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Law Offices of: PHILIP J.

BERG, ESQUIRE 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Identification No. 09867 (610) 825-3134

Attorney for: Plaintiffs

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
_____________________________________________

LISA LIBERI and PHILIP J. BERG, ESQUIRE and THE LAW OFFICES OF PHILIP J. BERG and EVELYN ADAMS a/k/a MOMMA E and LISA M. OSTELLA and GO EXCEL GLOBAL

vs.

: : : CIVIL ACTION NO. 09-1898 : : : JURY TRIAL DEMANDED : : Assigned to Honorable Eduardo C. Robreno : : : : : : : Plaintiffs, : : :

: ORLY TAITZ, a/k/a DR. ORLY TAITZ, a/k/a : : LAW OFFICES OF ORLY TAITZ; a/k/a : WWW.ORLYTAITZESQ.COM a/k/a : WWW.REPUBX.COM a/k/a ORLY TAITZ, : INC. : and : DEFEND OUR FREEDOMS : FOUNDATIONS, INC. : : and : YOSEF TAITZ : and : THE SANKEY FIRM : and : SANKEY INVESTIGATIONS, INC. : and : NEIL SANKEY : and : JAMES SUNDQUIST : and : ROCK SALT PUBLISHING :
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and LINDA SUE BELCHER a/k/a LINDA S. BELCHER a/k/a LINDA STARR; a/k/a NEWWOMENSPARTY a/k/a STITCHENWITCH a/k/a EVA BRAUN a/k/a WEB SERGEANT a/k/a KATY a/k/a

: : : : : : : WWW.OBAMACITIZENSHIPDEBATE.ORG : and : EDGAR HALE a/k/a JD SMITH; : and : CAREN HALE; : and : PLAINS RADIO NETWORK, a/ka PLAINS : : RADIO NETWORK, INC. a/k/a PLAINS : RADIO; : and : BAR H FARMS; : and : KPRN AM 1610; : and : DOES 1 through 200 Inclusive, : : Defendants. :

PLAINTIFFS COMPLAINT

I.

PRELIMINARY STATEMENT

NOW COMES, Lisa Liberi, Philip J. Berg, Esquire, the Law Offices of Philip J. Berg, Evelyn Adams a/k/a MommaE, Lisa M. Ostella and Go Excel Global, Plaintiffs by and through the undersigned counsel and brings this Complaint seeking injunctive relief and damages against the Defendants, Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation; Yosef Taitz; Neil Sankey; The Sankey Firm, Sankey, Sankey Investigations, Inc., James Sundquist; Rock Salt Publishing; Linda Sue Belcher a/k/a Linda S. Belcher a/k/a Linda Starr a/k/a Newwomensparty a/k/a Stitchenwitch a/k/a Eva Braun a/k/a Web Sergeant a/k/a Katy a./k/a www.obamacitizenshipdebate.org; Edgar (Ed) Hale a/k/a JD Smith; Caren Hale; Bar H Farms; Plains Radio Network, Inc. a/k/a Plains Radio; and KPRN
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AM 1610; individually and collectively, for their illegal acts against the Plaintiffs, their staff and their businesses. This is a case that sets forth the facts that Defendants, Orly Taitz a/k/a Law Offices of Orly Taitz a/k/a Orly Taitz, Inc., Defend our Freedoms Foundation, Inc., The Sankey Firm, Sankey Investigations, Inc., and Neil Sankey, have sent Plaintiff Lisa Liberi’s Social Security number and personal data via e-mail in mass mailings, media groups, internationally and to 1000’s of undisclosed recipients, requesting the information to be posted on websites across the internet and have been harassing Plaintiff Lisa Liberi, Philip J. Berg, Esquire and the Law Offices of Philip J. Berg. Defendants James Sundquist and Rock Salt Publishing have sent mass e-mailing with Lisa Ostella’s home address, phone number and maiden name through the internet to an unknown number of undisclosed recipients slandering and harassing Lisa Ostella and her family and have filed falsified police and law enforcement reports against Lisa Ostella regarding supposed “hacking” of Defendant Orly Taitz, et al websites and PayPal accounts. Lisa Liberi and her husband were also accused of “hacking” and tampering with Defendant Orly Taitz’s website and PayPal accounts. Defendants’ are well aware it is Orly Taitz, et al who has placed JS Kit software which is a “tracking” and “hacking” software on her Defend our Freedoms Foundation, Inc. websites and blogs in order to “track” and “hack” individuals and their computers who have visited her websites. Defendant Yosef Taitz has a server in Orly Taitz, et al and his home in order to complete their illegal activities. Defendants’ have been slandering Plaintiffs herein, their staff and their businesses; posting libel regarding the Plaintiffs, their staff and their businesses on the internet and through mass mailings on the internet; and harassing the Plaintiffs, their staff and their businesses. Defendants DOES 1 through 200 are Defendants internet providers, phone companies, e-mail providers, streamlines and unknown Defendants who have allowed Defendants’, Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly Taitz a/k/a Orly Taitz, Inc., Defendant our Freedoms Foundation, Inc., The Sankey Firm, Sankey

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Investigations, Inc., Neil Sankey; Linda Sue Belcher a/k/a Linda S. Belcher a/k/a Linda Starr a/k/a Newwomensparty a/k/a Stitchenwitch a/k/a Eva Braun a/k/a Web Sergeant a/k/a Katy a/k/a www.obamacitizenshipdebate.org, Plains Radio Network a/k/a Plains Radio Network, Inc. a/k/a Plains Radio and Mr. and Mrs. Hale, to continue their illegal and dangerous behaviors against Plaintiffs, their staff and their businesses. As a result, Plaintiffs, their staff and their businesses have been severely damaged as outlined herein. II. 1. JURISDICTION AND VENUE

This case involves diversity of citizenship and this Court has jurisdiction pursuant to 28 U.S.C. §1332(a).

2.

This case further arises under the Constitution and laws of the United States and presents a federal question within this Court’s jurisdiction under Article III of the Constitution and 28 U.S.C. § 1331.

3.

Venue is proper in this Court under 28 U.S.C. § 1391(b).

III.

PARTIES

4.

Plaintiff, Lisa Liberi [hereinafter “Liberi”] is an adult individual with a business address of 555 Andorra Glen Court, Suite 12, Lafayette Hill, PA 19444-2531;

5.

Plaintiff, Philip J. Berg, Esquire [hereinafter at times “Berg”] is an adult individual with a business address of 555 Andorra Glen Court, Suite 12, Lafayette Hill, PA 19444-2531;

6.

Plaintiff, The Law Offices of Philip J. Berg is a law firm, with a staff, owned and operated by Plaintiff Philip J. Berg, with a business address of 555 Andorra Glen Court, Suite 12, Lafayette Hill, PA 19444-2531;

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7.

Plaintiff, Evelyn Adams [hereinafter at times “Adams”] is an adult individual with a residential address of Route 1, Box 106 BB, Wynnewood, Oklahoma 73098;

8.

Plaintiff, Lisa M. Ostella [hereinafter “Ostella”] is an adult individual with a residential address of 2227 US Highway 1, #245, North Brunswick, NJ 08902-4402.

9.

Plaintiff Go Excel Global is a Web Communications company owned and operated by Lisa M. Ostella with a business address of 2227 US Highway 1, #245, North Brunswick, NJ 08902-4402;

10.

Defendant, Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly Taitz, a/k/a WWW.ORLYTAITZESQ.COM a/k/a WWW.REPUBX.COM a/k/a Orly Taitz, Inc. [hereinafter “Taitz”] is a licensed Attorney with a business addresses of 26302 La Paz, Suite 211, Mission Viejo, CA 92691 and 29839 S. Margarita Pkwy, Rancho Santa Margarita, CA 92688, and a home address of 31912 Monarch Crest, Laguna Niguel, CA 92677;

11.

Defendant, Defend our Freedoms Foundation, Inc. is incorporated as a non-profit organization owned and operated by Defendant Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly Taitz with a business address of 26302 La Paz, Suite 211, Mission Viejo, CA 92691;

12.

Defendant Yosef Taitz [hereinafter “Yosef”] is an adult individual with a home address of 31912 Monarch Crest, Laguna Niguel, CA 92677;

13.

Defendant, The Sankey Firm [hereinafter “Sankey Firm”] is owned and operated by Neil Sankey. The Sankey Firm has a business address of 2470 Stearns Street, #162, Simi Valley, California, 93063 and Post Office Box 8298, Mission Hills, California 91346;

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14.

Defendant Sankey Investigations, Inc. is incorporated in the State of California. Sankey Investigations, Inc. is owned and operated by Neil Sankey and is a private investigation Company. Sankey Investigations has a business address of Post Office Box 8298, Mission Hills, California 91346 and 2470 Stearns Street, #162, Simi Valley, California, 93063;

15.

Defendant, Neil Sankey [hereinafter “Sankey”] is an adult individual and owner of The Sankey Firm and with an business address of 2470 Stearns Street, #162, Simi Valley, California, 93063 and Post Office Box 8298, Mission Hills, California 91346;

16.

Defendant James Sundquist [hereinafter “Sundquist”], is an adult individual, owner and operator as Director of Defendant Rock Salt Publishing, with a business address of 551 Valley Road, Suite 123, Upper Montclair, New Jersey 07043;

17.

Defendant Rock Salt Publishing [hereinafter “Rock Salt”] is a company owned and operated by James Sundquist, as Director with a business address of 551 Valley Road, Suite 123, Upper Montclair, New Jersey 07043;

18.

Defendant, Linda Sue Belcher a/k/a Linda S. Belcher a/k/a Linda Starr a/k/a Newwomensparty a/k/a Stitchenwitch a/k/a Eva Brau a/k/a Web Sergeant a/k/a www.obamacitzenshipdebate.org [hereinafter “Linda”] is an adult individual with a home address of 201 Paris Street, Castroville, Texas 78009-4516;

19. Defendant Edgar (Ed) Hale [hereinafter at times “Mr. Hale”] is an adult individual with a residential and business address of 1401 Bowie Street, Wellington, Texas 79095; 20. Defendant Caren Hale [hereinafter at times “Mrs. Hale”] is an adult individual with a residential and business address of 1401 Bowie Street, Wellington, Texas 79095;

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21.

Defendant, Plains Radio Network a/k/a Plains Radio Network, Inc. a/k/a Plains Radio,] hereinafter at times “Plains Radio”] is a business and owned and operated by Defendants Edgar (Ed) and Caren Hale with a principal address of 1401 Bowie Street, Wellington, Texas 79095;

22.

Defendant, Bar H. Farms [hereinafter at times “Bar H” is a business owned and operated by Defendants Edgar (Ed) and Caren Hale with a principal address of 1401 Bowie Street, Wellington, Texas 79095;

23.

Defendant, KPRN AM 1610 [hereinafter “KPRN”] is a business owned and operated by Defendants, Edgar (Ed) and Caren Hale with a principal address of 1401 Bowie Street, Wellington, Texas 79095; and

24.

Defendants, DOES 1 through 200 are unknown Defendants who provide the internet access, streaming, e-mail, broadcasting, etc., for Plains Radio, KPRN, Bar H Farms and Mr. and Mrs. Hale.

IV.

FACTUAL ALLEGATIONS RELATING TO ORLY TAITZ a/k/a DR. ORLY TAITZ a/k/a LAW OFFICES OF ORLY TAITZ a/k/a WWW.ORLYTAITZESQ.COM a/k/a WWW.REPUBX.COM a/k/a ORLY TAITZ, INC., DEFEND OUR FREEDOMS FOUNDATION, INC. and YOSEF TAITZ

25.

In or about November 2008, the name Orly Taitz appeared as filing legal complaints in Sacramento, California on behalf of Alan Keyes and other Plaintiffs and against the California Secretary of State and other Defendants regarding the Barry Soetoro a/k/a Barack H. Obama citizenship issues1. Ironically, Taitz

Ambassador Dr. Alan Keyes, et al. v. California Secretary of State Debra Bowen, et al. Superior Court of the State of California for the County of Sacramento, Case No. 34-2008-80000096-CU-WM-GDS, which was recently dismissed. I:\FORMS\Liberi, Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages 7

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plagiarized the work of Philip J. Berg, his Assistant Lisa and his law practice, Law Offices of Philip J. Berg. 26. Orly Taitz set up the business name of Defend our Freedoms Foundation, Inc. as a non-profit Organization with a Federal Tax Identification number of 26-4328440. However, when you attempt to verify the Federal Tax Identification number it comes back invalid2. 27. Taitz had a website at drorly.blogspot.com, which did have some nefarious functions and Taitz authorized those functions. At this time, Ostella assumed it was because Taitz did not understand the internet. There was a third [3rd] party program added to drorly.blogspot.com. This program was collecting information from everyone who was visiting and posting at Taitz website (drorly.blogspot.com) and transferring the individuals’ private data to an unknown server. Taitz was well aware of these functions as she authorized them and had the head webmaster install the software on December 24, 2008. 28. The data transfer took place via a java script program plus a put command that enabled FTP transfer. The java program is what caused trouble with people using Taitz’s website located at drorly.blogspot.com. Most computers are set up with security firewalls that do not allow easy data collection. 29. Ostella purchased and owned the defendourfreedoms.us and

defendourfreedoms.org, websites and she maintained them on the server that she (Ostella) paid for. Ostella allowed Taitz to use said websites. Ostella supported Taitz and has always been involved with politics, campaigns and causes. So when Ostella saw the antics with the java script program on the other blog (drorly.blogspot.com),

2

http://www.melissadata.com/lookups/np.asp?zip=26-4328440&submit1=Submit 8

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and it was never clear on how much Taitz realized was going on, Ostella took Taitz over here to use Ostella’s accounts. All of the DefendOurFreedoms domain names were and are on Ostella’s web accounts. 30. DefendOurFreedoms.org, owned by Lisa Ostella was and is hosted at Ostella’s server. It is a stand-alone server on rack rental at HE.Net. Ostella had and has full access to this server and no other accounts are on this server but hers. Ostella verified her IP logs to ensure the website was not “hacked”. The IP Address logs show every IP address, which is a computer’s identification that entered the website and/or server. There has never been any other IP addresses that have appeared on the IP logs other than Ostella’s. Hence, the website and/or server have never been “hacked”. 31. As for DefendOurFreedoms.us, that was hosted at GoDaddy under Ostella’s reseller account. This domain did not point to a website, it pointed to a blog. Specifically, it pointed to QuickBlogcast. This is very important to understand. A blog is not a website. The domain points to a database label. If the blog had been “hacked”, someone would have had to break into GoDaddy’s database files and know what customer number the database files was under. This would have compromised a number of other accounts with more damage other than a change in the e-mail address. GoDaddy would have had to issue a notification to all customers. Of course, GoDaddy never issued such a notification because the blog was never “hacked”. 32. None of the DefendOurFreedoms website were ever hacked or sabotaged, as Taitz claimed. Being unable to access a website due to network latency does not equal

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“hacking”. Traffic, congestion, line repairs affect network flow and all can always be checked on the Internet Traffic Report3. 33. Another webmaster who goes by “creativeogre” and Ostella called Taitz and explained to Taitz her websites had never been hacked. 34. On or about March 9, 2009, another issue arose with Taitz and her PayPal account. Taitz had volunteers with access to the coding of her PayPal account on her blogs. One of Taitz’s volunteers or Taitz herself changed Taitz e-mail address with her PayPal account from orly.taitz@gmail.com to

associated

orly.taitz@gmail.org. 35. Bob Stevens, Taitz’s Head Webmaster created four [4] e-mail accounts for Taitz. Taitz was supplied all her e-mail accounts which included, amongst others, dr.taitz@gmail.com. Despite knowing this was her own e-mail address, Taitz sent a mass e-mailing out with the below statement and posted the statement on her website, knowing it to be false.

36.

