Liberi, et al Mem of Pts & Auth in Support of their Opp to YosefTaitzMTD 08.04.2011
“interface applications” or “remote application execution”, “cross site scripting”, “remoteinterface” and “injection attacks”?[“Taitz MTD, pgs. 1-2, Para“B1 through B3”]. Mr.Taitz counsel must
have conferred with their client, Mr. Taitz, and/or does
understand the workings of databases and/or the Internet. These statements, phrasesandlanguagewere taken directly from Mr. Taitz’s Manuals he prepared for DefendantDaylight’s products,located on his website at daylight.com.
also Exhibits “141”through “144”, Mr. Taitz’s Manuals for Daylight filed with this Court on May 20, 2011and appearing in this Court’s Docket as Docket Entry No.’s [“Dktno.”] 190, 190-26 and190-27.7.Mr. Taitzthen attempts to confuse this Court with twisting what thePlaintiffs have outlined in their Complaint. Mr. Taitzstates
“… he through Daylight CIS has designed computer systems which other Defendants …have allegedly used to violate plaintiffs’ privacyrights…Plaintiffs do not allege that Moving defendant personally, hasdone anything violating their privacy rights but instead that his corporation, Daylight CIS” has designed and provided computer systems which others then allegedly used toinvade Plaintiffs privacy…
” [Taitz MTD Para. I-B, sub paragraph 4, on pg. 3] Thisis
what Plaintiffs stated at all.8.Plaintiffs stated on pages75-76 of their FAC at paragraph179,“The use of DayCart with the Oracle server, unlocks the access of existing Oracle applications andtools (such as dual program interface plug in applications)”, which is Mr. Taitz’s ownwording in his Press Releasepertaining to Daylight and Oracle, of July 13, 2000.
Declaration of Philip J. Berg.
Case 8:11-cv-00485-AG -AJW Document 333-2 Filed 08/04/11 Page 3 of 25 Page ID#:7955