for anyone and particularly a convicted felon on probation, like

Liberi to simply show up in any court, commit perjury and fraud, file an

action solely for the purpose of harassment and use the federal court as a tool

for harassment, intimidation and for infliction of several emotional distress

against anyone, particularly any whistleblower, who reports his violations of

probation.

2. Judge Robreno refused to consider the fact, that according to the fact thatLiberi committed multiple economic crimes, she was not allowed access to

any credit cards of others, it would be a violation of her probation. For a

period of a year and a half Taitz reported that Berg runs a website

ObamaCrimes.com Webmaster Geoff Staples repeatedly reported that Liberi

handled the credit cards of others on that web site. Public was and is in

danger of more economic crimes on part of Liberi. Refusal by the court to

consider matters of the well being of the public was an error. Additionally,

the issue of Liberis handling of the credit cards of others represented a



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violation of her probation and a motif to commit perjury and fraud on the

court and claim, that she is a different person, It was also a motif for Berg to

claim that Liberi is a different person, as he knew that the truth will expose

him to charges of aiding and abetting a felon to violate terms of her

probation, as well as charges of perjury, fraud on the court, institution of

legal proceedings with the goal of harassment. Bergs actions could expose

him to severe sanctions and possible disbarment, so his and Liberis

inventions of crimes and accusations of crimes were as a result of their

desire to cover up unethical behavior and possibly criminal behavior.

E. JUDGE ROBRENO ERRED, SHOWED BIAS AND ABUSE OF

JUDICIAL DISCRETION IN NOT DOCKETING LETTERS FROM

THE DEFENDANT BELCHER AND RULING AND NOT

PROVIDING ANY ANSWERS TO BELCHER .

When Berg filed this case, he has written incorrect address for defendant Linda

Belcher. Docket entry of 12.22.09 states that a letter sent to defendant Linda

Belcher returned , unable to forward. Berg was claiming, that he served Belcher,

however in May of 2010 Belcher forwarded to the court a letter, stating that she

was not served with any pleadings from July of 2009 until May of 2010. Belcher

became a pro se defendant, when her attorney resigned, as she could not afford

the fees. From May of 2010 until now Belcher has written to judge Robreno

repeatedly, advising him that her Constitutional rights for due process under 5, 9,

14 amendment were violated as she was not served with any pleadings, the court



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had a wrong address and she demanded the court to set aside all orders issued

from July 2009, as she was unable to respond. Judge Robreno simply ignored

any and all letters sent by Belcher, who is a resident of Texas, an indigent and

had limited means of fighting this legal action. Not only this affected Belcher, it

affected other defendants as well, as Belcher used to be an insider and volunteer

researcher for Philip B erg, she had access to all the information and knew, that

Lisa Liberi did not reside in PA, she knew that Liberi manned the web site with

pay[pal and merchant accounts, as well as the fact, that Berg instituted a pay-pal

account for his girlfriend and connected it to the web site, which was dedicated

to the donations for Bergs constitutional legal efforts. Additionally, in her letters

Belcher disclosed, that Liberi was receiving Social Security as a disabled person.

In her letter she stated, that a merchant account was created under the name of

Liberis husband Brent and it was connected to ObamaCrimse.com account. This

was an indication of possible social security fraud, IRS fraud and terms of

probations fraud and a motif for this law suit. Only, when Belcher became

exasperated by Judge Robrenos refusal to respond, she forwarded her affidavits

to Taitz and Taitz included those in her pleadings, that she submitted to court on

06.14.10, 06.28.10, 07.02.10, 07.29.10, 08.02.10, 09.08.2010, 09.28.10, 10.21.10

and 1028.10.(Appendix volume 2, #3). Judge Robreno simply disregarding any

and all Constitutional rights violations against defendant Linda Belcher and

refused to provide any response. These actions were in error and represented



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abuse of judicial discretion. Belcher was an integral part of the case and

violation of her constitutional rights of due process affected all the defendants.

DEFENDANTS ARE REQUESTING THIS COURT TO USE ITS

INHERENT POWERS TO SANCTION PLAINTIFFS, WITNESS

SHIRLEY WADDELL AND ATTORNEY BERG

As the Appendix Vol 2, #1, 3, 4 clearly show Attorney Philip J. Berg used the

district court and filed pleadings based on fraud on the court and perjury and

harassment of defendants. His motif was the fact, that since 2006-2007 he was

working with a convicted forger and thief on probation Lisa Liberi. He clearly

knew, that she did not physically reside in PA, did not work in his office, but

rather corresponded with him via e-mails and phone. With extreme malice and

with egregious violation of code of professional ethics he filed a legal action

against the whistleblowers, who exposed Liberi and him. For a year and a half he

harassed the whistleblowers with a frivolous law suit for nearly a billion dollars.

