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    EXHIBIT "E"

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    Case No. 10-3000

    _______________________________________________________

    UNITED STATES COURT OF APPEALSFOR THE THIRD CIRCUIT

    _______________________________________________________

    LISA LIBERI, et al,

    Plaintiffs Appellees,

    v.

    ORLY TAITZ, et al,

    Respondents Appellants.

    ______________________________________________________

    On Appeal from the U.S. District Court, Eastern District of Pennsylvania,Case No. 09-cv-01898 ECR Judge Eduardo C. Robreno

    ____________________________________________________

    AFFIDAVIT OF SHIRLEY WADDELL

    Philip J. Berg, EsquirePennsylvania I.D. 9867555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531Ph: (610) 825-3134

    Fx: (610) 834-7659Email: [email protected]

    Attorney for Appellees

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    One category A great woman! Compared Liberi to llseKoch as told by Herr Dr. Josef Mengele aka Angel of Deathin the nazi concentration camps. Taken from wikipedia.

    One category Me ! Me! All about me! Was supposed to beLiberi talking about her life, marriage etc. Which was actuallycopied from the life of llse Koch in Wikipedia. Please seehttp://en.wikipedia.org/wiki/Ilse_Koch. They wrote how Liberienjoyed abusing the prisoners, and watched, as they would rapeone another.

    2. Other Websites picked up on this disgusting, offensive, vulgar website

    of http://lisaliberi.com very fast. Whois is an Internet directory service for

    looking up names of people on a remote server. At first Whois said that the

    registration was private. After this matter was cleared up and when the

    website paperwork" first started coming in, it showed on the paperwork from

    Whois that it was Geoff Staples [hereinafter at times "Staples"] that set up the

    website http://lisaliberi.com with a fake address of 123 Secret Dr. As the

    paperwork kept coming in from Whois it showed that the account had been

    originally set up in the name of Lisa Liberi by Geoff Staples. The response

    from the PDR (Public Domain Registration) showed that the Registration

    Service Provider was Nairobi Web Host. Registrant was Hostricity Web

    Hosting at 3883 Turtle Creek Blvd., Suite 205, Dallas Texas 75219 U. S. A.

    Geoffrey Tyler Staples owns Hostricity Web Hosting. As of the date of this

    affidavit, we are still waiting for more paperwork on this

    Domain/Website/Email.

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    3. The written contents within the category/articles are changed from

    time to time by Staples, Belcher and Taitz. A Detective from Dallas PD has

    already talked to Staples, and Staples admitted that all three of them (Linda

    Belcher [hereinafter at times "Belcher"], Orly Taitz [hereinafter at times

    "Taitz"], and Staples) are involved in this Domain/Website/Email conspiracy to

    do harm to Liberi. Since other websites picked up on Whois, and Public

    Domain Registration, and Geoffrey Staples name became public on November

    23, 2010, the threesome (Taitz, Staples, and Belcher) then decided to call the

    website a parody website. This was printed at bottom of website page (to them

    this made it a parody), and an article entitled Some people cant take a joke

    was added to website.

    4. Liberi found out that emails from [email protected]

    were being sent out to people that were in her Computer AOL database on

    November 22, 2010. The only way that anyone could have these names was to

    have hacked into Liberis computer. Liberi notified the lower Court a few

    months back about her computer being hacked. Taitz was posting a family

    picture of Liberi on Taitzs website, Facebook and on Pacer with Judge

    Robrenos Court, and the only way that Taitz could have gained access to this

    photograph was to have hacked into Liberis computer. This computer

    hacking either by Taitz or orchestrated by Taitz has now proven to be true with

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    these emails being sent to Liberis AOL contacts, and posted family picture that

    was on Liberis computer and later posted by Taitz at many locations.

    5. In June 2010 Judge Robreno severed the Liberi v Taitz case and

    ordered part of the case to Texas and part to California. Orly Taitz appealed to

    the Third Circuit Court of Appeals. Orly Taitz, a licensed attorney, continued

    to file documents in Judge Robrenos Court knowing that Judge Robreno had

    closed the case in June and the transfer of the case was being Appealed by her.

    Taitz also knew that only the documents filed prior to her Notice of Appeal

    would be reviewable by Appellate Judges. Taitz knew that documents on Pacer

    were being uploaded by Scribd.com/jack ryan, and being read by her viewers.

    Taitz, being dishonest and unethical, again seized the opportunity to file

    document after document of untrue, prejudicial, inflammatory material in her

    attempt to arouse the emotions, and prejudices of her followers. Taitz then

    served everybody and their cat with these filings with the exception of Mr.

    Berg. She sent copies of these filings to Federal Judges in Southern California

    where the Liberi v. Taitz case is being transferred with the intent of obstructing

    justice, see EXHIBIT "2" . Within these documents were filings that Taitz

    presented to the Court as Notarized Affidavits, which did not have proper

    Notary stamp, Notary acknowledgment, and Notary information. Taitz, a

    licensed attorney, presented documents from Geoffrey Tyler Staples that were

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    forged/altered/manufactured in order to frame Lisa Liberi, in another attempt to

    have her (Liberi) falsely arrested. These documents were also stolen from the

    financial database of Mr. Berg when Staples worked for Mr. Berg a very short

    while in 2008. Orly Taitz, a licensed attorney, also published these documents

    on Pacer without redacting the sensitive information of the Berg supporters.

    6. When Taitz would file these documents on Pacer of Judge Robrenos

    Court after the transfer order and after Taitzs appeal, then Mr. Berg would

    have to answer Taitzs filing in order to protect the Plaintiffs (Appellees). Mr.

    Bergs filed documents would disprove the false claims of Taitz. Taitz would

    then vindictively post something about Liberi that would be of a defaming,

    slanderous nature, and/or try to get everyone riled up against Liberi. Taitz

    would then start filing more documents on Pacer of lower Court Judge

    Robrenos Court. Mr. Berg did ask for a temporary restraining order, and

    sanctions in order to stop this behavior of Taitz but there was never an answer

    from lower Court Judge Robreno. Finally on October 26, 2010 (Exhibit 2),

    Mr. Berg wrote a letter to all of the people that Taitz was sending copies of her

    filings (Proof of Service List), and asked them not to read the material from

    Taitz that it was intended for Judge Robrenos Court. Mr. Berg also mentioned

    all of the crimes committed by Taitz, that a temporary restraining order was

    needed, and asked for their help in stopping Taitz. A day or so later, Judge

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    Robreno then issued an order that any letters or motions were to be filed in the

    Third Circuit Court of Appeals, not in his Court.

