Liberi V Taitz Appellees Exb E - Affd of Waddell To Their Emergency Motion For A TRO

Case: 10-3000 Document: 003110370449 Page: 1 Date Filed: 12/06/2010
EXHIBIT "E"
Case No. 10-3000
_______________________________________________________
UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
_______________________________________________________
LISA LIBERI, et al,
Plaintiffs’ – Appellees’,
v.
ORLY TAITZ, et al,
Respondents’ – Appellants’.
______________________________________________________
On Appeal from the U.S. District Court, Eastern District of Pennsylvania,

Case No. 09-cv-01898 ECR
Judge Eduardo C. Robreno
____________________________________________________
AFFIDAVIT OF SHIRLEY WADDELL
Philip J. Berg, Esquire

Pennsylvania I.D. 9867
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
Ph: (610) 825-3134
Fx: (610) 834-7659
Email: philjberg@gmail.com
Attorney for Appellees

AFFIDAVIT OF SHIRLEY WADDELL
I, Shirley Waddell, am over the age of eighteen (18) and am not a party to
the within action. I have personal knowledge of the facts herein and if called to do
so, I could and would competently testify under oath.
I declare as follows:
1. November 10th, 2010 my daughter Lisa Liberi (hereinafter Liberi)
received an email on her computer AOL account addressed from:
“convictedfelon@lisaliberi.com". In this email someone had written a message
that asked Liberi how she liked her new website, see EXHIBIT "1". Someone
had set up a Domain/Website/Email account in my daughter’s name without her
permission. There were different postings in different categories/articles that
had been set up.
 One category “I just received a fabulous gift”, was regarding

Liberi getting a gift from a Judge to protect her knees when she
performed sex acts on the Judges at parties.
 One category “It was Lisa” had a picture of Jerry Falwell that
said in part: “I wasn’t screwing my grandmother in the
outhouse, I was screwing Lisa”.
 One category “Fabulous Felon Resume” related to a rap sheet

with different and erroneous dates of arrests to make it appear
that Liberi had a long, continuous arrest record with many
convictions.
 One category “I’m so glamorous” classified Liberi with a

group of women serial killers.
1
 One category “A great woman!” Compared Liberi to llse

Koch as told by Herr Dr. Josef Mengele aka “Angel of Death”
in the nazi concentration camps. Taken from wikipedia.
 One category Me! Me! All about me! Was supposed to be