As a result, Taitz was not receiving her donations. Donations received were rejected by PayPal as the e-mail address was incorrect and no such e-mail address

3

http://www.internettrafficreport.com 10

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existed. Since the e-mail address did not exist, PayPal rejected the donations and sent them back to the contributors. Hence, the donations were not stolen or misdirected as Taitz claimed, which Taitz was well aware. 37. Despite the fact Taitz was well aware her websites and PayPal accounts had never been “hacked” or tampered with, on or about April 2, 2009, Taitz wrote to the U.S. Supreme Court Justices4 seeking help in an investigation regarding a criminal complaint she had filed with the Federal Bureau of Investigations regarding hacking into her websites and tampering of her PayPal accounts, and other things. Taitz sent this same letter to the Secret Service and other Governmental Law Enforcement Agencies. Taitz was aware the information she gave to the Federal Bureau of

Investigations was false and she was well aware she was filing a false report. 38. As a result of the false report made by Orly Taitz to the Federal Government, Ostella informed Taitz that she must clear up the false reports or Ostella was removing Taitz from her websites and server. Taitz refused to clear this matter up and refused to retract her falsified police reports. When Taitz refused to clear up this report, Ostella told Taitz she had to move her sites. Taitz asked Ostella to give her thirty [30] days so she would be able to find a new host. 39. Instead of Taitz locating a new server, she gave an interview to World Net Daily5 on April 4th, 2009 elaborating on her scheme to mislead the public and law

A copy of the letter Orly Taitz sent to the U.S. Supreme Court, which was posted by Orly Taitz on April 2, 2009 at 4:20 p.m. can be located at: http://defendourfreedoms.net/2009/04/02/open-letter-to-the-supreme-courtrequest-ofcooperation-with-the-fbi-investigation.aspx
5

4

Orly Taitz interview can be found at http://www.worldnetdaily.com/index.php?fa=PAGE.view&pageId=93832

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enforcement into believing her websites and PayPal accounts were “hacked” and “sabotaged”. Again, Taitz was well aware none of these events took place. 40. Although Ostella continued informing and explaining to Taitz her websites had never been “hacked”, Taitz continued to spread the falsified story. As a result, Ostella told Taitz she had to immediately move her sites. 41. Taitz found a person by the name of Jesse Smith who was to be her new web host. She authorized Ostella to transfer the domains to him. Jesse Smith first contacted Ostella on April 9, 2009. Ostella told him to initiate the transfer. Jesse Smith started the initiation on April 10, 2009 through Network Solutions. Ostella accepted the transfer request and the transfer process started. 42. Now, remember, the site was not a website. It is a blog. The domain pointed to a database label. Normally, when a domain is transferred from a website, the domain just switches from the one site to the new site smoothly. It will leave the old site still showing; but with the virtual host name. In order to move a blog site, which is a database, the account would delete when the transfer activates. To protect all the data, Ostella moved the account onto DefendOurFreedoms.Net, then unlocked the domain and authorized the transfer. For whatever reason, this outraged Taitz and Taitz accused Ostella of being defiant. 43. On April 12, 2009, Taitz went on the Evil Conservative Blogcast6 and told the audience that Ostella had threatened her and altered the focus of her story onto the PayPal account.

6

http://www.evilconservativeonline.com/2009/04/orly-taitz-update-site-moving.html

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44.

For protection purposes, Ostella locked the website access of all of her (Ostella’s) websites. Ostella changed the PayPal script in the donations button to reflect her own account and removed Taitz’s accounts from the site. Ostella placed notifications on all her webpages that the sites were no longer Taitz’s Defend our Freedom Foundation, Inc. and Ostella posted the following links to ensure people understood Taitz’s sites were never”hacked”.

Understanding the Internet 101 http://defendourfreedoms.net/2009/04/12/understanding-the-internet-101.aspx

45.

Once Ostella posted the above, she received the following Ceize [sic] and Desist from Taitz, which was untrue. Ostella at all times owned the domains and servers that the domains were located. “Ceize and Desist 04.13.09. Ms. Ostella, This is a Ceize and Desist Letter, advising you to stop immediately operation of sites and shut down DefendOurFreedoms.net; DefendOurFreedoms.US; DefendOurFreedoms.Org, and DefendOurFreedoms.Com and any other relating sites that you have been operating after I requested transfer. You have used those sites for defamatory purpose of me and my foundation and you have used my likeness and my material without my permission. If you do not shut down above sites immediately, further actions will be taken. Sincerely, Dr. Orly Taitz Esq 26302 La Paz ste 211 Mission Viejo Ca 92691”

46.

Moreover, Taitz, placed JS Kit software which is a “tracking” and “hacking” software on her Defend our Freedoms Foundation, Inc. websites and blogs, this softwith the exception of the DefendourFreedoms websites owned by Lisa Ostella, in

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order to “track” and “hack” individuals and their computers who have visited her websites. Defendant Yosef has a server in Taitz, and his home in order to complete their illegal activities. 47. Unfortunately, Liberi’s computer was infected with Taitz’s JS Kit Software and a remote server was placed on Liberi’s home computer by accessing Taitz website. 48. Taitz began changing her story to focus on “hacking” of her PayPal account, even though it never happened. Taitz was literally telling people that her PayPal account was “hacked”, knowing this to be false. In fact, there is no way Taitz’s PayPal account could have been hacked. PayPal’s servers that hold individuals’ private data are not connected directly to the internet. There are servers in between. So the server an individual logs into in order to access their PayPal account, is not the same server that houses the information. If someone was able to break into that system, PayPal would have had to notify all customers of a breach and shut all processes down to investigate. Taitz literally had people thinking that her e-mail address was changed from within the PayPal account, again knowing this information to be false. 49. Taitz never launched an investigation with PayPal in reference to her “hacking” allegations. Instead, Taitz made blatant statements saying money was stolen out of her account. Again, the entire time knowing this information was false. 50. Because of Taitz false statements regarding her PayPal account being “hacked”, Ostella posted the following: • Understanding the Internet 102 – PayPalGate http://defendourfreedoms.net/2009/04/14/understanding-the-internet-102— PayPalgate.aspx

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51.

The change was in the e-mail address on the blogsite. Originally, the PayPal donate code on the blogsite was in an encrypted script that PayPal makes available for copying and pasting into blogs and websites. But GoDaddy made some updates in the design in February 2009. The updates didn’t function with the PayPal script encryption. See the below e-mail received from GoDaddy.
Subject: Script Issue With Quick Blogcast From: "Andrew" <achristensen@godaddy.com> Date: Tue, April 21, 2009 6:40 am To: info@goexcelglobal.com -------------------------------------------------------------------------On February 11, 2009, Lisa, was advised that the PayPal button links do not work on the sidebar within the Quick Blogcast. Andrew S. Team Sapphire Customer Care Center

52.

Taitz is no stranger to falsifying stories and falsely claiming to be the victim of “hacking” of her websites. On December 12, 2009 Taitz and Bob Stevens, Taitz Head Webmaster, began telling people that “Obama thugs” had her business/dental site, drtaitz.com, shut down. They wanted this information immediately posted on the blogs. Ostella stopped the posting of this information by looking up the domain and finding Taitz’s prior host data. In short, what Taitz had done was switched her own domain off the website. Taitz told Ostella she (Taitz) was signing up for a web traffic program. Taitz told Ostella she (Taitz) was going to give Ostella access to get her domain back and Ostella would be her new hired webmaster for Taitz’s dental websites. Ostella was never given access. Taitz’s dental websites are up and running and Ostella is unsure who Taitz’s webmaster is.

53.

On April 12, 2009, Ostella received the following e-mail containing false and incomplete information further slandering Ostella. This e-mail was sent to an

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unknown number of undisclosed recipients as well as carbon copied to Ostella and the Chicago FBI:
----- Original Message ----From: Orly Taitz To: chuckolb Cc: Lisa Ostella ; Chicago FBI Sent: Sunday, April 12, 2009 2:55 PM Subject: Re: IMMEDIATE / Dr. Orly Taitz / Redirect defendourfreedoms.net / Phil - therightsideoflife.com - the Conservative Sanctuary no, things are not right it is being investigate by the FBI. I cannot post anything at the moment, Lisa Ostella, web master, has blocked me out of my own blog and refuses to give me codes for my own blog Orly Taitz DDS Esq 26302 La Paz ste 211 Mission Viejo Ca 92691 29839 S. Margarita Pkwy Rancho Santa Margarita Ca 92688 ph. w 949-586-8110 c-949-683-5411 fax 949-586-2082

54.

It was also discovered Taitz had authorized placement of JS Kit Software on all her Defend our Freedoms Foundation, Inc. websites and blogs. Again, this does not include the DefendourFreedome websites owned and operated by Ostella. JS Kit software is tracking software used in “hacking” websites and personal computers. In the JS Kit software is a function that places remote servers on individual and company computer systems in order to allow the person using JS Kit software, in this case, Taitz, Yoself and other unknown individuals on their behalf to illegally enter the individuals and company computers to steal and transfer data. This remote server function was located on Liberi’s computer.

55.

Yosef, Taitz husband and Taitz have implemented their own server in their home located in Laguna Niguel to utilize the “tracking” and “hacking” of individual and company computers who have visited Taitz websites and blogs. Yosef is assisting his

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wife, and their companies, Orly Taitz, Inc., Defend our Freedoms Foundation, Inc., and Taitz, in her illegal activities. Hence, it is not Plaintiffs Ostella or Liberi

“hacking” Taitz and/or Defend our Freedoms Foundation, Inc. websites, blogs and/or PayPal accounts, it is Taitz, her husband Yosef and other unknown named individuals on their behalf who are “hacking” the computers of the Plaintiffs and other individuals and companies who have visited any of their websites and/or blogs. 56. On or about April 12, 2009, Berg received an e-mail from Taitz stating he was to “Ceize and Desist” [sic] from using Taitz’s Quo Warranto, which Taitz claimed was sent to Berg inadvertently. In this same e-mail, Taitz made false allegations claiming his (Berg’s) Paralegal, Lisa Liberi had an extensive criminal record involving amongst other things identity theft. Taitz went on further in her e-mail to Berg that Liberi’s husband was currently on parole and he had set up two (2) accounts accepting credit cards on Berg’s “charitable foundation”, again all of which was falsified and fabricated by Taitz. Taitz in her e-mail stated as an officer of the Court she was obligated to send the information to the “FBI”, Attorney General of California and San Bernardino County District Attorney since Lisa Liberi had an eight [8] year conviction in San Bernardino County, California. Taitz in her e-mail informed Berg that she believed that Berg, as an Officer of the Court, as well and a former Assistant Attorney General of Pennsylvania, should join her in issuing a joint Complaint and demand for investigation from the authorities. Taitz then forwarded the e-mail addressed to Berg to an undisclosed number of recipients. 57. Liberi then received an e-mail from Mr. Hale claiming Lisa Liberi was stealing money from Taitz’s PayPal account. Mr. Hale’s e-mail was forwarding an e-mail sent out by mass mailing by Taitz stating, “I also received information that her

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husband, who is currently on parole, is an owner of 2 of accounts, accepting credit cards on your charitable foundation web site.” At all times, Taitz and Mr. Hale were well aware this information was false and untrue. From: Ed Hale <ed@barhfarms.net> Date: Mon, Apr 13, 2009 at 9:58 PM Subject: Fwd: Ceize and Desist, demand to file a joint FBI complaint To: Lisa Liberi <lisaliberi@gmail.com> - Hide quoted text “Well, I sure hope that you will enjoy your time in prison. We now have you as we ahve undercover where you diverted funds from Dr Orly to your website. We have had 2 people come forward with PayPal reciepts proving you are a theif. Now me and Plains radio have been proven right, You and your whole bunch will wind up in jaib. This is a great day for Plains Radio and Ed Hale.” ----- Forwarded Message ----From: "Orly Taitz" <dr_taitz@yahoo.com> To: "mark westmann" <mwestmann13@gmail.com>, "Ed HalePlainsRadio" <barhfarms@gmail.com> Sent: Monday, April 13, 2009 11:01:25 PM (GMT-0600) America/Chicago Subject: Fw: Ceize and Desist, demand to file a joint FBI complaint

Orly Taitz DDS Esq 26302 La Paz ste 211 Mission Viejo Ca 92691 29839 S. Margarita Pkwy Rancho Santa Margarita Ca 92688 ph. w 949-586-8110 c-949-683-5411 fax 949-586-2082 --- On Sun, 4/12/09, Orly Taitz <dr_taitz@yahoo.com> wrote:

From: Orly Taitz <dr_taitz@yahoo.com> Subject: Ceize and Desist, demand to file a joint FBI complaint To: "Phil J Berg Esq (pvt)" <PhilJBerg@gmail.com> Cc: "Orly Taitz" <dr_taitz@yahoo.com> Date: Sunday, April 12, 2009, 10:01 AM
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04.12.09. Mr. Phillip Berg, ”this is to inform you that a few days ago I have forwarded my quo warranto pleadings to Mr. John Hemenway, since he agreed to be my local co-counsel in Washington DC. This was a confidential communication and Mr. Hemenway stated, that mistakenly he has forwarded those pleadings to you. Shortly thereafter you have sent a press release, stating that you will be filing Quo Warranto action. This is a Ceize and Desist letter, demanding that you do not use my pleadings and confidential information in any way, shape or form, as you received those in error without my authorization. Additionally, I received information from a licensed Private investigator, with 20 years of experience with Scotland Yard and 12 years of experience in US, that your paralegal Lisa Liberi has an extensive criminal record, involving fraud, forgery of documents and identity theft. See attached file. I also received information that her husband, who is currently on parole, is an owner of 2 of accounts, accepting credit cards on your charitable foundation web site. As an officer of the court I am obligated to forward this information to the authorities: FBI, Attorney General of California and San Bernardino County Distict Attorney, since Lisa Liberi had a 8 year conviction in San Bernardino County, California. I believe that you, as an officer of the court, as well and a former Assitant Attorney General of Pennsylvania, should join me in issuing a joint complaint and demand for investigation from the above listed authorities. Dr. Orly Taitz Esq” 26302 La Paz ste 211 Mission Viejo Ca 92691 29839 S. Margarita Pkwy Rancho Santa Margarita Ca 92688 ph. w 949-586-8110 c-949-683-5411 fax 949-586-2082

58.

It should be noted, Berg does not have a charitable foundation website. He does have a website with a donation button which allows people to donate one (1) of two (2) ways, PayPal or by a separate credit card company, which Berg is the only party with access.

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59.

Moreover, Liberi has nothing to do with the web mastering of his (Berg’s) website, Taitz website or any other website. The coding for the donate buttons and the accounts which donations go into are all done by a third party webmaster and is all traceable.

60.

Berg never received the “supposed” Quo Warranto Taitz is referring to above, nor has he seen it. However, what Liberi received from Allan Edward Buck, was a Writ of Mandamus and a Writ of Quo Warranto that he himself had drafted and did all the work on. If this is what Taitz is spreading around, it is not her work, but yet the work of another party.

61.

Plaintiffs then learned Orly Taitz had people go onto among others, Berg’s website at obamacrimes.com, download all the briefs investigated and prepared by Berg and his assistant, copy the contents and Taitz then filed the briefs in Court claiming the work to be hers, again which is plagiarism of Berg’s and his assistant’s work, which is owned by the Law Offices of Philip J. Berg.

62.

On or about April 14, 2009, Liberi received an e-mail from a third party that contained a post on Plains Radio owned by Mr. and Mrs. Hale7. The post was made by Defendant Katy and states she received an e-mail from Taitz stating the following. This same e-mail was also sent to an unknown number of undisclosed recipients:
Dr. Orly's site has been taken over by Obots!! E-mail from Orly ”This is an e-mail I recieved from her this afternoon: Katy” ”This is a nightmare. I had hacking into my PayPal account. (see dossier #5 in attachment), the e-mail address on my PayPal account was changed, so I would not be able to get donations. It was reported by a number of donors and I have filed a complaint with the FBI. My blog was set up by a volunteer Lisa Ostella. She is the web master and

7

http://pub29.bravenet.com/forum/2442810129#bn-forum-1-1-2442810129/8/1006820/show

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she has the codes for the blog. She demanded that I take back my complaint to FBI, claiming that the change of e-mail address was done by a volunteer by name Fran, that she banned Fran from the site, that it took care of the problem and I need to take back my complaint of hacking with FBI, as it gives her, as a web master a bad name. I refused to do so, stating that it is a legitimate complaint, I want them to investigate. At that time she stated that I will need to get my blog of her server, if I don't take back the FBI complaint. I found somebody else to host the blog, however according to volunteers she never forwarded the release and the codes to the platform company Go Daddy, she locked me out of my own foundation site and refuses to give me the access codes. She has posted a defamatory statement, claiming that I authorized hacking into my own account and that I made bogus claims. This is totally ridiculous in light of the fact that I have statements from the donors and I lost donations. The FBI agent in charge of this investigation is Nathan Le, Orange county, CA, FBI, cyber crimes unit, phone 714-245-5328; 310-7103459. Orly Taitz DDS Esq I 26302 La Paz ste 211 Mission Viejo Ca 92691 29839 S. Margarita Pkwy Rancho Santa Margarita Ca 92688 ph. w 949-586-8110 c-949-683-5411 fax 949-586-2082 “

63.

Again, Taitz was aware all this information was false. Ostella is a Webmaster by trade, Taitz was maliciously slandering and posting libel about Ostella to punish and harm Ostella for telling the truth, which has effected Ostella’s company, Go Excel Global.

64.

