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8/8/2019 Liberi v Taitz Appellees Exb E - Affd of Waddell to Their Emergency Motion for a TRO
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EXHIBIT "E"
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Case No. 10-3000
_______________________________________________________
UNITED STATES COURT OF APPEALSFOR 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, EsquirePennsylvania I.D. 9867555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531Ph: (610) 825-3134
Fx: (610) 834-7659Email: [email protected]
Attorney for Appellees
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One category A great woman! Compared Liberi to llseKoch as told by Herr Dr. Josef Mengele aka Angel of Deathin the nazi concentration camps. Taken from wikipedia.
One category Me ! Me! All about me! Was supposed to beLiberi talking about her life, marriage etc. Which was actuallycopied from the life of llse Koch in Wikipedia. Please seehttp://en.wikipedia.org/wiki/Ilse_Koch. They wrote how Liberienjoyed abusing the prisoners, and watched, as they would rapeone 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.
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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 cant take a joke
was added to website.
4. Liberi found out that emails from [email protected]
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 Liberis computer. Liberi notified the lower Court a few
months back about her computer being hacked. Taitz was posting a family
picture of Liberi on Taitzs website, Facebook and on Pacer with Judge
Robrenos Court, and the only way that Taitz could have gained access to this
photograph was to have hacked into Liberis computer. This computer
hacking either by Taitz or orchestrated by Taitz has now proven to be true with
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these emails being sent to Liberis AOL contacts, and posted family picture that
was on Liberis 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 Robrenos 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
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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 Robrenos
Court after the transfer order and after Taitzs appeal, then Mr. Berg would
have to answer Taitzs filing in order to protect the Plaintiffs (Appellees). Mr.
Bergs 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
Robrenos 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 Robrenos 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
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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 Taitzs website being hacked,
Ostella refused, and Taitz posted all over accusing Ostella of stealing along
with other accusations.
8. Taitz posted Liberis Social Security number, mothers 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
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emailed, posted, and faxed Liberis 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
Liberis 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 Liberis Social Security number. On
page 39, lines 16 through 21 of June 25, 2009 Court Transcript Taitz told Judge
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Robreno that she had never posted Liberis 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 Liberis 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 dont achieve transparency in government by submitting
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 Carters Court
in Santa Ana, CA. Federal Judge Carter commented in his Order that he had
also received Affidavits that Orly Taitz had suborned perjury.
documents prepared by a convicted forger of documents, see the June 25,
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11. Judge Robreno evidently did not read the Affidavits, or view the many
documents supplied to him regarding Taitzs 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. Liberis 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
someones 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
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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 Robrenos attention.
13. After the June 25 th 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 Robrenos
Order. Taitz continued her business as usual with publishing Dossier 6 with
Liberis social security number, trashing Liberi, Ostella, and Berg on radio,
with postings, whoever would listen. She also started posting on approximately
June 27 th, 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 departments 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 25 th
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
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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 Plaintiffs that contained threats from Ed Hale
toward the Plaintiffs and witnesses, Judge Robrenos Order of August 3 rd, 2010,
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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 17 th, 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 7 th, 2009 from a Joan Carr, Court reporter, in Judge
Robrenos 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 Robrenos order, but Mr. Berg brought this matter to Judge
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Robrenos 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
Robrenos Order to transfer Sankey/Taitz (DOFF) to California. Taitz did not
ask for a Stay of Transfer, however Judge Robrenos Court did not start the
transfer of records to Southern California and Texas. I do not know why.
20. Taitzs 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 Taitzs Appeal, and do not
reflect the factual content of Affidavits, evidence, and Court Transcripts.
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21. Taitz stepped up her cyber stalking, and cyber bullying attacks to
daily postings after Judge Robrenos 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 grandsons college
education, and daily needs.
22. The physical effects on Liberis 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.
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23. Since November 10 th, 2010 Taitz has quieted down with
defaming/slandering Liberi on Taitzs 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 [email protected] and
[email protected] . They hacked into Liberis 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 Taitzs MO (method of operation) tactics and belief
are that the end justifies the means, and is a philosophy that is promoted by
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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 ones 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 ____ day of December 2010.
