liberi v taitz (appeal) - request for judicial notice document 00319985848 transport room

8/14/2019 LIBERI v TAITZ (APPEAL) - Request for Judicial Notice Document 00319985848 Transport Room

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U.S. District Court,Eastern District of Pennsylvania Case Number: 09-cv-01898 ECR

Court of Appeals No. 09-3403

UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT__________________________

LISA LIBERI, et al,

Plaintiffs Appellants,

v.

ORLY TAITZ, et al,

Respondents Appellees.

_________________________

APPELLANTS REQUEST FOR JUDICIAL NOTICE_____________________

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

Please Take Notice that Appellants, Lisa Liberi [hereinafter Liberi];

Philip J. Berg, Esquire [hereinafter Berg], the Law Offices of Philip J. Berg;

Evelyn Adams a/k/a Momma E [hereinafter Adams]; Lisa Ostella [hereinafter

Ostella]; and Go Excel Global by and through their undersigned counsel, Philip

J. Berg, Esquire, hereby submits this Request for Judicial Notice of a copy of

Appellee, Orly Taitz, et als website located at www.orlytaitzesq.com showing she

has again republished on January 14, 2010 her Dossier #6 that contains Appellant,

Lisa Liberis Social Security number and other private information. For this

Case: 09-3403 Document: 00319985848 Page: 1 Date Filed: 01/17/2010


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reason, Appellants have not included a copy of the Dossier #6 on Appellee, Orly

Taitz, et als website. On June 25, 2009, Judge Robreno specifically ordered

Appellee Orly Taitz, Esq. not to republish Appellant, Lisa Liberis Social Security

number.

Appellants request this Court to take Judicial Notice, pursuant to Federal

Rules of Evidence 201, of the copy of Appellee, Orly Taitz, et als website with the

attached screen shot photo attached hereto as EXHIBIT A.

The copy of Orly Taitz, et als website and the print screen photo are

imperative to the within as it shows further publication of Appellant, Lisa Liberis

Social Security number, date of birth and other confidential information, that

Appellee Taitz was Ordered by Judge Robreno on June 25, 2009 not to republish

Appellant Liberis Social Security number.

Moreover, Appellee Orly Taitz, et al filed this same Dossier #6 in an

unrelated matter,Keyes, et al v. Obama, et al, in the United States District Court,

Central District of California, Southern Division, Case No. SAC 09-00082-DOC

(ANx). Appellants counsel, Philip J. Berg, Esquire, sent a letter to Judge David O.

Carter, the Judge which Appellee Taitzs case was in front of, and requested the

Court to seal Dossier #6 filed by Ms. Taitz. Judge David O. Carter, issued said

Order on September 30, 2009 and not only sealed Dossier #6, but Ordered

Appellee Taitz to re-file her documents with all date of births and Social Security



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numbers redacted. Judge David O. Carters Order is attached hereto and

incorporated in by reference as EXHIBIT B. Appellants previously filed a

request for Judicial Notice of Judge David O. Carters September 30, 2009 Order.

A judicially noticed fact must be one not subject to reasonable dispute in

that it is either (1) generally known within the territorial jurisdiction of the trial

court or (2) capable of accurate and ready determination by resort to sources whose

accuracy cannot reasonably be questioned. Fed. R. Evid. 201(b); Easy

Sportswear, Inc. v. Am. Econ. Ins. Co., 2008 U.S. Dist. LEXIS 51402 (W.D. Pa.

2008);Nationwide Life Ins. Co. v. Commonwealth Land Title Ins. Com., 2005 U.S.

Dist. LEXIS 24479 (E.D. Pa. 2005);In re NAHC, Inc. Sec Litig, 306 F.3d 1315 (3d

Cir. 2002) [a] court shall take judicial notice if requested by a party and supplied

with the necessary information. Fed. R. Evid. 201(d),Easy Sportswear, Inc., 2008

U.S. Dist. LEXIS 51402 (W.D. Pa 2008) at *2.

It is firmly established that Requests for Judicial Notice are proper only to

the extent that the noticed facts are relevant to an issue that is before the Court.

