U.S.

District Court,
Court of Appeals Case No. 09-3403

UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
_____________
Ο

_____________

LISA LIBERI, et al,
Petitioner – Appellant,
v.
ORLY TAITZ, et al,
Respondents – Appellee.
_____________
Ο

_____________
APPELLANTS’ EMERGENCY MOTION TO EXPEDITE THIS COURT’S RULINGS IN
THE ABOVE REFERENCED APPEAL
_____________________

Counsel: PHILIP J. BERG, ESQUIRE
LAW OFFICES OF PHILIP J. BERG
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
(610) 825-3134
Identification No. 09867

Attorney for the Appellants’





Eastern District of Pennsylvania Case Number: 09-cv-01898-ECR
Case: 09-3403 Document: 00319959621 Page: 1 Date Filed: 12/27/2009



Appellants, Lisa Liberi [hereinafter “Liberi”]; Philip J. Berg, Esquire
[hereinafter “Berg”], the Law Offices of Philip J. Berg; Evelyn Adams a/k/a
Momma E [hereinafter “Adams”]; Lisa Ostella [hereinafter “Ostella”]; and Go
Excel Global by and through their undersigned counsel, Philip J. Berg, Esquire,
hereby submit this Emergency Motion to Expedite the Appellants Appeal, filed
and docketed on August 14, 2009 of Judge Robreno’s Order of August 7, 2009,
denying Plaintiffs (Appellants herein) Motion for an Emergency Temporary
Restraining Order and/or Injunction; and expedite its rulings on Appellants
Emergency Motion for a Temporary Restraining Order and/or Injunction pending
the outcome of this Appeal, filed with this Court on August 27, 2009.
Appellants are asking this Court to Order Appellants Brief (if required) to be
filed in their appeal on or before Friday, January 8, 2010; Appellees Response (if
required) on or before Friday, January 15, 2010 and any response thereto on or
before January 19, 2010. Appellants are further asking this Court for an expedited
ruling on their Emergency Motion for a Temporary Restraining Order and/or
Injunction pending the outcome of the Appeal, which was filed with this Court on
August 27, 2009.
This case was filed May 4, 2009, almost eight months (8) months ago, and
nothing has taken place in the case, not even a Scheduling Order. The more time
that goes by without any assistance by our Courts, the more comfortable the
Case: 09-3403 Document: 00319959621 Page: 2 Date Filed: 12/27/2009



Appellees become and continue their illegal and damaging behaviors, as proven by
the history of this case. All of the Defendants (Appellees herein) have waived their
affirmative defenses, and basically admitted to all the wrongs, thus Appellants will
be filing the appropriate Motions once the case is permitted to move forward.
Appellants Motion to expedite this Interlocutory Appeal and expedite a
ruling on Appellants pending Motion for an Emergency Temporary Restraining
Order and/or Injunction is permitted pursuant to the U.S. Court of Appeals for the
Third Circuit Local Rule, L.A.R. 4.1 (2008). Appellants Motion to Expedite is
based upon the Order issued by Judge Robreno of the United States District Court,
Eastern District of Pennsylvania, docketed December 11, 2009 as Doc. No. 115,
suspending Appellants case pending the U.S. Court of Appeals for the Third
Circuit, Rulings on Appellants Interlocutory Appeal. A copy of the U.S. District
Court, Eastern District of Pennsylvania, Judge Robreno’s Order of December 11,
2009 is attached hereto and incorporated in by reference as EXHIBIT “A”. This
is extremely prejudicial to the Appellants, as explained below, as Appellants have
a pending Motion to Transfer their Case to the U.S. District Court, Central District
of California, Southern Division, see EXHIBIT “B”, due to the Appellees threat
of liquidating their assets which are located in the State of California.
This pending Appeal stems from an Order of the lower Court denying
Plaintiffs (Appellants herein) Motion for a Temporary Restraining Order and/or
Case: 09-3403 Document: 00319959621 Page: 3 Date Filed: 12/27/2009



Injunction. In addition, Appellants have a pending Emergency Motion for a
Temporary Restraining Order and/or Injunction, filed on or about August 27, 2009
pending the outcome of their Interlocutory Appeal. None of the Appellees have
responded and/or opposed Appellants Emergency Motion for a Temporary
Restraining Order or Injunction pending Appeal and therefore, Appellants Motion
is uncontested. See Third Circuit L.A.R. 27.3 (2008) (“…In the absence of a
timely response, the Court may treat a Motion without such certification as
uncontested”).
When issues regarding assets being sold, hidden, transferred or moved off-
shore while the parties are involved in litigation require immediate attention and
action by the other parties. Under the Uniform Fraudulent Transfer Act, any type
of transfer or liquidation by a Defendant or Appellee during the course of
litigation, is unlawful, See Cal Civ Code § 3439, et sequitur (Uniform Fraudulent
Transfer Act). It is imperative to obtain an Order from the U.S. District Court,
Central District of California, Southern Division, freezing the Appellees assets and
immediately file actions to undue the illegal liquidation, transfer, selling of, and
hiding of Assets.
Appellants are informed, believe and thereon allege Appellee, Orly Taitz, et
al; her husband, Yosef Taitz; Appellee Defend our Freedoms Foundations, Inc.;
Appellees Neil Sankey; Sankey Investigations, Inc.; and the Sankey Firm, Inc a/k/a
Case: 09-3403 Document: 00319959621 Page: 4 Date Filed: 12/27/2009



The Sankey Firm are attempting to hide their assets and moving their assets off-
shore to avoid collection by the Appellants who are entitled to monetary damages
as a result of the Appellees wrongful, damaging and illegal behaviors. Again,
these Appellees assets are located in the State of California. In addition, California
is a community property state; therefore, any judgment obtained against one of the
Appellees can also be collected against their spouse’s assets.
None of the Appellees have entered an appearance or filed any of their initial
case opening documents and/or information as outlined in the Case Opening Letter
of August 17, 2009. Thus, Appellants are unaware if any of the Appellees will be
participating in this Appeal. In addition, none of the Appellees have responded to
Appellants Emergency Motion for a Temporary Restraining Order and/or
Injunction pending the outcome of this Appeal, filed with this Court on August 27,
2009. Therefore, Appellants can only assume the Appellees are in full agreement
with the issuance of an Emergency Injunction or Temporary Restraining Order
pending the outcome of Appellants Appeal.
Since the filing of Appellants Appeal herein and Appellants Emergency
Motion for a Temporary Restraining Order and/or Injunction, the Appellees
damaging behaviors have not only continued, but now Appellants have reason to
believe the Appellees are attempting to transfer, hide, liquidate and move off-shore
Case: 09-3403 Document: 00319959621 Page: 5 Date Filed: 12/27/2009



their assets, which Appellants depend upon for collection of any judgment issued
in favor of the Appellants.
In September 2009, Taitz used the Federal Docketing System in a case
unrelated to the Appellants herein and filed her famous Dossier #6 which
contained falsified information about Liberi, her Social Security number, date of
birth, and other private, confidential and personal information in the case of
Barnett, et al v. Obama, et al, Case No. 09-cv-00082 filed in the United States
District Court, Central District of California, Southern Division before Judge
Carter. Counsel herein sent a letter to Judge Carter and requested the sealing of
Appellee Taitz, et al’s Filing of Dossier #6 as it violated the Federal Rules of Civil
Procedure and the California local rules. Judge Carter in turn issued an Order
Sealing the Court Filing of Dossier #6 and Ordered Appellee Taitz, the attorney in
the Barnett Case, to re-file her documents with all Social Security numbers, date of
birth’s and other personal information redacted as he, Judge Carter, was
concerned about the confidentiality of Liberi, her spouse and other individuals
private confidential information being made public. This September 2009 Court
Order of Judge Carter has been filed with this Court by Appellants’ with a Request
for Judicial Notice.
In addition, it appears Appellees Neil Sankey, Sankey Investigations, Inc.
the Sankey Firm, Inc. a/k/a the Sankey Firm and Taitz have published further
Case: 09-3403 Document: 00319959621 Page: 6 Date Filed: 12/27/2009



private confidential information of the Appellants on the internet. This includes,
but is not limited to, Adoption records; Social Security numbers; Social Security
records; addresses; parents maiden names, etc.
Moreover, Appellee Taitz was caught in a love affair with a client of hers
and her law clerk, Charles Edward Lincoln, III, by her husband Yosef Taitz.
According to an Affidavit on file with the U.S. District Court, Southern District of
Florida, Mr. Lincoln claims that Taitz broke off their affair as Taitz’s husband,
Yosef Taitz, was demanding Appellee Orly Taitz, et al to sign off all her rights to
the Taitz’s assets. A copy of this Affidavit was filed with this Court with a
Request for Judicial Notice.
On or about November 29, 2009, Appellants sought leave from the United
States District Court for the Eastern District of Pennsylvania, Judge Robreno to file
a Motion to Transfer their Case to the U.S. District Court, Central District of
California, Southern Division as Appellees assets are located within that Court’s
jurisdiction and Appellants fear of the Appellees liquidating and hiding their
assets.
On or about December 2, 2009, Appellee Orly Taitz, et al filed another letter
in the Federal Docketing System, in a case unrelated to any of the Appellants
herein (Barnett Case) with a bunch of false accusations against Appellants Liberi
and Berg and placed it on the World Wide Web at Scribd prior to its filing in the
Case: 09-3403 Document: 00319959621 Page: 7 Date Filed: 12/27/2009