__________________________ Shirley Waddell, Affiant
s/ Shirley Waddell(Signature sent by fax - see attached)
6th
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CALIFORNIA ALL PURPOSECERTIFICATE OF ACKNOWLEDGEMENT
State of California )
On December _____, 2010, before me, 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.
Notary
County of Sacramento )
Signature (Seal)
s/ Cyndi Nguyen
Cyndi Nguyen6
(Signature and Seal received by fax -see attached paged)
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EXHIBIT "1"
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From: [email protected]
Sent: Wed, Nov 10, 2010 11:25 amSubject: Fwd: Good morning, Convicted Felon
I just received this email in my AOL inbox, can anyone detect where it camefrom? I have attached the header info
-----Original Message-----From: [email protected]: [email protected]
Sent: Wed, Nov 10, 2010 10:37 amSubject: Good morning, Convicted Felon
Love your new website.
Yours,
Convicted Felon
To: [email protected]; [email protected]
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EXHIBIT "2"
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Z:\Liberi Ltr regarding Taitz's Criminal Acts 1
LAW OFFICES OF PHILIP J. BERG
555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531
PHILIP J. BERGCATHERINE R. BARONEBARBARA MAY
(610) 825-3134
FAX (610) 834-7659
NORMAN B. BERG, Paralegal [Deceased] E-Mail: [email protected]
October 26, 2010
Honorable Eduardo C. Robreno Hon. James SecordUnited States District Court Deputy District Attorney for the Eastern District of Pennsylvania San Bernardino County11614 U.S. Courthouse 316 North Mountain View
601 Market Street San Bernardino, CA 92415-0004Philadelphia, PA 19106-1797 Sent via Regular Mail
San Bernardino County Probation Dept.Philadelphia District Attorneys Office 175 W. Fifth Street, 4 th Floor Three South Penn Square San Bernardino, CA 92415-0460Corner of Juniper and South Penn Square Sent via Fax to (909) 387-5600Philadelphia, PA 19107-3499
Sent via Regular MailChief Judge Audrey B. Collins
U.S. Attorney's Office U.S.D.C., Central District of CA
615 Chestnut Street Courtroom 680Suite 1250 255 East Temple StreetPhiladelphia, PA 19106 Los Angeles, CA 90012
Sent via Fax to (215) 861-8618 Sent via Regular Mail
Social Security Administration Judge David O. Carter6401 Security Blvd. Courtroom 9DBaltimore, MD 21235 U.S.D.C. Central District of CA,
Sent via Regular Mail Southern Division411 west Fourth Street
Public Integrity Section Santa Ana, CA 92701-4516
Department of Justice Sent via Regular Mail950 Pennsylvania Ave., NWWashington, D.C. 20530-0001 U.S. Attorney's Office
Sent via Regular Mail 312 North Spring StreetLos Angeles, California 90012
Sent via Regular Mail
Re: Orly Taitz's Obstruction of Justice and other Criminal Acts
Sent via Fax to (267) 299-5113
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Re: Orly Taitz Obstruction of Justice and other Criminal Acts October 26, 2010Page Two
I represent Plaintiffs, Evelyn Adams, Philip J. Berg, Esq., Lisa Liberi, Lisa Ostella, LawOffices of Philip J. Berg, and Go Excel Global in a case against Orly Taitz and other Defendants. TheCase was filed in the U.S. District Court, Eastern District of PA, Case No. 09-cv-01898 before theHonorable Eduardo C. Robreno. This Case was brought due to illegal behaviors of Defendant Taitzand the other Defendants.
I am sending this letter to each of you as Orly Taitz has now been obstructing justiceand attempting to prejudice and conflict out the very Court this case has been orderedtransferred to by sending copies of letters and filings to you. My request is that these documentsshould not be read by anyone other than the Honorable Eduardo C. Robreno. Further, Ibelieve a Restraining Order should be issued against Orly Taitz to stop her current tactics andSanctions 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, Ifiled a Motion for Reconsideration of this Order, which was Granted in part by Judge Robreno. JudgeRobreno amended (corrected) his Order on June 22, 2010, which maintained the Transfer of the Caseto 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, especiallyPlaintiffs 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 enforcementreports; 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 Appealedthe Ruling, said Appeal is in the U.S. Court of Appeals for the Third Circuit. However, Orly Taitz hascontinued filing frivolous documents with Judge Robreno's Court, which include many falsifiedstatements; falsified information pertaining to the Civil Case pending against her; forged and altereddocuments in the name of Plaintiff Lisa Liberi and Lisa Ostella, and falsified recitations of pleadingsfiled by Plaintiffs, just to name a few.