    7. Taitz does background checks on individuals without a permissible

    purpose, and uses this information for her benefit. She wanted Liberi to do her

    legal work the latter part of 2008, and both Liberi and Mr. Berg did not want to

    be involved with Taitz because of her unethical, and illegal ways. Mr. Berg

    also was having problems with Geoff Staples and Linda Belcher during the

    latter part of 2008. I remember the first of January 2009 that Taitz was posting

    on her blog Does anyone know how to get in touch with Linda Starr?

    Would someone have Linda Starr to call me. Linda Starr is one of the many

    names that Linda Belcher uses to post on websites. Taitz is the one that sought

    out Linda Belcher for the purpose of causing harm to Mr. Berg and Liberi.

    Approximately the same time frame, Taitz wanted Lisa Ostella [hereinafter at

    times "Ostella"] to lie to law enforcement about Taitzs website being hacked,

    Ostella refused, and Taitz posted all over accusing Ostella of stealing along

    with other accusations.

    8. Taitz posted Liberis Social Security number, mothers maiden name,

    fathers name, birth date, place of birth, all together on the Internet. Taitz also

    mailed, emailed, and faxed this information internationally on numerous

    occasions within a document that Taitz called Dossier 6. Taitz and Sankey also

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    emailed, posted, and faxed Liberis sensitive information in other documents.

    Taitz intentionally set Liberi up to live the horrors of multiple Identity Thefts to

    where Liberi would be financially ruined beyond restoration, falsely accused of

    crimes and never be able to live a peaceful life as Lisa Liberi. Taitz also posted

    Liberis husband's Social Security number and other sensitive information to set

    him up.

    9. Mr. Berg filed suit in May 2009. Taitz and Neil Sankey [hereinafter

    at times "Sankey"] continued the attack on Liberi, Ostella and Berg. May 28,

    2009 Sankey spoke on Ed Hales Radio Blog show and told everyone that Liberi

    had over 200 criminal counts against her, she was convicted of selling and

    reselling her home, and the outrageous lies continued for the duration of the

    Sankey visit. On another radio show with Ed Hale and Linda Belcher, they

    were making fun of Liberi having a heart attack. Linda Belcher was saying

    Look, look, there comes the ambulance now, she is holding her chest, she is

    going down. These radio tapes were filed in Court and are on record with

    lower Court Judge Robreno.

    10. Liberi v Taitz came before Judge Robreno on June 25, 2009. Taitz, a

    licensed attorney, and officer of the Court, was asked by Judge Robreno on two

    separate occasions if she had published Liberis Social Security number. On

    page 39, lines 16 through 21 of June 25, 2009 Court Transcript Taitz told Judge

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    Robreno that she had never posted Liberis Social Security number and she had

    proof of that. She said that she would never publish any private facts, or

    anything libelous. She said that she has never slandered anybody, and she has

    never published anything untrue. On Page 40, lines 7-10, Taitz again told

    Judge Robreno that she had not posted Liberis social security number. On

    Page 40 line 20 Taitz began her rhetoric of being from a Communist country

    and how important to have transparency in government. She went on to say

    that However, you dont achieve transparency in government by submitting

    2009 Court Transcript attached hereto as EXHIBIT "3" . Orly Taitz introduced

    Judge Robreno to her law clerk, Dr. Charles Lincoln III. Dr. Charles Lincoln

    III was an attorney that had been disbarred from about three or four states, and

    had spent quite a bit of time behind bars. Approximately August 1, 2009, it was

    reported in a few Affidavits that Yosef Taitz had sent a forged birth certificate

    of President Obama to Orly Taitz. Yosef Taitz had acquired this birth

    certificate from the Mossad. Orly Taitz knew that this birth certificate was

    forged, and presented the document as genuine in Federal Judge Carters Court

    in Santa Ana, CA. Federal Judge Carter commented in his Order that he had

    also received Affidavits that Orly Taitz had suborned perjury.

    documents prepared by a convicted forger of documents, see the June 25,

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    11. Judge Robreno evidently did not read the Affidavits, or view the many

    documents supplied to him regarding Taitzs postings. He took Orly Taitz at

    her word.

    12. On page 70, lines 2-6 Judge Robreno denied Temporary Restraining

    Order. Judge Robreno said it would be a serious problem if there were any

    publication of the Social Security number of anyone in this case, and stated I

    think that would tip the equity significantly. On Page 70, lines 7-18, Judge

    Robreno said that to the extent that Ms. Liberis may be subject to some

    controversy as to which number belongs to her that he would advise the

    defendants to publish no social security numbers of anyone. Page 70, lines 11-

    14, Judge Robreno said that it serves no purpose whatsoever to publish

    someones Social Security in this day and age. That it inflicts harm that is

    unrelated to the case, and it is unwise and improper to do so. Page 70, lines 15 -

    18, Judge Robreno said that he thought the defendants should take that to heart.

    Judge Robreno said that to the extent that this has happened, he did not know

    whether or not it has happened, but it should not happen in the future. Page 71,

    lines 11-14, Judge Robreno also said that there would be no further motions

    filed in the case without leave of Court. Leave of Court should be sought by

    way of a letter to the Court and the Court will then consider whether or not the

    attached motion should be filed of record. Page 71, lines 23-25 Judge Robreno

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    said that his written order controls over anything said on the Bench. Page 72,

    Judge Robreno told Mr. Berg if there is a violation of what he had advised the

    parties then Mr. Berg was to bring it to Judge Robrenos attention.

