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LIBERI v TAITZ (C.D. CA) - 224.3 - 3[RECAP] Exhibit declaration by Lisa Liberi for disciplinary board - gov.uscourts.cacd.497989.224.3

LIBERI v TAITZ (C.D. CA) - 224.3 - 3[RECAP] Exhibit declaration by Lisa Liberi for disciplinary board - gov.uscourts.cacd.497989.224.3

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Published by Jack Ryan
06/10/2011 224[RECAP] opposition to pro hac vice opposition to pro hac vice of Philip Berg re: APPLICATION for attorney Philip J. Berg to Appear Pro Hac Vice. (PHV FEE PAID.) 223 , APPLICATION for attorney Philip J. Berg to Appear Pro Hac Vice (PHV FEE NOT PAID.) APPLICATION for attorney Philip J. Berg to Appear Pro Hac Vice (PHV FEE NOT PAID.) 220 filed by Defendant DEFEND OUR FREEDOMS FOUNDATIONS, INC.. (Attachments: # 1[RECAP] Exhibit record of disciplinary trial of attorney Philip berg, # 2[RECAP] Exhibit petition for discipline against attorney Berg, # 3[RECAP] Exhibit declaration by Lisa Liberi for disciplinary board, # 4[RECAP] Exhibit mug shot and criminal record of Lisa Liberi, # 5[RECAP] Exhibit memorandum by judge Robreno, # 6[RECAP] Exhibit signature sample of Taitz, # 7[RECAP] Exhibit forgery of signature of Taitz, # 8[RECAP] Exhibit affidavit by former associate of Berg, Linda Belcher, # 9[RECAP] Exhibit letter from Geoff Staples, former web master for attorney Berg)(Taitz, Orly) (Entered: 06/10/2011)
06/10/2011 224[RECAP] opposition to pro hac vice opposition to pro hac vice of Philip Berg re: APPLICATION for attorney Philip J. Berg to Appear Pro Hac Vice. (PHV FEE PAID.) 223 , APPLICATION for attorney Philip J. Berg to Appear Pro Hac Vice (PHV FEE NOT PAID.) APPLICATION for attorney Philip J. Berg to Appear Pro Hac Vice (PHV FEE NOT PAID.) 220 filed by Defendant DEFEND OUR FREEDOMS FOUNDATIONS, INC.. (Attachments: # 1[RECAP] Exhibit record of disciplinary trial of attorney Philip berg, # 2[RECAP] Exhibit petition for discipline against attorney Berg, # 3[RECAP] Exhibit declaration by Lisa Liberi for disciplinary board, # 4[RECAP] Exhibit mug shot and criminal record of Lisa Liberi, # 5[RECAP] Exhibit memorandum by judge Robreno, # 6[RECAP] Exhibit signature sample of Taitz, # 7[RECAP] Exhibit forgery of signature of Taitz, # 8[RECAP] Exhibit affidavit by former associate of Berg, Linda Belcher, # 9[RECAP] Exhibit letter from Geoff Staples, former web master for attorney Berg)(Taitz, Orly) (Entered: 06/10/2011)

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Categories:Types, Research, Law
Published by: Jack Ryan on Jun 10, 2011
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06/11/2011

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Law
Officesof:
PHILIP
J.
BERG,
ESQTIIRE
555
Andorra
Glen
Cour{
Suite
12
Lafayette
Hill, PA
19444 2531
Identification
No.
09867
(610)
82s-3134
Respondent
in
Pro
Se
BEFORE
TIM
DISCIPLNIARY
BOARD
OF
THE
SUPREME
COTIRT OF
PEI{NSYLVANIA
OFFICE
OF
DISCPLINARY
COTINSEL,Petitioner,
vs.
PHILIP
J.
BERG"
Respondent.
NO.
208
DB
2010
Attorney
Regishation
No.
9867
(Montgomery
County,)
VERIFICATION
OF
LISA
LIBERI
I,
LISA LIBERI,
tm
overthe
age
of
eighteen
(18)
and am
not
a
partyto
the
within
action.
I
verify
that
the
statements
made
in
the
foregoing are
tnre
and correct
to
the
best
of
my
knowledgg
information
aud
belief.The
undersigned
understands
that
the
statements
therein
me
made
subject
to
the
penalties
of
18Pa-
C.S. Section
49M
and
the
laws
of
the United
States
relatingto
rmsworri
falsificationto
authorities.
I
have
personalknowledge
of
the
factsherein
and
if
called
to
do
so,
I
could
and
would
competently
testify
under
oath.
I
declare
as
follows:
l.
I
am
Mr.
Berg's
Assistant
in
the
Ianrr
Offrces
ofPhilip
J. Berg
and
am
familiar
with
the
events
surrounding
McCracken
v.
LancasterCitv Bureau of Police. et
al-
Case
No. 06-cv4958-LS.
Case 8:10-cv-01573-AG -PLA Document 59-3 Filed 02/28/11 Page 1 of 9 Page ID#:1499
Case 8:11-cv-00485-AG -AJW Document 224-3 Filed 06/10/11 Page 1 of 9 Page ID#:6324
 
