2013-12-17 - LIBERI V TAITZ - Reply To Response To Emergency Motion

Case No.
13-56253
IN THE UNITED STATES COURT OF APPEALS
FOR THE NINTH CIRCUIT
Lisa Liberi, et al.,
Plaintiffs/ Appellees,
vs.
Orly Taitz, et al.,
Defendant/ Appellant.
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__________________________ )
Appeal from the United States
District Court for the Central
District of California
Civil Action No.: 8:11-CV-
00485-AG (AJWx)
REPLYBY APPELLANT,
ORLY TAITZ, TO OPPOSITION OF APPELLEE, GO EXCEL GLOBAL,
TO EMERGENCY MOTION UNDER CIRCUIT RULE 27-3 FOR ORDER
BARRING GO EXCEL GLOBAL, A NON-EXISTENT PURPORTED
CORPORATION, FROM PARTICIPATING IN APPEAL
NOTICE OF NON-OPPOSITION BY APPELLANT TO EMERGENCY
MOTION UNDER CIRCUIT RULE 27-3 FOR ORDER BARRING
APPELLEE, LAW OFFICES OF PHILIP J. BERG, A NON-EXISTENT
PURPORTED ENTITY, FROM PARTICIPATING IN APPEAL
Kim Schumapn, Esq., CSBN 170942
Jeffre_y Cunmngham;., Esq., CSBN 151067
SCHUMANN LLP
3100 S. Bristol St.hSuite 100
Costa Mesa, CA 9L626
(714) 850-0210- telephone
(714) 850-0551- fax
Counsel for Defendant/ Appellant,
Orly Taitz
Case: 13-56253 12/17/2013 ID: 8905853 DktEntry: 11 Page: 1 of 21
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Defendant and Appellant, ORL Y TAITZ ("Taitz"), respectfully submits this
Reply to the Opposition of Plaintiff and Appellee, GO EXCEL GLOBAL
("Excel"), to her Motion for an Order barring Excel from participating in this
appeal, including but not limited to filing any brief, submitting oral argument or
participating in any other manner.
Taitz also submits this Notice of Non-Opposition regarding the portion of
her Motion for an Order barring Plaintiff and Appellee, LAW OFFICES OF
PHILIP J. BERG (the "Berg Offices"), from participating in this appeal, including
but not limited to filing any brief, submitting oral argument or participating in any
other manner.
I. Gittler & Bradford Misrepresent hat Excel is an Existing Entity with
Standing to Participate in the Appeal. In Fact, Excel is a Former
Corporation Which Has Had its Charter Revoked and Thus, as a
Matter of Law, Lacks Legal Standing to Participate Herein
Excel in its Opposition, submitted by Gittler & Bradford, misrepresent that
Excel is an corporation with legal standing to participate in this appeal.
(Opposition, pg. 3 and its "Exhibit A.")
Plaintiffs had not previously identified what type of entity (corporation,
limited liability company, etc.) Excel claimed to be, nor provided any other
information, such as its entity number, regarding it.
Plaintiffs now claim that Excel is a New Jersey corporation and submit
information from the New Jersey Secretary of State providing its entity number.
Using this new information, Taitz has obtained a Business Entity
Information and Records Service report from the website of the New Jersey
Secretary of State regarding Excel, a copy of which is attached hereto as "Exhibit
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E."
This report provides in part: "Status: REVOKED FOR NOT FILING
ANNUAL REPORT FOR 2 CONSECUTIVE YEARS," with its suspension
having gone into effect on January 16, 2012. (Emphasis added.)
Where Excel was a corporation, it must demonstrate that it maintains
"active" or "good standing" status with New Jersey authorities. A corporation no
longer existing, or otherwise not in good standing with the governmental body
with jurisdiction over it, does not have legal standing to prosecute or defend an
action. Grell v. Laci LeBeau Corp., 73 Cal.App.4th 1300, 1306 (1999); Palm
Valley Homeowners Assn., Inc. v. Design MTC, 85 Cal.App.4th 553, 560 (2000).
