LIBERI V TATIZ (C.D. CA) - 190.9 - Plaintiffs Exhibits 48-50 To Amended Complaint.190.9

Case 8:11-cv-00485-AG -AJW Document 190-9 Filed 05/20/11 Page 1 of 25 Page ID
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EXHIBIT “48”
#:4890
Exhibit "48"
Pg. 430
| Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?p=2259
Case 8:11-cv-00485-AG -AJW Document 190-9
http://www.orlytaitzesq.com/?p=2259 Filed 05/20/11 Page 3 of 25 Page ID
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WHEN THE PEOPLE FEAR THEIR GOVERNMENT,
THERE IS TYRANNY.
WHEN THE GOVERNMENT FEARS THE PEOPLE,
THERE IS LIBERTY.
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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.
Posted on | June 15, 2009 | 12 Comments

Update on Berg
I really tried to stay away from the frivolous action by Philip Berg, as I think it is just a distraction and a waste
of my time, however since he filed a legal action and he issues frequent press releases with outrageous
slanderous statements about me, I have to respond.
This is not the first time Berg brings an action with manufactured allegations. Please see an attachment below
showing Berg being sanctioned by the court and fined over $10,000 for bringing a frivolous baseless law suit
with the sole purpose of harassing the other party.
In regards to his legal actions- the one that he called a law suit under seal, was actually not a law suit but a
request for Atty. General to file a law suit. It was stating that Obama is not only not a Natural Born Citizen, but
not a citizen at all, which is harder to prove, as he could’ve become a citizen at any time. The request, filed by
Berg, was asking the Attorney General to take back Obama’s salary of the senator, whereby Berg were to get a
certain percentage of it, as a whistleblower. I was just skeptical about the viability of such a request.
In regards to two other legal actions he filed, they were dismissed and from January Berg was saying that he
has an oral argument scheduled for May. The month of May came and went and there was no argument and
nobody could find any such argument scheduled on the docket. Now he is saying that there is an argument
Exhibit "48"
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scheduled for September-October, but again nobody can find anything scheduled.
The only law suit he has going, is one with slanderous allegations against me and his only occupation as of late
has been issuing outrageous press releases about me and asking for money so he can slander me some more
and can file more law suits against me. It is just despicable that Berg, who was sanctioned by the court and
fined for bringing frivolous action with the sole purpose of harassment is calling to have me disbarred, that
Berg, who is employing Lisa Liberi, a convicted criminal, with 10 felony convictions of grand theft, forgery of
documents and forgery of seal (see record attached), is accusing others of forgery and fraud, including a
licensed investigator with 20 years of experience in Scotland Yard and over 15 years of experience, Mr. Sankey,
a Christian minister and editor of Christian publishing Pastor James Sundquist, a radio station, a talk show
host, the wife of a talk show host and even their own volunteer. I have attached a copy of the second amended
motion to dismiss due to lack of jurisdiction. I was asked –what does it mean. You are supposed to file such a
motion first, as if there is no jurisdiction the case is dismissed right then and there before it goes any further. I
hope Eastern District Court of Pennsylvania judge Eduardo Robreno will dismiss this case shortly.
Since my foundation Defend Our Freedoms Foundation (DOFF) is registered in California, I have filed a
complaint with the Attorney General of California, Orange County FBI and Mission Viejo, Orange County
Police, asking them to investigate actions by Lisa Ostella, Lisa Liberi, Evelyn Adams and Philip Berg, whereby
Lisa Ostella is fraudulently diverting donations from DOFF to her own pocket and Liberi, Adams and Berg are
being unjustly enriched by her actions and their own actions.
I have also included a list of legal actions and initiatives I am currently spearheading. I am asking for your
support and follow up with governmental officials. I firmly believe that unsealing of Obama’s records is only a
first step in the direction of the true transparency in government, that there is a long way ahead in turning
around this economy. It will not improve with empty slogans of hope and change and wasting billions of dollars
on un-stimulating stimulus, which stimulates only the printing press, that prints funny money, which soon will
be less valuable then money from Toys R Us. This economy will not change and improve by giving billions to
the thugs from Acorn, the thugs from Hamas and the crooks from AIG transferring 59% of the stimulus to
stimulate foreign banks.
We will achieve true economic growth and improvement, when we realize that the free market economy
benefitted only a few billioners, It bankrupted this whole country. We need to go back to sanity, we need
balanced trade, we need balanced budget for each and every state and the country in general, we need to fight
governmental corruption, we need to start producing again. This is a monumental task. It will take more then
one or two lawyers to make a difference. It will take each and every one of you working 24/7 to turn this
country around. Please go through the list. I need a couple of volunteers to go through the earlier posts and
insert the contact info for the officials. Please, form lobbying groups and don’t take no for an answer. We need
to reach each and every law enforcement and governmental official and we need to make all of them
accountable. Any official, who violates the Constitution and his oath of office and allows fraud and treason, will
th
be held accountable by the citizens of this country. Please join 4 of July tea parties and September 12-13
Nation Renewal million men march on Washington. I will be speaking there.
Lawyer Slapped With $10K in Sanctions for ‘Laundry List of Unethical Actions’
Shannon P. Duffy
The Legal Intelligencer
July 25, 2005
Printer-friendly Email this Article Reprints & Permissions
Finding that a Pennsylvania lawyer had committed a “laundry list of unethical actions,” a federal judge has imposed more than
$10,000 in sanctions and ordered the lawyer to complete six hours of ethics training.
U.S. District Judge J. Curtis Joyner’s 10-page opinion in Holsworth v. Berg is packed with criticism of the
conduct of attorney Philip Berg of Lafayette Hill, Pa.