On or about April 17, 2009 at approximately 9:31 a.m. Taitz sent out a mass emailing of slander and libel pertaining to Liberi, Ostella, Berg and the Law Offices of Philip J. Berg. Liberi received an e-mail which contained Taitz Dossier No. Six (6) which was nothing more than a vicious attack on Ostella and Liberi. Taitz fabricated false allegations about both Ostella and Liberi. Taitz, gave personal identifying information regarding Liberi including her entire Social Security. Taitz made many false statements including but not limited to the following: Ostella locked Taitz out of her website instead of transferring the access codes and domains; Ostella posted

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bizarre defamatory statements that Taitz authorized hacking into her own account; Taitz claimed she received reports that some defamatory comments were made under alias usually used by Lisa Liberi, assistant for Attorney Philip J. Berg; Taitz insinuated Ostella was taking monies donated to her; Liberi had an extensive criminal record going back to 1990; Liberi, among other things, engaged in falsification of police reports, manipulation of credit bureau reports; counterfeiting of court documents; Liberi had Twenty-One Thousand [$21,000] Dollars per month in restitution; several sources confirmed that Liberi lives in NM; they confirmed her date of birth and appearance as matching the ones on file with the San Bernardino, CA district attorney; Liberi launched vicious attacks against Taitz and then states Liberi disagreed with her and this was the vicious attack. The list goes on. Dossier No. 6 by Taitz own admission was an open letter posted on the internet and forwarded to 26,000 outlets of US and international media. In addition, Taitz sent this e-mail to an unknown number of undisclosed recipients asking them to post the information on their website. Again, included in this was Liberi’s full Social Security number that Taitz obtained without a permissible purpose from Defendants, Neil Sankey, The Sankey Firm and Sankey Investigations, Inc. Moreover, Taitz sent this Dossier No. 6 to Attorney General Eric Holder; Solicitor General Elena Kagan; Director of FBI Robert Mueller; FBI Cyber Crime division, Orange County CA, Officer Nathan Le; Director of Secret Service Mark Sullivan; Chief of Security of the Supreme Court, Officer Christine Giaccio; Chief Justice of the Supreme Court John Roberts; and Legal Counsel to the Chairman of Joint Chiefs of Staff Admiral Mullen, Captain Crawford. Taitz was well aware this information was false, and it was illegal to transmit a third (3rd) parties personal identifying information, including their Social

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Security number which Taitz had absolutely no permissible purpose to obtain; distribute via the internet, by e-mail and posting a person’s private confidential information on websites. A copy of Taitz Dossier No. 6 will be provided to the Court; with a request that it be placed “under seal”. Taitz also posted this on her website at Defend our Freedoms.8 Below is only one of the many e-mails Taitz sent on this date
-------Original Message------Date: Fri, 17 Apr 2009 09:10:41 -0700 From: dr_taitz@yahoo.com Subject: More explosive information dossier #6 To: amccarthy@nationalreview.com; amy.chozick@wsj.com; ken@jhelp.com; backon@vms.huji.ac.il; shellijbaker@aol.com; johnbatchelorshow@gmail.com; mbelcher72@yahoo.com; beesba@aol.com; talkradio@live.com; tammyblog@yahoo.com; heytammybruce@yahoo.com; sean@wcbm.com; charenmail@cox.net; pchesler@phyllischesler.com; chuck.todd@nbcuni.com; info@hillaryclinton.com; clochhead@sfchronicle.com; nocompromisewhenyoureright@gmail.com; evil@evilconservativeonline.com; john@gopsenators.com; jrlc@optonline.net; jric@optonline.net; jric@earthlink.net; acoulter@worldnetdaily.com; carol@harrismedia.com; darlagdawald@yahoo.com; dickmorris@dickmorris.com; jdooley@honoluluadvertiser.com; drudge@drudgereport.com; editor@americanthinker.com; editor@haaretz.co.il; elouis@nydailynews.com; gdescobar@aim.com; alisia.essig@mail.house.gov; eugenerobinson@washpost.com; eva@dennisprager.com; jfarah@wnd.com; joel.fishman@gmail.com; david.freddoso@gmail.com; dfrum@aei.org; mhgintn@comcast.net; kyeoj@mchsi.com; GaynorMike@aol.com; patrickgibsonmail@gmail.com; glenn.simpson@wsj.com; jonahnro@aol.com; agrobman@nj.rr.com; Patrick_Guinn@coburn.senate.gov; mh1690@hotmail.com; barhfarms@gmail.com; author@victorhanson.com; khassett@aei.org; hemingway@nationalreview.com; hhewitt@hughhewitt.com; Brannon@worldviewweekend.com; churt@nypost.com; ymibrahim@gmail.com; info@ap.org; editor@israelinsider.com; Gregg.Jackson@gmail.com; jhood@johnlocke.org; jhorowitz@observer.com; jim.manzi.nro@gmail.com; producer@infowars.com; bryant.jordan@military-inc.com; roger@aim.org; kevin@davnet.org; kincaid@comcast.net; jawaraking@yahoo.com; jklinghoff@aol.com; ck@charleskrauthammer.com; msk@cis.org; lkudlow@kudlow.com; comments.kurtz@nationalreview.com; devvyk@earthlink.net; stevenlaib@sbcglobal.net; MLANGBERT@NYC.RR.COM; larry.king.live@cnn.com; letters@cctimes.com; letters@macleans.ca; letters@msnbc.com; letters@nationalreview.com; letters@ocregister.com; letters@sun-sentinel.com; letters@washpost.com; marklevin.show@citcomm.com; ylevin@eppc.org; elrushbo@eibnet.com; david@davidlimbaugh.com; LINDABENT@aol.com; klopez@nationalreview.com; cmahtesian@politico.com; malzbergtalk@gmail.com; marc@webservicesmedia.com; McGrewMX@aol.com; doug@kabc.com; vicmord2001@yahoo.com; nate.fredman@foxnews.com; nightly@nbc.com; today@nbc.com Orly Taitz DDS Esq 26302 La Paz ste 211 Mission Viejo Ca 92691

8

http://216.221.102.26/blogger/post/Dissier6.aspx

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29839 S. Margarita Pkwy Rancho Santa Margarita Ca 92688 ph. w 949-586-8110 c-949-683-5411 fax 949-586-2082 Dossier #6 new.doc 8960K View as HTML Download

65.

April 13, 2009, Taitz was on a blog talk radio station, The Dame Truth9, which is an internet blog talk radio program. The entire time Taitz was on the air she did nothing but slander Liberi with the above referenced information.

66.

Taitz then posted on her website Defend our Freedoms:10 “More on Lisa Liberi, contact her probation officer in Santa Fe New Mexico 505-827-8627. She is not allowed to be anywhere near other people's credit cards, By Orlytaitz April 17, 2009”

67.

On April 18, 2009, Taitz posted further slander and libel about Ostella and Liberi, on her website, Defend our Freedoms11: Dr. Orly Taitz Esquire
Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691. e-mail: dr_taitz@yahoo.com « Key witness in presidential passport case fatally shot from Field McConnell »

Every day I get such evidence of missing or misdirected funds
“Every day I get such receipts, showing that my former web master Lisa Ostella (posts under name Calpernia) has redirected donations to herself, to her e-mail address. Currently, as this was uncovered, she created new web sites Defend our freedoms .org, .net and continues the scheme by making those sites similar to my old ones and using the foundation name to steal more donations. She created a visa donation site with her e-mail account Go Excell Global, underneath she posted a PayPal button showing my foundation Defend Our Freedoms (without my consent) and my e-mail address (without my consent) to look as if she is still connected to me and my foundation, even though all ties with her were severed a couple of weeks ago, when I found out about this scheme

9

http://blogtalkradio.com/My-Two-Cents

10

http://216.221.102.26/blogger/post/More-on-Lisa-Liberi-contact-her-probation-officer-in-Santa-Fe-New-Mexico505-827-8627-She-is-not-allowed-to-be-anywhere-near-other-peoples-credit-cards.aspx
11

http://www.orlytaitzesq.com/blog1/?p=119

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and I closed the Pay Pal account completely. Any person, whose donations were stolen by Lisa Ostella aka Lisa Current aka Calpernia is asked to report this to his local police or sheriff’s department. As I found out, she appears to be connected to Lisa Liberi, who is still working for attorney Phillip Berg. Please see my dossier #6, Lisa Liberi aka Lisa Richardson aka Lisa Courvelle has a long criminal record, that includes grand theft, forgery of documents, forgery of seal, falsification of police reports and credit statements, where financial institutions were defrauded out of thousands of dollars. She claims to be a different Lisa Liberi, living in PA, however she lives in NM and her probation officers are Joanne Martinez 505-827-8627 and Dawn Helling (not sure about spelling) 505476-2359.”

68.

Taitz then set-up another blog12 where she was slandering and posting libel about Ostella. Taitz set up the blog, orlytaitz.com and posted the following:

« Form to become a Military Plaintiff Important Notice regarding donations sent to DefendOurFreedoms .US blog or .ORG site. »

Don’t be fooled
“My former web master Lisa Ostella has created an account that she called Defend Our Freedoms Network and is soliciting donations, praying on unsuspecting readers that would not notice the difference between Defend Our Freedoms Foundation and Defend Our Freedoms Community. Please notice, your donations there will not go to the foundation, they will go to her personal bank account, connected to her personal e-mail address GoExcellGlobal. She posted underneath a PayPal logo with my e-mail address, however I have closed the pay-pal account. If you want to give donations to the Defend Our Freedoms Foundations, please, mail them to Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691” This entry was posted on Saturday, April 18th, 2009 at 5:27 pm and is filed under Other Criminal or Suspicious Activities. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.”

69.

On April 20, 2009, Mr. Hale had a radio show on at 9:00 p.m. Mr. Hale’s Guest was Orly Taitz. Orly Taitz did nothing but slander Ostella and Liberi on Mr. Hale’s radio show with the false allegations outlined above. Mr. Hale then went on falsely stating Lisa Ostella and Lisa Liberi were one and the same person and she was a criminal.

12

http://www.orlytaitzesq.com/blog1/?p=71 25

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70.

On April 21, 2009, Taitz posted the following slander and libel against Ostella, Liberi, Berg, the Law Offices of Philip J. Berg and Adams on her website13:

“Dear Mr. Barrs, I have reported the matter to the Sheriff’s department and FBI . See below the receipt for the police report with the name and phone number of the detective. The name of the FBI agent is John Haas- supervisor of the cyber crimes unit 714-542-8825. Please spread the word and give everybody the new web address for the Defend Our Freedoms Foundation, which is http://www.OrlyTaitzEsq.com Please post this web address in as many blogs and sites as you can, so it will be picked up quickly by different search engines and can be seen by all my readers. I have closed my pay pal account and did not receive any pay pal or visa donation since 04.11.09. If you or anybody else has given any donations after this date, using pay-pal, visa, MasterCard, American Express and so on, believing that these donations were received by the Defend Our Freedoms foundation, please demand a refund and report it to the Sheriffs department, FBI and IRS as funds stolen from the non profit organization. I have sent a Cease and Desist letter to Ms. Lisa Ostella, demanding that she forward to me the access codes for the domains and the e-mail address list of the readers and stop fraudulently operating under the name DefendOurFreedoms and stop drawing financial profit from the Defend Our Freedoms name. I have also sent a Cease and Desist letter to Evelyn Adams aka Momma E, talk show host David Levin and other parties who are fraudulently advertising on the foundation website and drawing profit from it or from reader lists given or sold to them by Ms. Ostella. Ironically Ms. Ostella has accused me of collecting information on the readers. In reality I did not have any such information and could not reach most of the readers, aside from ones whose names were in my dr_taitz@yahoo.com e-mail account. Ms. Lisa Ostella is the one, who collected names and e-mail addresses and she is currently fraudulently sending e-mails to these readers using DefendOurFreedoms name. If you get such e-mail, please demand that she immediately stop this practice and forward the list to me, as the president of the foundation. My primary goal is to expose all the fraud committed by Obama and removing him out of office as an usurper, litigation against Ms. Ostella is secondary. I also need to get full information in regards to full damage to the foundation and me, stemming from actions of Ms. Ostella and parties that patronage her site and are aiding and abetting her. I, also, sent an e-mail with dossier #6 to Mr. Phil Berg, advising him of lengthy criminal record of grand theft, forgery, forgery of seal and other related crimes, committed by Ms. Lisa Liberi, his paralegal and assistant, who reportedly was managing his fund raising efforts. I believe Mr. Berg should not be using a person with such past in his fund raising efforts and legal practice and should issue a statement advising the donors and supporters, that Ms. Lisa Liberi is no longer employed by him or his foundation and that he is reviewing all donations and all legal records handled by Ms. Lisa Liberi. I believe the donors to Mr. Berg foundation should get assurances that their donations were used for litigation and the cause and not to reimburse victims of Ms. Liberi’s prior schemes, reported to add to $21,000 per month. Sincerely, Dr. Orly Taitz, ESQ” 04.21.09.

13

http://www.orlytaitzesq.com/blog1/?p=195

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71.

Unfortunately, Taitz continued sending out the above false statements and her falsified Dossier No. 6, every day since to websites and undisclosed recipients requesting the posting of the information along with her requests for everyone out there to contact the FBI, the Orange County Sheriff’s Department, a probation officer in Santa Fe, New Mexico and report this information. It was nothing more than harassment of Liberi, Ostella, Berg and the Law Offices of Philip J. Berg.

72.

Taitz distributed this information including Liberi’s full Social Security number, date of birth, residency, etc. to in excess of Two Hundred and Fifty Thousand [250,000] individuals and businesses.

V.

FACTUAL ALLEGATIONS RELATING TO DEFENDANTS’ NEIL SANKEY, THE SANKEY FIRM AND SANKEY INVESTIGATIONS

73.

Plaintiffs incorporate by reference all of the foregoing allegations as if set forth herein at length.

74.

Defendant Neil Sankey is a licensed private investigator and owns and operates the Sankey Firm and Sankey Investigations, Inc. Sankey is aware aware of the State and Federal laws pertaining to disclosure of third party information: the posting of Social Security numbers; the disclosure of Social Security numbers and personal identifying information; the permissible purpose requirement before disclosing any

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parties Social Security number, date of birth, where they reside or any personal information at all; the transmittal of Social Security numbers; State and Federal laws against endangering, harassing, threatening and attempting to destroy any person’s life and/or reputation. 75. Despite knowing these very laws, Sankey through his investigation firms, the Sankey Firm and Sankey Investigations, Inc. conspired with Taitz to destroy Liberi and violated every privacy protection law; State and Federal laws for the disclosure, posting, and transmitting a person’s Social Security number and personal identifying information; and violated the permissible purpose rule. In so doing, Sankey through his investigation firms, the Sankey Firm and Sankey Investigations, Inc. just to mention a few, violated Liberi’s First Amendment Rights to Privacy, First and Fourteenth Amendment pertaining to invasion of privacy, a right to be safe, etc. See below which is a copy of Neil Sankey’s e-mails from the Sankey Firm and Sankey Investigations, Inc. 76. Neil Sankey, by his own admission received from Defendant Linda statements that Liberi had a long criminal record going back to the 90’s and Liberi had been convicted of among other things, real estate fraud, falsification of police reports, manipulation of credit bureau reports, and counterfeiting of documents, which is completely false. Without bothering to investigate the information sent by Linda, Neil Sankey through his firms, the Sankey Firm and Sankey Investigations, Inc. sent an e-mail out with the false information as if it were true. Since this e-mail was sent Neil Sankey admitted to two [2] separate individuals that he did not investigation the information and could not verify it was in fact Liberi. See below.

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From: nsankey@thesankeyfirm.com To: lisaostella@hotmail.com; dr_taitz@yahoo.com Subject: FW: >>>>>>>>>>Urgent IMPORTANT INFO SAME SUBJECT<<<<<Date: Mon, 16 Mar 2009 14:57:13 -0700 PLEASE NOTE THE LAST LINE! Thursday, April 10, 2008 New Mexico Woman Sentenced in Identity Theft and Real Estate Fraud Lisa Liberi, aka Lisa Richardson, 42, New Mexico, was sentenced in connection with felony charges involving identity theft and forged > documents. Liberi appeared in San Bernardino County, Rancho Cucamonga, Superior Court, on March 21, 2008. She was sentenced to a state prison term of 8 years, imposed but stayed, and placed on supervised probation for 3 years as part of a plea agreement. Liberi was sentenced on ten felony counts ranging from Grand Theft, Forgery, and Filing False Documents. From 2000 to 2004, Liberi engaged in a complex fraud involving falsification of police reports, manipulation of credit bureau reports, loan fraud, and counterfeiting of court documents resulting in hundreds of thousands of dollars in losses to banks and credit unions. In 2002, San Bernardino County Sheriff’s Department personnel arrested > Liberi on theft by false pretense charges. In July 2004, Investigators from the San Bernardino County District Attorney’s Real Estate Fraud Unit arrested Liberi at the Ontario International Airport for additional felony charges while she was out on bail. She has an extensive criminal record going back to the 90’s.