New Jersey law provides the same result- that a corporation no longer
existing, or otherwise not in good standing, does not have legal standing to
prosecute or defend an action. Higi v. Elm Tree Village, 114 N.J. Super. 88, 91,
274 A.2d 845 (1971 ); JB. Wolfe, Inc. v. Salkind, 3 N.J. 312, 70 A.2d 72 (1949).
Thus, and contrary to Gittler & Bradford's misrepresentation, Excel as a
matter of law lacks legal standing necessary to participate in this appeal. It should
be barred from doing so.
II. The Berg Offices, Which Fails to Submit Opposition to Taitz's Motion,
is Merely a Fictitious Business Name, and Not a Separate Business
Entity, and as a Matter of Law Lacks Legal Standing to Participate in
Taitz's Appeal
As established by Taitz, the Berg Offices is not a separate business entity,
but instead merely a fictitious business name used by Berg during the time that he
maintained a license to practice law issued by his home state of Pennsylvania.
Plaintiffs in opposition to the related Motion of DEFEND OUR FREEDOMS
FOUNDATIONS ("DOFF") in its appeal concur:
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"The "Law Offices of Philip Berg" is not a separate entity, but a fictitious
business name of Philip Berg, and is represented by Philip Berg, in pro per. "
("Exhibit C" to Motion, pg. 3.)
A fictitious business name is not a separate business entity, but only a
"name" used by an individual or business entity (such as a corporation, etc.). "Use
of a fictitious business name does not create a separate legal entity." Pinkerton's,
Inc. v. Superior Court, 49 Cal.App.4th 1342, 1348 (1996). Therefore, "[a] civil
action can be maintained only against a legal person ... [and] ... a nonentity is
incapable of being sued. Where a suit is brought against an entity which is legally
nonexistent, the proceeding is void ab initio and its invalidity can be called to the
attention of the court at any state of the proceeding." Oliver v. Swiss Club Tell,
222 Cal.App.2d 528, 537 (1963). "Accordingly, it is a corollary to this rule that the
objection that a plaintiff or defendant is nonexistent is not subject to waiver, as in
the case of misnomer or lack of legal capacity, because the defect is
jurisdictional." !d. at 538.
In addition to not being a business entity, Berg cannot represent himself to
the public as "Law Offices" when his license to practice has been suspended, and
to do so would be the unauthorized practice of law.
The Berg Offices does not oppose Taitz's Motion and, thus, admits that it is
not an entity with legal standing to participate in this appeal and it should be
barred from doing so.
Dated: December 17, 2013
Is/ - Jeffrey P. Cunningham
By: __________________________ _
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Kim Esq.
Jeffrey P. Cunmngham, Esq.
Attorneys for De:fendant ann
Appellant, ORL Y T AITZ
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DECLARATION OF JEFFREY P. CUNNINGHAM, ESQ. SUPPORTING
REPLY TO OPPOSITION OF MOTION BY P L I ~ T I F F AND
APPELLANT, ORLY TAITZ
I, Jeffrey P. Cunningham, declare as follows:
1. I am an attorney duly licensed to practice law in all courts of the State
of California and the United States Courts for the Ninth Circuit, and am a Partner
in the law offices of Schumann I Rosenberg, LLP, counsel for Defendant and
Appellant, ORL Y T AITZ ("Taitz"). I make this declaration based on my personal
knowledge of the facts stated herein. I gained my knowledge of those facts by
virtue of my participation in the events described herein, my preparation or review
of the documents described herein, or some combination of the foregoing as
identified herein. If called to testify to the facts stated herein, I could and would do
so competently and truthfully.
2. This declaration is submitted in support of Taitz's Reply to the
Opposition of Plaintiff and Appellee, GO EXCEL GLOBAL ("Excel"), to Taitz's
Motion for an Order barring Excel from participating in this appeal, including but
not limited to filing any brief, submitting oral argument or participating in any
other manner. It is also submitted in support of the Notice of Non-Opposition
regarding the portion ofTaitz's Motion for an Order barring Plaintiff and
Appellee, LAW OFFICES OF PHILIP J. BERG (the "Berg Offices"), from
participating in this appeal.
3. Excel in its Opposition misrepresents that it is a corporation with
legal standing to participate in this appeal. (Opposition, pg. 3 and its "Exhibit
A.") Plaintiffs had not previously identified what type of entity (corporation,
limited liability company, etc.) Excel claimed to be, nor provided any other
information, such as its entity number, regarding it.
