Case 2:09-cv-01898-ER Document 144-1 Filed 09/14/10 Page 1 of 14

EXHIBIT “1”
Liberi\Opp. to Def. Taitz’s Motion for Plaintiff Liberi’s D.L.
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Law Offices of:

PHILIP J. BERG, ESQUIRE
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531 Attorney for: Plaintiffs
Identification No. 09867
(610) 825-3134

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LISA LIBERI, et al, :

:
Plaintiffs, : Assigned to Honorable Eduardo C. Robreno
:
vs. :
: Case No.: 09-cv-01898-ECR
:
:
ORLY TAITZ, et al, :
:
Defendants. :
:

AFFIDAVIT OF K. STREBEL

I, K. Strebel am over the age of eighteen (18) and not a party to the within action. I have

personal knowledge of the facts herein and if called to do so, I could and would competently

testify under oath.

I declare as follows:

1. This Honorable Court continues to be paper bombed by Orly Taitz and the rest of

the defendants in this case for the simple fact of Diversity Jurisdiction. As a witness in the case,

Mr. Berg was asking your honor to rule that the Plaintiffs and their witnesses did not have to

disclose their full names and addresses. Your Honor ruled to protect the parties. I am quoting

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from page 19 of the August 7th, Hearing Transcript that shows what occurred after Mr. Berg’s

requests.

August 7, 2009 Hearing Transcript – Page 19, Lines 2-16

The Court: Well, we know who she is. How are you going to be able to deny
that? She doesn’t have to disclose her social security number?

Mr. Berg: No, but her actual address I think would be detrimental.
The Court: Well, the actual address we could do without it.
Mr. Berg: Okay. Could that be on other people, too, or just on Ms. Liberi?

The Court: Well, you could disclose it and file it with the Court under seal.

Mr. Berg: Thank you. With all of my witnesses today?

The Court: Yes

2. As your Honor is aware, I was the first witness called. The only identification

documents I was asked if I had seen was Plaintiff Lisa Liberi’s Social Security card, which I

testified yes, I had seen. I was not asked about any other identification documents, however, I

would like to testify herein to all of the documents I saw pertaining to Plaintiff Lisa Liberi. Lisa

Liberi willingly showed me her driver’s license, both her old and new Social Security cards, both

of which were located in an envelope from the Social Security Administration. The envelope

had the post mark showing mailed from the State of Maryland. (Lisa Liberi was issued a new

Social Security number as a result of being a victim of crimes, at the same time she was placed

into the Safe at Home program and given a confidential address). Also in this envelope were 3

Cards entitled Safe at Home which had the names of Lisa Liberi, Her Husband and her Son, all

of which she provided to you during the August 7th Hearing for you to verify for yourself. I also

was able to view her Marriage License to her Husband.

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3. All of the above information shown to both me and the Court on August 7, 2009

and the fact I talk to Lisa Liberi almost on a daily basis proves that Lisa Liberi does NOT reside

within the States of California or Texas, which I believe the Defendants are well aware of. Any

further attempt of Orly Taitz or Neil Sankey and the remaining Defendants to place her residency

as such is dishonest and simply wasting your time Your Honor and the valuable recourses of the

Court that can be better served elsewhere. Defendant Taitz continues stating Plaintiff Liberi

showed a Pennsylvania Driver’s License. Defendant Taitz was not present for Court on August

7, 2009, and at NO time has it been filed or testified to, the State of issuance of Plaintiff Lisa

Liberi’s driver’s license.

4. Plaintiff Lisa Liberi and her son are victims of Domestic Violence type crimes

from one John Mark Allen, father of Lisa Liberi's son. For this reason alone, I hope this Court,

as it should, denies Defendant Orly Taitz’s Motion for the driver’s license of Plaintiff Liberi, and

deny Defendant Taitz any type of access to Plaintiff Liberi and her family’s residence.

