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LAW OFFICES OF

PHILIP J. BERG
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
PHILIP J. BERG
CATHERINE R. BARONE
BARBARA MAY
(610) 825-3134

FAX (610) 834-7659

NORMAN B. BERG, Paralegal [Deceased] E-Mail: philjberg@gmail.com

July 30, 2009

Honorable Eduardo C. Robreno
United States District Court
for the Eastern District of Pennsylvania
11614 U.S. Courthouse
601 Market Street
Philadelphia, PA 19106-1797

Sent via Fax to (267) 299-7428...................................................................................................18 Pages

Re: Liberi, et al. v. Orly Taitz, et al, Case No. 09-cv-01898 ECR
Plaintiffs Opposition to Defendants’ Request for a Thirty [30] day Extension of Time

Dear Judge Robreno:

I am in receipt of Mr. Hoppe’s letter dated July 28, 2009. There are several problems with
Mr. Hoppe’s request for an Extension of Time as well as statements pertaining to Mr. Hale and Linda
Belcher. Unless this Court issues Plaintiffs’ request for an Emergency Injunction or Restraining Order
pending any Hearings, Plaintiffs are OPPOSED to any continuance of the Hearing pertaining to the
Plaintiffs’ Motion for an Emergency Injunction or Restraining Order as outlined herein.

Mr. Hoppe’s Continuance Request:

Mr. Hoppe was served with the letter that I sent on July 16, 2009 with Plaintiffs’ attached
motion and letters provided from two [2] witnesses who are not a party to this litigation. In my July
16, 2009 letter to Your Honor was also information regarding the actions of Defendant, Orly Taitz.
Mr. Hoppe was also served with my letter that I sent to Your Honor with further actions of Ms. Taitz
pertaining to Plaintiff Lisa Liberi’s Social Security number and other confidential information. Mr.
Hoppe was again served with my July 22, 2009 letter which was sent to Your Honor wherein I again
was requesting Leave to file the Plaintiffs’ Motion for an Emergency Injunction or Restraining Order;
and finally on July 24, 2009, a letter I sent to Your Honor with two [2] emails received from two [2]
additional witnesses who are not parties to this litigation, other than being witnesses for the Plaintiffs’.

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Yesterday, July 29, 2009 is the first response we have received from Mr. Hoppe regarding
this matter. Furthermore, Plaintiffs’ request for the thirty [30] day extension of time was to allow this
Court to take appropriate action to protect the Plaintiffs’ and their witnesses so we could properly
respond to Your Honor’s Rules to Show Cause, wherein Your Honor specifically asked for Affidavits.
Plaintiffs’ Response and Affidavits in support thereto are now due on August 26, 2009.

If this Court allows this continuance, which Plaintiffs’ completely oppose, then Plaintiffs’ are
again placed at a disadvantage and deprived of their Constitutionally protected rights to “due process”;
“equal protection of the laws”; their right to “bear and present witnesses”; their rights “for redress”,
etc., as they will be in the same position as their witnesses are, that being afraid to furnish Affidavits,
until this Court takes appropriate action to protect the parties, as a result of Defendant’s Belcher and
Hale’s threats

Mr. Hoppe has been aware of Plaintiffs’ request since July 16, 2009 and failed to assert
anything until now. In fact, he sent Mr. Hale a copy of my letter dated July 16, 2009, which Mr. Hale
immediately posted parts of on his internet site. This is exactly what the Plaintiffs’ witnesses fear, that
Mr. Hale and Ms. Belcher will purposely put their confidential information out on the internet and
incite their people to go after the witnesses to follow through with their threats towards the Plaintiffs
witnesses. Again, Ms. Belcher and Mr. Hale made it known to all witnesses of the Plaintiffs that they
(Ms. Belcher and Mr. Hale) will know who they are; where they reside; where they are located and
stated, “and we will go after them with a vengeance”. If Mr. Hoppe’s request for an extension of time
is granted, Plaintiffs’ will be unable to meet this Court’s Orders to reply to this Honor’s Rules to Show
Cause and support their responses with Affidavits. Mr. Hoppe is well aware of this and this simply is a
tactic to further ensure Plaintiffs’ will be deprived of their right to properly respond.

