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2013-12-10 - LIBERI v TAITZ - Response to Emergency Motion - 13-56253

2013-12-10 - LIBERI v TAITZ - Response to Emergency Motion - 13-56253

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Published by Jack Ryan
2013-12-10 - LIBERI v TAITZ - Response to Emergency Motion
2013-12-10 - LIBERI v TAITZ - Response to Emergency Motion

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Categories:Types, Business/Law
Published by: Jack Ryan on Jan 09, 2014
Copyright:Attribution Non-commercial

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10/15/2014

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STEPHEN H. MARCUS, ESQ. [CSBN 48294] RANDY A. BERG, ESQ. [CSBN 128445] GITTLER BRADFORD 10537 Santa
Monica
Blvd., Third Floor Los Angeles,
CA
90025 Telephone 310) 474-4007 e-mail: smarcus@gblaw.net Attorneys for Plaintiffs/Respondents LISA LIBERI, LISA M. OSTELLA, and GOEXCEL GLOBAL,
IN THE NINTH CIRCUIT COURT OF APPEALS Case No. 13-56253
ORLYTAITZ
Appellant/Defendant
v
LISA LIBERI, PHILIP BERG, LISA OSTELLA,
LAW
OFFICES OF PHILIP
BERG GOEXCELGLOBAL
Respondents/Plaintiffs
OPPOSITION TO EMERGENCY MOTION UNDER CIRCUIT RULE 27-3
Y
APPELLANT ORL Y TAITZ, FOR ORDER BARRING GITTLER BRADFORD FROM REPRESENTING APPELLEES, LISA LIBERI, LISA OSTELLA, AND GO EXCEL GLOBAL, IN THE ALTERNATIVE CLARIFYING REPRESENTATION OF SUCH PLAINTIFFS, AND STAYING BRIEFING SCHEDULE
Case: 13-56253 12/10/2013 ID: 8896732 DktEntry: 9-1 Page: 1 of 9
(1 of 22)
 
Respondents/Plaintiffs Lisa Liberi, Lisa Ostella, and GoExcel Global respectfully submit this Opposition to the Emergency Motion under Circuit Rule 27-3
y
Appellant Orly Taitz, for Order Barring Gittler & Bradford from Representing Appellees, Lisa Liberi, Lisa Ostella, and Go Excel Global, in the Alternative Clarifying Representation
of
Such Plaintiffs, and Staying Briefing Schedule filed by Appellant/Defendant Orly Taitz ( Taitz ).
1
Taitz has not complied with Circuit Rule 27-3(b)(4), which requires: (4)
if
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
if
not, why the motion should not be remanded or denied.
2
In fact, Taitz and co-defendant Defend Our Freedoms Foundation (who is represented
y
Taitz) raised this very issue concerning the representation
of
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
of
July 12, 2013 [District Court Docket No. 641, Exhibit A hereto] establishes that the representation
of
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
as
counsel for Philip Berg.]
Case: 13-56253 12/10/2013 ID: 8896732 DktEntry: 9-1 Page: 2 of 9
(2 of 22)
 
5
Taitz has not shown any good cause for any delay in the briefing schedule
of
this matter, and is merely seeking to delay the ultimate trial
of
this matter on the merits. Any emergency ,
if
any, is one
of
her own making, and does not justify any delay in these proceedings. Dated; December 10, 2013 Respectfully submitted,
STEPHEN H. MARCUS, ESQ.
R NDY
A. BERG, ESQ. members
of
GITTLER BRADFORD
;
4~
Case: 13-56253 12/10/2013 ID: 8896732 DktEntry: 9-1 Page: 3 of 9
(3 of 22)

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