LIBERI V TAITZ (C.D. CA) - .221.1 - Declaration of Philip J. Berg, Esquire

Case 8:11-cv-00485-AG -AJW Document 221-1 Filed 06/07/11 Page 1 of 7 Page ID
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1 Philip J. Berg, Esquire

2
Pennsylvania I.D. 9867
LAW OFFICES OF PHILIP J. BERG
3 555 Andorra Glen Court, Suite 12
4 Lafayette Hill, PA 19444-2531
Telephone: (610) 825-3134
5 E-mail: philjberg@gmail.com Attorney in pro se and for Plaintiffs
6
UNITED STATES DISTRICT COURT
7 FOR THE CENTRAL DISTRICT OF CALIFORNIA,
8 SOUTHERN DIVISION
9
10 LISA LIBERI, et al, :
: CIVIL ACTION NUMBER:
11 :
Plaintiffs, : 8:11-cv-00485-AG (AJW)
12 :
:
13 vs. : DECLARATION OF PHILIP J.
:
14 : BERG, ESQUIRE
:
15 ORLY TAITZ, et al, : Date of Hearing: June 13, 2011
: Time of Hearing: 10:00 a.m.
16 : Location: Courtroom 10D
Defendants. :
17 :
:
18 :
19 Declaration of Philip J. Berg, Esquire
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21 I, Philip J. Berg, Esquire, am over the age of 18 and am a party to the within
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action. I have personal knowledge of the facts herein, and if called to do, I could
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and would competently testify. I am making this Declaration under the penalty of
25 perjury of the Laws of the United States pursuant to 28 U.S.C. §1746.

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1. As outlined in my Declaration of May 31, 2011, appearing as Docket
27
28 Entry number 214, on May 24, 2011, I received a call from Jason Q. Marasigan,
Declaration of Philip J. Berg, Esquire 06/07/2011 1

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1 Esquire, counsel for Defendant Orly Taitz, asking me if I would cooperate in the
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filing of a Supplemental Rule 26(f) Report. I told Mr. Marasigan that I would
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4 cooperate to send me his proposed Supplemental Rule 26(f) Report.
5 2. After reviewing Mr. Marasigan’s proposed Supplemental Rule 26(f)
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Report, I sent Mr. Marasigan an email refusing to cooperate with the filing of this
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8 document as it contained false statements and false allegations regarding the
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Plaintiffs and Plaintiff Lisa Ostella, which had never been raised before.
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11 3. I received two (2) additional emails from Mr. Marasigan, stating he
12 was disappointed I would not cooperate with him.

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4. I responded to Mr. Marasigan’s emails again and stated that this case
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15 is two (2) years old, there had been a lot of filings, it was not the Plaintiffs
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changing their story, but instead his client, and now they were attempting to
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introduce new stories. I stated that I would not participate in deception or
19 perpetrating a fraud upon the Court. In particular, I pointed out that the statements
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regarding Plaintiffs changing or reciting their case in a different manner was
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22 completely untrue and the statement that Defendant Orly Taitz confronted Lisa
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Ostella regarding redirecting Defendant Orly Taitz’s website/blog site traffic to
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another website where Plaintiff Ostella was selling her goods also was untrue. See
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26 Mr. Marasigan’s Proposed Rule 26(f) Report on page 2, paragraph 2, lines 18-24.
27
I also informed Mr. Marasigan that I had the emails showing it was in fact
28

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1 Defendant Orly Taitz attempting to sell goods on her own website through a third
2
party. I told Mr. Marasigan if he would remove those statements, I would take
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4 another look at his proposed Supplemental Rule 26(f) Report and make a decision
5 upon the completion of our communications.
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5. Mr. Marasigan sent me another email on May 31, 2011 refusing to
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8 redact the new claims with another “draft” Rule 26(f) Report. See EXHIBIT “1”.
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6. Due to my trial schedule, I was unable to review this new draft sent by
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11 Mr. Marasigan until today, June 7, 2011, at which time this draft was filed by Mr.
12 Marasigan. I immediately wrote to Mr. Marasigan with the problems with this
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26(f) Report, and now additional stories which Defense has never raised until now.
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15 See EXHIBIT “2”.
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7. I also reminded Mr. Marasigan that I had provided information for
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him to review to see his statements in his Draft Rule 26(f) Report were false. In
19 addition, I pointed out contrary to his client’s false statements and his, it was Orly
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Taitz and a third party, Lyn Shaw, who were selling T-shirts; it was Orly Taitz who
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22 set the pricing of the T-shirts and it was Orly Taitz who set-up the Petition and not
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Plaintiff Lisa Ostella as they were claiming. I explained to Mr. Marasigan that he
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could locate the information regarding the T-shirts in Appellees Supplemental
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26 Appendices, pages J260-262 and J277 filed November 7, 2010 in Defendant Orly
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Taitz’s Appeal of the Transfer Order, U.S. Court of Appeals for the Third Circuit,
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1 Case No. 10-3000, available for download through PACER. These same
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documents were also filed in this Case, see Dkt No. 144-9, pages 37, 38, 39 and 54
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4 filed September 14, 2010. I told Mr. Marasigan as for the pricing of the T-shirts,
5 he would find Orly Taitz’s email, setting the pricing, in the Declaration of Lisa
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Ostella, filed May 31, 2011, appearing as Docket Entry No. 213, Exhibit C located
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8 in Docket Entry No. 213-1. See these pages filed in the Third Circuit Court of
9
Appeals and downloaded from PACER attached hereto as EXHIBIT “3”.
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11 8. As for the Petition, I explained to Mr. Marasigan, contrary to his and
12 his client, Orly Taitz’s, false statement that Lisa Ostella had anything to do with
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the Petition, it was in fact his client, Defendant Orly Taitz. I explained to Mr.
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15 Marasigan that Defendant Orly Taitz posted the Petition on March 25, 2009 and he
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could access Defendant Taitz’s Petition by going to
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http://defendourfreedoms.us/2009/03/25/indictments.aspx, which is the blog site
19 Defendant Orly Taitz was using at that time. I located this post by typing in
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http://defendourfreedoms.us/2009/03/25/indictments.aspx in my web browser and
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22 pulling the post directly from the site used by Orly Taitz in March 2009. See
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EXHIBIT “4”. I also directed Mr. Marasigan to a document maintained on scribd
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at http://www.scribd.com/doc/15546236/Taitz-State-Bar-Complaint, which is a
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26 State Bar Complaint filed against Orly Taitz with the California State Bar. In this
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Complaint, on page 9, it talks about Orly Taitz’s petition, See EXHIBIT “5”,
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1 which is a redacted copy of the State Bar Complaint I obtained by typing in my