He filed thousands of pages of inflammatory and defamatory material. When

asked to provide proof of Liberis PA residence he committed more egregious

fraud on the court and perjury and together with Liberi made up an accusation of

capital crimes, claiming that her drivers license cannot be revealed due to

threats and he further defamed and slandered the defendants by accusing them of

stalking, trying to hire hit men to kill her, forging documents and so on.

Plaintiffs were not content with lying by themselves, they enlisted Liberis



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mother to lie and submit perjured affidavits, claiming that Liberi was an innocent

woman, even though Liberis mother was the one who previously posted bail in

order to bail her daughter from prison. Defendants are asking this court to

sanction the plaintiffs for these egregious acts of fraud, perjury, uttering,

institution of legal proceedings with the sole purpose to harass. Defendants are

asking to forward the copy of these proceedings to the PA Disciplinary board of

the PA Supreme Court for purpose of severe sanctions and / disbarment of

Philip J. Berg for the above acts. Defendants are also asking this court to

forward the above to pleadings to the San Bernardino, CA probation department

for the purpose of revocation of Lisa Liberis probation.

While FRCP Rule 11 is not directly applicable to the appellate court since it

has not been incorporated by reference or otherwise in appellate rules of court, its

requirements help to define conduct becoming to member of bar, and sanctions

may be imposed for conduct inconsistent with its standards. In re Kelly, 808 F.2d

549 (7th Cir. 1986). Berg by putting his signature on the frivolous and deceptive

motion to dismiss with its false factual allegations against Dr. Taitz has opened

himself up to sanctions should this Court wish to impose them sua sponte.

Further FRAP Rule 38 is also available to this Court and Appellees have

gone to the trouble to respond to this motion. Appellants counsel is responsible

for the content of frivolous motions which waste judicial resources and are without

merit and therefore are potentially sanctionable under FRAP Rule 38. SeeMaier v.



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Orr, 758 F.2d 1578, 1584 (Fed. Cir. 1985);Meeks v. Jewel Cos., 845 F.2d 1421

(7th Cir. 1988).

CONCLUSION

Appellants request the Third Circuit Court of Appeals to find that District

Court assumed jurisdiction in error and had a duty to Dismiss the case 09-1898

due to lack of evidence of state citizenship Plaintiff Liberi and therefore the court

was without jurisdiction to rule over the case in diversity. Any orders as to this

case are in error and need to be reversed and the case dismissed.

Appellants are asking for sanctions against the Appellee and their attorney Philip

J. Berg and witness Shirley Waddell for repeated acts of fraud on the court and

filing this case for the dole reason of harassment of the defendants/appellants.

DATED: November 2, 2010

______/s/Orly Taitz_____________________Orly Taitz, Appellant inPro Se and as Counsel forAppellant Defend OurFreedoms Foundation

(Pro Se parties Neil Sankey and Linda Belcher adopt the Appeal by theAppellants)

ATTORNEYS CERTIFICATE OF SERVICE



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I hereby certify that a true and correct copy of the Appellant opening brief wasserved on all the parties on 11.02.10 by electronic mail.

All parties and entities were served by MAIL AND/or ELECTRONIC MAIL on

November 2,, 2010

Neil SankeyThe Sankey Firm, Inc. a/k/a The Sankey FirmSankey Investigations, Inc.2470 Stearns Street #162Simi Valley, CA 93063Phone: (805) 520_3151and (818) 366_0919Cell Phone: (818) 212_7615FAX: (805) 520_5804 and (818) 366_1491Email: [email protected]

Linda Sue Belcher201 ParisCastroville, Texas 78009Home Phone: (830) 538_6395Cell Phone: (830) 931_1781Email: [email protected] andEmail: [email protected]

Ed Hale

Caren HalePlains RadioKPRNBar H Farms1401 Bowie StreetWellington, Texas 79095Phone: (806) 447_0010 and (806) 447_0270Email: [email protected] andEmail: [email protected] and [email protected]

Philip Berg, Esq.Lisa Liberi c/o Law Office of Philip Berg555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444_2531(610) 825_3134FAX (610) 834_7659



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Public Integrity Section

Department of Justice

950 Pennsylvania Ave, NW

Washington DC 20530-0001

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

Special Rapporteur on the Situation of Human Rights Defenders

The Honorable Mrs. Margaret Sekaggya

Palais des Nations

CH-1211 Geneva 10, Switzerland

International Criminal bar Hague

United Nations Commission for

Civil Rights Defenders

Orsolya Toth (Ms)

Human Rights Officer

Civil and Political Rights Section

Special Procedures Division

Office of the High Commissioner for Human Rights

tel: + 41 22 917 91 51

email:[email protected]

__/s/Orly Taitz_________________________Dr. Orly Taitz, Esq11.02.10

mailto:[email protected]:[email protected]:[email protected]:[email protected]


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AppendixVolume I #1 notice of Appeal



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1



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. Docket of Case 09-1898 Liberi et al v Taitz et al

