Z:\Liberi, et al, Taitz, et al, Plaintiffs’ Reply to Defendants Response to OSC1

Law Offices of:

Philip J. Berg, Esquire

555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531Identification No. 09867(610) 825-3134

Attorney for Plaintiffs

UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIA

LISA LIBERI, et al,Plaintiffs,vs.ORLY TAITZ, et al,Defendants.::::::::::Case No.: 09-cv-01898-ECR

PLAINTIFFS’ REPLY TO DEFENDANTS RESPONSES TO THISCOURT’S RULES TO SHOW CAUSE ORDERED BY THEHONORABLE EDUARDO C. ROBRENO ON JUNE 25, 2009

Plaintiffs’ Lisa Liberi [hereinafter “Liberi”]; Philip J. Berg, Esquire [hereinafter “Berg”],the Law Offices of Philip J. Berg; Evelyn Adams a/k/a Momma E [hereinafter “Adams”]; LisaOstella [hereinafter “Ostella”]; and Go Excel Global by and through their undersigned counsel,Philip J. Berg, Esquire, hereby files the within Reply to the Defendants, Orly Taitz [hereinafter “Taitz”], Defend our Freedoms Foundations, Inc. [hereinafter “DOFF”], Edgar Hale, Caren Hale,Plains Radio, KPRN and Bar H Farms [hereinafter “The Hales”] Response in Reply to Plaintiffs’Responses to this Honorable Court’s Rules to Show Cause as to why the case should not bedismissed for lack of personal jurisdiction over the Defendants; why the case should not besevered into three [3] or fewer cases; and why this case should not be transferred to Texas or California, in support thereof, Plaintiffs’ aver as follows.

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Taitz and DOFF fail to deny, retract or argue against, the fact they havesystematic and continuous contacts with this forum, which is now admitted, andsubstantiates Plaintiffs’ argument that this Court undoubtedly has PersonalJurisdiction over the Defendants;

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Taitz and DOFF fail to deny, retract or argue against the facts that they targetedPlaintiffs within this Court’s Jurisdiction, thereby admitting they targetedPennsylvania and substantiates Plaintiffs’ argument that this very Court has personal jurisdiction over the Defendants;

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Taitz and DOFF fail to address the true issues before this Court which are 1) whythe case should not be dismissed for lack of personal jurisdiction; 2) why the caseshould not be severed; and 3) why the case should not be transferred;

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Taitz and DOFF have done nothing more than again attempt to confuse this Courtand twist the issues currently pending. Taitz and DOFF are again attempting toargue a Motion to Dismiss pursuant to Rule 12, when there is

Motion toDismiss before this Court and all of Taitz and DOFF prior filings of Motions toDismiss, which filings were completely improper, have been denied by this Court;

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The Hale Defendants have admitted to soliciting donations on behalf of Berg andhis Law Firm, Pennsylvania Plaintiffs’ and have admitted advertising for Bergand his Law Firm’s website, which satisfies the systematic and continuouscontacts with this Jurisdiction and substantiates Plaintiffs’ arguments that thisCourt has personal jurisdiction over them.

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The Hale Defendants fail to address the fact that they targeted the Plaintiffs inPennsylvania; instead, the Hale Defendants admitted Taitz, DOFF and NeilSankey used them and their radio show to assault Liberi to get to Berg, thussatisfying the Defendants common scheme requirements, which also satisfies the personal jurisdiction requirement and the reason not to sever the case;

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Neither the Hale Defendants, Taitz or DOFF responded to the issue of Transfer pursuant to 28 U.S. C. §1404(a), although Transfer of the case would not be proper;

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Taitz and DOFF waived their rights to raise the issue of Venue and/or PersonalJurisdiction by failing to timely raise the issue and timely object;

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Neil Sankey, Linda S. Belcher, et al, the Sankey Firm, Inc. a/k/a The Sankey Firmand Sankey Investigations, Inc. have failed to respond at all regarding the three(3) issues currently before this Court; and

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Venue is proper pursuant to 28 U.S.C. §1391(a)(3).

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I. STATEMENT OF ISSUES:

This Court’s Rules to Show Cause entered June 25, 2009 were very specific regardingissues this Court wanted the Plaintiffs’ to address. As stated above the issues to be addressedwere: (1) Why this case should not be dismissed for lack of Personal Jurisdiction over theDefendants’; (2) Why this Case should not be severed into three [3] or fewer cases…; and (3)Why this case should not be transferred to California or Texas pursuant to 28 U.S.C. §1404(a).As better explained in Plaintiffs’ Complaint, Plaintiffs’ hereby incorporate their Complaint as if fully set forth herein, Orly Taitz, et al through her company, DOFF threatenedBerg to take him down and to do so she would destroy his paralegal, Liberi, and get rid of her and anyone associated with Berg, which has now been admitted by Taitz in her latest filings.In Response to this Court’s Rules to Show Cause, Plaintiffs’ filed their Response with

Exhibits

One [1] through Twenty-Six [26] on August 26, 2009 [Doc. #106] and due to technicalcomplications with the ECF System, which can be verified by the time of filing,

Exhibits

Twenty-Seven [27] through Fifty-Five [55] appear on the docket as document number OneHundred and Seven [107]. In totality, Plaintiffs’ filed in excess of Seven Hundred and Forty[740] pages substantiating their position. Of Course, all Defendants were served with Plaintiffs’filings.In the Defendants Responses to Plaintiffs’ Responses, the Defendants clearly fail toaddress the issues outlined in this Court’s Rules to Show Cause. None of the Defendants givetheir positions regarding the three (3) items the Court asked to be addressed; they failed to giveany type of law to substantiate their positions on these issues and as better explained below, theDefendants even support the Plaintiffs’ position and arguments as to why this Court has personal jurisdiction over the Defendants; why this case should not be severed and why this case should

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