Defendant Orly Taitz will continue to publish all the private data of Lisa Liberi and her family,

as she continues to do along with Plaintiff Lisa Liberi’s family picture.

5. Since the August 7th, 2009 Hearing Defendant Taitz and John Mark Allen have

colluded to further bring harm to Lisa Liberi. According to Defendant Orly Taitz and Defendant

Neil Sankey's claim that John Mark Allen provided the photograph, filed in this Court several

times and posted all over the Internet by Defendant Orly Taitz. The truth of the matter is

Plaintiff Liberi’s family picture was obtained from Lisa Liberi’s computer illegally, where this

photograph was stored. No one in the Liberi family provided the picture to John Mark Allen yet

he confirms the picture to be that of Lisa Liberi, Her Husband and Son with the picture of her

son blacked out. Defendant Orly Taitz has sent Plaintiff Liberi’s picture, which she (Taitz)

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illegally obtained, over the Internet numerous times, and posted it all over her website in

approximately 6 different locations. And, Defendant Taitz again posted Plaintiff Liberi’s family

picture this September 10th, 2010 Weekend on two (2) separate documents posted on her

website1. With this, Defendant Taitz has again violated Lisa Liberi and her family's First and

Fourteenth Amendment rights, not to mention the fact that Defendant Orly Taitz is not only

harassing Plaintiff Liberi, she is cyber-stalking Lisa Liberi and her family.

6. Defendant Orly Taitz continues to spew her falsified rhetoric regarding Plaintiff

Philip J. Berg, Esquire’s nationwide fundraising falsely claiming Plaintiff Liberi has access to

Credit Cards for those who would donate to help Mr. Berg. It is true that Mr. Berg has a PayPal

account on his website, and the truth of the matter is when you click onto PayPal, you enter

PayPal’s private server. The person donating the money fills out his or her own information.

PayPal then sends a receipt to the PayPal owner who received the donation, showing a donation

made, the date of the donation, the amount of the donation, and the person’s. Defendant Orly

Taitz is well aware of this as she too has a PayPal Account. Defendant Orly Taitz has lied to this

Court, the public and law enforcement attempting to have Plaintiffs Lisa Liberi and Lisa Ostella

falsely arrested. Defendant Taitz is again wasting the Courts time with her continued lies and

further distortion of the truth.

7. Defendant Orly Taitz continues to accuse Plaintiffs Liberi, Ostella and Berg of the

crimes in which she (Taitz) is actually committing (“Projection”). For instance, Defendant Taitz

was sanctioned $20,000.00 by Judge Clay D. Land, U.S. District Court, Middle District of

Georgia. Defendant Taitz has been begging her supporters for money to cover the sanctions. As

of September 12, 2010, Defendant Taitz’s claims she has collected $6,701 and needs to collect

1
http://www.orlytaitzesq.com/?p=13878 and http://www.orlytaitzesq.com

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an additional $13,299.00 to make a full $20,000.00.2 What Defendant Taitz failed to tell her

supporters is that the sanctions have been paid. A deception to the general public in order to be

able to reimburse herself (Taitz).

8. This Court should also be aware that Defendant Taitz continues her California

Secretary of State fundraising on her website at www.orlytaitzesq.com, even though she is not

the Republican Nominee, and not on the ballot for California Secretary of State. See EXHIBIT

“A”.

9. I would like to address Defendant Orly Taitz’s statement that she is a Dentist,

Lawyer and never been convicted of any crimes. This is completely false. A simple search of

only the Orange County Superior Court returns seven (7) convictions for traffic violations; bail

forfeitures; and a failure to appear3:

10. In addition, as I’m sure this Court may have noticed, the past few filings in this

Court by Defendant Orly Taitz that are filled with untruthful and false allegations, Defendant

Taitz has sent to Judge David O. Carter, and Chief Judge Audrey B. Collins of the U.S. District