If true what Mr. Hoppe states, that Defendants Belcher and Sankey (no mention of Sankey
Investigations, Inc. or The Sankey Firm, Inc. a/k/a the Sankey Firm) are hiring a Texas Attorney to
litigate in Pennsylvania, they could have waited to do this until after Friday, August 7, 2009.

Mr. Hale interrupted Ken Dunbar’s radio show on Plains Radio to make a quick
announcement. Mr. Hale stated that one of Mr. Berg’s big supporters paid David Carlton Hughes, the
attorney all the Defendants’ wanted, twenty-five [$25,000.00] dollars to represent the Defendants’. Mr.
Hale also stated Mr. Hoppe sent an attorney to see the Judge to ask for a continuance, if the Judge
denied the continuance then Caren, Linda and he would be at Court on Friday, August 7, 2009. Mr.
Hale also stated he was having ten [10] CD’s transcribed which will be sent out federal express on
Friday so his Honor will have them by the deadline on Monday. See EXHIBIT “1”. Based on Mr.
Hale’s statements, there is no need for the continuance.

Mr. Hoppe’s Statements Regarding Jurisdiction:

This Court has personal jurisdiction over the Defendants’ as will be addressed in more detail
in Plaintiffs’ Responses to this Court’s Rules to Show Cause. However, since this Court Ordered
Plaintiffs’ to respond to this Court’s Rules to Show Cause regarding the Jurisdictional issues and back
up their responses with Affidavits; and the fact Defendant’s Belcher and Hale have now threatened any
witness who provides an Affidavit for the Plaintiffs’, this Court clearly has jurisdiction as the
Defendants’ have targeted the Plaintiffs’ in Pennsylvania; any witnesses planning to supply an
Affidavit or testify on behalf of Plaintiffs’ in Pennsylvania; and this case is currently in Pennsylvania;

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in attempts to ensure Plaintiffs’ are unable to comply with this Court’s Order that Plaintiffs’ are to
respond to this Court’s Rules to Show Cause due August 26, 2009.

Federal Courts may exercise personal jurisdiction over a non-resident of the forum "to the
extent permissible under the law of the state where the district court sits." Pennzoil Prods. Co. v.
Colelli & Assocs., 149 F.3d 197, 200 (3d Cir. 1998) (citation omitted.) In turn, Pennsylvania's long-
arm statute authorizes the exercise of jurisdiction over a non-resident "to the fullest extent allowed
under the Constitution of the United States." 42 Pa. Cons. Stat. Ann. § 5322 (b); see also O'Connor v.
Sandy Lane Hotel, 496 F.3d 312, 316 (3d Cir. 2007), noting that Pennsylvania's long-arm statute
"provides for jurisdiction based on the most minimum contact with the Commonwealth allowed under
the Constitution of the United States" (internal citations omitted.) That is, as long as the requirements
of the Due Process Clause of the Fourteenth Amendment to the United States Constitution have been
satisfied, jurisdiction will lie over non-resident Defendants in Pennsylvania. Pennzoil Prods., id.

All the Defendants’ meet the minimum contact standards, which gives this Court jurisdiction
and venue over them; their illegal, unethical and injurious behaviors and actions, which were activities
purposefully directed towards residents of this state. In so doing, Defendants’ were provided "fair
warning" that they may be subject to suit in this forum. Burger King Corp, v. Rudzewicz, 471 U.S. 462
at 472. Again, Taitz is a licensed Attorney and is aware of the laws of our land. Moreover, Taitz
through DOFF have several military clients; has formed a group of Pennsylvania residents to work
with her in having Arlen Spector, U.S. Senator Pennsylvania recalled.

It is more than obvious; Belcher and Hale directed their threats towards the Plaintiffs’ witnesses
who would be supplying Affidavits and appearing in this Court in Pennsylvania. Ms. Taitz clearly
continued her illegal behaviors of publishing Plaintiff Liberi’s Social Security number and other
personal identifying information despite this Court’s warnings. On June 25, 2009, this Court plainly
stated that the continued behaviors would weight in favor of the Plaintiffs’.