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4. Plaintiffs now claim that Excel is a New Jersey corporation and
submit information from the New Jersey Secretary of State providing its entity
number. (Opposition, pg. 3 and its "Exhibit A.")
5. Using this new information, I have reviewed the website of the New
Jersey Secretary of State (www.secstates.com/NJ) for information regarding Excel.
On December 12, 2013, I reviewed, downloaded and printed its Business Entity
Information and Records Service report for Excel providing that its corporate
charter has been revoked. A true and correct copy of that report is attached hereto
as "Exhibit E" and is incorporated herein by this reference as though fully set
forth.
6. The Berg Offices has not submitted Opposition to the portion of
Taitz's Motion regarding it.
I hereby declare under penalty of perjury under the laws of the State of
California and of the United States of America that the above is true and correct.
Executed on December 1 7, 20 13, in Costa Mesa, California.
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By: ____________________ _
Jeffrey P. Cunningham, Esq.
Declarant
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EXHIBIT A
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New Jersey Business Gateway
Business Entity Information and Records Service
Business ld : 0400011809
Status Report For:
Report Date:
Confirmation Number:
GO EXCEL GLOBAL INCORPORATED
12/12/2013
3346381844
IDENTIFICATION NUMBER, ENTITY TYPE AND STATUS INFORMATION
Business ID Number: 0400011809
Business Type: DOMESTIC PROFIT CORPORATION
Status: REVOKED FOR NOT FILING ANNUAL REPORT FOR 2
CONSECUTIVE YEARS
Original Filing Date: 06/11/2002
Stock Amount: 100
Home Jurisdiction: NJ
Status Change Date: NOT APPLICABLE
REVOCATION/SUSPENSION INFORMATION
DOR Suspension Start
Date:
DOR Suspension End
Date:
Tax Suspension Start
Date:
Tax Suspension End
Date:
ANNUAL REPORT INFORMATION
Annual Report Month:
Last Annual Report
Filed:
Year:
01-16-2012
N/A
N/A
N/A
JUNE
11/06/2009
2009
AGENT/SERVICE OF PROCESS (SOP)INFORMATION
Agent: LISA OSTELLA
Agent/SOP Address: 2227 US HIGHWAY 1 ,N. BRUNSWICK,NJ,08902 4402
Address Status: DELIVERABLE
Main Business Address: 2227 US HIGHWAY 1,N. BRUNSWICK,NJ,08902 4402
Principal Business N/A
Address:
ASSOCIATED NAMES
Associated Name:
Type:
N/A
N/A
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PRINCIPALS
Following are the most recently reported officers/directors (corporations),
managers/members/managing members (LLCs), general partners (LPs), trustees/officers
(non-profits).
Title:
Name:
Address:
CHIEF EXEC. OFFICER (CEO)
OSTELLA,LISA
2227 US HIGHWAY 1 ,N. BRUNSWICK,NJ 08902 4402
FILING HISTORY -- CORPORATIONS, LIMITED LIABILITY COMPANIES, LIMITED PARTNERSHIPS AND
LIMITED LIABILITY PARTNERSHIPS
To order copies of any of the filings below, return to the ser vice page,
https://www.njportal.com/DOR/ businessrecords/Default . aspx and follow the instructions
for obtaining copies. Please note that trade names are filed initially with the County
Clerk(s) and are not available through this service. Contact the Division for
instructions on how to order Trade Mark documents.
Charter Documents for Corporations, LLCs, LPs and LLPs
Original Filing
(Certificate) Date :
2002
Changes and Amendments to the Original Certificate:
Note:
Filing Type
CHANGE OF AGENT AND
OFFICE
Year Filed
2009
REVOKED FOR FAILURE TO 2012
PAY ANNUAL REPORTS
Copies of some of the charter documents above, particularly those filed before August
1988 and recently filed documents (filed less than 20 work days from the current date),
may not be available for online download.
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For older filings, contact the Division for instructions on how to order.
For recent filings, allow 20 work days from the estimated filing date, revisit the
service center at https://www.njportal.com/DOR/businessrecords/Default.aspx
periodically, search for the business again and build a current list of its
filings. Repeat this procedure until the document shows on the list of documents
available for download.
The Division cannot provide information on filing requests that are in process. Only
officially filed documents are available for download.
