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LINCOLN v DAYLIGHT CHEMICAL, et al. - 24.2 - - 031111532355.24.2

LINCOLN v DAYLIGHT CHEMICAL, et al. - 24.2 - - 031111532355.24.2

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Published by Jack Ryan
# 2 Exhibit Sanctions against the Plaintiff's proposed pro hac vice counsel, PA attorney Philip Berg, - 01/09/2011 24 NOTICE OF MOTION AND MOTION for Joinder in Request for Judicial Notice, Request for Relief 7 , MOTION to Strike Plaintiff's First Claim for Relief Pursuant to Section 425.16 of the California Code of Civil Procedure 18 , Declaration (Motion related), Declaration (Motion related), Declaration (Motion related) 21 , Request for Judicial Notice, Request for Relief,,,,,, 22 , Amendment (Motion related) 12 , Declaration (Motion related), Declaration (Motion related), Declaration (Motion related) 20 , MOTION to Strike Plaintiff's First Claim For Relief, Pursuant To Section 425.16 Of the California Code Of Civil Procedure MOTION to Strike Plaintiff's First Claim for Relief Pursuant to Section 425.16 of the California Code of Civil Procedur 19 , First MOTION to Dismiss Case 6 filed by defendants Orly Taitz Inc. Motion set for hearing on 2/7/2011 at 10:00 AM before Judge Andrew J. Guilford. (Attachments: # 1 Exhibit Record of some 70 legal actions in Federal courts with Lincoln as a party, # 2 Exhibit Sanctions against the Plaintiff's proposed pro hac vice counsel, PA attorney Philip Berg, # 3 Exhibit Mug shot and CA criminal record of Lisa Liberi, paralegal for the Plaintiff's proposed pro hac vice counsel, PA attorney Philip berg, # 4 Exhibit Plaintiffs CA candidate for office registrar form, negating his claims of TX residency, # 5 Exhibit Evidence of pattern of similar frivolous RICO actions, Lincoln v Freiman)(Taitz, Orly) (Entered: 01/09/2011)
# 2 Exhibit Sanctions against the Plaintiff's proposed pro hac vice counsel, PA attorney Philip Berg, - 01/09/2011 24 NOTICE OF MOTION AND MOTION for Joinder in Request for Judicial Notice, Request for Relief 7 , MOTION to Strike Plaintiff's First Claim for Relief Pursuant to Section 425.16 of the California Code of Civil Procedure 18 , Declaration (Motion related), Declaration (Motion related), Declaration (Motion related) 21 , Request for Judicial Notice, Request for Relief,,,,,, 22 , Amendment (Motion related) 12 , Declaration (Motion related), Declaration (Motion related), Declaration (Motion related) 20 , MOTION to Strike Plaintiff's First Claim For Relief, Pursuant To Section 425.16 Of the California Code Of Civil Procedure MOTION to Strike Plaintiff's First Claim for Relief Pursuant to Section 425.16 of the California Code of Civil Procedur 19 , First MOTION to Dismiss Case 6 filed by defendants Orly Taitz Inc. Motion set for hearing on 2/7/2011 at 10:00 AM before Judge Andrew J. Guilford. (Attachments: # 1 Exhibit Record of some 70 legal actions in Federal courts with Lincoln as a party, # 2 Exhibit Sanctions against the Plaintiff's proposed pro hac vice counsel, PA attorney Philip Berg, # 3 Exhibit Mug shot and CA criminal record of Lisa Liberi, paralegal for the Plaintiff's proposed pro hac vice counsel, PA attorney Philip berg, # 4 Exhibit Plaintiffs CA candidate for office registrar form, negating his claims of TX residency, # 5 Exhibit Evidence of pattern of similar frivolous RICO actions, Lincoln v Freiman)(Taitz, Orly) (Entered: 01/09/2011)

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Published by: Jack Ryan on Jan 10, 2011
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02/03/2011

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A July 25, 2005 article
from The Legal Intelligencer, “Lawyer Slapped With $10K in
Sanctions for 'Laundry List of Unethical Actions' sums the situation here up:
Finding that a Pennsylvania lawyer had committed a "laundry list of unethicalactions," a federal judge has imposed more than $10,000 in sanctions andordered the lawyer to complete six hours of ethics training.
U.S. District Judge J.Curtis Joyner's 10-page opinion in
Holsworth v. Berg
is packed with criticism of the conduct of attorney Philip Berg of Lafayette Hill, Pa."Other attorneys shouldlook to Mr. Berg's actions as a blueprint for what not to do when attempting toeffectively and honorably perform the duties of the legal profession," Joynerwrote. "This court has grown weary of Mr. Berg's continuous and brazendisrespect toward this court and his own clients. Mr. Berg's actions ... are anenormous waste of judicial time and resources that this court cannot, in goodconscience, allow to go unpunished," Joyner wrote
. In the suit, Berg is accused of legal malpractice by former clients who claim his failure to respond to an ERISAclaim against them led to a default judgment. But the sanctions against Berg stemfrom his decision to file a third-party counterclaim of fraud against a pension fundthat had sued his former clients, according to court papers. Joyner blasted Bergfor filing the fraud claim, calling it an "irresponsible decision" because the claimwas "utterly barren of any scintilla of legal principles." Berg's motion was rejected
Case 8:10-cv-01573-AG -PLA Document 24-2 Filed 01/09/11 Page 1 of 3 Page ID#:493
 
and a default judgment of more than $5,300 was entered against his clients. The judgment swelled to more than $10,000 when Carpenters Health latersuccessfully moved for a supplemental judgment to recover more than $4,700 inattorney fees for its efforts in responding to Berg's untimely motions. Holsworthand his wife later filed a legal malpractice suit against Berg in the PhiladelphiaCounty Court of Common Pleas, alleging that Berg negligently failed to representthem in the Carpenters Health case. A year later, in February 2005, Berg moved to join Carpenters Health as a third-party defendant in the malpractice suit,demanding more than $20,000 in damages. In his counterclaim, Berg alleged thatthe ERISA suit filed by Carpenters Health in 2001, which led to the malpracticeclaim against him, was "a fraud upon the court and a fraudulent taking from theHolsworths."Carpenter Health's lawyers removed the case to federal court andfiled a motion to dismiss the claim. Joyner agreed, finding that Berg's fraud claimwas "frivolous" and was motivated by an intent "to harass Carpenters Health andthe Holsworths, as well as to delay and disrupt the administration of justice." Theclaim was fatally flawed, Joyner found, because Berg had no standing to bring suitagainst Carpenters Health and had "failed to conduct even a minimally reasonableinquiry before filing his complaint." Granting summary judgment in favor of Carpenters Health, Joyner said he found it "wholly unnecessary" even to consider
Case 8:10-cv-01573-AG -PLA Document 24-2 Filed 01/09/11 Page 2 of 3 Page ID#:494

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