LIBERI V TAITZ - 299.0 - NOTICE OF MOTION AND MOTION To Dismiss Case Filed by Defendant Orly Taitz, Inc - Orly Taitz, Inc. Motion To Dismiss.299.0

Case 8:11-cv-00485-AG -AJW Document 299 Filed 07/19/11 Page 1 of 18 Page ID #:7080
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DR. ORLY TAITZ ESQ CA license 223 433 29839 SANTA MARGARITA PKWY, STE 100 RANCHO SANTA MARGARITA, CA 92688 PH 949-683-5411 FAX 949-766-7603 Attorney for Orly Tatz, inc Co-counsel for Law Offices of Orly Taitz.
US DISTRCT COURT CENTRAL DISTRICT OF CALIFORNIA
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LIBERI ET AL, PLAINTIFF, VS. TAITZ AT AL, DEFENDANT
) CASE NO.: 11-CV-00485 ) ) DATE 05.22.2011 ) TIME 10:00 ) COURTROOM 10 D ) Motion to dismiss first amended ) complaint under 12b(6) and 12(b)(1) ) ) )
Liberi v Taitz motion to dismiss under 12b- 1
Notice to all parties and their counsel: on August 22, 2011 defendant Orly Taitz,
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inc, will move this court to dismiss the above mentioned action in its entirety under 12(b)1 and 12(b)6 for lack of subject matter jurisdiction and for failure to state a claim for relief. This motion will be based on the memorandum of points and authorities below and oral argument. Additionally, above mentioned defendants join in motions to dismiss filed by Defend Our Freedoms Foundation and Orly Taitz and incorporate by reference all the arguments and exhibits brought forward in those motions to dismiss. MEMORANDUM OF POINTS AND AUTHORITIES. TABLE OF CONTENTS Complaint against Orly Taitz, inc needs to be dismissed under 12( b)6 due to failure to state a claim for relief .............................................................................p2 Complaint needs to be dismissed due to lack of jurisdiction under 12 (b)1.p12 TABLE OF AUTHORITIES Ashcroft v. Iqbal, 129 S. Ct. 1937, 1940 (2009) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 554, 555 (2007)...............................................................................p2 Pollard v. Geo Group, Inc., 607 F.3d 583, 585 n.3 (9th Cir. 2010);............................................................................................................ p3 Westlands Water Dist. v. Firebaugh Canal, 10 F.3d 667, 670 (9th Cir. 1993)p3 Sprewell v. Golden State Warriors, 266 F.3d 979, 988 (9th Cir. 2001)............p3 Schmidt v. Herrmann, 614 F.2d 1221, 1223 (9th Cir.1980)..............................p4 Vacek v United states postal service 447 F3d 1248, 1250 (9th Cir 2006) (quoting Kokkonen v Guardian life Ins. Co.of Am 511 US. 375, 377 (1994) (citation omitted)). .....................................................................................................p12
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A court should dismiss a complaint when its allegations fail to state a claim upon which relief can be granted. Fed. R. Civ. P. 12(b)(6). A complaint need only include a short and plain statement of the claim showing that the pleader is entitled to relief. Fed. R. Civ. P. 8(a)(2). [D]etailed factual allegations are not required. Ashcroft v. Iqbal, 129 S. Ct. 1937, 1940 (2009) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 554, 555 (2007) (stating that a complaint attacked by a Rule 12(b)(6) motion to dismiss does not need detailed factual allegations)). The Court must accept as true all factual allegations in the complaint and must draw all reasonable inferences from those allegations, construing the complaint in the light most favorable to the plaintiff. Pollard v. Geo
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Group, Inc., 607 F.3d 583, 585 n.3 (9th Cir. 2010); Westlands Water Dist. v. Firebaugh Canal, 10 F.3d 667, 670 (9th Cir. 1993). But the complaint must allege sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face. Iqbal, 129 S. Ct. at 1949 (quoting Twombly, 550 U.S. at 570). A claim has facial plausibility when the pleaded factual content allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. Iqbal, 129 S. Ct at 1940 (citing Twombly, 550 U.S. at 556). A court should not accept threadbare recitals of a cause of actions elements, supported by mere conclusory statements, id., or allegations that are merely conclusory, unwarranted deductions of fact, or