The attached copy of Appellee, Orly Taitz, et als website and print screen photo,

which Appellants are requesting Judicial Notice of, are of the type that have

previously been admitted by Judicial Notice in the Third Circuit. This includes

documents integral to or explicitly relied upon in the Plaintiffs Complaint and the

reasons Plaintiffs were forced to bring suit against the Appellees. The attached



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copy of Appellee, Orly Taitz, et als website and print screen photo are directly

related to this within action and are relevant to the issues herein. Moreover, the

attached copy of Appellee Taitzs website and the print-screen photo attached as

EXHIBIT A show Appellee Taitzs disregard for the lower Courts Orders and

warnings and her continued publication of information that is in no way public. Li

Hua Bai v. AG of the United States, 2009 U.S. App. LEXIS 28501 (3d Cir. Dec.

28, 2009).

For the above aforementioned reasons, Appellants respectfully request this

Honorable Court to take Judicial Notice of the copy and print screen of Appellee

Orly Taitzs website showing her republication on January 14, 2010 of Appellant

Lisa Liberis social security number, date of birth and other private confidential

information.

Respectfully submitted,

Dated: January 17, 2010 ____________________________Philip J. Berg, Esquire

555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531

(610) 825-3134

Attorney for the Appellants

s/ Philip J. Berg



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http://www.orlytaitzesq.com/

Home Comments are disabled due to malicious hacking attempts.

Dr. Orly Taitz Esquire

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

Rancho Santa Margarita CA, 92688 Copyright 2009

World's Leading Obama Eligibility Challenge Web

Site

Your donations to the cause are much appreciated.

Posted on | January 14, 2010 |

Dossie#1

Dossier#3

Dossie#5RSM

Dossier#6

http://www.orlytaitzesq.com/wp-content/uploads/2010/01/Dc279.doc

Dossier #6 is a hyperlink above which takes you to the actual dossier #6 with Lisa Liberi's

social security number and other private confidential information. This dossier #6 was

republished on Thursday, January 14, 2010 after being instructed by Judge Robreno on

June 25, 2009 not to republish Lisa Liberi's social security number. When you click on the

Dossier#6 hyperlink on Orly Taitz, et al's website above, it takes you to:


This is a copy of Orly Taitz, et al's actual website located at www.orlytaitzesq.com



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http://www.orlytaitzesq.com/

This is a print screen of Orly Taitz, et al's actual website located at www.orlytaitzesq.com

Dossier #6 is a hyperlink above which takes you to the actual dossier #6 with Lisa Liberi's

social security number and other private confidential information. This dossier #6 was

republished on Thursday, January 14, 2010 after being instructed by Judge Robreno on

June 25, 2009 not to republish Lisa Liberi's social security number. When you click on the



Dossier#6 hyperlink on Orly Taitz, et al's website above, it takes you to:



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EXHIBIT B



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Case 8:09-cv-00082-DOC-AN Document 77 Filed 09/30/2009 Page 1 of 5Case: 09-3403 Document: 00319985848 Page: 9 Date Filed: 01/17/2010


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U.S. District Court,Eastern District of Pennsylvania Case Number: 09-cv-01898 ECR

Court of Appeals No. 09-3403

UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT

__________________________

LISA LIBERI, et al,

Plaintiffs Appellants,

v.

ORLY TAITZ, et al,

Respondents Appellees.

__________________________

CERTIFICATE OF SERVICE_____________________

I, Philip J. Berg, Esquire, hereby certify that Appellants Request for Judicial

Notice was served upon Appellees, this 17th day of January 2010 electronically

upon the following:

Orly Taitz

Defend our Freedoms Foundation, Inc. (unrepresented)

26302 La Paz Ste 211Mission Viejo, CA 92691

Email: [email protected]



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CERTIFICATE OF SERVICE, Continued

Neil SankeyThe Sankey Firm, Inc. a/k/a The Sankey Firm (unrepresented)

Sankey Investigations, Inc.2470 Stearns Street #162

Simi Valley, CA 93063


Linda Sue Belcher

201 Paris

Castroville, Texas 78009Email: [email protected] and


Ed HaleCaren Hale

Plains RadioKPRN

Bar H Farms

1401 Bowie Street

Wellington, Texas 79095Email: [email protected];[email protected];

ed@barhfarnet; and [email protected]

________________________

PHILIP J. BERG, ESQUIRE

s/ Philip J. Berg


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