QueryReports

UtilitiesLogout

CLOSED, APPEAL, STANDARD

United States District Court

Eastern District of Pennsylvania (Philadelphia)

CIVIL DOCKET FOR CASE #: 2:09-cv-01898-ER

LIBERI et al v. TAITZ et alAssigned to: HONORABLE EDUARDO C.ROBRENO

Case in other court: USCA Third Circuit, 09-03403

USCA Third Circuit, 10-03000

Cause: 28:1332 Diversity-Libel,Assault,Slander

Date Filed: 05/04/2009Date Terminated: 06/04/2010Jury Demand: BothNature of Suit: 320 Assault Libel& SlanderJurisdiction: Diversity

Plaintiff

LISA LIBERI represented by PHILIP J. BERGLAW OFFICES OFPHILIP J. BERG

555 ANDORRA GLENCOURTSUITE 12LAFAYETTE HILL, PA19444610-825-3134Fax: 610-834-7659Email:[email protected] ATTORNEYATTORNEY TO BE

NOTICED

Plaintiff

ESQ. PHILIP J. BERG represented by PHILIP J. BERG(See above for address)LEAD ATTORNEYATTORNEY TO BE

https://ecf.paed.uscourts.gov/cgi-bin/iquery.plhttps://ecf.paed.uscourts.gov/cgi-bin/iquery.plhttps://ecf.paed.uscourts.gov/cgi-bin/DisplayMenu.pl?Reportshttps://ecf.paed.uscourts.gov/cgi-bin/DisplayMenu.pl?Reportshttps://ecf.paed.uscourts.gov/cgi-bin/DisplayMenu.pl?Utilitieshttps://ecf.paed.uscourts.gov/cgi-bin/DisplayMenu.pl?Utilitieshttps://ecf.paed.uscourts.gov/cgi-bin/login.pl?logouthttps://ecf.paed.uscourts.gov/cgi-bin/login.pl?logouthttps://ecf.paed.uscourts.gov/cgi-bin/login.pl?logouthttps://ecf.paed.uscourts.gov/cgi-bin/DisplayMenu.pl?Utilitieshttps://ecf.paed.uscourts.gov/cgi-bin/DisplayMenu.pl?Reportshttps://ecf.paed.uscourts.gov/cgi-bin/iquery.pl


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NOTICED

Plaintiff

THE LAW OFFICES OF PHILIP J.

BERGrepresented by PHILIP J. BERG

(See above for address)

LEAD ATTORNEYATTORNEY TO BE

NOTICED

Plaintiff

EVELYN ADAMSa/k/a MOMMA E

represented by PHILIP J. BERG(See above for address)LEAD ATTORNEYATTORNEY TO BE

NOTICED

PlaintiffLISA M. OSTELLA represented by PHILIP J. BERG

(See above for address)LEAD ATTORNEYATTORNEY TO BE

NOTICED

Plaintiff

GO EXCEL GLOBAL represented by PHILIP J. BERG(See above for address)LEAD ATTORNEY

ATTORNEY TO BENOTICED

V.

Defendant

ORLY TAITZa/k/a DR. ORLY TAITZ, a/k/a LAW

OFFICES OF ORLY TAITZ;

a/k/aWWW.ORLYTAITZESQ.COM, a/k/a

WWW.REPUBX.COM, a/k/a ORLY TAITZ,INC.

represented by ORLY TAITZ29839 SANTAMARGARITA PKWYSUITE 300

RANCHO SANTAMARGARITA, CA 92688PRO SE

Defendant

DEFEND OUR FREEDOMS

FOUNDATIONS, INC.represented by DEFEND OUR

FREEDOMSFOUNDATIONS, INC.



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PRESIDENTC/O ORLY TAITZ26302 LA PAZSUITE 211MISSION VIEJO, CA

92691PRO SE

PHILIP J. BERG(See above for address)LEAD ATTORNEYATTORNEY TO BE

NOTICED

Defendant

YOSEF TAITZ

TERMINATED: 05/26/2009

represented by BRAD MILLER

COOPER MORRISON &ASSOCIATES, LLC325 CHESTNUT ST.SUITE 403PHILADELPHIA, PA19106215-829-9500Email:[email protected] ATTORNEYATTORNEY TO BE

NOTICED

Defendant

THE SANKEY FIRM

Defendant

SANKEY INVESTIGATIONS, INC. represented by SANKEYINVESTIGATIONS,INC.c/o NEIL SANKEY4230 ALAMO STREET

SIMI VALLEY, CA 93063PRO SE

L. THEODORE HOPPE ,

JR.HOPPE & MARTIN LLP423 MCFARLAN RD STE100



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KENNETT SQUARE, PA19348610-444-2001Email:[email protected]

ATTORNEY TO BENOTICED

Defendant

NEIL SANKEY represented by NEIL SANKEY4230 ALAMO STREETSIMI VALLEY, CA 98063PRO SE

L. THEODORE HOPPE ,

JR.

