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Liberi v Taitz Plaintiffs Opposition to Taitz Motion for Reconsideration

Liberi v Taitz Plaintiffs Opposition to Taitz Motion for Reconsideration

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Published by nocompromisewtruth
The wise learn many things from their foes.
The wise learn many things from their foes.

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Published by: nocompromisewtruth on Feb 03, 2011
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02/04/2011

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Liberi\Plaintiffs’ Resp. in Opposition to Def. Taitz’s Frivolous Motion(s) 02/03/20111
Law Offices of:
Philip J. Berg, Esquire
555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531Identification No. 09867(610) 825-3134
 Attorney for Plaintiffs
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 
PLAINTIFFS’ RESPONSE IN OPPOSITION TO DEFENDANT ORLY TAITZ’SFRIVOLOUS MOTION TO CORRECT ERRORS; FRIVOLOUS MOTION TODISMISS; and FRIVOLOUS MOTION FOR SANCTIONS
Plaintiffs by and through their undersigned counsel, Philip J. Berg, Esquire, herebyOppose Defendant, Orly Taitz’s [hereinafter “Defendant”], who is an attorney licensed to practice Law, frivolous Motion to Correct Errors pursuant to the Federal Rules of CivilProcedure [Fed. R. Civ. P.] 59(e) and 60(b); frivolous Motion to Dismiss; and frivolous Motionfor Sanctions. In support thereof, Appellees set forth the following:1.Defendants’ Motion(s) are frivolous.2.This Court lacks jurisdiction to entertain Defendants’ Motion to Dismiss as theissues are under Appeal to the Third Circuit Court of Appeals.3.Defendants are asking for reconsideration pursuant to Federal Rules of CivilProcedure 59(e) of the Court’s December 23, 2010 Memorandum. Motion’s for 
Case 2:09-cv-01898-ER Document 166 Filed 02/03/11 Page 1 of 17
 
Liberi\Plaintiffs’ Resp. in Opposition to Def. Taitz’s Frivolous Motion(s) 02/03/20112
Reconsideration must be filed ten (10) days of the Court’s ruling. ThereforeDefendants’ Motion is untimely and must be denied.4.Defendants in the alternative are trying to Amend the Court’s December 23, 2010Memorandum pursuant to Federal Rules of Civil Procedure Rule 60(b).Defendants’ request is not based on
an intervening change of controlling law”; the“availability of new evidence”, or the “need to correct a clear error or preventmanifest injustice”
, nor was the motion filed timely. Therefore, Defendants’Motion must be denied.5.Defendants have again intentionally misquoted and misstated the facts of the case;testimony; documents on file with this Court and part of the Court’s Record; andwhat this case is about, which is extremely prejudicial to the Plaintiffs.6.Defendants’ Exhibits are unauthenticated documents, hearsay documents,redundant, irrelevant, immaterial, and scandalous material, in violation of theFederal Rules of Evidence.7.Defendants’ Motions are not only unwarranted, but it is in violation
of Fed. R.Civ. P.
11.For the reasons stated herein, Defendants’ filing of February 1, 2011, Docket Entry No.165, must be denied.Respectfully submitted,Dated: February 3, 2011___________________________Philip J. Berg, Esquire555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531(610) 825-3134
 Attorney for the Plaintiffs’ 
s/ Philip J. Berg
Case 2:09-cv-01898-ER Document 166 Filed 02/03/11 Page 2 of 17
 
Liberi\Plaintiffs’ Resp. in Opposition to Def. Taitz’s Frivolous Motion(s) 02/03/20113
Law Offices of:
Philip J. Berg, Esquire
555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531Identification No. 09867(610) 825-3134
 Attorney for Plaintiffs
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 
PLAINTIFFS’ MEMORANDUM OF LAW IN SUPPORT OF THEIR OPPOSITION TODEFENDANTS’ FRIVOLOUS MOTION TO CORRECT ERRORS; FRIVOLOUSMOTION TO DISMISS; and FRIVOLOUS MOTION FOR SANCTIONS
On July 2, 2010, Defendant Orly Taitz [hereinafter at times “Defendant”] AppealedJurisdiction of this Court; this Court’s Order Severing and Transferring the within case toCalifornia and Texas; and this Court’s Order Dismissing Defendants James Sundquist and Rock Salt Publishing.Although the Appeal is still pending, Defendants have now filed another Motion with thisCourt pursuant to
 Fed. R. Civ. P.
59(e) and 60(b) asking this Court to Amend its prior Orders,the same Orders currently under Appeal; Motion to Dismiss, which is Defendants’ fifth or sixthMotion to Dismiss; and Motion for Sanctions, of which this Court is without jurisdiction toentertain.
Case 2:09-cv-01898-ER Document 166 Filed 02/03/11 Page 3 of 17

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