“Other attorneys should look to Mr. Berg’s actions as a blueprint for what not to do when attempting to
effectively and honorably perform the duties of the legal profession,” Joyner wrote.
“This court has grown weary of Mr. Berg’s continuous and brazen disrespect toward this court and his own
clients. Mr. Berg’s actions … are an enormous waste of judicial time and resources that this court cannot, in
good conscience, allow to go unpunished,” Joyner wrote.
Exhibit "48"
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In the suit, Berg is accused of legal malpractice by former clients who claim his failure to respond to an
ERISA claim against them led to a default judgment.
But the sanctions against Berg stem from his decision to file a third-party counterclaim of fraud against a
pension fund that had sued his former clients, according to court papers.
Joyner blasted Berg for filing the fraud claim, calling it an “irresponsible decision” because the claim was
“utterly barren of any scintilla of legal principles.”
In the ERISA suit, Berg’s former clients — Richard Holsworth and his company, Richard’s General
Contracting — were sued by a group of pension funds led by the Carpenters Health and Welfare Fund of
Philadelphia and Vicinity.
Carpenters Health claimed that Holsworth and his company had failed to make required payment of fringe
benefit contributions.
According to court papers, Joyner found that Berg “neglected to file a response to [Carpenter Health's] claim
or provide any legal defense whatsoever for his client.”
Even after a default judgment was entered against Holsworth, Joyner found that Berg “remained silent.”In
April 2002 — two months after the default judgment was granted and 11 months after the suit was first filed
— Joyner found that Berg “broke his silence” by filing a petition to strike the judgment or to open the default
judgment.
Berg’s motion was rejected and a default judgment of more than $5,300 was entered against his clients.The
judgment swelled to more than $10,000 when Carpenters Health later successfully moved for a supplemental
judgment to recover more than $4,700 in attorney fees for its efforts in responding to Berg’s untimely
motions.
Holsworth and his wife later filed a legal malpractice suit against Berg in the Philadelphia County Court of
Common Pleas, alleging that Berg negligently failed to represent them in the Carpenters Health case.
A year later, in February 2005, Berg moved to join Carpenters Health as a third-party defendant in the
malpractice suit, demanding more than $20,000 in damages.
In his counterclaim, Berg alleged that the ERISA suit filed by Carpenters Health in 2001, which led to the
malpractice claim against him, was “a fraud upon the court and a fraudulent taking from the Holsworths.”
Carpenter Health’s lawyers removed the case to federal court and filed a motion to dismiss the claim.Joyner
agreed, finding that Berg’s fraud claim was “frivolous” and was motivated by an intent “to harass Carpenters
Health and the Holsworths, as well as to delay and disrupt the administration of justice.”
The claim was fatally flawed, Joyner found, because Berg had no standing to bring suit against Carpenters
Health and had “failed to conduct even a minimally reasonable inquiry before filing his complaint.”
Granting summary judgment in favor of Carpenters Health, Joyner said he found it “wholly unnecessary”
even to consider the facts of the ERISA case because it was “abundantly clear” that Carpenters Health was
entitled to a judgment as a matter of law.
Joyner invited Carpenters Health to file a motion for Rule 11 sanctions. When it did, Joyner found that Berg
“continued his trend of unprofessional conduct by, once again, failing to file a timely response.”
In a footnote, Joyner said Berg’s response to the sanctions motion was due on May 26. In a phone call to
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chambers on May 31, Joyner said, Berg’s assistant requested permission to move for an extension of time,
saying Berg had been out of town for two or three weeks and would not be returning until June 9.
Joyner said he agreed to accept such a request if it were filed the next day, but none was.
Instead, Joyner said, a letter signed by Berg’s assistant was faxed to chambers on June 2, requesting that the
deadline be extended until June 27.
Joyner said he refused because “in light of Mr. Berg’s persistent and repeated neglect of his professional
obligations, this court was not inclined to permit Mr. Berg to further delay the review of Carpenters Health’s
ripe motion.”
In a June 2 opinion, Joyner found that Berg had violated Rule 11 by “filing a complaint completely devoid of
any basis in fact or law, as would be apparent to any reasonable attorney after the slightest inquiry.”
Berg’s fraud claim, Joyner said, was “inadequately pled, not grounded in fact, time-barred, and utterly
irrelevant to the pending malpractice action against him.”
In his sanctions order, Joyner ordered Berg to reimburse Carpenters Health the $10,668 in attorney fees and
costs it incurred in defending the claim. He also ordered Berg to complete six credits of ethics courses
certified by the Pennsylvania Board of Continuing Legal Education, and recommended that Berg be
investigated by the Pennsylvania Bar Association’s Committee on Legal Ethics and Professional
Responsibility.
On June 16, Berg filed a motion for reconsideration urging that the sanctions imposed on him should be
forgiven due to “extenuating circumstances,” including health problems, a three-week European business trip
and financial difficulties.
Berg conceded in his brief that “there were numerous procedural errors, untimely responses and omissions,”
but said he “did not do so with intention or defiance.”
Joyner flatly rejected the motion, saying “in no way, shape or form do the ‘extenuating circumstances’
proffered by Mr. Berg even begin to justify, excuse, or explain his unprofessional and unethical course of
conduct throughout this matter. These transparent excuses are not only patently insufficient to meet the legal
standard for a motion for reconsideration, they are insulting to this court and demeaning to the legal
profession.”
Berg, reached in his office, declined to comment on Joyner’s decision except to say that he is considering
whether to file an appeal.
Carpenters Health was represented by attorneys Sanford G. Rosenthal and Eric B. Meyer of Jennings
Sigmond.
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Dr. Orly Taitz, pro se
Orly Taitz Law Offices
26302 La Paz, Suite 211
Mission Viejo, California 92691
(949) 683-5411
dr_taitz@yahoo.com
UNITED STATES DISTRCT COURT