(See above for address)ATTORNEY TO BE

NOTICED

Defendant

JAMES SUNDQUISTTERMINATED: 06/26/2009

represented by JAMES SUNDQUIST551 VALLEY ROAD,PMB #123MONTCLAIR, NJ 07043PRO SE

DefendantROCK SALT PUBLISHING

Defendant

LINDA SUE BELCHERa/k/a LINDA S. BELCHER a/k/a LINDA

STARR; a/k/a NEWWOMENSPARTY a/k/a

STITCHENWITCH a/k/a EVA BRAUN a/k/a

WEB SERGEANT a/k/a KATY a/k/a

WWW.OBAMACITIZENSHIPDEBATE.ORG

represented by LINDA SUE BELCHER210 PARIS STREETCASTROVILLE, TX78009PRO SE

L. THEODORE HOPPE ,

JR.(See above for address)ATTORNEY TO BE

NOTICED

Defendant

EDGAR HALE represented by EDGAR HALE



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a/k/a JD SMITH 1401 BOWIEWELLINGTON, TX 79095PRO SE

L. THEODORE HOPPE ,


NOTICED

Defendant

CAREN HALE represented by CAREN HALE1401 BOWIEWELLINGTON, TX 79095PRO SE

L. THEODORE HOPPE ,JR.(See above for address)ATTORNEY TO BE

NOTICED

Defendant

PLAINS RADIO NETWORKa/k/a PLAINS RADIO NETWORK, INC.

a/k/a PLAINS RADIO

represented by L. THEODORE HOPPE ,JR.(See above for address)ATTORNEY TO BE

NOTICED

Defendant

BAR H FARMS represented by L. THEODORE HOPPE ,JR.(See above for address)ATTORNEY TO BE

NOTICED

Defendant

KPRN AM 1610 represented by L. THEODORE HOPPE ,


NOTICED

Defendant

DOES 1 THROUGH 200 INCLUSIVE



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V.

Movant

J. JOHNSON represented by J. JOHNSON

2600 BRINKLEY ROADPH 1005FORT WASHINGTON,MD 20744PRO SE

Date Filed # Docket Text

05/04/2009 1 COMPLAINT against defts' ORLY TAITZ, DEFEND OURFREEDOMS FOUNDATIONS, INC., YOSEF TAITZ, THESANKEY FIRM, SANKEY INVESTIGATIONS, INC., NEIL

SANKEY, JAMES SUNDQUIST, ROCK SALT PUBLISHING,LINDA SUE BELCHER, EDGAR HALE, CAREN HALE,PLAINS RADIO NETWORK, BAR H FARMS, KPRN AM 1610( Filing fee $ 350 receipt number PPE000127.), filed by plffs' GOEXCEL GLOBAL, LISA LIBERI, PHILIP J. BERG, THE LAWOFFICES OF PHILIP J. BERG, EVELYN ADAMS, LISA M.OSTELLA. ( FILED IN HARD COPY ) (gn, ) Modified on5/5/2009 (gn, ). (Additional attachment(s) added on 8/4/2010: #1Part 2) (gn, ). (Entered: 05/04/2009)

05/04/2009 Summons Issued as to ORLY TAITZ, DEFEND OUR

FREEDOMS FOUNDATIONS, INC., YOSEF TAITZ, THESANKEY FIRM, SANKEY INVESTIGATIONS, INC., NEILSANKEY, JAMES SUNDQUIST, ROCK SALT PUBLISHING,LINDA SUE BELCHER, EDGAR HALE, CAREN HALE,PLAINS RADIO NETWORK, BAR H FARMS, KPRN AM 1610.Given To: counsel on 5/4/09 (gn, ) Modified on 5/4/2009 (gn, ).(Entered: 05/04/2009)

05/04/2009 2 Disclosure Statement Form pursuant to FRCP 7.1 by GO EXCELGLOBAL, LISA LIBERI, PHILIP J. BERG, THE LAWOFFICES OF PHILIP J. BERG, EVELYN ADAMS, LISA M.OSTELLA.(gn, ) (Entered: 05/04/2009)

05/04/2009 3 EMERGENCY MOTION FOR AN INJUNCTION AND/ORTEMPORARY RESTRAINING ORDER, FILED BY PLFFS' GOEXCEL GLOBAL, LISA LIBERI, PHILIP J. BERG, THE LAWOFFICES OF PHILIP J. BERG, EVELYN ADAMS, LISA M.OSTELLA. ( FILED IN HARD COPY ) (gn, ) Modified on5/5/2009 (gn, ). (gn, ). (Entered: 05/04/2009)

https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=29&dm_id=7588971&doc_num=1&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=29&dm_id=7588971&doc_num=1&pdf_header=1https://ecf.paed.uscourts.gov/doc1/15318098151https://ecf.paed.uscourts.gov/doc1/15318098151https://ecf.paed.uscourts.gov/doc1/15318098151https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=35&dm_id=5133334&doc_num=2&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=35&dm_id=5133334&doc_num=2&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=37&dm_id=5855581&doc_num=3&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=37&dm_id=5855581&doc_num=3&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=37&dm_id=5855581&doc_num=3&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=35&dm_id=5133334&doc_num=2&pdf_header=1https://ecf.paed.uscourts.gov/doc1/15318098151https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=29&dm_id=7588971&doc_num=1&pdf_header=1