In so doing, Orly Taitz has been sending her filings containing many falsified statementsforged 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'sin 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 arrestedon falsified allegations.
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Re: Orly Taitz Obstruction of Justice and other Criminal Acts October 26, 2010Page Three
Again, Orly Taitz began sending all her falsified statements, falsified recitations of pleadingsfiled by the Plaintiffs; forged and altered documents, etc., which she filed in Judge Robreno's Court toall the parties listed in this letter, including the Chief Judge of the U.S. District Court, Central Districtof California as well as Judge Carter, U.S. District Court, Central District of California, SouthernDivision 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 andOrder 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. Notonly am I concerned regarding the prejudices this creates for my clients, I am extremely concernedabout the safety of my clients.
Orly Taitz's filing of false statements (perjury) as well as forged and altered documents in thename of Plaintiffs Lisa Liberi and Lisa Ostella also constitutes Obstruction of Justice, Perjury, Forgeryand 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 OrlyTaitz.
Please do not hesitate contacting me should you require anything additional.
Thank you.
Respectfully,
Philip J. BergPJB:jb
Enclosures
cc: Orly Taitz26302 La Paz Ste 211Mission Viejo, CA 92691Ph: (949) 683-5411Fax: (949) 586-2082 Sent via Regular Mail
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EXHIBIT "A"
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IN THE UNITED STATES DISTRICT COURTFOR 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 Defendants home jurisdiction.
Before the Court is Plaintiff Bergs motion for leave to file a
motion for reconsideration (doc. no. 120), Defendant Taitzs
response (doc. no. 121) and Defendant Sankeys response (fax
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dated 6/11/10). On June 18, 2010, Plaintiff Berg filed a motion
for leave to file a motion to strike Defendant Taitzs 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. Maxs 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
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Defendant Taitzs response does not substantively1
address Plaintiff Bergs motion for leave to file a motion forreconsideration, thus it is inapposite to the issues at bar.
Defendant Sankeys letter disputes Plaintiff Liberisassertions of Pennsylvania citizenship and argues that Plaintiff
Liberi is a citizen of New Mexico. See Sankey Ltr., dated June11, 2010. However, diversity jurisdiction would only bedestroyed if Plaintiff Liberi was a citizen of either of thestates of which Defendants are citizens: California or Texas.Thus, the issue is inapposite to Plaintiff Bergs motion forleave to file a motion for reconsideration and the legalconclusions reached in this case.
-3-
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. Sankeys 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 Bergs 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:
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Point 6: There is a discrepancy in the Courts Order ofJune 3, 2010, docketed on June 4, 2010appearing as Docket Entry No. 118;
Point 8: Amendment of this Courts June 3, 2010 Order,docketed June 4, 2010, appearing, as DocketEntry No. 118 is proper. This Court has theinherent Power to amend its Final Judgment;and
Point 9: A proposed Order is attached to PlaintiffsMotion.
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 Courts Memorandum[Doc. No. 117] that the Sankey Defendants,which would be Neil Sankey, SankeyInvestigations, Inc. and The Sankey Firm, Inc.a/k/a The Sankey Firm are citizens andresidents of the State of California;
Point 2: Defendants Neil Sankey and SankeyInvestigations, Inc. are not within thejurisdiction of the U.S. District Court,Western District of Texas, but instead arelocated in the Central District of California;
Point 3: Although in Default, the Court made no mentionof transfer as to Defendant, The Sankey Firm,
Inc. a/k/a The Sankey Firm. Is the Courtplanning on keeping this one Defendant andallowing Plaintiffs to enter Default againstthem?; If not then,
Point 4: The Sankey Firm, Inc. a/k/a The Sankey Firm isa California Corporation, in the U.S. District
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Court, Central District of California,Southern Division jurisdiction. Therefore,transfer of Plaintiffs claims against thisDefendant is only proper to the U.S. DistrictCourt, Central District of California,Southern Division; and
Point 5: Defendants Neil Sankey, Sankey Investigations,Inc. and The Sankey Firm, Inc. a/k/a TheSankey Firm conducted the offenses giving riseto this suit from their office locations inCalifornia.