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unreasonable inferences, Sprewell v. Golden State Warriors, 266 F.3d 979, 988 (9th Cir. 2001). The pleading standard that Rule 8announces does not require detailed factual allegations, but demands more than an unadorned, thedefendant-unlawfully-harmed-me accusation. Iqbal, 129 S.Ct. at 1949 (citing Twombly, 127 S.Ct. at 1955). A pleading that offers labels and conclusions or a formulaic recitation of the elements of a cause of action will not do. Id. Nor does a complaint suffice if it tenders naked assertion[s] devoid of further factual enhancement. Id. Where a complaint fails to meet this standard, it may be dismissed with prejudice. See Schmidt v. Herrmann, 614 F.2d 1221, 1223 (9th Cir.1980). As stated previously, dismissal without leave to amend is appropriate
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only when the Court is satisfied that the deficiencies of the complaint could not possibly be cured by amendment. Jackson, 353 F.3d at 758. The conflict in question revolved around publication by Orly Taitz on the web site of her foundation of the criminal record of plaintiff Lisa Liberi and of the fact that former volunteer web master Lisa Ostella locked Taitz out of the old web site for Defend our Freedoms Foundation (hereinafter DOFF) and replaced Taitz pay pal account with her own pay pal account on the web site, and that any donations made on the old web site would benefit Ostella personally and not DOFF. Taitz also advised the donors, that Ostella is using the old web site to promote attorney Philip Berg. Plaintiffs claim, that such disclosures represented invasion of their
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privacy(apparently, they considered diversion of donation from DOFF to be their private matter) and they claimed defamation of character in their complaint filed on May 4, 2009. After two years of litigation on 12.20.2010 at the motion hearing before prior judge on the case, judge Robreno, as Taitz confronted Liberi with her mug shot, and did it in front of Judge Robreno and witnesses in the audience, Liberi admitted that she is indeed a convicted felon from California and Ostella admitted, that she indeed locked Taitz, the president of DOFF, out of the old web site for the foundation and replaced Taitz pay pal account with her own.
(12.23.2011 memorandum by judge Robreno). The case was transferred to California, Taitz filed a motion to dismiss under AntiSLAPP and Plaintiffs filed a
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motion for leave of court to file a first amended complaint. In their amended complaint they added multiple plaintiffs, among them Orly Taitz, inc. Orly Taitz is both a doctor of dental surgery and a doctor of law and she is licensed in both professions. Orly Taitz, inc is her dental office. Without doing any minimal inquiry to ascertain whether there is any connection between the dental office of Dr. Orly Taitz and Defend our Freedoms Foundation, the plaintiffs have added Orly Taitz, inc as an additional defendant. In paragraph 11 of the FAC without a scintilla of evidence to support this, Plaintiffs are stating that Orly Taitz, inc controlled the defendants Defend Our Freedoms foundation, and Law offices of Orly Taitz. In fact, Orly Taitz, inc never controlled any other
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defendants and Plaintiffs did not plead any facts to show, that Orly Taitz, inc controls other defendants and that Orly Taitz, inc has any connection whatsoever with the dispute in question. This is indeed a naked assertion without any factual enhancement. The complaint was filed over two years ago, the Plaintiffs had ample time to do minimum investigation to ascertain, if there is any connection between the entities. They were given an opportunity to amend and submitted a 170 page first amended complaint, which provided nothing but bare speculation, that the dental office of Dr. Orly Taitz, Orly Taitz, inc controls other defendants.