Liberi talking about her life, marriage etc. Which was actually
copied from the life of llse Koch in Wikipedia. Please see
http://en.wikipedia.org/wiki/Ilse_Koch. They wrote how Liberi
enjoyed abusing the prisoners, and watched, as they would rape
one another.
2. Other Websites picked up on this disgusting, offensive, vulgar website
of http://lisaliberi.com very fast. Whois is an Internet directory service for
looking up names of people on a remote server. At first Whois said that the
registration was private. After this matter was cleared up and when the
“website paperwork" first started coming in, it showed on the paperwork from
Whois that it was Geoff Staples [hereinafter at times "Staples"] that set up the
website http://lisaliberi.com with a fake address of 123 Secret Dr. As the
paperwork kept coming in from Whois it showed that the account had been
originally set up in the name of Lisa Liberi by Geoff Staples. The response
from the PDR (Public Domain Registration) showed that the Registration
Service Provider was Nairobi Web Host. Registrant was Hostricity Web
Hosting at 3883 Turtle Creek Blvd., Suite 205, Dallas Texas 75219 U. S. A.
Geoffrey Tyler Staples owns Hostricity Web Hosting. As of the date of this
affidavit, we are still waiting for more paperwork on this
Domain/Website/Email.
2
3. The written contents within the category/articles are changed from
time to time by Staples, Belcher and Taitz. A Detective from Dallas PD has
already talked to Staples, and Staples admitted that all three of them (Linda
Belcher [hereinafter at times "Belcher"], Orly Taitz [hereinafter at times
"Taitz"], and Staples) are involved in this Domain/Website/Email conspiracy to
do harm to Liberi. Since other websites picked up on Whois, and Public
Domain Registration, and Geoffrey Staples’ name became public on November
23, 2010, the threesome (Taitz, Staples, and Belcher) then decided to call the
website a parody website. This was printed at bottom of website page (to them
this made it a parody), and an article entitled “Some people can’t take a joke”
was added to website.
4. Liberi found out that emails from convictedfelon@lisaliberi.com
were being sent out to people that were in her Computer AOL database on
November 22, 2010. The only way that anyone could have these names was to
have hacked into Liberi’s computer. Liberi notified the lower Court a few
months back about her computer being hacked. Taitz was posting a family
picture of Liberi on Taitz’s website, Facebook and on Pacer with Judge
Robreno’s Court, and the only way that Taitz could have gained access to this
photograph was to have hacked into Liberi’s computer. This “computer
hacking” either by Taitz or orchestrated by Taitz has now proven to be true with
3
these emails being sent to Liberi’s AOL contacts, and posted family picture that
was on Liberi’s computer and later posted by Taitz at many locations.
5. In June 2010 Judge Robreno severed the Liberi v Taitz case and
ordered part of the case to Texas and part to California. Orly Taitz appealed to
the Third Circuit Court of Appeals. Orly Taitz, a licensed attorney, continued
to file documents in Judge Robreno’s Court knowing that Judge Robreno had
closed the case in June and the transfer of the case was being Appealed by her.
Taitz also knew that only the documents filed prior to her Notice of Appeal
would be reviewable by Appellate Judges. Taitz knew that documents on Pacer
were being uploaded by Scribd.com/jack ryan, and being read by her viewers.
Taitz, being dishonest and unethical, again seized the opportunity to file
document after document of untrue, prejudicial, inflammatory material in her
attempt to arouse the emotions, and prejudices of her followers. Taitz then
served everybody and their cat with these filings with the exception of Mr.
Berg. She sent copies of these filings to Federal Judges in Southern California
where the Liberi v. Taitz case is being transferred with the intent of obstructing
justice, see EXHIBIT "2". Within these documents were filings that Taitz
presented to the Court as Notarized Affidavits, which did not have proper
Notary stamp, Notary acknowledgment, and Notary information. Taitz, a
licensed attorney, presented documents from Geoffrey Tyler Staples that were
4
forged/altered/manufactured in order to frame Lisa Liberi, in another attempt to
have her (Liberi) falsely arrested. These documents were also stolen from the
financial database of Mr. Berg when Staples worked for Mr. Berg a very short
while in 2008. Orly Taitz, a licensed attorney, also published these documents
on Pacer without redacting the sensitive information of the Berg supporters.
6. When Taitz would file these documents on Pacer of Judge Robreno’s
Court after the transfer order and after Taitz’s appeal, then Mr. Berg would
have to answer Taitz’s filing in order to protect the Plaintiffs (Appellees). Mr.
Berg’s filed documents would disprove the false claims of Taitz. Taitz would
then vindictively post something about Liberi that would be of a defaming,
slanderous nature, and/or try to get everyone riled up against Liberi. Taitz
would then start filing more documents on Pacer of lower Court Judge
Robreno’s Court. Mr. Berg did ask for a temporary restraining order, and
sanctions in order to stop this behavior of Taitz but there was never an answer
from lower Court Judge Robreno. Finally on October 26, 2010 (Exhibit 2),
Mr. Berg wrote a letter to all of the people that Taitz was sending copies of her
filings (Proof of Service List), and asked them not to read the material from
Taitz that it was intended for Judge Robreno’s Court. Mr. Berg also mentioned
all of the crimes committed by Taitz, that a temporary restraining order was
needed, and asked for their help in stopping Taitz. A day or so later, Judge
5
Robreno then issued an order that any letters or motions were to be filed in the
Third Circuit Court of Appeals, not in his Court.
7. Taitz does background checks on individuals without a permissible
purpose, and uses this information for her benefit. She wanted Liberi to do her
legal work the latter part of 2008, and both Liberi and Mr. Berg did not want to
be involved with Taitz because of her unethical, and illegal ways. Mr. Berg
also was having problems with Geoff Staples and Linda Belcher during the
latter part of 2008. I remember the first of January 2009 that Taitz was posting
on her blog “Does anyone know how to get in touch with Linda Starr?”
“Would someone have Linda Starr to call me”. Linda Starr is one of the many
names that Linda Belcher uses to post on websites. Taitz is the one that sought
out Linda Belcher for the purpose of causing harm to Mr. Berg and Liberi.
Approximately the same time frame, Taitz wanted Lisa Ostella [hereinafter at
times "Ostella"] to lie to law enforcement about Taitz’s website being hacked,
Ostella refused, and Taitz posted all over accusing Ostella of stealing along
with other accusations.
8. Taitz posted Liberi’s Social Security number, mother’s maiden name,
fathers name, birth date, place of birth, all together on the Internet. Taitz also
mailed, emailed, and faxed this information internationally on numerous
occasions within a document that Taitz called Dossier 6. Taitz and Sankey also
6
emailed, posted, and faxed Liberi’s sensitive information in other documents.
Taitz intentionally set Liberi up to live the horrors of multiple Identity Thefts to
where Liberi would be financially ruined beyond restoration, falsely accused of
crimes and never be able to live a peaceful life as Lisa Liberi. Taitz also posted
Liberi’s husband's Social Security number and other sensitive information to set
him up.
9. Mr. Berg filed suit in May 2009. Taitz and Neil Sankey [hereinafter
at times "Sankey"] continued the attack on Liberi, Ostella and Berg. May 28,
2009 Sankey spoke on Ed Hales Radio Blog show and told everyone that Liberi
had over 200 criminal counts against her, she was convicted of selling and
reselling her home, and the outrageous lies continued for the duration of the
Sankey visit. On another radio show with Ed Hale and Linda Belcher, they
were making fun of Liberi having a heart attack. Linda Belcher was saying
“Look, look, there comes the ambulance now, she is holding her chest, she is
going down”. These radio tapes were filed in Court and are on record with
lower Court Judge Robreno.
10. Liberi v Taitz came before Judge Robreno on June 25, 2009. Taitz, a
licensed attorney, and officer of the Court, was asked by Judge Robreno on two
separate occasions if she had published Liberi’s Social Security number. On
page 39, lines 16 through 21 of June 25, 2009 Court Transcript Taitz told Judge
7
Robreno that she had never posted Liberi’s Social Security number and she had
proof of that. She said that she would never publish any private facts, or
anything libelous. She said that she has never slandered anybody, and she has
never published anything untrue. On Page 40, lines 7-10, Taitz again told
Judge Robreno that she had not posted Liberi’s social security number. On
Page 40 line 20 Taitz began her rhetoric of being from a Communist country
and how important to have transparency in government. She went on to say
that “However, you don’t achieve transparency in government by submitting
documents prepared by a convicted forger of documents”, see the June 25,
2009 Court Transcript attached hereto as EXHIBIT "3". Orly Taitz introduced
Judge Robreno to her law clerk, Dr. Charles Lincoln III. Dr. Charles Lincoln
III was an attorney that had been disbarred from about three or four states, and
had spent quite a bit of time behind bars. Approximately August 1, 2009, it was
reported in a few Affidavits that Yosef Taitz had sent a forged birth certificate
of President Obama to Orly Taitz. Yosef Taitz had acquired this birth
certificate from the Mossad. Orly Taitz knew that this birth certificate was
forged, and presented the document as genuine in Federal Judge Carter’s Court
in Santa Ana, CA. Federal Judge Carter commented in his Order that he had
also received Affidavits that Orly Taitz had suborned perjury.
8
11. Judge Robreno evidently did not read the Affidavits, or view the many
documents supplied to him regarding Taitz’s postings. He took Orly Taitz at
her word.
12. On page 70, lines 2-6 Judge Robreno denied Temporary Restraining
Order. Judge Robreno said it would be a serious problem if there were any
publication of the Social Security number of anyone in this case, and stated “I
think that would tip the equity significantly”. On Page 70, lines 7-18, Judge
Robreno said that to the extent that Ms. Liberi’s may be subject to some
controversy as to which number belongs to her that he would advise the
defendants to publish no social security numbers of anyone. Page 70, lines 11-
14, Judge Robreno said that it serves no purpose whatsoever to publish
someone’s Social Security in this day and age. That it inflicts harm that is
unrelated to the case, and it is unwise and improper to do so. Page 70, lines 15 -
18, Judge Robreno said that he thought the defendants should take that to heart.
Judge Robreno said that to the extent that this has happened, he did not know
whether or not it has happened, but it should not happen in the future. Page 71,
lines 11-14, Judge Robreno also said that there would be no further motions
filed in the case without leave of Court. Leave of Court should be sought by
way of a letter to the Court and the Court will then consider whether or not the
attached motion should be filed of record. Page 71, lines 23-25 Judge Robreno
9
said that his written order controls over anything said on the Bench. Page 72,
Judge Robreno told Mr. Berg if there is a violation of what he had advised the
parties then Mr. Berg was to bring it to Judge Robreno’s attention.
13. After the June 25th hearing, Taitz posted on her website that Judge
Robreno told Berg to put up or shut up, and implied that Judge Robreno found
the Defendants to be in the right. Taitz completely ignored Judge Robreno’s
Order. Taitz continued her “business as usual” with publishing Dossier 6 with
Liberi’s social security number, trashing Liberi, Ostella, and Berg on radio,
with postings, whoever would listen. She also started posting on approximately
June 27th, 2009 that Liberi murdered her sister. She posted for everyone to
call Santa Fe Police Department, Coroner and get information on my daughter
that died, and she posted the telephone numbers, see EXHIBIT "4". She said
that the police knew that Liberi killed her sister but police could not prove it.
She also published Santa Fe Probation department’s telephone numbers and
names to contact and demand that Liberi be put in jail. The pounding was
constant on Liberi and Ostella. Of course the above Taitz postings were untrue
and hurtful.
14. Dr. Charles Lincoln III stated in an Affidavit that after the June 25th
Court hearing, Taitz had him to drive her around New Jersey. The routes taken
were right next to where Ostella resided and her children attended school. He
10
was also driving Taitz to different police stations where Taitz was filing false
police reports on Liberi and Ostella, see EXHIBIT "5". Two individuals
called Ostella and told her that Taitz was talking at a “ResistNet” meeting
(white supremacist group supposedly started by a friend of Defendant Ed Hale)
about professionally kidnapping Ostella's children. Affidavit of Ostella is filed
with lower Court.
15. Taitz did not follow the rules of Court. Mr. Berg would submit a
letter to the Court asking for leave of Court to file a motion but Taitz would just
file a motion without asking for leave of Court. Judge Robreno did nothing.
Taitz kept filing frivolous documents for the benefit of her followers, which had
nothing to do with the lawsuit whatsoever. Sankey and Taitz also filed forged
emails that they claimed to be from Ostella. Taitz maintained her attack toward
the Plaintiffs. The above documents have been filed with the lower Court.
16. Mr. Berg again went into Court August 2009 for a TRO. Taitz did
not attend due to a media tour in Russia and Israel. Dr. Charles Lincoln III,
acting as Taitz Law Clerk filed documents on Taitz's behalf. Plaintiffs were
present to testify, and some witnesses. Affidavits and recording tapes with
transcripts were produced by Plaintiff’s that contained threats from Ed Hale
toward the Plaintiffs and witnesses, Judge Robreno’s Order of August 3rd, 2010,
11
denied the TRO. Judge Robreno did nothing regarding the “Taitz Violations"
that Judge Robreno had told Mr. Berg to bring to his attention.
17. Mr. Berg appealed to the Third Circuit of Appeals on approximately
August 17th, 2009, see Liberi v Taitz, Case No. 09-3403. This was held up for
months due to the inability of Mr. Berg to get a Court Transcript for the Court
hearing of August 7th, 2009 from a Joan Carr, Court reporter, in Judge
Robreno’s Court. Marsha Waldron, Clerk USCA, issued a RULE TO SHOW
CAUSE upon Joan Carr USDC. This problem with Joan Carr was still going
on approximately the end of February 2010, and six months had already been
wasted. Finally, Mr. Berg withdrew the appeal so the Plaintiffs could move
forward. Nothing had been accomplished. Taitz was still posting her
slanderous remarks about Liberi and Ostella, misquoting and distorting facts
filed in the case, trying to incite her followers against Liberi. Taitz kept filing
her frivolous documents, which she would post on her website, and then file on
pacer for Scribd.com/jack ryan to upload for public view. Mr. Berg would
have to answer Taitz filings to protect his Plaintiffs, and asking Judge Robreno
to uphold the Court Rules.
18. In June 2010 Robreno severed the case. Some mistakes were made
within Judge Robreno’s order, but Mr. Berg brought this matter to Judge
12
Robreno’s attention, and Judge Robreno corrected the mistakes, which further
delayed the judicial process.
19. Judge Robreno transferred the case of Defendant Taitz and Defend
our Freedoms Foundations, Inc. (DOFF), and the Sankey Defendants to
Southern California, and the Hale Defendants and Belcher to Texas. The
Court Transcript of June 25, 2009 pages 31 through 34 has attorney Mr.
Hoppe speaking about Jurisdiction and Venue. Mr. Hoppe said that he felt that
the proper place would be California and Texas. Page 31, line 8, to page 34 line
10 . On page 48, line 1-9, Taitz told Judge Robreno that the proper place for
Venue/Jurisdiction would be California. However, Taitz later appealed Judge
Robreno’s Order to transfer Sankey/Taitz (DOFF) to California. Taitz did not
ask for a Stay of Transfer, however Judge Robreno’s Court did not start the
transfer of records to Southern California and Texas. I do not know why.
20. Taitz’s appeal is nothing more than a delaying tactic to be able to
hash, bash, and pound on Berg, Liberi and Ostella by utilizing the Courts
electronic filing system “PACER” to disseminate her “documents of lies”,
uploaded by Scribd.com/jack ryan and then onto the Internet. The Appellate
Court only needs to check their docket and see the content of the documents
filed by Taitz. The documents do not pertain to Taitz’s Appeal, and do not
reflect the factual content of Affidavits, evidence, and Court Transcripts.
13
21. Taitz stepped up her cyber stalking, and cyber bullying attacks to
daily postings after Judge Robreno’s Transfer Order. Taitz hired actors to do
videos, which appeared to be news reporters reporting about Berg, Liberi, and
Ostella. The contents of the videos were all lies but did appear authentic.
David Acton was one of the actors. Taitz started posting that Lisa Liberi
should be in jail, posted pictures, addresses, phone numbers, and made threats.
Accused Liberi of keeping Taitz from “doing her job for the people regarding
Obama”. She would hash and bash on radio shows, saying that she had
supplied the pictures and given directions. At every opportunity she would
make remarks that Liberi should be gotten rid of. Meanwhile, Liberi and
Ostella endure continued harassment and daily anxiety over the safety of
themselves, and their families. Liberi and her husband are experiencing many
problems with continued identity theft, which, among other obvious things,
makes it difficult to supply the necessary funds for my grandson’s college
education, and daily needs.
22. The physical effects on Liberi’s heart alone, due to the anxiety and
emotional stress caused by Taitz and associates have mounted into the hundreds
of thousands of dollars in emergency care, hospital care, and daily care. The
immediate family has also been affected by the terrorist actions of Taitz.
14
23. Since November 10th, 2010 Taitz has quieted down with
defaming/slandering Liberi on Taitz’s website. She is still posting a picture of
Liberi with a defaming/slandering article on her many Facebook accounts that
have been up for months. Facebook has been notified but has not taken any
action. As I mentioned at the beginning of this Afidavit, Taitz, Belcher and
Staples have now set up a Domain/Website/Email in the name of Lisa Liberi at
http://lisaliberi.com and Email of convictedfelon@lisaliberi.com and
perjurylesson@lisaliberi.com. They hacked into Liberi’s computer and are
sending emails to her AOL contacts. Law enforcement reports have been filed
in three different states regarding this website. Law enforcement talked with
Staples, and Staples admitted that Belcher and Taitz were involved.
24. All of the postings, radio shows, and other events referenced herein
are on file with the lower Court. If this Court would like to see Taitz's postings
directly, then please go to www.orlytaitzesq.com, in the search box, put either
Liberi, Ostella or Berg, and pages of disgusting posts will come up. In the
event that Taitz decides to delete postings from her wesbsite, there are copies of
all the postings filed in the lower Court's docket.
25. I have read that Taitz’s MO (method of operation) tactics and belief
are that “the end justifies the means”, and is a philosophy that is promoted by
15
Communism, and the Mossad. Taitz was born, and raised to adulthood as a
Communist, and there are reports that she has links to the Mossad.
26. I believe that most Americans think as Ayn Rand (1905 – 1982) who
said: "I do not believe that the end justifies the means. No one’s rights can be
secured by the violation of the rights of others."
27. Taitz will continue to “delegate and/or execute” terrorist attacks
against Liberi, Ostella, and Berg, until she is stopped. We are praying that the
Court Order's the Domain/Website/Email to be removed, and a Restraining
Order of some type to be put in force to deter future retaliatory, harassing,
threatening, dangerous, and abusive actions against the Plaintiffs (Appellees)
and their witnesses.
I declare under the penalty of Perjury of the laws of the United States that
the foregoing is true and correct. Executed this ____

