Respondents/Plaintiffs Lisa Liberi, Lisa Ostella, and GoExcel Global respectfully submit this Opposition to the Emergency Motion under Circuit Rule 27-3
Appellant Orly Taitz, for Order Barring Gittler & Bradford from Representing Appellees, Lisa Liberi, Lisa Ostella, and Go Excel Global, in the Alternative Clarifying Representation
Such Plaintiffs, and Staying Briefing Schedule filed by Appellant/Defendant Orly Taitz ( Taitz ).
Taitz has not complied with Circuit Rule 27-3(b)(4), which requires: (4)
the relief sought in the motion was available in the district court, Bankruptcy Appellate Panel or agency, the motion shall state whether all grounds advanced in support thereof in this Court were submitted to the district court, panel or agency, and
not, why the motion should not be remanded or denied.
In fact, Taitz and co-defendant Defend Our Freedoms Foundation (who is represented
Taitz) raised this very issue concerning the representation
Lisa Liberi, Lisa Ostella, and Go Excel Global in the District Court, and its request for relief was denied. The Ron. Andrew Guilford's Minute Order
July 12, 2013 [District Court Docket No. 641, Exhibit A hereto] establishes that the representation
the said Plaintiffs/Respondents was established in the District Court. District Court Docket Nos. 633 and 644 (referred to in Judge Guilford's Minute Order) are attached hereto as Exhibit B. [Messrs. Marcus and Berg have since withdrawn
counsel for Philip Berg.]
Case: 13-56253 12/10/2013 ID: 8896732 DktEntry: 9-1 Page: 2 of 9
(2 of 22)