FIRST CAUSE OF ACTION IS WILFUL AND INTENTIONAL

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VIOLATION UPON LIBERI'S AND OSTELLA'S SOLITUDE, SECLUSION AND PRIVATE AFFAIRS, VIOLATIONS OF FIRST AND FOURTEENTH AMENDMENTS TO THE CONSTITUTION NEEDS TO BE DISMISSED DUE TO FAILURE TO STATE CLAIM Plaintiffs did not plead any facts to show, how dental office of Dr. Orly Taitz invade privacy of the Plaintiffs and how private dental office violated First and Fourteenth amendment rights of the Plaintiffs. They do not even specify what rights did the dental office violate: did it violate their right to free speech or freedom of religion or free press? This cause of action shows how frivolous the whole complaint is. None of the defendants are part of the Federal or state
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government. It shows, that the attorneys, who filed the complaint did not do any minimal investigation before filing and possibly did not even read the complaint before filing. SECOND CAUSE OF ACTION PUBLIC DISCLOSURE OF PRIVATE FACTS NEEDS TO BE DISMISSED UNDER 12B6. None of the patients were aver patients of Dr. Taitz, there is nothing in the complaint alleging that the Plaintiffs were ever patients of Dr. Taitz. Again, the Plaintiffs did not plead even a whisper of any fact to show that the Dental office of Dr. Taitz ever had any private facts relating to Plaintiffs and that it disclosed any
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such facts. Plaintiffs did not plead any remnant of a fact to show, how dental office of Dr. Taitz is connected to the dispute and how dental office of Dr. Taitz controlled other defendants. THIRD CAUSE OF ACTION- FALSE LIGHT, INVASION OF PRIVACY NEEDS TO BE DISMISSED UNDER 12B6 DUE TO FAILURE TO STATE A CLAIM. In third cause of action Plaintiffs are spewing insane allegations without any specificity and again do not provide any nexus to the dental office of Dr. Taitz, do not explain how any of the allegations are connected to the dental office of Dr. Taitz
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FOURTH CAUSE OF ACTION APPROPRIATION OF NAME, PHOTO AND LIKE-INVASION OF PRIVACY NEEDS TO BE DISMISSED FOR FAILURE TO STATE A CLAIM. Plaintiffs did not plead any facts, that would show, that dental office of Dr. Taitz published pictures of Plaintiffs to bring business to her dental practice. They are talking about the fact, that Orly Taitz, as president of DOFF published a mug shot of Liberi to warn the supporters and donors, that the old web site for the foundation was taken over by Ostella, former web master, and is being used to promote attorney Philip Berg, who is employing a felon on probation Lisa Liberi, convicted of 10 counts of grand theft, forgery of an official seal and attempt to tender forged
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documents. Plaintiffs failed to plead, how does that publication benefit dental office of Dr. Taitz. We are not talking here about glamour shots of Christie Brinkley, we are talking about a mug shot of Lisa Liberi, if anything, such association can destroy business, not add business. FIFTH CAUSE OF ACTION-WILLFUL VIOLATION OF CAL. PRIVACY ACT NEEDS TO BE DISMISSED UNDER FAILURE TO STATE A CLAIM. Yet again, plaintiffs did not plead any connection between publication made on the web site of Defend our Freedoms foundation and the dental office of Dr. Taitz. Plaintiffs did not plead any connection between the dental office and the
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publication in question, moreover they did not show, how the dental practice was willful in violating privacy of the Plaintiffs SIXTH CAUSE OF ACTION VIOLATION OF CAL IPA CAL CIV PRO CODE 1798.85 NEEDS TO BE DISMISSED DUE TO FAILURE STATE A CLAIM. In the sixth cause of action plaintiffs talk about publication of Liberi's social security number. There is no pleading of posting of Ostella's social security number. Plaintiffs are referring to the publication on the web site for the Defend Our Freedoms foundation. Plaintiffs did not plead any facts, that would show that the dental office of Dr. Taitz is in any way connected to such publication.