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web browser, http://www.scribd.com/doc/15546236/Taitz-State-Bar-Complaint.
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4 9. I also outlined that Defendant Orly Taitz has republished Plaintiff Lisa
5 Liberi’s Social Security number on her website at http://www.orlytaitzesq.com/wp-
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content/uploads/2010/01/Dc279.doc. I found this posting by doing a search in
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8 Google under “Orly Taitz Dossier #6”. I accessed this posting by typing in my
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Internet address bar http://www.orlytaitzesq.com/wp-
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11 content/uploads/2010/01/Dc279.doc and Defendant Orly Taitz’s Dossier #6 with
12 Plaintiff Lisa Liberi’s Social Security number downloaded from Defendant Taitz’s
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website.
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15 10. I notified Mr. Marasigan that Defendant Orly Taitz’s still has Plaintiff
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Liberi’s full Social Security number published on her supporter, David Crockett
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a/k/a David T. Baldursson’s, website located at
19 http://www.oilforimmigration.org/facts/?p=1478. I located Defendant Orly Taitz’s

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Dossier #6 with Plaintiff Lisa Liberi’s full Social Security number by typing in
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22 http://www.oilforimmigration.org/facts/?p=1478.
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11. Mr. Marasigan responded back that Plaintiff Liberi’s Social Security
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number is public record due to Plaintiff Liberi filing Bankruptcy. See EXHIBIT
25
26 “6”. Whether Plaintiff Liberi filed Bankruptcy or not, her Social Security number
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is not nor has it ever been public record. See California Civil Code Section 1798,
28

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1 et. Seq. which prevents the disclosure and publication of Social Security numbers,
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address information, dates of birth and other private data.
3
4 12. I also notified Mr. Marasigan of his client, Orly Taitz’s, continued
5 publication of false statements about Plaintiff Lisa Liberi and sent him the links to
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Orly Taitz postings on May 25, 2011, May 31, 2011 and June 1, 2011.
7
8 13. See Orly Taitz’s May 25, 2011 derogatory and false post regarding
9
Plaintiff Liberi which I located on Defendant Orly Taitz’s website by typing
10
11 http://www.orlytaitzesq.com/?p=22102 in my internet web browser. See EXHIBIT
12 “7”. See Defendant Orly Taitz’s May 31, 2011 derogatory and false post
13
regarding Plaintiff Liberi which I obtained from Defendant Orly Taitz’s website by
14
15 typing http://www.orlytaitzesq.com/?p=22219 into my Internet web browser
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attached as EXHIBIT “8”. See Defendant Orly Taitz’s June 1, 2011 derogatory
17
18
and false post regarding Plaintiff Liberi which I obtained directly from Orly Taitz’s
19 website by typing http://www.orlytaitzesq.com/?p=22297 into my Internet web

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browser attached as EXHIBIT “9”. I also located all three [3] of these posts by
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22 going directly to Defendant Orly Taitz’s Facebook page located at
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http://www.facebook.com/orlytaitz?sk=wall and
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http://www.facebook.com/orlytaitz.
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26 14. Other than receiving ridiculous statements that my client, Lisa
27
Liberi’s Social Security number is public, which I took as Defendants refusal to
28

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1 remove it from the Internet, I never received a response from Mr. Marasigan
2
regarding his client, Orly Taitz’s, continued false publications regarding Plaintiff
3
4 Liberi which constitutes harassment, cyber stalking, cyber-bullying, cyber-
5 harassment, violation of California Civil Code Section 1798, et. Seq., etc. of my
6
client, Plaintiff Lisa Liberi.
7
8 15. These continued improper tactics of Defendant Orly Taitz and now
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her attorney, Mr. Marasigan, are furthering damaging the Plaintiffs and extremely
10
11 prejudicial to my clients. If this Court allows Defendants to continue their false
12 stories; the filing of altered and forged documents as genuine; and Defendants
13
continued improper acts, it gives the Defendants an unfair advantage over my
14
15 clients and causes additional unnecessary costs to the Plaintiffs.
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I declare under the penalty of perjury of the Laws of the United States and
19 California that the foregoing is true and correct.

20
21
22 Executed this 7th day of June, 2011 in the Commonwealth of Pennsylvania,
23
County of Montgomery.
24
/s/ Philip J. Berg
25
Philip J. Berg, Esquire, Declarant
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EXHIBIT “1”

#:6243
From: Jayson Marasigan <jmarasigan@dacklaw.com>

Date: Tue, May 31, 2011 at 4:02 PM
Subject: RE: 26(f) Disclosures
To: Philip Berg <philjberg@gmail.com>
Cc: Martin Dack <mdack@dacklaw.com>
Mr. Berg:
Attached, please find the revised Rule 26(f) report bearing some minor changes. I
understand that you and the other Plaintiffs do not agree with my client's synopsis
of the facts. In my experience, rarely do parties ever agree on the facts, even at
trial. I will not amend my client's synopsis of her case based solely upon your and
the other Plaintiffs' objections thereto as not being grounded on what you
collectively perceive to be the "facts". In order to avoid any suggestion that you
are agreeing to the synopsis as presented by my client, I have added another
contention qualifier to the synopsis.
Let me know if you are willing to participate, otherwise I will be filing a separate
Rule 26(f) report tomorrow.
Very Truly Yours,
Jayson Q. Marasigan, Esq.

Dack | Marasigan, LLP
23041 Avenida de la Carlota,
Suite 300
Laguna Hills, California
92653
Telephone: (949) 206-9848
Facsimile: (949) 206-9851
*****The information contained
E-Mail:
in this communication may be
jmarasigan@dacklaw.com
confidential and is intended only
for the use of the recipient(s) named above, and may be legally privileged. If the
reader of this message is not the intended recipient, you are hereby notified that
any dissemination, distribution, or copying of this communication, or any of its
contents, is strictly prohibited. If you have received this communication in error,
please return it to the sender immediately and delete the original message and any
copy of it from your computer system. If you have any questions concerning this
message please send an e-mail to jmarasigan@dacklaw.com*****
Exhibit "1"
Pg. 9
#:6244
IRS Circular 230 Disclosure: In order to comply with requirements imposed by the
Internal Revenue Service, we inform you that any U.S. tax advice contained in this
Website (including any attachments) is not intended to be used, and cannot be
used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or
(ii) promoting, marketing, or recommending to another party any transaction or
matter addressed herein.
Exhibit "1"
Pg. 10
#:6245
1 JAYSON Q. MARASIGAN (Bar No. 227225)