Exhibit "48"
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FOR THE EASTERN DISTRICT OF PENNSYLVANIA
Lisa Liberi, et al., §

Plaintiffs, §
§
v. § Civil Action No. 2:09-cv-01898-ER
§
Orly Taitz, et al. §
Defendants §
SECOND AMENDED MOTION TO DISMISS COUNTS ONE-SIX FOR 12(b)(1)
LACK OF SUBJECT MATTER JURISDICTION &
JUDGMENT ON THE PLEADINGS

It has long been the case that the jurisdiction of the Court depends upon the state of things at the time of the action
brought.” Mollan v. Torrance, 22 U.S. 537, 9 Wheat. 537, 539, 6 L. Ed. 154 (1824). This time-of-filing rule is
hornbook law (quite literally) [*571] taught to first-year law students in any basic course on federal civil
procedure. It measures all challenges to subject-matter jurisdiction premised upon diversity of citizenship against
the state of facts that existed at the time of filing–whether the challenge be brought shortly after filing, after the trial,
or even for the first time on appeal. (Challenges to subject-matter jurisdiction can of course be raised at any time
prior to final judgment. See Capron v. Van Noorden, 6 U.S. 126, 2 Cranch 126, 2 L. Ed. 229 (1804).
Grupo Dataflux v. Atlas Global Group, L.P., 541 U.S. 567 at 570-71; 124 S.Ct. 1920 at 1924; 158 L.Ed.2d 866 at 872 (2004).
Without wishing to minimize the appearance created by the volume of paperwork filed to date in this above-entitled-
and-numbered civil action, the case ends here or it ought to. Count One is labeled as and would apparently pretend to be a federal
cause of action, in its title only, but it is at best a California statutory suit for violation of privacy, and must accordingly be evaluated,
for subject matter jurisdiction, under the same diversity of citizenship analysis applied to the state-labeled Counts Two through Six.
The only colorable basis for Federal Court subject matter jurisdiction over the state-law “substance” (without conceding, in fact, that
there is any substance) of Counts Two (Complaint p. 66 ¶¶158-166: “Defemation[sic], per se, Slander and Libel”), Three (Complaint
p. 69, ¶¶167-173: False-Light Invasion of Privacy), Four (Complaint p. 72, §§174-181: “Harassment”), Five (Complaint p. 75,
¶¶182-189: “False Designations and Descriptions of Facts”), and Six (Complaint p. 78, ¶¶190-196: “Injunctive Relief” as to
“defamation,” “false allegations,” “misrepresentations of their character” and “false light”) would be diversity of citizenship, as is
alleged in paragraph 1 on page 4 of the original (and only) Complaint, filed in this case on May 4, 2009.
All of these “Counts” are woefully insufficient as a matter of competent federal practice and pleading, but none of these
counts contain even the suggestion of a conceivable much less plausible cause of action arising under Federal Law, so diversity is the
only imaginable basis for jurisdiction and the federal standards for diversity are neither novel nor difficult to apply: the Complaint
reveals on its face that “complete diversity of citizenship” between Plaintiffs and Defendants simply does not exist, and cannot be
cured by amendment because jurisdiction is established by the case initial “snapshot” of the parties, not later changes.
Dr. Orly Taitz admits that she is a dentist, by primary profession, and although admitted to practice in the State of California
and several federal courts, she is not primarily a litigator. Defendant also admits that “ignorance of the law is no excuse,” but would
nevertheless submit that “A party cannot inadvertently or intentionally (e.g. by agreement) waive its right to object to the Court’s lack
Exhibit "48"
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of subject matter-jurisdiction.” Insurance Company of Ireland, Ltd., v. Compagnie des Bauxites de Guinee, 456 U.S. 694 at 702,
102 S.Ct. 2099 at 2104 (1982). And since Strawbridge v. Curtiss, 7 U.S. 267, 3 Cranch 267, 2 L.Ed. 435 (decided February 13,
1806), the United States Supreme Court has read the statutory formulation “between . . . citizens of different States,” 28 U.S.C. §
1332(a)(1), to require complete diversity between all plaintiffs and all defendants. So, every other objection and contention the
parties have made up to this point set aside, the case ends here, for the following reasons which Defendant Dr. Orly Taitz
inadvertently failed to raise in her previous motions and answer:
On the first (title) page of Philip J. Berg’s Complaint for Damages, with Jury Trial Demanded, filed on May 4, 2009, and
never amended or otherwise superceded, Lisa M. Ostella and Go Excel Global are identified as Plaintiffs while James Sundquist and
Rock Salt Publishing are identified as Defendants. In paragraphs 8 and 9 on page 5 of the May 4, 2009, complaint, Lisa M. Ostella is
identified as residing at 2227 US Highway 1, #245, North Brunswick, New Jersey 08902-4402 with her principal place of business
at the offices of Plaintiff Go Excel Global, also in North Brunswick, New Jersey 08902-4402.
On page 6 of the May 4, 2009, complaint, in paragraphs 16-17, a Defendant James Sundquist and his principal place of
business Rock Salt Publishing are identified as having a business address of 551 Valley Road, Suite 123, Upper Montclair, New
Jersey 07043.
The undersigned Defendant has previously argued and submitted evidence that Plaintiff Lisa Liberi should be deemed a citizen
of California for purposes of diversity, on account of her long-time residence and criminal history and multiple convictions and status
as a probationer in Defendant Orly Taitz’ home state[1]. While Defendant still contends that her analysis of Lisa Liberi’s citizenship
for purposes of Strawbridge v. Curtiss “complete diversity” analysis is correct, it is upon reflection mere surplusage, at this point,
because the paired Plaintiffs Lisa Ostella and her Go Excel Global, when paired against the paired Defendants James Sundquist and
his Rock Salt Publishing, as identified and described expressly and explicitly ON THE FACE OF PLAINTIFFS’ OWN
COMPLAINT, completely and effectively destroy any contention of “complete diversity.” Even if Defendants Dr. Orly Taitz and her
“Defend Our Freedoms Foundations, Inc.” should be deemed to have defaulted so egregiously as to have confessed the well-pled
allegations (if any) of the Plaintiffs’ Complaint, such a default is not and cannot be taken as a waiver of objections to subject matter
jurisdiction. Without subject matter jurisdiction, which can only be established by the well-pled allegations of Plaintiffs’ Complaint,
this United States District Court is entirely without power to proceed, to entertain any part of Plaintiffs’ Complaint, or to afford to
Plaintiffs’ any relief whatsoever.

FAILURE TO IDENTIFY FEDERAL QUESTION CAUSES OF ACTION
(FRCP RULES 12(b)(6) & 12(c) JUDGMENT ON THE PLEADINGS)
For purposes of the present motion, Defendant Dr. Orly Taitz submits that the Plaintiffs have failed even to identify any actual
or conceivable Federal question Causes of Action in their May 4, 2009, Complaint, and are thus subject to Judgment on the Pleadings
pursuant to Rule 12(c). Much less have the Plaintiffs actually pled any plausible Federal Causes of Action with anything approaching
the specificity required by Rule 12(b)(6) as construed and applied under the Supreme Court’s latest evaluation Bell Atlantic v.
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Twombly, 550 U.S. 544; 127 S. Ct. 1955 at 1964-65; 167 L.Ed.2d 929 (2007). In fact, it is fair to say, paraphrasing the language of
Twombly, that the Plaintiffs Liberi et al. have not even made the conclusory allegations, or sufficient factual allegations to identify the
“labels and conclusions” necessary to constitute a “formulaic recitation of the elements of any causes of action” arising under Federal
statutes or jurisprudence, whatsoever. Count One, as noted above, is basically a “sham” based on a content-free title including two
Constitutional Amendments not mentioned again in any paragraph.
In relation to Counts Two through Six, which bear state court “labels” and little else suggesting any theory of recovery at all,
there are repeated but vague references to Defendants’ “posting and distributing Liberi’s social security number” and then, on page
73, ¶180, that “Defendants have acted unlawfully and in violation of” several federal statutes without more in the way of material
factual allegations. Such sloppy “pleading” was not permitted in Federal Court prior to Twombly, but it is clearly frivolous and
sanctionable now after the Supreme Court’s decision in that case.
This leaves COUNT ONE of Plaintiffs’ May 4, 2009, Complaint, at page 60, ¶¶ 144-157 for analysis. “COUNT ONE” is
entitled “VIOLATION OF THE FIRST AND FOURTEENTH AMENDMENT OF THE UNITED STATES CONSTITUION [sic] and
ILLEGAL DISCLOSURE OF AN INDIVIDUAL’S SOCIAL SECURITY NUMBER AND PERSONAL IDENTIFYING
INFORMATION”. While the First and Fourteenth Amendments of the United States Constitution would appear to frame federal
issues, no federal civil rights (nor any other) statutes are cited until paragraph 157. In fact, no statutes or case law authorities are
cited until paragraph 151, and the subsequent paragraphs focus exclusively on California Civil Code §§1798.81-1798.85” along with
vague reference to (other?) “California privacy laws” as providing possible grounds or factual frameworks for liability or recovery.
Accordingly the mere recitation of two constitutional amendments in the FEDERAL CONSTITUTIONAL TITLE of Count One should
be disregarded, and judgment entered on the pleadings in this case pursuant to Rule 12(c) of the Federal Rules of Civil Procedure, or
in the alternative under 12(b)(6) because no conceivable Federal law theories of recovery are stated or even identified in Count One.
As in paragraph 180 on page 73, discussed above, paragraph 157 on pages 63-64 contains random citations to several federal
laws, but the factual allegations of this paragraph are so vague, conclusory, and general, without reference to any specific outline of
any causes of action recognized or established by federal law, that there is no substantial basis for the exercise of federal question
jurisdiction. Count One may contain more “Federal Words” in its title than the other counts of Plaintiffs’ May 4, 2009 complaint, but
it does not contain more “Federal Substance” and should be dismissed along with Counts Two through Six as an attempt to utilize
federal diversity jurisdiction to sue and impose liability under what is, at the absolute most, examining the Complaint in the light most
favorable to the Plaintiffs, as nothing more nor less than an extremely poorly pled California state cause of action.
PRAYER FOR RELIEF

