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LIBERI v TAITZ (C.D. CA) - 177 - REPLY First MOTION to Disqualify Counsel Philip J. erg - Taitz Supplemental Reply 04.18.2011.177.0

LIBERI v TAITZ (C.D. CA) - 177 - REPLY First MOTION to Disqualify Counsel Philip J. erg - Taitz Supplemental Reply 04.18.2011.177.0

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Published by Jack Ryan
04/18/2011 177 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. (Taitz, Orly) (Entered: 04/18/2011)
04/18/2011 177 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. (Taitz, Orly) (Entered: 04/18/2011)

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Published by: Jack Ryan on Apr 18, 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 949-766-7603US DISTRICT COURTFOR THE CENTRAL DISTRICT OF CALIFORNIA LIBERI ET AL,PLAINTIFF, VS.TAITZ AT AL,DEFENDANT))))))))))CASE NO.: 11-CV-00485Supplemental brief toReply to opposition to MOTION-REQUEST TO TERMINATEPHILIP J. BERG AS AN ATTORNEY ON THE CASEHON. ANDREW GUILFORDPRESIDINGDATE 05.09.2011TIME 10:00COURTROOM 10 D
Defendantsare submitting this supplemental brief with two morepoints, which were inadvertently omitted in the Reply toopposition to motion to terminate (disqualify) attorney Berg, asan attorney for the Plaintiffs in this case.1. All of the cases broughtin citationsby the plaintiffs intheir opposition brief,are completely irrelevant to this motionand this case in general, as all of such cases relate tocriminal defendants exercising their 6th Amendment right tocounsel in criminal case.
United states v Gonzales-Lopez, United States v Lilie, United States v Garett, United States v Walters,United State v Panzareli-Alvarez
areall criminal cases. Thereis more leeway in granting pro hac vice to attorneys forcriminal defendants in accordance with their 6th amendmentrights. The case at hand is a civil case, Berg wants torepresent plaintiffs, notdefendants, and he did not provide anylaws, statutes or precedents, which will allow him to do sowithout a valid license or without a valid pro hac vice signed
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Motion to terminate Philip Berg as an attorney on the case-212345678910111213141516171819202122232425262728
by a local attorney and in the midst of Disciplinary Board trialagainst him in Pennsylvania.2. Just looking at the documents and pleadings in this verycase, it is clear, that Berg does not possess a good moralcharacter, that is needed for pro hac vice.Defendants are asking the court to simply read three documentsin this very file to ascertain, that Berg does not have a goodmoral character. Such documents are;a.complaint filed by Berg on behalfof the plaintiffs on May 4,2009.b. document 137, an emergency response by the Plaintiffs filedJuly 30,201oc. an order and memorandum by the prior judge, PA US Districtjudge Eduardo Robreno filed on December 23,2010.This complaint revolves around the fact that Taitz publishedcriminal record of Berg's legal assistant Lisa Liberiandadvised her supporters and donors, that her prior volunteer webmaster Lisa Ostela locked Taitz out of the her old web site andreplaced Taitz pay-pal with her own pay-paland any donationsgiven at the old web site will not go to either Taitz or herfoundation, "Defend Our freedoms Foundation"but rather toOstela.Berg, Liberi and Ostella filed thislegal actionfordefamation, assaultand libel. Berg gave his business address asLiberi's address and in their verified complaint, Plaintiffsattempted to create an illusion, thatLisa Liberi working forBerg is not aconvicted felon from CA but a different LisaLiberi, residing in PA.
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Motion to terminate Philip Berg as an attorney on the case-312345678910111213141516171819202122232425262728
After the last hearing in this case, which was held in PA inDecember 2010, when Taitz cross examined Liberi, Ostella andBerg, Judge Robreno stated in his 12.23.2010 order, thatPlaintiffs were evasive and not believable as witnesses and thatLiberi concededthat she was a convicted felon from Californiaand Ostela conceded that she indeed locked Taitz out of the website of her foundation and replaced Taitz Paypal with her own.This in itself shows the case to be frivolous andso far amotion to dismiss was
not
decided with prejudice, as the casewas transferred and the court of appeals decided that all themotions are to be decided by the transferee court. Proper motionto dismiss will be filed shortly with this court, as this courtis the transferee court,however just reading thecomplaint andthe transcript of 12.20.2010 motion hearing and the subsequent12.23.2010 order by judge Robreno, shows that attorney Bergfiled a totally frivolous legal action and he did it withmalice, which does not show good moral character.Even more malice and bad moral character can be seen by readingDocument 137 of this docket.In this document,filed by Berg, inresponse to Taitz request to unseal the transcript of the08.07.2009 hearing, at which Taitz was not present, Bergdemandedthe court to keep the transcript sealed, and without ashred of evidence he madeup a totally outrageous accusation,where he statedas fact, that attorney Taitz tried to hire a hitman to kill his legal assistant Lisa Liberi and for that reasonthe transcript needs to be kept sealed. Inthe recent 12.23.2010order Judge Robreno has stated, that Plaintiffs did not provideany evidence to substantiate such allegations. What is
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