77.

Instead of truly investigating the information, Sankey through his investigation firms “The Sankey Firm” and “Sankey Investigations” sent the information to Taitz and a reporter with World Net Daily via e-mail along with Liberi’s full social security number, date of birth and where she resided. Also included, was Liberi’s private confidential information.

78.

Sankey sent false and incorrect information claiming it to be associated with Liberi. See below, Liberi’s full Social Security has been replaced with X’s in order to protect the confidentiality of her Social Security number, however, in the original email her full Social Security number is disclosed:

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From: Neil SANKEY Subject: FW: LISA LIBERI etc To: dr_taitz@yahoo.com Date: Monday, April 13, 2009, 7:04 PM Here is the Liberi stuff you requested. This is also what I sent to Bob Unruh From: Neil SANKEY [mailto:nsankey@thesankeyfirm.com] Sent: Friday, April 10, 2009 10:01 AM To: Bob Unruh Subject: LISA LIBERI etc Bob here are some bare facts about Berg’s assistant. See below and attachments I don’t know how much of the story you have already, but is essentially about WHO she really is and the questions that unfortunately brings up about Berg. Call, if you need to, at your convenience. Neil Sankey Investigator & Consultant. THE SANKEY FIRM Simi Valley, California 93063 nsankey@thesankeyfirm.com 805 520 3151 818 212 7615 cell (Addendum) LISA RENEE LIBERI. Bn 5/28/1965. 462-45-xxxx, XXX-XX-XXXX (& others) According to the Police she was born COURVILLE and married a Richardson (Possible Alan Douglas Richardson, currently residing in Las Vegas .) IF it was the other way around, then the Courville is Bill Marshall Courville 11/10/61 of Houston , Tx. 457-71-x I have several SS#’s for her and a LOT of AKA’s. Her real SS# is probably 462-45-xxxx. Most prominent otherwise are 563-60-xxxx, 572-17-x, 622-19-x She went BK in 2002 Her brother is probably Lawrence E Morris of Fontana and Rancho Cuc , CA . He was born 1/16/64 Her Husband, Brent J, a Parolee, I have not researched that. Is probably Brent J McCormack 563-77, also uses 331-02-x There is also a Jerry HELLER and Douglas Cramer look interesting, but where do you stop?. From: Neil SANKEY Subject: Bergs PayPal To: dr_taitz@yahoo.com Date: Monday, April 13, 2009, 7:15 PMIt comes as no surprise to learn that the link to a Visa donation to Berg, (as opposed to PayPal) has been removed. Neil

79.

Sankey through his investigation firms, the Sankey Firm and Sankey Investigations, Inc., did not have a permissible purpose to obtain Liberi’s Social Security number or any other personal identifying information of Liberi.

80.

Moreover, Taitz did not have a permissible purpose to obtain or receive Liberi’s Social Security number and personal identifying information. This was nothing more than a complete libel/slander and invasion of privacy not to mention it violated state and federal laws.

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81.

Furthermore, Sankey through his investigation firms, the Sankey Firm and Sankey Investigations, Inc., did not have any permissible purpose to disclose Liberi’s Social Security number to any third parties including a Reporter with World Net Daily.

82.

In so doing, Sankey through his investigation firms, the Sankey Firm and Sankey Investigations, Inc., have severely endangered Liberi, her son and husband. Liberi was given a confidential address as a result of her and her son being victims of domestic violence. Sankey, through his investigation firms, the Sankey Firm and Sankey Investigations, Inc., have now disclosed Liberi’s private personal information, full Social Security number, date of birth and where she lives and has allowed said information to be posted all over the internet by Taitz and sent across the United States and Internationally, by Taitz own admission.

83.

Sankey through his investigation firms, the Sankey Firm and Sankey Investigations, Inc., conspired with Taitz to ensure Liberi’s life was endangered and ruined. Sankey was well aware of Taitz threat to destroy Liberi to get to Berg and his law practice.

84.

Sankey through his investigations firms, the Sankey Firm and Sankey Investigations, Inc., had a duty to abide by the California privacy laws. Because Sankey through his investigation firms, the Sankey Firm and Sankey Investigations, Inc., failed to ensure Taitz had a permissible purpose, which she did not, the fact Sankey himself distributed Liberi’s Social Security number and private personal identifying information through e-mail to a Reporter and Taitz, since Sankey and his investigation firms failed to ensure and sign a contract with Taitz and the Reporter with World Net Daily to ensure the confidentiality of Liberi’s Social Security

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number, date of birth, and other private personal identifying information, he is liable for all the mass e-mailing Taitz did as if he sent the e-mails personally.

VI.

FACTUAL ALLEGATIONS RELATING TO DEFENDANTS’ JAMES SUNDQUIST and ROCK SALT PUBLISHING

85.

Plaintiffs incorporate by reference all of the foregoing allegations as if set forth herein at length.

86.

James Sundquist through his company, Rock Salt Publishing, accessed Ostella’s home address and began sending mass e-mailing with her private confidential information to an unknown number of undisclosed recipients. In so doing, Sundquist through Rock Salt listed Ostella’s phone number as his personal phone number in order to entice people to call and harass Ostella. The original e-mail from James Sundquist at Rock Salt Publishing is below, however, the X’s placed were done so to protect Ostella and are replacements from the actual address and phone number. The X’s were not part of the original e-mail and only added as this complaint will be public record.

From: Subject: Date: To:

"James Sundquist" <rock.salt@verizon.net> re Lisa Ostella Tue, April 21, 2009 6:40 am contact@nbro.us,info@breederville.com

Dear Tom O’Neill & North Brunswick Republican Organization and Breederville Director, I need to alert you to the fact that Lisa Ostella has defrauded Dr. Orly Taitz and has hijacked her website. I have just spoken at length to Dr. Taitz. You can call her to verify this. Dr. Taitz tel number is 949-683-5411. I live in New Jersey and have written two books and have a massive database in which I am able to expose what Lisa Ostella did to Dr. Orly Taitz, including approximately a thousand radio stations which I frequent as a guest. Ms. Ostella's address and tel # are:

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Ostella, Lisa breederville.com xxxxxxxxxxxxxxxxx North Brunswick, New Jersey 08902 United States *** Sincerely, James Sundquist Director Rock Salt Publishing (732) xxx-xxxx

87.

Sundquist through his company Rock Salt filed false police reports with the Brunswick, New Jersey FBI and local authorities falsely accusing Ostella of hijacking Taitz’s websites and diverting funds from Taitz’s PayPal accounts.

88.

Sundquist. through his company Rock Salt, posted on Taitz’s website, orlytaitz.com, that Ostella had hijacked Taitz’s website and was diverting Taitz’s PayPal funds and that he had reported to the Brunswick, New Jersey FBI and local authorities. In addition, Sundquist, through his company Rock Salt, also posted Ostella’s home address and telephone numbers.14

Dr. Orly Taitz Esquire Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691 Copyright 2009 Official Blog of Dr. Orly Taitz Esquire April 22nd, 2009 Welcome to the OFFICIAL Dr. Orly Taitz Esquire blog. Please Note: I am NOT using PayPal anymore at this time for donations, Please mail your donations to: Defend Our Freedoms Foundation 26302 La Paz ste 211 Mission Viejo CA 92691. e-mail: dr_taitz@yahoo.com From James Sandquist, director of Rock Salt Publising April 23rd, 2009 Fwd: Lisa Ostella Internet Fraud in North Brunswick, NJ Thursday, April 23, 2009 6:44 AM

14

http://www.orlytaitzesq.com/blog1/?p=246 33

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From: “James Sundquist” <rock.salt@verizon.net> View contact details To: “Orly Taitz” <dr_taitz@yahoo.com> Begin forwarded message: From: James Sundquist <rock.salt@verizon.net> Date: April 23, 2009 9:39:46 AM EDT To: askconsumeraffairs@lps.state.nj.us Subject: Lisa Ostella Internet Fraud in North Brunswick, NJ Dear Director of Consumer Affairs and the FBI for New Jersey, You should be alerted to the following report regarding North Brunswick resident Lisa Ostella. Because this also involves interstate commerce, the FBI needs to know about this too! I need to alert you to the fact that Lisa Ostella has defrauded Dr. Orly Taitz and has hijacked her website. I have just spoken at length to Dr. Taitz. You can call her to verify this. Dr. Taitz tel number is 949-683-5411. WORLDNETDAILY has just run a national story on this: http://www.wnd.com/index.php?fa=PAGE.view&pageId=95555 I live in New Jersey and have written two books and have a massive database in which I am able to expose what Lisa Ostella did to Dr. Orly Taitz, including approximately a thousand radio stations which I frequent as a guest. Ms. Ostella’s address and tel # are: Ostella, Lisa breederville.com xxxxxxxxxxxxxx North Brunswick, New Jersey 08902 United States *** I hope that you will do what you can do to warn your community about Lisa Ostella! Sincerely, James Sundquist Director Rock Salt Publishing http://rock-to-salt.cephasministry.com/

89.

Sundquist, through Rock Salt, is known to make terrorist threats through the internet against individuals in order to intimidate them and scare them on behalf of others when the individuals do not agree in their cause and/or stand up for themselves.

90.

Sundquist, through his Company Rock Salt, Taitz and Defend our Freedoms Foundation, Inc., have placed Ostella in fear for her children and family. Moreover, Sundquist, through his company Rock Salt, Taitz and Defend our Freedoms Foundation, Inc., have caused Ostella and her family to be harassed and have placed

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their lives in danger.

Ostella and her family have been repeatedly harassed by

individuals on behalf of Taitz, Defendant our Freedoms, Sundquist and Rock Salt. 91. Sundquiest, Rock Salt, Taitz and Defend our Freedoms Foundation, Inc. are well aware Ostella has never “hacked” anything and their reports are all falsified. They are well aware Taitz and Defend our Freedoms Foundation, Inc. have never been hacked. Instead, it is Taitz and her associations on her behalf who have installed JS Kit software which is a “hacking” and “tracking” software on Taitz’s Defend our Freedoms Foundation, Inc. in order to “track” and “hack” individuals and their computers who have visited Taitz and Defend our Freedoms, Inc. websites and blogs.

VII.

FACTUAL ALLEGATIONS RELATING TO LINDA SUE BELCHER a/k/a LINDA S. BELCHER a/k/a LINDA STARR a/k/a NEWWOMENSPARTY a/k/a STITCHENWITCH a/k/a EVA BRAUN a/k/a WEB SERGEANT a/k/a KATY a/k/a WWW.OBAMACITIZENSHIPDEBATE.

92.

Plaintiffs incorporate by reference all of the foregoing allegations as if set forth herein at length.

93.

Defendant, Linda contacted Berg in or about August 2008 regarding the questions into Barack H. Obama’s citizenship status. Berg and his staff investigated the Mr. Obama’s citizenship and found there were genuine questions as to his Constitutional qualifications to run for and serve as President of the United States.

94.

Due to some unauthorized credit card charges by Geoff Staples, double billing and failure to maintain Berg’s website, in or about November 2008, Berg fired Geoff Staples as webmaster and hired another third party, Gail Fry, to take over the website. Due to the expense involved, Linda was allowed to be a moderator.

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95.

In or about the end of January 2009, Linda began causing the webmasters and administrators problems with Berg’s website. Linda was warned to calm down

numerous times, however failed to comply. Linda felt she was in charge of Berg’s website and sent e-mails to the website moderators deterring anyone from contacting Berg, Berg’s assistant or the webmaster. Linda even stated she was in charge. As a result, Linda’s moderator status was removed. However, she was still capable of posting on the blogs at obamacrimes.com. 96. In or about early February 2009, Berg on behalf of Adams had all the Defendants herein served with a cease and desist in attempts to stop the Defendants from their illegal and dangerous behaviors against and towards Adams. 97. Linda began posting on Berg’s blog that individuals who were assisting with Berg’s website were hacking Berg’s website. Linda even posted on the blog a third party blog called Politijab had hacked Berg’s site. All of this was unfounded and untrue. 98. In or about the end of February 2009, Linda called Berg’s assistant and asked her to attend a conference call. Berg’s assistant, Lisa, told Linda she was not available to call Berg. Linda called Berg and called Lisa back excited that Berg had agreed. During the conference call, Berg gave out his e-mail address and told folks with questions they could e-mail him. Berg hung up the call. One individual mentioned he had some important material to send to Berg, Linda immediately stated “send the e-mail to me at newwomensparty@aol.com and I will make sure Berg gets it. Linda told the caller not to send it to Berg’s e-mail address.” Berg never received the email.

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99.

On or about March 4, 2009, Linda began calling all the webmasters, moderators and past volunteers of Berg’s website telling them that Lisa, Berg’s assistant was a liar, she was deleting Berg’s e-mails and phone messages, no one could reach Berg and slandering Berg’s assistant, she was hostile with some and harassing others. Berg and his staff received numerous complaints regarding Linda’s unacceptable behaviors. Berg’s assistant stated she would quit, as the false rumors of Linda’s were not helping the cause. Berg cut all ties with Linda at that time.

100.

On or about March 6, 2009, Linda continued her unacceptable behaviors,

badmouthing Lisa, Berg’s Assistant, badmouthing and slandering Berg, harassing people from Berg’s blog, etc. Linda made derogatory remarks about Berg and Berg’s assistant, Lisa, on Berg’s website blog. Linda’s last post was:
Re: Weekly Discussion Topics 03/01/09 - 03/07/09

by Linda Starr on Today, 23:23 I am done with all the lies, false accusations, trashing and vicious crap that has been done to me since January by certain people around here. They tell me my services are no longer needed and I am not welcome here. I spent all these months doing nothing but working my butt off for Phil and this cause and I'm out. No explanations except for more lies told about me...and Phil won't even talk to me after over a 10 year friendship!! How's that one? Lisa wants the trolls to take over and everyone knows Phil jumps to her tune, or so she tells it. 101. As a result, Linda was completely banned. Before being banned, Linda took After being banned, Linda sent the

Berg’s blog database of e-mail addresses.

following e-mail out via her newwomensparty@aol.com e-mail address as a mass mailing on several different dates to hundreds of people including Berg’s Expert Witnesses, Berg’s supporters, attorney’s Berg works with on other cases, Berg’s

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contributors, Defendants Orly Taitz, Mr. & Mrs. Hale, etc. only a few are attached for this Honorable Court’s review: Original Message ----From: Newwomensparty@aol.com To: newwomensparty@yahoogroups.com Sent: Saturday, March 07, 2009 1:26 AM Subject: I am sorry to tell you all... but my affiliation with Obamacrimes.com and Phil J Berg has come to a unhappy parting of the ways. I cannot abide the lies, false accusations and trashing of me when I discovered some less than honest dealings were going on. One lie after another has been told to me and about me! I have given this cause and Phil everything in my being since last July, when my research really began in June. Maybe in a few days I will be able to talk about it, but my stomach is churning tonight and I am heartbroken at the betrayal of me after a 10 + year friendship was ended tonight, where Phil was not even willing to listen to me or even tell me what it is I am supposed to have done, this time. I will try to make a more complete statement in a day or two. I am certain that Barry Soetoro is not a US citizen, but we need people with more integrity to pursue this cause.

_|Çwt fàtÜÜ jÉÅxÇá YÉâÇwxÜ?axã jÉÅxÇá ctÜàç
Feminism: (noun) the radical notion that women are people. Well behaved women seldom make history!

--- On Sat, 3/7/09, Newwomensparty@aol.com <Newwomensparty@aol.com> wrote:

From: Newwomensparty@aol.com <Newwomensparty@aol.com> Subject: Re: Fw: I am sorry to tell you all...

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She didn't like it that I could reach Phil and she wanted to shut off that line of communication. I got him on your call and she didn't like that at all. And the fact that I defied her and did it anyway ticked her off a lot. She wants all the attention I am guessing. I found out things about her that were just awful from Kat who quit 3 days ago. She wouldn't say what she found, she told me to do a search for "Lisa Liberi" maiden name of Richardson out of NM formerly of San Bernadino, CA An honest person doesn't stand a chance against a lying charlatan.

_|Çwt fàtÜÜ YÉâÇwxÜ?axã jÉÅxÇá ctÜàç
Feminism: (noun) the radical notion that women are people. Well behaved women seldom make history!
--- On Sat, 3/7/09, Newwomensparty@aol.com <Newwomensparty@aol.com> wrote: From: Newwomensparty@aol.com <Newwomensparty@aol.com> Subject: Re: Fw: I am sorry to tell you all... No one can reach him. she controls all his e-mail and all his phone messages. she deletes what she doesn't want him to see or hear.

