LIBERI, et al. v TAITZ, et al.- Open Document ECF FILER: Request for Judicial Notice of Judge...

8/14/2019 LIBERI, et al. v TAITZ, et al.- Open Document ECF FILER: Request for Judicial Notice of Judge David O. Carter's September 21, 2009 Order - 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

the attached Court Order of United States District Court, Central District of California, Judge David

O. Carter, directing Orly Taitz [Defendant / Appellee in this case] to remove Dossier #6, which

contains Appellant Lisa Liberis Social Security number, date of birth and other personal identifying

information filed in the ECF filing system by Orly Taitz on September 21, 2009, in a case unrelated

to Appellant Lisa Liberi.

Case: 09-3403 Document: 00319882493 Page: 1 Date Filed: 10/31/2009


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Evidence 201, of the following document which is a Court Order issued by Judge David O.

Carter, Judge in the United States District Court for the Central District of California, Southern

Division filed in Pacer, the Federal Docketing System, on September 30, 2009 in the Case of

Barnett, et al v. Obama, et al, Case No. 8:09-cv-00082 as Document number seventy-seven [77].

personal identifying information filed in the ECF filing system by Ms. Taitz on September 21,

2009 by October 2, 2009.

to republish Liberis Social

Security number, date of birth, mothers maiden name, place of birth, and other personal private

identifying information.

this Honorable Court to take Judicial Notice of Judge Carters 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 (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

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

Judge Carters Order is directing attorney Orly Taitz [Appellee in this case] to remove Dossier

#6, which contains Appellant Lisa Liberi 's Social Security number, date of birth and other

In this case, Appellee, Orly Taitz, et al filing of Dossier #6 was addressed in this Court

on June 25, 2009 and Judge Robreno warned Appellee Taitz not

Security number. Despite this, Appellee Taitz has continued republication of Liberis Social

Judge Carters Order is attached hereto as EXHIBIT A and AppellantsH hereby request



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information. Fed. R. Evid. 201(d) (emphasis added) Easy Sportswear, Inc., 2008 U.S. Dist.

LEXIS 514002 (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. Judge Carters Order that

is a Court Order issued by a United States District Court Federal Judge directly related to this

action and is relevant to the issues herein. See In re Ravisent Techs., Inc. Sec. Litig., 2004 U.S.

Dist. LEXIS 132355 (D. Pa. 2004)

Court to take Judicial Notice of Judge David O. Carters Order dated September 30, 2009

attached hereto as EXHIBIT A.

Respectfully submitted,

Philip J. Berg, Esquire

555 Andorra Glen Court, Suite 12

Lafayette Hill, PA 19444-2531(610) 825-3134

Appellants' are requesting Judicial Notice is of the type that Judicial Notice has been taken of by

the Third Circuit. This includes documents integral to or explicitly relied upon in the Appellants

Complaint and the reasons Appellants ' were forced to bring suit against the Appellees '. In

addition, the attached document, EXHIBIT A that Appellants are requesting Judicial Notice of

For the above aforementioned reasons, Appellant s respectfully request this Honorable

ated: October 31, 2009 ____________________________

Attorney for the Appellants



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EXHIBIT A



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Case 8:09-cv-00082-DOC-AN Document 77 Filed 09/30/2009 Page 1 of 5Case: 09-3403 Document: 00319882493 Page: 5 Date Filed: 10/31/2009


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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 31st

day of October 2009 electronically and/or by first class mail

upon the following:

Orly TaitzDefend our Freedoms Foundation, Inc. (unrepresented)

26302 La Paz Ste 211

Mission Viejo, CA 92691Email: [email protected]

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

Sankey Investigations, Inc.

2470 Stearns Street #162

Simi Valley, CA 93063Email: [email protected]



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CERTIFICATE OF SERVICE, Continued

Linda Sue Belcher

201 ParisCastroville, Texas 78009

Email: [email protected] and

Email: [email protected]

Ed Hale

Caren 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


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