Court, Central District of California, Southern Division for absolutely no permissible purpose,

other than to prejudice the Judges and/or to force the Judges in this District to recuse themselves,

as this is the Court Your Honor Ordered transfer of the within matter to. This is documented on

the Certificate of Service on the filings made by Defendant Taitz. Defendant Taitz’s actions

interfere with the proper administration of justice and therefore, constitutes criminal Obstruction

of Justice. The definition of Obstruction of Justice is “the crime or act of willfully interfering

with the process of justice and law esp. by influencing, threatening, harming, or impeding a

2
http://www.orlytaitzesq.com/?p=13942
3
https://ocapps.occourts.org/Vision_Public/DisplayCaseInfo.do?caseobjid=1284188012325&src=case_src

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witness, potential witness, juror, or judicial or legal officer or by furnishing false information

in or otherwise impeding an investigation or legal process”4 [emphasis added] See

Defendant Orly Taitz’s Certificate of Service pages on file with this Court attached as EXHIBIT

“B” and “C”.

11. It is my understanding that the Federal Courts in California are assigned based on

the alphabet split. Meaning it appears that Judge David O. Carter has the alpha split J, K, L,

which means this case would be assigned to him.

12. Defendant Taitz has also stated that she continues putting out Plaintiff Liberi’s

information because she is a career document forger , which is not true, and the public has a

right to know. Defendant Taitz further states she does not associate with any criminals. This is

a complete lie to this Court. Defendant Taitz has employed (volunteers) and called for

witnesses, all of which have criminal records. Just to name a few:

Pamela R. Feldman, (1957) a/k/a Heaven Feldman a/k/a Pamella Rowlette and other aka’s.
Convicted Felon.
Volunteer of Defendant Orly Taitz. Also one of the people threatening Plaintiffs Liberi, Ostella
and Berg on the Internet
Florida Court Report for Pamela Feldman;
08/15/1994 Homicde-wilful Kill
07/25/1994 Criminal Solicitation to commit Aggravated Battery
03/01/2007 Aggravated Battery.

Cody Robert Judy (1965) also used birth year 1966.

Worked with Taitz on Barnett vs. Obama and attempted to file a joinder
On Feb. 7, 1993, Cody Judy interrupted a BYU fireside where LDS apostle Howard W. Hunter
was speaking. Judy held a briefcase containing what he said was a bomb, and in his other hand
he held what he said was a detonator. There were 14,000 – 17,000 people in attendance during
this event. He served 8 years in prison. He went back to prison in 2001 for aggravated
Burglary.

Walter Francis Fitzpatrick, III, (1952)

Worked with Defendant Orly Taitz , re: Implementation of Citizen Grand Jury’s

4
http://dictionary.reference.com/browse/obstruction+of+justice

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There are many, many convictions throughout the years: Approx. 6 convictions of Harassment,
assault, coercion by use of threat, approx. 2 convictions of fraud, theft, and many more.
Fitzpatrick is currently up on more criminal charges, as he was indicted on the following:
Rioting; Disrupting a Meeting; Disorderly Conduct; Resisting Arrest; Retaliation for Past Action
(felony); and Civil Rights Intimidation (felony)
State of TN v. Walter F. Fitzpatrick, III, In the Criminal Court for Monroe County, at
Madisonville, TN Case No. 10213

Charles Edward Lincoln, III, (1960).

Part of Defendant Taitz’s Legal team. Worked as Orly Taitz’s Legal Assistant, prepared
documents; signed Orly Taitz’s name to documents and filed them with the Courts, was even
introduced to Your Honor on June 25, 2009 as Defendant Taitz Legal Assistant
Deemed a Domestic/Paper Terrorist. Convicted Felon (convicted in Texas) – convicted of using
a false Social Security number to open Bank account and was accused of forging a Federal
Court Receipt and attempting to pay off the witnesses. See
http://members.calbar.ca.gov/fal/Member/Detail/171793 Mr. Lincoln gave up his law license in
Texas as part of the plea agreement and was disbarred from Florida and California. Mr. Lincoln
had a falling out with Taitz when Lucas Daniel Smith made public the adulterous affair between
Lincoln and Defendant Orly Taitz.