_|Çwt fàtÜÜ YÉâÇwxÜ?axã jÉÅxÇá ctÜàç
Feminism: (noun) the radical notion that women are people. Well behaved women seldom make history!
Newwomensparty@aol.com <Newwomensparty@aol.com> wrote: From: Newwomensparty@aol.com <Newwomensparty@aol.com> Subject: Re: Fw: I am sorry to tell you all... I shouldn't tell you what Kat found out about her and told me to search for today. It is shocking, but there is a problem with MY credibility? This explains why she doesn't become
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a licensed attorney in her own right. Convicted felons can't. Do NOT let either Phil or Lisa know I told you about this. No telling what that nut would do to me or my family. Mortgage Fraud Blog - New Mexico Woman Sentenced in Identity Theft and Real Estate Fraud Thursday, April 10, 2008 New Mexico Woman Sentenced in Identity Theft and Real Estate Fraud Lisa Liberi, aka Lisa Richardson, 42, New Mexico, was sentenced in connection with felony charges involving identity theft and forged documents. Liberi appeared in San Bernardino County, Rancho Cucamonga, Superior Court, on March 21, 2008. She was sentenced to a state prison term of 8 years, imposed but stayed, and placed on supervised probation for 3 years as part of a plea agreement. Liberi was sentenced on ten felony counts ranging from Grand Theft, Forgery, and Filing False Documents. From 2000 to 2004, Liberi engaged in a complex fraud involving falsification of police reports, manipulation of credit bureau reports, loan fraud, and counterfeiting of court documents resulting in hundreds of thousands of dollars in losses to banks and credit unions. In 2002, San Bernardino County Sheriff’s Department personnel arrested Liberi on theft by false pretense charges. In July 2004, Investigators from the San Bernardino County District Attorney’s Real Estate Fraud Unit arrested Liberi at the Ontario International Airport for additional felony charges while she was out on bail. mortgage fraud

_|Çwt fàtÜÜ YÉâÇwxÜ?axã jÉÅxÇá ctÜàç
Feminism: (noun) the radical notion that women are people. Well behaved women seldom make history!

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From: Newwomensparty@aol.com <Newwomensparty@aol.com> Subject: New site www.ObamaCitizenshipDebate.com To: newwomensparty@yahoogroups.com Date: Wednesday, March 18, 2009, 6:45 PM As you've probably noticed, there have been changes to the OC Board discussions lately. Everything from additional Agents, to subtraction of Agents and members, to Obots being allowed back to the board and to be placed into positions of trust as Moderators/Agents. A lot has been going on behind the scenes, as well as on the OC board itself. I'm sure you're not happy with what's going on. We aren't, either. It's counter productive to having discussions, when you're busy rehashing 6 month-old arguments with people who are purposely derailing every discussion. So a group of us got together, including former Moderators/Agents, and decided it was time to do our own thing. We've decided to create our own board. It will be an atmosphere that is Obot-FREE. Our core group want nothing more than Justice for the usurper in our Office. We can have flowing discussion, like we had before the changes at OC. Also, there may be some pleasant surprises in store, on the new board. Surprises that will definitely be a HUGE benefit for this cause. We aren't limiting ourselves to discussions of any one attorney or effort. We want to raise public awareness of all the efforts to expose the truth and remove the Usurper from office. We'd like to have you join us at our new site, if you are interested in truth and justice. Please invite others to join, but only invite those who you're SURE are with US, not THEM. This will ensure progress in our daily discussions. We are implementing a screening process to insure only like minded individuals are accepted into our ranks. Welcome to our friends. Thanks. The Administration Team at ObamaCitizenshipDebate

_|Çwt fàtÜÜ YÉâÇwxÜ?axã jÉÅxÇá ctÜàç
Feminism: (noun) the radical notion that women are people. Well behaved women seldom make history!
to Lisa Liberi <lisaliberi@gmail.com> date Mar 20, 2009 9:48 PM subject ... mailed-by Lisa, below is the e-mail Linda sent to Amboy Duke, the guy she thinks is Ted Nudgent. Amboy Duke is not Ted Nugent but someone from another
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blog. Thank you for responding. I am glad to hear from you again. I was beginning to think you got frustrated and quit. I have a new effort and site that is very exciting to a lot of people who are following me, having gotten disgusted with Phil. We just got the new site up and plan to raise public awareness for all the cases. This way I have not publicly gone against Phil, whose efforts I truly do not want to harm, or diminish his chances to win any of his cases. He deserves credit for all his hard work when he was the only one willing to take action and the first to file suit. He has worked tirelessly, but unfortunately, he won't win because there is a serious problem with Lisa and Barry's people are going to hurl it out in the court and that'll be it for all the cases. Berg supporters know something very bad happened to make me leave (which it did), but I do not intend to make it a public issue. Many of them did and a lot of people left and convinced me to do my own campaign and are following me now. It's because I was accused of terrible things by Lisa that are simply not true and I defended myself, but only with a handful of people. Phil believed her and I was forced out. Then he wrote me another nasty e-mail basically trying to intimidate me into silence about Lisa, which wasn't necessary because I wasn't the one who exposed her issues as I was accused of doing. I didn't even know it, but she has some major credibility problems that I don't want to get into. We believe our time is better spent raising public awareness for the efforts of everyone. Phil shouldn't be slamming Orly Taitz just because she's making a lot of noise and getting a lot of attention. I told him not to be slamming her, but now that I'm forced out, he is listening to Lisa. It looks like sour grapes. My role was both cheerleader and attack dog since I could do that as a volunteer. Lisa has allowed trolls to take over and even become moderators. I don't know if she's getting blackmailed by them or what, but it's a very toxic environment and people just don't want to be there, and that includes financial supporters who wonder now how their donations have been spent. It got so bad that you saw the results when you kept asking questions. And it's was never that way before. Posters welcomed the chance to answer questions. My site will be like that and we will have a section that isn't up yet, to list the facts and answer most of the pertinent questions. You will be able to go to one place and get answers without having to sort through 1000's of blogger posts.

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I used to be a guest on a lot of radio shows talking about my findings exposing various scandals and crimes. I am going to start doing that again to reach a larger audience. Me and the others who came with me to start this new effort feel that if we can raise the public awareness to a level that 100 million people are demanding Barry produce the proof, or that the DOJ arrest and remove him to prosecute for all his many crimes in illegally usurping office as POTUS. My efforts will not conflict with Phil's, but I feel compelled to say, please don't get involved with him. I no longer trust Phil or his Judgment after he was willing to listen to outright lies about me made by Lisa. You don't throw someone under the bus after being friends for more than 10 years, especially not your main cheerleader who fires people up to support the cause. Like I said before, this is no catfight. It's a major integrity issue. Lisa is a pathological liar and it really pains me to say that, but it's true. I can't, in good conscience, possibly recommend you get involved with Phil after what I learned. I don't want to say more in writing. In answer to your second e-mail, no one contacted me on your behalf. And if someone does, I will answer their questions in detail. I have enough knowledge to do that and speak coherently on the subject. In fact, I have been doing that all along except for a few legal questions. Now I know the answers so we don't necessarily need anyone else to answer. I am raising funds to wage a media campaign to raise public awareness, buying media ads and such. And if you decide to help us, you will know exactly what we are doing. My site is moving to another server today that is a better place for our bloggers and security. My site is going to be bigger than Phil's because a lot of the supporters who had another favorite and scattered when their efforts failed, will join me and we'll support them ALL. I look forward to speaking to you or someone on your behalf soon.

_|Çwt fàtÜÜ YÉâÇwxÜ?axã YÉâÇwxÜ?axã jÉÅxÇá ctÜàç
Feminism: (noun) the radical notion that women are people. Well behaved women seldom make history!

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102.

On March 7, 2009, Linda called the office and left a message for Berg stating

“Lisa is sending vial things out about me, she is bad mouthing me, she is deleting my e-mail to you and she sent me e-mails admitting it.” Knowing the entire time these were all lies and fabricated stories. 103. Linda called Berg and told him his Liberi had a criminal record and was stealing

Twelve Thousand [$12,000.00] Dollars per month from Berg’s PayPal account and was sending “vial” things around the internet about Linda. Linda went on further stating Liberi had a criminal record going all the way back to the 1990’s, all of which Linda knew was false. Berg told Linda to send him an e-mail with all these e-mails attached. Berg then called Liberi and asked for the same thing. Liberi sent Berg thirty-seven [37] pages. Linda sent nothing. 104. As time went on, Berg sent e-mails to Linda asking for her list. Berg finally

received another nasty e-mail about Lisa stating Lisa didn’t like what Linda had sent on Thursday so Lisa deleted it. Berg asked Linda numerous times to resend the “supposed” e-mail, Berg never received anything. Instead, Linda blocked Berg’s email address. 105. Linda sent the same accusations outlined above via e-mail to a private

investigator named Neil Sankey with The Sankey Firm and Sankey Investigations, Inc. Instead of investigating the information Sankey e-mailed the information along with Liberi’s Social Security number, date of birth and where she lived to a Reporter at World Net Daily and to Orly Taitz. [see above under “Factual Allegations

pertaining to Orly Taitz, et al” and Factual Allegations pertaining to Sankey, et al.”] 106. Linda’s behaviors continued and she then began contacting moderators on Berg’s

website blog. Linda was attempting to lure all of Berg’s moderators over to her new

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website.

Linda was also attempting to steal Berg’s supporters.

It was later

discovered Linda was in fact the individual with an extensive criminal record dating back to 1992 through 2007 for Theft, Fraud, and Fraud by Check, etc., according to the Texas Department of Public Safety and according to a criminal background check run on her by her Social Security number.

VIII. FACTUAL ALLEGATIONS RELATING TO EDGAR (ED) HALE, CAREN HALE, PLAINS RADIO NETWORK a/ka/ PLAINS RADIO NETWORK, INC. a/k/a PLAINS RADIO, a/k/a BAR H FARMS and KPRN AM 1610 107. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth

herein at length. 108. Defendants, Mr. and Mrs. Hale began operating a radio program, Plains Radio,

through a tower, which they own, KPRN. The Radio show is an internet radio show that is broadcast through different stations. Plains Radio also has a website and chat room located at plainsradio.com. that Mr. and Mrs. Hale worked. 109. In or about June 2008, Mr. and Mrs. Hale contacted Evelyn Adams and requested

she co-host their radio shows on Plains Radio Network, an internet radio show. Mrs. Adams quit and left Plaintiff’s radio show on or about August 21, 2008. Defendants Hale banned Mrs. Adams computer IP address from his website located at http://www.plainsradio.com, thus Adams could not access his website at all as she was permanently banned. 110. Shortly thereafter, Adams began hosting another show, Momma E Radio Rebels

and co-hosted shows on Monks Media. Once Adams began with her own show, Defendants Mr. & Mrs. Hale began slandering Adams name on their radio show,

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Plains Radio through their Tower, KPRN, on their chat room site at http://www.plainsradio.com and by mass mailings of e-mails from Bar H. 111. The Defendants Hale behaviors intensified. Mr. Hale through Bar H Farms sent

the following e-mail to one of Adams website moderators on her website located at http://countryfirst.bravehost.com regarding Adams website: “From: "Ed Hale" barhfarms@gmail.com Date: 8/26/2008 12:31:35 AM To: "jeff justjeff" greybeard411@yahoo.com” “I hope you don't need much sleep cause your forum is going to be atacked 24 hours a day. I was just sent a e-mail telling me that. Hope you and Momma E have a great timewith your new forum and radio show. It will not last 2 weeks from what I have been told. so have a great day. Enjoy your backstabbing while you can. Ed” 112. On August 21, 2008 Berg filed the first lawsuit against Barry Soetoro a/k/a

Barack H. Obama. At this time, Linda referred Berg to her friend, Geoffrey Staples to set up and maintain a website for the lawsuit.15 113. During this same time, Mr. & Mrs. Hale requested the appearance of Philip J.

Berg on their radio show, Plains Radio through their tower KPRN. Berg was the first attorney who field suit against Barry Soetoro a/k/a Barack Hussein Obama regarding his citizenship issues. Berg agreed to appear several times. 114. Berg’s office than received calls regarding donations that Mr. Hale was seeking

on behalf of Berg. The callers were concerned and wanted verification that Mr. Hale was in fact authorized to seek donations on behalf of Berg. The callers were notified that Mr. Hale was never authorized by Berg or his law firm to accept donations on his behalf.

15

Geoffrey Staples created the website for Berg www.obamacrimes.com

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115.

When Berg would no longer attend Mr. Hale’s shows and refused

communications with him, Mr. and Mrs. Hale became extremely angry. Mr. and Mrs. Hale through Plains Radio, KPRN began making horrible slanderous statements against Plaintiffs, Adams and Berg. 116. Defendants’ behaviors continued and Adams continued receiving nasty e-mails

from Mr. Hale at Bar H Farms. Although, Plaintiffs have a stack of the abusive, threatening and nasty e-mails, only a few are posted herein for this Honorable Court’s review:
-------Original Message-------

“From: Ed Hale Date: 1/1/2009 5:47:42 PM To: Evelyn/MommaE Subject: why” “Why in the hell are you stealing my host and telling lyes about me. I am about to come down on you like stink on shit. This is bullslhit. I will have attorney on your butt tomorrow. You have gone to far this time old lady. You have nothing but a pissant radio show and maybe a 25 listener if your lucky. You say the same old shit day after day. No good guest will come on your show. You get lairs like Sammy from API and that crook Phil Berg on your show. Then you beg for money for them and get people to give to something that an't worth a damn. I will see you in court. Ed”

-------Original Message------“From: Ed Hale Date: 1/4/2009 1:35:08 AM To: Evelyn/MommaE Subject: yoru in for it now” “hey bitch: I can prove that those document you have on your web site that you and berg have had for month is not true. They are my document and you remove plains radio off o them. I am going trash you and Berg Monday night on my show. Your nothing but a fucking crook bitch and now I got you. I put secret codes in those document and that code is in your. You such a low life fucking good for nothing bitch. I am going to sue you fucking whore. those document were copyright protected and now I have you and you son of bitches. Ed”
-------Original Message-------

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From: xxxxx (name removed for protection) Date: 1/3/2009 5:57:05 PM To: mammaE Subject: Ed Hale mouthing attachment:16

117.

Mr. and Mrs. Hale on their radio programs on Plains Radio through their tower,

KPRN, stated Berg was a crook, he was conning and scamming people. Mr. Hale was cussing Berg, calling him a shyster and falsely claiming Berg had lied that he in fact had the Kenyan Birth Certificate of Barack H. Obama because he (Mr. Hale) had obtained it for him, that Berg’s law license was going to be taken away, etc., all the time knowing these statements were false. Mr. and Mrs. Hale and others on their behalf also sent out this false information across the internet and through mass mailings from Bar H. 118. At the same time Mr. and Mrs. Hale through their radio program, Plains Radio

and their tower, KPRN, began calling Adams heinous names including but not limited to “Bitch,” “Whore,” “Worthless Piece of Shit,” “a Fraud,” “a Liar,” a “Thief,” etc. These remarks were broadcast through KPRN AM 1610 in Wellington, Texas, through talkstreamlive.com, posted on Hale’s internet website blogs and sent out by Hale’s via the internet by mass mailing through Bar H. 119. Mr. and Mrs. Hale used their radio show, Plains Radio, through

talkstreamlive.com, the internet, and KPRN AM 1610 encouraging many individuals to call into Adams radio shows and tell Adams how stupid she was and what a liar she was. Mr. & Mrs. Hale gave out Mrs. Adams Radio show internet website. Mr. & Mrs. Hale went further and encouraged individuals to obtain the call in number from

16

This chat was taken from Defendants, Mr. and Mrs. Hale and Plains Radio website at plainsradio.com at which time was an open public area and is about Plaintiff, Philip J. Berg, Esquire 48

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Adams radio show so they are able to call into the show and harass Adams, which they did. 120. Mr. and Mrs. Hale through Plains Radio and KPRN had listeners and staffs

publish Mrs. Adams home address and telephone number on the internet, which resulted in Mrs. Adams receiving threatening, harassing and degrading phone calls at all hours of the day and night stating Mrs. Adams “should stop trashing Ed Hale and leave Ed Hale alone.” Defendants, Mr. and Mrs. Hale were well aware Adams has never harassed or trashed them. 121. Mr. and Mrs. Hale have repeatedly used their radio show through

talkstreamlive.com, the internet, and KPRN AM 1610 giving false statements regarding Mrs. Adams which includes but is not limited to her radio shows; falsely accusing Adams of “trashing” them; falsely accusing Adams of stealing written documents, being the “Obama” divorce papers; falsely accusing Adams of defrauding the State of California for her disability, etc. 122. Mr. and Mrs. Hale have used their radio show through talkstreamlive.com, the

internet, and KPRN AM 1610, to post on their internet website blog and sent mass emailings from Bar H falsely accusing Adams of “stealing” their “Obama” divorce records. Mr. and Mrs. Hale falsely claim they have their copy of the “Obama” divorce papers copyrighted when in fact Adams had possession of the said records prior to Mr. and Mrs. Hale’s receipt of said divorce papers, which they were well aware of. 123. Mr. and Mrs. Hale have used their radio show through talkstreamlive.com, the

internet, and KPRN AM 1610, to advise they have posted on their internet website blog and sent mass e-mailings through Bar H falsely accusing Adams of having a