As stated in JNA-1 Corp. v. Uni-Marts, LLC (In re Uni-Marts, LLC), 404 B.R. 767 (Bankr. D.
Del. 2009 @ *9:

“Where a non-resident defendant "purposefully directed his activities at residents of the
forum," his contacts with the forum are sufficient to support personal jurisdiction in any
"litigation [that] results from alleged injuries that arise out of or relate to those activities."
Burger King Corp. v. Rudzewicz, 471 U.S. 462, 472, 105 S. Ct. 2174, 85 L. Ed. 2d 528
(1985) (quotations omitted). A single transaction with the forum by the plaintiff will
suffice. See McGee v. Int'l Life Ins. Co., 355 U.S. 220, 223, 78 S. Ct. 199, 2 L. Ed. 2d 223
(1957). The defendant's activity need not take place within the forum so long as it is
"intentional conduct . . . calculated to cause injury" to the plaintiff within the forum.
Calder v. Jones, 465 U.S. 783, 791, 104 S. Ct. 1482, 79 L. Ed. 2d 804 (1984). See also
Burger King, 471 U.S. at 476 ("[W]e have consistently rejected the notion that an absence
of physical contacts can defeat personal jurisdiction . . . .")”

Mr. Hoppe is now claiming for the first time that the Defendants’ coming to Pennsylvania is a
hardship because they are located in California and Texas. This was never raised in the Defendants’
Motions to Dismiss, filed with this Court on May 26, 2009, which was denied, or in the alternative
transferred. The California Defendants’ are willing to travel to Texas, but now they are unwilling to
travel to Pennsylvania because it is a hardship? If true, then why would these Defendant’s be hiring an

Z:\Liberi Ltr to Judge Robreno July 30, 2009 3
out of state Attorney, who is not licensed in Pennsylvania, to travel to Pennsylvania, which would
severely increase the cost of litigation? As stated above in the transcription of Mr. Hale on his radio
show July 29, 2009, the Hale Defendant’s; the Sankey Defendants and Linda Sue Belcher, et al were
given the money by one of my supporters to hire their attorney and pay for their travel expenses. Thus,
there is absolutely no hardship.

Moreover and most importantly, if the Defendants’ did not want to travel to Pennsylvania, then
the Defendants’ should not have gone out of their way after the June 25, 2009 Hearing with Your
Honor and continue their illegal behaviors, which has severely hampered Plaintiffs’ ability to comply
with this Court’s Orders. Threatening witnesses is illegal as pointed out in Plaintiffs’ Motion and
letters to Your Honor. Defendant’s Belcher and the Hales through Defendant Plains Radio
intentionally set out, just hours after the June 25, 2009 hearing, to make extremely difficult if not
impossible for the Plaintiffs’ to respond to Your Honor’s Rules to Show Cause and support their
Responses with Affidavits.

Mr. Hoppe’s Inaccurate Explanation of Defendant’s Belcher and Hale’s Threats and Plaintiffs’
Witnesses concerns:

Mr. Hoppe claims Mr. Berg did not put out the full statement by his clients. Mr. Hoppe states,
“…is a blatant misrepresentation of what was said. Mr. Berg intentionally left out part of the
statement in an effort to justify his request.” This is completely absurd. The concerning threat, which
was outlined by six [6] parties who heard the actual radio show, four [4] of which are witnesses for the
Plaintiffs.’ As clearly pointed out in the witnesses letters provided to the Court in Plaintiffs’ Motion
on July 16, 2009: K. Strebel’s Affidavit; Lisa Liberi’s Verification; and two [2] emails provided to this
Court on July 24, 2009 where the witnesses stated their concerns and fears and included “[excerpt]
June 25th show Ed Hale to Linda (Belcher) Starr: "Let me tell you something, when these affidavits
come in that they claim they have, these people's names are gonna be known, their addresses are
gonna be known, and you know something? We're gonna know who they are, and you know what?
We will go after them with a vengeance..." Mr. Hoppe appears to have only read what Edgar Hale
sent him, as Mr. Hale is notorious for spelling the word “liars” as “lairs.” Mr. Hoppe states, “and
prove that they are lairs” [sic] is not accurate. First off, “go after them with a vengeance” “and prove
them a liar also” are clearly two different events. Plaintiffs’ were not concerned with Ms. Belcher and
Mr. Hale’s statements of their attempts to try and prove their witnesses as liars as Plaintiffs’ witnesses
are not lying. Plaintiffs’ and their witnesses are concerned with the statements the Defendants’ made
known that, “These peoples names are gonna be known”; “Their addresses are gonna be known”;
“And you know something, we are gonna know who they are…we will go after them with a
vengeance.” Mr. Hoppe may wish to listen to the actual radio show recording, not the altered version
he received from his clients.