6th day of December 2010.
s/ Shirley Waddell
(Signature sent by fax - see attached)
__________________________
Shirley Waddell, Affiant
16
CALIFORNIA ALL PURPOSE

CERTIFICATE OF ACKNOWLEDGEMENT
State of California )
County of Sacramento )
On December _____,
6 2010, before me, Cyndi Nguyen
Name of Notary
Personally appeared Shirley Waddell, proved to me on the basis of satisfactory
evidence to be the person whose name is subscribed to the within instrument and
acknowledged to me that she executed the same in her authorized capacity; and
that by her signature on the instrument the person, or the entity upon behalf of
which the person acted, executed the instruction.
I certify under PENALTY OF PERJURY under the laws of the State of California
that the foregoing paragraph is true and correct.
WITNESS my hand and official seal.
s/ Cyndi Nguyen
(Signature and Seal received by fax -
Signature see attached paged) (Seal)
Notary
17
EXHIBIT "1"
From: llisaliberi@aol.com
To: shirleywaddell@att.net; philjberg@gmail.com
Sent: Wed, Nov 10, 2010 11:25 am
Subject: Fwd: Good morning, Convicted Felon
I just received this email in my AOL inbox, can anyone detect where it came
from? I have attached the header info
-----Original Message-----
From: convictedfelon@lisaliberi.com
To: llisaliberi@aol.com
Sent: Wed, Nov 10, 2010 10:37 am
Subject: Good morning, Convicted Felon
Love your new website.
Yours,
Convicted Felon
EXHIBIT "2"
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
October 26, 2010
Honorable Eduardo C. Robreno Hon. James Secord

United States District Court Deputy District Attorney
for the Eastern District of Pennsylvania San Bernardino County
11614 U.S. Courthouse 316 North Mountain View
601 Market Street San Bernardino, CA 92415-0004
Philadelphia, PA 19106-1797 Sent via Regular Mail
Sent via Fax to (267) 299-5113
San Bernardino County Probation Dept.
Philadelphia District Attorneys Office 175 W. Fifth Street, 4th Floor
Three South Penn Square San Bernardino, CA 92415-0460
Corner of Juniper and South Penn Square Sent via Fax to (909) 387-5600
Philadelphia, PA 19107-3499
Sent via Regular Mail
Chief Judge Audrey B. Collins
U.S. Attorney's Office U.S.D.C., Central District of CA
615 Chestnut Street Courtroom 680
Suite 1250 255 East Temple Street
Philadelphia, PA 19106 Los Angeles, CA 90012
Sent via Fax to (215) 861-8618 Sent via Regular Mail
Social Security Administration Judge David O. Carter

6401 Security Blvd. Courtroom 9D
Baltimore, MD 21235 U.S.D.C. Central District of CA,
Sent via Regular Mail Southern Division
411 west Fourth Street
Public Integrity Section Santa Ana, CA 92701-4516
Department of Justice Sent via Regular Mail
950 Pennsylvania Ave., NW
Washington, D.C. 20530-0001 U.S. Attorney's Office
Sent via Regular Mail 312 North Spring Street
Los Angeles, California 90012
Re: Orly Taitz's Obstruction of Justice and other Criminal Acts
Z:\Liberi Ltr regarding Taitz's Criminal Acts 1

Re: Orly Taitz Obstruction of Justice and other Criminal Acts October 26, 2010
Page Two
I represent Plaintiffs, Evelyn Adams, Philip J. Berg, Esq., Lisa Liberi, Lisa Ostella, Law
Offices of Philip J. Berg, and Go Excel Global in a case against Orly Taitz and other Defendants. The
Case was filed in the U.S. District Court, Eastern District of PA, Case No. 09-cv-01898 before the
Honorable Eduardo C. Robreno. This Case was brought due to illegal behaviors of Defendant Taitz
and the other Defendants.
I am sending this letter to each of you as Orly Taitz has now been obstructing justice
and attempting to prejudice and conflict out the very Court this case has been ordered
transferred to by sending copies of letters and filings to you. My request is that these documents
should “not” be read by anyone other than the Honorable Eduardo C. Robreno. Further, I
believe a Restraining Order should be issued against Orly Taitz to stop her current tactics and
Sanctions should be imposed against her as she is an attorney who should know better.
On June 3, 2010, Judge Robreno Ordered the Case Transferred to the U.S. District Court,
Central District of California, Southern Division against the California Defendants and to the U.S.
District Court, Western District of Texas against the Texas Defendants. Due to some inconsistencies, I
filed a Motion for Reconsideration of this Order, which was Granted in part by Judge Robreno. Judge
Robreno amended (corrected) his Order on June 22, 2010, which maintained the Transfer of the Case
to the U.S. District Court, Central District of CA and the U.S. District Court, Western District of
Texas.
Since this time, Orly Taitz's behaviors have intensified against the Plaintiffs, especially
Plaintiffs Lisa Liberi and Lisa Ostella. Orly Taitz's behaviors include but are not limited to Cyber-
stalking; Cyber-bullying; harassment; stalking; inchoate offenses; forgery; false law enforcement
reports; attempting to have Lisa Liberi and Lisa Ostella falsely arrested based on falsified allegations;
which Plaintiffs Lisa Liberi and Lisa Ostella are the victims.
Moreover, Orly Taitz has been attempting to intimidate/retaliate against a Witness for
Plaintiffs, Shirley Waddell to deter her from testifying in the Civil Case.
Since Judge Robreno's Order of June 22, 2010 Transferring this Case, Orly Taitz Appealed
the Ruling, said Appeal is in the U.S. Court of Appeals for the Third Circuit. However, Orly Taitz has
continued filing frivolous documents with Judge Robreno's Court, which include many falsified
statements; falsified information pertaining to the Civil Case pending against her; forged and altered
documents in the name of Plaintiff Lisa Liberi and Lisa Ostella, and falsified recitations of pleadings
filed by Plaintiffs, just to name a few.
In so doing, Orly Taitz has been sending her filings containing many falsified statements
forged and altered documents to all parties listed above for absolutely no permissible purpose other
than to continue her harassment of the Plaintiffs and to attempt to conflict out or prejudice the Judge's
in the U.S. District Court, Central District of California, Southern Division, the very Court this Case is
being Transferred to. And, attempting to have Plaintiffs Lisa Liberi and Lisa Ostella falsely arrested
on falsified allegations.

Re: Orly Taitz Obstruction of Justice and other Criminal Acts October 26, 2010
Page Three
Again, Orly Taitz began sending all her falsified statements, falsified recitations of pleadings
filed by the Plaintiffs; forged and altered documents, etc., which she filed in Judge Robreno's Court to
all the parties listed in this letter, including the Chief Judge of the U.S. District Court, Central District
of California as well as Judge Carter, U.S. District Court, Central District of California, Southern
Division after Judge Robreno's June 22, 2010 Order Transferring this Case to the U.S. District Court,
Central District of California, Southern Division. See Judge Robreno's June 22, 2010 Opinion and
Order attached hereto as EXHIBIT "A". See Orly Taitz's "Certificate of Services" for 7/29/2010;
9/8/2010; 9/28/2010; and 10/21/2010 attached hereto as EXHIBIT "B".
This is extremely concerning as Orly Taitz continues breaking State and Federal Laws. Not
only am I concerned regarding the prejudices this creates for my clients, I am extremely concerned
about the safety of my clients.
Orly Taitz's filing of false statements (perjury) as well as forged and altered documents in the
name of Plaintiffs Lisa Liberi and Lisa Ostella also constitutes Obstruction of Justice, Perjury, Forgery
and other criminal acts.
Orly Taitz is an attorney licensed in the State of California and is well aware her actions,
behaviors and activities are illegal and constitute crimes, for which she must be prosecuted.
I would appreciate any assistance for my clients in order to stop the illegal behaviors of Orly
Taitz.
Please do not hesitate contacting me should you require anything additional.
Thank you.
Respectfully,
Philip J. Berg
PJB:jb
Enclosures
cc: Orly Taitz

26302 La Paz Ste 211
Mission Viejo, CA 92691
Ph: (949) 683-5411
Fax: (949) 586-2082

EXHIBIT "A"
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 123 Page:
Filed29
06/23/10
Date Filed:
Page12/06/2010
1 of 6
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. :
M E M O R A N D U M
EDUARDO C. ROBRENO, J. June 22, 2010
I. BACKGROUND
On May 4, 2009, Plaintiffs Lisa Liberi (“Liberi”),
Philip J. Berg, Esq. (“Berg”), the Law Offices of Philip J. Berg,
Evelyn Adams a/k/a Momma E (“Adams”), Lisa Ostella (“Ostella”),
and Go Excel Global (collectively, “Plaintiffs”) initiated this
defamation, libel and slander action against Defendants Orly
Taitz (“Taitz”), Defend our Freedoms Foundations, Inc. (“DOFF”),
Neil Sankey, The Sankey Firm and Sankey Investigations, Inc.
(collectively, "Sankey"), Edgar Hale, Caren Hale, Plains Radio,
KPRN AM 1610, Bar H. Farms, Plains Radio Network (collectively,
“the Hales”), and Linda Sue Belcher (collectively, “Defendants”).
On June 3, 2010, the Court severed the action and
transferred the claims to each Defendant’s home jurisdiction.
Before the Court is Plaintiff Berg’s motion for leave to file a
motion for reconsideration (doc. no. 120), Defendant Taitz’s
response (doc. no. 121) and Defendant Sankey’s response (fax

Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 123 Page:
Filed30
06/23/10
Date Filed:
Page12/06/2010
2 of 6
dated 6/11/10). On June 18, 2010, Plaintiff Berg filed a motion
for leave to file a motion to strike Defendant Taitz’s response
(doc. no. 122).
II. MOTION FOR RECONSIDERATION
A. Legal Standard
A motion for reconsideration is treated as the
“functional equivalent” of a motion pursuant to Rule 59(e) which
seeks to alter or amend a judgment. Fed. Kemper Ins. Co. v.
Rauscher, 807 F.2d 345, 348 (3d Cir. 1986) (internal citation
omitted). The purpose of a motion for reconsideration is to
“correct manifest errors of law or fact or to present newly
discovered evidence.” Harsco Co. V. Zlotnicki, 779 F.2d 906, 909
(3d Cir. 1985). Reconsideration is appropriate where the party
seeking reconsideration establishes “(1) an intervening change in
the controlling law; (2) the availability of new evidence that
was not available when the court . . . [issued its previous
decision]; or (3) the need to correct a clear error of law or
fact or prevent manifest injustice.” Max’s Seafood Cafe ex rel.
Lou Ann v. Quinteros, 176 F.3d 669, 677 (3d Cir. 1999); North
River Ins. Co. v. CIGNA Reinsurance Co., 52 F.3d 1194, 1218 (3d
Cir. 1995); U.S. v. Cabiness, 278 F. Supp. 2d 478. 483-84 (E.D.
Pa. 2003) (Robreno, J.).
B. Proposed Grounds for Reconsideration
-2-
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 123 Page:
Filed31
06/23/10
Date Filed:
Page12/06/2010
3 of 6
On June 7, 2010, Plaintiff Berg faxed a motion for
leave to file a motion for reconsideration. See doc. no. 120
(docketed 6/13/10). Defendant Taitz responded by fax on June 10,
2010 and Defendant Sankey responded by fax on June 11, 2010. See
Taitz 6/10/10 Ltr., doc. no. 121 (docketed 6/14/10); see also
Sankey 6/11/10 Ltr. Mr. Sankey’s response was not filed of
record.1
In his letter, Plaintiff Berg lists eight purported
errors in the Court's 6/3/10 Order that severed the action and
transferred the claims to each of Defendants’ home jurisdictions.
Upon review, Plaintiff Berg actually raises only three discrete
issues. Importantly, Plaintiff Berg’s motion does not argue that
the legal conclusions set forth in the Memorandum were incorrect.
The three outstanding administrative errors raised by
Plaintiff Berg are grouped as follows.
1. Points 6, 8 and 9
Points 6, 8 and 9 are as follows:
1
Defendant Taitz’s response does not substantively
address Plaintiff Berg’s motion for leave to file a motion for
reconsideration, thus it is inapposite to the issues at bar.
Defendant Sankey’s letter disputes Plaintiff Liberi’s
assertions of Pennsylvania citizenship and argues that Plaintiff
Liberi is a citizen of New Mexico. See Sankey Ltr., dated June
11, 2010. However, diversity jurisdiction would only be
destroyed if Plaintiff Liberi was a citizen of either of the
states of which Defendants are citizens: California or Texas.
Thus, the issue is inapposite to Plaintiff Berg’s motion for
leave to file a motion for reconsideration and the legal
conclusions reached in this case.
-3-
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 123 Page:
Filed32
06/23/10
Date Filed:
Page12/06/2010
4 of 6
Point 6: There is a discrepancy in the Court’s Order of

June 3, 2010, docketed on June 4, 2010
appearing as Docket Entry No. 118;
Point 8: Amendment of this Court’s June 3, 2010 Order,

docketed June 4, 2010, appearing, as Docket
Entry No. 118 is proper. This Court has the
inherent Power to amend its Final Judgment;
and
Point 9: A proposed Order is attached to Plaintiffs’

Motion.
See Berg Mot. Reconsideration 2, doc. no. 120.
These notations are not relevant to the legal
disposition of this case. Therefore, Points 6, 8 and 9 will be
denied.
2. Points 1, 2, 3, 4 and 5
Points 1, 2, 3, 4 and 5 are as follows:
Point 1: This Court concedes on page two (2), second

(2nd) paragraph of the Court’s Memorandum
[Doc. No. 117] that the Sankey Defendants,
which would be Neil Sankey, Sankey
Investigations, Inc. and The Sankey Firm, Inc.
a/k/a The Sankey Firm are citizens and
residents of the State of California;
Point 2: Defendants Neil Sankey and Sankey

Investigations, Inc. are not within the
jurisdiction of the U.S. District Court,
Western District of Texas, but instead are
located in the Central District of California;
Point 3: Although in Default, the Court made no mention

of transfer as to Defendant, The Sankey Firm,
Inc. a/k/a The Sankey Firm. Is the Court
planning on keeping this one Defendant and
allowing Plaintiffs to enter Default against
them?; If not then,
Point 4: The Sankey Firm, Inc. a/k/a The Sankey Firm is

a California Corporation, in the U.S. District
-4-
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 123 Page:
Filed33
06/23/10
Date Filed:
Page12/06/2010
5 of 6
Court, Central District of California,

Southern Division jurisdiction. Therefore,
transfer of Plaintiffs’ claims against this
Defendant is only proper to the U.S. District
Court, Central District of California,
Southern Division; and
Point 5: Defendants Neil Sankey, Sankey Investigations,

Inc. and The Sankey Firm, Inc. a/k/a The
Sankey Firm conducted the offenses giving rise
to this suit from their office locations in
California.
See id. at 1-2.
The final Memorandum correctly identifies Defendants
Neil Sankey, The Sankey Firm and Sankey Investigations, Inc. as
citizens of California; however, the original Order, dated June
3, 2010, incorrectly transferred their case to Texas instead of
California. The enclosed Amended Order corrects this error and
transfers Neil Sankey, The Sankey Firm and Sankey Investigations,
Inc. to the Southern Division of the Central District of
California.
No prejudice has resulted because the cases have not
yet been transferred and the error has no impact on the legal
conclusions reached in this case. Therefore, Plaintiff Berg’s
motion for reconsideration is granted as to Points 1-5.
3. Point 7
Point 7 is as follows:
Point 7: None of the Parties to this Action asked for

severance of the Case; The Court’s Order
states Defendants Motion to Transfer is
Granted; and on page two (2) states
Defendants’ Motion to Dismiss or, in the
-5-
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 123 Page:
Filed34
06/23/10
Date Filed:
Page12/06/2010
6 of 6
alternative, Motion to Transfer (doc. No. 10)

is Denied as Moot. First, Doc. No. 10 is an
Affidavit of Service, not a Motion to Dismiss
or in the alternative to Transfer. It is
believed the Court meant Plaintiffs’ Motion to
Transfer is Granted, as Plaintiffs’ had a
pending Motion to Transfer the Case.
See id. at 2.
In Point 7, Plaintiff Berg requests that Defendants’
motion to dismiss or, in the alternative, motion to transfer
(doc. nos. 24, 25) be denied as moot. However, in its 6/25/09
Order, the Court already denied Defendants’ motion to dismiss or,
in the alternative, motion to transfer (doc. nos. 24, 25). See
Ct. 6/25/09 Order, doc. no. 77.
Currently, there are no motions pending that have not
been previously denied as moot. As such, Point 7 will be denied
as moot. See docket.
III. CONCLUSION
Plaintiff Berg’s motion for leave to file a motion for
reconsideration will be granted. Points 1, 2, 3, 4 and 5 of the
motion for reconsideration will be granted and Points 6, 7, 8 and
9 will be denied as moot.
Plaintiff Berg’s motion for leave to file a motion to
strike Defendant Taitz’s response will be denied as moot.
An amended Order follows.
-6-
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 124 Page:
Filed35
06/23/10
Date Filed:
Page12/06/2010
1 of 2
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. :
AMENDED ORDER
AND NOW, this 22nd day of June, 2010, it is hereby
ORDERED that the Court Order, dated June 3, 2010, is AMENDED as
follows. On June 25, 2009, the Court issued a rule to show cause
upon Plaintiff as to why this case should not be (1) dismissed
for lack of personal jurisdiction; (2) severed into three or
fewer cases against the following groups or Defendants: (i) the
Hales; (ii) Belcher; (iii) Taitz, DOFF, and Sankey; and (3)
transferred to an appropriate district in either Texas or
California, pursuant to 28 U.S.C. § 1404(a).1 See Court Order,
doc. no. 80.
IT IS FURTHER ORDERED that, upon consideration of
Plaintiffs’ responses to the rule to show cause, Defendants’
1
On June 25, 2009, the Court issued an order that no
further motions shall be filled without prior leave of the Court.
See Court Order, doc. no. 78. No motions granted leave to file
are currently pending.
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 124 Page:
Filed36
06/23/10
Date Filed:
Page12/06/2010
2 of 2
replies thereto and Plaintiff Berg's motion for reconsideration,
the Court will now SEVER the instant case into two separate,
independent actions and TRANSFER each action to the jurisdiction
of the following district courts. All claims pending against
Defendants Linda Sue Belcher, Edgar Hale, Caren Hale, Plains
Radio Network, Bar H. Farms, and KPRN A.M. 1610 are transferred
to the Western District Court of Texas. All claims pending
against Defendants Orly Taitz, Defend Our Freedoms Foundations,
Neil Sankey, The Sankey Firm and Sankey Investigations, Inc. are
transferred to the Southern Division of the Central District of
California.2
IT IS FURTHER ORDERED that this case shall be marked
CLOSED.
AND IT IS SO ORDERED.
s/Eduardo C. Robreno
EDUARDO C. ROBRENO, J.
2
All requests for leave to file pleadings submitted
during the time the case was in suspense from December 9, 2009 to
June 4, 2010, of which only one letter was made part of the
docket (see Berg Letter in Opp'n to Def. Taitz, dated Jan. 10,
2010, doc. no. 116), are denied as moot.
- 2 -
EXHIBIT "B"
09/17/2029 06:03 110493 P.001/080
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 136 Page:
Filed38
07/29/10
Date Filed:
Page12/06/2010
1 of 51
Dr. Orly Taib, Esq

Attorney Pro Se & Attorney
For Defelld Our FreedolDl Foundation
29839 Santa Margari1a Parkway, Suite 100
Randlo Sata Margarita CA 92688
Tel: (949) ~5411; Fax (949) 7"-7603
E-Mail: dr_ tait7@.yshoo.eom
Il5J [§ © [§ U'\'i' ~ - (\
,.,
JUL 2 8 2010
J
IN THE UNITED STATES DISTRICT COURT :::
FOR THE EASTERN DISTRICf OF PENNSYLVANIA
LISA LmERI, et at., ) Response to tbe 07.26.10. emergency motion by the

plaintiffs to keep tnmscnp. ts under
seal
) Motion for clarification and motion-request
) for order to show cause, wby sanctions shouldnot - '
) be assessed against parties defrauding the courts c'
"
)by ciaivtiog that Judge Robreno issued an
, .
Pla.iD.tiffs )"order" to seal transcript of Liberi v Taitt j..... ;
) forwarded to the Third Circuit court of Appeals ~)

v. )
) District Court ease # 09-cv- 01898-ER ',... __.t
ORLY TAITZ, et at, ) Court ofAppeals number case #09-3403 ;:!i"~'
) aad other repeated ads oftraud "~,,fl)' c", 6,
DefendaDts.. ) 60 B motion AW/CJrJ.. ~- ~ ~ {J (. {J .
-z -......,~. "- III
~~. "(,/"~
BaCkground of the ease . '~O"'1Ji-
~
Due to the great importance of this. matter. and fraud being perpetrated on the US District
Court as well as the Court of Appeals, and due to the fact that the plaintiff here Lisa
Liberi is cur.rently on probation in the state of CA as a result of 10 felony convictions of
forgery, forgery of an official seal and gmnd theft, this motion is addressed to the
presiding judge The Hon Eduardo Robreno; as well as the Chief Judge of US District
Court for the Eastern District of Pennsylvania The Hon Harvey Bartle, ill; and the Chief
Liberi v Taitz Motion for Clarification 1