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criminal record; and falsely claiming Adams has a history of lying and stealing. Mr. and Mrs. Hale also falsely claimed that Adams hides who she is on her radio shows; Mr. Hale even went as far as making the open threat, “your day is coming you piece of shit,” referring to Adams. In furtherance of this, Mr. Hale attached an unknown and unidentified printout of a woman by the name of Evelyn A. Adams with a date of birth of November 9, 1937, whom he was aware, was a completely different person. 124. Unfortunately, this did not stop the Defendants Hale. Once the Defendants were

served with the Cease and Desist, which was on February 2, 2009, Mr. and Mrs. Hale immediately, just to name a few, posted on their radio show webpage at plainsradio.com and on their radio program, Plains Radio through KPRN the following: Ed Hale IP: 75.91.201.231 Feb 2, 09 - 3:33 PM “Phil Berg is going to sue me” “Phil Berg has send us a letter stating that if we do not0 retract everything that we said about him, he will sue us. Ok Mr Berg, I retact all the lies I said about you. Hope this makes you happy and now I will continue to tell the truth about you. In my opinion, you have not won any case in court because you don't have any evidence to back up what your case is about. You just grab something out of the air and try to make it look good so people will donate more money to you. I was on your web site the other day and you were asking people to donate $50 or get 5 of their friend to donate $10 each. Mr. Berg, we raised $10,000 for Steve Pidgeon and he still has money to use. How many $1000's have you received and what did you do with that money? Have you published a report about where you spent their money? Why will you not tell the people who donate to you what is going on with your cases? Why did you send Oprah a letter? Was this a way to raise more money? The courts has turned down you cases as fast as you file them. Wonder why that is so Mr Berg? Mr. Berg, I will give you the entire 4 hours this Friday night to come on my show and answer these question and others. The problem is you will not do it because you know I will ask the hard question. This is your chance to set the record straight. You will have 1000's of people listening and here is your chance to make your case to them, teh American people. If you think
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I have not told the truth aobut you, then come on the air and prove me wrong. Now Mr. Berg, you have the ball, what are you going to do with it? I will bet anyone a $100 to a dollar you will not show up. Ed Hale”17

Ed Hale IP: 75.91.201.231 Feb 2, 09 – 8:04 PM “I jsut recieved a copy of the letter” “Yes it appears that Mr Berg is now licenced in the state of Oklahoma also. He is going to sue me for Momma E. Momma E does not like beign told that she is a lair and a thief. All she has to do is prove that she has a set of the orginal 1964 Obama divorce documents and I will retract all of it. I can tell you this much we will find out who is laying about this. Anyway stay tune it is going to get jucier.”18 “Re: Ed Hale "Phil Berg is Going to Sue Me" “She's 72 years old...alright... That picture she's got up there makes her look like a beautiful young chick...I got news for you. She's fat, ugly, grey-headed, and she has to use a walker to get around. And, you know something? She's gonna be meetin' her maker real soon. I'm tellin' you that. [sound effect of some kind of gun being cocked and shot.] Bitch! Ed Hale.”19 125. In or about March 2009 Mr. and Mrs. Hale through Plains Radio filed a false

lawsuit against Adams. To further perpetrate their fraud and for further harassment, Mr. and Mrs. Hale and Plains Radio did not have Adams served correctly and only served her with the Collingsworth County Small Claims Citation. 126. As a result, Adams had to hire Berg to respond to the Defendants frivolous small

claims lawsuit. Liberi from Berg’s Office called the Collingsworth County Small Claims Court and informed them Adams was not served with any type of Complaint.

17

This was posted on February 2, 2009 at 3:33 p.m. on Defendants website, plainsradio.com blog forum at http://pub29.bravenet.com/forum/2442810129/show/972859 - Page URL2/2/2009ate 18 Posted February 2, 2009 at 8:04 a.m. at Plains Radio Network, Inc. at http://pub29.bravenet.com/forum/2442810129#bn-forum-1-1-2442810129/8. Plaintiffs’ counsel maintains a copy of this posting. Posted on the internet February 2, 2009 at 9:06 p.m. Mr. Hale also stated this on his radio program; Plaintiffs counsel has a copy of the audio file. I:\FORMS\Liberi, Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages 51
19

The Justice read the Complaint on file and stated Mr. and Mrs. Hale through Plains Radio claimed Adams stole their copyrighted “Obama” Divorce papers. Berg

responded to the Defendants frivolous lawsuit, supplied the Collingsworth County Court with copies of the “Obama” divorce papers which were given to Adams. 127. Liberi, assistant to Philip J. Berg, Esquire, sent Ms. Adams a copy of the Obama

v. Obama, Hawaii D. No. 57972, Divorce Decree in the early morning of January 2, 2009, which Berg’s Law Firm received from their Hawaiian Private Investigator via e-mail and Federal Express. 128. Adams posted said divorce papers on her website, Country First, on January 2,

2009 at approximately 4:37 p.m. Eastern Standard Time, 3:37 Central Standard Time. 129. Ed Hale, owner and operator of Plains Radio Network, obviously obtained copies

of the same Obama v. Obama divorce decree from Hawaii. However, Mr. Hale through Plains Radio Network did not receive the said divorce decree until January 2, 2009 at approximately 2:25 p.m. Central Standard Time and did not post said divorce papers until approximately 8:00 p.m. Central Standard Time, by his own admission. 130. Mr. and Mrs. Hale were very unhappy with the fact Berg responded on behalf of

Adams to his frivolous lawsuit. Mr. and Mrs. Hale then prepared a letter, which they claimed they sent to the Justice of the Peace of Collingsworth County stating it is a fact Berg and Adams conspired to raise money for Berg; it is a fact that Berg is not licensed to practice law within the state of Texas; Liberi’s e-mail sent to Adams with the “Obama” divorce papers was a forgery; Liberi’s e-mail was doctored; Berg and Adams have partnered together and has collected thousands of dollars from people based on lawsuits that had no chance of success; Berg has been proven to be a shyster; Berg is under investigation by several Federal agencies; Berg and Adams

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have conned thousands of Americans out of hundreds of thousands of dollars, etc. This very letter was never sent to Judge Henard, Justice of the

Peace of the Collingsworth County Court, Precinct One, Number One, instead Mr. and Mrs. Hale posted it on their radio show website, plainsradio.com and sent it out in mass e-mailing from Bar H which was nothing more than further slander and libel. 131. Mr. Hale continued his above behaviors and began sending harassing e-mails to

Liberi. In one of his e-mails, Mr. Hale went as far and threatened Liberi and Berg stating, “You and berg are going to regreat getting into this” [sic]20. 132. Mr. and Mrs. Hale then went onto their website, plainsradio.com through Plains

Radio and posted a statement in their open forum stating the following: “Berg and Adams is under investigation !!!!” “I have been informed that Phil Berg and Evelyn Adams are under investigation by the Federal Trade Commission and the FBI for conning thousands of Americans out hundred of thousand of dollars. Adams used her radio show to promote Berg lawsuits and asked for and received money. These lawsuit were all dismissed. According to my source, Berg had declared bankruptcy in July. He use this money to pay his personal debts. The money was never used to fund the lawsuits as was promoted by Adams and Berg. Berg has used thousands of dollar for his nightclub drinking binge, throwing money around like a big shot. I have been told to expect Berg to be arrested within a the next few days or weeks as the case is nearing a end. Adams is also going to be charged under the Ricco act as they conspired to defraud the American people out of hundreds of thousand of dollars. This could not happen to 2 more deserving people.”21 133. The above post was placed on an open forum for the internet world to see. This

posting was also carried over to another website, unassociated with the Defendants at

E-mail sent from Defendant Edgar (Ed Hale) on April 1, 2009 at 10:42 a.m. from ed@barhfarms.net to Berg’s assistant at LisaLiberi@gmail.com
21

20

Posted March 31, 2009 at 2:58 a.m. at Plains Radio Network, Inc. at http://pub29.bravenet.com/forum/2442810129#bn-forum-1-1-2442810129/8. Plaintiffs’ counsel maintains a copy of this posting. I:\FORMS\Liberi, Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages 53

http://politijab.com/phpBB3/index.php. maliciously by Mr. Hale. 134.

None of which is true and was done

On April 14, 2009, Plaintiffs receive a copy of a mass e-mailing and a falsified

statement, sent out by the Defendants Hale and posted on the Defendants Hale websites further slandering Liberi. The e-mails and postings, just to name a few, stated: Date: Apr 14, 2009 7:32 AM Subject: Seen Ed Hale's Latest vs YOU To: lisaliberi@gmail.com Hi Lisa............seen this from Ed Hale's page: Dr Orly has been scamed by Lisa Liberia (Phil Berg assistant) It appears that Lisa Liberi, who works for Phil Berg has been stealing from Dr Orly. Tonight, 2 of our listeners have came forward with recipet from paypay where they thought that they were donating to Dr Orly and instead it went to this Lisa Liberi. At this point, we do not know if Phil Berg is involued, but as my mother has stated "birds of a feather flock together". These are e-mails that I received from Dr Orly. As I have said many times, Phil Berg was in this for nothing but money and also those who helped him also. I can assure you that we have proof that Lisa Liberi did in fact take money that was to go to Dr Orly. That whole bunch that has accused me of stealing is now actually proved that they themselves are thieves Postings on Plains Radio:
http://pub29.bravenet.com/forum/2442810129#bn-forum-1-1-2442810129/8/1007326/show

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Ed Hale

Apr 13, 2009 - 11:46PM

QuoteReply Dr Orly has been scamed by Lisa Liberia (Phil Berg assistant) It appears that Lisa Liberi, who works for Phil Berg has been stealing from Dr Orly. Tonight, 2 of our listeners have came forward with recipet from paypay where they thought that they were donating to Dr Orly and instead it went to this Lisa Liberi. At this point, we do not know if Phil Berg is involued, but as my mother has stated "birds of a feather flock together". These are e-mails that I recieved from Dr Orly. As I have said many times, Phil Berg was in this for nothing but money and also those who helped him also. I can assure you that we have proof that Lisa Liberi did in fact take money that was to go to Dr Orly. That whole bunch that has accused me of stealing is now actually proved that they themselves are thieves.

From: Orly Taitz Subject: Ceize and Desist, demand to file a joint FBI complaint To: "Phil J Berg Esq (pvt)" Cc: "Orly Taitz" Date: Sunday, April 12, 2009, 10:01 AM

04.12.09. Mr. Phillip Berg, this is to inform you that a few days ago I have forwarded my quo warranto pleadings to Mr. John Hemenway, since he agreed to be my local co-counsel in Washington DC. This was a confidential communication and Mr. Hemenway stated, that mistakenly he has forwarded those pleadings to you. Shortly thereafter you have sent a press release, stating that you will be filing Quo Warranto action. This is a Ceize and Desist letter, demanding that you do not use my pleadings and confidential information in any way, shape or form, as you received those in error without my authorization. Additionally, I received information from a licensed Private investigator, with 20 years of experience with Scotland Yard and 12 years of experience in US, that your paralegal Lisa Liberi has an extensive criminal record, involving fraud, forgery of documents and identity theft. See attached file. I also received information that her husband, who is currently on parole, is an owner of 2 of accounts, accepting credit cards on your charitable foundation web site. As an officer of the court I am obligated to forward this information to the authorities: FBI, Attorney General of California and San Bernardino County Distict Attorney, since Lisa Liberi had a 8 year conviction in San Bernardino County, California. I believe that you, as an officer of the court, as well and a former Assitant Attorney General of Pennsylvania, should join me in issuing a joint complaint and demand for investigation from the above listed authorities. Dr. Orly Taitz Esq 26302 La Paz ste 211 Mission Viejo Ca 92691

Lisa Ostella Defend Our Freedoms Foundation http://defendourfreedoms.org Peace through Strength http://www.barofintegrity.com > From: nsankey@thesankeyfirm.com > To: lisaostella@hotmail.com; dr_taitz@yahoo.com > Subject: FW: >>>>>>>>>>Urgent IMPORTANT INFO SAME SUBJECT<<<<< > Date: Mon, 16 Mar 2009 14:57:13 -0700 > > PLEASE NOTE THE LAST LINE! > > Thursday, April 10, 2008 New Mexico Woman Sentenced in Identity Theft and Real Estate Fraud > > > Lisa Liberi, aka Lisa Richardson, 42, New Mexico, was sentenced in > connection with felony charges involving identity theft and forged > documents. Liberi appeared in San Bernardino County, Rancho Cucamonga, > Superior Court, on March 21, 2008. She was sentenced to a state prison term > of 8 years, imposed but stayed, and placed on supervised probation for 3 > years as part of a plea agreement. Liberi was sentenced on ten felony > counts ranging from Grand Theft, Forgery, and Filing False Documents. > > From 2000 to 2004, Liberi engaged in a complex fraud involving falsification > of police reports, manipulation of credit bureau reports, loan fraud, and > counterfeiting of court documents resulting in hundreds of thousands of > dollars in losses to banks and credit unions. >

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> In 2002, San Bernardino County Sheriff's Department personnel arrested > Liberi on theft by false pretense charges. In July 2004, Investigators from > the San Bernardino County District Attorney's Real Estate Fraud Unit > arrested Liberi at the Ontario International Airport for additional felony > charges while she was out on bail. > > She has an extensive criminal record going back to the 90's. From: John D. Hemenway Subject: FW: Writ To: dr_taitz@yahoo.com Date: Sunday, April 12, 2009, 11:03 AM

April 12, 2009 Dear Orly, This would indicate that Lisa Liberi received your Writ. It is not specified and she does not say so and it could refer to the earlier Writ she said was written by a former inmate, but I do not think so. Best regards, JDH -------------------------------------------------------------------------------From: Lisa Liberi [mailto:lisaliberi@gmail.com] Sent: Friday, April 10, 2009 1:07 AM To: John D. Hemenway Subject: Writ John, There are many problems with this Writ of Quo Warranto. A Writ of Quo Warranto is used when a Government office has been usurped. Furthermore, you cannot go after a person as a Plaintiff using Federal Criminal Codes. You can mention them, however, you can't go after the individual unless you are a prosecutor. Lisa -Lisa Liberi Assistant to Philip J. Berg LAW OFFICES OF PHILIP J. BERG State: Texas

Ed Hale

QuoteReply Proof that noly is Lisa involued but more Hi folks: Look at this page from one of the web sites that Lisa has set up and see who is her partners in this. Get ready for a shock on the right hand side.

Apr 14, 2009 - 1:17AM

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State: Texas

TollandRCR

QuoteReply Re: Dr Orly has been scamed by Lisa Liberia (Phil Berg assistant) Before you go too far with this, you might want to listen to a recording of your interview with Orly Taitz. It is widely available on the Internet if you don't have a copy. In it, Orly seems to clearly state that she believes that the donations are going to Lisa Ostella, her former Webmaster. It is often difficult to understand her speech, so that might be the root of the problem. The donations being routed via Ostella might make some technical sense, depending upon how Orly set things up. Ostella was a volunteer for her and evidently has Web skills that Orly does not. Orly does not accuse Lisa Liberi (Berg's associate) of this. Your posting of this claim is widely replicated on the Web, so it is getting quite a bit of exposure. That may be the last thing that you want. You also might want to note that there are many Lisa Liberi's in the U.S. The one with the criminal history is almost certainly not Berg's associate.

Apr 14, 2009 - 10:06AM

Without commenting on Orly's charges against Lisa Ostella, I would note that it is likely that, with Orly's help, you have just gotten yourself into a real legal pickle. Beyond defamation, when did you start believing people who tell you that they have learned something from an anonymous source? It looks to me as if those few who are still questioning Obama's eligibility to serve as President are now engaged in a mutually destructive war. This was predictable, because this is always what happens with extremists, particularly those who are remarkably capable of denying reality. It's nice to see it happen. State: CT

Molly Pitcher

QuoteReply Re: Dr Orly has been scamed by Lisa Liberia (Phil Berg assistant) TolandRCR, I have plenty of proof about Obama's fraud. His forgered COLBs, his forged Selective Service Registration, his Intelligence appointees employee getting into Obama's passport records to alter them. We are not extremists as you say.. I don't know about the reported "theft" but I hope it is not true. State: ca

Apr 14, 2009 - 10:47AM

kukaniloko

QuoteReply

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Apr 14, 2009 - 12:42PM

Re: Dr Orly has been scamed by Lisa Liberia (Phil Berg assistant) Why is it no suprise that all the birfers are now fighting amoung themselves? It would be prudent at this juncture if you can all arrange a team building exercise - go Big Foot Hunting together or something. Maybe at your 10 year reunion, you all can make a field trip to the Obama Presidential Library. State: Denial Index

135.