Federal Docketing System. Neither Liberi nor Berg have anything to do with the
Barnett case filed in California and the only reason these documents have been
Filed by Appellee Orly Taitz, et al is to use the Federal Docketing System to
further her illegal, harmful, damaging behaviors towards Appellant Liberi,
Appellant Berg, the other Appellants and any party associated with them. In
addition, once Appellee Taitz posted this letter on the internet, it also caused the
republishing of Taitz’s Dossier #6, which again contains the full social security
number, date of birth and other very personal private information of Appellant
Liberi. Appellants requested this Court to take Judicial Notice of these documents
on or about December 8, 2009.
On December 11, 2009, Judge Robreno, U.S. District Court, Eastern District
of Pennsylvania, the lower Court, issued an Order that two (2) issues were pending
before his Court. The first was the Court’s Rules to Show Cause and the second
issue was Plaintiffs’ (Appellants herein) letter seeking Leave to File their Motion
to Transfer the case to the U.S. District Court, Central District of California,
Southern Division. However, to preserve status quo, Judge Robreno stated he was
not going to rule on the issues pending the ruling of the Third Circuit Court of
Appeals on Plaintiffs (Appellants herein) Interlocutory Appeal. See EXHIBIT
“A”.
Case: 09-3403 Document: 00319959621 Page: 8 Date Filed: 12/27/2009



The Appellees and their followers have continued their stocking behaviors
towards the Appellants herein. Appellee Orly Taitz, et al has continued wide
distribution of slanderous, libelous, and tortuous statements pertaining to
Appellants Liberi, Ostella, Berg and the other Appellants and wide distribution of
Liberi’s and the other Appellants private confidential information, including but
not limited to full social security numbers, mother’s maiden name, date of birth,
place of birth, Adoption records, etc. In fact, Appellee Orly Taitz has now resorted
to using the Federal Docketing System to further her criminal activities and
spreading of completely private and confidential information of Appellant Liberi in
unrelated cases.
Without a prompt disposition of the pending Interlocutory Appeal and
Appellants Emergency Motion for a Temporary Injunction and/or Restraining
Order, Appellants will continue to suffer irreparable injuries and damages which
monetary awards alone will not suffice. Moreover, Appellants do not have any
legal remedies of law to prohibit the posting of their Social Security Number, date
of births, mother’s maiden name, place of birth and/or any other extremely
sensitive and confidential information placed all over the world wide web and
provided by mass emailing by Appellee Orly Taitz, et al or any of the other
Appellees.
Case: 09-3403 Document: 00319959621 Page: 9 Date Filed: 12/27/2009



Appellants will continue to suffer irreparable injury that the Court cannot
fully compensate if Appellants Emergency Motion for Expedited Rulings on their
Pending Motion for a Temporary Restraining Order and/or Injunction pending
Appeal and Appellants actual Interlocutory Appeal is not granted. Deerfield Med.
Ctr. v. City of Deerfield Beach, 661 F.2d 328, 338 (5th Cir. 1981) (injury is
irreparable if it cannot be undone by monetary damages). Roland Mach. Co. v.
Dresser Indus., Inc., 749 F.2d 380, 386 (7th Cir. 1984) (irreparable harm is harm
that cannot be prevented or fully rectified by final judgment).
Appellants respectfully request this Honorable Court to Expedite Appellants
Appeal and Expedite Appellants Emergency Motion for an Emergency Temporary
Restraining Order and/or Injunction as a result of the lower Court’s December 11,
2009 Order suspending the Plaintiffs (Appellants herein) case pending the rulings
of this Court. See Third Circuit L.A.R. 4.1 (2008) (“A party who seeks to expedite
a case must file a motion within fourteen (14) days…setting forth the exceptional
reason that warrants expedition. If a reason for expedition arises thereafter; the
moving party must file a motion within fourteen (14) days of the occurrence that is
the basis of the motion…”) In re Walsh, 229 Fed. Appx. 58, 61 (3d Cir. 2007). See
also 28 U.S.C. §1657(a) (“Notwithstanding any other provision of law, each Court
of the United States shall…expedite consideration of any action…for temporary or
preliminary relief…”).
Case: 09-3403 Document: 00319959621 Page: 10 Date Filed: 12/27/2009



Pursuant to the Third Circuit Court of Appeals L.A.R. 4.1 (2008),
Appellants have attached a proposed Scheduling Order for the within Appeal as
EXHIBIT “C”.
WHEREFORE, Appellants respectfully request this Honorable Court to
Grant their Motion to Expedite their Appeal and Order Appellants Brief (if
required) to be filed on or before Friday, January 8, 2010; Appellees Responsive
Brief (if required) on or before Friday, January 15, 2010; and any response thereto
on or before January 19, 2010 and Expedite the Ruling on Appellants Pending
Emergency Motion for a Temporary Restraining Order and/or Injunction Pending
the outcome of this Appeal.
Respectfully submitted,

Dated: December 27, 2009 ___________________________
Philip J. Berg, Esquire
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
(610) 825-3134

Attorney for the Appellants’










s/ Philip J. Berg
Case: 09-3403 Document: 00319959621 Page: 11 Date Filed: 12/27/2009
















































EXHIBIT “A”
Case: 09-3403 Document: 00319959621 Page: 12 Date Filed: 12/27/2009
There are two matters pending before the Court. First,
1
the parties’ responses to this Court’s Rule to Show Cause (doc.
no. 80), ordering that Plaintiffs show cause as to why their
complaint should not be dismissed on the following three grounds:
(1) why this case should not be dismissed for lack of personal
jurisdiction, (2) why this case should not be severed into three
or fewer cases against the following groups or Defendants: (i)
Edgar & Caren Hale, Plains Radio Network, Bar H. Farms and KPRN
AM 1610; (ii) Linda S. Belcher; (iii) Orly Taitz, Defend Our
Freedoms Foundations, Inc., Neil Sankey, Sankey Investigations,
Inc. and The Sankey Firm, and (3) why this case should not be
transferred to an appropriate district in either Texas or
California, pursuant to 28 U.S.C. § 1404(a). Second, Plaintiffs’
letter to the Court, dated November 29, 2009, requesting leave to
file a motion to transfer to the Central District of California.
Given that Plaintiffs have taken an appeal to the
Court’s denial of their motion for an injunction or restraining
order, dated August 10, 2009 (doc. no. 83), and that none of the
matters pending are intended to preserve the status quo, the
Court will await adjudication of the appeal before proceeding to
rule on these matters.
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
LISA LIBERI et al., : CIVIL ACTION
: NO. 09-1898
Plaintiffs, :
:
v. :
:
ORLY TAITZ et al., :
:
Defendants. :
O R D E R
AND NOW, this 9th day of December, 2009, it is hereby
ORDERED that this case shall be placed in suspense until further
order of the Court.
1
AND IT IS SO ORDERED.
s/Eduardo C. Robreno
EDUARDO C. ROBRENO, J.
Case 2:09-cv-01898-ER Document 115 Filed 12/11/2009 Page 1 of 1 Case: 09-3403 Document: 00319959621 Page: 13 Date Filed: 12/27/2009


























EXHIBIT “B”
Case: 09-3403 Document: 00319959621 Page: 14 Date Filed: 12/27/2009
Z:\Liberi Ltr to Judge Robreno Nov. 29, 2009
1
LAW OFFICES OF
PHILIP J. BERG
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
PHILIP J. BERG
CATHERINE R. BARONE
BARBARA MAY
(610) 825-3134

FAX (610) 834-7659

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


November 29, 2009


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

Sent via Fax to (267) 299-7428...................................................................................................45 Pages

Re: Liberi, et al. v. Orly Taitz, et al, Case No. 09-cv-01898 ECR
Leave to file Plaintiffs’ Emergency Motion to Transfer Venue of the within Case to the
United States District Court, Central District of California, Southern Division________

Dear Judge Robreno:
Pursuant to this Court’s Order of June 25, 2009 Plaintiffs’ are seeking Leave of this Court to
file the attached Emergency Motion to Transfer Venue of the within action to the United States District
Court, Central District of California, Southern Division located in South Orange County at 411 West
Fourth Street, Santa Ana, CA 92701-4516 with telephone number (714) 338-4750.

Plaintiffs’ bring to this Courts attention that all Defendants have prior hereto requested this
Court to transfer this case to California or Texas, although Plaintiffs’ are unaware of the Defendants
position to Plaintiffs’ request herein.

Thank you.

Respectfully,

Philip J. Berg
PJB:jb
Enclosures
Case: 09-3403 Document: 00319959621 Page: 15 Date Filed: 12/27/2009
Z:\Liberi Ltr to Judge Robreno Nov. 29, 2009
2
Honorable Eduardo C. Robreno November 29, 2009
United States District Court
for the Eastern District of Pennsylvania
Page Two of Two



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

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

Linda Sue Belcher
201 Paris
Castroville, Texas 78009
Home Phone: (830) 538-6395
Cell Phone: (830) 931-1781
Email: Newwomensparty@aol.com and
Email: starrbuzz@sbcglobal.net

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

Case: 09-3403 Document: 00319959621 Page: 16 Date Filed: 12/27/2009
Z:\Liberi Motion to Transfer Venue to South Orange County, CA 11 28 09
1
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA



LISA LIBERI, et al,
Plaintiffs,


vs.


ORLY TAITZ, et al,
Defendants.
:
:
:
:
:
:
:
:
:
:


Assigned to Honorable Eduardo C. Robreno


Case No.: 09-cv-01898-ECR






ORDER

AND NOW, this _____ day of ___________________, 2009, upon Plaintiffs’
Emergency Motion to Transfer Venue; any responses thereto; and for good cause shown,
it is hereby
ORDERED and DECREED that Plaintiffs’ Emergency Motion to Transfer
Venue to the United States District Court, Central District of California, Southern
Division pursuant to 28 U.S.C. §1404(a) is hereby GRANTED.
IT IS FURTHER ORDERED that the Clerk of the Court shall transfer the
within Case to the United States District Court, Central District of California, Southern
Division located in South Orange County at 411 West Fourth Street, Santa Ana, CA
92701-4516 with telephone number (714) 338-4750.

