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LIBERI v TAITZ - Berg Letter to Judge Robreno - 7/30/09

LIBERI v TAITZ - Berg Letter to Judge Robreno - 7/30/09

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Published by Jack Ryan

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Published by: Jack Ryan on Jul 31, 2009
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Z:\Liberi Ltr to Judge Robreno July 30, 2009
1LAW OFFICES OF
PHILIP J. BERG
555 Andorra
 
Glen Court, Suite 12Lafayette Hill, PA 19444-2531
PHILIP J. BERGCATHERINE R. BARONEBARBARA MAY(610) 825-3134FAX (610) 834-7659 NORMAN B. BERG, Paralegal [Deceased] E-Mail:
 philjberg@gmail.com 
July 30, 2009Honorable Eduardo C. Robreno
United States District Courtfor the Eastern District of Pennsylvania
11614 U.S. Courthouse601 Market StreetPhiladelphia, PA 19106-1797Re: Liberi, et al. v. Orly Taitz, et al, Case No. 09-cv-01898 ECR Plaintiffs Opposition to Defendants’ Request for a Thirty [30] day Extension of TimeDear Judge Robreno:I am in receipt of Mr. Hoppe’s letter dated July 28, 2009. There are several problems withMr. Hoppe’s request for an Extension of Time as well as statements pertaining to Mr. Hale and LindaBelcher. Unless this Court issues Plaintiffs’ request for an Emergency Injunction or Restraining Order  pending any Hearings, Plaintiffs are
OPPOSED
to any continuance of the Hearing pertaining to thePlaintiffs’ Motion for an Emergency Injunction or Restraining Order as outlined herein.
Mr. Hoppe’s Continuance Request
:Mr. Hoppe was served with the letter that I sent on July 16, 2009 with Plaintiffs’ attachedmotion and letters provided from two [2] witnesses who are
not
a party to this litigation. In my July16, 2009 letter to Your Honor was also information regarding the actions of Defendant, Orly Taitz.Mr. Hoppe was also served with my letter that I sent to Your Honor with further actions of Ms. Taitz pertaining to Plaintiff Lisa Liberi’s Social Security number and other confidential information. Mr.Hoppe was again served with my July 22, 2009 letter which was sent to Your Honor wherein I againwas requesting Leave to file the Plaintiffs’ Motion for an Emergency Injunction or Restraining Order;and finally on July 24, 2009, a letter I sent to Your Honor with two [2] emails received from two [2]additional witnesses who are
not
parties to this litigation, other than being witnesses for the Plaintiffs’.
Sent via Fax to (267) 299-7428...................................................................................................18 Pages
 
Z:\Liberi Ltr to Judge Robreno July 30, 2009
2Yesterday, July 29, 2009 is the first response we have received from Mr. Hoppe regardingthis matter. Furthermore, Plaintiffs’ request for the thirty [30] day extension of time was to allow thisCourt to take appropriate action to protect the Plaintiffs’ and their witnesses so we could properlyrespond to Your Honor’s Rules to Show Cause, wherein Your Honor specifically asked for Affidavits.Plaintiffs’ Response and Affidavits in support thereto are now due on August 26, 2009.If this Court allows this continuance, which Plaintiffs’ completely oppose, then Plaintiffs’ areagain placed at a disadvantage and deprived of their Constitutionally protected rights to “due process”;“equal protection of the laws”; their right to “bear and present witnesses”; their rights “for redress”,etc., as they will be in the same position as their witnesses are, that being afraid to furnish Affidavits,until this Court takes appropriate action to protect the parties, as a result of Defendant’s Belcher andHale’s threatsMr. Hoppe has been aware of Plaintiffs’ request since July 16, 2009 and failed to assertanything until now. In fact, he sent Mr. Hale a copy of my letter dated July 16, 2009, which Mr. Haleimmediately posted parts of on his internet site. This is exactly what the Plaintiffs’ witnesses fear, thatMr. Hale and Ms. Belcher will purposely put their confidential information out on the internet andincite their people to go after the witnesses to follow through with their threats towards the Plaintiffswitnesses. Again, Ms. Belcher and Mr. Hale made it known to all witnesses of the Plaintiffs that they(Ms. Belcher and Mr. Hale) will know who they are; where they reside; where they are located andstated, “
and we will go after them with a vengeance
”. If Mr. Hoppe’s request for an extension of timeis granted, Plaintiffs’ will be unable to meet this Court’s Orders to reply to this Honor’s Rules to ShowCause and support their responses with Affidavits. Mr. Hoppe is well aware of this and this simply is atactic to further ensure Plaintiffs’ will be deprived of their right to properly respond.If true what Mr. Hoppe states, that Defendants Belcher and Sankey (no mention of SankeyInvestigations, Inc. or The Sankey Firm, Inc. a/k/a the Sankey Firm) are hiring a Texas Attorney tolitigate in Pennsylvania, they could have waited to do this until after Friday, August 7, 2009.Mr. Hale interrupted Ken Dunbar’s radio show on Plains Radio to make a quick announcement. Mr. Hale stated that one of Mr. Berg’s big supporters paid David Carlton Hughes, theattorney all the Defendants’ wanted, twenty-five [$25,000.00] dollars to represent the Defendants’. Mr.Hale also stated Mr. Hoppe sent an attorney to see the Judge to ask for a continuance, if the Judgedenied the continuance then Caren, Linda and he would be at Court on Friday, August 7, 2009. Mr.Hale also stated he was having ten [10] CD’s transcribed which will be sent out federal express onFriday so his Honor will have them by the deadline on Monday. See
EXHIBIT “1”.
Based on Mr.Hale’s statements, there is no need for the continuance.
Mr. Hoppe’s Statements Regarding Jurisdiction:
This Court has personal jurisdiction over the Defendants’ as will be addressed in more detailin Plaintiffs’ Responses to this Court’s Rules to Show Cause. However, since this Court OrderedPlaintiffs’ to respond to this Court’s Rules to Show Cause regarding the Jurisdictional issues and back up their responses with Affidavits; and the fact Defendant’s Belcher and Hale have now threatened anywitness who provides an Affidavit for the Plaintiffs’, this Court clearly has jurisdiction as theDefendants’ have targeted the Plaintiffs’ in Pennsylvania; any witnesses planning to supply anAffidavit or testify on behalf of Plaintiffs’ in Pennsylvania; and this case is currently in Pennsylvania;
 
