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LIBERI v TAITZ (ORLY APPEAL THIRD CIRCUIT) - Response filed by Appellants Defend Our Freedoms Fndtn and Orly Taitz - Transport Room

LIBERI v TAITZ (ORLY APPEAL THIRD CIRCUIT) - Response filed by Appellants Defend Our Freedoms Fndtn and Orly Taitz - Transport Room

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Published by Jack Ryan
08/06/2010 Open Document ECF FILER: Response filed by Appellants Defend Our Freedoms Fndtn and Orly Taitz to Motion for attorney fees, Motion for reimbursement of appeal fees, Motion for sanctions for filing a frivolous appeal (F.R.A.P. 38), Motion to Award Costs, Motion to dismiss case for lack of jurisdiction. Certificate of Service dated 08/05/2010. (OT)
08/06/2010 Open Document ECF FILER: Response filed by Appellants Defend Our Freedoms Fndtn and Orly Taitz to Motion for attorney fees, Motion for reimbursement of appeal fees, Motion for sanctions for filing a frivolous appeal (F.R.A.P. 38), Motion to Award Costs, Motion to dismiss case for lack of jurisdiction. Certificate of Service dated 08/05/2010. (OT)

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Published by: Jack Ryan on Aug 06, 2010
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Case #10-3000
UNITED STATES COURT OF APPEALSFOR THE THIRD DISTRICT____________________________________
Liberi et al
 – 
AppelleesVDefend Our Freedoms Foundation, Taitz and Belcher
 – 
appellants
 
Appellants
Taitz, Belcher and Defend Our Freedoms FoundationResponse to Motion to Dismiss, filed by the appellees prior to appellantsopening brief Dr. Orly Taitz ESQ29839 Santa Margarita Pkwy, ste 100Rancho Santa Margarita CA 92688949-683-5411Attorney for the Appellants
Case: 10-3000 Document: 003110242718 Page: 1 Date Filed: 08/06/2010
 
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Background of the case
1. In an around of April of 2009 Attorney Orly Taitz, who is also a president of Defend Our Freedoms foundation was forced to start a new website for herfoundation, when her former volunteer web master Lisa Ostella without anyauthorization took over the website of her foundation and continued solicitingdonations from supporters, whereby diverting funds from the foundation, while atthe same time denigrating Taitz and promoting attorney Philip Berg.2. At the same time Taitz was contacted by Linda Belcher, former volunteer forAttorney Philip Berg, whereby Belcher disclosed that assitant for Berg, LisaLiberi, has a long wrap sheet of 10 felony convictions of forgery of documents,forgery of an official seal and grand theft.3. Taitz and licensed investigator Sankey did their due diligence conductedmultiple interviews of Liberi's arresting officer, District attorney on the case,James Secord, probation officer, victims, pulled all the public records and verifiedthat indeed assitant for attorney Berg, is Lisa Liberi, an individual, convicted inCA in 2008, who received eight years prison term, which was reduced toprobation until March of 2011. According to the terms of her probation, she isallowed to reside only in CA or NM. Exhibit 6-3 Superior court of San BernardinoCounty, CA printout of case FWV028000, defendant 1608112 Lisa Renee Liberi,aka Lisa Courville Richardson, aka Lisa Courville Rich, aka Lisa Richardson.showing 10 felony convictions. Exhibit 6-4 Superior Court of CA, San BernardinoCounty counts of indictments FSB044914 for Lisa Liberi and Exhibit 5 Superiorcourt of CA, San Bernardino County Case FWV082000 indictments for Lisa
Case: 10-3000 Document: 003110242718 Page: 2 Date Filed: 08/06/2010
 
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Liberi. Indictments show multiple schemes, where through forgery and fraudLiberi effectuated grand theft.4. In and around April of 2009 Taitz has contacted Berg by two e-mails, forwardedto him Liberi's conviction summary and advised him that she is aware of Liberi'spast, that she is aware that Liberi assists Berg by preparing documents for him andmailing those to him and that she had a number of concerns. She was concernedabout the fact that Berg and Liberi went on a number of radio shows, where theyannounced that Liberi was an able assistant for Berg, that she has prepared hiscase Berg v Obama, that contained affidavits from Kenya, attesting to Obama'sbirth there. Taitz asked Berg to allow her and forensic document expert to examinethe original documents from Africa, to make sure that those are not forged, as itwas possible in light of Liberi's convictions just a year earlier. While Taitz believesthat Mr. Obama needs to unseal his original birth certificate with the name of thehospital and doctor, she was concerned about those affidavits from Africa, as thosewill only undermine the case, and disclosure had to be made. In light of the factthat Berg and Liberi were conducting a nation wide fundraising for that case(Exhibit 6-6 Example of advertising of fundraising), Taitz advised Berg, thataccording to terms of her probation Liberi cannot be associated with anyfundraising and cannot handle credit cards of others. Additionally Taitz advisedBerg, that his association with Lisa Ostella, Taitz former web master constitutesdiversion of funds from her foundation.
Case: 10-3000 Document: 003110242718 Page: 3 Date Filed: 08/06/2010

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