What was said in totality regarding the threats was:

Linda Starr: “Well I feel like the Judge threw Berg a bone today. Because he said, ok,
you made all of these allegations and I'm gonna wait and give you a chance to support
the allegations you made with proof and evidence. And sworn affidavits with real
identities. Not fake IDs. They are gonna have to put their real identities out there.”
[emphasis added]

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Ed Hale: “Yeah and I'm gonna tell you something. When these affidavits come in that
they claim that they have. These people's names are gonna be known. Their addresses
are gonna be known. And you know something, we are gonna know who they are. And
you know what, we will go after them with a vengeance. And prove that they are liars
also.” [emphasis added]

Caryn: “Who are you talking about?”

Ed Hale: “All of these affidavits that Berg claims he has. We are talking about...”

Caryn: “From just?...”

Linda Starr: “Caryn here is the deal. They are not going to be allowed to use
usernames. In order to produce sworn affidavits in court they are gonna be notarized
they are gonna have to use their real names.”

Caryn: “Ok.”

Ed Hale: “Yeah, there is no more hiding.”

Linda Starr: “Then we can identify them.”

Caryn: “And these are people that are using their user names that are making all of
these statements.”

Ed Hale: “That's correct.”

Linda Starr: “That's right”.

Caryn: “Ok.”

Ed Hale: “But now they have to come out from behind the anonymity of the internet.
And they have to come out and face us. And you know something...?”

Caryn: “And they will probably refuse to do it for Berg, huh?”

Ed Hale: “Let me tell you something. It’s easy as hell...”

Linda Starr: “Ron Polarik's ID is gonna be exposed.”

Ed Hale: “Let me tell you something...”

Linda Starr: “All these people that want to know who he is, it's gonna come out who
he is.”

Ed Hale: “Let me tell you something and listen to this.”

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Caryn: “We're listen...”

Ed Hale: “This is what is hilarious in a way. The people that have told Berg, on the
Internet, oh let's just use Chilieman for an example. That Ed Hale wanted him to give
him money so he can give it to Berg. Well let me tell you something. Chilieman, you
can't hide no more. You're gonna have to come out and say who you are and
where you are.” [emphasis added]

Linda Starr: “Oh we know who he is. We know...” [emphasis added]

Linda Belcher a/k/a Linda Starr, as this Court can see, stated “Ron Polarik’s ID is gonna be
exposed…All these people that want to know who he is, it's gonna come out who he is.” Ron Polarik
is a witness for me in another case and has provided forensic analysis. Mr. Polarik has maintained
confidentiality of his legal name to protect him and his family from people like the Defendants’ herein.
It is apparent Ms. Belcher and Mr. Hale believed Mr. Polarik was going to supply an affidavit in favor
of the Plaintiffs’. As of yesterday, July 29, 2009, Ms. Belcher has carried out her threat towards Mr.
Polarik. A post was placed on Edgar and Caren Hale’s website located at www.plainsradio.com at
9:00 a.m. which states Ron Polarik, Mr. Berg’s forensic document expert’s, legal name is Ronald Jay
Polland and he resides in Florida. See EXHIBIT “2”.

To further carry out their threats, Linda Belcher a/k/a Linda Starr also had Mr. Polarik’s
information posted on her website at http://obamacitizenshipdebate.org/2009/07/meet-ronald-jay-
polland.html which states:

Meet Ronald Jay Polland
By CaptainAstro on July 29, 2009 6:38 PM | No Comments | No TrackBacks
This is Dr. Ronald Jay Polland. He received a BA in Psychology from Florida State
University in 1970, a Masters in Educational Research from FSU in 1972, and a
Doctorate in Instructional Systems from FSU in 1978. His curriculum vitae lists the
other accomplishments he finds noteworthy. He holds himself out as an expert on
surveys and market research.