DACK MARASIGAN, LLP
2 23041 Avenida de la Carlota, Suite 300
Laguna Hills, California 92653
3 Telephone: (949) 206-9848
Facsimile: (949) 206-9851
4
Attorneys for Defendant Orly Taitz
5
6
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA – SOUTHERN DIVISION
10
11 LISA LIBERI and PHILIP J. BEG,
ESQUIRE and THE LAW OFFICES OF
CASE NO. 8:11-cv-00485-AG (AJW)
12 PHILIP J. BERG and EVELYN ADAMS

a/k/a MOMMA E and LISA M. OSTELLA
RULE 26(f) REPORT FILED BY
ORLY TAITZ
13 and GO EXCEL GLOBAL,
14 Plaintiffs,
vs.
15 ORLY TAITZ, a/k/a DR. ORLY TAITZ,
16 a/k/a LAW OFFICES OF ORLY TAITZ;
a/k/a WWW.ORLYTAITZESQ.COM Complaint Filed: May 4, 2009
17 a/k/a WWW.REPUBX.COM a/k/a ORLY
TAITZ, INC. and DEFEND OUR
18 FREEDOMS FOUNDATIONS, INC. and
YOSEF TAITZ and THE SANKEY FIRM
19 and SANKEY INVESTIGATIONS, INC.
and NEIL SANKEY and JAMES
20 SUNQUIST and ROCK SALT
PUBLISHING and LINDA SUE
21 BELCHER a/k/a LINDA S. BELCHER
a/k/a LINDA STARR; a/k/a
22 NEWWOMENSPARTY a/k/a
STITCHENWITCH a/k/a EVA BRAUN
23 a/k/a WEB SERGEANT a/k/a KATY a/k/a
WWW.OBAMACITIZENSHIPDEBATE.
24 ORG and EDGAR HALE a/k/a JD
SMITH; and CAREN HALE; and PLAINS
25 RADIO NETWORK, a/k/a PLAINS
RADIO NETWORK, INC. a/k/a PLAINS
26 RADIO; and BAR H FARMS; and KPRN
AM 1610; and DOES 1 through 200
27 Inclusive,
28 Defendants.
1 Exhibit "1"
RULE 26(f) REPORT FILED BY ORLY TAITZ Pg. 11
#:6246
1 I.
2 INTRODUCTION
3
4 II.
5 JOINT REPORT
6 A. Statement of Claims, Affirmative Defenses and Key Legal Issues
7 1. Plaintiff
8
9 2. Defendants Orly Taitz and Defend Our Freedoms Foundation Inc.’s
10 Synopsis
11 Defendant Taitz denies the claims raised by Plaintiffs in their pleadings and in their
12 Rule 26(f) Report. Taitz contends that Plaintiffs have engaged in revisionist history in
13 attempting to tailor their allegations to their claims, which are not in any way supported by
14 the facts or evidence.
15 Taitz was the founder of the political foundation Defend Our Freedoms Foundation,
16 Inc. After founding that political foundation, Taitz was approached by Ostella who offered
17 to run a website on behalf of the foundation. To that end, Ostella, on behalf of Taitz and
18 Defend Our Freedoms Foundation, Inc. (“DOFF”), registered domain names bearing the
19 name “defendourfreedoms”. Plaintiff Ostella was Taitz’s volunteer webmaster for her
20 blog which was located on defendourfreedoms.us, the only domain name of the numerous
21 domain names registered by Ostella on behalf of Taitz that was used. That blog allowed
22 its readers to donate money, using PayPal, to Taitz’s political foundation, Defend Our
23 Freedoms Foundation, Inc.
24 Some time after the blog was running, Taitz noticed that Ostella was placing
25 commercial messages on the pages, Ostella started selling T-shirts using Defend Our
26 Freedoms website. Ostella had no authorization to enter any commercial agreements on
27 behalf of Defend Our Freedoms foundation without written authorization by Taitz and
28 without Taitz reviewing and signing such agreement. Taitz repetedly requested Ostella to
Exhibit "1"
2
#:6247
1 provide her with the agreement Ostella made with the t-shirt company in an attempt to
2 account for the proceeds from the sales that were being generated from the political
3 foundation’s website. Ostella never provided such agreement or accounting and Taitz told
4 her to remove the whole t-shirt selling operation from the web site of Defend Our
5 Freedoms Foundation.
6 In addition to the commercial messages, Ostella set up a petition on the web site of
7 the political foundation. Several supporters complained to Taitz, that they were asked to
8 donate money to the petition company. Yet again Taitz demanded from Ostella a contract,
9 accounting for the proceeds of those donations. Ostella never provided the contract or
10 accounting.
11 Lastly, Taitz received e-mails from donors, that there was a problem with donation
12 button. When Taitz checked, it showed that the e-mail address connected to the donation
13 button was changed. Taitz filed a report with the FBI, stating that she runs a foundation
14 with nation wide donations and the e-mail to the donation button was changed, she asked
15 to investigate. Ostella demanded, that Taitz take back her complaint to FBI, claiming, that
16 such complaint will reflect badly on her as a web master. Taitz refused to take back the
17 complaint. When Taitz confronted Ostella about the commercial content, Ostella, utilizing
18 her position of trust and confidence as Taitz’s webmaster, locked Taitz out of the web site
19 for her foundation and replaced Taitz’s pay-pal account with her own account. As a result
20 of the e-mail address change, Taitz and her political foundation was unable to receive
21 donations from readers of the blog.
22 Ostella, though she registered the domain name as Taitz and/or DOFF’s agent,
23 unlawfully maintained control of the defendourfreedoms.us web address and attempted to
24 deceive the general public by using pages confusingly similar to Taitz’s on her
25 defendourfreedoms.net web address to solicit donations which went to Ostella’s PayPal
26 account. Additionally Ostella colluded with PA attorney Philip J Berg and his legal
27 assistant, Lisa Richardson Liberi, who was convicted of 10 felony counts of forgery,
28 forgery of an official seal and theft, to use the web site for Taitz foundation to defame
3 Exhibit "1"
RULE 26(f) REPORT FILED BY ORLY TAITZ
Pg. 13
#:6248
1 Taitz and promote Berg. Berg profiteered from this switch, as a link to his web site was
2 placed on the web site of Defend Our Freedoms Foundation.
3 Taitz had to start a new website and sustained significant financial damage to her
4 and to her foundation due to the above actions of the Plaintiffs.
5 Taitz truthfully advised her supporters, that her old web site was taken over by her
6 volunteer web master, and any donations given on the old web site will not go to Defend
7 Our Freedoms Foundation, but will rather go to Ostella's pocket and will benefit Ostella
8 personally.
9 Additionally Taitz advised her supporters, that Lisa Liberi, legal assistant of Berg,
10 is a convicted felon. Taitz posted public records of Liberi's 2008 criminal conviction of 10
11 counts of forgery and theft in the Superior Court of San Bernardino County, CA, as well as
12 her record of 23 felony charges in one case and 4 felony charges in another case, filed
13 against her. This was done with a proper concern and in public interest, to show that a
14 convicted thief is working as an assistant for an attorney, who conducted nation wide fund
