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LIBERI v TAITZ (C.D. CA) - 175 - REPLY First MOTION to Disqualify Counsel Philip J. erg - gov.uscourts.cacd.497989.175.0

LIBERI v TAITZ (C.D. CA) - 175 - REPLY First MOTION to Disqualify Counsel Philip J. erg - gov.uscourts.cacd.497989.175.0

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Published by Jack Ryan
04/18/2011 175[RECAP] REPLY First MOTION to Disqualify Counsel Philip J. erg Motion to terminate attorney Berg, as not licensed to practice in this jurisdiction 172[RECAP] filed by Defendants DEFEND OUR FREEDOMS FOUNDATIONS, INC., ORLY TAITZ. (Attachments: # 1[RECAP] Exhibit criminal record of 23 felony charges and 10 felony convictions for forgery and grand theft of Lisa Liberi, legal assistant to attorney Berg, # 2 Exhibit opposition to pro hac vice of Berg in case 10-1573)(Taitz, Orly) (Entered: 04/18/2011)
04/18/2011 175[RECAP] REPLY First MOTION to Disqualify Counsel Philip J. erg Motion to terminate attorney Berg, as not licensed to practice in this jurisdiction 172[RECAP] filed by Defendants DEFEND OUR FREEDOMS FOUNDATIONS, INC., ORLY TAITZ. (Attachments: # 1[RECAP] Exhibit criminal record of 23 felony charges and 10 felony convictions for forgery and grand theft of Lisa Liberi, legal assistant to attorney Berg, # 2 Exhibit opposition to pro hac vice of Berg in case 10-1573)(Taitz, Orly) (Entered: 04/18/2011)

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Categories:Types, Research, Law
Published by: Jack Ryan on Apr 18, 2011
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01/27/2013

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1
2
3
456
189
l0
t1
1213L41516
I1
1B
1920
212224
25
Zt'
21
ZO
DR.
ORI.Y
TArTZ
ESQ
29839
SAI.ITA
I'IARGA!{ITA
PKIfY,
STE
100
RA}ICHO
SAI{TA
MARGARITA,
CA
92688
PH
949-683-5411FAx
949-766-7603
US
DISTRICT
COT'RT
FOR
THE
CENTRAI,
DISTRICT
OF
CAIIFORNIA
LIBERI
ET
AL,PI.AINTIFF,
vs.
TAITZ AT
AT.,
/
CASE
NO.
:
11-Cv-00485
Reply to opposition to
MOETON-REQI'EST
TO
TERMTNATE
PHILIP
J.
BERG
AS
A}I
ATTORNSY
ON
TTTECASE
HON.
A}IDREW GUILFORD
PRESIDING
DATE
05.09.2011
TIME
10:00
cottRTRooM
10
D
EFEIIDA}IT
Defendants
are
hereby
replying to opposition totheir motlon tcdisqualifyattorney Bergrdsan attorney ofrecord for
the
plaintiffs.
Defendants
assert thatPlaintiffs oppositionisnothingbut
dozens
of
pages
of
ouLrageous, unfounded
allegationsand slander,withoutany relationsto the
moti-on.
Pennsylvania
Attorney Philip J.Berg(hereinafterBerg) didnotprovide
any
1egal
ground
which
would al-low
him toserveas an attorney
on
thiscase.
Allowi-ng
Berg
to
proceed
asan
at-torney
onthis
case
will
be
aiding
and
abetting
an
unlicensed
practiceof
law.
MEMORJA}IDUM
OF
POINTSAI{D
AUTHORTTIES
1.
Defendants
have
fil-ed a
one
page
motion,pointingout to
the
court the fact that
Pennsylvania
attorney Philip J.Berg islisted asplaintiff'sattorney in this case/
however
he
cannot
serve asPlaintiffs'attorneyr dshe isnot Iicensedas
an
attorney inCalifornia, did notobtainprohac vice,
cannot
obtainprohacvice,ds he doesnot have a localattorney-signatoryforpro
hac vj-ce
and
Berg'spriorrequest forpro
hac
vj-ce,
(even
withsignatoryin apriorcase),
was
denled
by thiscourt. An order of
deni-af
ofprohac vice
was
attached as
an
Motion to terminatePhilipBergas an attorneyonthe case-
l-
Case 8:11-cv-00485-AG -AJW Document 175 Filed 04/18/11 Page 1 of 6 Page ID#:4057
 