IT IS SO ORDERED:
Date: November _____, 2009 ______________________________
Eduardo C. Robreno, Judge
U.S. District Court for the Eastern
District of Pennsylvania
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Z:\Liberi Motion to Transfer Venue to South Orange County, CA 11 28 09
2
Law Offices of:
PHILIP J. BERG, ESQUIRE
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531 Attorney for: Plaintiffs
Identification No. 09867
(610) 825-3134

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA




LISA LIBERI, et al,
Plaintiffs,
vs.



ORLY TAITZ, et al,
Defendants.
:
:
:
:
:
:
:
:
:
:



Case No.: 09-cv-01898-ECR



Assigned to Honorable Eduardo C. Robreno



PLAINTIFFS’ EMERGENCY MOTION REQUESTING TRANSFER OF VENUE
PURSUANT TO 28 U.S.C. § 1404(a) FROM THE U.S. DISTRICT COURT,
EASTERN DISTRICT OF PENNSYLVANIA TO THE U.S. DISTRICT COURT,
CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION


NOW COMES the Plaintiffs’, Lisa Liberi [hereinafter “Liberi”], Philip J. Berg,
Esquire [hereinafter “Berg”], the Law Offices of Philip J. Berg, Evelyn Adams a/k/a
Momma E [hereinafter “Adams”], Lisa Ostella [hereinafter “Ostella”] and Go Excel
Global by and through their undersigned counsel and respectfully requests this Honorable
Court to grant their Emergency Motion to Transfer Venue of the within case from this
Court, the United States District Court for the Eastern District of Pennsylvania to the
United States District Court, Central District of California, Southern Division located in
Case: 09-3403 Document: 00319959621 Page: 18 Date Filed: 12/27/2009
Z:\Liberi Motion to Transfer Venue to South Orange County, CA 11 28 09
3
South Orange County at 411 West Fourth Street, Santa Ana, CA 92701-4516 with
telephone number (714) 338-4750. In support hereof, Plaintiffs’ aver as follows:

• Although this is a Diversity Case and venue is proper in both
locations, the vast majority of the Defendants are located in Southern
California;

• Defendants Orly Taitz, Esquire a/k/a Orly Taitz a/k/a Dr. Orly Taitz
a/k/a Law Offices of Orly Taitz a/k/a Orly Taitz, Inc [hereinafter
“Taitz”], Defend our Freedoms Foundations, Inc. [hereinafter
“DOFF”], Neil Sankey [hereinafter “Sankey”], Sankey Investigations,
Inc. and the Sankey Firm, Inc. a/k/a The Sankey Firm own and
operate their businesses and own property within the United States
District Court, Central District of California, Southern Division;

• The Statute relied on by the Plaintiffs’ and the Statute the Plaintiffs’
are asking to be utilized and upheld is a California Statute, California
Civil Code 1798, et sequitur;

• There is a concern that Defendant Taitz and DOFF are attempting to
liquidate their assets and sign away their rights to the assets owned
and operated by Taitz, DOFF and Taitz’s husband, Yosef Taitz.

• California is a Community Property State, any judgment obtained
against Taitz is also collectable from any assets owned by her
husband, Yosef Taitz;

• Transfer of venue is appropriate pursuant to 28 U.S.C. § 1404(a) as a
result of California being able to enforce the Judgment, practical
considerations that would expedite and simplify the trial; California’s
local interest in deciding the local controversies at home, in particular
upholding California’s Civil Code 1798, et sequitur; and this is a
Diversity Case and the United States District Court, Central District
of California, Southern Division is very familiar with this State Law.

• All Defendants have asked this Court to transfer the within Case to
California and the Case must be tried together as there was a common
scheme in the actions of the Defendants which have severely harmed
and damaged the Plaintiffs.



Case: 09-3403 Document: 00319959621 Page: 19 Date Filed: 12/27/2009
Z:\Liberi Motion to Transfer Venue to South Orange County, CA 11 28 09
4
WHEREFORE, Plaintiffs’ respectfully prays that this Honorable Court Grant
their Motion and Transfer Venue of the within Case to the United States District Court,
Central District of California, Southern Division located in South Orange County at 411
West Fourth Street, Santa Ana, CA 92701-4516 with telephone number (714) 338-4750.
Respectfully submitted,
Dated: November 29, 2009 _____________________________
Philip J. Berg, Esquire
Attorney for the Plaintiffs’
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
Identification No. 09867
(610) 825-3134

























Case: 09-3403 Document: 00319959621 Page: 20 Date Filed: 12/27/2009
Z:\Liberi Motion to Transfer Venue to South Orange County, CA 11 28 09
5
Law Offices of:
PHILIP J. BERG, ESQUIRE
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531 Attorney for: Plaintiffs
Identification No. 09867
(610) 825-3134

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA




LISA LIBERI, et al,
Plaintiffs,
vs.



ORLY TAITZ, et al,
Defendants.
:
:
:
:
:
:
:
:
:
:



Case No.: 09-cv-01898-ECR



Assigned to Honorable Eduardo C. Robreno




PLAINTIFFS’ MEMORANDUM OF LAW IN SUPPORT OF
THEIR EMERGENCY MOTION REQUESTING TRANSFER OF VENUE
PURSUANT TO 28 U.S.C. § 1404(a) FROM THE U.S. DISTRICT COURT,
EASTERN DISTRICT OF PENNSYLVANIA TO THE U.S. DISTRICT COURT,
CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION


I. STATEMENT OF FACTS:
Defendant Taitz through DOFF and Defendant Sankey through Sankey
Investigations and the Sankey Firm have invaded the privacy of Liberi, Ostella, and
Adams by publicizing Liberi’s full Social Security number, date of birth, mother’s
maiden name, place of birth and other personal information of Liberi’s, including
information about Liberi’s medical conditions, child, husband, etc. and has targeted all
the work Liberi has performed for Berg in Pennsylvania. Taitz through DOFF has also
Case: 09-3403 Document: 00319959621 Page: 21 Date Filed: 12/27/2009
Z:\Liberi Motion to Transfer Venue to South Orange County, CA 11 28 09
6
publicized Ostella’s name, address, maiden name, where her family resides, parents
names and where they reside, etc. and Taitz has also published Adams name, address,
husband’s information, etc. Taitz filed false law enforcement reports with the Federal
Bureau of Investigations (FBI); police departments; called for people where the
Plaintiffs’ reside; falsely accused Liberi and Ostella of “hacking” her paypal account and
website or forum; falsely accused Adams and Berg of diverting funds and making money
off of her company name; falsely accused Liberi of “murdering” her sister; falsely
accused Liberi’s husband of diverting funds from Berg; falsely accused Liberi of being
convicted of crimes including but not limited to identity theft, manipulation of police
reports, manipulation of credit reports, real estate crimes, etc., which has placed the
Plaintiffs’ in the false light before the publics eye; slandering the Plaintiffs’; harassed the
Plaintiffs; invaded the Plaintiffs’ seclusion; publicly disclosed private facts about the
Plaintiffs’; destroyed the Plaintiffs’ reputation; and interfered with the Plaintiffs’ business
associates, etc.
Shortly thereafter, the Hales had Taitz through DOFF and Sankey through Sankey
Investigations and the Sankey Firm on their radio show. Taitz continued her malicious
lies about Plaintiffs’ and Sankey continued his distribution of Liberi’s private
confidential information as well as Adams and Ostella’s. In fact, Sankey and Hale
announced on the radio show on May 28, 2009 that Liberi had recently taken out a loan,
which she had. The only way they would have known this is if they had illegally
accessed Liberi’s credit report or applied for and taken out credit in Liberi’s name.
Sankey, Taitz and Hale then altered and forged Ostella’s emails and published them on
the internet. Edgar Hale admitted in an email to Liberi that Taitz used him to assault
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7
Liberi to get to Berg. The Hales also have viciously attacked, slandered, harassed and
threatened Adams. The Hales have admitted in writing that is on file with this Court,
Taitz, DOFF and the other Defendants used them to “assault” Liberi to take down Berg.
Belcher joined forces with Taitz in or about January 2009 in their attempts to
destroy Berg and Liberi. Belcher sent out mass emails with all kinds of false statements
about Liberi and Berg. Belcher filed false reports with the Social Security
Administration, manufactured emails and “chat logs” which she had filed with this Court;
and further published Liberi’s private confidential information.
As a result, Plaintiffs’ filed suit on May 4, 2009 of which all Defendants were
served. The Defendants’ Answers to the Plaintiffs’ Complaint were due May 26, 2009.
Taitz and DOFF failed to timely Answer Plaintiffs’ Complaint and therefore, default was
entered against them, and they waived their rights to raise any type of affirmative
defenses. Despite this, Taitz and DOFF untimely filed a one sentence denial as their
Answer and a “Motion to Dismiss” without any type of supporting law.
Since the time Plaintiffs’ filed suit, the Defendants actions and behaviors have
continued. Taitz, DOFF, Sankey, Sankey Investigations, Inc, and the Sankey Firm, Inc.
a/k/a the Sankey Firm are located in California. The majority of their Assets are located
in California. In addition, Taitz’s owns two [2] Dental Practices in the jurisdiction of the
United States District Court, Central District of California, Southern Division and she and
her husband own a Software Engineering company with their headquarters located in the
jurisdiction of the United States District Court, Central District of California, Southern
Division with offices over seas, in New Jersey and Santa Fe, New Mexico.
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Furthermore, according to Affidavits on file in the United States District Court,
Southern District of Florida, Taitz was having a “love affair” with her law Clerk,
disbarred Attorney Charles Lincoln. Mr. Lincoln has filed his Affidavits claiming Yosef
Taitz has demanded that Orly Taitz sign all her rights to the Assets over to him (Yosef
Taitz), see EXHIBITS “A” and “B”. California is a community property state. Any
judgment obtained against the Defendants is also collectible against the Defendants
spouse and their assets, even if not in the other party’s name. Also in California, as well
as many other states today, it is illegal to transfer ownership of property or assets when
the party knows there is pending litigation against them. See the Uniform Fraudulent
Transfer Act, Cal Civ Code § 3439, et sequitur.
Because there has been a threat of Taitz signing away her rights to the family
assets, which are valued at approximately Twenty-Five Million [$25,000,000.00] Dollars
and based on the award of statutory penalties pursuant to California Civil Code 1798, et
sequitur, Plaintiff Liberi’s award pursuant to statute alone against Taitz and DOFF is in
excess of Eight Hundred and Seventy Million [$870,000,000.00] Dollars for just one
count. Thus, Plaintiffs’ are relying on the assets owned by Taitz, DOFF and her spouse,
Yosef Taitz, in order to collect against any judgment granted by the Court. For these
reasons, it may be imperative for Plaintiffs’ to move the United States District Court,
Central District of California, Southern Division for an Ex Parte Order freezing all of
Taitz, DOFF and Taitz’s portion of her spouses Assets.
Sankey, Sankey Investigations, Inc., and the Sankey Firm, Inc. a/k/a the Sankey
Firm are licensed in California, conduct business in and are located in Southern
California. In addition, Plaintiff Liberi has been speaking with and learned the California
8
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9
licensing bureau of Private Investigators, the actions of Sankey through his corporations
are criminal in nature and therefore, Liberi was instructed to report Sankey’s illegal
actions to the County District Attorney where Sankey and his Corporations are located
and demand prosecution.
In addition, all the Defendants requested the within case be transferred to
California or Texas. Texas is an improper venue, however, venue is proper in both
Pennsylvania and the United States District Court, Central District of California,
Southern Division, located at 411 West Fourth Street, Santa Ana, CA 92701-4516 with
telephone number (714) 338-4750.
For the above aforementioned reasons, Plaintiffs’ respectfully request this
Honorable Court to Grant their Emergency Motion and Transfer the within action to the
United States District Court, Central District of California, Southern Division located
within South Orange County at 411 West Fourth Street, Santa Ana, CA 92701-4516 with
telephone number (714) 338-4750.