09/17/2029 08:08 #0493 P,038/080
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 136 Page:
Filed 39
07/29/10
Date Filed:
Page 12/06/2010
38 of 51
San Bernardino CA 92415-0004
909-387-8309
www.co.san-bemardino.ca.uslda
San Bernardino County, CA
Probation Department
175 w. Fifth str. 4th floor
S. Bernardino, CA
Audrey B. Collins
Chief Judge
US District Court
411 W. Fourth str
Santa Ana CA 92701
Judge David O. Carter -
..
-'
USDC Central Dis1rict of CA
411 West Fourth Str
Santa Ana CA 92701
US Commission on Civil Rights
624 Ninth Street, NW

Case
09/17/2029 Case:
06:09 2:09-cv-01898-ER
10-3000 Document: Document 136 Page:
003110370449 Filed 40
07/29/10
Date Filed: 40 of #0493
51 P,040/080
Page 12/06/2010
Office ofthe High Commissioner for Hwnan Rights
tel: + 4122 917 9151
email: OWth~
lsI OrlyTaitz ~
07.27.10.
Proposed order
I"":
c;
..
-' , ,
c,..""
,(11
Law offices of

Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 143 Page:
Filed41
09/08/10
Date Filed:
Page12/06/2010
1 of 18
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 143 Page:
Filed 42
09/08/10
Date Filed:
Page 12/06/2010
14 of 18
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 143 Page:
Filed 43
09/08/10
Date Filed:
Page 12/06/2010
16 of 18
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 145 Page:
Filed44
09/28/10
Date Filed:
Page12/06/2010
1 of 44
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 145 Page:
Filed 45
09/28/10
Date Filed:
Page 12/06/2010
19 of 44
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 145 Page:
Filed 46
09/28/10
Date Filed:
Page 12/06/2010
20 of 44
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 145 Page:
Filed 47
09/28/10
Date Filed:
Page 12/06/2010
21 of 44
Case:
Case10-3000
2:09-cv-01898-ER ORL VTAITZ
Document: 003110370449
Document 147 Page:
Filed 48
10/21/10
Date Filed:
Page 12/06/2010
45 of 58
11'0829 p 04:5/059
GriyT.E
A"""""Y I'n> &A"""""Y
_ ... F"""","",.
-
.1'0._0
:191139 • Parlovoy, Saito 100
CA~U!l8
Tell~) 11;)'u (949) 166-768i1
E~MalI'4r_ ytd>oo.eom
IN THE UNITED STATES DISTRICT OOlJRT
FOR THE EASTERN mSTRICT OF PENNSYLVANlA
,
USA LIBE ,et oL, ) C"""II89-1S9S HOD Eduard& Robnoo prt:Siding
) Rl>pIy to lo.o7.HI motion by the Plaiulifllo
) _ant'. "",1leIIt1\)' lIle ....rt to _!U' luh_ pow...
to_lIle~
) Alto....")' PIIiIip J.Berg _ WI...... Sh;,tey Waddell for
.1'- ) ~ ads offraed .... the _ r i - perjll'Y
)
v. ) lIeqllellt w e:tpedIte produetloo ofLisa Libori'.
I P-.ylvaaia driv<!t'I L~ aIIepcIIy provided W court
) dmiJ!g the emergen,,), hea~ OIl 08#7.09.
)
)
RespoJJSeJ Plaintiff's 10.07.10 motion IIlId simulta"""us ""1- for this

court 1<> im Inbereat powers saaetion Plaintiff's Attonley Philip Bel"ll lOr
repeated t· offraad 011 the ..,art aad perjllry and ""I-t 1<> expedite
prodllCUo of Liberi'. PAdriv.er's!lee...."
This case i filed by plaintiffs on May 04., 2009. The case is fur defamatioo of
character. re essenre of the case is the sworn statement hy the Plaintiff Lisa
Liberi and co-plaintiff and attorney Philip J Berg, claiming that Lib<:ri is an
et al v Taitz et aI. Dererulants response to motion. Defundants d<mand for sanctions

against l'IainIiffS, witness Shirley Wadden and Anomey l'b.ilip J. Berg 1
10/21/2010 13.52 2:09-cv-01898-ER
Case 949r Document 147 Page:
Filed 49
10/21/10 Page 12/06/2010
55 of 58
Case: 10-3000 Document: 003110370449 Date Filed:
lsi Dr. Or! Talrz, ESQ~

_____
07.28.10.
er penalty of peIjury, that 1 served above ple<t!llngs on full owing

oritiell:
Philip Berg i,
555 Andoni Glen Court, sle 12
Lafayette HjnPA 19444-2531
NeilS~
2470 ' str #162
Simi Valle CA 93063
Linda Belc
201 Paris
Castroville 78009
Pbi!adelphi~ District Attorneys' office

3 South P square
Philadelphi PA
US Attu ' office

Eastern Dil/trict ofM
615 Chestrlut str, ste 1250
Philadel . PA 19106-4100
Social Sec 'ty Administration

6401 Secu Blvd
e1 at v Taitt e1 aI. Defendants r _ to motion. Defundants demmd for .....mUllS

against plaintiffs, witness Shirley Wadddl and Attol'l"'Y Philip J. Bct:g 11
10/21/201C 13.52 8491887602 DflL \'T AITZ #0928 P,058/058
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 147 Page:
Filed 50
10/21/10
Date Filed:
Page 12/06/2010
56 of 58
AudreyB.
ChiefJudge
US District t::otnt
411 W. F str
Santa Ana CA 92701
i
Judge Dav; , O. Carter
USDC District of CA
411 west F urth Str
SantaAna A 92701
Public 'ty Section

l)epanInentofJustice
950 Pe vania Ave, NW
Washingtnn DC 20530-0001
!
, United Nations High Commissioner for Human Rights (OHCHR)

" ~~~rteur OIl the Situation ofHuman Rights Defenders
01 Ie Mrs. Margaret Sekaggya
atioos
eva 10, Switzerland
Criminal bar Hague
al v Taitt et aI. De1imda:n1S response to motion. De1imdaa1s 00:aWld for sanctions

against Plaintif!ls. witness Shirley Waddell and Attorney Philip J. Berg 12
10/21/2010 13_52 949;
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 147 Page:
Filed 51
10/21/10
Date Filed:
Page 12/06/2010
57 of 58
latjoJllS Commission for
Defenders
(Ms)
Human Ri 1;$ Officer

Civil and p Utica! Rights Section
Special Division
Office of High Commissioner fur Human Rights
tel:+4129179151
email:otol
IslOrlyTa
07.28.10.
Lawoffi of
Dr. Orly T .tz, ESQ
29839 San.or Defend
Pro se and
Margarita CA 92688
Our Freedoms Foundation
UNITED STATES DISTRICT
FOR THE EASTERN DISTRICT OF PENNSYLVAN!A
Lisa Li . et al ) Case # 09-cv"()1898-ECR
Plaintiffs ) Assigned to Honotllble Eduardo C.
Robreno
V )
al )
Li .. aI v Taitz et 01. DefOlldm!t9 ""'JlO1l5" to motion. Defendants demand fot $OllOIions