Ron Polland is Ron Polarik.

http://barackryphal.blogspot.com/2009/07/meet-ronald-jay-polland.html

Again, Mr. Hale and Ms. Belcher are carrying out their threats made against Plaintiffs’ and
their witnesses. With Mr. Hale and Ms. Belcher putting out my expert witnesses name, I may have lost
my expert which could cause my case to be dismissed. As stated herein, Defendants’ threats have
become a reality in regards to Mr. Polarik; Orly Taitz threats to bring me down, destroy my paralegal
and anyone associated with us and to destroy my active cases. Since the threat against Polarik has
been a reality, it went from a threat to it happening, the fear is if your Honor does not stop the
Defendants, then it will also become a reality regarding the threats made against the Plaintiffs’ and
their witnesses.

Defendant’s Belcher and Hale are carrying out there threats made on June 25, 2009 and
carrying out the threats made by Defendant Orly Taitz to bring me down and to do so destroy my
paralegal, Lisa Liberi and get rid of her. All the Defendants’ joined forces early on to carry out

Z:\Liberi Ltr to Judge Robreno July 30, 2009 6
Defendant Taitz’s threats towards me, my paralegal and anyone associated with us. The intentions of
the Defendants’ speak for themselves.

This is further proof to this Court as to why Plaintiffs’ Motion for an Emergency Injunction or
Restraining Order must be immediately issued. It should be noted, not only was this post located by
Plaintiff Lisa Liberi, I also received the posts located on the Hale’s website from two [2] of the
Plaintiffs’ witnesses who will not supply an affidavit or testify until this Court takes protective
measures. Plaintiffs’ again request this Court to forward this information to the State’s Attorney
General pertaining to the threats made by the Defendant’s to all of Plaintiffs’ witnesses, for immediate
investigation and prosecution.

Mr. Hoppe further claims in his letter, “Mr. Berg has not produced any evidence that anyone
has in fact been so intimidated that they have refused to provide affidavits.” This is completely false.
In my letter to Your Honor on July 16, 2009, I reference two [2] of our witnesses who are very
important. In fact, in my letter I state, “Our witnesses were further instructed by the attorney’s in their
local area that until this Court acts, they were not to file any “Affidavits” or testify in this action for
their own protection.” [My letter of July 16, 2009, p. 2, ¶3]. Attached to my July 16, 2009 letter was
Plaintiffs’ Motion for the Emergency Injunction or Restraining Order, attached to the Motion as
EXHIBIT “D” is a letter dated June 29, 2009 from these two [2] particular witnesses outlining the
threats by Defendant’s Linda S. Belcher and Edgar Hale, which they heard and recorded from
Defendant Hale’s radio program. Attached as EXHIBIT “E” to Plaintiffs’ Motion is an Affidavit of
K. Strebel who was afraid to place his full name and address as a result of the threats made by
Defendant’s Linda S. Belcher and Edgar Hale and who also heard the threats by Belcher and Hale; and
attached as EXHIBIT “F” is another letter from the two [2] witnesses of ours who state they were
advised by their attorney’s until this Court takes protective action, they are not to provide affidavits
and EXHIBIT “G” the verification of Lisa Liberi who also listened to Mr. Hale and Linda Belcher’s
radio show of June 25, 2009, just hours after our Court hearing where this very Court had discussions
regarding the behaviors of the Defendants and issued an Order with a footnote stating, “Defendants’
are to conduct themselves as discussed in Court.” See EXHIBIT “3”. A couple of hours later is when
Mr. Hale and Ms. Belcher did the above radio show. In addition, attached to my letter to Your Honor
of July 24, 2009, which Mr. Hoppe was served with, were two emails from two [2] additional
witnesses of the Plaintiffs’ who heard the threats made by Mr. Hale and Ms Belcher and are concerned
for their safety and well being as a result of the threats made by Ms. Belcher and Mr. Hale. Contrary
to Mr. Hoppe’s statements, Ms. Belcher and Mr. Hale have undoubtedly made known what their
intentions are towards any witness who submit an affidavit for the Plaintiffs’, see above. As this
Court can see, I have supplied documentation received from witnesses for the Plaintiffs’.