II. TRANSFER OF VENUE TO THE UNITED STATES DISTRICT
COURT, CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN
DIVISION IS PROPER IN THIS CASE:

In considering whether to grant venue transfer under 28 USCS § 1404(a), courts
engage in a two-part test: (1) whether action might have been brought in proposed
transferee forum; and (2) whether transfer promotes convenience and justice. Excelsior
Designs, Inc. v Sheres, 291 F Supp 2d 181 (E.D. NY 2003).
In a diversity action like this one, venue is proper "only in (1) a judicial district
where any Defendant resides, if all defendants reside in the same State, (2) a judicial
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10
district in which a substantial part of the events or omissions giving rise to the claim
occurred, or a substantial part of property that is the subject of the action is situated, or
(3) a judicial district in which any Defendant is subject to personal jurisdiction at the time
the action is commenced, if there is no district in which the action may otherwise be
brought." 28 U.S.C. §1391(a).
It is in the public and private interests that the Federal Laws be upheld pertaining
to venue and transfer of cases within the Federal Court systems. 28 U.S.C. §1404(a) only
provides for the transfer of a case where both the original and the requested venue are
proper. Jumara v. State Farm Ins. Co., 55 F.3d 873, 878.
Section 1404(a) transfers are discretionary determinations made for the
convenience of the parties and presuppose that the Court has jurisdiction and that the case
has been brought in the correct forum. Lafferty v. Gito St. Riel, 495 F.3d 72, 77 (3d Cir.
Pa. 2007) citing Jumara v. State Farm Ins. Co., 55 F.3d 873, 878 (3d Cir. 1995).
However, the moving party is not required to show truly compelling
circumstances for change of venue, but rather that all relevant things considered, the case
would be better off transferred to another district. Dominy v. CSX Transp., Inc., 2006
U.S. Dist. LEXIS 9422 (E.D. Pa. Mar. 9, 2006), supra., citing In re United States, 273
F.3d 380, 388 (3d Cir. 2001).
In determining whether to transfer a case, the court must first determine whether
the action "might have been brought" in the proposed transferee district. Banket v. GC
Am., Inc., 2005 U.S. Dist. LEXIS 23550 at *10 (E.D. Pa. Oct. 11, 2005), citing Van
Dusen, 376 U.S. at 616, 84 S. Ct. at 809. Assuming that this requirement has been
satisfied, which it has been herein, the court must then assess a number of private and
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11
public interest factors in addition to those enumerated in § 1404(a) (convenience of the
parties and witnesses and the interests of justice). Jumara v. State Farm Insurance
Company, 55 F.3d 873, 879 (3d Cir. 1995). Specifically, the private interests have
included: (1) the plaintiff's forum preference as manifested in the original choice; (2) the
defendant's choice of forum; (3) where the claim arose; (4) the convenience of the parties
as indicated by their relative physical and financial conditions; (5) the convenience of the
witnesses--but only to the extent that the witnesses may actually be unavailable for trial
in one of the fora; and (6) the location of books and records. In re Amendt, 169 Fed.
Appx. 93 at *8 (3d Cir. 2006), citing Jumara, at 879-80. The public interests have
included: (1) the enforceability of the judgment; (2) practical considerations that could
expedite or simplify trial; (3) the relative administrative difficulty in the two fora
resulting from court congestion; (4) the local interest in deciding local controversies at
home; (5) the public policies of the fora; and (6) in a diversity case, the familiarity of the
two courts with state law. Id. Rogal v. Skilstaf, Inc., 446 F. Supp. 2d 334, 336 (E.D. Pa.
2006).
It would be far easier for the United States District Court, Central District of
California; Southern Division to enforce any judgment’s obtained, as the bulk of the
Defendants assets are located in that Court’s jurisdiction. This particular Court that the
Plaintiffs’ are seeking the case to be transferred to is readily familiar with their own State
statutes, California Civil Code 1798, et sequitur, which the Plaintiffs’ rely upon. It is in
the public interest to see that California upholds its statutes when wrongs have been
committed; and the United States District Court, Central District of California, Southern
Division has the ability to expedite and/or simplify the trial.
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12
For the above aforementioned reasons, Plaintiffs’ respectfully request this
Honorable Court to Grant their Emergency Motion and Transfer the within action to the
United States District Court, Central District of California, Southern Division located
within South Orange County at 411 West Fourth Street, Santa Ana, CA 92701-4516 with
telephone number (714) 338-4750.

III. IT IS IMPERATIVE TO KEEP THIS CASE TOGETHER IN A
SINGLE LAWSUIT AS THE DEFENDANTS HAVE ALL SHARED
A COMMON SCHEME AND THEREFORE, THE ENTIRE
LAWSUIT SHOULD BE TRANSFERRED TO THE U.S. DISTRICT
COURT, CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN
DIVISION PURSUANT TO 28 U.S.C. SECTION 1404(a):