    13. After the June 25 th hearing, Taitz posted on her website that Judge

    Robreno told Berg to put up or shut up, and implied that Judge Robreno found

    the Defendants to be in the right. Taitz completely ignored Judge Robrenos

    Order. Taitz continued her business as usual with publishing Dossier 6 with

    Liberis social security number, trashing Liberi, Ostella, and Berg on radio,

    with postings, whoever would listen. She also started posting on approximately

    June 27 th, 2009 that Liberi murdered her sister. She posted for everyone to

    call Santa Fe Police Department, Coroner and get information on my daughter

    that died, and she posted the telephone numbers, see EXHIBIT "4" . She said

    that the police knew that Liberi killed her sister but police could not prove it.

    She also published Santa Fe Probation departments telephone numbers and

    names to contact and demand that Liberi be put in jail. The pounding was

    constant on Liberi and Ostella. Of course the above Taitz postings were untrue

    and hurtful.

    14. Dr. Charles Lincoln III stated in an Affidavit that after the June 25 th

    Court hearing, Taitz had him to drive her around New Jersey. The routes taken

    were right next to where Ostella resided and her children attended school. He

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    was also driving Taitz to different police stations where Taitz was filing false

    police reports on Liberi and Ostella, see EXHIBIT "5" . Two individuals

    called Ostella and told her that Taitz was talking at a ResistNet meeting

    (white supremacist group supposedly started by a friend of Defendant Ed Hale)

    about professionally kidnapping Ostella's children. Affidavit of Ostella is filed

    with lower Court.

    15. Taitz did not follow the rules of Court. Mr. Berg would submit a

    letter to the Court asking for leave of Court to file a motion but Taitz would just

    file a motion without asking for leave of Court. Judge Robreno did nothing.

    Taitz kept filing frivolous documents for the benefit of her followers, which had

    nothing to do with the lawsuit whatsoever. Sankey and Taitz also filed forged

    emails that they claimed to be from Ostella. Taitz maintained her attack toward

    the Plaintiffs. The above documents have been filed with the lower Court.

    16. Mr. Berg again went into Court August 2009 for a TRO. Taitz did

    not attend due to a media tour in Russia and Israel. Dr. Charles Lincoln III,

    acting as Taitz Law Clerk filed documents on Taitz's behalf. Plaintiffs were

    present to testify, and some witnesses. Affidavits and recording tapes with

    transcripts were produced by Plaintiffs that contained threats from Ed Hale

    toward the Plaintiffs and witnesses, Judge Robrenos Order of August 3 rd, 2010,

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    denied the TRO. Judge Robreno did nothing regarding the Taitz Violations"

    that Judge Robreno had told Mr. Berg to bring to his attention.

    17. Mr. Berg appealed to the Third Circuit of Appeals on approximately

    August 17 th, 2009, see Liberi v Taitz, Case No. 09-3403. This was held up for

    months due to the inability of Mr. Berg to get a Court Transcript for the Court

    hearing of August 7 th, 2009 from a Joan Carr, Court reporter, in Judge

    Robrenos Court. Marsha Waldron, Clerk USCA, issued a RULE TO SHOW

    CAUSE upon Joan Carr USDC. This problem with Joan Carr was still going

    on approximately the end of February 2010, and six months had already been

    wasted. Finally, Mr. Berg withdrew the appeal so the Plaintiffs could move

    forward. Nothing had been accomplished. Taitz was still posting her

    slanderous remarks about Liberi and Ostella, misquoting and distorting facts

    filed in the case, trying to incite her followers against Liberi. Taitz kept filing

    her frivolous documents, which she would post on her website, and then file on

    pacer for Scribd.com/jack ryan to upload for public view. Mr. Berg would

    have to answer Taitz filings to protect his Plaintiffs, and asking Judge Robreno

    to uphold the Court Rules.

    18. In June 2010 Robreno severed the case. Some mistakes were made

    within Judge Robrenos order, but Mr. Berg brought this matter to Judge

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    Robrenos attention, and Judge Robreno corrected the mistakes, which further

    delayed the judicial process.

    19. Judge Robreno transferred the case of Defendant Taitz and Defend

    our Freedoms Foundations, Inc. (DOFF), and the Sankey Defendants to

    Southern California, and the Hale Defendants and Belcher to Texas. The

    Court Transcript of June 25, 2009 pages 31 through 34 has attorney Mr.

    Hoppe speaking about Jurisdiction and Venue. Mr. Hoppe said that he felt that

    the proper place would be California and Texas. Page 31, line 8, to page 34 line

    10 . On page 48, line 1-9, Taitz told Judge Robreno that the proper place for

    Venue/Jurisdiction would be California. However, Taitz later appealed Judge

    Robrenos Order to transfer Sankey/Taitz (DOFF) to California. Taitz did not

    ask for a Stay of Transfer, however Judge Robrenos Court did not start the

    transfer of records to Southern California and Texas. I do not know why.

    20. Taitzs appeal is nothing more than a delaying tactic to be able to

    hash, bash, and pound on Berg, Liberi and Ostella by utilizing the Courts

    electronic filing system PACER to disseminate her documents of lies,

    uploaded by Scribd.com/jack ryan and then onto the Internet. The Appellate

    Court only needs to check their docket and see the content of the documents

    filed by Taitz. The documents do not pertain to Taitzs Appeal, and do not

    reflect the factual content of Affidavits, evidence, and Court Transcripts.

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    21. Taitz stepped up her cyber stalking, and cyber bullying attacks to

    daily postings after Judge Robrenos Transfer Order. Taitz hired actors to do

    videos, which appeared to be news reporters reporting about Berg, Liberi, and

    Ostella. The contents of the videos were all lies but did appear authentic.

    David Acton was one of the actors. Taitz started posting that Lisa Liberi

    should be in jail, posted pictures, addresses, phone numbers, and made threats.

    Accused Liberi of keeping Taitz from doing her job for the people regarding

    Obama. She would hash and bash on radio shows, saying that she had

    supplied the pictures and given directions. At every opportunity she would

    make remarks that Liberi should be gotten rid of. Meanwhile, Liberi and

    Ostella endure continued harassment and daily anxiety over the safety of

    themselves, and their families. Liberi and her husband are experiencing many

    problems with continued identity theft, which, among other obvious things,

    makes it difficult to supply the necessary funds for my grandsons college

    education, and daily needs.