As you can see from the above posts, Orly Taitz was accusing Lisa Ostella of

hacking and stealing from her PayPal account, not Berg’s assistant, Lisa Liberi. Mr. Hale aired the show where Taitz was accusing Lisa Ostella. However, as stated above, Mr. Hale threatened Berg and his assistant that they would regret getting involved in the matter regarding Adams. Mr. Hale’s statements above were

statements to damage Berg, his assistant and his law practice, knowing the entire time they were falsified statements. Mr. Hale obviously carried out his threat to Berg’s assistant. 136. On April 20, 2009, Mr. Hale had a radio show on at 9:00 p.m. Mr. Hale’s Guest

was Orly Taitz. Mr. Hale then went on falsely stating Lisa Ostella and Lisa Liberi were one and the same person and she was a criminal, knowing the information to be false. IX. 137. FACTUAL ALLEGATIONS RELATING TO ALL DEFENDANTS

Plaintiffs incorporate by reference all of the foregoing allegations as if set forth

herein at length. 138. Plaintiffs are in possession of the Plains radio shows with the above information

as well as copies of the postings on the internet placed by Defendants Taitz, Defend our Freedoms Foundation, Inc., Sankey, from the Sankey Firm and Sankey Investigations, Inc., James Sundquist, Rock Salt Publishing, Mr. & Mrs. Hale, Plains Radio, Bar H Farms and Linda and e-mails which were sent.

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139.

The illegal acts of Defendants’ Sankey through his investigation firms, the Sankey

Firm and Sankey Investigations, Inc., Taitz, Defend our Freedoms Foundation, Inc., and Yosef were all commenced under the laws of California and followed through against Liberi in the State of California. 140. Defendants are and have been well aware their statements about Liberi, Berg, the

Law offices of Philip J. Berg, Adams and Ostella are falsified. The Defendants will stop at nothing to destroy all Plaintiffs. Plaintiffs’ counsel is in possession of all the audio files of Taitz, Mr. and Mrs. Hale, Plains Radio, KPRN, and Bar H Farms and all radio shows they have done broadcastings further slandering the Plaintiffs. 141. Defendants’ disclosure, posting on the internet, emailing, etc. of Plaintiffs’

personal identifying information including but not limited to social security numbers, names, address, and date of birth Defendants actions also violated and were done in violation of State and Federal Laws, e.g. the Social Security Act; California Privacy Laws, Civil Code §1798 et sequitur; Identity Theft and Assumption Deterrence Act, 18 U.S.C. §1028(a)(7); Pennsylvania Privacy Acts (74 Pa. Stat. Ann. § 201 (West 2006); California Business and Professions Code 22577(a); the Electronic Communications Privacy Act, 18 U.S.C. §§2510-22, and the Stored Communications Act, 18 U.S.C. §§2701-11; Cyber harassment, Cyber stalking, etc. in violation of the Women’s Violence Act, Department of Justice Reauthorization Act of 2005, H.R. 3402, titled "Preventing Cyber stalking" and numbered as § 113, §113(a)(3) provides that Section 223(a)(1)(C) applies to "any device or software that can be used to originate telecommunications or other types of communications that are transmitted, in whole or in part, by the Internet; Cyber-stalking and Cyber-harassment laws in violation of the Communications Act, 47 U.S.C. § 223(a)(1)(C) and § 223(h)(1)(B).

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142.

Defendants DOES 1 through 200 are Defendants internet providers, phone

companies, e-mail providers, streamlines, etc. who have allowed Taitz, Defend our Freedoms Foundations, Inc., Neil Sankey with the Sankey Firm and Sankey Investigations, Inc., James Sundquist, Rock Salt Publishing, Plains Radio, Mr. and Mrs. Hale, Bar H Farms, and Linda to continue their illegal and dangerous behaviors against Plaintiffs. DOES 1-200 also represent all unknown unnamed Defendants. 143. For the above-mentioned reasons, Plaintiffs herein are seeking immediate

injunctive relief and damages for the injuries caused by the Defendants illegal behaviors. COUNT ONE VIOLATION OF THE FIRST AND FOURTEENTH AMENDMENT OF THE UNITED STATES CONSTITUION and ILLEGAL DISCLOSURE OF AN INDIVIDUAL’S SOCIAL SECURITY NUMBER AND PERSONAL IDENTIFYING INFORMATION (Liberi v. Taitz, Defend our Freedoms Foundation, Inc., Sankey, the Sankey Firm and Sankey Investigations, Inc.) 144. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth

herein at length. 145. Defendants Taitz, Defend our Freedoms Foundation, Inc., Sankey, the Sankey

Firm and Sankey Investigations, Inc., violated Liberi’s right to privacy, right of publicity, harassment, endangerment and publication of private facts. 146. Taitz had threatened to destroy Liberi and took every step to ensure she not only

destroyed Liberi but harmed and injured her in the process. 147. Taitz sought Liberi’s Social Security number and personal identifying information

without a permissible purpose from Sankey with the Sankey Firm and Sankey Investigations, Inc., information Taitz was not entitled too. Taitz had been spreading

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false criminal information about Liberi over the internet, on radio shows and through mass e-mailing all of which was done through her law firm. Taitz published Liberi’s Social Security number, date of birth, where she resided, false information about Liberi’s husband; false criminal information through mass e-mailing requesting everyone to post the information on their website. Taitz’s e-mails and postings went out to over Two Hundred and Fifty Thousand [250,000] people, all of which was done through her law firm (business) with malice. 148. Sankey through the Sankey Firm and Sankey Investigations, Inc. obtained

information from a third party. Without verifying said information and at the request of Taitz, Sankey through the Sankey Firm and Sankey Investigations, Inc. obtained Liberi’s Social Security number, without a permissible purpose. 149. Sankey through the Sankey Firm and Sankey Investigations, Inc. illegally e-

mailed Liberi’s Social Security number, date of birth, where she resided and description and e-mailed it to Taitz and a Reporter with World Net Daily. Sankey through the Sankey Firm and Sankey Investigations, Inc. was well aware the information would be posted on the internet and sent out by mass e-mailing. All of these actions were done through Sankey’s businesses and was done with malice to injure and harm Liberi. 150. Liberi had a confidential address as a result of her child and her being victims of

domestic violence. The publication of Liberi’s personal identifying information by Taitz, Defend our Freedoms Foundation, Inc., Sankey, the Sankey Firm and Sankey Investigations, Inc. made sure anyone with internet had access to Liberi’s Social Security number, date of birth and where she resided, further placing Liberi, her son and husband in further danger.

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151.

In so doing, Taitz, Sankey, the Sankey Firm and Sankey Investigations, Inc.

violated California Civil Code §1798.85 which states in pertinent part: “(a) Except as provided in this section, a person or entity may not do any of the following: (1) Publicly post or publicly display in any manner an

individual’s social security number. "Publicly post" or "publicly display" means to intentionally communicate or otherwise make available to the general public.” 152. If there had been a permissible purpose for Sankey through he Sankey Firm and

Sankey Investigation, Inc. to disclose Liberi’s confidential information including full name, date of birth and Social Security number, which there was not, Sankey through the Sankey Firm and Sankey Investigations, Inc. violated California Civil Code §1798.81.5 (c) by not ensuring Liberi’s private, personal and confidential information was not maintained pursuant to the privacy laws and not maliciously disseminated via the internet and mass e-mailing. California Civil Code § 1798.81.5(c) states in pertinent part:

“A business that discloses personal information…pursuant to a contract with a nonaffiliated third party shall require by contract that the third party implement and maintain reasonable security procedures and practices appropriate to the nature of the information, to protect the personal information from unauthorized access, destruction, use, modification, or disclosure.” 153. Taitz hired Neil Sankey, The Sankey Firm and Sankey Investigations, Inc. to

illegally obtain Liberi’s private and personal information, which Sankey through his investigation firms, the Sankey Firm and Sankey Investigations, Inc. did. Thus, they had a contract for work to be provided. 154. Taitz had a special “tracking” and “hacking” software on her websites and blogs

that attached a remote access on Liberi’s computer. Yosef assisted Taitz in entering
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Liberi’s computer, invading her privacy and taking documents which did not belong to them. 155. California Civil Code §1798.84 states in pertinent part (b) stats a party injured for

violation of this title injured by a violation of this title may institute a civil action to recover damages and…(c) dictates a civil penalty over and above actual damages and punitive damages for a willful, intentional, or reckless violation…may recover a civil penalty not to exceed three thousand dollars ($3,000) per violation…(e) Any business that violates, proposes to violate, or has violated this title may be enjoined…(f) A prevailing plaintiff in any action commenced shall also be entitled to recover his or her reasonable attorney's fees and costs…(g) The rights and remedies available under this section are cumulative to each other and to any other rights and remedies available under law. 156. Taitz Sankey, the Sankey Firm and Sankey Investigations, Inc. violated the

California privacy laws in excess One Hundred Forty-Four Thousand [140,000] times. 157. Defendants’ disclosure, posting on the internet, emailing, etc. of Plaintiffs’

personal identifying information including but not limited to social security numbers, names, address, and date of birth Defendants actions also violated and were done in violation of State and Federal Laws, e.g. the Social Security Act; California Privacy Laws, Civil Code §1798 et sequitur; Identity Theft and Assumption Deterrence Act, 18 U.S.C. §1028(a)(7); Pennsylvania Privacy Acts (74 Pa. Stat. Ann. § 201 (West 2006); California Business and Professions Code 22577(a); the Electronic Communications Privacy Act, 18 U.S.C. §§2510-22, and the Stored Communications Act, 18 U.S.C. §§2701-11; Cyber harassment, Cyber stalking, etc. in violation of the

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Women’s Violence Act, Department of Justice Reauthorization Act of 2005, H.R. 3402, titled "Preventing Cyber stalking" and numbered as § 113, §113(a)(3) provides that Section 223(a)(1)(C) applies to "any device or software that can be used to originate telecommunications or other types of communications that are transmitted, in whole or in part, by the Internet; Cyber-stalking and Cyber-harassment laws in violation of the Communications Act, 47 U.S.C. § 223(a)(1)(C) and § 223(h)(1)(B).

WHEREFORE Plaintiffs’ request: A. An immediate Order enjoining Defendants Taitz, Defend our Freedoms

Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc. and any party on their behalf from disseminating Liberi’s Social Security number, date of birth, name, where she lives, etc.; B. An immediate Order of retraction against Defendants Taitz, Defend our

Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc. and any party who has published Liberi’s confidential information on their behalves to immediately retract and remove Liberi’s private confidential information, including but not limited to her Social Security number, date of birth, where she resides, information about her husband, the false criminal accusations, etc; C. An immediate Order of retraction against Defendants’ Taitz, Defend our

Freedoms Foundation, Inc., Sundquist, Rock Salt Publishing, and anyone on their behalf from distributing Lisa Ostella’s personal and confidential information, including but not limited to her home address and telephone number; D. Enjoin Defendant Taitz, Defend our Freedoms, Inc., Yosef and any party

operating on their behalf from any further “hacking” of the Plaintiffs’ computers;

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E.

Enter Judgment against the Defendants, Taitz, Defend our Freedoms

Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., collectively, jointly and separately, for civil penalties in the amount of Four Hundred Thirty-Two Million [$432,000,000.00] Dollars separately per Defendant to be awarded to Liberi as civil penalties pursuant to the California Privacy Laws, California Civil Code 1798, et sequitur. Pursuant to Taitz’ own admission she has a total of Thirty-Six

Thousand [36,000] people on her media and individual mail lists, Taitz sent out a minimum of four e-mails with in excess Thirty-Six Thousand [36,000] recipients, including international which is a total of One Hundred Forty-Four Thousand [140,000] e-mails multiplied by Three Thousand Dollars [$3,000.00] per e-mail, which Plaintiff Liberi is entitled too pursuant to the California privacy laws, California Civil Code 1798 et sequitur; F. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for damages in the amount of One Million dollars [$1,000,000.00] per Defendant to be awarded to Plaintiff Liberi; G. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for compensatory damages in the amount of Five Hundred Thousand Dollars [$500,000.00] per Defendant to be awarded to Plaintiff Liberi; H. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for Punitive damages in the amount of Ten Million Dollars [$10,000,000.00] per Defendant to be awarded to Plaintiff Liberi; I. J. Attorney’s fees, costs and interest for Plaintiff Liberi; and Such other relief as this Court deems proper.

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COUNT TWO DEFEMATION Per Se, SLANDER AND LIBEL (Against All Defendants) 158. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth

herein at length. 159. Defendants’ Taitz, Defend our Freedoms Foundation, Inc., Yosef, Sankey with

the Sankey Firm, Sankey Investigations, Inc., Mr. & Mrs. Hale, Plains Radio, Bar H Farms and Linda made false statements about Liberi claiming she had a criminal record for convictions of amongst other things, identity theft, falsification of police reports, falsification of credit reports, falsification of documents, claiming Lisa Liberi and Lisa Ostella were one and the same, falsely claiming Liberi and Ostella were diverting funds from Taitz’s PayPal account; falsely claiming Liberi and Ostella were working together; falsely claiming Liberi was diverting funds from Berg and the Law Offices of Philip J. Berg; falsely claiming Liberi was posting on blogs under her aliases; falsely claiming Liberi was committing crimes, falsely claiming Liberi was “trashing” Linda; falsely claiming Liberi was “trashing Taitz”, falsely claiming Liberi had to pay Twenty-One Thousand [$21,000] Dollars per month in restitution, falsely claiming Liberi was convicted of amongst other things, identity theft, falsifying police reports, falsifying credit reports, counterfeiting documents, etc. 160. Defendants’ Taitz, Mr. and Mrs. Hale, Plains Radio and Bar H Farms made false

statements about Adams claiming she had a criminal record; conning people out of money; calling her horrible names; falsely accusing her of stealing the “Obama” documents; threatening her, etc.

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161.

Defendants’ Taitz, Mr. and Mrs. Hale, Plains Radio, Bar H Farms and Linda

made false statements about Berg and the Law Offices of Philip J. Berg claiming he was under federal investigation; he was a shyster; conning money out of innocent people, was only in it for the money, had a criminal working for him, etc. 162. Defendants Taitz, Yosef, Defend our Freedom Foundations, Inc., James

Sundquist, Rock Salt Publishing made false statements about Ostella that she hijacked Taitz’s website; was working with Liberi; was diverting funds from Taitz PayPal accounts, she hijacked Taitz’s websites, filing false police reports with the Orange County Sheriff’s Department, the FBI in California and New Jersey, claiming her website and PayPal accounts had been hacked, etc. 163. Defendants’ false statements about Plaintiffs were made across the entire internet

world; sent to unknown individuals by way of mass e-mailing; telephone conversation; posting on the Defendants websites, etc. 164. 165. At all relevant times, Defendants have acted with actual malice. Defendants’ defamatory statements about all Plaintiffs have severely injured the

reputation and honorable services provided by each one of them. 166. Defendants’ defamatory statements about the Plaintiffs have caused Plaintiffs to

suffer mental anguish and impaired their personal and professional reputation and standing in the community.

WHEREFORE Plaintiffs’ request: A. An immediate Order enjoining the Defendants’ and all parties acting on

their behalf from airing and/or publishing any defamatory or false statements about Plaintiffs, Lisa Liberi, Philip J. Berg, the Law Offices of Philip J. Berg, Evelyn Adams,

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Lisa Ostella and Go Excel Global, the Plaintiffs’ family members, etc. via the internet or any other print or electronic medium or broadcasts and/or radio, from portraying Plaintiffs in a false light via the internet or another print or electronic medium or broadcasts and/or radio, untrue statements about the Plaintiffs’ enjoin the Defendants’ from posting and distributing Liberi’s Social Security number and personal identifying information; enjoin the Defendants’ from any further harassment of the Plaintiffs’, enjoin Defendants’ from the filing and reporting of falsified criminal activity, etc.; B. An immediate Order enjoining Defendants, Taitz, Defend our Freedoms

Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any party on their behalf from disseminating Liberi’s Social Security number, date of birth, name, where she lives, etc.; C. An immediate Order of Retraction against Defendants, Taitz, Defend our

Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any party who has published Liberi’s confidential information on their behalves to immediately retract and remove Liberi’s private confidential information, including but not limited to her Social Security number, date of birth, where she resides, information about her husband, the false criminal accusations, etc.; D. An immediate Order of Retraction against Defendants’, Taitz, Defend our

Freedoms Foundation, Inc., Sundquist, Rock Salt Publishing, and anyone on their behalf from distributing Lisa Ostella’s personal and confidential information, including but not limited to her home address and telephone number; E Enjoin Defendants, Taitz, Defend our Freedoms, Inc. and Yosef, and any

party operating on their behalf from any further “hacking” of the Plaintiffs’ computers;

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F.