It appears Mr. Hale forgot to mention to Mr. Hoppe, that when he received Your Honor’s
Order and copies of the Plaintiffs’ Motion for the Emergency Injunction or Restraining Order on July
27, 2009, Mr. Hale immediately posted it on his website and encouraged his supporters and followers
to review it. As this Court is aware, K. Strebel’s Affidavit was attached as well as the letters provided
by two [2] of Plaintiffs’ witnesses and this is exactly why addresses were omitted and I “blacked-out”
the other two [2] witnesses names and addresses.

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For the above aforementioned reasons, unless this Court issues Plaintiffs’ Emergency
Injunction or Restraining Order pending the Hearing on Plaintiffs’ Request, the Plaintiffs’ and I hereby
oppose Mr. Hoppe’s request for a thirty [30] day extension of time and respectfully request this Court
to deny Mr. Hoppe’s request for the continuance.

Thank you.

Respectfully,

Philip J. Berg

PJB:jb

Enclosures

cc: Orly Taitz, et al and
Defend our Freedoms Foundation, Inc.
26302 La Paz Ste 211
Mission Viejo, CA 92691
Ph: (949) 683-5411
Fax: (949) 586-2082
By Email: dr_taitz@yahoo.com
Counsel in pro se
Defend our Freedoms Foundations, Inc. is unrepresented

Mr. Ted Hoppe, Esquire
Hoppe & Martin
423 McFarlan Road, Suite 100
Kennett Square, PA 19348
Phone: (610) 444-2001
Fax: (610) 444-5819
By e-mail: thoppe@hoppemartin.com

Neil Sankey
The Sankey Firm, Inc. a/k/a The Sankey Firm
Sankey Investigations, Inc.
2470 Stearns Street #162
Simi Valley, CA 93063
Phone: (805) 520-3151and (818) 366-0919
Cell Phone: (818) 212-7615
FAX: (805) 520-5804 and (818) 366-1491
Email: nsankey@thesankeyfirm.com

Z:\Liberi Ltr to Judge Robreno July 30, 2009 8
Linda Sue Belcher
201 Paris
Castroville, Texas 78009
Home Phone: (830) 538-6395
Cell Phone: (830) 931-1781
Email: Newwomensparty@aol.com and
Email: starrbuzz@sbcglobal.net

Ed Hale
Caren Hale
Plains Radio
KPRN
Bar H Farms
1401 Bowie Street
Wellington, Texas 79095
Phone: (806) 447-0010 and (806) 447-0270
Email: plains.radio@yahoo.com and
Email: barhfarms@gmail.com and ed@barhfarms.net

Z:\Liberi Ltr to Judge Robreno July 30, 2009 9
EXHIBIT “1”

Z:\Liberi Ltr to Judge Robreno July 30, 2009 10
Plains Radio Network, Host: Ken Dunbar, July 29, 2009 at 6:00 – 8:00 p.m. CST
at 126:20 through 131.57 into the show, Ed Hale comes on
126:20

Ed Hale: “There is a letter that was written by Ted Hoppe, who was our attorney that he sent to the
Judge and it’s on our website and go to www.plainsradio.com/linda.html and you can see that letter in
PDF file. Also I want to announce, thanks to Linda Starr we have a benefactor, who has paid David
Carlton Hughes, the Attorney in Dallas that we originally wanted the twenty five thousand dollars to
defend us. I want to personally thank Linda for all her hard work she has done to help us out on this
matter. Now, Plains Radio is going to stay on the air. Now all the money you guys donated to us were
going to use that for plane tickets for me, Caren and Linda so when our Attorney appears in that
Courtroom we will be there also to look Berg in the eyeball and tell him he is falsifying information
and manufactured evidence, Ed can’t use that word anymore. But anyway that is what I got to say
about that, okay.”

Ken Dunbar: “Now what date is that Ed?”