    22. The physical effects on Liberis heart alone, due to the anxiety and

    emotional stress caused by Taitz and associates have mounted into the hundreds

    of thousands of dollars in emergency care, hospital care, and daily care. The

    immediate family has also been affected by the terrorist actions of Taitz.

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    23. Since November 10 th, 2010 Taitz has quieted down with

    defaming/slandering Liberi on Taitzs website. She is still posting a picture of

    Liberi with a defaming/slandering article on her many Facebook accounts that

    have been up for months. Facebook has been notified but has not taken any

    action. As I mentioned at the beginning of this Afidavit, Taitz, Belcher and

    Staples have now set up a Domain/Website/Email in the name of Lisa Liberi at

    http://lisaliberi.com and Email of [email protected] and

    [email protected] . They hacked into Liberis computer and are

    sending emails to her AOL contacts. Law enforcement reports have been filed

    in three different states regarding this website. Law enforcement talked with

    Staples, and Staples admitted that Belcher and Taitz were involved.

    24. All of the postings, radio shows, and other events referenced herein

    are on file with the lower Court. If this Court would like to see Taitz's postings

    directly, then please go to www.orlytaitzesq.com , in the search box, put either

    Liberi, Ostella or Berg, and pages of disgusting posts will come up. In the

    event that Taitz decides to delete postings from her wesbsite, there are copies of

    all the postings filed in the lower Court's docket.

    25. I have read that Taitzs MO (method of operation) tactics and belief

    are that the end justifies the means, and is a philosophy that is promoted by

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    Communism, and the Mossad. Taitz was born, and raised to adulthood as a

    Communist, and there are reports that she has links to the Mossad.

    26. I believe that most Americans think as Ayn Rand (1905 1982) who

    said: " I do not believe that the end justifies the means. No ones rights can be

    secured by the violation of the rights of others. "

    27. Taitz will continue to delegate and/or execute terrorist attacks

    against Liberi, Ostella, and Berg, until she is stopped. We are praying that the

    Court Order's the Domain/Website/Email to be removed, and a Restraining

    Order of some type to be put in force to deter future retaliatory, harassing,

    threatening, dangerous, and abusive actions against the Plaintiffs (Appellees)

    and their witnesses.

    I declare under the penalty of Perjury of the laws of the United States that

    the foregoing is true and correct. Executed this ____ day of December 2010.

    __________________________ Shirley Waddell, Affiant

    s/ Shirley Waddell(Signature sent by fax - see attached)

    6th

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    17

    CALIFORNIA ALL PURPOSECERTIFICATE OF ACKNOWLEDGEMENT

    State of California )

    On December _____, 2010, before me, Name of Notary

    Personally appeared Shirley Waddell, proved to me on the basis of satisfactory

    evidence to be the person whose name is subscribed to the within instrument and

    acknowledged to me that she executed the same in her authorized capacity; and

    that by her signature on the instrument the person, or the entity upon behalf of

    which the person acted, executed the instruction.

    I certify under PENALTY OF PERJURY under the laws of the State of California

    that the foregoing paragraph is true and correct.

    WITNESS my hand and official seal.

    Notary

    County of Sacramento )

    Signature (Seal)

    s/ Cyndi Nguyen

    Cyndi Nguyen6

    (Signature and Seal received by fax -see attached paged)

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    EXHIBIT "1"

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    From: [email protected]

    Sent: Wed, Nov 10, 2010 11:25 amSubject: Fwd: Good morning, Convicted Felon

    I just received this email in my AOL inbox, can anyone detect where it camefrom? I have attached the header info

    -----Original Message-----From: [email protected]: [email protected]

    Sent: Wed, Nov 10, 2010 10:37 amSubject: Good morning, Convicted Felon

    Love your new website.

    Yours,

    Convicted Felon

    To: [email protected]; [email protected]

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    EXHIBIT "2"

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    Z:\Liberi Ltr regarding Taitz's Criminal Acts 1

    LAW OFFICES OF PHILIP J. BERG

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

    PHILIP J. BERGCATHERINE R. BARONEBARBARA MAY

    (610) 825-3134

    FAX (610) 834-7659

    NORMAN B. BERG, Paralegal [Deceased] E-Mail: [email protected]

    October 26, 2010

    Honorable Eduardo C. Robreno Hon. James SecordUnited States District Court Deputy District Attorney for the Eastern District of Pennsylvania San Bernardino County11614 U.S. Courthouse 316 North Mountain View

    601 Market Street San Bernardino, CA 92415-0004Philadelphia, PA 19106-1797 Sent via Regular Mail

    San Bernardino County Probation Dept.Philadelphia District Attorneys Office 175 W. Fifth Street, 4 th Floor Three South Penn Square San Bernardino, CA 92415-0460Corner of Juniper and South Penn Square Sent via Fax to (909) 387-5600Philadelphia, PA 19107-3499

    Sent via Regular MailChief Judge Audrey B. Collins

    U.S. Attorney's Office U.S.D.C., Central District of CA

    615 Chestnut Street Courtroom 680Suite 1250 255 East Temple StreetPhiladelphia, PA 19106 Los Angeles, CA 90012

    Sent via Fax to (215) 861-8618 Sent via Regular Mail

    Social Security Administration Judge David O. Carter6401 Security Blvd. Courtroom 9DBaltimore, MD 21235 U.S.D.C. Central District of CA,

    Sent via Regular Mail Southern Division411 west Fourth Street

    Public Integrity Section Santa Ana, CA 92701-4516

    Department of Justice Sent via Regular Mail950 Pennsylvania Ave., NWWashington, D.C. 20530-0001 U.S. Attorney's Office

    Sent via Regular Mail 312 North Spring StreetLos Angeles, California 90012

    Sent via Regular Mail

    Re: Orly Taitz's Obstruction of Justice and other Criminal Acts

    Sent via Fax to (267) 299-5113

    Case: 10-3000 Document: 003110370449 Page: 25 Date Filed: 12/06/2010

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    Re: Orly Taitz Obstruction of Justice and other Criminal Acts October 26, 2010Page Two

    I represent Plaintiffs, Evelyn Adams, Philip J. Berg, Esq., Lisa Liberi, Lisa Ostella, LawOffices of Philip J. Berg, and Go Excel Global in a case against Orly Taitz and other Defendants. TheCase was filed in the U.S. District Court, Eastern District of PA, Case No. 09-cv-01898 before theHonorable Eduardo C. Robreno. This Case was brought due to illegal behaviors of Defendant Taitzand the other Defendants.