Determination of whether the claims or parties should be severed is more
appropriately made when the Court can determine which issues will go to trial, Miller v.
Hygrade Food Prods. Corp., 202 F.R.D. 142, 145 (E.D. Pa. 2001). To address this issue
now is simply premature because this action has not proceeded beyond the pleading
stage, and the Court has yet to sort out the intricacies of the relationships among the
Defendants’, United States v. Private Sanitation Indus. Ass’n of Nassau/Suffolk, Inc., 793
F. Supp. 1114, 1154 (E.D. N.Y. 1992). Indeed, although Plaintiffs strongly disagree, this
case could possibly develop so that Plaintiffs cannot prove that Defendants acted in a
common way; however, because the record is not fully developed, it is premature to
foreclose Plaintiffs from pursuing that opportunity. Foreman Indus., Inc. v. Gen. Motors
Corp., 34 B.R. 712, 715 (S.D. Ohio 1983).
The purpose of Rule 20(a) is to "promote trial convenience and expedite the final
determination of disputes, thereby preventing multiple law suits." 7 Charles Alan Wright,
et al., Federal Practice and Procedure § 1652 at 395 (3d ed. 2001); see also Formosa
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13
Plastics Corp., U.S.A. v. ACE Am. Ins. Co., 2009 U.S. Dist. LEXIS 71712 (D.N.J. Aug.
14, 2009) citing Mosley v. General Motors Corp., 497 F.2d 1330, 1332 (8th Cir. 1974)
(all 'logically related' events entitling a person to institute a legal action against another
generally are regarded as comprising a transaction or occurrence).
Courts generally apply a case-by-case approach in determining whether a
particular factual situation meets the same transaction or occurrence test. See 7 Charles
Alan Wright, et al., Federal Practice and Procedure § 1653 at 409 (3d ed. 2001); Blood v.
Fed. Bureau of Prisons, 2009 U.S. Dist. LEXIS 21529 (M.D. Pa. Mar. 17, 2009) citing
Mosley, 497 F.2d at 1333. The test mirrors the one applied under Federal Rule of Civil
Procedure 13(a), under which "'Transaction' is a word of flexible meaning. It may
comprehend a series of many occurrences, depending not so much upon the
immediateness of their connection as upon their logical relationship.'" Mosley, 497 F.2d
at 1333 (emphasis added) (quoting Moore v. New York Cotton Exchange, 270 U.S. 593,
610, 46 S. Ct. 367, 371, 70 L. Ed. 750 (1926)); see also In re University Med. Ctr., 973
F.2d 1065, 1086 (3d Cir. 1992) (recognizing logical relationship test under Rule 13(a)).
Identifying each event is not demanded. See Mosley, 497 F.2d at 1333; King v. Pepsi
Cola Metro. Bottling Co., 86 F.R.D. 4, at *6 (E.D. Pa. 1979).
Here, the Defendants’ all joined forces with Taitz to destroy Berg and destroy his
paralegal, Liberi and get rid of her and any other parties associated with Berg and Liberi.
All of the Defendants’ went after the Plaintiffs, due to their association with Berg and his
lawsuits and caused the Plaintiffs’ to suffer injuries.
Furthermore, none of the Defendants have raised the issue, cited or established
any legally cognizable prejudice as a result of hearing together all of the Plaintiffs’ claims
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14
against all of them responsibly for Plaintiffs’ injuries; however, there would be great
prejudice to the Plaintiffs. First, severance would be a tactical boon to all Defendants. If
the case is separated and tried in different locations, the Defendants’ would then point to
the other Defendants’ not named in those particular actions if these claims were not tried
together, leaving the jury wondering why a claim had not been brought against the other
Defendants. e.g., The case against Taitz and Sankey is separated and moved to California
while the case against the Hale Defendants is moved to Texas. First problem with this is
all the Plaintiffs’ would have to travel to three (3) different locations and Hale would
blame Taitz for the actions, which would cause the jury to wonder why the Plaintiff failed
to name Taitz. The permutations of this prejudice are boundless. The jury might give a
compromise verdict, in which case Plaintiffs would not get the full value of their
damages. Next, there are many parties who are willing to be witnesses against the
Defendants named herein. Severance of these claims would cause each of the witnesses
to have to be brought to Court three (3) or more times in different States to testify to a
pattern of facts and opinions, where experts are concerned, which are common to all
Defendants. Not to mention the fact, Plaintiffs’ witnesses would have to be deposed
three (3) times if the case is severed. This would triple all costs associated with
Plaintiffs’ witnesses.
Severance would cause inconvenience and prejudice to the parties, especially the
Plaintiffs’ and their witnesses. In addition, it would undermine Plaintiffs’ ability to
contest the Defense case, in light of the fact that this triplication would burden all the
witnesses and jurors as well as waste judicial resources.
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15
These are important reasons to try the case as a single, coherent whole, and
Plaintiffs’ urge the Court not to undermine that. Severance is an extraordinary procedure
and cannot be justified unless it will substantially further the ends of judicial economy,
prevention of delay and prejudice, and otherwise serve the ends of justice. This standard
has not been met in this case and therefore, the case should not be severed.
For the above aforementioned reasons, Plaintiffs’ respectfully request this
Honorable Court to Grant their Emergency Motion and Transfer the within action to the
United States District Court, Central District of California, Southern Division located
within South Orange County at 411 West Fourth Street, Santa Ana, CA 92701-4516 with
telephone number (714) 338-4750.

IV. CONCLUSION:
For the reasons stated herein, Plaintiffs’ respectfully request this Honorable Court
to grant their Emergency Motion and Transfer the entire case to the United States District
Court, Central District of California, Southern Division located in South Orange County
at 411 West Fourth Street, Santa Ana, CA 92701-4516 with telephone number (714) 338-
4750.
. Respectfully submitted,
Dated: November 29, 2009 _____________________________
Philip J. Berg, Esquire
Attorney for the Plaintiffs’
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
Identification No. 09867
(610) 825-3134


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EXHIBIT “A”
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Case 9:09-cv-81255-WPD Document 20 Entered on FLSD Docket 11/13/2009 Page 19 of 37 Case: 09-3403 Document: 00319959621 Page: 33 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 20 Entered on FLSD Docket 11/13/2009 Page 20 of 37 Case: 09-3403 Document: 00319959621 Page: 34 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 20 Entered on FLSD Docket 11/13/2009 Page 21 of 37 Case: 09-3403 Document: 00319959621 Page: 35 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 20 Entered on FLSD Docket 11/13/2009 Page 22 of 37 Case: 09-3403 Document: 00319959621 Page: 36 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 20 Entered on FLSD Docket 11/13/2009 Page 23 of 37 Case: 09-3403 Document: 00319959621 Page: 37 Date Filed: 12/27/2009
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EXHIBIT “B”
17
Case: 09-3403 Document: 00319959621 Page: 38 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 6 of 30
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA---PALM BEACH
MARSHA G. RIVERNIDER, §
ROBERT H. RIVERNIDER, §
CHARLES EDWARD LINCOLN, III, §
Plaintiffs, §
§
v. § Case No. 09-91255-CIV
§ HON. W.P. DIMITROULEAS
U.S. BANK NATIONAL ASSOCIATION, §
AS TRUSTEE FOR THE C-BASS §
MORTGAGE LOAN ASSET-BACKED §
CERTIFICATES, SERIES 2006-CBS, §
And all JOHN & JANE DOES 1-50 § AFFIDAVIT REGARDING
Defendants. § ALLEGATIONS OF FRAUD
§
§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§
AFFIDAVIT AND DECLARATION OF CHARLES EDWARD LINCOLN, III
1. My name is Charles Edward Lincoln, III. I am over the age of 18, of sound mind,
and have never been convicted of any crime of moral turpitude within the meaning of
Beltran-Tirado v. INS, 213 F.3d 1179, 1183 (9th Cir. 2000) and Quintero-Salazar v.
Keisler, 506 F.3d 688 (9th Cir. 2007); I write this affidavit from personal knowledge.
2. I have a J.D. from the University of Chicago in addition to a Ph.D. from Harvard
University and am a former judicial law clerk to the Honorable Kenneth L. Ryskamp in
this United States District Court for the Southern District of Florida, having applied for
my clerkship in March 1991 and completed my term in September 1993.
3. I was later disbarred due to a December 1999 indictment, which I can only call
politically motivated and unjust, although I take full responsibility for my own errors. I
also apologize to this United States District Court, and in particular to the Honorable
Kenneth L. Ryskamp, for the dishonor my misfortunes may have brought to this court, in
the past and at the present time, by my failures and indiscretions, especially in light of the
honor which Judge Ryskamp bestowed upon me by hiring me as his law clerk.
4. Dr. OrIy Taitz was aware of all details of my background, and in May 2009, hired
me to work with her as a consultant and law clerk on a series of cases relating to the
Affidavit of Charles Edward Lincoln, III, in Response to Order to Show Cause, 1
Document 21, Dated November 13,2009, regarding promised legal representation
in this Case by Dr. Orly Taitz, Esquire
Case: 09-3403 Document: 00319959621 Page: 39 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 7 of 30
Article II Constitutional eligibility of the current President of the United States, Barack
H. Obama. I continued to work with her through November 4,2009.
5. I prepared all the documents, which Dr. Taitz signed in this case, as I have been
preparing almost all (approximately 95-98%) the documents she has signed in all of her
recent cases pending in Federal court in any and every state where she has appeared. I
never caused any papers to be filed, in this or any other case, which she had not approved
and signed or authorized to be electronically signed or submitted.
6. I was responsible for delivering all papers in this case to Robert H. Rivernider for
filing. I certainly never gave him any documents, which I knew or suspected to be
fraudulent in any way, shape or form.
7. I never knowingly submitted any false documents to this Court nor did I submit
any documents I had any imaginable reason to believe were false. I submitted every
document signed by Orly Taitz or any other person only in the belief that these were
legitimate documents.
8. Our agreement was a mixture of pay plus exchange of services. Since I am no
longer a licensed attorney I have been involved in real estate management and mortgage
finance. Dr. Orly Taitz agreed to represent me as legal counsel
9. What has happened here is that, much to our mutual discomfort I am sure, Orly
Taitz and I had an intense but adulterous love affair, which continued until November 4,
2009. I can say nothing in our defense except that I fell in love with Dr. Taitz and she
repeated on dozens of occasions that she loved me, but could not leave her husband
because she did not want to lose "her children and her life."
10. I am not proud of these facts, but put together they constitute the simple if
unremarkably tawdry background against which Dr. Taitz' behavior and accusations
against me/all the Plaintiffs in this case must be judged and evaluated.
Affidavit ofCharles Edward Lincoln, III, in Response to Order to Show Cause, 2
Document 21, Dated November 13,2009, regarding promised legal representation
in this Case by Dr. Orly Taitz, Esquire
Case: 09-3403 Document: 00319959621 Page: 40 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 8 of 30
11. Dr. Taitz terminated our relationship in the aftermath of the October 12, 2009,
disclosures made by one Lucas Daniel Smith on the internet which in rather grotesquely
vulgar and sensationalistic manner revealed my love affair with Dr. Taitz to the world,
and not coincidentally, to arly's husband Yosef Taitz, whom arly has consistently
described to me as viciously controlling, verbally, and emotionally abusive, he is the kind
of husband who will not allow his wife to speak freely at the dinner table or in front of
her children or guests, and who becomes violently angry if his wife is not at home by
sunset on the Sabbath for family/home prayer.
12. I provided copies of my affidavit to both Dr. Taitz and her attorney Dr. Jonathan
H. Levy of Hilton Head, South Carolina and Washington.
13. Dr. Levy warned me that I could expect "strong and vengeful" action from Dr.
Taitz' when I spoke to him last on Thursday, November 12, 2009, although he did not
condone such acts, and specifically qualified that he had absolutely nothing to do with
Dr. Taitz' prior letter to this Court Noted "Received" at Docket Entry 1 in this case.
14. I have no other explanation for what Dr. Taitz is doing in this case, but I will give
the following opinions:
15. Dr. Taitz' letters to the court and her Sunday November 15, 2009, communication
to me bye-mail (a true and correct copy of which is attached as Exhibit A), are the acts of
an extremely unhappy woman who got caught having an adulterous love affair by her
husband and the entire world at the moment of maximum political and public exposure in
her entire life.
16. Dr. Kathy Garcia-Lawson's separate affidavit submitted alongside this one
addresses the concerns raised in Dr. Taitz' E-mail.
17. Neither my affair with Dr. arly Taitz nor anything else which I have done
constitutes a fraud on this court, nor any other court, nor any reason for the Court to
dismiss my Complaint jointly filed with Robert H. and Marsha G. Rivernider.
Affidavit ofCharles Edward Lincoln, III, in Response to Order to Show Cause, 3
Document 21, Dated November 13,2009, regarding promised legal representation
in this Case by Dr. Orly Taitz, Esquire
Case: 09-3403 Document: 00319959621 Page: 41 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 9 of 30
18. It is terribly embarrassing and a professional disgrace when personal lives intrude
themselves upon Court Judicial Proceedings.
19. If this Court feels that the events have in any way colored this Court's perception
of the parties or ability to judge the facts of the case between the Plaintiffs and the
Defendants impartially, or if the Court feels that it will be prejudiced against the
Plaintiffs because of my and Dr. Taitz' love affair, which had NOTHING whatsoever to
do with the validity of a mortgage or assignments between US BANK, Robert H. and
Marsha G. Rivernider, and Charles Lincoln, this Court should consider recusal rather
than dismissing the case.
20. As undignified, unprofessional, and unseemly as this Plaintiffs exchange with
Dr. Taitz may seem, it is merely reflective (at the absolute worst) of this Plaintiffs and
Dr. Taitz' emotional immaturity in the handling of their personal lives, and do not reflect
on ANY of the other matters raised in Plaintiffs' Response to the Court's Second Order
to Show Cause and the Defendant's Motion to Dismiss in any way, shape or form.
Further affiant sayeth naught.
Signed, declared under penalty of perj , and executed in Palm Beach Gardens,
Florida, on this Monday the 16
th
day of No ember,