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05/04/2009 4 Memorandum in support of plff's motion for EmergencyInjunction and/or Temporary Restraining Order, filed by plffs' GOEXCEL GLOBAL, LISA LIBERI, PHILIP J. BERG, THE LAWOFFICES OF PHILIP J. BERG, EVELYN ADAMS, LISA M.OSTELLA, Proof of Service. ( FILED IN HARD COPY ) (gn, )

Modified on 5/5/2009 (gn, ). (Additional attachment(s) added on8/4/2010: #1Part 1, #2Part 2) (gn, ). (Entered: 05/04/2009)

05/04/2009 5 Minute Entry for proceedings held before HONORABLEEDUARDO C. ROBRENO: Motion for Temporary RestrainingOrder held on 5/4/09. ESR Reporter: Joseph Matkowski. (gn, )(Entered: 05/05/2009)

05/07/2009 6 SUMMONS Returned Executed by GO EXCEL GLOBAL, LISALIBERI, THE LAW OFFICES OF PHILIP J. BERG, EVELYNADAMS, LISA M. OSTELLA re: Don Clayton served Summonsand Complaint upon ORLY TAITZ by personal service. ORLY

TAITZ served on 5/4/2009, answer due 5/26/2009. (gn, ) (Entered:05/08/2009)

05/07/2009 7 SUMMONS Returned Executed by GO EXCEL GLOBAL, LISALIBERI, PHILIP J. BERG, THE LAW OFFICES OF PHILIP J.BERG, EVELYN ADAMS, LISA M. OSTELLA re: Don Claytonserved Summons and Complaint upon DEFEND OURFREEDOMS FOUNDATIONS, INC., YOSEF TAITZ by personalservice. DEFEND OUR FREEDOMS FOUNDATIONS, INC.served on 5/5/2009, answer due 5/26/2009; YOSEF TAITZ servedon 5/5/2009, answer due 5/26/2009. (gn, ) (Entered: 05/08/2009)

05/07/2009 8 SUMMONS Returned Executed by GO EXCEL GLOBAL, LISALIBERI, PHILIP J. BERG, THE LAW OFFICES OF PHILIP J.BERG, EVELYN ADAMS, LISA M. OSTELLA re: Bob Shultzserved Summons and Complaint upon THE SANKEY FIRM,SANKEY INVESTIGATIONS, INC., NEIL SANKEY bypersonal service. THE SANKEY FIRM served on 5/5/2009,answer due 5/26/2009; SANKEY INVESTIGATIONS, INC.served on 5/5/2009, answer due 5/26/2009; NEIL SANKEYserved on 5/5/2009, answer due 5/26/2009. (gn, ) (Entered:05/08/2009)

05/07/2009 9 SUMMONS Returned Executed by GO EXCEL GLOBAL, LISALIBERI, PHILIP J. BERG, THE LAW OFFICES OF PHILIP J.BERG, EVELYN ADAMS, LISA M. OSTELLA re: Joe servedSummons and Complaint upon EDGAR HALE, CAREN HALE,PLAINS RADIO NETWORK, BAR H FARMS, KPRN AM 1610by personal service. EDGAR HALE served on 5/7/2009, answerdue 5/27/2009; CAREN HALE served on 5/7/2009, answer due

https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=39&dm_id=7588147&doc_num=4&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=39&dm_id=7588147&doc_num=4&pdf_header=1https://ecf.paed.uscourts.gov/doc1/15318097282https://ecf.paed.uscourts.gov/doc1/15318097282https://ecf.paed.uscourts.gov/doc1/15318097282https://ecf.paed.uscourts.gov/doc1/15318097283https://ecf.paed.uscourts.gov/doc1/15318097283https://ecf.paed.uscourts.gov/doc1/15318097283https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=45&dm_id=5162701&doc_num=6&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=45&dm_id=5162701&doc_num=6&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=47&dm_id=5162879&doc_num=7&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=47&dm_id=5162879&doc_num=7&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=49&dm_id=5162951&doc_num=8&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=49&dm_id=5162951&doc_num=8&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=51&dm_id=5163031&doc_num=9&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=51&dm_id=5163031&doc_num=9&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=51&dm_id=5163031&doc_num=9&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=49&dm_id=5162951&doc_num=8&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=47&dm_id=5162879&doc_num=7&pdf_header=1https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=45&dm_id=5162701&doc_num=6&pdf_header=1https://ecf.paed.uscourts.gov/doc1/15318097283https://ecf.paed.uscourts.gov/doc1/15318097282https://ecf.paed.uscourts.gov/cgi-bin/show_doc.pl?caseid=302150&de_seq_num=39&dm_id=7588147&doc_num=4&pdf_header=1