15 raising. It also showed that a convicted document forger was employed by Berg.
16 Ostella, Berg and Liberi retaliated against the defendants, who were the whistle
17 blowers and filed a SLAPP law suit against the defendants. Plaintiffs concocted pleadings,
18 where they tried to present Liberi as a different person, an innocent woman in
19 Pennsylvania, not a convicted forger and thief from CA. they claimed defamation. When
20 Taitz demanded to see Liberi's proof of citizenship for purposes of proof of diversity,
21 Plaintiffs concocted more egregious defamatory statements, claiming that Taitz tried to
22 hire a hit man to kill Liberi and kidnap children of Ostella. Plaintiffs demanded
23 emergency TRO hearings, claiming that they were threatened by Taitz. Three such
24 hearings were held and all of TRO's were denied. During the last hearing on 12.20.2010,
25 the Honorable Judge Robreno found that Ostella, Liberi and Berg were evasive and not
26 believable as witnesses and they provided no proof of any of their allegations. On cross-
27 examination during the TRO hearing, Ostella admitted that she indeed locked Taitz out of
28 the web site for her foundation and replaced Taitz’s PayPal account with her own. Liberi
4 Exhibit "1"
Pg. 14
#:6249
1 admitted on the stand that she is indeed a convicted felon from California. Ostella
2 admitted on the stand, that all of the allegations of Taitz trying to kidnap her children did
3 not come from her, but were concocted by Berg and Liberi. Plaintiffs attempted to appeal
4 judge Robreno's denial of their motion for TRO, but after 9 months they withdrew their
5 appeal.
6 B. Subject Matter Jurisdiction
7 Taitz is informed and believes that this court does not have jurisdiction to hear the
8 subject matter of this action because of incomplete diversity. Plaintiffs had originally pled
9 that Plaintiff Liberi was a resident of Pennsylvania and when they could not produce any
10 evidence to support that allegation, have since stated in their Rule 26(f) report that Liberi is
11 a resident of New Mexico. Plaintiffs’ averment is insufficient to establish diversity under
12 the circumstances. Diversity is determined at the time the action is filed. Thus, a change
13 of a party’s citizenship after commencement of the action does not affect the court's
14 jurisdiction. Diversity jurisdiction continues even if the opposing parties are now citizens
15 of the same state. (Bank One, Texas, N.A. v. Montle (1st Cir. 1992) 964 F.2d 48, 49; Lewis
16 v. Lewis (9th Cir. 1966) 358 F.2d 495, 502—P moved to California where D resided
17 during pendency of action; see Saadeh v. Farouki (DC Cir. 1997) 107 F.3d 52, 56–57-
18 change in citizenship after action commenced did not cure defect in complete diversity
19 existing when action filed)
20 Plaintiffs may attempt to vest subject matter jurisdiction based upon its purported
21 federal claims. Plaintiffs’ attempt would not have any merit because their federal claims
22 are joined with alternative state law claims. Where several claims are joined in the
23 complaint, and alternative state law theories exist for each of those claims, there is no
24 federal question jurisdiction. (Duncan v. Stuetzle (9th Cir. 1996) 76 F.3d 1480, 1486;
25 Dixon v. Coburg Dairy, Inc. (4th Cir. 2004) 369 F.3d 811, 816 (en banc))
26 Taitz raised the issue of lack of subject matter jurisdiction in the US district court in
27 the Eastern District of Pennsylvania and sought to have this issue addressed in the third
28 Circuit Court of Appeals. Originally 3rd circuit decided that they have jurisdiction to hear
Exhibit "1"
5
#:6250
1 the appeal. Nine months later the appeal panel was reshuffled. Two judges, who voted
2 originally, that there is jurisdiction to hear Taitz appeal in the3 rd circuit, were removed
3 from the panel. One judge, that originally voted, that the third circuit does not have
4 jurisdiction, was kept. Two new judges were added and the appeal was dismissed with the
5 notion that that the 3rd circuit does not have jurisdiction and all outstanding machines are
6 to be heard by the transferee court- this court.
7 C. Additional Parties and Amended Pleadings:
8 Discovery has not commenced. As of the filing of this report, to the extent that the
9 case is allowed to continue after procedural motions are adjudicated, Taitz anticipates
10 filing a counter-claim against Plaintiffs for breach of fiduciary duty, defamation of
11 character, slander, intentional infliction of severe emotional distress, interference with
12 prospective advantage, harassment, conversion, fraud, conspiracy to defraud, theft by false
13 pretenses, pattern of racketeering and corrupt organizations activity with predicate acts
14 involving mail fraud, wire fraud, and electronic access (bank and credit cards) fraud, as
15 well as misuse of confidential identity and access codes, all in violation of 18 U.S.C.
16 §1961-1964(c).
17 D. Discovery and Experts pursuant to Rule 26(f)
18 Defendant anticipates serving Interrogatories, Requests for Admission, and Request
19 for Production of Documents shortly after the initial exchange pursuant to Fed. R. Civ. P.
20 26(a). Anticipated discovery also includes depositions of the parties and government
21 agencies. The parties anticipate exchanging expert witness information and expert
22 depositions.
23 The parties believe that no changes need to be made to the timing, form, or
24 requirements of discovery.
25 E. Anticipated Procedural Motions:
26 Taitz intends to file a rule 12(b)(1) motion for lack of subject matter jurisdiction.
27 F. Settlement Procedure and Discussion
28 Plaintiffs and Defendant Taitz have engaged in preliminary settlement discussions.
Exhibit "1"
6
#:6251
1 Those discussions reveal that the parties are at opposite ends of the spectrum.
2 Notwithstanding, Taitz selects Settlement Procedure No. 1 whereby a Magistrate Judge
3 presides over settlement conferences pursuant to L.R. 16-15.
4 G. Proposed Dates
5 Because of the pending Anti-SLAPP and Rule 12(b) motion, Taitz refrains from
6 offering any dates at this time.
7 H. Conflicts
8 The parties are unaware of any conflicts in this case.
9 I. Complex Case:
10 The parties do not believe that this case is complex or that any part of the Manual
11 for Complex Litigation should be utilized.
12
13 Respectfully Submitted,
14 DATED: June 7, 2011 DACK MARASIGAN, LLP
MARTIN E. DACK
15 JAYSON Q. MARASIGAN
16
17 By:
JAYSON Q. MARASIGAN
18 Attorneys for Defendant Orly Taitz
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7 Exhibit "1"
Pg. 17
#:6252
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EXHIBIT “2”
28