    I am sending this letter to each of you as Orly Taitz has now been obstructing justiceand attempting to prejudice and conflict out the very Court this case has been orderedtransferred to by sending copies of letters and filings to you. My request is that these documentsshould not be read by anyone other than the Honorable Eduardo C. Robreno. Further, Ibelieve a Restraining Order should be issued against Orly Taitz to stop her current tactics andSanctions should be imposed against her as she is an attorney who should know better.

    On June 3, 2010, Judge Robreno Ordered the Case Transferred to the U.S. District Court,Central District of California, Southern Division against the California Defendants and to the U.S.District Court, Western District of Texas against the Texas Defendants. Due to some inconsistencies, Ifiled a Motion for Reconsideration of this Order, which was Granted in part by Judge Robreno. JudgeRobreno amended (corrected) his Order on June 22, 2010, which maintained the Transfer of the Caseto the U.S. District Court, Central District of CA and the U.S. District Court, Western District of Texas.

    Since this time, Orly Taitz's behaviors have intensified against the Plaintiffs, especiallyPlaintiffs Lisa Liberi and Lisa Ostella. Orly Taitz's behaviors include but are not limited to Cyber-stalking; Cyber-bullying; harassment; stalking; inchoate offenses; forgery; false law enforcementreports; attempting to have Lisa Liberi and Lisa Ostella falsely arrested based on falsified allegations;which Plaintiffs Lisa Liberi and Lisa Ostella are the victims.

    Moreover, Orly Taitz has been attempting to intimidate/retaliate against a Witness for Plaintiffs, Shirley Waddell to deter her from testifying in the Civil Case.

    Since Judge Robreno's Order of June 22, 2010 Transferring this Case, Orly Taitz Appealedthe Ruling, said Appeal is in the U.S. Court of Appeals for the Third Circuit. However, Orly Taitz hascontinued filing frivolous documents with Judge Robreno's Court, which include many falsifiedstatements; falsified information pertaining to the Civil Case pending against her; forged and altereddocuments in the name of Plaintiff Lisa Liberi and Lisa Ostella, and falsified recitations of pleadingsfiled by Plaintiffs, just to name a few.

    In so doing, Orly Taitz has been sending her filings containing many falsified statementsforged and altered documents to all parties listed above for absolutely no permissible purpose other than to continue her harassment of the Plaintiffs and to attempt to conflict out or prejudice the Judge'sin the U.S. District Court, Central District of California, Southern Division, the very Court this Case is

    being Transferred to. And, attempting to have Plaintiffs Lisa Liberi and Lisa Ostella falsely arrestedon falsified allegations.

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    Re: Orly Taitz Obstruction of Justice and other Criminal Acts October 26, 2010Page Three

    Again, Orly Taitz began sending all her falsified statements, falsified recitations of pleadingsfiled by the Plaintiffs; forged and altered documents, etc., which she filed in Judge Robreno's Court toall the parties listed in this letter, including the Chief Judge of the U.S. District Court, Central Districtof California as well as Judge Carter, U.S. District Court, Central District of California, SouthernDivision after Judge Robreno's June 22, 2010 Order Transferring this Case to the U.S. District Court,Central District of California, Southern Division. See Judge Robreno's June 22, 2010 Opinion andOrder attached hereto as EXHIBIT "A" . See Orly Taitz's "Certificate of Services" for 7/29/2010;9/8/2010; 9/28/2010; and 10/21/2010 attached hereto as EXHIBIT "B" .

    This is extremely concerning as Orly Taitz continues breaking State and Federal Laws. Notonly am I concerned regarding the prejudices this creates for my clients, I am extremely concernedabout the safety of my clients.

    Orly Taitz's filing of false statements (perjury) as well as forged and altered documents in thename of Plaintiffs Lisa Liberi and Lisa Ostella also constitutes Obstruction of Justice, Perjury, Forgeryand other criminal acts.

    Orly Taitz is an attorney licensed in the State of California and is well aware her actions, behaviors and activities are illegal and constitute crimes, for which she must be prosecuted.

    I would appreciate any assistance for my clients in order to stop the illegal behaviors of OrlyTaitz.

    Please do not hesitate contacting me should you require anything additional.

    Thank you.

    Respectfully,

    Philip J. BergPJB:jb

    Enclosures

    cc: Orly Taitz26302 La Paz Ste 211Mission Viejo, CA 92691Ph: (949) 683-5411Fax: (949) 586-2082 Sent via Regular Mail

    Case: 10-3000 Document: 003110370449 Page: 27 Date Filed: 12/06/2010

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    Z:\Liberi Ltr regarding Taitz's Criminal Acts 4

    EXHIBIT "A"

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    IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIA

    LISA LIBERI, et al., : CIVIL ACTION: NO. 09-1898

    Plaintiffs, ::

    v. ::

    ORLY TAITZ, et al., ::

    Defendants. :

    M E M O R A N D U M

    EDUARDO C. ROBRENO, J. June 22, 2010

    I. BACKGROUND

    On May 4, 2009, Plaintiffs Lisa Liberi (Liberi),

    Philip J. Berg, Esq. (Berg), the Law Offices of Philip J. Berg,

    Evelyn Adams a/k/a Momma E (Adams), Lisa Ostella (Ostella),

    and Go Excel Global (collectively, Plaintiffs) initiated this

    defamation, libel and slander action against Defendants Orly

    Taitz (Taitz), Defend our Freedoms Foundations, Inc. (DOFF),

    Neil Sankey, The Sankey Firm and Sankey Investigations, Inc.

    (collectively, "Sankey"), Edgar Hale, Caren Hale, Plains Radio,

    KPRN AM 1610, Bar H. Farms, Plains Radio Network (collectively,

    the Hales), and Linda Sue Belcher (collectively, Defendants).