124
561
I
9
1011
I2
13141516
I1
1879
2A
2I
22232425
26
2'7
2B
exhibit..Oppositionto the motionis
supposed
to revolve
around
t.he
motion itself
and
pointsraised in the motion.Instead
of
responding
to this
one
page
motion
and
explainingon
what
legal
ground
can Bergpossibly
proceed
as anattorneyon this
case,
Bergprovided
some
30
pages
in totalof
outrageous
unfounded
alleqationsandslander ofDefendants' attorneyTa:-tz.
Such
response
isfrivolous
and
made
wit.h
malice.Taitz deniesall
of
theslanderous allegations.Addj-tionally,oppositiondid
not
providea singlelaworstatute thatwiIlprovidethis
court
withjurisdictionto allowanunlicensedindividualto serve
as
an
attorney
on
the case.
Berg
didnotrefute thefactthat;a.
he
isnot licensedinCaliforniab.he doesnothave a CaliforniaIicensed
attorney,
willing to signapro
hac
vice for
him
whoisc. hj-sprohacviceapplicationin another
case
was
denied
by
this courtjust
one
month
ago
d. thereis ne statuteallowing'this courttoqrant
one
arightto
serve
as
an
attorney,while notbeinglicensed
and
without
a
localcounsel,
who
wouldsign aprohac vice,particularly
in
lightof thefact thatPhilip
Berg
is currentlyinthe midst
of
Disciplinalytrial institutedbytheDisciplinary
Board
of
the
Supreme
courtof
Pennsylvania.The
first dayof hearing
was
on
April1,
2011
and
the
proceedingscontinue.
2.
Berg
statesthat he
should
be
allowed
to
serve
as
anattorney
on this case,
eventhough
hej-snotlicensed,
does
nothave
a
Iocalattorneyandis inthemidst ofdisciplinalytrial'
because
he
didnot
have
time tofind aCaliforniaattorney.
This
stalement
d.oes
nothold wateI,asBerg andPl-aintif
f
s had
Lwc
Motion to terminatePhilip
Bergi
as an attorneyon thecase-
2
Case 8:11-cv-00485-AG -AJW Document 175 Filed 04/18/11 Page 2 of 6 Page ID#:4058
 
1
23
4
56
'1
I
o
10
l1
1,2
13
I4
1516
I7
1B
19
2021
22
23
2425
26
2728
yearsto find a Californiaattorney. This case
was improperll
flledinfederalcourt
and
improperly filed in Pennsylvania
b1
theplaintiffson May 4,2009. Shortly thereafter
presiding
judgeinthis case, Eduardo Robreno issued anorderforplainti-f
f
s
to showcause,whVthiscaseshould not
be
dismissed due tol-ack ofjurisdictionor in alternativetransferredoutof
Pennsylvanla,
ds suchthe Plaintiffs
had
twc
yearsto find a Californi-aattorney.
Defendants
suspectthatPlainti-ffsdidnot finda Californialicensed attorney,
because
the
case
is completely
f
rivol-ous. A
motj-on
to dismiss is
being
filed shortly.3.AttacksonDefendant'sattorney are simply
infl-ammatory,
defamatory and
without
any
basis brought toprejudicethe
court
againstthe
defendants.
4.
Berg
dedicates
a
whole
page
in his opposition to the issue
of
the
Defendants'
attorneysignature
and
claims that the fact that
Defendants'
attorney Taitzsigned/s/faitz
and
notwith
actual
signature, 1t
makes
hermotion invalid.It
shows
thatMr.
Berg
does not understand ECF system at all. ECF filingis
a
requirement
inthis court.
When
a 1ocal attorney appliesfor
ECF
filingprivileges,
such atLorney
passes
a
course and
obtai-ns
an
electronic stamp. Signing/s/Taitzin conjunctionwith
her
electronic
stamp
is sufficient, it represents
such
an attorney'ssiqnature. Apparently
Bergr
never
went
througrh
ECF
filing
course
and doesnot havea clue astohowitworks.Itis
d
curiosity, that Berg is trying to mimicTai-tzand submitshispleadingwith hisclients signing thepleading/s/LLsaLiberipro
se
and
/s
/
Li-sa
Ostell-a
prose,
which
is totally
improper
Motion
to
terminate
Philip
Berq
as
an
attorney
on
the
case-
3
Case 8:11-cv-00485-AG -AJW Document 175 Filed 04/18/11 Page 3 of 6 Page ID#:4059

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