Ed Hale: “It’s supposed to be August 7, now this lawyer that Ted Hoppe sent to the Judge telling him
that we had changed attorney’s, he is asking for a thirty [30] day continuance, however, the back up
plan is if the Judge does not grant us that thirty [30] day extension, Caren, Linda and I will be in
Philadelphia to defend ourselves on August 7 at 10:30 a.m. so what we are doing now is just sitting
there waiting to see what the Judge is going to say.”

Ken Dunbar: “Very good, that is just 9 days away Ed, not this Friday but the next.”

Ed Hale: “That’s why we are going to have all our cd’s transcribed, which we never got them all
transcribed, and we will fed ex them out Friday to the Judge so he will have them by the deadline on
Monday. He didn’t give us but a week to get all this done. We have ten [10] cd’s we have to
transcribe.”

Ken Dunbar: “But the good news is Ed is that you don’t have a show to do yourself so you’re not
scrambling to get a guest or what have you, your just scrambling now to work on for the lawsuit”

Ed Hale: “Well, this is true Ed has all, he has all the audio tapes now on cd’s, actually they are called
a high quality like a recording studio did it. We have several of the great patriots here at plains radio
network who are transcribing these discs for us. And, let me tell you something, when we present this
and if you will read that letter that Mr. Hoppe sent I want to tell you something that is a dynamite letter
because in that he basically said Berg you are lying to the Judge.”

Ken Dunbar: “Judges don’t like to be lied at, do they Ed?”

Ed Hale: “No, I don’t think so and you know we just got this thing going and what’s funny about this
donor is that he is a former major supporter of Phil Berg and when he seen that Phil Berg was lying
about or there I go using that word again I aint supposed to, manufacturing that evidence that was not
true against us he told or she told Berg or who ever it was to take a hike and that person then called

Z:\Liberi Ltr to Judge Robreno July 30, 2009 11
Linda up and said can I help you. Linda then explained the situation with this attorney and he called
this David Carlton Hughes up in Dallas and said what is it going to take, David said it will take twenty-
five thousand dollars, a wire transfer was completed this morning. That was money that was gonna go
to support Berg, but he aint gonna get it now.”

Ken Dunbar: “So you can’t use the words, don’t say it again, but can you instead say he was making
allegations.”

Ed Hale: “He was making false allegations”

Ken Dunbar: “So certain false allegations that have been proven to be false per the audio record.”

Ed Hale: “That is correct, and it is like one of the people transcribing said I don’t know why we need
this, a spoken word is heavy and I said because the Judge wants to read it He said he’s gotta listen to
these tapes because he said it just proves that what Mr. Berg said was false.”

Ken Dunbar: There you go.

Ed Hale: “Alright I’m getting off of here, go ahead Ken I’m sorry for butting in here but I thought
people need to know.”

131:57

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EXHIBIT “2”

Z:\Liberi Ltr to Judge Robreno July 30, 2009 13
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Index > General > General Forum > PJer Outs Ron Polarik as a Fraud July 29, 2009 - 11:59:28 AM

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rikker PJer Outs Ron Polarik as a Fraud Quote Reply

PJ member Loren has been tracking down Ron Polarik, Phil
Berg's forensic document expert. It turns out that Polarik is a
Jul 29, 2009 - 9:00AM far right Israel supporter who agreed with IsraeliInsider's
original fears about Obama's muslim ties. None of his claims
about document expertise are borne out by his actual resume.
ANd that's why he'll never testify about Obama's "forged" COLB
in any American court.

http://barackryphal.blogspot.com/2009/07/meet-ronald-jay-
polland.html

Polarik's real name is Ronald Jay Polland. And he lives in MY
city!! Oh, joy!!!

For those of you that don't know Ron Polarik, here is his
analysis of Obama's COLB:

http://www.freerepublic.com/focus/bloggers/2136816/posts?

http://pub29.bravenet.com/forum/static/show.php?usernum=2442810129&frmid=8&msgid=1040553...
Plains Radio Network - Voice of the People - Window Title

page=321#321.

State: FL

Civis Naturaliter Natus Re: PJer Outs Ron Polarik as a Fraud Quote Reply

I see no evidence that one is the other. Merely a gratuitous
assertion.
Jul 29, 2009 - 9:36AM
Aslo, what this guy who does the outing does not understand, is
that even if this fellow does not have the expertise, he could
have been collaborating with other document experts and
posted their collective work under the Pollark name...