    On June 3, 2010, the Court severed the action and

    transferred the claims to each Defendants home jurisdiction.

    Before the Court is Plaintiff Bergs motion for leave to file a

    motion for reconsideration (doc. no. 120), Defendant Taitzs

    response (doc. no. 121) and Defendant Sankeys response (fax

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    -2-

    dated 6/11/10). On June 18, 2010, Plaintiff Berg filed a motion

    for leave to file a motion to strike Defendant Taitzs response

    (doc. no. 122).

    II. MOTION FOR RECONSIDERATION

    A. Legal Standard

    A motion for reconsideration is treated as the

    functional equivalent of a motion pursuant to Rule 59(e) which

    seeks to alter or amend a judgment. Fed. Kemper Ins. Co. v.

    Rauscher, 807 F.2d 345, 348 (3d Cir. 1986) (internal citation

    omitted). The purpose of a motion for reconsideration is to

    correct manifest errors of law or fact or to present newly

    discovered evidence. Harsco Co. V. Zlotnicki, 779 F.2d 906, 909

    (3d Cir. 1985). Reconsideration is appropriate where the party

    seeking reconsideration establishes (1) an intervening change in

    the controlling law; (2) the availability of new evidence that

    was not available when the court . . . [issued its previous

    decision]; or (3) the need to correct a clear error of law or

    fact or prevent manifest injustice. Maxs Seafood Cafe ex rel.

    Lou Ann v. Quinteros, 176 F.3d 669, 677 (3d Cir. 1999); North

    River Ins. Co. v. CIGNA Reinsurance Co., 52 F.3d 1194, 1218 (3d

    Cir. 1995); U.S. v. Cabiness, 278 F. Supp. 2d 478. 483-84 (E.D.

    Pa. 2003) (Robreno, J.).

    B. Proposed Grounds for Reconsideration

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    Defendant Taitzs response does not substantively1

    address Plaintiff Bergs motion for leave to file a motion forreconsideration, thus it is inapposite to the issues at bar.

    Defendant Sankeys letter disputes Plaintiff Liberisassertions of Pennsylvania citizenship and argues that Plaintiff

    Liberi is a citizen of New Mexico. See Sankey Ltr., dated June11, 2010. However, diversity jurisdiction would only bedestroyed if Plaintiff Liberi was a citizen of either of thestates of which Defendants are citizens: California or Texas.Thus, the issue is inapposite to Plaintiff Bergs motion forleave to file a motion for reconsideration and the legalconclusions reached in this case.

    -3-

    On June 7, 2010, Plaintiff Berg faxed a motion for

    leave to file a motion for reconsideration. See doc. no. 120

    (docketed 6/13/10). Defendant Taitz responded by fax on June 10,

    2010 and Defendant Sankey responded by fax on June 11, 2010. See

    Taitz 6/10/10 Ltr., doc. no. 121 (docketed 6/14/10); see also

    Sankey 6/11/10 Ltr. Mr. Sankeys response was not filed of

    record. 1

    In his letter, Plaintiff Berg lists eight purported

    errors in the Court's 6/3/10 Order that severed the action and

    transferred the claims to each of Defendants home jurisdictions.

    Upon review, Plaintiff Berg actually raises only three discrete

    issues. Importantly, Plaintiff Bergs motion does not argue that

    the legal conclusions set forth in the Memorandum were incorrect.

    The three outstanding administrative errors raised by

    Plaintiff Berg are grouped as follows.

    1. Points 6, 8 and 9

    Points 6, 8 and 9 are as follows:

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    -4-

    Point 6: There is a discrepancy in the Courts Order ofJune 3, 2010, docketed on June 4, 2010appearing as Docket Entry No. 118;

    Point 8: Amendment of this Courts June 3, 2010 Order,docketed June 4, 2010, appearing, as DocketEntry No. 118 is proper. This Court has theinherent Power to amend its Final Judgment;and

    Point 9: A proposed Order is attached to PlaintiffsMotion.

    See Berg Mot. Reconsideration 2, doc. no. 120.

    These notations are not relevant to the legal

    disposition of this case. Therefore, Points 6, 8 and 9 will be

    denied.

    2. Points 1, 2, 3, 4 and 5

    Points 1, 2, 3, 4 and 5 are as follows:

    Point 1: This Court concedes on page two (2), second(2nd) paragraph of the Courts Memorandum[Doc. No. 117] that the Sankey Defendants,which would be Neil Sankey, SankeyInvestigations, Inc. and The Sankey Firm, Inc.a/k/a The Sankey Firm are citizens andresidents of the State of California;

    Point 2: Defendants Neil Sankey and SankeyInvestigations, Inc. are not within thejurisdiction of the U.S. District Court,Western District of Texas, but instead arelocated in the Central District of California;

    Point 3: Although in Default, the Court made no mentionof transfer as to Defendant, The Sankey Firm,

    Inc. a/k/a The Sankey Firm. Is the Courtplanning on keeping this one Defendant andallowing Plaintiffs to enter Default againstthem?; If not then,

    Point 4: The Sankey Firm, Inc. a/k/a The Sankey Firm isa California Corporation, in the U.S. District

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    -5-

    Court, Central District of California,Southern Division jurisdiction. Therefore,transfer of Plaintiffs claims against thisDefendant is only proper to the U.S. DistrictCourt, Central District of California,Southern Division; and

    Point 5: Defendants Neil Sankey, Sankey Investigations,Inc. and The Sankey Firm, Inc. a/k/a TheSankey Firm conducted the offenses giving riseto this suit from their office locations inCalifornia.

    See id. at 1-2.

    The final Memorandum correctly identifies Defendants

    Neil Sankey, The Sankey Firm and Sankey Investigations, Inc. as

    citizens of California; however, the original Order, dated June

    3, 2010, incorrectly transferred their case to Texas instead of

    California. The enclosed Amended Order corrects this error and

    transfers Neil Sankey, The Sankey Firm and Sankey Investigations,

    Inc. to the Southern Division of the Central District of

    California.