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SEVENTH CAUSE OF ACTION: CYBER STALKING, CYBER HARASSMENT AND CYBER BULLYING NEEDS TO BE DISMISSED DUE TO FAILURE TO STATE A CLAIM. Seventh cause of action in general makes no sense, as it talks about the Fact that Taitz as the president of Defend Our Freedoms Foundation posted on the new web site for her foundation information about Liberi's criminal record and the fact that Ostella took over the old web site and diverted the donations. That in itself does not represent stalking, but moreover the pleading does not show, how the dental office of dr. Taitz was stalking the plaintiffs and how publication on the pages of
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DOFF is in any way connected to the dental office of Dr. Taitz., as such the seventh cause of action needs to be dismissed due to failure to state a claim. EIGHTH CAUSE OF ACTION-DEFAMATION PER SE- NEEDS TO BE DISMISSED FOR FAILURE TO STATE A CLAIM. again, the plaintiffs are throwing around a lot of unsupported allegations against all the defendants and again did not provide any facts in the pleading to show, how did the dental office of Dr. Taitz defame them and how did the dental office of Dr. Taitz controlled other defendants in defaming them. NINTH CAUSE OF ACTION INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS NEEDS TO BE DISMISSED FOR FAILURE TO
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STATE A CLAIM. Plaintiffs bring forward bizarre allegations and claims of infliction of emotional distress, however all the allegations revolve around publication by Taitz as the president of DOFF of Liberi's criminal record and Ostella's dealings in taking over the old web site. Plaintiffs did not plead, how does any of these alleged instances of infliction of emotional distress are connected to the dental office of Dr. Taitz. TENTH CAUSE OF ACTION-MALICIOUS PROSECUTION NEEDS TO BE DISMISSED FOR FAILURE TO STATE A CLAIM. Plaintiffs consider filing of complaints with authorities by Taitz, as president of DOFF to be malicious prosecution. Plaintiffs failed to plead any legal action
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initiated by the defendants, that would qualify as a basis for the malicious prosecution. Moreover, they did not plead any malicious prosecution of behalf of the dental office of Dr. Taitz. ELEVENTH ACTION -ABUSE OF PROCESS NEEDS TO BE DISMISSED DUE TO FAILURE TO STATE A CLAIM. Plaintiffs claim, that the complaints to the authorities made by Taitz, as the president of DoFF represent abuse of process. Plaintiffs failed to plead, how complaints made in furtherance of Taitz right for redress of grievances represents abuse of process. Yet again Plaintiffs failed to plead, how such alleged abuse
of process is in any way connected to the dental office of Dr. Taitz, as such the
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eleventh cause of action needs to be dismissed due to failure to state a claim. Allegations against Orly Taitz, inc are so void of any factual enhancement, that the complaint against Orly Taitz, inc needs to be dismissed without leave to amend. Additionally, allegations in the complaint need to be plausible. Memorandum order by the prior judge on the case, judge Robreno, would weigh heavily against plausibility of the allegations. In his 12.23.2011 order judge Robreno has already ruled, that the claims brought by the Plaintiffs are bare allegations, without any credible evidence to support them.(Liberi v Taitz, 12.23.2011 memorandum order by judge Robreno). It is true, that Judge Robreno ruled on the original complaint and this court has to rule on the FAC, however, most of allegations brought against
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Orly Taitz, inc. are the same or similar: Liberi claims to be defamed, however she admitted to being a convicted felon. Previously the defendants submitted certified copies of her convictions. Additionally, in her FAC Liberi mentions her probation hearings before judge Sabeth this year. If she is an innocent woman, who was defamed, why is she on probation? Why is there a hearing to ascertain, whether her probation needs to be revoked? Similarly, one can see a pattern of allegation, that are so implausible, that they go
into the area of insane and bizarre concoctions of a criminal mind of Liberi who has 27 criminal charges and 10 convicions of grand theft, forgery of an official seal and attempt to tender forged documents in California alone. (summary of case
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FVW -028000, pled 316
page 122 of the FAC). Additionally, defendants