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 Bergs
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 forseverance of the Case; The Courts Orderstates Defendants Motion to Transfer isGranted; and on page two (2) statesDefendants Motion to Dismiss or, in the
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alternative, Motion to Transfer (doc. No. 10)is Denied as Moot. First, Doc. No. 10 is anAffidavit of Service, not a Motion to Dismissor in the alternative to Transfer. It isbelieved the Court meant Plaintiffs Motion toTransfer is Granted, as Plaintiffs had apending 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 Bergs 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 Bergs motion for leave to file a motion to
strike Defendant Taitzs response will be denied as moot.
An amended Order follows.
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On June 25, 2009, the Court issued an order that no1
further motions shall be filled without prior leave of the Court.See Court Order, doc. no. 78. No motions granted leave to fileare currently pending.
IN THE UNITED STATES DISTRICT COURTFOR 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). See Court Order, 1
doc. no. 80.
IT IS FURTHER ORDERED that, upon consideration of
Plaintiffs responses to the rule to show cause, Defendants
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All requests for leave to file pleadings submitted2
during the time the case was in suspense from December 9, 2009 toJune 4, 2010 , of which only one letter was made part of thedocket (see Berg Letter in Opp'n to Def. Taitz, dated Jan. 10,2010, doc. no. 116), are denied as moot.
- 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.
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EXHIBIT "B"
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09/17/2029 06:03 110493 P.001/080
Dr. Orly Taib, EsqAttorney Pro Se & AttorneyFor Defelld Our FreedolDl Foundation29839 Santa Margari1a Parkway, Suite 100Randlo Sa ta Margarita CA 92688
Tel: (949) ~ 5 4 1 1 ;Fa x (949) 7"-7603E-Mail: d r _ [email protected]
IN THE UNITED STATES DISTRICT COURT
FO R THE EASTERN DISTRICf OF PENNSYLVANIA
LISA LmERI, et at., ) Response to tbe 07.26.10. emergency motioplaintiffs to keep tnmscnpseal
) Motion fo r clarification an d motion-reques) fo r order to show cause, wby sanctions sh) be assessed against parties defrauding the)b y 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
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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, i l l ; and the Chief
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09/17/2029 08:08
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
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Liberi v Taitz Motion for Clarification 38
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09/17 /2029 06 :09
Office of the High Commissioner for Hwnan Rights
tel: + 4122 917 9151
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Proposed order
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This case i filed by plaintiffs on May 04., 2009. The case is fur defamatioo ofcharacter. reessenre of the case is the sworn statement hy the Plaintiff LisaLiberi and co-plaintiff and attorney Philip J Berg, claiming that Lib
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10/21/2010 13.52 949r
lsi Dr. Or! Talrz, E S Q ~_ _ _ _ _07.28.10.
er penalty of peIjury, that 1 served above ple
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Li . . aI v Taitz et 01. DefOlldm!t9""'JlO1l5"to motion. Defendantsdemand fo t $OllOIionsagainst plaintiffil.witness Sbidey Wadden and Attorney Philip I. Beti I ,
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EXHIBIT "3"
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EXHIBIT "4"
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Home1.4 million people saw this clip, send it to another 1.4 millionAppeal of Carter Caseelections fraud around the countryFrom reader CarolQuo Warranto Filed and ServedUS state dep is paying to restore mosques around the world
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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 PAto appear at the hearing in the garbage law suit filed by Philip Berg. My wireless connection didnt work there, I couldnt blog.
I returned yesterday at 12:30 and and was doing a radio show in VA with Chuck Chrismayer. You can reachhim at 800-754-1822 or 804-677-2783, he will have archives of the show.
ack from PA. Very Important. | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?p=2585
http://www.orlytaitzesq.com/?p=2585
12/6/2010 12:43 AM
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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 andclerical default was lifted, he gave me a pro hac vice to represent my foundation, denied all of Bergs motionsfor 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 Bergs case due to lack of jurisdiction. I would like to explain that if the caseis filed out of state, the first thing that is being reviewed, is jurisdiction. It doesnt 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 simplycause me to waste time and money, going to Philly. At any rate, I am not concerned about this frivolous lawsuit, 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 inmind that recently I had threats to shoot me and burn my body for the world to see. Later a clamp wasmissing and fumes emissions hose was disconnected in my car, that lead to the fumes accumulating aroundthe engine, which is extremely dangerous.