-
.
Mr.
Berg
filed suit
for
Ms.
McCracken
on
November
8,
2A06,
based
on
infonnationtold
to
him
by
Ms.
McCracken.
Maria
DiDonato,
Mr.
Berg's Paralegal
at
the
time,
left
several
messages
for
Ms.
McCrackenon
Decemb
er
14,
2006; Decembsr
22,
2A06;and
January
13, 2007
regarding
g[g
dssrrmsnts
Ms.
McCracken
had
promised
to
fumish.
The
documents
included
thenames
of
her
Medical
Providers;
MedicallPsychological
Reports;
Medications;Medical
Bills
and
Prescription
costs.
Ms.DiDonato
never
received
a
return
call
back.
On
January
16,2007,
DefenseCounsel
filed
a
Joint
Motion
to
Dismiss Ms.
McCracken's
lawsuit.
In additioaMr.
Berg had discovered new evidence regardingMs.McCracken,
which Ms.
McCracken
had
failed
to inform
and/or
share
with Mr. Berg. Mr.
Berg
leamed that
Mr.
McCrackenhad been
arrested
for
stabbing another
individual
and
plead
guilty
to
two
(2)felonies
and
five
(5)
misdemeanors.
In
addition,
Mr.
McCracken
had been
previously
convicted
of
adangerous
crime,
Murder. Mr.
Berg
also
leanred that
Ms.
MoCrackenletthe
law
enforcementofficers
into
her
premises,
which
was
contary
to
whatMs. McCracken
had stated
to
lv{r.
Berg.
On
January
17,2007,I
sent
aletter
to
Ms.
McCracken,
attached as
EXHIBIT
rt3rt
to
Mr.
Berg's
Response,
inforrring
her that
Ms.
DiDanato
had
been
trying to
reach
her.
I
stated
to
Ms.
McCracken
that we
were
in
need
ofher
medicalprovideds
namesand
addresses,
medical
bills,
and
medical reports
to
substantiate
her
claims
regardingdamages.
I
also
informed
Ms.
McCrackenthat
the Defendants had
filed
a
Joint
Motion
toDismiss, and
she
needed
to
make animmediate
appoinhent with
Mr.
Berg
regarding
someissues,
which
had come
up.
I
stated
to Ms.
McCracken
if
she
did not furnish
therequired documents
and
didnot
meet
with
Mr.
Berg
then
Mr.
Berg
could
not
and
would
4.
5.
Case 8:10-cv-01573-AG -PLA Document 59-3 Filed 02/28/11 Page 2 of 9 Page ID#:1500
Case 8:11-cv-00485-AG -AJW Document 224-3 Filed 06/10/11 Page 2 of 9 Page ID#:6325
 
6.7.
nct
be able
to
respond
to
theDefendants
Joint
Motion
to
Dismiss.
I
also
explainedto
Ms.
McCrackenthat
if
we do not respcnd to
the
Defendants Joint
Motion
to
Dismiss, then
the
Court
will
grant
the
Defendants
Motion
as
unopposed-
Ms.
McCracken
never
rnade an
appoinfuent
and
ourOffice
neverreceivedthe
requested
documents.
Thus,
Mr.
Berg
was unable
to
respond
to
the
DefendantsJoint
Motion
to Disuriss.On February L6,2A07, theCourt dismissed
Ms.
McCracken's
Case.
OnFebruary
20,2007,I
sent
Ms.
McCracken
a
letter
with
a
copy
of
theOrderattached
see
Mr.
Berg's
D(HIBIT
'r5rrto his
response.
In
mid
June2008,
Mr.
Berg
received
an
email
from
Ms.
McCracken regarding
a
tree
incident.
Mr.
Berg
called
Ms.
McCrackenon
or
about
June
23,2008.
I
asked
Mr.
Berg
if
Ms. McCracken
ever
confinned receipt
of
the
Order
of
Dismissal,
and
Mr.
Berg
statedyes,
she
conceded
that
shereceived
theOrderduring
their
Jrme
23,2A08 telephonecall.
OnFebruary L9,2009,
Mr.
Berg was
out
of
the
office
so
I
checked
his email
foranythingurgent.
I
found
an
email
from
Ms.
McCracken
threatening
to
report
Mr.
Berg
to
the
Pennsylvania
Disciplinary
Board-
I
immediately
responded
to
Ms.McCracken
and
told
her,
if
memory
served
me
correctly,
I
had
sent
her
a
letterregarding
the
Defendants
Joint
Motion to
Dismiss
and another
letter
with
theOrder
of
Dismissal,
see
E)ffIIBIT
rr6tr
toMr.
Berg's
Response.
I
received
an
email
back
from
Ms.McCracken
this
sarnedate,
and
Ms.
McCracken
stated
that
she
had
not
received
any
communication from
Mr.
Berg's
Offrce
since
she
receivedthe
cornplain!
see
E)CIIBIT
rr7rr
to
Mr.
Berg's
Response.
8.
Case 8:10-cv-01573-AG -PLA Document 59-3 Filed 02/28/11 Page 3 of 9 Page ID#:1501
Case 8:11-cv-00485-AG -AJW Document 224-3 Filed 06/10/11 Page 3 of 9 Page ID#:6326

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