Judgment should accordingly be entered in favor of all the Defendants dismissing the May 4, 2009, Complaint for Want of Subject
Matter Jurisdiction pursuant to Rule 12(b)(1), Failure to State a Claim upon which Relief can be Granted pursuant to Rule 12(b)(6),
or in the alternative for Judgment on the Pleadings pursuant to Rule 12(c). The scattered references to federal statutes or
constitutional amendments do not add up to any cognizable theory of recovery under federal law, and since complete diversity of
citizenship between the Plaintiffs and Defendants is lacking, the May 4, 2009, Complaint in this case should be dismissed with
prejudice to the refiling of the same in any federal court anywhere, for any purposes.
Defendants Dr. Orly Taitz and Defendant our Freedoms Foundations, Inc., accordingly move and pray for complete dismissal of the
Complaint filed by Lisa Liberi, Philip J. Berg, the Law Offices of Philip J. Berg, Evelyn Adams a/k/a Momma E, Lisa M. Ostella,
and Go Excel Global, and ask that all Defendants be released from further liability to appear or answer in this case, and that all
Exhibit "48"
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proceedings in this case be adjourned sine die.
Respectfully submitted,
Wednesday, June 10, 2009
By:________________________________
Defendant, in propia persona and on behalf
of Defend Our Freedoms Foundations, Inc..
Dr. Orly Taitz, President,
Telephone (949) 683-5411

E-Mail: dr_taitz@yahoo.com
This report came from volunteer Sarah redacted

Case FWV028000 – Defendants
Seq Defendant Next Court Status Agency / Arrest Date Count 1 Violation Date
Date DR Number Charge
1 LIBERI , LISA RA 05/18/2001 PC 115(A) 05/18/2001
R 110013759
ALIAS: LIBERI, LISA R
ALIAS: COURVILLERICHARDSON, LISA
ALIAS: LIBERI, LISA A
ALIAS: RICHARDSON, LISA C
ALIAS: COURVILLERICH, LISA
ALIAS: LIBERI, LISA RENEE
ALIAS: LIBERI, LISA
ALIAS: RICHARDSON, LISA RENEE
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Status
Custody N/A
Filing Type Held to Answer Filing Date 05/09/2003
Ordered Bail $0.00 Posted Bail $0.00
D.A. James R. Secord Defense Dean Pitcl (Court Appointed)
Next Action: Deputy Report #: RA-RC 110013759
Warrant Type Status Issued Affidavit

NONE N/A N/A
Probation Type Granted Expiration
Formal 03/21/2008 03/21/2011
Sentence Convicted Date County Jail CTS
01/25/2008 26 Days 26 Days
State Prison Max Sentence
N/A N/A
Fine and Penalty Restitution Fine Restitution to Victim
0 N/A
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Charges
Arrest Charges
Count Charge Severity Description Violation Plea Status
Date
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1 PC 459 F BURGLARY 05/18/2001

Filed Charges
Date
1 PC 487(A) F GRAND THEFT: 05/18/2001 HTA

PROPERTY/ETC OVER $400
2 PC 470(D) F FORGERY 05/18/2001 HTA
3 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 HTA
4 PC 115(A) F OFFER/ETC FALSE/FORGED 05/18/2001 HTA
INSTRUMENT TO FILE
6 PC 470(D) F FORGERY 05/18/2001 HTA
7 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 HTA
8 PC 115(A) F OFFER/ETC FALSE/FORGED 05/18/2001 HTA
INSTRUMENT TO FILE
11 PC F GRAND THEFT: 05/18/2001 HTA
487(D)(1) AUTOMOBILE/ANIMAL/ETC
Infor Charges
Date
1 PC 487(A) F GRAND THEFT: 05/18/2001 GUILTY CONVICTED

2 PC F NONSUFFICIENT FUNDS: 05/18/2001 GUILTY CONVICTED
476A(A) CHECKS
3 PC 470(D) F FORGERY 05/18/2001 DISMISSED
4 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 DISMISSED
5 PC 115(A) F OFFER/ETC FALSE/FORGED 05/18/2001 GUILTY CONVICTED
INSTRUMENT TO FILE
7 PC 476 F MAKING, POSSESSING, 05/18/2001 DISMISSED
UTTERING FICTIOUS INSTRS
Exhibit "48"
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9 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 GUILTY CONVICTED
10 PC 115(A) F OFFER/ETC FALSE/FORGED 05/18/2001 DISMISSED
INSTRUMENT TO FILE
13 PC F GRAND THEFT: 05/18/2001 DISMISSED
14 PC 487(A) F GRAND THEFT: 05/18/2001 DISMISSED
16 PC 487(A) F GRAND THEFT: 05/18/2001 DISMISSED
20 PC 115(A) F OFFER/ETC FALSE/FORGED 05/18/2001 GUILTY CONVICTED
INSTRUMENT TO FILE
23 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 DISMISSED
List of initiatives and legal actions spearheaded by Orly Taitz

