Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
1Activity
0 of .
Results for:
No results containing your search query
P. 1
LIBERI v TAITZ (C.D. CA) - 186.4 - # 4[RECAP] Declaration of Philip J. Berg, Esquire - gov.uscourts.cacd.497989.186.4

LIBERI v TAITZ (C.D. CA) - 186.4 - # 4[RECAP] Declaration of Philip J. Berg, Esquire - gov.uscourts.cacd.497989.186.4

Ratings: (0)|Views: 16|Likes:
Published by Jack Ryan
# 4[RECAP] Declaration of Philip J. Berg, Esquire - 05/05/2011 186[RECAP] OPPOSITION to First MOTION to Dismiss Case under 425.16 AntiSLAPP 178[RECAP] Memorandum of Points and Authorities; Declaration of Lisa Liberi; Declaration of Philip J. Berg, Esquire; Certificate of Service and Proposed Order filed by Plaintiffs PHILIP J. BERG, GO EXCEL GLOBAL, Lisa Liberi, LISA M. OSTELLA, THE LAW OFFICES OF PHILIP J. BERG. (Attachments: # 1[RECAP] Table of Contents, # 2[RECAP] Memorandum, # 3[RECAP] Declaration of Lisa Liberi, # 4[RECAP] Declaration of Philip J. Berg, Esquire, # 5 Certificate of Service, # 6 Proposed Order)(Berg, Philip) (Entered: 05/05/2011)
# 4[RECAP] Declaration of Philip J. Berg, Esquire - 05/05/2011 186[RECAP] OPPOSITION to First MOTION to Dismiss Case under 425.16 AntiSLAPP 178[RECAP] Memorandum of Points and Authorities; Declaration of Lisa Liberi; Declaration of Philip J. Berg, Esquire; Certificate of Service and Proposed Order filed by Plaintiffs PHILIP J. BERG, GO EXCEL GLOBAL, Lisa Liberi, LISA M. OSTELLA, THE LAW OFFICES OF PHILIP J. BERG. (Attachments: # 1[RECAP] Table of Contents, # 2[RECAP] Memorandum, # 3[RECAP] Declaration of Lisa Liberi, # 4[RECAP] Declaration of Philip J. Berg, Esquire, # 5 Certificate of Service, # 6 Proposed Order)(Berg, Philip) (Entered: 05/05/2011)

More info:

Categories:Types, Research, Law
Published by: Jack Ryan on May 05, 2011
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

05/05/2011

pdf

text

original

 
Declaration of PhilipJ. Berg, Esquire
112345678910111213141516171819202122232425262728
Philip J. Berg, EsquirePennsylvania I.D. 9867LAW OFFICES OF PHILIP J. BERG555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531Telephone: (610) 825-3134E-mail: philjberg@gmail.com 
 Attorney for Plaintiffs
UNITED STATES DISTRICT COURTFOR THE CENTRAL DISTRICT OF CALIFORNIA,SOUTHERN DIVISION
LISA LIBERI, et al, Plaintiffs,vs.ORLY TAITZ, et al,Defendants.:::::::::::::::::CIVIL ACTION NUMBER:
8:11-cv-00485-AG (AJW)DECLARATION OF PHILIP J.BERG, ESQUIRE
Date of Hearing: June 13, 2011Time of Hearing: 10:00 a.m.Location: Courtroom 10D
Declaration of Philip J. Berg, Esquire
I, Philip J. Berg, Esquire,am over the age of eighteen [18]and ama party tothe within action. I have personal knowledge of the facts herein, and if called todo, I could and would competently testify. I am making this Declaration under the penalty of perjury of the Laws of the United States pursuant to 28 U.S.C. §1746.1.I am an Attorney in good standing, licensed to practice law in theCommonwealth of Pennsylvania. I am licensed to practice in the U.S.
 
Case 8:11-cv-00485-AG -AJW Document 186-4 Filed 05/05/11 Page 1 of 6 Page ID#:4365
 
Declaration of PhilipJ. Berg, Esquire
212345678910111213141516171819202122232425262728
District Courts, Middle and Eastern District of Pennsylvania; the ThirdCircuit Court of Appeals; the Pennsylvania Supreme Court; and the U.S.Supreme Court.2.Plaintiffs were forced to file suit against Defendants, including OrlyTaitz and Defend our Freedoms Foundations, Inc. for their illegal background checks, illegal access of Lisa Liberi and LisaOstella’s creditreports, and the publication of all their confidential primary identificationinformation. The publication of private data included but was
not
limited totheir full Social Security numbers; dates of birth; place of birth; mother’smaiden name; father’s name; credit details; and other private data.3.Plaintiffs did
not
 bring suit as a result of Taitz disclosure of a“supposed” criminal record of Liberi. However, in Plaintiffs Complaintthere is a cause of action for Slander, Defamation andLibel as a result of Defendants publication that Liberi had been convicted of crimes that she had
not
 been; Defendants false publication that Ostella had a criminal record;that Liberi has a criminal history going back to the 1990’s; that Liberi has a pending criminal case against her; that Liberi and Ostella stole monies fromTaitz and her Foundation; that Liberi and Ostella “hacked” Taitz PayPalaccount and website, and many other false accusations.
Case 8:11-cv-00485-AG -AJW Document 186-4 Filed 05/05/11 Page 2 of 6 Page ID#:4366
 
Declaration of PhilipJ. Berg, Esquire
312345678910111213141516171819202122232425262728
4.Taitz still to this date continues claiming Liberi is a“career forgerand been convicted of forgery of documents and forgery, which is
not
true.Liberi has never been convicted of forging documents or forgery of anydocuments.5.Plaintiffs have filed a Motion Seeking Leave to Amend their Complaint. However, Plaintiffs are also Seeking to Amend their Complaintin their Response in Opposition to Defendants Taitz and Defend our Freedoms Anti-SLAPP Motion and Motion to Dismiss pursuant to Fed. R.Civ. P. 12(b)(1) and 12(b)(6).6.Further, Taitz has claimed she neverfiled a previous Anti-SLAPPMotion and Plaintiffs have committed Fraud upon the Court by claiming shehad. The truth of the matter, as demonstrated by the Docket, Taitz filed anAnti-SLAPP Motion almost identical to the one filed April 25, 2011, onJune 16, 2009, which appears as Docket Entry No. 61.7.Further, Taitz claims that this Court lacks subject-matter jurisdictionin that Liberi has
not
 proven to her or provided her with her (Liberi’s)Driver’s License. Liberi is
not
a citizen of the State of California and Taitzhas failed to address why she feels diversity is lacking. Diversity is proven by the fact that none of the Plaintiffs reside in the same state as any of theDefendants. None of the Plaintiffs reside in the State of California. It is
not
Case 8:11-cv-00485-AG -AJW Document 186-4 Filed 05/05/11 Page 3 of 6 Page ID#:4367

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->