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LIBERI v TAITZ (C.D. CA) - 172 - NOTICE OF MOTION AND First MOTION to Disqualify Counsel Philip J. erg - gov.uscourts.cacd.497989.172.0

LIBERI v TAITZ (C.D. CA) - 172 - NOTICE OF MOTION AND First MOTION to Disqualify Counsel Philip J. erg - gov.uscourts.cacd.497989.172.0

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Published by Jack Ryan
04/05/2011 172[RECAP] NOTICE OF MOTION AND First MOTION to Disqualify Counsel Philip J. erg Motion to terminate attorney Berg, as not licensed to practice in this jurisdiction filed by defendants DEFEND OUR FREEDOMS FOUNDATIONS, INC., ORLY TAITZ. Motion set for hearing on 5/9/2011 at 10:00 AM before Judge Andrew J. Guilford. (Attachments: # 1 Exhibit prior order to deny pro hac vice for attorney Philip J. Berg)(Taitz, Orly) (Entered: 04/05/2011)
04/05/2011 172[RECAP] NOTICE OF MOTION AND First MOTION to Disqualify Counsel Philip J. erg Motion to terminate attorney Berg, as not licensed to practice in this jurisdiction filed by defendants DEFEND OUR FREEDOMS FOUNDATIONS, INC., ORLY TAITZ. Motion set for hearing on 5/9/2011 at 10:00 AM before Judge Andrew J. Guilford. (Attachments: # 1 Exhibit prior order to deny pro hac vice for attorney Philip J. Berg)(Taitz, Orly) (Entered: 04/05/2011)

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Published by: Jack Ryan on Apr 05, 2011
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 Motion to terminate Philip Berg as an attorney on the case- 112345678910111213141516171819202122232425262728
DR. ORLY TAITZ ESQ29839 SANTA MARGARITA PKWY, STE 100RANCHO SANTA MARGARITA, CA 92688PH 949-683-5411 FAX 949-766-7603LIBERI ET AL,PLAINTIFF,VS.TAITZ AT AL,DEFENDANT))))))))))CASE NO.: 11-CV-00485OTION-REQUEST TO TERMINATE PHILIP J. BERGS AN ATTORNEY ON THE CASEHON. ANDREW GUILFORD PRESIDINGDATE 05.09.2011TIME 10:00COURTROOM 10 D
Notice of motion to terminate Philip J. Berg as an attorney of recordTo all parties and attorneys of record. On 05.09.2011, 10 am, courtroom 10D RonaldReagan federal Building, 411 4th street, Santa Ana, CA defendants "Defend OurFreedoms Foundation" and Orly Taitz will move this court to terminate Philip J. Bergas an attorney of record in this case. This motion will be based on the memorandum ofpoints and authorities attached herein, exhibits attached to this motion and oralargument on 05.09.2011.
MEMORANDUM OF POINTS AND AUTHORITIES
In order for one to be listed as an attorney of record for a party, one needs to belicensed as an attorney in the jurisdiction, where the case is heard or obtain aspecial permission to appear pro hac vice in collaboration with a local counsel.Local rule 83-2.3.1 provides for admission of attorneys pro hac vice:Permission to appear Pro Hac Vice. Any person who is not otherwise eligible foradmission to practice before this court, but who is a member in good standing of, andeligible to practice before, the bar of any United States Court, or of the highestcourt of any State, Territory or insular Possession of the United States, who is ofgood moral character, and who has been retained to appear before this Court, may, uponwritten application and proof of payment of the fee as required by the Court, and inthe discretion of the Court be permitted to appear and participate pro hac vice in aparticular case. The application shall be accompanied by a certificate from the state
Case 8:11-cv-00485-AG -AJW Document 172 Filed 04/05/11 Page 1 of 3 Page ID#:4015
 
 Motion to terminate Philip Berg as an attorney on the case- 212345678910111213141516171819202122232425262728bar for each of the states in which the applicant is a member of the particular bar,which has been issued within thirty (30) days prior to the filing of the applicationand states that the applicant is a member in good standing of the bar of that court.Philip J. Berg (hereinafter Berg) is listed as an attorney of record for all theplaintiffs in this case, however Berg is not licensed as an attorney in the state ofCalifornia. Mr. Berg, also, did not obtain pro hac vice to appear in this case as anout of state co-counsel. On March 2, 2011, only a month ago, this court denied Berg'sapplication to appear pro hac vice in this jurisdiction.(exhibit 1). Based on theabove, there is no legal ground to allow Berg to appear as an attorney on this case.Attached is affidavit by attorney Orly Taitz, attesting to the above mentioned facts.Wherefore:Defendants respectfully move this court to terminate Philip J Berg as an attorney onthis case.
Dated this 04.04.2011____________________________Dr. Orly Taitz, ESQAttorney forDefend Our FreedomsFoundation andOrly Taitz
AFFIDAVIT OF ORLY TAITZ
I, Orly Taitz, am over 18 years old, I do not suffer of any mental impairment, I havepersonal knowledge of the above facts and declare under the penalty of perjury:1. I checked the web site of the California state bar, Philip J. Berg is not alicensed attorney in the state of California according to bar.2. I checked the docket of this case, Mr. Berg did not obtain pro hac vice to appearas an attorney in this case.
Case 8:11-cv-00485-AG -AJW Document 172 Filed 04/05/11 Page 2 of 3 Page ID#:4016

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