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5/27/2009; PLAINS RADIO NETWORK served on 5/7/2009,answer due 5/27/2009; BAR H FARMS served on 5/7/2009,answer due 5/27/2009; KPRN AM 1610 served on 5/7/2009,answer due 5/27/2009. (gn, ) (Entered: 05/08/2009)

05/11/2009 10 SUMMONS Returned Executed by GO EXCEL GLOBAL, LISALIBERI, PHILIP J. BERG, THE LAW OFFICES OF PHILIP J.BERG, EVELYN ADAMS, LISA M. OSTELLA re: LANACOPELAN served Summons and Complaint upon LINDA SUEBELCHER by Personal Service. LINDA SUE BELCHER servedon 5/5/2009, answer due 5/26/2009. (stb, ) (Entered: 05/12/2009)

05/22/2009 11 AFFIDAVIT of Service by Richard Minervino re: servedSummons, Complaint, Motion for Injunction and/or TempRestrainnig Order, Memorandum of Law in Support of Motion forInjunction or temp. TRO, Proposed Order upon James Sundquistthrough his wife Karen Sundquist by Personal on May 21, 2009

(BERG, PHILIP) (Entered: 05/22/2009)

05/22/2009 12 AFFIDAVIT of Service by Richard Minervino re: servedSummons, Complaint, Motion for Injunction and/or TempRestrainnig Order, Memorandum of Law in Support of Motion forInjunction or temp. TRO, Proposed Order upon Rock SaltPublishing through James Sundquist by Personal on May 21, 2009(BERG, PHILIP) (Entered: 05/22/2009)

05/22/2009 13 SUMMONS Returned Executed by GO EXCEL GLOBAL, LISALIBERI, PHILIP J. BERG, THE LAW OFFICES OF PHILIP J.BERG, EVELYN ADAMS, LISA M. OSTELLA re: RichardMinervino served Summons and Complaint upon JAMESSUNDQUIST by Personal. JAMES SUNDQUIST served on5/21/2009, answer due 6/10/2009. (BERG, PHILIP) (Entered:05/22/2009)

05/22/2009 14 SUMMONS Returned Executed by THE LAW OFFICES OFPHILIP J. BERG re: Richard Minervino served Summons andComplaint upon ROCK SALT PUBLISHING by Personal. ROCKSALT PUBLISHING served on 5/21/2009, answer due 6/10/2009.(BERG, PHILIP) (Entered: 05/22/2009)

05/22/2009 15 AFFIDAVIT of Service by Don Clayton re: served EmergencyMotion for Injunction and/or Temp Restrainnig Order,Memorandum of Law in Support of Motion for Injunction or temp.TRO, Proposed Order upon Orly Taitz through the person inCharge, Lila Dubert by Substituted Service on May 4, 2009(BERG, PHILIP) (Entered: 05/22/2009)

05/22/2009 16 AFFIDAVIT of Service by Lana Copeland re: served Emergency

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Motion for Injunction and/or Temp Restrainnig Order,Memorandum of Law in Support of Motion for Injunction or temp.TRO, Proposed Order upon Linda Sue Belcher by Personal onMay 5, 2009 (BERG, PHILIP) (Entered: 05/22/2009)

05/22/2009 17 AFFIDAVIT of Service by Joe Dale Stewart re: served EmergencyMotion for Injunction and/or Temp Restrainnig Order,Memorandum of Law in Support of Motion for Injunction or temp.TRO, Proposed Order upon Caren Hale by Personal on May 7,2009 (BERG, PHILIP) (Entered: 05/22/2009)

05/22/2009 18 AFFIDAVIT of Service by Joe Dale Stewart re: served EmergencyMotion for Injunction and/or Temp Restrainnig Order,Memorandum of Law in Support of Motion for Injunction or temp.TRO, Proposed Order upon Edgar Hale by Personal on May 7,2009 (BERG, PHILIP) (Entered: 05/22/2009)

05/22/2009 19 AFFIDAVIT of Service by Joe Dale Stewart re: served EmergencyMotion for Injunction and/or Temp Restrainnig Order,Memorandum of Law in Support of Motion for Injunction or temp.TRO, Proposed Order upon KPRN AM 1610, Plains Radio, Inc.,and Bar H Farms by Personal on May 7, 2009 (BERG, PHILIP)(Entered: 05/22/2009)

05/22/2009 20 AFFIDAVIT of Service by Bob Shultz re: served EmergencyMotion for Injunction and/or Temp Restrainnig Order,Memorandum of Law in Support of Motion for Injunction or temp.TRO, Proposed Order upon Neil Sankey, The Sankey Firm, andSankey Investigations, Inc. by Personal on May 5, 2009 (BERG,PHILIP) (Entered: 05/22/2009)