Lucas Daniel Smith – (1980)

Convicted Felon
Witness and Employee of Orly Taitz. Had a falling out with Taitz when Taitz wanted him to lie
about some matters in Court. Smith refused and wrote affidavit to Federal Judge Carter
regarding the matter. Also swore that according to an email he received originating from Yosef
Taitz, Defendant Orly Taitz’s husband, Mr. Smith believed Yosef Taitz was who created the
forged Kenyan Registration of Birth bearing the name Barack H. Obama, which Defendant Taitz
filed in the Federal Court in California, the same document Defendant Taitz wanted Lucas D.
Smith to give false testimony claiming he (Smith) obtained the Kenyan Registration of Birth for
Defendant Taitz, which he did not.
State of Iowa v. Lucas Daniel Smith - Convictions: 3 or 4 convictions of Forgery by making
false licenses, ID forms or blank forms; approximately 4 convictions of theft.
06571 FECR 23705; 05771 FECR 144901; 05501 FECR 007084; 06521 FECR 054329.

Larry Sinclair
Convicted Felon
Witness of Orly Taitz. Orly Taitz asked him to lie in court on several matters. Mr. Sinclair
refused to perjure himself, went home and sent affidavit to Federal Judge Carter about Taitz
asking him to lie in court. Mr. Sinclair also mentioned in his affidavit filed with this Court that
Defendant Orly Taitz admitted she was aware the two (2) Kenyan birth documents she filed in
Court as genuine, were forged and altered.

Leo Patrick Haffey,

Works with Orly Taitz drafting legal documents.
Assault’; May 17, 2010 Aggravated Assault; May 17, 2010

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Arrested in May 2009 (warrant issued 5/12/2009) for aggravated assault (Serious Bodily injury
or weapon) upon the prosecutor, prosecuting the case against Haffey.
Arrested in May 2009 (warrant issued 5/12/2009) for Assault upon another prosecutor,
prosecuting Haffey. May 17, 2010, Violation of protective order; May 17, 2010 convicted of
domestic offense:
John Mark Allen (1956) – lives close to Taitz in South Orange County, Southern California
Convicted of burglary of Lisa Liberi’s home
Protective Orders for stalking Lisa Liberi and violence against son. Lisa Liberi was placed in the
safe at home project, given a confidential address, and new SSN.
Defendants Orly Taitz and Neil Sankey sought out John Mark Allen, gave the personal
information of Lisa Liberi to him, knowing Lisa Liberi was protected from this man, as it was
plead in the Complaint against the Defendants.

L.S. (Initials replaced actual name to protect this party), Conviction or convictions in theft.
Works with Orly Taitz. Orly Taitz advertised that people email their credit card information to
her and L.S. for an event in Texas.

11. This Court should note, Defendant Taitz continues falsely claiming Plaintiff

Liberi is taking all the credit cards for donations into the Law Offices of Philip J. Berg, Esq. that

is completely false. But, as you can see, and this party’s name will be provided to the court

under seal, if needed, it was in fact Defendant Orly Taitz and her supporters taking credit cards

over the phone and via email for an event in Texas.

12. I have also included below Opinions from other Court’s in which Defendant Orly

Taitz has appeared, to show the pattern of Defendant Orly Taitz for deception and additional

criminal intent, which has been noted in the followoing cases regarding Defendant Orly Taitz:

Barnett, et al v. Obama - U.S. District Court, Central District of CA, Southern

Division, Case #09-cv-00082-DOC

California Federal Judge David O. Carter received several affidavits from

witnesses, which claimed Orly Taitz wanted them to lie on the stand. Judge
Carter found, and stated “...Plaintiffs’ counsel has favored rhetoric seeking to
arouse the emotions and prejudices of her followers her witnesses...” [Judge
Carter’s Opinion and Order of Oct. 29, 2009, Para. “F”, pg. 28, ll 4-5]. Judge
Carter further found “Additionally, the Court has received several sworn
affidavits that Taitz asked potential witnesses that she planned to call before this
Court to perjure themselves. This Court is deeply concerned that Taitz may have

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suborned perjury through witnesses she intended to bring before this Court.”
[Judge Carter’s Opinion and Order of Oct. 29, 2009, pg. 29, ll 1-4].

