Appellants’, Lisa Liberi [hereinafter “Liberi”]; Philip J. Berg, Esquire[hereinafter “Berg”], the Law Offices of Philip J. Berg; Evelyn Adams a/k/aMomma E [hereinafter “Adams”]; Lisa Ostella [hereinafter “Ostella”]; and GoExcel Global by and through their undersigned counsel, Philip J. Berg, Esquire,hereby files the within Motion to File Pages in Excess of the Ten (10) Page Limiton Reply’s pursuant to Federal Rules of Appellate Procedure [F.R.A.P.] 27(d)(2).Appellees Orly Taitz [hereinafter at times “Taitz”] and Defend our Freedoms Foundations, Inc. [hereinafter “DOFF”] filed an Opposition toAppellants’ Motion to Withdraw their Appeal or in the alternative, their Motion toDismiss their Appeal Without Costs pursuant to F.R.A.P. 42(b). In Taitz’sOpposition, she raised numerous issues and many false accusations whichAppellants must address appropriately. Unfortunately, Appellants are unable to doso without exceeding the ten (10) page limit in F.R.A.P. 27(d)(2), complexity of the matters. In addition, Appellees Taitz and DOFF also request costs andsanctions, which also needed to be properly addressed.Appellants’ filed their Reply to Taitz’s Opposition on May 1, 2010,however, the Reply is twenty-two (22) pages, which exceeds the ten (10) pagelimit. Without Leave of Court to File in Excess of ten (10) pages, Appellants’ arenot able to properly respond to and/or address Taitz’s Opposition and properlyrespond to Taitz’s request for Costs and Sanctions.
Case: 09-3403 Document: 003110132184 Page: 2 Date Filed: 05/05/2010