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LIBERI v TAITZ - 132 - RESPONSE in Opposition re 131 MOTION to Stay - gov.uscourts.paed.302150.132.0

LIBERI v TAITZ - 132 - RESPONSE in Opposition re 131 MOTION to Stay - gov.uscourts.paed.302150.132.0

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Published by Jack Ryan
07/09/2010 132[RECAP] RESPONSE in Opposition re 131 MOTION to Stay ; Memorandum; Proposed Order; and Certificate of Service filed by EVELYN ADAMS, PHILIP J. BERG, GO EXCEL GLOBAL, LISA LIBERI, LISA M. OSTELLA, THE LAW OFFICES OF PHILIP J. BERG. (Attachments: # 1[RECAP] Text of Proposed Order Proposed Order)(BERG, PHILIP) (Entered: 07/09/2010)
07/09/2010 132[RECAP] RESPONSE in Opposition re 131 MOTION to Stay ; Memorandum; Proposed Order; and Certificate of Service filed by EVELYN ADAMS, PHILIP J. BERG, GO EXCEL GLOBAL, LISA LIBERI, LISA M. OSTELLA, THE LAW OFFICES OF PHILIP J. BERG. (Attachments: # 1[RECAP] Text of Proposed Order Proposed Order)(BERG, PHILIP) (Entered: 07/09/2010)

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Categories:Types, Research, Law
Published by: Jack Ryan on Jul 09, 2010
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04/19/2015

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Z:\Liberi Plaintiffs’ Response/Memorandum in Opp to Defendant Taitz’s Motions to unseal and transfer 07.07.2010
1Law Offices of:
PHILIP J. BERG, ESQUIRE
555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531 Attorney for: PlaintiffsIdentification No. 09867(610) 825-3134
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 
 Assigned to Honorable Eduardo C. Robreno
PLAINTIFFS’ RESPONSE and MEMORANDUM IN OPPOSITIONTO DEFENDANT ORLY TAITZ’S REQUEST TO UNSEALTRANSCRIPTS and FOR A STAY PENDING APPEALNOW COME
Plaintiffs’, 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 Go ExcelGlobal by and through their undersigned counsel, Philip J. Berg, Esquire, and herebyRespond in Opposition to Defendant Orly Taitz’s Request to Unseal Transcripts andRequest to Stay the Transfer of the Case to California pending the outcome of her Appeal. In support hereof, Plaintiffs aver as follows:
Case 2:09-cv-01898-ER Document 132 Filed 07/09/10 Page 1 of 19
 
Z:\Liberi Plaintiffs’ Response/Memorandum in Opp to Defendant Taitz’s Motions to unseal and transfer 07.07.2010
2
Defendant Orly Taitz failed to serve her Notice of Appeal, Request toStay the Transfer of the Case to California, pending Appeal, and her Motion to Unseal Transcripts and failed to file a Certificate of Service;
Defendant Taitz is attempting to appeal Orders which are
not
appealable as they are Interlocutory and
not
final Orders;
Defendant Taitz fails to meet the requirements to AppealInterlocutory Orders as established by the Collateral Order Doctrine;
Defendant Orly Taitz’s filing appearing as Docket Entries 128, 130and 131 are frivolous; and filed for an improper purpose to further delay the proceedings; to waste judicial resources; and to costPlaintiffs’ additional Attorney Fees;
Defendant Orly Taitz’s filing appearing as Docket Entries 128, 130and 131 fails to cite any cognizable reasons why a Stay of Action isRequested;
Defendant Orly Taitz’s filing appearing as Docket Entries 128, 130and 131 fails to cite any type of legal authority or law to support her requests;
Defendant Orly Taitz’s filing appearing as Docket Entries 128, 130and 131 are not in accordance with the Federal Rules of CivilProcedure;
The only Transcript Sealed is the Transcript of August 7, 2009, whichwas Plaintiffs’ Motion for an immediate Temporary RestrainingOrder and offers nothing regarding Defendant Taitz’s reasons for Appeal;
The Transcript of August 7, 2009 contains the Social Security number of Plaintiff Liberi;
Defendant Orly Taitz’s Appeal is based on an Ex Parte Letter whichPlaintiffs’ were
never
served with and is not a proper basis for anappeal;
Defendant Orly Taitz’s Appeal of this Court’s Order of June 25, 2009is time barred;
Defendant Orly Taitz’s filings appearing as Docket Entries 128, 130and 131 are an attempt to deceive this Court. All Defendants
Case 2:09-cv-01898-ER Document 132 Filed 07/09/10 Page 2 of 19
 
Z:\Liberi Plaintiffs’ Response/Memorandum in Opp to Defendant Taitz’s Motions to unseal and transfer 07.07.2010
3requested transfer of the within case as documented in their filingsappearing as Docket Entry numbers 23, 24, 25 and Taitz own filingsappearing as Docket Entries 35, 48, 50, and 53, just to name a few,stating California is the proper jurisdiction of this Case;
Defendant Taitz’s Appeal of this Court’s Orders appearing as DocketEntry numbers 109; 116; 118; 123; 124; and 125 are completelyimproper as outlined below and therefore do
not
warrant any type of Stay; and
Plaintiffs’ will be severely damaged and prejudiced if DefendantTaitz’s Request/Motion for Stay is Granted.
I.FACTS:
Plaintiffs’ filed suit against the Defendants on May 4, 2009 for amongst other things the publication of Plaintiff Liberi’s Social Security number; date of birth; place of  birth; and other confidential information.Contrary to Defendant Orly Taitz’s filings appearing as Docket Entry numbers128, 130 and 131 filed July 2, 2010, all Defendants filed Motions to Dismiss, appearingas Docket Entries twenty-three through twenty-five [23-25], which are Defendants oneline answers: Motion to Dismiss Plaintiffs Complaint or in the Alternative to Transfer thecase to the Western District of Texas. And in Defendant Orly Taitz’s own filingsappearing as Docket Entry numbers 35, 48, 50, and 53, just to name a few, whereinDefendant Orly Taitz clearly states California is the proper jurisdiction.Moreover, Defendant Taitz’s clearly fails to raise Plaintiffs’ Motion to Transfer the within action, which again went unopposed as
none
of the Defendants responded toPlaintiffs’ Motion, except for Defendant Taitz’s Letter Brief for Sanctions against theundersigned for filing Plaintiffs’ Motion to Transfer Venue.
Case 2:09-cv-01898-ER Document 132 Filed 07/09/10 Page 3 of 19

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