05/22/2009 21 AFFIDAVIT of Service by Don Clayton re: served EmergencyMotion for Injunction and/or Temp Restrainnig Order,Memorandum of Law in Support of Motion for Injunction or temp.TRO, Proposed Order upon Defend our Freedoms Foundation, Inc.by Substituted Service on May 5, 2009 (BERG, PHILIP) (Entered:05/22/2009)

05/22/2009 22 AFFIDAVIT of Service by Don Clayton re: served EmergencyMotion for Injunction and/or Temp Restrainnig Order,

Memorandum of Law in Support of Motion for Injunction or temp.TRO, Proposed Order upon Yosef Taitz by Substituted Service onMay 5, 2009 (BERG, PHILIP) (Entered: 05/22/2009)

05/26/2009 23 ANSWER AND MOTION TO DISMISS, FILED BY DEFTNEIL SANKEY, SANKEY INVESTIGATIONS, AND SANKEYINVESTIGATIONS INC., with jury demand, AFFIDAVIT,CERTIFICATE OF SERVICE. (gn, ) Modified on 5/26/2009 (gn,

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). Modified on 5/26/2009 (gn, ). (Entered: 05/26/2009)

05/26/2009 24 ANSWER AND MOTION TO DISMISS, FILED BY DEFTLINDA SUE BELCHER, with jury demand, AFFIDAVIT,CERTIFICATE OF SERVICE. (gn, ) Modified on 5/26/2009 (gn,

). (Entered: 05/26/2009)05/26/2009 25 ANSWER AND MOTION TO DISMISS, FILED BY DEFTS

EDGAR HALE, CAREN HALE, jury demand, AFFIDAVITS,CERTIFICATE OF SERVICE.(gn, ) Modified on 5/26/2009 (gn,). (Entered: 05/26/2009)

05/26/2009 26 STIPULATION of Dismissal without prejudice by YOSEFTAITZ. (MILLER, BRAD) (Entered: 05/26/2009)

05/27/2009 27 Request for Default JudgmentEntry, Request for Entry of Default;Declaration of Philip J. Berg, Esquire in support thereof;

Certificate of Service and Proposed Entry of Default OrderGOEXCEL GLOBAL, LISA LIBERI, PHILIP J. BERG, THE LAWOFFICES OF PHILIP J. BERG, EVELYN ADAMS, LISA M.OSTELLA against ORLY TAITZ, DEFEND OUR FREEDOMSFOUNDATIONS, INC.. (BERG, PHILIP) Modified on 5/28/2009(nd). (Entered: 05/27/2009)

05/27/2009 28 Request for Default JudgmentEntry, Request for Entry of Default,Declaration of Philip J. Berg, Esquire in Support thereof;

Certificate of Service; and Proposed Entry of Default OrderLISALIBERI against THE SANKEY FIRM. (BERG, PHILIP)Modified on 5/28/2009 (nd, ). (Entered: 05/27/2009)

05/27/2009 DEFAULT BY ORLY TAITZ, DEFEND OUR FREEDOMSFOUNDATIONS, INC., THE SANKEY FIRM FOR FAILURETO APPEAR, PLEAD OR OTHERWISE DEFEND. (gn, )Modified on 6/29/2009 (gn, ). ( STRICKEN PURSUANT TOPAPER #79) (Entered: 05/28/2009)

05/27/2009 Default Entered (gn, ) Modified on 6/29/2009 (gn, ). ( STRICKENPURSUANT TO PAPER #79) (Entered: 05/28/2009)

05/28/2009 29 STIPULATION AND ORDER OF DISMISSAL WITHOUTPREJUDICE OF DEFENDANT YOSEF TAITZ THAT ALL

CLAIMS AGAINST DEFENDANT YOSEF TAITZ AREHEREBY DISMISSED WITHOUT PREJUDICE, ETC.COUNSEL FOR DEFENDANT YOSEF TAITZ SHALLCONTINUE TO BE INCLUDED ON THIS COURT'S DOCKETFOR PURPOSES OF RECEIVING ALL FILINGS, AND SHALLBE PERMITTED TO PARTICIPATE IN ALL DISCOVERYPROCEEDINGS. SIGNED BY HONORABLE EDUARDO C.