    No prejudice has resulted because the cases have not

    yet been transferred and the error has no impact on the legal

    conclusions reached in this case. Therefore, Plaintiff Bergs

    motion for reconsideration is granted as to Points 1-5.

    3. Point 7

    Point 7 is as follows:

    Point 7: None of the Parties to this Action asked forseverance of the Case; The Courts Orderstates Defendants Motion to Transfer isGranted; and on page two (2) statesDefendants Motion to Dismiss or, in the

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    -6-

    alternative, Motion to Transfer (doc. No. 10)is Denied as Moot. First, Doc. No. 10 is anAffidavit of Service, not a Motion to Dismissor in the alternative to Transfer. It isbelieved the Court meant Plaintiffs Motion toTransfer is Granted, as Plaintiffs had apending Motion to Transfer the Case.

    See id. at 2.

    In Point 7, Plaintiff Berg requests that Defendants

    motion to dismiss or, in the alternative, motion to transfer

    (doc. nos. 24, 25) be denied as moot. However, in its 6/25/09

    Order, the Court already denied Defendants motion to dismiss or,

    in the alternative, motion to transfer (doc. nos. 24, 25). See

    Ct. 6/25/09 Order, doc. no. 77.

    Currently, there are no motions pending that have not

    been previously denied as moot. As such, Point 7 will be denied

    as moot. See docket.

    III. CONCLUSION

    Plaintiff Bergs motion for leave to file a motion for

    reconsideration will be granted. Points 1, 2, 3, 4 and 5 of the

    motion for reconsideration will be granted and Points 6, 7, 8 and

    9 will be denied as moot.

    Plaintiff Bergs motion for leave to file a motion to

    strike Defendant Taitzs response will be denied as moot.

    An amended Order follows.

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    On June 25, 2009, the Court issued an order that no1

    further motions shall be filled without prior leave of the Court.See Court Order, doc. no. 78. No motions granted leave to fileare currently pending.

    IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIA

    LISA LIBERI, et al., : CIVIL ACTION: NO. 09-1898

    Plaintiffs, ::

    v. ::

    ORLY TAITZ, et al., ::

    Defendants. :

    AMENDED ORDER

    AND NOW , this 22nd day of June, 2010 , it is hereby

    ORDERED that the Court Order, dated June 3, 2010, is AMENDED as

    follows. On June 25, 2009, the Court issued a rule to show cause

    upon Plaintiff as to why this case should not be (1) dismissed

    for lack of personal jurisdiction; (2) severed into three or

    fewer cases against the following groups or Defendants: (i) the

    Hales; (ii) Belcher; (iii) Taitz, DOFF, and Sankey; and (3)

    transferred to an appropriate district in either Texas or

    California, pursuant to 28 U.S.C. 1404(a). See Court Order, 1

    doc. no. 80.

    IT IS FURTHER ORDERED that, upon consideration of

    Plaintiffs responses to the rule to show cause, Defendants

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    All requests for leave to file pleadings submitted2

    during the time the case was in suspense from December 9, 2009 toJune 4, 2010 , of which only one letter was made part of thedocket (see Berg Letter in Opp'n to Def. Taitz, dated Jan. 10,2010, doc. no. 116), are denied as moot.

    - 2 -

    replies thereto and Plaintiff Berg's motion for reconsideration,

    the Court will now SEVER the instant case into two separate,

    independent actions and TRANSFER each action to the jurisdiction

    of the following district courts. All claims pending against

    Defendants Linda Sue Belcher, Edgar Hale, Caren Hale, Plains

    Radio Network, Bar H. Farms, and KPRN A.M. 1610 are transferred

    to the Western District Court of Texas. All claims pending

    against Defendants Orly Taitz, Defend Our Freedoms Foundations,

    Neil Sankey, The Sankey Firm and Sankey Investigations, Inc. are

    transferred to the Southern Division of the Central District of

    California. 2

    IT IS FURTHER ORDERED that this case shall be marked

    CLOSED .

    AND IT IS SO ORDERED.

    s/Eduardo C. Robreno

    EDUARDO C. ROBRENO, J.

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    EXHIBIT "B"

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    09/17/2029 06:03 110493 P.001/080

    Dr. Orly Taib, EsqAttorney Pro Se & AttorneyFor Defelld Our FreedolDl Foundation29839 Santa Margari1a Parkway, Suite 100Randlo Sa ta Margarita CA 92688

    Tel: (949) ~ 5 4 1 1 ;Fa x (949) 7"-7603E-Mail: d r _ [email protected]

    IN THE UNITED STATES DISTRICT COURT

    FO R THE EASTERN DISTRICf OF PENNSYLVANIA

    LISA LmERI, et at., ) Response to tbe 07.26.10. emergency motioplaintiffs to keep tnmscnpseal

    ) Motion fo r clarification an d motion-reques) fo r order to show cause, wby sanctions sh) be assessed against parties defrauding the)b y ciaivtiog that Judge Robreno issued an

    Pla.iD.tiffs )"order" to seal transcript of Liberi v Taitt j..... ;) forwarded to the Third Circuit court of Appeals ~ )

    v. )) District Court ease # 09-cv- 01898-ER ',... __ .t

    ORL Y TAITZ, et at,) Court of Appeals number case #09-3403

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    BaCkground of the ease . ' ~ O " ' 1 J i -~Due to the great importance of this. matter. and fraud being perpetrated on the US District

    Court as well as the Court of Appeals, and due to the fact that the plaintiff here Lisa

    Liberi is cur.rently on probation in the state of CA as a result of 10 felony convictions of

    forgery, forgery of an official seal and gmnd theft, this motion is addressed to the

    presiding judge The Hon Eduardo Robreno; as well as the Chief Judge of US District

    Court for the Eastern District of Pennsylvania The Hon Harvey Bartle, i l l ; and the Chief

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    09/17/2029 08:08

    San Bernardino CA 92415-0004

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    www.co.san-bemardino.ca.uslda

    San Bernardino County, CA

    Probation Department

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    Chief Judge

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    Judge David O. Carter

    USDC Central Dis1rict of CA

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    Liberi v Taitz Motion for Clarification 38

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    09/17 /2029 06 :09

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    Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 57 of 58Case: 10-3000 Document: 003110370449 Page: 51 Date Filed: 12/06/2010

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    EXHIBIT "3"

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    EXHIBIT "4"

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    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 c laims and allegations in the articles.