#:6253
From: Philip Berg <philjberg@gmail.com>

To: Jayson Marasigan <jmarasigan@dacklaw.com>
Sent: Tue, Jun 7, 2011 12:56 pm
Subject: Liberi, et al vs. Taitz, et al [Your 26(f) Report]
Mr. Marasigan:
I apologize for the delay in responding to you.
I was just able to review your new 26(f) report that you just filed. As
you are aware, I filed the 26(f) report on behalf of the Plaintiffs on the
evening of May 20, 2011, when your client, Defendant Orly Taitz, was
representing herself and DOFF and refused to cooperate.
You have now added additional theories, which have never been
raised in the last two [2] years. Further, your new synopsis does not
address the publication of my client, Lisa Liberi's full Social Security
Number [SSN], home address, date of birth, place of birth, mother's
maiden name, father's name, and other private data, and other things,
which your client, Defendant
Orly Taitz, admitted to during the June 25, 2009 hearing.
Ms. Taitz also recently republished her Dossier #6 on her website with
Mrs. Liberi's Social Security number now omitting the last four, date
of birth, her spouse’s partial Social Security number and date of birth
and other private data, which is after your client, Orly Taitz, was
Ordered by Judge Robreno not to publish any Social Security
number. See the June 25, 2009 transcript. As you are aware, the
publication of address information, Social Security numbers, dates of
birth, and other private data violated California Civil Code Section
1798, et seq. and gives cause for a Temporary Injunction and/or TRO.
Mrs. Taitz's Dossier #6 with my client's full SSN, date of birth and
other private data is also still available online, on Ms. Taitz's
supporter, David Crockett a/k/a David-T-Baldursson's website located
at http://www.oilforimmigration.org/facts/?p=1478. This needs to be
removed from the Internet immediately. Ms. Taitz has been on notice
regarding this for over a year.
Exhibit "2"
Pg. 19
#:6254
Nor does your synopsis address the harassment of Mrs. Liberi by

your client: the repeated false reports filed with law enforcement and
governmental agencies.
Additionally, you are now accusing my clients and me of additional

wrongs, which are completely false allegations and have not been
raised in the past two [2] years - building new stories based on the
Plaintiffs filings.
Mrs. Liberi has never been convicted of forging documents, which

your client is well aware of; the statements and allegations regarding
Mrs. Ostella are false, as I
stated to you in my earlier email and as filed with this Court on May
31, 2011. Your client is not being honest with you and you need to
read the Court filings.
Mrs. Ostella was not involved with the T-shirts, except for an
occasional email. After reviewing your draft 26(f) report, Mrs. Ostella
did searches on the internet and found Lyn Shaw’s postings
regarding the T-shirt sales on behalf of Orly Taitz, as a
fundraiser. Lyn Shaw, Orly Taitz’s supporter, was handling the T-
shirts on behalf of your client, Ms. Taitz. In fact, if you look at Liberi,
et al v. Taitz, et al, Case No. 10-3000 in the Third Circuit Court of
Appeals, your client’s appeal, Appellees Supplemental Appendixes
filed November 7, 2010, pages J260-J262 and J277. The T-shirts were
approved by your client and again, Lyn Shaw was handling it for Ms.
Taitz. This coupled with the email sent to Plaintiff Ostella, which is an
exhibit to Mrs. Ostella’s declaration showing that your client set the
pricing for said T-shirts, filed May 31, 2011 in this case, you will see
your statements regarding the T-shirts and Mrs. Ostella are
completely false. Lyn Shaw also has been convicted of a theft crime.
As for the Petition and your false claims that Mrs. Ostella handled that
and was diverting funds to herself from this Petition; again
false. Your client, Orly Taitz, published the Petition herself on
03/25/2009. This post is still available at
http://defendourfreedoms.us/2009/03/25/indictments.aspx.
In addition, a State Bar Complaint was filed against

your client, Ms. Taitz, which can be located at
Exhibit "2"
Pg. 20
#:6255
http://www.scribd.com/doc/15546236/Taitz-State-Bar-Complaint. In
this State Bar Complaint the Petition is also mentioned. See page 9 of
this State Bar Complaint.
The allegations against me are also false.
You also need to be aware, your client, Orly Taitz, within the last
week, has been going after Mrs. Liberi again, using her website,
Facebook account, Twitter and other social networks to distribute her
falsehoods and incite against Mrs. Liberi. Your client must be aware,
as she is an attorney, that every time she changes her story, Plaintiffs
and their witnesses are capturing it off of her website, Facebook and
other social network sites. See the following direct links to your
client’s website where these posts are maintained:
http://www.orlytaitzesq.com/?p=22102 (May 25, 2011)

http://www.orlytaitzesq.com/?p=22219 (May 31, 2011)
http://www.orlytaitzesq.com/?p=22297 (June 1, 2011)
Your client, Ms. Taitz, also published these on her Facebook pages at
the following links:
http://www.facebook.com/orlytaitz?sk=wall
http://www.facebook.com/orlytaitz
For these reasons, I will not participate with these tactics.
Respectfully,
Philip J. Berg, Esquire

Attorney for Plaintiffs
Exhibit "2"
Pg. 21
#:6256
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#:6257
Exhibit "3"
Pg. 23
#:6258
Exhibit "3"
Pg. 2
#:6259
Exhibit "3"
Pg. 25
#:6260
Exhibit "3"
Pg. 26
#:6261
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#:6262
Exhibit "4"
Pg. 28
Defend Our Freedoms From the Absense of Privacy: Indictments- About ... http://defendourfreedoms.net/2009/03/25/indictments.aspx
#:6263
DEFEND OUR FREEDOMS

defend our freedoms from the absense of privacy
INDICTMENTS- ABOUT 2200 SIGNATURES SO FAR
Petition is offline for Clean Up BACK TO MA
DEFEND OUR
Redress of grievances-Petition for indictment of Timothy Geitner,
COMMUNITY
Barack Obama, Supreme Court clerk for stays Danny
Defend Our Free
Bickel, Judges that refuse to uphold Constitution and hear the Privacy
cases of Obama's ineligibility on the merits and members of Defend Our Free
Shop DOF
Congress and Senate, that refuse to hold Judicial hearings and
sign subpoenas for all of Obama's vital records.
RECOMMEN
We will be running petitions and giving you a voice. We will tally the Naked Communi
numbers. Germany's Maste