1. Keyes et al v Obama et al filed in Central District of CA.
2. Easerling et al v Obama et al submitted to SCOTUS
3. Lightfoot et al v Bowen was filed in the Supreme Court of CA and later in SCOTUS. It was referred by Chief Justice
Roberts for conference on January 23, however it did not go to oral argument.
4. Co-authored Keyes et al v Bowen.
5. James et al v Obama demand for Quo Warranto submitted to the US attorney for the DC Jeffrey a Taylor, who has
resigned. Demand for the new acting US attorney for the DC to file Quo Warranto against Obama
6. Quo Warranto demand was submitted to Atty gen. Eric Holder. A phone call was received stating that the Dossiers
were forwarded to the Criminal division of the DOJ.
7. Pro Hac Vice appearance was made on behalf of Jody Brockhausen and a complaint was filed with the US attorney
for the western District of TX for criminal Matters Richard Durbin and assistant US atty Chris Peel.
8. 8 dossiers describing suspected illegal activity perpetrated by Obama and his supporters was submitted to Holder
9. Request for criminal investigation of Obama’s Selective Service Certificate and Certification of Live Birth with
numerous signs of perjury was forwarded to the Beaumont police (Obama campaigned in Beaumont) on behalf of a
number of clients.
10. After the chief of Beaumont police told officer Dischler not to investigate, due to the fact that it is a political issue
and after the officer was threatened that the Chief of Police will investigate him, a criminal complaint was forwarded
to the US attorney for the Eastern District of TX Rebeccah Gregory. Ms. Gregory resigned, the complained will be
handled by the successor.
11. Copy of the complaint was forwarded to Governor Perry on May 5th . On May 6th the legal counselor for the
governor referred us to the DA of Jefferson County Tom Manness.
12. All of the dossiers and the complaint were forwarded to DA Manness and Chief investigator Rose as well as the San
Antonio DA Susan Reed.
13. Dossiers were either hand delivered by me or sent by certified mail to each and every member of the Senate Judicial
committee, as well as Senator Thune of Armed Services Committee and Senator Grassley of Finance Committee and
Senator Feinstein, who was the chair of Intelligence committee.
14. Dossiers were forwarded to Robert Mueller –director of FBI
15. Dossiers were forwarded to Mark Sullivan, Director of Secret service
Exhibit "48"
10 of 12
Pg. 440 5/1/2011 12:36 AM
#:4901
16. Dossiers were forwarded to Captain James Crawford, legal counselor for Admiral Mike Mallin, chairman of the
Joint Chiefs of staff (response is expected shortly)
17. Dossiers were forwarded to Steven Whitlock, director of the whistle blower office of the IRS
18. Dossiers were forwarded to the SSA, a phone call was received in April, advising that the analyst is working on the
matter and a response will be arriving in 2 weeks. It was not received yet.
19. Addressed the issue with Justice Scalia on March 9th.
20. Addressed the issue with Chief Justice Roberts on March 13th.
21. 15 trips were made to lobby elected and appointed officials in different states to review the issue of Obama’s
eligibility for presidency
22. Over a 100 radio shows and numerous TV shows, documentaries and newspaper and magazine articles were done to
bring awareness to the issue of lack of eligibility of Obama for the presidency of the US.
23. During the meeting with the KY assistant secretary of state a letter was written by the assistant secretary of state to
the Attorney General of the state, requesting to verify Obama’s eligibility
24. 4 TN state representatives joined the legal action to unseal Obama’s eligibility
25. 3 MO state representatives joined the legal action
26. 2 NH state representatives joined the legal action
27. Over a 100 members of the US military including high ranked officials such as major General joined the action
28. A request for Quo warranto investigation was made, on behalf of the WY Guardsman Matthew Michael Edwards
upon the Governor and attorney general of WY.
29. Meetings were conducted with 9 state representatives and state senators in the State of WA, as well as WA
assistant Atty Gen. and WA FBI
30. FBI field offices were visited in a number of states.
31. A meeting was conducted with the National director of the selective service William Chatfield.
32. Case presentation was done to a number of citizen’s common law grand juries, which indicted Barack Hussein
Obama with fraud and in some states treason.
33. Meetings with volunteers were conducted in San Antonio, TX during April 15 tea party.
34. Pleadings and dossiers were hand delivered to the office of the Governor of GA Sonny Purdue, Atty Gen of GA,
elections committee and US Atty Nahmias. First citizen’s grand jury was organized by the foreman Mr. Carl
Swenssen.
35. Meetings were conducted with the speaker of the House of OK Chric Benge, state senator and current candidate
for Gov of OK Randy Brangdon, st. rep Dr. Mike Ritz.
36. Met with current leading candidate for governor of Al Judge Moore and one of Al electors Robert Cusanelli became
one of the plaintiffs.
Exhibit "48"
Pg. 441
11 of 12 5/1/2011 12:36 AM
#:4902
[1] Lisa Liberi remains under the continuing jurisdiction of the Superior Court of the State of California for the County of San Bernardino in connection with her probation or
parole status in Case No: FSB-044914 (Judge John M. Pachecho), and whether this is determinative of her citizenship for diversity purposes or not, it seems more than casually
significant that Judge John M. Pacheco, in allowing Lisa Liberi to post bail bonds and be released from custody stated on the record, in open court on August 4, 2004:
“Having said all that, Ms. Liberi, if you don’t come back here [“here” meaning to California Superior Court whenever required by the terms of her probation] the mud is going to be
on my face that I allowed all this to happen.” Defendant Lisa Liberi responded “I will be here, your Honor. I have made every court appearance.” The issue concerning the
citizenship of parolees and probationers is not well-settled, but would seem to favor “last residence prior to sentencing” as the residence of the probationer/parolee, which in this
case would definitely be California.
Under the diversity jurisdiction statute, the federal courts have original jurisdiction to decide a plaintiff’s state-law lawsuit if the dispute “is between . . . citizens of different
States.” See 28 U.S.C. § 1332(a)(1). A party’s “citizenship” for purposes of federal jurisdiction is determined by looking to the person’s domicile. See Crowley v. Glaze, 710
F.2d 676, 678 (10th Cir. 1983). Domicile, in turn, is determined by finding the last place where a person resided with an intention of remaining there indefinitely. See Mississippi
Band of Choctaw Indians v. Holyfield, 490 U.S. 30, 48, 104 L. Ed. 2d 29, 109 S. Ct. 1597 (1989) (“For adults, domicile is established by physical presence in a place in connection
with a certain state of mind concerning one’s intent to remain there.”); Crowley, 710 F.2d at 678 (“To effect a change in domicile, two things are indispensable: First residence in a
new domicile, and second, the intention to remain there indefinitely.”).
It is obviously true that an adult can freely and intentionally change her residence for purposes of diversity jurisdiction as a matter of fundamental right, but prisoners, probationers,
and parolees ordinarily lose the right to determine their own citizenship. Lisa Liberi does not have complete freedom to sever her ties to California, and in fact she has promised
NOT to do so, as shown in the above quoted lines from the Reporter’s Transcript of the August 4, 2004, hearing in San Bernardino Superior Court Case No.: FSB-44914. page 122,
to which this Defendant
Some courts have recognized that the restrictions on the liberty of a prisoner affect the determination of the prisoner’s domicile because domicile is a voluntary status. See Sullivan
v. Freeman, 944 F.2d 334, 337 (7th Cir. 1991). As a result, courts have applied a presumption that when a prisoner has been moved out-of-state by prison officers, the prisoner’s
citize nship for diversity purposes is the state where he was domiciled before he was imprisoned. See id.; see also Ferrer v. Dailey, 1996 U.S. App. LEXIS 33322, No.
96-3155, 1996 WL 731618, at *1 (10th Cir. Dec. 20, 1996) (unpublished Order & Judgment) (“For purposes of diversity jurisdiction, when an inmate has been forcibly
incarcerated in another state, the state of citize nship ’should be the state of which he was a citizen before he was sent to prison unless he plans to live elsewhere when he gets
out, in which event it should be that state.‘”) (quoting Singletary v. Continental Ill. Nat’l Bank & Trust Co., 9 F.3d 1236, 1238 (7th Cir. 1993)). This presumption, however, is
rebuttable upon a showing of sufficient facts to indicate that a prisoner has both residence and present intent to remain indefinitely in a new state. See Sullivan, 944 F.2d at 337.
Category: Uncategorized
Comments
12 Responses to “”
1. 8by8
June 15th, 2009 @ 12:56 pm
We need to reach each and every law enforcement and governmental official and we need to make all
of them accountable. Any official, who violates the Constitution and his oath of office and allows fraud
and treason, will be held accountable by the citizens of this country.
Right On Orly. Let us all join the American Grand Jury and indict all the crooks. AGJ needs everyone.
We must build up a tidal wave of American Protest via indicting all the crooks.
Please join NOW.
http://www.AmericanGrandJury.org
2. 8by8
June 15th, 2009 @ 1:09 pm
This report came from volunteer Sarah redacted
Sarah You did a nice job. Thank you for all your work. You write up a legal statement very well. I hope
you continue to help Orly and our cause for a free America.
3. sillyhaha
June 15th, 2009 @ 2:04 pm
Exhibit "48"
Pg. 442
12 of 12 5/1/2011 12:36 AM
#:4903
EXHIBIT “49”
#:4904
Exhibit "49"
Pg. 443
#:4905
http://www.orlytaitzesq.com/blog1/?p=2522

Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691
Copyright 2009
« Previous Post
Ties to Everett, need help with research
You mentioned Everett, Wash. connection with Barack Obama’s mother’s family. Just
wondering if you knew that connection went back for over a century…
http://www.heraldnet.com/apps/pbcs.dll/article?AID=/20081026/NEWS01/710269867
Plus a bit more about the Wolfleys:

http://www.santacruzsentinel.com/world/ci_12517525
So with a POTUS with a Muslim father and German roots mother, why shouldn’t Israelis
be worried?
If you do post this info, please don’t mention my name or email.
Cheers
Response
I am really concerned about several coincidences
1. a man who threatened to shoot me and burn my body for the world to see was tracked
to a computer server in Everett WA. Another person that threatened me was traced to
Chauhelis WA and yet another one to Canada (from what I understand not far from the
border with WA state). A few days after the threat there was a clamp missing and a
disconnected fumes emissions hose in my car and my husbands car died, suddenly a fuse
was missing.
2. Obama does not talk about it, but his mother wasn’t in HI when he was a baby, she was
enrolled in the U of Seattle WA from August 1961-till June 1962, which means that as a
baby he lived in WA.
3. Lisa Liberi, assistant for Berg, who has a lengthy criminal record of grand theft,
forgery of documents and forgery of official seal doesn’t talk about it, but according
to records she was born in WA state. From what I recall Bellview WA. (her name at
birth was Lisa Richardson. From what I recall father -Jack Richardson, mother
Shirley Wadell)
Exhibit "49"
Pg. 444
#:4906
4. Obama, Liberi and Obama’s mother Stanley Ann Dunham- all have multiple
social security numbers according to databases.
5. Liberi was convicted of forgery of documents and according to experts, there are
multiple signs of forgery in Obama’s documents.
6. Stanley Ann Dunham also went by the name Shirley Ann Dunham.
We found a Dunham organization, owned by Shirley Ann Dunham; one location
was in Seattle another in Bellview WA. They dealt with insurances, lawyers,
mortgages- you can get ss numbers from all of these records.
7. From what I recall, there was a discrepancy between Intellius records and Secretary of
state records. According to the sec. of state a man owned that co. One of our volunteers
pulled court records in Bellview for the Dunham organization. This man, Mr. Dunham
(don’t remember first name) kept changing his middle initial in several court cases,
which was suspicious by itself.
8. There was a very strange newspaper article in WA (I believe Seattle), from what I
recall, when Obama supposedly was in Columbia. It stated that one, Roman Obama
studied at the university of Patrice Lumumba in Moscow, Russia, and had some financial
difficulties.
9. When grandma Dunham got sick, a reporter from WA (I believe Seattle) has writen an
interview with Charles Payne, saying the grandma got a broken hip. She was dead of
cancer a few days later. I was wondering, why did it come out in WA, and not HI or IL?
10. Based on all of the above, I have a nagging feeling, that there is somebody there in
WA, some relative of Obama, somebody who we might think is no longer with us.
This entry was posted on Monday, June 22nd, 2009 at 3:35 pm and is filed under Uncategorized. You can
follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from
your own site.
[emphasis added]
Exhibit "49"
Pg. 445
#:4907
EXHIBIT “50”
#:4908
Exhibit "50"
Pg. 446
Unfortunately I have to spend more time on Berg’s latest motion, I have to ... http://www.orlytaitzesq.com/?p=2579
http://www.orlytaitzesq.com/?p=2579
#:4909
VIDEOS
Home

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.
Unfortunately I have to spend more time on Berg’s

latest motion, I have to provide a response
Posted on | June 24, 2009 | 21 Comments

Orly Taitz Law Offices
(949) 683-5411
dr_taitz@yahoo.com
UNITED STATES DISTRCT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA
Exhibit "50"
Pg. 447
1 of 5 5/1/2011 12:58 AM
#:4910
Lisa Liberi, et al., §
Plaintiffs, §
§
v. § Civil Action No. 2:09-cv-01898-ER
§
Orly Taitz, et al. §
Defendants §
DEFENDANT’S OPPOSITION TO EMERGENCY MOTION FOR THE ISSUANCE OF PLAINTIFFS’ INJUNCTION OR