    I am back from PA. Very Important.Posted on | June 27, 2009 | 5 Comments

    I appreciate everybody calling and e-mailing and texting to make sure I am OK. I am OK.I had to go to PAto appear at the hearing in the garbage law suit filed by Philip Berg. My wireless connection didnt work there, I couldnt blog.

    I returned yesterday at 12:30 and and was doing a radio show in VA with Chuck Chrismayer. You can reachhim at 800-754-1822 or 804-677-2783, he will have archives of the show.

    ack from PA. Very Important. | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?p=2585

    http://www.orlytaitzesq.com/?p=2585

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    I had to work from 1-5:30 and later wanted to have dinner and spend some time with my family.

    In regards to Berg things are going well. Judge denied all of his motions for default judgment against me andclerical default was lifted, he gave me a pro hac vice to represent my foundation, denied all of Bergs motionsfor injunction against me and, what is most important he ordered Berg to show cause, why his case should not

    be dismissed due to lack of jurisdiction. For those of you, who are not attorneys, it is a very good sign that the judge is very inclined to dismiss Bergs case due to lack of jurisdiction. I would like to explain that if the caseis filed out of state, the first thing that is being reviewed, is jurisdiction. It doesnt mean that the case has any

    merit aside from jurisdiction, it means that this court cannot hear it. I believe Berg filed it in PA to simplycause me to waste time and money, going to Philly. At any rate, I am not concerned about this frivolous lawsuit, I am though concerned about something else.

    On the plane to Philly I read hundreds of pages of transcripts in criminal case hearings of Liberi. Keep inmind that recently I had threats to shoot me and burn my body for the world to see. Later a clamp wasmissing and fumes emissions hose was disconnected in my car, that lead to the fumes accumulating aroundthe engine, which is extremely dangerous.

    As I read August 4, 2004 transcript, I found a testimony of detective Liebreich. He testified in regards torecording of phone calls Lisa Liberi made from jail to her husband Brent Liberi. She was telling him that she

    was upset with her sister Cheryl Richardson. Cheryl cooperated with the police and told them about 19 prior criminal investigations of Liberi. Liberi told Brent (see copies of the transcripts attached) that she will get her sister in jail and will spread the word that she is a rat. She was telling Brent do you know what they do in

    prison to rats?

    At that time DA James Secord asked the detective to explain. The detective stated that a contract will beissued on such person, a green light and such person will be attacked and/ or killed. He mentioned that 5

    people were killed last year alone. I got concerned, if this woman could plan a hit, a contract on her own sister, it would not be inconceivable that she would plan a hit on an attorney and her family, if thisattorney outed her. I kept reading and found out that indeed less then a year later her sister was dead. Officialcause of death, from what I understand, is drug overdose. However, drug overdose can be self inflicted or

    inflicted by others.

    At this time I would like to know if there are any pathologists among the readers of this blog? Can someonego to the police department and probation department in Santa Fe NM and show them all this info.

    According to detective Teresa Standiford from Orange County economic crimes unit, my report and thewhole file was transferred to Santa Fe, as Lisa Liberi lives there. I tried to find out the status, but it is veryhard to reach anybody in the police department there. The phone number of detective Teresa Standford in CA714-647-7486, 714-647-7038. Case # 09-068339.

    Liberis prosecuting DA in Ca is James Secord 909-387-8309

    In Santa Fe I was given a number for detective Martin Lopez 505-955-5010, General number for the Santa Fe police is 505-955-5038. Investigations unit- 505-955-5038

    The supervisor of her probation department is Joan Martinez 505-476-2359 Regional probation officer isRose Bobchack 505-476-2363.

    After the hearing on Thursday I talked to Phil Berg and I have shown him the transcripts of Liberis prior hearings. I put him on notice in regards to her dangerous propensities and let him know that if he continueswith this law suits and continues denying, what is clearly a public record, he endangers me and my wholefamily. If something happens and Liberi is involved, he will be held accountable as an accomplice.

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    Category: Events , Uncategorized

    Comments

    5 Responses to I am back from PA. Very Important.

    sillyhahaJune 27th, 2009 @ 5:57 pm

    I am thrilled that all went well for you and the other defendants on Thur! Seems like the Judge feelsthat this case is a complete waste of time and unfair to all the defendants. It is a frivolous case.

    Interesting info on Lisa Liberi. Sounds like she may be looking at more legal problems as a result of going after you and Linda Starr. Serves her rightand I hope Berg gets sanctioned for this nonsense.

    Well done, Dr. Taitz!!!

    1.

    sillyhahaJune 27th, 2009 @ 6:22 pm

    Dr. Taitz,

    Please be careful. This Lisa Liberi woman is dangerous. Thank God she doesnt live near you.

    Somewhere someone talked about escorting you to the courthouse on the 13thhe would be carrying agun. This concerns me. He wont be allowed in with the gun. And, I wouldnt want anything to damageyour reputation. I personally would leave all guns at home. Peaceful protesters can assist you to andfrom the building. After the von Brunn incident, I would hate to see further linking of guns/violenceand the citizenship issue.

    2.

    Bill AnglesJune 27th, 2009 @ 6:52 pm

    Searched web for Chuck Crismayer with no luck, so I called phone number you posted and talked withMr. CRISMIER. He was kind enough to give me instructions to be able to hear your interview withhim. Thought I would pass it on: http://www.saveus.org Click on Viewpoint broadcast button on leftside of page, click on ARCHIVES. Interview is posted there. Of all the interviews Ive listened to (andthat is most of them) this is the best. Mr. Crismier did a great job with his supporting commentary. He isa first-class broadcaster, talented enough to have a show on a major network in my opinion.

    3.

    tainler June 27th, 2009 @ 8:20 pm

    I am VERY concerned for Orly and her family. Lisa liberi doesnt have to live close to Orly to attemptanything. If she has connections to get rid of someone then all she needs is a phone or computer. Isthere a way to investigate her co