against plaintiffil. witness Sbidey Wadden and Attorney Philip I. Beti I,
EXHIBIT "3"
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed53
08/31/10
Date Filed:
Page12/06/2010
1 of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed54
08/31/10
Date Filed:
Page12/06/2010
2 of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed55
08/31/10
Date Filed:
Page12/06/2010
3 of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed56
08/31/10
Date Filed:
Page12/06/2010
4 of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed57
08/31/10
Date Filed:
Page12/06/2010
5 of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed58
08/31/10
Date Filed:
Page12/06/2010
6 of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed59
08/31/10
Date Filed:
Page12/06/2010
7 of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed60
08/31/10
Date Filed:
Page12/06/2010
8 of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed61
08/31/10
Date Filed:
Page12/06/2010
9 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 62
08/31/10
Date Filed:
Page 12/06/2010
10 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 63
08/31/10
Date Filed:
Page 12/06/2010
11 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 64
08/31/10
Date Filed:
Page 12/06/2010
12 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 65
08/31/10
Date Filed:
Page 12/06/2010
13 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 66
08/31/10
Date Filed:
Page 12/06/2010
14 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 67
08/31/10
Date Filed:
Page 12/06/2010
15 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 68
08/31/10
Date Filed:
Page 12/06/2010
16 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 69
08/31/10
Date Filed:
Page 12/06/2010
17 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 70
08/31/10
Date Filed:
Page 12/06/2010
18 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 71
08/31/10
Date Filed:
Page 12/06/2010
19 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 72
08/31/10
Date Filed:
Page 12/06/2010
20 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 73
08/31/10
Date Filed:
Page 12/06/2010
21 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 74
08/31/10
Date Filed:
Page 12/06/2010
22 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 75
08/31/10
Date Filed:
Page 12/06/2010
23 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 76
08/31/10
Date Filed:
Page 12/06/2010
24 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 77
08/31/10
Date Filed:
Page 12/06/2010
25 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 78
08/31/10
Date Filed:
Page 12/06/2010
26 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 79
08/31/10
Date Filed:
Page 12/06/2010
27 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 80
08/31/10
Date Filed:
Page 12/06/2010
28 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 81
08/31/10
Date Filed:
Page 12/06/2010
29 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 82
08/31/10
Date Filed:
Page 12/06/2010
30 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 83
08/31/10
Date Filed:
Page 12/06/2010
31 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 84
08/31/10
Date Filed:
Page 12/06/2010
32 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 85
08/31/10
Date Filed:
Page 12/06/2010
33 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 86
08/31/10
Date Filed:
Page 12/06/2010
34 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 87
08/31/10
Date Filed:
Page 12/06/2010
35 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 88
08/31/10
Date Filed:
Page 12/06/2010
36 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 89
08/31/10
Date Filed:
Page 12/06/2010
37 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 90
08/31/10
Date Filed:
Page 12/06/2010
38 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 91
08/31/10
Date Filed:
Page 12/06/2010
39 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 92
08/31/10
Date Filed:
Page 12/06/2010
40 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 93
08/31/10
Date Filed:
Page 12/06/2010
41 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 94
08/31/10
Date Filed:
Page 12/06/2010
42 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 95
08/31/10
Date Filed:
Page 12/06/2010
43 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 96
08/31/10
Date Filed:
Page 12/06/2010
44 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 97
08/31/10
Date Filed:
Page 12/06/2010
45 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 98
08/31/10
Date Filed:
Page 12/06/2010
46 of 77
Case:
Case10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed 99
08/31/10
Date Filed:
Page 12/06/2010
47 of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed100
08/31/10
Date Page
Filed: 48
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed101
08/31/10
Date Page
Filed: 49
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed102
08/31/10
Date Page
Filed: 50
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed103
08/31/10
Date Page
Filed: 51
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed104
08/31/10
Date Page
Filed: 52
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed105
08/31/10
Date Page
Filed: 53
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed106
08/31/10
Date Page
Filed: 54
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed107
08/31/10
Date Page
Filed: 55
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed108
08/31/10
Date Page
Filed: 56
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed109
08/31/10
Date Page
Filed: 57
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed110
08/31/10
Date Page
Filed: 58
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed111
08/31/10
Date Page
Filed: 59
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed112
08/31/10
Date Page
Filed: 60
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed113
08/31/10
Date Page
Filed: 61
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed114
08/31/10
Date Page
Filed: 62
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed115
08/31/10
Date Page
Filed: 63
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed116
08/31/10
Date Page
Filed: 64
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed117
08/31/10
Date Page
Filed: 65
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed118
08/31/10
Date Page
Filed: 66
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed119
08/31/10
Date Page
Filed: 67
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed120
08/31/10
Date Page
Filed: 68
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed121
08/31/10
Date Page
Filed: 69
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed122
08/31/10
Date Page
Filed: 70
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed123
08/31/10
Date Page
Filed: 71
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed124
08/31/10
Date Page
Filed: 72
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed125
08/31/10
Date Page
Filed: 73
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed126
08/31/10
Date Page
Filed: 74
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed127
08/31/10
Date Page
Filed: 75
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed128
08/31/10
Date Page
Filed: 76
12/06/2010
of 77
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110370449
Document 140 Page:
Filed129
08/31/10
Date Page
Filed: 77
12/06/2010
of 77
EXHIBIT "4"
I am back from PA. Very Important. | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?p=2585
Case: 10-3000 Document: 003110370449 Page: 131
http://www.orlytaitzesq.com/?p=2585 Date Filed: 12/06/2010
Home
1.4 million people saw this clip, send it to another 1.4 million
Appeal of Carter Case
elections fraud around the country
From reader Carol
Quo Warranto Filed and Served
US state dep is paying to restore mosques around the world
Dr. Orly Taitz Esquire

Defend Our Freedoms Foundation – 29839 Santa Margarita Pkwy, ste 100, Rancho
Santa Margarita CA, 92688 – Copyright 2010
World's Leading Obama Eligibility Challenge Web Site

Your donations to the cause are much appreciated.
WHEN THE PEOPLE FEAR THEIR GOVERNMENT,
THERE IS TYRANNY.
WHEN THE GOVERNMENT FEARS THE PEOPLE,
THERE IS LIBERTY.
- Thomas Jefferson
The articles posted represent only the opinion of the writers, do not necessarily represent the opinion of Dr. Taitz, ESQ, and Dr. Taitz, ESQ has no means of
checking the veracity of all the claims and allegations in the articles.
I am back from PA. Very Important.

Posted on | June 27, 2009 | 5 Comments
I appreciate everybody calling and e-mailing and texting to make sure I am OK. I am OK….I had to go to PA
to appear at the hearing in the garbage law suit filed by Philip Berg. My wireless connection didn’t work
there, I couldn’t blog.
I returned yesterday at 12:30 and and was doing a radio show in VA with Chuck Chrismayer. You can reach
him at 800-754-1822 or 804-677-2783, he will have archives of the show.
1 of 7 12/6/2010 12:43 AM
I had to work from 1-5:30 and later wanted to have dinner and spend some time with my family.
In regards to Berg things are going well. Judge denied all of his motions for default judgment against me and
clerical default was lifted, he gave me a pro hac vice to represent my foundation, denied all of Berg’s motions
for injunction against me and, what is most important he ordered Berg to show cause, why his case should not
be dismissed due to lack of jurisdiction. For those of you, who are not attorneys, it is a very good sign that the
judge is very inclined to dismiss Berg’s case due to lack of jurisdiction. I would like to explain that if the case
is filed out of state, the first thing that is being reviewed, is jurisdiction. It doesn’t mean that the case has any
merit aside from jurisdiction, it means that this court cannot hear it. I believe Berg filed it in PA to simply
cause me to waste time and money, going to Philly. At any rate, I am not concerned about this frivolous law
suit, I am though concerned about something else.
On the plane to Philly I read hundreds of pages of transcripts in criminal case hearings of Liberi. Keep in
mind that recently I had threats “to shoot me and burn my body for the world to see”. Later a clamp was
missing and fumes emissions hose was disconnected in my car, that lead to the fumes accumulating around
the engine, which is extremely dangerous.
As I read August 4, 2004 transcript, I found a testimony of detective Liebreich. He testified in regards to
recording of phone calls Lisa Liberi made from jail to her husband Brent Liberi. She was telling him that she
was upset with her sister Cheryl Richardson. Cheryl cooperated with the police and told them about 19 prior
criminal investigations of Liberi. Liberi told Brent (see copies of the transcripts attached) that she will get her
sister in jail and will spread the word that she is a rat. She was telling Brent “do you know what they do in
prison to rats?”
At that time DA James Secord asked the detective to explain. The detective stated that a contract will be
issued on such person, a green light and such person will be attacked and/ or killed. He mentioned that 5
people were killed last year alone. I got concerned, if this woman could plan a hit, a contract on her
own sister, it would not be inconceivable that she would plan a hit on an attorney and her family, if this
attorney outed her. I kept reading and found out that indeed less then a year later her sister was dead. Official
cause of death, from what I understand, is drug overdose. However, drug overdose can be self inflicted or
inflicted by others.
At this time I would like to know if there are any pathologists among the readers of this blog? Can someone
go to the police department and probation department in Santa Fe NM and show them all this info.
According to detective Teresa Standiford from Orange County economic crimes unit, my report and the
whole file was transferred to Santa Fe, as Lisa Liberi lives there. I tried to find out the status, but it is very
hard to reach anybody in the police department there. The phone number of detective Teresa Standford in CA
714-647-7486, 714-647-7038. Case # 09-068339.
Liberi’s prosecuting DA in Ca is James Secord 909-387-8309
In Santa Fe I was given a number for detective Martin Lopez 505-955-5010, General number for the Santa Fe
police is 505-955-5038. Investigations unit- 505-955-5038
The supervisor of her probation department is Joan Martinez 505-476-2359 Regional probation officer is
Rose Bobchack 505-476-2363.
After the hearing on Thursday I talked to Phil Berg and I have shown him the transcripts of Liberi’s prior
hearings. I put him on notice in regards to her dangerous propensities and let him know that if he continues
with this law suits and continues denying, what is clearly a public record, he endangers me and my whole
family. If something happens and Liberi is involved, he will be held accountable as an accomplice.
2 of 7 12/6/2010 12:43 AM
3 of 7 12/6/2010 12:43 AM
4 of 7 12/6/2010 12:43 AM
5 of 7 12/6/2010 12:43 AM
Category: Events, Uncategorized
Comments
5 Responses to “I am back from PA. Very Important.”
1. sillyhaha
June 27th, 2009 @ 5:57 pm
I am thrilled that all went well for you and the other defendants on Thur! Seems like the Judge feels
that this case is a complete waste of time and unfair to all the defendants. It is a frivolous case.
Interesting info on Lisa Liberi. Sounds like she may be looking at more legal problems as a result of
going after you and Linda Starr. Serves her right…and I hope Berg gets sanctioned for this nonsense.
Well done, Dr. Taitz!!!
2. sillyhaha
June 27th, 2009 @ 6:22 pm
Dr. Taitz,
Please be careful. This Lisa Liberi woman is dangerous. Thank God she doesn’t live near you.
Somewhere someone talked about escorting you to the courthouse on the 13th…he would be carrying a
gun. This concerns me. He won’t be allowed in with the gun. And, I wouldn’t want anything to damage
your reputation. I personally would leave all guns at home. Peaceful protesters can assist you to and
from the building. After the von Brunn incident, I would hate to see further linking of guns/violence
and the citizenship issue.
3. Bill Angles
June 27th, 2009 @ 6:52 pm
Searched web for Chuck Crismayer with no luck, so I called phone number you posted and talked with
Mr. CRISMIER. He was kind enough to give me instructions to be able to hear your interview with
him. Thought I would pass it on: http://www.saveus.org Click on Viewpoint broadcast button on left
side of page, click on ARCHIVES. Interview is posted there. Of all the interviews I’ve listened to (and
that is most of them) this is the best. Mr. Crismier did a great job with his supporting commentary. He is
a first-class broadcaster, talented enough to have a show on a major network in my opinion.
4. tainler
June 27th, 2009 @ 8:20 pm
I am VERY concerned for Orly and her family. Lisa liberi doesnt have to live close to Orly to attempt
anything. If she has connections to “get rid of someone” then all she needs is a phone or computer. Is
there a way to investigate her computer or tap her phone lines that would be legal? A very frightening
situation. I am starting to wonder if Lisa L. has any deep ties with obama and his clan. I’m sure she
does. Anyway, remember AirFrance flight 447 that just crashed in the ocean? I read there there were
people of “status” that maybe were or could expose anything government wise and suspiciously enough
the plane went down. Orly should not announce any travel plans, flight information and should not
leave her car at the airport. Is there any way that police could be notified ahead of time and have the
area checked out at the location of the hearing on the 13th…. looking for snipers, a “so-called” drunk
6 of 7 12/6/2010 12:43 AM
driver that could run up on a sidewalk and kill anyone with their car and make it look like an accident?
I personally feel every act of protection should be high priority for Orly and her family’s safety. They
know she will be gone on this trip…will her house, family, personal property be safe? Is it possible to
have a neighborhood watch while she is gone or have the police do frequent checks at her house while
not there? I know Orly is smart but she probably is the most hated person by Obama and his corrupt
thugs. I just want Orly and her family to be safe. The electrical wires to her house should be checked
too as well as air conditioning units. Anything can be done to those things to make them malfunction
and overheat. Not sure if this should be posted as long as Orly reads it.
5. live oak
June 27th, 2009 @ 10:03 pm
It’s really good to have you back Orly! I’m so sorry that you’ve had to spend time away from your
family with this mess that Berg has caused you, and I hope the good people that did donate to Berg can
get their money back. Mr. Berg should have to pay all your court costs and expenses as well. What he
has done to you and to the profession is beyond despicable!
Please be careful Orly. We all love you and have you in our prayers. Have a peaceful and relaxing
weekend with your family. No worries. Monday is a big day. I pray that this will be over soon while
America is still recognizable.
!! IMPORTANT NOTICES – PLEASE READ !!
NEW! CA REP CENTRAL COMMITTEE LIST