arIes Ed ara co n, III
c/o Peyton Yates Freiman
603 Elmwood Place, Suite #6
Austin, Texas 78705
Telephone: 512-968-2500
E-mail: charles.lincoln@rocketmail.com
Alternative Address:
c/o Kathy Ann Garcia-Lawson
2620 Nature's Way
Palm Beach Gardens, Florida 33410
Telephone: 512-968-2500/512-923-1889
Facsimile: 561-691-1423
Affidavit ofCharles Edward Lincoln, III, in Response to Order to Show Cause, 4
Document 21, Dated November 13,2009, regarding promised legal representation
in this Case by Dr. Orly Taitz, Esquire
Case: 09-3403 Document: 00319959621 Page: 42 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 10 of 30
NOTARY'S JURAT
Charles Edward Lincoln, III, appeared in person before me on this Monday the
16
th
day of November, 2009, in Palm Beach Gardens, Florida, and having been by me
duly sworn upon his oath he did verify the truth of all the statements of fact set forth
above, and did declare and acknowledge the statements of opinion made above and the
sincerity of their submission to the Court.
I am an officer authorized to administer oaths and take testimony under the laws
of the State of Florida, my principle place of bus' eing in Palm Beac County,
Florida.
ALEJANDROVERA
Notary Public, State 01 Florida
Commisslon#00812909
My comm. expires Aug. 7, 2012
Printed Name o_ __={)._(£_-f)p_'__ _
Business AddresscQ)'"dS RL-IJ.u fBC Ft,. S34/(J
My Commission Expires:
)
Affidavit ofCharles Edward Lincoln, III, in Response to Order to Show Cause, 5
Document 21, Dated November 13,2009, regardingpromised legal representation
in this Case by Dr. Orly Taitz, Esquire
Case: 09-3403 Document: 00319959621 Page: 43 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 11 of 30
Exhibit A:
Sunday, November 15,2009
E-Mail from
Dr. Orly Taitz, Esquire
Affidavit ofCharles Edward Lincoln, III, in Response to Order to Show Cause, 6
Document 21, Dated November 13,2009, regarding promised legal representation
in this Case by Dr. Orly Taitz, Esquire
Case: 09-3403 Document: 00319959621 Page: 44 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 12 of 30 Drucken
Von: Dr. Orly Taitz ESQ (dr_taitz@yahoo.com)
An: Charles Lincoln
Datum: Sonntag, den 15. November 2009,9:45:01 Uhr
Betreff: Charles, you need to see a doctor and your case needs to be stayed pending tr-nt
Page 1 of 1
Charles,
I received your two phone messages. In the first message your speech was extremely blurry, unclear, second message
sounded like you were a different person.
I believe that you need urgent evaluation and treatment by a psychiatrist. All of your behavior as of late, all of the e-
mails to me, my husband and my attorney suggest the same. You are hurting me, my husband, my children, your wife,
your son, Rverniders and yourself
I am sending a declaration to judge Dimitrious in FL, letting him know, that I believe you are in need of urgent
psychiatric evaluation and possibly treatment, and I believe that case needs to be stayed pending your evaluation and
treatment.
Dr. Orly Taitz ESQ
29839 Santa Margarita Pkwy ste 100
Rancho Santa Margarita Ca 92688
ph. 949-683-5411
fax 949-766-7603
orlytaitzesq.com
drtaitz.com
taitzofficesuites.com
http://de.mg41.mai1.yahoo.com/dc/launch?.gx=1&.rand=17q8i4v26j71i 11/15/2009
Case: 09-3403 Document: 00319959621 Page: 45 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 13 of 30
AFFIDAVIT NUMBER 2:
Dr. Kathy Ann Garcia-Lawson, Ph.D.
Marsha G. Rivernider, Robert H. Rivernider, Charles Edward Lincoln, III v.
U.S. Bank, NA., Combined Response to Second Order to Show Cause Filed 11-02-09 and Motion to 6
Dismissedfiled 9-24-09, with reservation ofPlaintiffs' Rights to File Motion to Convert 12(b)(6) to
Rule 56MSJ
Case: 09-3403 Document: 00319959621 Page: 46 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 14 of 30
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA---PALM BEACH
v.
MARSHA G. RIVERNIDER,
ROBERT H. RIVERNIDER,
CHARLES EDWARD LINCOLN, III,
Plaintiffs,
U.S. BANK NATIONAL ASSOCIATION,
AS TRUSTEE FOR THE C-BASS
MORTGAGE LOAN ASSET-BACKED
CERTIFICATES, SERIES 2006-CBS,
And all JOHN & JANE DOES 1-50
Defendants.
§
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§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§
Case No. 09-91255-CIV
HON. W.P. DIMITROULEAS
Affidavit of Psychologist
Regarding Charles E. Lincoln
AFFIDAVIT OF DR. KATHY GARCIA-LAWSON
1. My name is Kathy Ann Garcia-Lawson. I am over the age of 18 and
otherwise competent to make this affidavit.
2. I received a Ph.D. from Nova Southeastern University in Clinical Psychology
where I also completed a one year postdoctoral specialty in psychoanalytic psychology
and technique followed by a two year postdoctoral residency at 45
th
Street Mental Health
Center in West Palm Beach, Florida (now called "Oakwood").
3. A true and correct (if slightly out of date) copy of my vita is attached as
Exhibit B to this Affidavit.
4. Since 1995 I have engaged in the private practice of clinical psychology with
my current office location at 2401 PGA Boulevard, Suite 128, Palm Beach Gardens,
Florida 33410.
5. I have known Charles Edward Lincoln, III, since Saturday, May 11,2008,
when he called me to discuss my concerns regarding rampant abuses in the Family Law
Courts and in Family Law/Divorce/Child Custody systems generally.
6. I consider him to be a good-hearted, honorable, and trustworthy man, as well
as a competent and well-read student of the law and constitutional history and theory.
Affidavit ofDr. Kathy Ann Garcia-Lawson, Ph.D. in Support ofCharles Lincoln's 1
Response to Order to Show Cause, Document 21, Dated November 13,2009,
regarding promised legal representation in this Case by Dr. Orly Taitz, Esquire
Case: 09-3403 Document: 00319959621 Page: 47 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 15 of 30
7. I am perfectly aware of his background and status as a disbarred attorney, but
in some ways, I think his background makes him more useful and trustworthy than many
licensed attorneys who cannot criticize the system because they depend upon it and are
part of it.
8. One of my past attorneys, Montgomery Blair Sibley, was suspended in both
the District of Columbia and Florida, as well as threatened with disbarment, because of
his criticism of the judiciary and the unconstitutional operation of the Family Courts
which routinely deny due process of law in an arbitrary and capricious manner, to the
great injury of spouses and children all over the United States.
9. In January-May of2009, I became interested in the work of Dr. Orly Taitz
against the constitutional eligibility of President Barack H. Obama. I made contact with
Dr. Taitz who indicated that she lacked competent assistance in her litigation, whose end
goal of removing the President I supported on moral, philosophical, and political
grounds, and I suggested to her that she contact Charles Lincoln and see whether they
could work together, which they quickly began to do.
10. Sometime in early-mid July 2009, Charles Lincoln confided to me in a late-
night telephone call that he was involved in a very intense love affair with Orly Taitz as
well as working for her constantly to the exclusion of everything else in his life. Charles
said that he had been very lonesome since he separated from his wife Elena in late July
2002, and that Orly had made him "feel alive" and he believed that they could work
together and accomplish things he could never do on his own.
11. Although he was calling me and updating me as a friend, that night Charles
Lincoln at that time said that he was very disturbed by the events, which had transpired
with Orly, a married woman, and requested that I advise him as a psychologist. I spoke
to Charles about Orly about 3-4 times a week after that, sometimes more.
Affidavit ofDr. Kathy Ann Garcia-Lawson, Ph.D. in Support of Charles Lincoln's 2
Response to Order to Show Cause, Document 21, Dated November 13, 2009,
regarding promised legal representation in this Case by Dr. Orly Taitz, Esquire
Case: 09-3403 Document: 00319959621 Page: 48 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 16 of 30
12. Charles has also come to visit me in Palm Beach Gardens on three separate
occasions since this started, and Orly is always on his mind, as are his concerns with their
relationship.
13. I should make it clear that Charles was never a formal patient of mine, never
paid me for services, and I consider our relationship still to be that of friends rather than
doctor-patient. I counseled him professionally as ifhe were a patient of mine, but more
informally than formally, as I would do to any friend in need.
14. I did my best to advise Charles to terminate his relationship with Orly, after
all I am an advocate for Christian marriage and monogamy.
15. I had the opportunity to travel to Orange County, California, on the weekend
of October 2-6 in Orange County, California, and did spend some time meeting with Orly
and Charles as they worked together on the Obama litigation.
16. Charles had asked for my professional observations concerning the
authenticity of Orly' s feelings towards him.
17. I, like others close to Charles, were gravely concerned about the sincerity of
Orly's involvement with Charles or whether she was taking advantage of a lonely man in
exchange, quid pro quo, of his drafting of her pleadings.
18. I have no personal knowledge of any of the papers passing between Charles
and Orly in this case or any other case, but I cannot imagine any reason why Charles
would have needed to falsify documents from Orly because they worked together, very
intensely, for five months and I know he wrote more documents which she signed than
she ever wrote on her own, by a very dramatic factor.
19. Charles copied me on almost everything he wrote for Orly, including his legal
research for her, and his output was nothing less than prodigious. I was concerned for his
well-being and his general health because Orly's demands on him sometimes seemed
excessive.
Affidavit ofDr. Kathy Ann Garcia-Lawson, Ph.D. in Support of Charles Lincoln's 3
Response to Order to Show Cause, Document 21, Dated November 13,2009,
regarding promised legal representation in this Case by Dr. Orly Taitz, Esquire