Rhodes v. McDonald, et al, U.S. District Court, Middle District of Georgia,

Case No. 4:09-cv-106 (CDL).

Federal Judge Clay D. Land of Georgia sanctions Orly Taitz for unethical
behavior and sends complaint to State Bar of California.
Judge Clay D. Land sanctioned Orly Taitz $20,000.00 for her inappropriate
actions, in so doing, Judge Land found “The Court concludes from this conduct
that counsel did have an intent to injure anyone associated with the litigation who
did not agree with her.” [Judge Land Opinion and Order of Oct. 13, 2009, pg. 34]
Judge Land further ordered “The Court further directs the Clerk of this Court to
send a copy of this Order to the State Bar of California, 180 Howard Street, San
Francisco, CA 94105, for whatever use it deems appropriate.” [Judge Land
Opinion and Order of Oct. 13, 2009, pg. 42]

13. Further, a convicted felon by the name of Ruben Nieto attempted to receive

payment from Defendant Taitz with 3 simultaneous money requests, one in the amount of $9,000

and two (2) in the amount of $8,000, totaling $25,000.00 on two (2) separate occasions, May 25,

2009 and May 29, 2009. Interesting the amounts being requested were each under $10,000,

under the limits of reporting pursuant to the Patriot Act. Ruben Nieto, according to Court

Records, was convicted of Aggravated Assault. It is believed Defendant Taitz was hiring Ruben

Nieto to harm Plaintiffs Liberi, Ostella and their families.

14. Defendant Orly Taitz threatened to take Philip J. Berg, Esquire down, and to do

so she stated she was going to destroy his paralegal, Lisa Liberi, and get rid of her. The only

reason, I can think of, that Defendant Taitz’s wants Plaintiff Liberi’s driver’s license, is for

confirmation of Plaintiff Liberi’s address, to post all over the Internet and to carry out the

balance of her threat, to get rid of Plaintiff Liberi. Defendant Taitz has already destroyed

Plaintiffs Liberi and Ostella.

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15. Defendant Taitz also claims in her filing that Plaintiffs have failed to file any

evidence or proof. Plaintiffs have filed thousands of pages, most of which were Defendant Taitz

very own posts published by Defendant Taitz on her own website and taken directly from

Defendant Taitz’s website. It is Defendant Taitz who continues falsely accusing Plaintiffs

Liberi, Ostella and Berg of falsified criminal activities, and fails to file any type of collaborating

evidence whatsoever, as demonstrated by Defendant Taitz’s own Court filings. This is clearly

because Defendant Taitz knows her stories are falsified. It should also be noted, and it was filed

in this Court, it was Defendants Taitz, Sankey and Linda Belcher who were forging and altering

the Plaintiffs Emails and a chat logs, again the proof was filed with this Court.

16. Defendant Taitz next contends that the Plaintiffs, especially Plaintiff Liberi, have

lied to the Court claiming harassment and stalking, as they have never been harassed. This is

also untrue. Again, all of Defendant Taitz’s publications on her website show continued

harassment, stalking and cyber-stalking. The definition of harassment is “1). to disturb

persistently; torment, as with troubles or cares; bother continually; pester; persecute. 2). to

trouble by repeated attacks, incursions, etc., as in war or hostilities; harry; raid.”5 The definition

of Stalking is “the act or crime of willfully and repeatedly following or harassing another person

in circumstances that would cause a reasonable person to fear injury or death esp. because of

express or implied threats; broadly a crime of engaging in a course of conduct directed at a

person that serves no legitimate purpose and seriously alarms, annoys, or intimidates that

