LIBERI, et al v TAITZ, et al. - ECF FILER: Request for Judicial Notice of Judge Clay D. Land's October 13, 2009 Order

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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

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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, Middle District of Georgia,Judge Clay D. Land, sanctioning Orly Taitz, et al Twenty Thousand [$20,000.00] Dollars for Orly Taitz’s inappropriate behaviors including accusing Judge Land of Treason, and other unsubstantiated allegations of criminal acts. Appellants’ are also requesting Judicial Notice of Orly Taitz’s Interview of October 13, 2009 with Talking Points Memo (TPM) and theHuffington Post article, wherein she is refusing to comply with Judge Land’s Order. Appellants’

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request this Court to take Judicial Notice, pursuant to Federal Rules of Evidence 201, These arethe same behaviors Orly Taitz, Appellee herein has instituted against the Appellants’. JudgeClay D. Land’s Order is attached hereto as

EXHIBIT “A”

and Orly Taitz interview withTalking Points Memo (TPM) and the Huffington Post Articles are attached hereto as

EXHIBIT“B”

. Judge Clay D. Land’s Order of October 13, 2009 and Appellee Orly Taitz’s refusal tocomply with Judge Land’s Order is imperative to the Appellants’ case herein as it shows theextents Ms. Taitz will go to in order to get her way, with no regard to any individuals; to theLaws of our Nation; and absolutely no respect for our Judiciary. Not only have the Appellants’ herein been severely damaged by Appellee Taitz’scontinued illegal actions, which have now extended to our United States District Court’s FederalJudges, but Appellee Orly Taitz has also failed to comply with the United States District Court,Eastern District of Pennsylvania Court’s Orders and warnings, as she is now doing to JudgeLand. These documents show Appellee Taitz’s continued disrespect for any individual; our Laws; and Judiciary.“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 necessaryinformation.” Fed. R. Evid. 201(d),

Easy Sportswear, Inc.

, 2008 U.S. Dist. LEXIS 514002 (D. Pa2008) at *2.

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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. The attached Court Order of Judge Clay D. Land and the October 13, 2009 Interview of Orly Taitz and the Huffington PostArticle, which Appellants are requesting Judicial Notice of, are of the type that have previously been admitted by Judicial Notice in the Third Circuit. This includes documents integral to or explicitly relied upon in the Appellants’ (Plaintiffs’) Complaint and requests for a temporaryRestraining Order or Injunction and the reasons Appellants’ were forced to bring suit against theAppellees’. The Order of Judge Clay D. Land and the October 13, 2009 Interview with OrlyTaitz regarding Judge Land’s Order, which Appellants’ are requesting Judicial Notice of, aredirectly related to this within action and are relevant to the issues herein.

In re Ravisent Techs., Inc. Sec. Litig

., 2004 U.S. Dist. LEXIS 132355 (D. Pa. 2004)For the above aforementioned reasons, Appellants’ respectfully request this Court to takeJudicial Notice of United States District Court, Middle District of Georgia, Judge Clay D. Land’sOrder of October 13, 2009 sanctioning Appellee Orly Taitz for her illegal behaviors that are lessthan what the Appellants’ herein have been put through by Appellee Taitz. In addition,Appellants’ respectfully request this Court to take Judicial Notice of the October 13, 2009Interview of Orly Taitz and the Huffington Post Article pertaining to Judge Land’s Order.Respectfully submitted,Dated: October 31, 2009

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

Attorney for Appellants’

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