Case: 09-3403 Document: 00319959621 Page: 49 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 17 of 30
20. I have read arly's Sunday Novmeber 15,2009, e-mail attached as Exhibit A
to this affidavit and in my professional opinion, this tum of events seems to be rooted in
vindictiveness and hostility, and I find it suspect thatfher conduct and actions have so
radically changed in the immediate aftermath of the October 29,2009, dismissal of the
Obama case before Judge Carter's case.
21. I have wondered whether arly's involvment with Charles was strictly a result
of her interest in using him on the Obama case, and I think that arly may have been
"leading Charles" on and that she never really intended to follow through on her
commitments to the mortgage litigation.
22. In my time of knowing Charles I have found him always to be forthright and
honest in a genuine and caring individual.
23. I would be happy to testify on his behalf or elaborate upon this affidavit in
response to any questions which the Court might have in the future.
24. I find it quite unfortunate that this inappropriate and personal relationship has
found its way to contaminate a significant case such as the present one, but I agree that
Charles had the need to be forthcoming and truthful regarding all the circumstances
bearing on his defense against arly's charges.
25. It is my professional opinion that Charles Edward Lincoln suffers from no
psychological disorders, excluding possible occasional mild depression brought on by
loneliness, and I see no cause to recommend him for psychiatric evaluation of any kind.
26. I have also met Bob Rivemider and nothing in my observation of either
Lincoln or Rivemider suggests to me that they were likely to have been attempting to
falsify Orly's involvement in this case in any way. I am aware that Orly did appear or
attempt to appear in several other cases for Charles E. Lincoln involving mortgages and
real-estate around the United States.
Further affiant sayeth naught.
Affidavit ofDr. Kathy Ann Garcia-Lawson, Ph.D. in Support of Charles Lincoln's 4
Response to Order to Show Cause, Document 21, Dated November 13,2009,
regarding promised legal representation in this Case by Dr. Orly Taitz, Esquire
Case: 09-3403 Document: 00319959621 Page: 50 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 18 of 30
Signed, declared under penalty of perjury, and executed in Palm Beach Gardens,
Florida, on this Monday the 16
th
day of November, 2009.
B
()
" / ,}/1P .
Y -r-.';,-'..:::o.._'1,-"U=,,--vl..-;:::',..---:;:(,:;:-t:.(.&_'.:....t-.:..../'-- __
Kathy Ann Gar . -Lawson, Ph.D.
2401 PGA Boulevard, Suite 128
Palm Beach Gardens, Florida 33410
Office Telephone: 561-694-2772
Facsimile: 561-691-1423
NOTARY'S JURAT
Kathy Ann Garcia-Lawson appeared in person before me on this Monday the 16
th
day of November, 2009, in Palm Beach Gardens, Florida, and having been by me duly
sworn upon her oath she did verify the truth of all the statements of fact set forth above,
and did declare and acknowledge the statements of her professional opinion made above
and the sincerity of their submission to the Court.
I am an officer authorized to administer oaths and take testimony under the laws
of the State of Florida, my principle place of business being in Palm Beach /ounty,
Florida.
ALEJANDROVERA
Notary Public, State of Florida
Commission, 00812909
My oomm. ellplres Aug. 7, 2012
Printed Name of Notary: I/If3,Y19/J JOd tZJ2A
Business Address: d50S fG-4. Wi) 'Pes:;. Pc- 33£//0
My Commission Expires:_--,-.t1.....;O<:::........:=G-,,-'-<l-7+-'..... _
Affidavit ofDr. Kathy Ann Garcia-Lawson, Ph.D. in Support ofCharles Lincoln's 5
Response to Order to Show Cause, Document 21, Dated November 13,2009,
regarding promised legal representation in this Case by Dr. Orly Taitz, Esquire
Case: 09-3403 Document: 00319959621 Page: 51 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 19 of 30
Exhibit A:
Sunday, November 15, 2009
E-Mail from
Dr. Orly Taitz, Esquire
Affidavit ofDr. Kathy Ann Garcia-Lawson, Ph.D. in Support ofCharles Lincoln's 6
Response to Order to Show Cause, Document 21, Dated November 13,2009,
regarding promised legal representation in this Case by Dr. Orly Taitz, Esquire
Case: 09-3403 Document: 00319959621 Page: 52 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 20 of 30 Drucken
Von: Dr. Orly Taitz ESQ (dr_taitz@yahoo.com)
An: Charles Lincoln
Datum: Sonntag, den 15. November 2009,9:45:01 Uhr
Betreff: Charles, you need to see a doctor and your case needs to be stayed pending tr-nt
Page 1 of 1
Charles,
I received your two phone messages. In the first message your speech was extremely blurry, unclear, second message
sounded like you were a different person.
I believe that you need urgent evaluation and treatment by a psychiatrist. All of your behavior as of late, all of the e-
mails to me, my husband and my attorney suggest the same. You are hurting me, my husband, my children, your wife,
your son, Rverniders and yourself
I am sending a declaration to judge Dimitrious in FL, letting him know, that I believe you are in need of urgent
psychiatric evaluation and possibly treatment, and I believe that case needs to be stayed pending your evaluation and
treatment.
Dr. Orly Taitz ESQ
29839 Santa Margarita Pkwy ste 100
Rancho Santa Margarita Ca 92688
ph. 949-683-5411
fax 949-766-7603
orlytaitzesq.com
drtaitz.com
taitzofficesuites.com
http://de.mg41.mail.yahoo.com/dc/launch?.gx=1&.rand=17q8i4v26j7li 11/15/2009
Case: 09-3403 Document: 00319959621 Page: 53 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 21 of 30
Exhibit B:
Professional Vita
Kathy Ann Garcia-Lawson, Ph.D.,
In Psychology with specialty
In Psychoanalytic Technique
Affidavit ofDr. Kathy Ann Garcia-Lawson, Ph.D. in Support of Charles Lincoln's 7
Response to Order to Show Cause, Document 21, Dated November 13,2009,
regarding promised legal representation in this Case by Dr. Orly Taitz, Esquire
Case: 09-3403 Document: 00319959621 Page: 54 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 22 of 30
VITA
Kathy Ann Garcia-Lawson, Ph.D.
A. Personal Data
Address:
Telephone:
DOB:
2620 Natures Way, Palm Beach Gardens, Florida 33410
561.624.8725
February 4, 1958
B. Educational Background
1.
2.
3.
4.
5.
Montclair State College, Upper Montclair, NJ 07043
Major: Psychology
Minor: Counseling, Human Services and Guidance
Nova Southeastern University, Ft. Lauderdale, FL 33314
Major: Counseling Psychology
Major: School Guidance and Counseling
Nova Southeastern University, Ft. Lauderdale, FL 33314
Ph.D. - Clinical Psychology
Advanced Training: Psychoanalytic Psychotherapy Program
Nova Southeastern University, Ft. Lauderdale, FL 33314
Family and County Court Mediation Training
Broward County Bar Association, Ft. Lauderdale, FL 33314
B.A. 1982
M.S. 1990
M.S. 1990
Ph.D. 1995
1996
10-12-04
C. Professional Membership
American Psychological Association
D. Current Position
Private Practice in Clinical Psychology
2401 PGA Boulevard, Ste.128, Palm Beach Gardens, FL 33410
E. Clinical Experience
1992-Present
1995- Present
1.
2.
Essex Rehabilitation Center, Verona, NJ Group
Therapy with dually diagnosed patients.
Glenbeigh Hospital of the Palm Beaches, West Palm Beach, FL
Group psychotherapy with adolescents with eating disorders and
substance abuse problems.
1
1981-1982
1988-1989
Case: 09-3403 Document: 00319959621 Page: 55 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 23 of 30
Clinical Experience (continued).
3.
4.
5.
Humana Hospital West Palm Beach, FL
Group psychotherapy with adolescents in a long-term residential
psychiatric program. Group and individual psychotherapy with
geriatric patients in short-term facility. Provided crisis intervention to
adults.
Nova University Comm. Mental Health Clinic, Coral Springs, FL
Dual Diagnosis Program: Provided individual short-term and long-
term psychotherapy. Intake interviewing, treatment planning,
testing, and evaluation of patients.
45
th
Street Mental Health Center, West Palm Beach, FL
Provided individual and group psychotherapy to adolescents and
adults in both out-patient and in-patient facilities. Treatment
planning, testing, and evaluation was conducted. Provided
individual and family therapy to school-age children through
contract with Palm Beach Board of Education.
1989-1990
1992-1993
1993-1996
F. Teaching Experience
1.
2.
3.
4.
Palm Beach School Board, West Palm Beach, FL (ESE)
Embry Riddle Aeronautical University (Psychology Classes)
Palm Beach Community College (Psychology Classes) Barry
University (Psychology Classes)
1988-1990
1992
1990-1994
1994
G. Administration
1. Developed the psycho-educational program at Glenbeigh Hospital.
2. Editor for Books and Article Reviews for Southeast Florida Association
for Psychoanalytic Psychotherapy (SEFAPP) Newsletter.
3. Grant proposal for prevention ofjuvenile delinquency.
4. Consultant to Florida's Commission on Marriage and Family Initiatives-Cited
as a consultant in the Commission's Report, Is No-Fault at Fault?, released
March, 2008.
H. Dissertation
The Effects ofthe Sudden Death ofa Psychotherapist on Patients
I. Publications
Garcia-Lawson, Kathy (1997). Thoughts on Termination - Practical Considerations:
Journal of Psychoanalytic Psvchology, 14(2),239-257.
Garcia-Lawson, Kathy (2000), Sudden Death ofthe Therapist: Effects on the Patient:
Journal of Contemporary Psychotherapy, 30(1) 85-103.
Non-published: Family Law
Garcia-Lawson, Kathy, Baker, Josiah, and Posthumus, Stanley, (2006) Protecting
Florida Families- Ending the Divorce Epidemic: A Social Disease. Presented to the
Childrens Rights Council, November, 2006 in Washington DC and at the State of
Case: 09-3403 Document: 00319959621 Page: 56 Date Filed: 12/27/2009
Case 9:09-cv-81255-WPD Document 22 Entered on FLSD Docket 11/17/2009 Page 24 of 30
Florida South Legislative Meeting.
J. Areas of Research/Interest: Activist in Safeguarding Marriage and Family.
K References
Available Upon Request.
2
Case: 09-3403 Document: 00319959621 Page: 57 Date Filed: 12/27/2009
Z:\Liberi Motion to Transfer Venue to South Orange County, CA 11 28 09
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, et al,
Plaintiffs,
vs.