CAMPAIGN FLIER for Orly Taitz as CA SOS
CAMPAIGN FLIER for Orly Taitz as CA SOS, 2 Per Page
How to contact public Integrity unit
See The PDF File Here
US Department of Justice has a special unit in their Criminal Division called the
PUBLIC INTEGRITY SECTION
Contact Orly!
email: dr_taitz@yahoo.com Urgent? Call: 949-683-5411
Recent Posts
as I’ve been fighting and arguing with Obots, I was drafting this supplemental brief
What a generous deal from the regime: only one year in prison for standing up for the constitution
is it 1861 all over again?
From Sean Hannity show “discussion web site”
Latest: 6 state legislatures will be reviewing eligibility bills next year. Terry Lakin trial is Dec 14-15 9
am Fort Meade. Make an effort to be there and support Terry
Categories
Dossiers (48)
Dr. Orly TV; Videos (106)
DUNNGATE (68)
7 of 7 12/6/2010 12:43 AM
EXHIBIT "5"
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No.: 09-Civ-81255-DIMITROULEAS/SNOW
MARSHA G. RIVERNIDER,
ROBERT H. RIVERNIDER, and
CHARLES EDWARD LINCOLN, III,
Plaintiffs,
vs.
U.S. BANK NATIONAL ASSOCIATION,

As Trustee for the C-Bass Mortgage Loan
Asset-Backed Certificates, Series 2006-CBS,
and all John & Jane Does, 1-10,
Defendants.
AFFIDAVIT OF CHARLES EDWARD LINCOLN, III
I, Charles Edward Lincoln, III am over the age of eighteen (18) and am a Plaintiff in the
above-entitled-and-numbered cause. I have personal knowledge of the facts stated herein and
when called to do so, I can and will competently testify to the same in open court.
I declare the following facts to be true and correct:
1. On June 25, 2009, I was with Orly Taitz in Philadelphia, after the morning
hearing in the case of Liberi v. Taitz. Pending before Judge Eduardo Robreno in the United
States District Court for the Eastern District of Pennsylvania.
2. As of that date I had only met Philip J. Berg in Court and Orly had just barely
introduced me to him. I had never met him before that date. I had never communicated with
him before that date, although I had heard about him in connection with his several well-
known litigations concerning the events of 9/11 and then in connection with Barack Obama.
3. I had begun working on the LIberi case with Orly Taitz on June 9, 2009.
Affidavit of Charles Edward Lincoln, III, regarding Dr. Orly Taitz 1

4. Orly Taitz and I rented a car (my driver's license, her credit card) after the hearing
on Tuesday and we drove around New Jersey for the purpose of Orly making a police report
concerning Lisa Ostella and to request her arrest and prosecution for fraud, forgery, and/or
embezzlement of funds belonging to Defend Our Freedoms Foundations, Inc. of which Orly
Taitz was President. Orly Taitz has accused several people of forgery (See Exhibit A).
5. Orly Taitz asked me to drive because she said she was too tired to drive, and so
she did not even give her driver's license at the car rental, although we both signed the rental
agreement.
6. At that time I knew nothing about Lisa Ostella (except that she was a Plaintiff
against Orly together with Lisa Liberi in Liberi v. Taitz. I did not even realize how closely
Lisa Ostella and Orly Taitz had worked together.
7. Orly Taitz said that she had reason to believe that Lisa Ostella had
misappropriated funds belonging to her and/or her foundation.
8. Orly Taitz carried with her several copies of a very large file which, she said,
contained the evidence of Lisa Ostella's embezzlement and/or fraud.
9. I knew absolutely nothing about the allegations against Lisa Ostella or anything
else to do with her. I did not examine the contents of the file at all.
10. Orly and I had been up all night the night before; the original purpose of our
meeting was to prepare for the hearing but other things happened that night, and frankly I
was energized and just delighted to be driving Orly around New Jersey: with someone with
whom I had spent such a wonderful, romantic, night as the night before. I was in a rather
happy daze at the time, which seems pretty ironic and stupid now, but even "during the
moment" I recall thinking that Orly was at the very least unusually intense and eccentric.

11. We went to several towns and I cannot at the present time recall what those towns
were, but we drove a very long circuit around New Jersey. I recall that we were basically
driving in circles around Highways 1, 130, and 206.
12. I remember these highways between Princeton and New Brunswick because I
used to visit friends at the Institute of Advanced Studies as well as the
archaeology/anthropology and history departments at Princeton University and Rutgers
University. But the towns Orly wanted to visit were all strange to me and I was so focused
on Orly I wasn't really thinking about the political geography.
13. We went to several police stations and each time Orly announced herself,
requested to speak to a supervising officer, and offered one of her large (apparently
duplicate) files concerning Lisa Ostella; Orly called her various "investigative files" by the
term "Dossiers" but I am not sure which "Dossier" this was. However, the document she
was circulating on that day might have been Orly's "Dossier #6", and if not, it was a very
"
similar document.
14. Exhibit A is a true and correct copy of the cover letter for Orly's famous "Dossier
#6" which Orly had sent to U.S. Attorney General Eric Holder, FBI Chief Robert Mueller
and others on April 08, 2009, which she sent in the form of an "open letter posted ·on the
internet and forwarded to 26,000 outlets of US and international media."
15. The central focus of the first page of this letter are the bolded words:
Dossier #6 Further evidence of forgery; more questions raised in regard to illegal
campaign contributions; efforts to undermine fundraising of dissidents, criminal
element used; more cyber crimes, defamation of character, identity theft; false leaders
of the dissident constitutional movement.

16. Each time, the officer who received her file looked at the file and told her it was
not in the proper form of a sworn complaint, and that it appeared to have to do with events in
California which had already been reported to California police and/or Federal authorities.
17. 1 really wasn't paying much attention, 1 admit, but Orly got angry and started
arguments with officers at each point. 1 told her that it seemed futile to persist, but when we
got to the third (I think) and final police station, (some nice suburban city center, surrounded
by grass, 1 cannot remember the name but 1 can picture it in my mind) it was after 5:00 p.m.
and all the day staff had departed.
18. Orly insisted on talking to someone. At first the security guard The officer
politely told her it was out of their jurisdiction after which she started yelling. The officer
was giving us very strange looks. 1 told him that she had been tlrrough a lot and he started to
raise his hand as if to call time out or tell her to stop or something and 1 saw she was about to
explode at him. 1 didn't think that would have helped at all and 1 was mildly worried the
officer might think Orly was disturbed or on drugs or drunk or something (especially because
her eyes were bulging and bloodshot from lack of sleep, even though she had slept a little in
the car during the day) so 1 grabbed her and kissed her and squeezed her and told her to calm
down, which she did, and smiled, and finally we left, without having filed any reports
anywhere. She whispered that the police were corrupt and stupid and it made her crazy. 1
told her "welcome to the world that I've lived in for twenty years."
19. The last officer told her there was no possible way that he could accept the
papers even during regular business hours because they had no system for receiving such
evidence. Orly wondered why the police were so inefficient. We drove back to Philadelphia.

20. It was, for me, more like a "lover's picnic" (it was a very nice, beautiful day) than
anything else. Orly was agitated while she was at the Police stations but not otherwise.
21. Periodically she would get calls from her husband and apologize to me for
speaking to him in Hebrew.
22. I told Orly that I thought that the best way to raise the issues she wanted to raise
were by filing a counterclaim in the civil action, but she said she was afraid that it would
more likely cause venue to remain in Philadelphia rather than being dismissed for want of
jurisdiction or transferred out to California or Texas.
23. I declare under the Penalty of Perjury of the Laws of the United States that the
above-and-foregoing statements of fact are true and correct.
Signed and executed this Saturday, the 23 rd day of January.. 2010 in West Palm Beach,
Palm Beach County, in the State of Florida.
Affidavit of Charles Edward Lincoln, Ill, regarding Dr. Orly Taitz 5

NOTARY ACKNOWLEDGMENT OF INDIVIDUAL
STATE OF FLORIDA §
PALM BEACH COUNTY §
The foregoing affidavit was acknowledged before me, ~_r=.=.: _t=:-,- - -~-,- - -M K_,,-_o_c..:::c....A _
Name of Notary
in my official presence, on this Saturday the 23 rd day of January 2010, by Charles Edward
Lincoln, III, who appeared in person before me and, who whereupon, having produced
satisfactory legal identification at my place of business at CJ '1" \j', II (l...li-e... ~ IlJ/ , West
Palm Beach, Florida 33409, did then and there take the oath which I duly administered to him as
~~ of Florida, authorized to do.
.Notary Public, West Palm Beach,

Palm Beach County, State of Florida
9') \ V
----'-_;>
1\
It Cr '"
' _ _'
e( J S'.
l!
1
TC OJ O)~ , West Palm Beach, Florida 33409
Business Address of Notary
' VEAMrDZA
My Commission Expires: J11A r c& 2. i L IL
0
4}
,
:
•
•
!
MY CQMMISSION' DO 755817
exPIRES: M8Idt 2, 2012
BonIiId llW NcarJ NiIO iJnclerwItIIrI
Commission #_ _ D_\)__-:+_~~_~
__Il-
__ NOTARIAL SEAL
Affixed Above

Exhibit A:
Copy of
"Open letter posted on the internet":
Cover or Transmittal..
Fronl Dr. Orly Taitz, Esq. to
Attorney General Eric Holder, et al.
Dated
04.08.09