So who he is proves nothing.

Look,

If an anonymous fellow gives you the mathematical solutoin to
the

Integral

(x-3)^.1-(x^2+3x)^2=y, for y=1 to 5,

It does not matter what his credentials are, if the truth of the
answer he gives you can be independently determined.

So the real "proof" will be a document expert who critiques
Pollarks work.

But in one sense it is a wast of time, because the JPG is not a
document, and so no disproof is necessary, since it is not
admissable in Court.

So when Obots claim the BC is on the net; their claim is
rediculous and inadmissable evidence.

It is illogical for them to hunt down someone who calls that
evidence into doubt, because it is not evidence admissable in
court in the first place!

rikker Re: PJer Outs Ron Polarik as a Fraud Quote Reply

Civis,

Jul 29, 2009 - 9:47AM Do you know anything about establishing and impeaching
subject matter experts in a court of law? The first thing that
impeaches a subject matter expert is "I hang around with
people who are experts."

The second thing that impeaches a SME is to have a written
record of lies. Polarik claimed that HE possessed doctorate level
forensic document analysis skills. He does not. He has lied in
writing. Any lawyer who puts him on the stand is a fool.

State: FL

http://pub29.bravenet.com/forum/static/show.php?usernum=2442810129&frmid=8&msgid=1040553...
Plains Radio Network - Voice of the People - Window Title

Rebel Rose Re: PJer Outs Ron Polarik as a Fraud Quote Reply

Quote:
Jul 29, 2009 - 11:10AM
Originally Posted by rikker
Civis,

Do you know anything about establishing and impeaching
subject matter experts in a court of law? The first thing
that impeaches a subject matter expert is "I hang around
with people who are experts."

The second thing that impeaches a SME is to have a
written record of lies. Polarik claimed that HE possessed
doctorate level forensic document analysis skills. He does
not. He has lied in writing. Any lawyer who puts him on
the stand is a fool.

I see Civis drank the Kool-Aid on this one, too.

Polarik's research meant SQUAT from day one, and anyone who
wasted time on his claims of "fraud" and "forgery" regarding
the COLB clearly lacked knowledge of what constitutes proof in
a court of law and what doesn't.

Recently, he's tried to get the spotlight to shine on his study yet
again--obviously seeking more publicity for himself--and some
blogs are even foolish enough to publish it. Others are even
gullible enough to believe one word he says.

Despite all of his ramblings, the online version was never
acceptable proof of ANYTHING. It was NOT the original, it was
NOT the vault form that was needed to prove citizenship--
digitized image or not, irregular borders or not, "seal" or not, so
there was absolutely no value in paying any attention
whatsoever to any of his claims.

I put him in my "hoax" file a long time ago. Focus on the long
form--period.

State: Tennessee

Index > General > General Forum > PJer Outs Ron Polarik as a Fraud

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EXHIBIT “3”

Z:\Liberi Ltr to Judge Robreno July 30, 2009 14
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LISA LIBERI et al., : CIVIL ACTION
: NO. 09-1898
Plaintiffs, :
:
v. :
:
ORLY TAITZ et al., :
:
Defendants. :

O R D E R

AND NOW, this 25th day of June, 2009, it is hereby

ORDERED that Plaintiffs’ emergency motions for an injunction

and/or a temporary restraining order (doc. nos. 3 & 66) are

DENIED without prejudice.1

IT IS FURTHER ORDERED that Defendants' motions to

dismiss (doc. nos. 23, 24, 25, 35, 50, 53 & 59) are DENIED

without prejudice.

IT IS FURTHER ORDERED that Plaintiffs' motions to

strike (doc. nos. 58 & 64) are DENIED without prejudice.

IT IS FURTHER ORDERED that Defendant Taitz's motion to

strike (doc. no. 61) is DENIED without prejudice.

AND IT IS SO ORDERED.

s/Eduardo C. Robreno

EDUARDO C. ROBRENO, J.

1
Defendants are to conduct themselves according to the
parameters discussed today in open court.