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Case No. 13-56253
vs.
Orly Taitz, et al.,
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__________________________ ),
A_ppeal from the United States
00485-AG (AJWx)
REPLY BY APPELLANT, ORLY TAITZ, TO OPPOSITION TO
EMERGENCY MOTION UNDER CIRCUIT RULE 27-3 FOR ORDER
BARRING GITTLER & BRADFORD FROM REPRESENTING
APPELLEES, LISA LIBERI, LISA OSTELLA AND GO EXCEL GLOBAL,
OR IN THE ALTERNATIVE CLARIFYING REPRESENTATION OF
SUCH PLAINTIFFS
Kim Schumann, Esq. , CSBN 170942
Jeffre_y Cunningham;., E s g ~ CSBN 151067
SCHUMANN [RO;:,ENBERG, LLP
3100 S. Bristol St., Suite 100
Costa Mesa, CA 92626
(714) 850-0210- telephone
(714) 850-0551 -fax
Orly Taitz
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Reply regarding the Opposition of Plaintiffs and Appellees, LISA LIBERI, LISA
OSTELLA and GO EXCEL GLOBAL (collectively "Plaintiffs"), to Taitz's
Emergency Motion for an Order disqualifying Gittler & Bradford, Stephen H.
Marcus, Esq. and Randy Berg, Esq. from representing Plaintiffs, due to the
absence of any Substitution of Attorney or Request for Approval of Substitution or
Withdrawal of Counsel signed by Plaintiffs substituting such counsel in place of
Plaintiff and Appellee, PHILIP J. BERG ("Berg").
I. CONTRARY TO PLAINTIFFS' UNSUPPORTED CONTENTION,
THE DISTRICT COURT HAS NEVER "ESTABLISHED" OR
OTHERWISE APPROVED PLAINTIFFS' REPRESENTATION BY
GITTLER & BRADFORD
Plaintiffs assert that Taitz, as counsel for other Defendants [including
Defend Our Freedoms Foundations ("DOFF")], in the District Court sought the
same relief she seeks herein, and that the District Court denied such request, thus
"establishing" Gittler & Bradford's representation of Plaintiffs. (Opposition, pg.
2.) Plaintiffs are wrong.
Plaintiffs rely on the District Court's July 12, 2013 Order (Document 641,
"Exhibit A" to the Opposition) for their argument. It does not support Plaintiffs'
argument, including that it does not "establish" or otherwise approve Gittler &
Bradford's purported representation of Plaintiffs. It provides in part that Taitz, as
counsel for other Defendants, sought an Order seeking Plaintiffs' addresses for the
purpose of serving a notice of appeal by DOFF on them. That request was denied.
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That Order does not address, or even mention, whether Gittler & Bradford
complied with the mandatory procedures to be substituted in as counsel for
Plaintiffs in place of Plaintiff and Appellee, PHILIP J. BERG ("Berg").
Plaintiffs next rely on District Court Documents 633 and 634. (Opposition,
pg. 2.)
Document 633 is an "Appearance of Counsel" form regarding all Plaintiffs
("Exhibit B" to the Opposition). The "Appearance of Counsel" form is a nullity.
It did not substitute Gittler & Bradford in place of Berg. The only circumstance
where that form could potentially accomplish that purpose is where a party was
not already represented by other counsel. Here, of course, all Plaintiffs were
already represented by Berg and, thus, the "Appearance of Counsel" form has no
effect.
Document 634 is the same "Appearance of Counsel" form as Document
633, except that Document 634 was filed one day later ("Exhibit C" to the
Opposition). Document 634 is, likewise, a nullity. For these reasons,
there is no Order "establishing" or otherwise approving Gittler & Bradford's
purported representation of Plaintiffs.
Plaintiffs fail to submit any evidence that Taitz pursued the relief sought in
this Motion in the District Court. Moreover, Taitz could not have sought that relief
in the District Court, barring Gittler & Bradford from representing Plaintiffs in this
appeal or clarifying their representation in this appeal, due to the simple fact that
this appeal did not exist at that time. The District Court, also, clearly does not have
authority to issue an Order affecting representation of a party in an appeal.
The appropriate (and in fact only) forum for Taitz to seek that relief is in the
Court of Appeals.