As I read August 4, 2004 transcript, I found a testimony of detective Liebreich. He testified in regards torecording 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 beissued 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 thisattorney outed her. I kept reading and found out that indeed less then a year later her sister was dead. Officialcause 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 someonego 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 thewhole file was transferred to Santa Fe, as Lisa Liberi lives there. I tried to find out the status, but it is veryhard to reach anybody in the police department there. The phone number of detective Teresa Standford in CA714-647-7486, 714-647-7038. Case # 09-068339.
Liberis 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 isRose Bobchack 505-476-2363.
After the hearing on Thursday I talked to Phil Berg and I have shown him the transcripts of Liberis prior hearings. I put him on notice in regards to her dangerous propensities and let him know that if he continueswith this law suits and continues denying, what is clearly a public record, he endangers me and my wholefamily. If something happens and Liberi is involved, he will be held accountable as an accomplice.
ack from PA. Very Important. | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?p=2585
12/6/2010 12:43 AM
Case: 10-3000 Document: 003110370449 Page: 132 Date Filed: 12/06/2010
8/8/2019 Liberi v Taitz Appellees Exb E - Affd of Waddell to Their Emergency Motion for a TRO
133/148
ack from PA. Very Important. | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?p=2585
12/6/2010 12:43 AM
Case: 10-3000 Document: 003110370449 Page: 133 Date Filed: 12/06/2010
8/8/2019 Liberi v Taitz Appellees Exb E - Affd of Waddell to Their Emergency Motion for a TRO
134/148
ack from PA. Very Important. | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?p=2585
12/6/2010 12:43 AM
Case: 10-3000 Document: 003110370449 Page: 134 Date Filed: 12/06/2010
8/8/2019 Liberi v Taitz Appellees Exb E - Affd of Waddell to Their Emergency Motion for a TRO
135/148
ack from PA. Very Important. | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?p=2585
12/6/2010 12:43 AM
Case: 10-3000 Document: 003110370449 Page: 135 Date Filed: 12/06/2010
8/8/2019 Liberi v Taitz Appellees Exb E - Affd of Waddell to Their Emergency Motion for a TRO
136/148
Category: Events , Uncategorized
Comments
5 Responses to I am back from PA. Very Important.
sillyhahaJune 27th, 2009 @ 5:57 pm
I am thrilled that all went well for you and the other defendants on Thur! Seems like the Judge feelsthat 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 rightand I hope Berg gets sanctioned for this nonsense.
Well done, Dr. Taitz!!!
1.
sillyhahaJune 27th, 2009 @ 6:22 pm
Dr. Taitz,
Please be careful. This Lisa Liberi woman is dangerous. Thank God she doesnt live near you.
Somewhere someone talked about escorting you to the courthouse on the 13thhe would be carrying agun. This concerns me. He wont be allowed in with the gun. And, I wouldnt want anything to damageyour reputation. I personally would leave all guns at home. Peaceful protesters can assist you to andfrom the building. After the von Brunn incident, I would hate to see further linking of guns/violenceand the citizenship issue.
2.
Bill AnglesJune 27th, 2009 @ 6:52 pm
Searched web for Chuck Crismayer with no luck, so I called phone number you posted and talked withMr. CRISMIER. He was kind enough to give me instructions to be able to hear your interview withhim. Thought I would pass it on: http://www.saveus.org Click on Viewpoint broadcast button on leftside of page, click on ARCHIVES. Interview is posted there. Of all the interviews Ive listened to (andthat is most of them) this is the best. Mr. Crismier did a great job with his supporting commentary. He isa first-class broadcaster, talented enough to have a show on a major network in my opinion.
3.
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 attemptanything. If she has connections to get rid of someone then all she needs is a phone or computer. Isthere a way to investigate her co