RESTRAINING ORDER
.
Defendants Orly Taitz and Defend Our Freedoms Foundation hereby file their opposition and objections to Plaintiffs’ motion
for injunctions for following reasons:
1. The First Amendment provides that “Congress shall make no law… abridging the freedom… of the press,” and it is “no
longer open to doubt that the liberty of the press, and of speech, is within the liberty safeguarded by the due process clause of the
Fourteenth Amendment from invasion by state action.” Near v. Minnesota ex rel. Olson, 283 U.S. 697, 707 (1931). See also
Grosjean v. American Press Co., 297 U.S. 233, 244 (1936). The United States Supreme Court has interpreted these guarantees to
afford special protection against orders that prohibit the publication or broadcast of particular information or commentary – orders
that impose a “previous” or “prior” restraint on speech. None of the Supreme Court’s decided cases on prior restraint involved
restrictive orders entered to protect a convicted forger’s history of convictions for forgery, but the opinions on prior restraint have a
common thread relevant to this case.
2. “Prior restraints on speech and publication are the most serious and the least tolerable infringement on First Amendment
rights.” Pittsburgh Press Co. v. Pittsburgh Comm’n on Human Relations, 413 U.S. 376, 390, 37 L.Ed. 2d 669, 93 S.Ct. 2553
(1973): a prior restraint should not “sweep” any “more broadly than necessary”. As such, the Constitution forbids prior restraint on
freedom of publication in the press, media, all together. See Carroll v. President and Comm’rs of Princess Anne, 393 U.S. 175,
183-184, 21 L.Ed.2d 325, 89 S.Ct. 347 (1968).
3. Any “order” issued in “the area of First Amendment rights” must be “precise” and narrowly “tailored” to achieve the
“pin-pointed objective” of the “needs of the case”. Tory v. Cochran, 544 U.S. 734, 738 125 S. Ct. 2108, 2111; 161
L.Ed.2d 1042, 1048 (2005); see also Board of Airport Comm’rs of Los Angeles v. Jews for Jesus, Inc., 482 U.S. 569,
575, 577, 96 L.Ed.2d 500, 107 S.Ct. 2568 (1987) (regulation prohibiting “all ‘First Amendment activities’” substantially
overbroad).
4. The Plaintiffs’ June 23, 2009, proposed order in this case is laughably unspecific and substantially overbroad, and would
basically impose a “Plaintiffs’ standard” censorship on Defendants’ commentary on the world-wide web, with the Court enrolled as
enforcing referee.
5. Nearly two months have passed since the filing of Plaintiffs’ complaint, and both the title and substance of Philip J. Berg’s
Exhibit "50"
2 of 5
Pg. 448 5/1/2011 12:58 AM
#:4911
latest “ex-parte” motion confirm, demonstrate, and reaffirm that there are no recently developing emergencies or exigent
circumstances which compel action at the present time, if any action were ever warranted at all (cf., e.g., Tory v. Cochran, 544 U.S.
734 (supra).
6. Plaintiffs’ requests for injunctions when aligned and evaluated against their somewhat lame and insubstantial recitations of
alleged past misconduct are non-sensical, because Plaintiffs Liberi, Berg, et al. make no allegations and offer no evidence of any
ongoing defamation or publication of private facts, and in particular, none that have arisen since the initiation of their present Suit to
Limit Access to Public Proceedings (e.g. “SLAPP”) filed May 4, 2009.
7. Historically, defamatory speech and disclosure of private facts of adults are immunized from legislative or executive
censorship, as well as judicial injunctive relief (known as “prior restraint”) in the United States. If false statements are made, which
result in injury, damages are the sole and exclusive remedy.
8. All of the substantive requests, including but not limited to the key phrase in the proposed order submitted to this Court on
June 23, 2009, “Defendants’ Orly Taitz … Defend our Freedoms Foundation… [….and] …all parties acting on their behalf are
enjoined from airing and/or publishing any defamatory or false statements”, and 100% of Defendants’ request for injunctive
relief concerns expressive activity, specifically Defendants’ activities as purveyors of truthful information through the electronic
media communications over the “world-wide web” or “internet.”
9. As the United States Supreme Court articulated 33 years ago this month (June 30, 1976) in Nebraska Press Association v.
Stuart, 427 U.S. 539; 96 S.Ct. 2791; 49 L.Ed.2d 683, 697-98 (1976):
A prior restraint, by contrast and by definition, has an immediate and irreversible sanction. If it can be said that a
threat of criminal or civil sanctions after publication “chills” speech, prior restraint “freezes” it at least for the
time. … The damage can be particularly great when the prior restraint falls upon the communication of news and
commentary on current events. Truthful reports of public judicial proceedings[1] have been afforded special
protection against subsequent punishment. See Cox Broadcasting Corp v. Cohn, 420 U.S. 469, 492-493 (1975);
see also, Craig v. Harney, 331 U.S. 367, 374 (1947). For the same reasons the protection against prior restraint
should have particular force as applied to reporting of criminal proceedings, whether the crime in question is a
single isolated act or a pattern of criminal conduct.
10. In that same case (Nebraska v. Stuart) the Supreme Court set out an analytical and procedural test for prior restraint on
expressive activities which has been widely followed throughout the United States. Under this test, a prior restraint on expression is
presumptively unconstitutional. With this concept in mind, the court adopts the following test: a [injunctive] order in civil judicial
proceedings will withstand constitutional scrutiny only where there are specific findings supported by evidence that (1) an imminent
and irreparable harm to the judicial process will deprive litigants of a just resolution of their dispute, and (2) the judicial action
represents the least restrictive means to prevent that harm. See, for example, the Texas Supreme Court’s Analysis in Davenport v.
Garcia, 834 S.W.2d 4, 10 (1992).
11. Defendants suggest that this Court specifically adopt the Texas four part rendition of the Nebraska v. Stuart test, in that
Exhibit "50"
Pg. 449
3 of 5 5/1/2011 12:58 AM
#:4912
several of the Defendants in this case are in fact from Texas and would be entitled to such protection if they had been sued “at home”:
Concerned that public prejudice could prevent impanelling of a jury, a trial judge issued an order restraining the
news media from publishing any information about a murder suspect in Nebraska Press Ass’n v. Stuart, 427 U.S.
at 542-43. The United States Supreme Court invalidated the order as an unconstitutional prior restraint, noting that:
(1) the underlying basis was too speculative; (2) less restrictive alternatives were not investigated; (3) no evidence
was presented that the prior restraint would have in fact achieved its purpose; and (4) the order was overbroad. Id.
at 562-69. These conclusions are quite fact specific, id. at 569, and thus only serve to reinforce a presumption that
prior restraints, including those directed at media publication, are unconstitutional.
Davenport v. Garcia, supra, at 10.
12. “A responsible press has always been regarded as the handmaiden of effective judicial administration, especially in the
criminal field. Its function in this regard is documented by an impressive record of service over several centuries. The press does not
simply publish information about trials but guards against the miscarriage of justice by subjecting the police, prosecutors, and judicial
processes to extensive public scrutiny and criticism.” Sheppard v. Maxwell, 384 U.S. 333 at 350 (1966).
13. Censorship of the press was, quite simply, one of the primary and central evils brought over the water from monarchical and
ecclesiastical domination in Europe against which the First Amendment was enacted and adopted by Congress and the original 13
states. As the Court recited in its historical summary in Nebraska Press Ass’n v. Stuart, supra: in Patterson v. Colorado ex rel.
Attorney General, 205 U.S. 454, 462 (1907): “[T]he main purpose of [the First Amendment] is ‘to prevent all such previous
restraints upon publications as had been practiced by other governments.’” Defendant Dr. Orly Taitz was born in a country, the
Soviet Union, in which restraints on freedom of expression were ubiquitous and constituted a constant feature of everyday life.
14. All content-based prior restraints on the dissemination of information by and through the free media or “press” by judicial
injunction constitute a form of “censorship” of free expression which are subject to strict scrutiny and a very important series of
safeguards outlined by the Supreme Court for this central, core of First Amendment Protections. Lisa Liberi and Philip Berg
completely and callously ignore, in their memorandum, the fact that the entire thrust of the injunctive relief they seek is focused on the
suppression of freedom of speech and communication about a topic of general public interest in the free press and open media. They
do not cite in their memorandum of law a single First Amendment case nor any other authority which would show them entitled to any
relief of any kind whatsoever.
15. All of the pleadings filed by the plaintiffs in this case were done with the sole reason to harass Defendant Dr. Orly Taitz and
other defendants and try to keep them silent about the fact that Berg’s assistant Liberi has a criminal record, specifically criminal
record of forgery of documents, which casts doubt on documents Berg has submitted to this honorable court as well the Supreme
court, as the documents were prepared or at least handled by a convicted document forger. This is a matter of public concern and
public interest as well as a legitimate topic of press reporting and is entitled to full First Amendment protection.
16. Lisa Liberi has (in California Courts) demonstrated a pattern of filing frivolous legal actions and motions, having filed
groundless actions against police officers, district attorney, the judge and the county solely to obtain leverage in her own criminal
Exhibit "50"
Pg. 450
4 of 5 5/1/2011 12:58 AM
#:4913
actions, or for other improper purposes.
17. Philip J. Berg has shown the same pattern of filing frivolous and fraudulent actions and was fined by US District Judge J.
Curtis Joyner more then $10,000 for bringing legal actions “utterly barren of any scintilla of legal principles”. In his opinion Judge
Joyner has stated “This court has grown weary of Mr. Berg’s continuous disregard and brazen disrespect toward this court and his
own clients. Mr. Berg’s actions …are an enormous waste of judicial time and resources that this court cannot, in good conscience,
allow to go unpunished”. In this action Berg has filed hundreds of pages of pleadings without a scintilla of proof or legal theory upon
which he can possibly proceed against the defendants.
18. This opposition to motion for emergency injunction and or restraining order is filed with full reservation of rights, as the
defendants are awaiting the ruling on their second amended motion to dismiss due to lack of jurisdiction.
19. Due to the fact that not one but several serious questions concerning the existing either of Federal Question or Diversity
jurisdiction over this case, Defendants reserve their right to plead further in opposition to Plaintiffs’ request for “emergency
injunctive relief” if this Court should decide it does indeed possess jurisdiction.
20. However, the question of the Court’s power to proceed does and should indeed precedes any other issues of litigation and
due to the fact that the defendants were harassed by hundreds and hundreds of pages of pleadings and premature demands for
discovery, even though the defendants are waiting for the ruling on jurisdiction, the defendants respectfully request a stay on all other
proceedings and filing of subsequent motions and pleadings until there is a ruling on jurisdiction.
Respectfully submited
Wednesday, June 24, 2009