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II. Plaintiffs Concede By Their Silence That There is No Required
Substitution of Attorney, Request for Approval of Substitution or
Withdrawal of Counsel, Nor Order Substituting Gittler & Bradford in
Place of Berg as Counsel for Plaintiffs
Taitz in her Motion discusses the mandatory procedures under the Local
Rules for counsel to substitute in place of other counsel, and demonstrates
Plaintiffs' and Gittler & Bradford's failure to comply with those required
procedures.
As shown above, Plaintiffs are silent as to compliance with those mandatory
procedures and instead rely on the irrelevant July 12, 2013 Order and "Appearance
of Counsel" form. Their silence is a tacit admission that they have not complied
with those procedures, which require the following:
1. "L.R. 83-2.3.1 Appearance by Attorney. Whenever a party has
appeared by an attorney, the party may not thereafter appear or act pro se, except
upon order made by the Court after notice to such attorney and to any other
parties who have appeared in the action. "
Plaintiffs fail to provide any Order under this Rule regarding their
representation following Berg's suspension.
2. "L.R. 83-2.3.2 Motion for Withdrawal. An attorney may not withdraw
as counsel except by leave of court. An application for leave to withdraw must be
made upon written notice given reasonably in advance to the client and to all
other parties who have appeared in the action. "
Plaintiffs fail to provide any Motion for Withdrawal, nor Order on such a
Motion, under this Rule regarding their representation following Berg's
suspension.
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3. "L.R. 83-2.3.3 Individuals. When an attorney of record for any
reason ceases to act for a party, such party must appear pro se or appoint another
attorney by a"' ritten ubstitution of attorney signed by the party and the
attorneys." (Emphasis added.)
This Rule applies to Plaintiffs, Lisa Liberi and Lisa Ostella. Berg "cease[ d]
to act for" those Plaintiffs, but there is no required Substitution of Attorney signed
by those Plaintiffs, Berg, nor Gittler & Bradford appointing it in place of Berg.
4. "L.R. 83-2.3.4 Organizations. An attorney requesting leave to
withdraw from representation of an organization of any kind (including
corporations, limited liability corporations, partnerships, limited liability
partnerships, unincorporated associations, trusts) must give written notice to the
organization of the consequences of its inability to appear pro se. "
This Rule applies to Plaintiff, Go Excel Global, which claims to be an
"organization" represented by Berg. Plaintiffs fail to provide any required "written
notice to the organization," nor Substitution of Attorney appointing Gittler &
Bradford for it.
Further, where Go Excel Global claims to be an entity it cannot, as a matter
of law, represent itself. It must be represented herein by licensed legal counsel.
In re Highley, 459 F.2d 554, 555 (9th Cir. 1972). Church of the New Testament v.
United States, 783 F.2d 771, 773 (9th Cir. 1986).
Compounding Gittler & Bradford's failure to comply with these
requirements is the lack of any writing or other evidence establishing that Liberi
and Ostella even know that Berg can longer represent them and that Gittler &
Bradford purport to represent them. Plaintiffs are silent on this issue in their
Opposition, thus tacitly admitting that Liberi and Ostella likely are unaware of the
purported change in representation.
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Under these circumstances, an Order disqualifying Gittler & Bradford,
Stephen H. Marcus, Esq. and Randy Berg, Esq. from representing Plaintiffs should
issue or, in the alternative, clarifying representation of Plaintiffs given the absence
of any Substitution of Attorney or Order allowing same.
Dated: December 1 7, 20 13
By: ________________________ _
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Kim Esq.
Jeffrey P. Cunmngham, Esq
Attorneys for Derendant ana
AppelJant, ORLY TAITZ
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Case No. 13-56253
vs.
Orly Taitz, et al.,
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)
00485-AG (AJWx)
NOTICE OF NON-OPPOSmON REGARDING EMERGENCY MOTION
UNDER CIRCUIT RULE 27-3 BY APPELLANT,
ORLY TAITZ, FOR ORDER DISQUALIFYING APPELLEE, PHILIP J.