ORLY TAITZ, et al,
Defendants.
:
:
:
:
:
:
:
:
:
:





Case No.: 09-cv-01898-ECR



CERTIFICATE OF SERVICE

I, Philip J. Berg, Esquire, hereby certify that a copy of Plaintiffs’ Emergency
Motion to Transfer Venue to the U.S. District Court, Central District of California,
Southern Division was served this 29
th
day of November 2009 electronically upon the
following:

Orly Taitz
Defend our Freedoms Foundation, Inc. (unrepresented)
26302 La Paz Ste 211
Mission Viejo, CA 92691
Email: dr_taitz@yahoo.com

Neil Sankey
The Sankey Firm, Inc. a/k/a The Sankey Firm (unrepresented)
Sankey Investigations, Inc.
2470 Stearns Street #162
Simi Valley, CA 93063
Email: nsankey@thesankeyfirm.com



18
Case: 09-3403 Document: 00319959621 Page: 58 Date Filed: 12/27/2009
Z:\Liberi Motion to Transfer Venue to South Orange County, CA 11 28 09
Linda Sue Belcher
201 Paris
Castroville, Texas 78009
Email: Newwomensparty@aol.com and
Email: starrbuzz@sbcglobal.net


Ed Hale
Caren Hale
Plains Radio
KPRN
Bar H Farms
1401 Bowie Street
Wellington, Texas 79095
Email: plains.radio@yahoo.com; barhfarms@gmail.com;



________________________
PHILIP J. BERG, ESQUIRE













ed@barhfarms.net; and ed@plainsradio.com
19
Case: 09-3403 Document: 00319959621 Page: 59 Date Filed: 12/27/2009

























EXHIBIT “C”
Case: 09-3403 Document: 00319959621 Page: 60 Date Filed: 12/27/2009
UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

09-3403

Lisa Liberi, et al v. Orly Taitz, et al

2:09-cv-01898

BRIEFING AND SCHEDULING ORDER


It is ORDERED that the brief for Appellant(s) and the joint appendix shall be filed
and served on or before January 8, 2010.

It is FURTHER ORDERED that the brief(s) for Appellee(s) shall be filed and
served on or before January 15, 2010.

It is FURTHER ORDERED that a reply brief, if any, shall be filed and served on
or before January 19, 2010.

It is FURTHER ORDERED that in the event of default by Appellant in filing the
brief and appendix as directed, the appeal may be dismissed without further notice.

It is FURTHER ORDERED that If Appellee fails to file a brief within the time
directed, the matter will be listed on Appellant(s) brief only and Appellee(s) may
be subject to such sanctions as the court deems appropriate.

It is noted that, where applicable, parties must comply with 3
rd
Cir. LAR 31.2
which provides: A local, state or federal entity or agency, which was served in
the district court and which is the appellee, must file a brief in all cases in which a
briefing schedule is issued unless the court has granted a motion seeking
permission to be excused from filing a brief. The rule does not apply to entities or
agencies that are respondents to a petition for review unless the entity or agency is
the sole respondent or to entities or agencies which acted solely as an adjudicatory
tribunal.

This Court requires the filing of briefs by counsel in both electronic and paper
format. 3
rd
Cir. LAR 31.1(b). Pro se litigants are exempt from the electronic filing
requirement. Appendices are not required to be filed electronically.
Case: 09-3403 Document: 00319959621 Page: 61 Date Filed: 12/27/2009
Checklists regarding the requirements for filing a brief and appendix are available
on the Court’s website at www.ca3.uscourts.gov.


For the Court,



_______________________________



Dated: ______________, 20____



cc: Philip J. Berg, Esq. Counsel for the Appellants
Appellee Orly Taitz, Esq. in Pro Se
Appellee Defend our Freedoms Foundations, Inc. c/o Orly Taitz
Appellee Neil Sankey in Pro Se
Appellee Sankey Investigations, Inc. c/o Neil Sankey
Appellee The Sankey Firm, Inc. a/k/a The Sankey Firm c/o Neil Sankey
Appellee Edgar Hale, et al in Pro Se
Appellee Caren Hale in Pro Se
Appellee Plains Radio Network, et al c/o Edgar and Caren Hale
Appellee KPRN AM 1610 c/o Edgar and Caren Hale
Appellee Bar H Farms c/o Edgar and Caren Hale
Appellee Linda Sue Belcher, et al in Pro Se
Case: 09-3403 Document: 00319959621 Page: 62 Date Filed: 12/27/2009


U.S. District Court,
Court of Appeals Case No. 09-3403

UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
_____________
Ο

_____________

LISA LIBERI, et al,
Petitioner – Appellant,
v.
ORLY TAITZ, et al,
Respondents – Appellee.
_____________
Ο

_____________
CERTIFICATE OF SERVICE
_____________________

I, Philip J. Berg, Esquire, hereby certify that Appellants’ Emergency Motion
to Expedite Appellants Appeal and Ruling on Appellants Emergency Motion for a
Temporary Restraining Order and/or Injunction was served via email this 27
th
day
of December, 2009 upon the following:

Orly Taitz
Defend our Freedoms Foundation, Inc. (unrepresented)
26302 La Paz Ste 211
Mission Viejo, CA 92691
Email: dr_taitz@yahoo.com
Eastern District of Pennsylvania Case Number: 09-cv-01898-ECR
Case: 09-3403 Document: 00319959621 Page: 63 Date Filed: 12/27/2009




Neil Sankey
The Sankey Firm, Inc. a/k/a The Sankey Firm (unrepresented)
Sankey Investigations, Inc.
2470 Stearns Street #162
Simi Valley, CA 93063
Email: nsankey@thesankeyfirm.com


Linda Sue Belcher
201 Paris
Castroville, Texas 78009
Email: Newwomensparty@aol.com and
Email: starrbuzz@sbcglobal.net

Ed Hale
Caren Hale
Plains Radio
KPRN
Bar H Farms
1401 Bowie Street
Wellington, Texas 79095
Email: plains.radio@yahoo.com;
barhfarms@gmail.com and ed@barhfarnet






Philip J. Berg, Esquire
Attorney for Appellants’
s/ Philip J. Berg
Case: 09-3403 Document: 00319959621 Page: 64 Date Filed: 12/27/2009

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