Dossier #6
Dr. Orly Taitz, ESQ
26302 La Paz ste 211
Mission Viejo CA 92691
ph 949-683-5411
fax 949-586-2082
dr taitz@yahoo.com
www.repubx.com
04.08.09.
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;
Legal Counsel to the Chairman of Joint
Chiefs of Staff Admiral Mullen, Captain Crawford
Via Certified mail, return receipt, restricted delivery addressee only
Dossier #6 in the form of
open letter posted on the internet and forwarded to 26,000 outlets of US and international media
Dossier #6 Further evidence of forgery; more questioned raised

in regards to illegal campaign contributions; efforts to
undermine fundraising of dissidents, criminal element used;
more cyber crimes, defamation of character, identity theft; false
leaders of the dissident constitutional movement.
Please see in attachment affidavit of licensed private investigator Jorge Baro and forensic
document examiner Sandra Ramsey Lines. Both are stating that Certification of Live
Birth posted by Obama on internet cannot be viewed as genuine and original birth
certificate from the vault in Hawaii needs to be produced to verify his place of birth and
citizenship.
Further you can see a statement by Suzie Murzinski in regards to fundraising by Obama
in Senegal, using Western Union. Fundraising abroad for the presidential election is
illegal and this statement is consistent with prior reports of Obama illegally getting
campaign contributions from abroad, mostly from Arabic Muslim countries.
Further you can see receipts showing diversion of campaign contributions. I have
received e-mails from donors, stating that they had problems with pay-pal. I described
these problems in dossier #5, specifically that the e-mail address in my blog for pay-pal
was changed, which prevented me from raising funds. My web master Lisa Ostella stated
that such a report gives her, as a web master. bad name and demanded that I take the
hacking report back. She stated that she was convinced that the changing of the e-mail
address was done by a volunteer moderator Fran, she stated that she locked Fran from the
blog and that should solve the problem. I felt that the matter needs to be investigated by
the FBI and I felt that they should draw their own conclusions. Ms. Ostella stated that if I
do not take back my complaint to FBI, she will no longer host my foundation on her
server. When I found a new web master to host my foundation, Ms. Ostella instead of
transferring the access codes and the domain, has locked me and another volunteer
moderator out of the blog, posted a bizarre defamatory statement, that I supposedly
authorized hacking into my own account and further defamatory comments about me
were placed under different names and aliases. Moreover, there were comments posted
supposedly under my name, even though I was locked out of the account and couldn't
respond. I got reports that some defamatory comments were made under alias usually
used by Lisa Liberi, assistant for Attorney Phillip Berg, who filed similar legal actions. I
started receiving statements and copies of pay -pal receipts, showing instead of my e
mail address, an e-mail address of Lisa Ostella. Originally, I thought that maybe her
address showed on the receipt, since she was a web master on the account, however,
when I checked the names and dates on the receipts against the names on the roster, that I
downloaded earlier, I could see that those were not received by the foundation, those
donations were missing.
A couple of weeks ago I have received a phone call, providing infonnation that Lisa
Liberi, a paralegal, assisting Mr. Berg, has an extensive criminal r~cord. I decided to
verify that. According to Mr. Neil Sankey, licensed private investigator with 20 years of
experience in Scotland Yard and over 12 years of experience in US, those statements
were correct. Lisa Liberi aka Lisa Richardson aka Lisa Courville and other aliases had an
extensive criminal record going back to 1990s, that included Grand Theft, forgery,
forgery of seals "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." (see attachment). Please see the report attached and reports
relating to criminal conviction in San Bernardino California. Interesting fact is that Lisa
Liberi was convicted recently, in March of2008, she was supposed to serve 8 years in
jail. Miraculously this 8 year jail tenn was reduced to probation and an order to repay the
victims. When I added up all the restitutions in the conviction, it added up to 21,000 per
month. Where is this money coming from? Who is paying it? And paying to do what? I
have sent an e-mail to Philip Berg, alerting him to this matter, however I did not hear
from him back. After I raised my concerns to other parties and they confronted Liberi,
she tried to claim that it is not her, but another Liberi, that she lives in PA and the one
convicted lives in NM, however several sources confinned that she indeed lives in NM,
they confinned her date of birth and appearance as matching the ones on file with the San
Bernardino, CA district attorney. I tried to analyze the instances when Liberi was the
most vicious in her attacks towards me and found two distinct areas:
a. Obama's Natural Born status and definition of it
b. my efforts to conduct investigation of illegal, criminal activity and my efforts to have
FBI and attorney generals of different states involved.
In regards to the Natural Born status, she claimed that she has written pleadings for Phil
Berg and that the citizenship ofObama's father is of no importance. This was repeated
time and again when she appeared together with Phil Berg at different radio programs. In
reality definition of Natural Born citizen is, that it is one, who is born in the country, with
both parents citizens of the country, one that does not have allegiance to any other
sovereignty at birth. It appears that it was an effort to sway the public and redirect
attention from the most obvious, the fact that Obama's father was not a citizen of the US
and therefore he does not qualify, no matter where he was born. Did someone help Liberi
avoid 8 year jail term here in CA in exchange for her efforts to cloud the issue?
Second issue dealt with criminal activities surrounding Obama and his supporters. I have
been the only one investigating those issues. Why?
Another interesting fact. Plains radio had a legal action against a blog radio talk show
host Evelyn Adams aka momma E. Momma E is represented in this action by attorney
Philip Berg. When Lisa Ostella locked me out of my own foundation, due to the fact that
she has registered the domain before I had an opportunity to do so; she created several
diversionary blogs and posted links to Momma E and a few other parties that are rumored
to be plants, meaning false leaders of the movement.
I am not a historian and not a theologist, however this whole situation reminds me of a
story ofShabtai Zvi. A few centuries ago there was a false leader in Europe, his name
was Shabtai Zvi. He claimed to be a Masaya and thousands followed him until he was
summoned by a sultan, who has given Zvi two choices:
First- if you are really a Masaya, you will be executed, but you will be resurrected as a
Masaya. ~
Second - if you are not a Masaya and want to live, you have to convert to Islam.
Within about five minutes Shabtai Zvi put on a Muslim garb and converted and that was
the end of the false Masaya, false leader and false movement.
Similarly here, a leader is judged by his willingness to go all the way, regardless of
hardships and risks or financial problems. You can't talk only about the birth certificate
and not see an elephant in the room, which is Obama'd British citizenship at birth, based
on his father's citizenship. You can't talk about his birth certificate only and not demand
immediate investigation of his numerous reported social security numbers, reported
forgery of the Selective Service Certificate, perjury on the Illinois Bar application, all the
evidence of campaign contributions fraud, charitable foundations fraud, tax fraud and
numerous reports of his supporters being engaged in cyber crimes, intimidation,
harassment, identity theft and all the other related crimes
Due to the above I renew my demand upon all the law enforcement agencies listed in this
dossier to conduct immediate criminal investigator, I demand on behalf of my clients Quo
Warranto proceedings to resolve those issues once and for all.
Sincerely,
Dr. orty Taitz, ESQ
Ph 949-683-5411
Fax 949-586-2082
Dr_taitz@yahoo.com
www.repubx.com

Liberi V Taitz Appellees Exb E - Affd of Waddell To Their Emergency Motion For A TRO

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Liberi V Taitz Appellees Exb E - Affd of Waddell To Their Emergency Motion For A TRO

Uploaded by

Copyright:

Available Formats

Case: 10-3000 Document: 003110370449 Page: 1 Date Filed: 12/06/2010

Case No. 10-3000

On Appeal from the U.S. District Court, Eastern District of Pennsylvania,

AFFIDAVIT OF SHIRLEY WADDELL

Philip J. Berg, Esquire

Attorney for Appellees

AFFIDAVIT OF SHIRLEY WADDELL

so, I could and would competently testify under oath.

1. November 10th, 2010 my daughter Lisa Liberi (hereinafter Liberi)

received an email on her computer AOL account addressed from:

“convictedfelon@lisaliberi.com". In this email someone had written a message

had set up a Domain/Website/Email account in my daughter’s name without her

permission. There were different postings in different categories/articles that

had been set up.

 One category “I just received a fabulous gift”, was regarding

 One category “Fabulous Felon Resume” related to a rap sheet

 One category “I’m so glamorous” classified Liberi with a

 One category “A great woman!” Compared Liberi to llse

 One category Me! Me! All about me! Was supposed to be

2. Other Websites picked up on this disgusting, offensive, vulgar website

of http://lisaliberi.com very fast. Whois is an Internet directory service for

website http://lisaliberi.com with a fake address of 123 Secret Dr. As the

affidavit, we are still waiting for more paperwork on this

3. The written contents within the category/articles are changed from

Belcher [hereinafter at times "Belcher"], Orly Taitz [hereinafter at times

"Taitz"], and Staples) are involved in this Domain/Website/Email conspiracy to

do harm to Liberi. Since other websites picked up on Whois, and Public

Domain Registration, and Geoffrey Staples’ name became public on November

was added to website.

4. Liberi found out that emails from convictedfelon@lisaliberi.com

picture of Liberi on Taitz’s website, Facebook and on Pacer with Judge

photograph was to have hacked into Liberi’s computer. This “computer

was on Liberi’s computer and later posted by Taitz at many locations.

would be reviewable by Appellate Judges. Taitz knew that documents on Pacer

document after document of untrue, prejudicial, inflammatory material in her

Notary stamp, Notary acknowledgment, and Notary information. Taitz, a

forged/altered/manufactured in order to frame Lisa Liberi, in another attempt to

on Pacer without redacting the sensitive information of the Berg supporters.

6. When Taitz would file these documents on Pacer of Judge Robreno’s

then vindictively post something about Liberi that would be of a defaming,

Third Circuit Court of Appeals, not in his Court.

7. Taitz does background checks on individuals without a permissible

with other accusations.

8. Taitz posted Liberi’s Social Security number, mother’s maiden name,

mailed, emailed, and faxed this information internationally on numerous

emailed, posted, and faxed Liberi’s sensitive information in other documents.

where Liberi would be financially ruined beyond restoration, falsely accused of

lower Court Judge Robreno.

separate occasions if she had published Liberi’s Social Security number. On

and how important to have transparency in government. She went on to say

that “However, you don’t achieve transparency in government by submitting

documents prepared by a convicted forger of documents”, see the June 25,

also received Affidavits that Orly Taitz had suborned perjury.

documents supplied to him regarding Taitz’s postings. He took Orly Taitz at

controversy as to which number belongs to her that he would advise the

14, Judge Robreno said that it serves no purpose whatsoever to publish

parties then Mr. Berg was to bring it to Judge Robreno’s attention.

the Defendants to be in the right. Taitz completely ignored Judge Robreno’s

call Santa Fe Police Department, Coroner and get information on my daughter

She also published Santa Fe Probation department’s telephone numbers and

(white supremacist group supposedly started by a friend of Defendant Ed Hale)

about professionally kidnapping Ostella's children. Affidavit of Ostella is filed