BERG, FROM REPRESENTING APPELLEE, LAW OFFICES OF PHILIP
J. BERG
Kim Schmnann, Esq. , CSBN 170942
J effre_y Cunningham;, Esg CSBN 151067
SCHUMANN LLP
(714) 850-0210- telephone
(714) 850-0551- fax
Orly Taitz
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Notice of Non-Opposition regarding her Emergency Motion for an Order
disqualifying Plaintiff and Appellee, PHILIP J. BERG ("Berg"), from representing
Plaintiff and Appellee, LAW OFFICES OF PHILIP J. BERG ("Berg Offices"),
due to Berg's suspension of his license to practice law in his home State of
Pennsylvania.
Neither Berg nor the Berg Offices have submitted Opposition to Taitz's
Motion and it should, therefore, be granted.
Dated: December 1 7, 20 13

Kun E q.
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Jeffrey P. Cunmngham, Esq.
Attorneys for De:fendant ana
Appellant ORL Y T AITZ
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Case No. 13-56253
vs.
Orly Taitz, et al.,
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)
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)
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)
00485-AG (AJWx)
CERTIFICATE OF SERVICE
Kim Schumann, Esq., CSBN 170942
Jeffrey_ (Uf!l}ingham;., CSBN 151067
SCHUMANN LLP
(714) 850-0210- telephone
(714) 850-0551- fax
Orly Taitz
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CERTIFICATE OF SERVICE
I, Jeffrey P. Cunningham, Esq., hereby certify that true and correct copies of
Defendant, Orly Taitz's:
1. Reply by_ AQ_pellant, Orly Taitz, to Opposition of Go Excel
Global, To Emergency Motion Under Circuit Rule 27-3 for Order
Baning Go Excer Global, A Non-Existent Purpotied
from Participating fn A_j)peal ofNon-O_pJ?osition oy Appellant
to Emergency Mohon Under Ctrcmt Rule 27-3 for Order Barnng
Appellee, Law Offi.ces J. Berg, A Non-Existent Purpmted
Enhty, From Part1c1patmg tn Appeal;
2. Reply b_y Appellant, Orly Taitz, to Opposi6on to Emergency Motion
Under Circmt Rule 27-3 for Order Baning Gittler & Bradford From
Representing Appellees, Lisa Liberi, Lisa Ostella and Go Excel
Global, or in the alternative, Clarifymg Representation of Such
Plaintiffs; and
3. Notice of Non-Opposition Regarding Emergency Motion Under
Circuit Rule 27-3 by_ Appellant Orly Taitz, for Order Di qualifying
Appellee, Phillip J. -Berg, from Repre enting Appellee, Law Offices
of Phillip J. Berg.
were served electronically through the ECF Filing System on the 17th of
December, 2013, upon the following:
Phil X J. Berg, Esq. AttomeJ. for Plaintiff/ Appellee
555 ndoiTa Glen Suite 12 Phillip . Berg
PA 1944 -2531
P:f 134
F: 610 834-7659
e-mail: philjberg@gmail.com
Randy Alan Berg, Esq. Attorney for Plaintiffs/ Appellees
Stephen H. Marcus, Esq. Lisa Liberi
Gittler & Bradford Lisa M. Ostella
10537 Santa Monica Boulevard 3rd Floor Go Excel Global
Los Angeles, CA 90025 The Law Offices of Philip J. Berg
P: (310) 477-4007
Fax: (310) 474-4407
Email: raberg@gblaw.net
Taitz,
Attorney for DefendantsfnDefend Our
29 39 Santa argarita, Suite 100 Freedoms Foundations c. Law
Rancho Santa Margarita, CA 92688 Offices of Orly Taitz, Orly taitz, Inc.
e-mail: orlv.taitz(a),'gmail.com
e-mail: dr taitz(a),vahoo.com
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Mark Steven Colen, Esq.
Law Offices of Marc Steven Colen
5737 Kana Road, Suite 347
Agoura Hills, CA 91301
e-mail: mco 1 en(a).co 1 en law. com
e-mail: lcolen(a).colenlaw.com
Dated: December 17, 20 13
Attorneys for Neil Sankey, Todd
Sankey, Sankey Investi_gations, Inc.,
and The Sankey Firm, Inc.
I sf - Jeffrey P. Cunningham
B y ~ ~ ~ ~ ~ ~ ~ ~
J effrey P. Cunmngham, Esq.
-2-
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2013-12-17 - LIBERI V TAITZ - Reply To Response To Emergency Motion

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