Do you think Timothy Geitner should be indicted? Why yes and why not? Offensive
Robert R. Young
Should Obama be indicted for massive fraud of American people and
Nazi Nexus: Ame
treason? Hitler's Holocaus
The Difference B
Should the judges be indicted for not upholding constitution and not *God Doesn't Th
hearing the cases of Obama's lack of eligibility?
The Info Mesa: S
Alchemy on the S
Should clerk Danny Bickel be indicted for interfering with the justice system?
Should attorney general Eric Holder be indicted for not investigating all QUICK SEARC
of Obama's illegal acts? Search only in tit
Should the Congressmen and Senators be indicted for not holding judicial
committee hearings on BO's illegitimacy for presidency?
Advanced Searc
Posted by Dr. Orly Taitz at 3/25/2009 8:58 PM
Categories: Petition
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Exhibit "4"
Pg. 29
1 of 2 6/7/2011 11:57 PM
Defend Our Freedoms From the Absense of Privacy: Indictments- About ... http://defendourfreedoms.net/2009/03/25/indictments.aspx
#:6264
trackbacks BLOG TAGS
Trackback specific URL for this post
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CATEGORY A
comments
Able Danger (1)
Display comments as (Linear | Threaded)
ACORN (25)
activism (65)
Africa (3)
AIPAC (11)
JBH wrote: 3/25/2009 9:13 PM
Al Gore (2)
Yes to all questions
Alan Keyes (10)
JBH Andy Martin (2)
Reply to this Auchi (6)
Barakat Osama (
Biden (1)
Judi wrote: 3/25/2009 9:15 PM
Bioterrorism (8)
Absolutely YES on all counts, but does this mean that Chief Justice Roberts denied all of your pleadings and supporting
documents???? birth certificate (2
Reply to this Black Panthers (
blood diamonds
Body Brokers (5)
12th Generation AMERICAN wrote: 3/25/2009 9:18 PM
BURLEW PLUM
YES to all!!
California (6)
Reply to this
Cases (95)
Census (1)
SharkGirl wrote: 3/25/2009 9:18 PM Chavez (2)
How can anyone answer no to any of these? With the exception of Timothy Geitner, I vote yes on all of the others. Chicago Crimes
Child Porn (9)
The only reason I'm not voting on Geitner is because I haven't kept up with the story as much, and I don't know who he
China (30)
is. So, to be fair, I'm going to research his name and I'll withhold my vote until I know what he allegedly did.
Reply to this Christopher Stru
Cintra (3)
Liberty Bell wrote: 3/26/2009 1:18 PM Citizen Grand Ju
I have followed Geithner. It is a YES to the TurboTax cheat, the Gov't power to Nationalize all US Companies, and Clinton (6)
the architect of sending the wealth of the US to the Fed Reserve Banks, Geithner. COLIFAM (1)
Reply to this Columbia Univer
communism (12)
Computers/Intern
Congress (1)
Ginger wrote: 3/25/2009 9:21 PM Constitution (5)
Yes...Yes...Yes...Yes...Yes...Yes...Yes...Yes...Yes...Yes...Yes...Yes...Yes... Cort Wrotnowski
Reply to this
CPUSA (18)
Craig M. Robinso
Judi wrote: 3/25/2009 9:26 PM Cuba (1)
What else happened today? Yes they should all go down, but what did Chief Justice Roberts do or say? Cyber Crimes (14
Reply to this David Axelrod (2
December 2008
Hugh Bodey wrote: 3/25/2009 9:31 PM DHS (5)
YES - A GREAT BIG YES on every one of these issues. What all of them are doing and attempting to do to their fellow DNC (11)
countrymen is definitely CRIMINAL and they should be compelled to face the courts and the people on these matters. I'd DOE (2)
love to be on every one of the juries! ! ! But, by saying that, I guess I disqualify myself and that's alright, too, as I can DOF (2)
keep on shouting it to the world - until they stop me - about how I feel about anyone who would do such a thing to God, Domestic Terrori
Family, and Country - in that order of importance. DrOrly (73)
Duncan Hunter (
God Bless you for asking,
Earth Day (1)
Bro. Hugh Elections (24)
Reply to this Electors (7)
Eminent Domain
Enron (1)
james wrote: 3/25/2009 9:37 PM
EPA (4)
Taking the risk of being under surveilance or arrested as some that have spoken out against Obama's lack of eligibility, I
Eric Holder (27)
think all of of your questions are pertinent.
From the evidence I have seen and the commentary from those that know far more than I have the resources to uncover FARC (3)
information these are all justifiable questions that I could only answer a resounding YES. Thanks Orly for your tireless FEC (1)
Exhibit "4"
Pg. 30
2 of 2 6/7/2011 11:57 PM
#:6265
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28 EXHIBIT “5”

#:6266
Exhibit "5"
Pg. 32
#:6267
Exhibit "5"
Pg. 33
#:6268
Exhibit "5"
Pg. 34
#:6269
Exhibit "5"
Pg. 35
#:6270
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#:6271
From: Jayson Marasigan <jmarasigan@dacklaw.com>

Date: Tue, Jun 7, 2011 at 3:13 PM
Subject: RE: Liberi, et al vs. Taitz, et al [Your 26(f) Report]
To: Philip Berg <philjberg@gmail.com>
Cc: Martin Dack <mdack@dacklaw.com>
Mr. Berg:
I disagree with your conclusion that the theories were never raised in the last 2
years. I have reviewed the docket, and underlying supporting documents, and they
clearly support Dr. Taitz's position as set forth in the report filed this morning. As
far as Ms. Liberi a/k/a Richardson's social security numbers, they are public record
based upon her Chapter 13 and Chapter 7 bankruptcy filings. I have certified
copies of her bankruptcy petitions in which she listed 2 different SSNs. She has
not been damaged in any way.
I will not respond to the remainder of your e-mail because it serves no purpose and
is a waste of resources. Provided the Plaintiffs' claims survive the pleadings stage,
which I believe is doubtful at this point, the Plaintiffs will be given an opportunity
to prove their claims and defend against Orly Taitz and Defend Our Freedoms
Foundation, Inc.'s claims against them.
Very Truly Yours,
Jayson Q. Marasigan, Esq.