Z:\Liberi Ltr to Judge Robreno July 30, 2009
3in attempts to ensure Plaintiffs’ are unable to comply with this Court’s Order that Plaintiffs’ are torespond to this Court’s Rules to Show Cause due August 26, 2009.Federal Courts may exercise personal jurisdiction over a non-resident of the forum "to theextent permissible under the law of the state where the district court sits."
 Pennzoil Prods. Co. v.Colelli & Assocs., 149 F.3d 197, 200 (3d Cir. 1998)
(citation omitted.) In turn, Pennsylvania's long-arm statute authorizes the exercise of jurisdiction over a non-resident "to the fullest extent allowedunder the Constitution of the United States."
42 Pa. Cons. Stat. Ann. § 5322 (b)
;
 see also
 
O'Connor v.Sandy Lane Hotel, 496 F.3d 312, 316 (3d Cir. 2007)
, noting that Pennsylvania's long-arm statute"provides for jurisdiction based on the most minimum contact with the Commonwealth allowed under the Constitution of the United States" (internal citations omitted.) That is, as long as the requirementsof the
 Due Process Clause of the Fourteenth Amendment to the United States Constitution
have beensatisfied, jurisdiction will lie over non-resident Defendants in Pennsylvania.
 Pennzoil Prods
., id.All the Defendants’ meet the minimum contact standards, which gives this Court jurisdictionand venue over them; their illegal, unethical and injurious behaviors and actions, which were activities purposefully directed towards residents of this state. In so doing, Defendants’ were provided "fair warning" that they may be subject to suit in this forum.
 Burger King Corp, v. Rudzewicz, 471 U.S. 462
at
472
. Again, Taitz is a licensed Attorney and is aware of the laws of our land. Moreover, Taitzthrough DOFF have several military clients; has formed a group of Pennsylvania residents to work with her in having Arlen Spector, U.S. Senator Pennsylvania recalled.It is more than obvious; Belcher and Hale directed their threats towards the Plaintiffs’ witnesseswho would be supplying Affidavits and appearing in this Court in Pennsylvania. Ms. Taitz clearlycontinued her illegal behaviors of publishing Plaintiff Liberi’s Social Security number and other  personal identifying information
despite
 
this Court’s warnings
. On June 25, 2009, this Court plainlystated that the continued behaviors would weight in favor of the Plaintiffs’.As stated in
 JNA-1 Corp. v. Uni-Marts, LLC 
(In re Uni-Marts, LLC), 404 B.R. 767 (Bankr. D.Del. 2009 @ *9:“Where a non-resident defendant "purposefully directed his activities at residents of theforum," his contacts with the forum are sufficient to support personal jurisdiction in any"litigation [that] results from alleged injuries that arise out of or relate to those activities."
 Burger King Corp. v. Rudzewicz 
, 471 U.S. 462, 472, 105 S. Ct. 2174, 85 L. Ed. 2d 528(1985) (quotations omitted). A single transaction with the forum by the plaintiff willsuffice.
See McGee v. Int'l Life Ins. Co.
, 355 U.S. 220, 223, 78 S. Ct. 199, 2 L. Ed. 2d 223(1957). The defendant's activity need not take place within the forum so long as it is"intentional conduct . . . calculated to cause injury" to the plaintiff within the forum.
Calder v. Jones, 465 U.S 
. 783, 791, 104 S. Ct. 1482, 79 L. Ed. 2d 804 (1984).
See also Burger King 
, 471 U.S. at 476 ("[W]e have consistently rejected the notion that an absenceof physical contacts can defeat personal jurisdiction . . . .")”Mr. Hoppe is now claiming for the first time that the Defendants’ coming to Pennsylvania is ahardship because they are located in California and Texas. This was never raised in the Defendants’Motions to Dismiss, filed with this Court on May 26, 2009, which was denied, or in the alternativetransferred. The California Defendants’ are willing to travel to Texas, but now they are unwilling totravel to Pennsylvania because it is a hardship? If true, then why would these Defendant’s be hiring an

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