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CDCA ECF 593 - Liberi v Taitz - TAITZ Response to OSC

CDCA ECF 593 - Liberi v Taitz - TAITZ Response to OSC

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Published by Jack Ryan
02/04/2013 593, REPLY filed by Defendant DEFEND OUR FREEDOMS FOUNDATIONS, INC. to Order to Show Cause, 591[RECAP] Response to order to show cause by Orly Taitz, showing that she provided truthful information during 01.14.2013 hearing and request for leave of court to file a Rule 11 motion against plaintiffs and their attorneys for fraud and falsification of records from CA state court (Attachments: # 1 Exhibit True and correct copy of the 9 page memorandum in opposition filed by the Occidental college, # 2 Exhibit Notice of Ruling filed by the Occidental college, # 3 Exhibit Affidavit by Tony Dolz, attesting to order of shift of costs, # 4 Certificate of Service)(Taitz, Orly) (Entered: 02/04/2013)
02/04/2013 593, REPLY filed by Defendant DEFEND OUR FREEDOMS FOUNDATIONS, INC. to Order to Show Cause, 591[RECAP] Response to order to show cause by Orly Taitz, showing that she provided truthful information during 01.14.2013 hearing and request for leave of court to file a Rule 11 motion against plaintiffs and their attorneys for fraud and falsification of records from CA state court (Attachments: # 1 Exhibit True and correct copy of the 9 page memorandum in opposition filed by the Occidental college, # 2 Exhibit Notice of Ruling filed by the Occidental college, # 3 Exhibit Affidavit by Tony Dolz, attesting to order of shift of costs, # 4 Certificate of Service)(Taitz, Orly) (Entered: 02/04/2013)

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Published by: Jack Ryan on Feb 05, 2013
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 Response to order to show cause12345678910111213141516171819202122232425262728
Orly Taitz29839 Santa Margarita Pkwy, ste 100Rancho Santa Margarita, CA 92688US DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALiberi et al,Plaintiff,vs.Taitz et al,Defendant)))))))))ase o.: -Response to order to show cause byOrly Taitz, showing that she providedtruthful information during 01.14.2013hearing and request for leave of court tofile a Rule 11 motion against plaintiffsand their attorneys for fraud andfalsification of records from CA statecourt
RESPONSE TO ORDER TO SHOW CAUSE BY ORLY TAITZ, SHOWINGTHAT SHE PROVIDED TRUTHFUL INFORMATION DURING 01.14.2013HEARING AND REQUEST BY TAITZ FOR LEAVE OF COURT TO FILEA MOTION FOR SANCTIONS AGAINST PLAINTIFFS AND THEIRATTORNEYS FOR FRAUD AND FALSIFICATION OF RECORDS FROMCA SUPERIOR COURT
On October 22, 2012 Judge Guilford ordered the parties to "inform the Courtimmediately of any action taken on pending ethical, disciplinary or relatedmatters".
There were no pending ethical, disciplinary or related mattersregarding Orly Taitz.
The only pending matter is the appeal by Attorney Berg of the ruling of the Hearing Panel of the Disciplinary Board of the Supreme Court of Pennsylvania to suspend the law license of attorney Philip Berg for one year andone day, which would prevent him from being an attorney in the case at hand.On January 14, 2013 Attorney Berg told the court that on November 1, 2012 a judge sanctioned Taitz $4,000. Taitz stated that the award of $4,000 by JudgeMarginis was for
discovery, that it was indeed a cost shifting of attorneys feesrelated to discovery. J
udge Guilford stated in court on the record that indeed
Case 8:11-cv-00485-AG-AJW Document 593 Filed 02/04/13 Page 1 of 9 Page ID #:15705
 
 Response to order to show cause12345678910111213141516171819202122232425262728
discovery related sanctions do not represent ethical violations, that California statelaws allow sanctions in the form of attorneys fees when a party loses a motion.Plaintiffs' attorney Berg responded to court verbally during the hearing and in aletter where Berg claimed that the sanction was for much more than discovery.Taitz responded by a letter stating that $4,000 was indeed for discovery. JudgeGuilford issued an order to show cause where he stated "Taitz said in court that thesanction was FOR DISCOVERY... The parties have since subjected the court to aflurry of papers, which the Court dismisses as irrelevant except for the sole issuenow of whether Taitz lied to the court when she said the sanction was FORDISCOVERY" The court ordered Taitz to respond in writing to show cause whyshe should not be sanctioned for lying to this court.".On 02.04. 2013 Plaintiffs and their attorneys filed a response and further defraudedJudge Guilford by:1.
 
Falsifying/forging an actual opposition filed by the Occidental college
,where they removed from the Opposition filed with The California Superiorcourt 2 pages, where the Occidental college specifically requested $4,000under the California rule 1987.1 Exhibit 1 is an actual order filed by theOccidental college, where the Occidental college on page 8, line 16specifically states “Section 1987.1-the provision which Plaintiff should befollowing –allows the court to rule upon a motion to compel, and to quashservice of the subpoena. Section 1987.2 allows the court to award reasonableexpenses and fees to the prevailing party in making a ruling. For the reasonsset forth above, Occidental College respectfully requests that the court denyPlaintiff’s motion, quash the subpoena, and award sanctions in the amount of $4,000”. Plaintiffs and their attorneys Philip Berg and local counsel GaryKreep committed an egregious fraud on the court by falsifying the actualdocument from the CA Superior court and removing 2 pages from thedocument they filed with this court today on 02.04.2013, which actually
Case 8:11-cv-00485-AG-AJW Document 593 Filed 02/04/13 Page 2 of 9 Page ID #:15706
 
 Response to order to show cause12345678910111213141516171819202122232425262728
showed that Taitz was telling the truth, and the award of $4,000 was fordiscovery based on CA code section 1987.2.2.
 
Plaintiffs and their attorneys further defrauded Judge Guilford by notproviding the actual
NOTICE OF RULING filed by the OccidentalCollege
Exhibit 2 that states the same, that the order by Judge Marginis wasa discovery related shift of cost under CA rule 1987.2. Plaintiffsintentionally have hidden from Judge Guilford the actual 3 page Notice of ruling and submitted to the court a falsified original opposition by theOccidental college, where they kept the pages that were simply defamatoryagainst Taitz and removed the pages, which stated that the request for feeswas under Rule 1987.2Additionally, during the hearing Judge Marginis expressly stated on the recordthat this is not a penalty, but cost shifting. There was no court reporter at thehearing, however Taitz is providing Exhibit 3 Sworn affidavit of a member of the audience Tony Dolz, as well as sworn affidavit by Taitz, attesting thatindeed Judge Marginis stated on the record that the order of $4,000 was costshifting.Moreover, Taitz is currently appealing this order by Judge Marginis, as with hermotion to compel she presented Judge Marginis with an order from Judge Malihi,where he upheld a subpoena by Taitz seeking Occidental College records fromBarack Obama himself. Since Obama did not comply with an order to producerecords before and since he did not show up for several motion hearings, eventhough he was properly served by a professional server of process and due toproximity of the national election, it was reasonable for Taitz to seek an order tocompel production of the same records from the custodian of records, Occidentalcollege. Additionally, $4,000 fee sought by the Occidental college for one shortappearance, was not a reasonable fee. Jay Ritt, co-counsel for Occidental college isa neighbor and acquaintance of Obama's personal attorney Scott J. Tepper and Ritt
Case 8:11-cv-00485-AG-AJW Document 593 Filed 02/04/13 Page 3 of 9 Page ID #:15707

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