Enter Judgment, collectively, jointly and separately, against the

Defendants’ for damages in the amount of One Million [$1,000,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein; G. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for compensatory damages in the amount of Five Hundred Thousand [$500,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein; H. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for Punitive damages in the amount of Ten Million [$10,000,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein; I. J. Attorney’s fees, costs and interest for each separate Plaintiff herein; and Such other relief as this Court deems proper.

COUNT THREE FALSE-LIGHT INVASION OF PRIVACY (Against all Defendants) 167. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth

herein at length. 168. Defendants’ defamatory statements about Plaintiffs’ placed Plaintiffs’ and their

staff in a false-light before the public. 169. The false-light in which Defendants’ placed Plaintiffs’ and their staff would be

highly offensive to a reasonable person.

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170.

At all times Defendants’ knew that their statements were false and/or acted in

reckless disregard of whether they were true or false. 171. 172. At all relevant times, Defendants’ have acted with actual malice. Defendants’ defamatory statements about Plaintiffs’ have had a deleterious

impact on Plaintiffs’ and their businesses because they were forced to expend money to defend against false statements and that they were embarrassed and humiliated. 173. Defendants’ false statements about Plaintiffs’ and their businesses have severely

injured the reputation and honorable services the Plaintiffs, their businesses and their staff were providing.

WHEREFORE Plaintiffs’ request: A. An immediate Order enjoining the Defendants’ and all parties acting on

their behalf from airing and/or publishing any defamatory or false statements about Plaintiffs, Lisa Liberi, Philip J. Berg, the Law Offices of Philip J. Berg, Evelyn Adams, Lisa Ostella, the Plaintiffs’ family members, etc. via the internet or any other print or electronic medium or broadcasts and/or radio, from portraying Plaintiffs in a false-light via the internet or another print or electronic medium or broadcasts and/or radio, untrue statements about the Plaintiffs’; enjoin the Defendants’ from posting and distributing Liberi’s Social Security number and personal identifying information; enjoin the Defendants’ from any further harassment of the Plaintiffs’, enjoin Defendants’ from the filing and reporting of falsified criminal activity, etc.; B. An immediate Order enjoining Defendants, Taitz, Defend our Freedoms

Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any

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party on their behalf from disseminating Liberi’s Social Security number, date of birth, name, where she lives, etc.; C. An immediate Order of Retraction against Defendants, Taitz, Defend our

Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any party who has published Liberi’s confidential information on their behalves to immediately retract and remove Liberi’s private confidential information, including but not limited to her Social Security number, date of birth, where she resides, information about her husband, the false criminal accusations, etc.; D. An immediate Order of Retraction against Defendants’, Taitz, Defend our

Freedoms Foundation, Inc., Sundquist and Rock Salt Publishing and anyone on their behalf from distributing Lisa Ostella’s personal and confidential information, including but not limited to her home address and telephone number. E Enjoin Defendants, Taitz, Defend our Freedoms, Inc. and Yosef, and any

party operating on their behalf from any further “hacking” of the Plaintiffs’ computers; F. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for damages in the amount of One Million [$1,000,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein; G. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for compensatory damages in the amount of Five Hundred Thousand [$500,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein; H. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for Punitive damages in the amount of Ten Million [$10,000,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein;

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I. J.

Attorney’s fees, costs and interest for each separate Plaintiff herein; and Such other relief as this Court deems proper.

COUNT FOUR HARASSMENT (Against All Defendants) 174. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth

herein at length. 175. Defendants’ have engaged in a longstanding and persistent campaign directed to

damaging the Plaintiffs, their staff’s reputation and business by publishing on the internet a massive volume of false statements and postings and broadcasting across the internet and other channels false and defamatory statements regarding Plaintiffs’. 176. In conjunction with their campaign of internet disparagement, Defendants’ have

further sent thousands of e-mails and other direct communications and has made numerous phone calls making a variety of falsified statements, accusations about the Plaintiffs’ and Plaintiffs businesses and demands upon Plaintiffs’ and their businesses. 177. Plaintiffs’ and their businesses have been alarmed and felt threatened as a result

of the harassment and threats, which they have carried out, by the Defendants’. 178. Despite Plaintiff Adams reasonable efforts to address Defendants’, Mr. and Mrs.

Hale and Plains Radio, allegations regarding the “Obama” divorce decree, Defendants have persistently demanded additional information and for Plaintiff Berg to turn over his certified set of the “Obama” divorce decree and demanding Plaintiff Adams to

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turn over Berg’s certified set of his “Obama” divorce decree, Defendants Edgar (Ed) and Caren Hale would go away. 179. Defendants have engaged in unreasonable and outrageous conduct directed to

harming the Plaintiffs’ and their businesses unjustifiably and to coercing them to accede to the Defendants demands. 180. Defendants have acted unlawfully and in violation of 18 U.S. C. §875(d), 47

U.S.C. §223(a), et al, Texas Penal Code §42.07; the Women’s Violence Act, Department of Justice Reauthorization Act of 2005, H.R. 3402, titled "Preventing Cyber-stalking" and numbered as § 113, § 113(a)(3) provides that Section 223(a)(1)(C) applies to "any device or software that can be used to originate telecommunications or other types of communications that are transmitted, in whole or in part, by the internet; Cyber-stalking and Cyber-harassment laws in violation of the Communications Act, 47 U.S.C. § 223(a)(1)(C) and § 223(h)(1)(B). 181. Plaintiffs’ and their businesses have suffered losses and damages as a result of the

Defendants harassment.

WHEREFORE Plaintiffs’ request: A. An immediate Order enjoining the Defendants’ and all parties acting on

their behalf from airing and/or publishing any defamatory or false statements about Plaintiffs, Lisa Liberi, Philip J. Berg, the Law Offices of Philip J. Berg, Evelyn Adams, Lisa Ostella, the Plaintiffs’ family members, etc. via the internet or any other print or electronic medium or broadcasts and/or radio, from portraying Plaintiffs in a false-light via the internet or another print or electronic medium or broadcasts and/or radio, untrue statements about the Plaintiffs’ enjoin the Defendants’ from posting and distributing

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Liberi’s Social Security number and personal identifying information; enjoin the Defendants’ from any further harassment of the Plaintiffs’, enjoin Defendants’ from the filing and reporting of falsified criminal activity, etc.; B. An immediate Order enjoining Defendants, Taitz, Defend our Freedoms

Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any party on their behalf from disseminating Liberi’s Social Security number, date of birth, name, where she lives, etc.; C. An immediate Order of Retraction against Defendants Taitz, Defend our

Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations and any party who has published Liberi’s confidential information on their behalves to immediately retract and remove Liberi’s private confidential information, including but not limited to her Social Security number, date of birth, where she resides, information about her husband, the false criminal accusations, etc.; D. An immediate Order of Retraction against Defendants’, Taitz, Defend our

Freedoms Foundation, Inc., Sundquist and Rock Salt Publishing, and anyone on their behalf from distributing Lisa Ostella’s personal and confidential information, including but not limited to her home address and telephone number; E Enjoin Defendants, Taitz, Defend our Freedoms, Inc. and Yosef, and any

party operating on their behalf from any further “hacking” of the Plaintiffs’ computers; F. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for damages in the amount of One Million [$1,000,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein; G. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for compensatory damages in the amount of Five Hundred Thousand

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[$500,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein; H. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for Punitive damages in the amount of Ten Million [$10,000,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein; I. J. Attorney’s fees, costs and interest for each separate Plaintiff herein; and Such other relief as this Court deems proper.

COUNT FIVE FALSE DESIGNATIONS AND DESCRIPTIONS OF FACTS (Against all Defendants) 182. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth

herein at length. 183. Plaintiffs’ and their businesses have invested considerable effort and expense in

establishing goodwill in their names and in promoting their careers and professional reputation. Liberi in promoting her profession as a skillful and highly competent Legal Assistant and Paralegal; Berg in promoting his profession as skillful and highly competent provider as a prominent attorney with a professional staff and law firm; Adams in promoting her profession as a skillful and highly competent radio host/broadcaster; and Ostella and Go Excel Global in promoting her profession as a skillful and highly competent Webmaster and a Website Hosting Company. 184. Defendants have published on the internet numerous statements in conjunction

with false and misleading designations and false and misleading descriptions and representations of fact.

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185.

Defendants’ false and misleading statements about the Plaintiffs’ and their

businesses are likely to cause and have caused public confusion regarding their associations, intents and purposes. Those false and misleading statements further have grossly misrepresented the nature, characteristics and quality of the Plaintiffs’ and their businesses services. 186. Defendants’ false and misleading statements about Plaintiffs’ and their businesses

have been designed to tarnish and have tarnished the Plaintiffs’ and their businesses names, reputation and business. 187. On information and belief, Defendants’ have acted with an intent and design to

achieve publicity, fame and notoriety for themselves and thereby enhance the market for the Defendants’ regarding the Obama lawsuits. 188. The Defendants’ false and misleading statements about Plaintiffs’ and their

businesses have been designed to harm and have harmed Plaintiffs’, and their businesses and have caused losses and damages to the Plaintiffs’ and their businesses. 189. Defendants’ have engaged in unlawful conduct in violation of 15 U.S.C. §1125,

False designations of origin, false descriptions, and dilution forbidden.

WHEREFORE Plaintiffs’ request: A. An immediate Order enjoining the Defendants’ and all parties acting on

their behalf from airing and/or publishing any defamatory or false statements about Plaintiffs, Lisa Liberi, Philip J. Berg, the Law Offices of Philip J. Berg, Evelyn Adams, Lisa Ostella, the Plaintiffs’ family members, etc., via the internet or any other print or electronic medium or broadcasts and/or radio, from portraying Plaintiffs in a false-light via the internet or another print or electronic medium or broadcasts and/or radio, untrue

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statements about the Plaintiffs’, enjoin the Defendants’ from posting and distributing Liberi’s social security number and personal identifying information; enjoin the Defendants’ from any further harassment of the Plaintiffs’, enjoin Defendants’ from the filing and reporting of falsified criminal activity, etc.; B. An immediate Order enjoining Defendants Taitz, Defend our Freedoms

Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any party on their behalf from disseminating Liberi’s Social Security number, date of birth, name, where she lives, etc.; C. An immediate Order of Retraction against Defendants Taitz, Defend our

Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any party who has published Liberi’s confidential information on their behalves to immediately retract and remove Liberi’s private confidential information, including but not limited to her Social Security number, date of birth, where she resides, information about her husband, the false criminal accusations, etc.; D. An immediate Order of Retraction against Defendants’, Taitz, Defend our

Freedoms Foundation, Inc., Sundquist and Rock Salt Publishing, and anyone on their behalf from distributing Lisa Ostella’s personal and confidential information, including but not limited to her home address and telephone number; E Enjoin Defendants, Taitz, Defend our Freedoms, Inc. and Yosef, and any

party operating on their behalf from any further “hacking” of the Plaintiffs’ computers; F. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for damages in the amount of One Million [$1,000,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein;

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G.

Enter Judgment, collectively, jointly and separately, against the

Defendants’ for compensatory damages in the amount of Five Hundred Thousand [$500,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein; H. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for Punitive damages in the amount of Ten Million [$10,000,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein; I. J. Attorney’s fees, costs and interest for each separate Plaintiff herein; and Such other relief as this Court deems proper.

COUNT SIX INJUNCTIVE RELIEF (Against All Defendants)

190.

Plaintiffs incorporate by reference all of the foregoing allegations as if set forth

herein at length. 191. The Defendants’ defamatory statements about Plaintiffs’ and their businesses

have damaged Plaintiffs’ and their businesses reputation as well as Liberi’s effective and skillful law experience; Berg’s law practice, Adams Radio Shows and Ostella’s Web Mastering and Web Hosting Company, Go Excel Global with false allegations, misrepresentations of their character and publicity that placed them in false-light. Such intentional and recklessly made statements have caused Plaintiffs, their staff and their businesses irreparable harm for which there is no adequate remedy at law. 192. As a direct and proximate result of the Defendants’ defamatory statements, the

Plaintiffs’ and their businesses have lost present and future business opportunities,
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has suffered and will suffer, irreparable harm to their reputation and standing in the legal, radio, webmaster and web hosting communities, and have suffered and will suffer restrictions on their ability to pursue support for future endeavors for which there is no adequate remedy at law. 193. 194. 195. Plaintiffs’ will likely succeed on the merits of its underlying case. The injunctive relief sought will not adversely affect the publics’ interests. As a direct and proximate result of the Defendants illicit actions, Plaintiffs’ and

their businesses are entitled to an injunction against the Defendants’. 196. It has been necessary for the Plaintiffs’ to retain the services of an attorney to

obtain redress, and Plaintiffs are entitled to reasonable attorney fees and costs therefore.

WHEREFORE Plaintiffs’ request: A. An immediate Order enjoining the Defendants’ and all parties acting on

their behalf from airing and/or publishing any defamatory or false statements about Plaintiffs, Lisa Liberi, Philip J. Berg, the Law Offices of Philip J. Berg, Evelyn Adams, Lisa Ostella, the Plaintiffs’ family members, etc. via the internet or any other print or electronic medium or broadcasts and/or radio, from portraying Plaintiffs in a false-light via the internet or another print or electronic medium or broadcasts and/or radio, untrue statements about the Plaintiffs’ enjoin the Defendants’ from posting and distributing Liberi’s Social Security number and personal identifying information; enjoin the Defendants’ from any further harassment of the Plaintiffs’, enjoin Defendants’ from the filing and reporting of falsified criminal activity, etc.;

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B.

An immediate Order enjoining Defendants, Taitz, Defend our Freedoms

Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any party on their behalf from disseminating Liberi’s Social Security number, date of birth, name, where she lives, etc.; C. An immediate Order of Retraction against Defendants, Taitz, Defend our

Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any party who has published Liberi’s confidential information on their behalves to immediately retract and remove Liberi’s private confidential information, including but not limited to her Social Security number, date of birth, where she resides, information about her husband, the false criminal accusations, etc.; D. An immediate Order of Retraction against Defendants’, Taitz, Defend our

Freedoms Foundation, Inc., Sundquist and Rock Salt Publishing, and anyone on their behalf from distributing Lisa Ostella’s personal and confidential information, including but not limited to her home address and telephone number; E Enjoin Defendants, Taitz, Defend our Freedoms, Inc. and Yosef, and any

party operating on their behalf from any further “hacking” of the Plaintiffs’ computers; F. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for damages in the amount of One Million [$1,000,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein; G. Enter Judgment, collectively, jointly and separately, against the

Defendants’ for compensatory damages in the amount of Five Hundred Thousand [$500,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein;

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H.

Enter Judgment, collectively, jointly and separately, against the

Defendants’ for Punitive damages in the amount of Ten Million [$10,000,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff herein; I. J. Attorney’s fees, costs and interest for each separate Plaintiff herein; and Such other relief as this Court deems proper.

Date: May 04, 2009

Respectfully submitted,

s/ Philip J. Berg _______________________________ Philip J. Berg, Esquire Attorney for Plaintiffs

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VERIFICATION
I, Lisa Liberi, hereby state that I am a Plaintiff in this action and verify that the statements made in the foregoing .Complaint are true and correct to the best of my Knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904 and the laws of the United States relating to unsworn falsification to authorities. s/Lisa Liberi ____________________________ LISA LIBERI, Plaintiff

Dated: April 25, 2009

VERIFICATION
I, Philip J. Berg, Esquire, hereby state that I am a Plaintiff in this action and verify that the statements made in the foregoing .Complaint are true and correct to the best of my Knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904 and the laws of the United States relating to unsworn falsification to authorities. s/ Philip J. Berg ____________________________ PHILIP J. BERG, ESQUIRE, Plaintiff

Dated: April 25, 2009

VERIFICATION
I, Evelyn Adams, hereby state that I am a Plaintiff in this action and verify that the statements made in the foregoing .Complaint are true and correct to the best of my Knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904 and the laws of the United States relating to unsworn falsification to authorities. s/ Evelyn Adams ____________________________ EVELYN ADAMS, Plaintiff

Dated: April 25, 2009

VERIFICATION
I, Lisa M. Ostella, hereby state that I am a Plaintiff in this action and verify that the statements made in the foregoing .Complaint are true and correct to the best of my Knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904 and the laws of the United States relating to unsworn falsification to authorities. s/ Lisa M. Ostella ____________________________ LISA M. OSTELLA, Plaintiff

Dated: April 25, 2009