Dack | Marasigan, LLP
23041 Avenida de la Carlota,
Suite 300
Laguna Hills, California *****The information contained
92653 in this communication may be
Telephone: (949) 206-9848 confidential and is intended only
Facsimile: (949) 206-9851 for the use of the recipient(s)
E-Mail: named above, and may be legally
jmarasigan@dacklaw.com privileged. If the reader of this
message is not the intended recipient, you are hereby notified that any
dissemination, distribution, or copying of this communication, or any of its
contents, is strictly prohibited. If you have received this communication in error,
please return it to the sender immediately and delete the original message and any
Exhibit "6"
Pg. 37
#:6272
copy of it from your computer system. If you have any questions concerning this
message please send an e-mail to jmarasigan@dacklaw.com*****
IRS Circular 230 Disclosure: In order to comply with requirements imposed by the
Internal Revenue Service, we inform you that any U.S. tax advice contained in this
Website (including any attachments) is not intended to be used, and cannot be
used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or
(ii) promoting, marketing, or recommending to another party any transaction or
matter addressed herein.
Exhibit "6"
Pg. 38
#:6273
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#:6274
Exhibit "7"
Pg. 40
Berg’s disciplinary hearing was held today. There are a number of very st... http://www.orlytaitzesq.com/?p=22102
#:6275
VIDEOS
Home
from Drudge report
from my supporter Jeanie
Dr. Orly Taitz Esquire

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

Your donations to the cause are much appreciated.
WHEN THE PEOPLE FEAR THEIR GOVERNMENT,
THERE IS TYRANNY.
WHEN THE GOVERNMENT FEARS THE PEOPLE,
THERE IS LIBERTY.
- Thomas Jefferson
The articles posted represent only the opinion of the writers, do not necessarily represent the opinion of Dr. Taitz, ESQ, and Dr. Taitz, ESQ has no means of
checking the veracity of all the claims and allegations in the articles.
Berg’s disciplinary hearing was held today. There

are a number of very strange circumstances
Posted on | May 25, 2011 | 1 Comment
I wanted to attend this disciplinary hearing, because of all the emotional distress and slander caused by Berg.
The page of the disciplinary board shows that the hearing was continued on 05.06.2011 to 05.25.2011,
however I did not see this notation until today. Can someone check, when was this notation made. Did
someone help Berg by not posting the notification of his hearing timely. Also, on 05.23.2011 there was
supposed to be a motion hearing to dismiss Berg’s insane case against me. Without any explanation this
hearing was postponed. Is someone helping Berg? On whose side is Berg? His original case against Obama
Exhibit "7"
Pg. 41
1 of 2 6/8/2011 12:14 AM
Berg’s disciplinary hearing was held today. There are a number of very st... http://www.orlytaitzesq.com/?p=22102
#:6276
was filed to benefit Hillary Clinton against Obama. After Clinton became the secretary of State Berg did not
come up with any new law suits against Obama, but rather spent two and a half years together with his
paralegal, a convicted document forger and convicted thief Lisa Renee Richardson Liberi, attacking me with
thousands of pages of garbage and insane accusations (like Orly Taitz tried to hire a hit man to kill Lisa Liberi,
able assistant of Philip Berg). In big part due to harassment by Berg and his CA co-counsel Kreep I could not
move in Obama cases as fast I could, if not for all of their harassment. Every attorney I talked to, is asking the
same question: “why are the courts allowing Berg to continue harassing me?’ You tell me
Exhibit "7"
Pg. 42
2 of 2 6/8/2011 12:14 AM
#:6277
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#:6278
Exhibit "8"
Pg. 44
An order from the judge is due any time now. An opposition from this atto... http://www.orlytaitzesq.com/?p=22219
#:6279
VIDEOS
Home
from Drudge report


THERE IS TYRANNY.
THERE IS LIBERTY.
- Thomas Jefferson
An order from the judge is due any time now. An

opposition from this attorney for the federal
government, who harassed me, is due today. I am
still waiting for an answer from the Chief judge
McKee from the Third Circuit and from the
Philadelphia DA and the US attorney re court
Exhibit "8"
Pg. 45
1 of 7 6/8/2011 12:27 AM
#:6280
reporter Dona Anders, who removed from the
certified transcript 14 pages in order to benefit
Berg and his assistant, convicted document forger
and thief Lisa Liberi and to infringe on my right to
fair trial. We have to hold employees of the federal
government and federal courts accountable.
Posted on | June 1, 2011 | Comments Off
Exhibit "8"
Pg. 46
2 of 7 6/8/2011 12:27 AM
#:6281
Exhibit "8"
Pg. 47
3 of 7 6/8/2011 12:27 AM
#:6282
Exhibit "8"
Pg. 48
4 of 7 6/8/2011 12:27 AM
#:6283
Exhibit "8"
Pg. 49
5 of 7 6/8/2011 12:27 AM
#:6284
Exhibit "8"
Pg. 50
6 of 7 6/8/2011 12:27 AM
#:6285
Exhibit "8"
Pg. 51
7 of 7 6/8/2011 12:27 AM
#:6286
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#:6287
Exhibit "9"
Pg. 53
Thank god for judge Wilkinson in the Eastern District of Louisiana | Dr. Or... http://www.orlytaitzesq.com/?p=22297
#:6288
VIDEOS
Home
from Drudge report


THERE IS TYRANNY.
THERE IS LIBERTY.
- Thomas Jefferson
Thank god for judge Wilkinson in the Eastern