By:________________________________
Defendant, in propia persona and on behalf
of Defend Our Freedoms Foundations, Inc..
Dr. Orly Taitz, President,
Telephone (949) 683-5411

E-Mail: dr_taitz@yahoo.com
[1] Such as Defendant Orly Taitz’ reports on the CLOSED (not ongoing) legal proceedings involving Lisa Liberi.
Category: Uncategorized
Comments
21 Responses to “Unfortunately I have to spend more time on Berg’s latest motion, I have to provide a
response”
1. Bob
June 24th, 2009 @ 3:42 am
Exhibit "50"
Pg. 451
5 of 5 5/1/2011 12:58 AM

LIBERI V TATIZ (C.D. CA) - 190.9 - Plaintiffs Exhibits 48-50 To Amended Complaint.190.9

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Case 8:11-cv-00485-AG -AJW Document 190-9 Filed 05/20/11 Page 1 of 25 Page ID

Dr. Orly Taitz Esquire

World's Leading Obama Eligibility Challenge Web Site

WHEN THE PEOPLE FEAR THEIR GOVERNMENT,

WHEN THE GOVERNMENT FEARS THE PEOPLE,

Posted on | June 15, 2009 | 12 Comments

Subscribe to The Legal Intelligencer

UNITED STATES DISTRCT COURT

Lisa Liberi, et al., §

SECOND AMENDED MOTION TO DISMISS COUNTS ONE-SIX FOR 12(b)(1)

LACK OF SUBJECT MATTER JURISDICTION &

JUDGMENT ON THE PLEADINGS

inadvertently failed to raise in her previous motions and answer:

Plaintiffs’ any relief whatsoever.

sanctionable now after the Supreme Court’s decision in that case.

ILLEGAL DISCLOSURE OF AN INDIVIDUAL’S SOCIAL SECURITY NUMBER AND PERSONAL IDENTIFYING

PRAYER FOR RELIEF

Telephone (949) 683-5411

This report came from volunteer Sarah redacted

Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Status

Warrant Type Status Issued Affidavit

Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Charges

1 PC 459 F BURGLARY 05/18/2001

1 PC 487(A) F GRAND THEFT: 05/18/2001 HTA

1 PC 487(A) F GRAND THEFT: 05/18/2001 GUILTY CONVICTED

List of initiatives and legal actions spearheaded by Orly Taitz

Please join NOW.

This report came from volunteer Sarah redacted

Dr. Orly Taitz Esquire

Plus a bit more about the Wolfleys:

If you do post this info, please don’t mention my name or email.

Dr. Orly Taitz Esquire

World's Leading Obama Eligibility Challenge Web Site

WHEN THE PEOPLE FEAR THEIR GOVERNMENT,

WHEN THE GOVERNMENT FEARS THE PEOPLE,

Unfortunately I have to spend more time on Berg’s

Dr. Orly Taitz, pro se

UNITED STATES DISTRCT COURT

DEFENDANT’S OPPOSITION TO EMERGENCY MOTION FOR THE ISSUANCE OF PLAINTIFFS’ INJUNCTION OR

for injunctions for following reasons:

common thread relevant to this case.

183-184, 21 L.Ed.2d 325, 89 S.Ct. 347 (1968).

Limit Access to Public Proceedings (e.g. “SLAPP”) filed May 4, 2009.

result in injury, damages are the sole and exclusive remedy.

media communications over the “world-wide web” or “internet.”

Garcia, 834 S.W.2d 4, 10 (1992).

Davenport v. Garcia, supra, at 10.

relief of any kind whatsoever.

which he can possibly proceed against the defendants.

Wednesday, June 24, 2009

Telephone (949) 683-5411

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