5
http://dictionary.reference.com/browse/harassment

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person”6 And, the crime of cyber-stalking is “using tactics that harass and threaten their victims,

such as posting the victim’s name and address on the Internet along with false claims.”7

17. Your Honor, it is true that irreparable damage has already been done to Plaintiff

Liberi and her husband with Identity Theft, however, each time Defendant Taitz publishes a post

with Plaintiff Liberi’s information and picture, or a video about the Plaintiffs with false

information that is posted and circulated by Defendant Taitz, the chances increase that

individuals who suffer mental illnesses or violent tendencies, will react with violence toward the

Plaintiffs. According to affidavits filed with the Courts and Complaints filed with the State Bar

of California, Defendant Taitz has asked “her people” to lie or perjure themselves in Federal

Court. Thus, Defendant Taitz is certainly capable of demanding violence towards the Plaintiffs

from “her people”, which it appears she has already done.

18. PayPal records already show a violent convicted felon, Ruben Nieto, attempted to

get paid in increments of $8,000 and $9,000, totaling $25,000 from Orly Taitz on two separate

occasions. To date, this Honorable Court has not taken steps to stop Defendant Orly Taitz, and I

pray that the Court does not assist Defendant Taitz’s further by allowing her to continue her daily

distribution through the Internet by posting her falsified allegations, Plaintiffs private data and

her falsified video tapes regarding the Plaintiffs.

19. In addition, Defendant Taitz has her “supporter” and Plaintiff in cases which were

dismissed, sent out by mass email Plaintiff Liberi’s picture and the address which Defendant

6
http://dictionary.reference.com/browse/stalking (Legal Dictionary)
7
Wayne Petherick, Cyber-Stalking: Obsessional Pursuit and the Digital Criminal, The Crime Library, (cyber-
stalking is “an extension” of “real world” stalking in which “electronic mediums such as the Internet” are used to
“pursue, harass or contact another in an unsolicited fashion”). See i-safe America, Cyber Stalking.

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Taitz believes is Plaintiff Liberi’s home address. In addition, Defendant Taitz posts these on her

website, see EXHIBITS “D” and “E”. Your Honor, these two (2) emails were also sent to

Militia and White Supremacy Groups.

20. Defendant Taitz has continually published Plaintiff Liberi’s Social Security

number, date of birth, place of birth, mother’s maiden name, the address which Defendant Taitz

believes is Plaintiff Liberi’s home address, Plaintiff Liberi’s family picture, A phone number

which Defendant Taitz’s believes is Plaintiff Liberi’s telephone number, and many false

allegations about Plaintiff Liberi, Ostella and Berg, see EXHIBITS “F” through “X”, which

are posts just since July 1, 2010. All previous posts by Defendant Taitz have previously been

filed with this court. I have also attached a blog-url search using the terms

blogurl:http://www.orlytaitzesq.com(space)Liberi, so this Court can see the continued posts by

Defendant Taitz just as to Plaintiff Liberi, see EXHIBIT “Y”, please note in the search, Dossier

#6 still appears. The return for Plaintiff Ostella blog-url search is attached as EXHIBIT “Z”.

Plaintiffs Liberi and Ostella are continually harassed, they receive death threats, they live in fear

daily. As this Court can see, all the elements of Harassment, Stalking and Cyber-Stalking have

been met.

21. Your Honor, the longer Defendant Taitz is permitted to get away with her

unlawful actions, the more serious the crimes have become. Your Honor our courts are here to

utilize to protect those parties and situations that get in the way of safety and violations of the

law. Defendant Taitz actions have become more serious and escalated, as clearly demonstrated

by her continued publication of Plaintiff Liberi’s family picture, continued publication of where

she believes Plaintiff Liberi resides, defendant Taitz’s recent radio appearances, continued

attacks on the Plaintiffs, and the fact she (Taitz) had an actor, David Acton to do a video on or

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