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ROBRENO ON 5/28/09. 5/28/09 ENTERED AND COPIESMAILED TO UNREPS AND PRO SE, E-MAILED.(lisad, )(Entered: 05/28/2009)

05/28/2009 30 Request for Default Judgment LISA LIBERI against ORLY

TAITZ. (BERG, PHILIP) (COPY FORWARDED TO CLERKFOR APPROVAL) Modified on 5/29/2009 (md). (Entered:05/28/2009)

05/28/2009 35 MOTION TO DISMISS DUE TO LACK OF JURISDICTION,FILED BY ORLY TAITZ, DEFEND OUR FREEDOMSFOUNDATIONS, INC.(gn, ) (Entered: 05/29/2009)

05/28/2009 36 Opposition to Injunction, filed by ORLY TAITZ, DEFEND OURFREEDOMS FOUNDATIONS, INC., Certificate of Service. (gn,) (Additional attachment(s) added on 5/29/2009: #1opposition)(gn, ). Modified on 6/3/2009 (gn, ). (Entered: 05/29/2009)

05/28/2009 37 ANSWER to1Complaint, by ORLY TAITZ, DEFEND OURFREEDOMS FOUNDATIONS, INC., Certificate of Service.(gn, )(Entered: 05/29/2009)

05/28/2009 48 MOTION TO SET ASIDE DEFAULT, FILED BY DEFT ORLYTAITZ, CERTIFICATE OF SERVICE.(gn, ) (Entered:06/08/2009)

05/29/2009 31 Request for Default Judgment, Declaration in support thereof;certificate of service; and proposed Default JudgmentLISALIBERI against DEFEND OUR FREEDOMS FOUNDATIONS,

INC.. (BERG, PHILIP) (COPY FORWARDED TO CLERK FORAPPROVAL) Modified on 5/29/2009 (md). (Entered: 05/29/2009)

05/29/2009 32 Declaration re30Request for Default JudgmentRequest forDefault Judgment, Declaration in support thereof; Certificate of

Service; and Proposed Default Judgmentby LISA LIBERI.(BERG, PHILIP) (Entered: 05/29/2009)

05/29/2009 33 Request for Default Judgment ; Declaration in support thereof;Certificate of Service; and Proposed Default JudgmentLISALIBERI against THE SANKEY FIRM. (BERG, PHILIP) (COPYFORWARDED TO CLERK FOR APPROVAL) Modified on

5/29/2009 (md). (Entered: 05/29/2009)

05/29/2009 34 Request for Default Judgment ; Declaration in support thereof;Certificate of Service; and Proposed Default JudgmentLISA M.OSTELLA against ORLY TAITZ. (BERG, PHILIP) (COPYFORWARDED TO CLERK FOR APPROVAL) Modified on5/29/2009 (md). (Entered: 05/29/2009)

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05/29/2009 38 ORDER THAT A STATUS AND SCHEDULINGCONFERENCE WITH THE PARTIES WILL TAKE PLACE ON6/25/2009 AT 10:30 AM IN COURTROOM 11A. ( SIGNED BYHONORABLE EDUARDO C. ROBRENO ON 5/28/09. ) 5/29/09ENTERED AND COPIES MAILED, E-MAILED.(gn, ) (Entered:

05/29/2009)

06/02/2009 39 Request for Default Judgment ; Declaration in support thereto;Certificate of Service; and Proposed Judgment by Default OrderPHILIP J. BERG against ORLY TAITZ. (BERG, PHILIP)(Entered: 06/02/2009)

06/02/2009 40 Request for Default Judgment ; Declaration in support thereof;Certificate of Service; and Default Judgment OrderPHILIP J.BERG against DEFEND OUR FREEDOMS FOUNDATIONS,INC.. (BERG, PHILIP) (Entered: 06/02/2009)

06/02/2009 41 Request for Default Judgment ; Declaration in support thereof;Certificate of Service; and Proposed Default JudgmentTHE LAWOFFICES OF PHILIP J. BERG against DEFEND OURFREEDOMS FOUNDATIONS, INC.. (BERG, PHILIP) (Entered:06/02/2009)

06/07/2009 42 Request for Default Judgment ; Declaration in support thereto;Certificate of Servcie; and Proposed Default Judgment OrderTHE LAW OFFICES OF PHILIP J. BERG against ORLY TAITZ.(BERG, PHILIP) (Entered: 06/07/2009)

06/07/2009 43 Request for Default Judgment ; Declaration in Support thereto;

Certificate of Service; and Proposed Judgment by Default OrderGO EXCEL GLOBAL against ORLY TAITZ. (BERG, PHILIP)(Entered: 06/07/2009)

06/07/2009 44 Request for Default Judgment ; Declaration in Support thereto;Certificate of Service; and Proposed Default Judgment OrderEVELYN ADAMS against DEFEND OUR FREEDOMSFOUNDATIONS, INC.. (BERG, PHILIP) (Entered: 06/07/2009)

06/07/2009 45 Request for Default Judgment ; Declaration in Support thereto;Certificate of Service; and Proposed Default Judgment OrderEVELYN ADAMS against ORLY TAITZ. (BERG, PHILIP)(Entered: 06/07/2009)

06/07/2009 46 Request for Default Judgment ; Declaration in Support thereto;Certificate of Service; and Proposed Default Judgment OrderLISA M. OSTELLA against DEFEND OUR FREEDOMSFOUNDATIONS, INC.. (BERG, PHILIP) (Entered: 06/07/2009)

06/08/2009 47 Request for Default Judgment ; Declaration in Support thereto;

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