District of Louisiana
Posted on | June 1, 2011 | 10 Comments
Exhibit "9"
Pg. 54
1 of 4 6/8/2011 12:34 AM
#:6289
Exhibit "9"
Pg. 55
2 of 4 6/8/2011 12:34 AM
#:6290
Exhibit "9"
Pg. 56
3 of 4 6/8/2011 12:34 AM
#:6291
One of the reasons Obama is able to get away with obvious crimes, is because employees of the federal
government, among them attorneys and clerks for judges and court reporters and others were aiding and
abetting him by harassing, intimidating and defaming me and other attorneys and patriots who stood up and
demanded prosecution of ObamaFraudgate.
A group, called “Fogbow” was formed. This group included employees of the federal government, who were
on attack. They used assumed names. While hiding behind those assumed names, they attacked. One of them
is an attorney, working for IRS in New Orleans, Mitzi Lynn Craig Torri. Torri is licensed in AZ and her
licensed was suspended in VA. She is allowed to work for the Federal government in Louisiana.
When I appeared in oral argument in New Orleans, Torri showed up. She bragged there, that she works for the
department of treasury. She was flashing her badge. Later she wrote a report, where she misrepresented the
events. She also appeared on radio programs together with another attorney,Scott J Tepper, who goes under
the pseudonym Sternguard Friegen or Sterny. Tepper and his group of associates filed multiple outrageous
statements on the pages of Fogbow, as well as a radio program, that they started, called “Reality radio”. They
e-mailed inappropriate comments to my blog as well. Most of their written comments in writing and verbal
comments on the radio were nothing, but outrageous slander and defamation of character, including very
inappropriate sexual remarks. They wrote to each and every agency, including CA bar, in order to affect my
professional licenses and take away my livelihood, do anything in order to protect ObamaFraudGate from
prosecution by killing the messenger. Torri went further, than others. I have her posted remarks, where she
bragged, that she will have “people in black” show up at my home and it will not be a pleasant social visit. As
an attorney for IRS, she has access to tax information of any citizen.Her threats are clear. We have to make
sure, that people, who work for the federal government do not abuse their authority, or we will be another
Soviet Union. I will be filing a formal complaint in regards to this incident, the moment I have the sign in
sheet. I also have the recordings of the radio programs with her.
Similarly, a court reporter in the Eastern District of PA, Dona Anders, removed 14 pages of cross examination
of a witness from the certified transcript and neatly arranged the transcript of the examination of the next
witness right after the previous examination, trying to create an impression, as if there was no cross
examination. This deletion of 14 pages benefited a convicted document forger and thief Lisa Rene
Richardson Liberi, who works as a “legal assistant” for Philip J. Berg. This is tampering with evidence and
obstruction of justice. I filed criminal complaints with Philadelphia DA, US attorney, chief judge of the district
and the chief judge of the Circuit, as well as Inspector General. Inspector General forwarded my complaint to
the chief judge of the Third Circuit Court of Appeals. So far nothing was done by either the chief judge
McKee or Philadelphia DA or US attorney. This woman continues working as a court reporter and one can
only imagine how many people were victimized and will be victimized by such actions.
I’ve seen manipulation of dockets by the clerks of the courts, including the Supreme Court. My case
Lightfoot v Bowen was deleted from the electronic docket of the Supreme Court of the United states. It was
done one day after the inauguration. I confronted the chief judge of the Supreme Court John Roberts during a
lecture. He promised to investigate, but so far two and a half years passed and nothing was done. If we do not
address all this lawlessness and corruption in the government and the courts, if we do not address our rigged
and manipulated elections, we will end up in the worst tyranny one can imagine.
Let’s hope that holding members of Fogbow accountable, holding employees of the federal government
accountable will help us start on the path of cleaning corruption and will be that thread of evidence, that will
help us prosecute ObamaFraudGate
Category: Events, HOT ITEMS!, Latest News, Legal Actions, Obama Fraud Gate, Other Criminal or
Suspicious Activities
Comments Exhibit "9"

Pg. 57
4 of 4 6/8/2011 12:34 AM

LIBERI V TAITZ (C.D. CA) - .221.1 - Declaration of Philip J. Berg, Esquire

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Case 8:11-cv-00485-AG -AJW Document 221-1 Filed 06/07/11 Page 1 of 7 Page ID

1 Philip J. Berg, Esquire

25 perjury of the Laws of the United States pursuant to 28 U.S.C. §1746.

Declaration of Philip J. Berg, Esquire 06/07/2011 1

12 was disappointed I would not cooperate with him.

Declaration of Philip J. Berg, Esquire 06/07/2011 2

Declaration of Philip J. Berg, Esquire 06/07/2011 3

Declaration of Philip J. Berg, Esquire 06/07/2011 4

1 which is a redacted copy of the State Bar Complaint I obtained by typing in my

19 http://www.oilforimmigration.org/facts/?p=1478. I located Defendant Orly Taitz’s

Declaration of Philip J. Berg, Esquire 06/07/2011 5

19 website by typing http://www.orlytaitzesq.com/?p=22297 into my Internet web

Declaration of Philip J. Berg, Esquire 06/07/2011 6

19 California that the foregoing is true and correct.

Declaration of Philip J. Berg, Esquire 06/07/2011 7

Declaration of Philip J. Berg, Esquire 06/07/2011 8

From: Jayson Marasigan <jmarasigan@dacklaw.com>

Very Truly Yours,

Jayson Q. Marasigan, Esq.

1 JAYSON Q. MARASIGAN (Bar No. 227225)

12 PHILIP J. BERG and EVELYN ADAMS

Declaration of Philip J. Berg, Esquire 06/07/2011 18

From: Philip Berg <philjberg@gmail.com>

I apologize for the delay in responding to you.

Nor does your synopsis address the harassment of Mrs. Liberi by

Additionally, you are now accusing my clients and me of additional

Mrs. Liberi has never been convicted of forging documents, which

In addition, a State Bar Complaint was filed against

The allegations against me are also false.

http://www.orlytaitzesq.com/?p=22102 (May 25, 2011)

For these reasons, I will not participate with these tactics.

Philip J. Berg, Esquire

Declaration of Philip J. Berg, Esquire 06/07/2011 22

Declaration of Philip J. Berg, Esquire 06/07/2011 27

DEFEND OUR FREEDOMS

INDICTMENTS- ABOUT 2200 SIGNATURES SO FAR

Petition is offline for Clean Up BACK TO MA

numbers. Germany's Maste

Declaration of Philip J. Berg, Esquire 06/07/2011 31

Declaration of Philip J. Berg, Esquire 06/07/2011 36

From: Jayson Marasigan <jmarasigan@dacklaw.com>

Very Truly Yours,

Jayson Q. Marasigan, Esq.

Declaration of Philip J. Berg, Esquire 06/07/2011 39

Dr. Orly Taitz Esquire

World's Leading Obama Eligibility Challenge Web Site

WHEN THE PEOPLE FEAR THEIR GOVERNMENT,

WHEN THE GOVERNMENT FEARS THE PEOPLE,

Berg’s disciplinary hearing was held today. There

Declaration of Philip J. Berg, Esquire 06/07/2011 43

Dr. Orly Taitz Esquire

World's Leading Obama Eligibility Challenge Web Site

WHEN THE PEOPLE FEAR THEIR GOVERNMENT,

WHEN THE GOVERNMENT FEARS THE PEOPLE,

An order from the judge is due any time now. An

Declaration of Philip J. Berg, Esquire 06/07/2011 52

Dr. Orly Taitz Esquire

World's Leading Obama Eligibility Challenge Web Site

WHEN THE PEOPLE FEAR THEIR GOVERNMENT,

WHEN THE GOVERNMENT FEARS THE PEOPLE,

Thank god for judge Wilkinson in the Eastern

Comments Exhibit "9"

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