U.S. District Court,Eastern District of Pennsylvania Case Number: 09-cv-01898 ECR Court of Appeals No. 09-3403

UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT

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LISA LIBERI, et al,

Plaintiffs’ – Appellants’,v.

ORLY TAITZ, et al,

Respondents’ – Appellees’. ____________

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APPELLANTS’ REQUEST FOR JUDICIAL NOTICE

_____________________

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD

Please Take Notice that Appellants’, 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”]; Lisa Ostella [hereinafter “Ostella”]; and Go Excel Global by and throughtheir undersigned counsel, Philip J. Berg, Esquire, hereby submits this Request for Judicial Notice of the attached Court Order of United States District Court, Central District of California, Judge DavidO. Carter, directing Orly Taitz [Defendant / Appellee in this case] to remove Dossier #6, whichcontains Appellant Lisa Liberi’s Social Security number, date of birth and other personal identifyinginformation filed in the ECF filing system by Orly Taitz on September 21, 2009, in a case unrelatedto Appellant Lisa Liberi.

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Evidence 201, of the following document which is a Court Order issued by Judge David O.Carter, Judge in the United States District Court for the Central District of California, SouthernDivision filed in Pacer, the Federal Docketing System, on September 30, 2009 in the Case of

Barnett, et al v. Obama, et al

, Case No. 8:09-cv-00082 as Document number seventy-seven [77]. personal identifying information filed in the ECF filing system by Ms. Taitz on September 21,2009 by October 2, 2009.to republish Liberi’s SocialSecurity number, date of birth, mother’s maiden name, place of birth, and other personal privateidentifying information.this Honorable Court to take Judicial Notice of Judge Carter’s Order.“A judicially noticed fact must be one not subject to reasonable dispute in that it is either (1) generally known within the territorial jurisdiction of the trial court or (2) capable of accurateand ready determination by resort to sources whose accuracy cannot reasonably be questioned.”Fed. R. Evid. §201(b);

Easy Sportswear, Inc. v. Am. Econ. Ins. Co

., 2008 U.S. Dist. LEXIS51402 (D. Pa. 2008);

Nationwide Life Ins. Co. v. Commonwealth Land Title Ins. Com

., 2005 U.S.Dist. LEXIS 24479 (E.D. Pa. 2005);

In re NAHC, Inc. Sec Litig

, 306 F.3d 1315 (3d Cir. 2002)“[a] court shall take judicial notice if requested by a party and supplied with the necessaryAppellants’ request this Court to take Judicial Notice, pursuant to Federal Rules of Judge Carter’s Order is directing attorney Orly Taitz [Appellee in this case] to remove Dossier #6, which contains Appellant Lisa Liberi

's Social Security number, date of birth and other

In this case, Appellee, Orly Taitz, et al filing of Dossier #6 was addressed in this Courton June 25, 2009 and Judge Robreno warned Appellee Taitz

not

Security number. Despite this, Appellee Taitz has continued republication of Liberi’s SocialJudge Carter’s Order is attached hereto as

EXHIBIT “A”

and AppellantsH hereby request

Case: 09-3403 Document: 00319882493 Page: 2 Date Filed: 10/31/2009

information.” Fed. R. Evid. 201(d) (emphasis added)

Easy Sportswear, Inc.

, 2008 U.S. Dist.LEXIS 514002 (D. Pa 2008) at *2.It is firmly established that Requests for Judicial Notice are proper “only to the extentthat the noticed facts are relevant to an issue” that is before the Court. Judge Carter’s Order thatis a Court Order issued by a United States District Court Federal Judge directly related to thisaction and is relevant to the issues herein. See

In re Ravisent Techs., Inc. Sec. Litig

., 2004 U.S.Dist. LEXIS 132355 (D. Pa. 2004)Court to take Judicial Notice of Judge David O. Carter’s Order dated September 30, 2009attached hereto as

EXHIBIT “A”

.Respectfully submitted,Philip J. Berg, Esquire555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531(610) 825-3134Appellants

are requesting Judicial Notice is of the type that Judicial Notice has been taken of bythe Third Circuit. This includes documents integral to or explicitly relied upon in the Appellants’Complaint and the reasons Appellants

were forced to bring suit against the Appellees

. Inaddition, the attached document,

EXHIBIT “A”

that Appellants are requesting Judicial Notice of For the above aforementioned reasons, Appellants’ respectfully request this Honorableated: October 31, 2009

____________________________

Attorney for the Appellants’

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