provided previously the court with the testimony of detective Liebricht, who testified of Liberis prior 19 criminal charges and her attempt to frame her own sister. Is it plausible, that Taitz, who is a licensed dentist and attorney and who was never been in trouble with the law would have anything to do with some gutted rabbits in New Jersey, is it plausible that she would look for some hit man to kill Liberi and kidnap children of Ostella? Why would she do it? Plaintiffs are bringing forward these insane allegations, which were already found to be unfounded by judge Robreno, another federal judge, who handled this case
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until now, and which are utterly implausible and appear to be the product of wild imagination of the criminal mind of Liberi. Additionally, one can see a pattern of Plaintiffs simply throwing in the same pot multiple defendants without pleading any facts to substantiate the allegations. One can see, that the Plaintiffs threw in the same pot, included as additional defendant the husband of Orly Taitz. Again, without a scintilla of evidence they made up an insane allegation, that the husband of attorney Taitz is spying on the plaintiffs and that he colluded with the world renown computer company "Oracle" to install the software, that is spying on people and got personal information of the plaintiff Liberi. Husband of attorney Orly Taitz is a CEO of the Daylight Chemical information systems, a company dealing with a chemical software used by a small group of scientists. Again, without doing any minimum inquiry, and in violation of Rule 11, Plaintiffs accused him, his company and Oracle of spying on people and getting personal information of the Plaintiffs. Just reading the name of the company would be sufficient to see, that this company is engaged in chemical software and has nothing to do with the personal information of the Plaintiffs. this pattern shows, that the allegations are not only allegations that are merely conclusory, unwarranted deductions of fact, or unreasonable inferences, Sprewell v. Golden State Warriors, 266 F.3d 979, 988 (9th Cir. 2001) but are also
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highly improbable, bordering on clinical insanity and need to be dismissed under 12(b)6.
THIS WHOLE CAUSE OF ACTION FAILS AND HAS TO BE DISMISSED UNDER FRCP 12(B)1 Prior to addressing the specific counts of the complaint the Defendants assert that the complaint was filed in federal court frivolously in violation of section 12b(1) of Federal rules of Civil Procedure. This legal action was filed based on diversity of citizenship. Federal Rule of Civil Procedure 12(b)1 provides for dismissal of a complaint for lack of subject matter jurisdiction. Because federal courts are courts of limited jurisdiction, it is presumed that a cause lies outside this limited jurisdiction, and the burden of establishing the contrary rests upon the party asserting jurisdiction. Vacek v United states postal service 447 F3d 1248, 1250 (9th Cir 2006) (quoting Kokkonen v Guardian life Ins. Co.of Am 511 US. 375, 377 (1994) (citation omitted)). Plaintiffs in their Tenth and eleventh causes of action are describing the court hearing in regards to violation of probation of Lisa Liberi, which was held in Rancho Cucamonga Division of the San Bernardino California Superior Court case FVW-028000 in March of this year. This in itself shows, that Plaintiff Liberi is indeed subject to jurisdiction of the Superior Court of the State of California. As it
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was provided in the Request for Judicial notice filed concurrently with the Motion to dismiss filed by Orly Taitz, case FVW-028000 is indeed Liberi's criminal conviction on 03.21.2009, whereby Liberi's eight year prison term was reduced to time served and three years probation under the supervision of the san Bernardino county, California, probations department and subject to jurisdiction of the Superior court of the state of Califoria. This destroys the diversity in the case. It shows, that from March of 2008 until March of 2011, and specifically on May 4, 2009, when Plaintiffs filed their complaint under diversity, there was no diversity and the complaint needs to be dismissed due to lack of jurisdiction. For diversity of citizenship Plaintiffs were supposed to provide competent
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evidence of state citizenship of the parties at the time this legal action was filed, in order to show that the parties were diverse. Plaintiffs refused to provide drivers license or an ID card to show the state citizenship of the lead plaintiff Lisa Liberi. Defendants provided Liberis criminal record from the San Bernardino, California court, showing Liberi being on probation under supervision of the San Bernardino, California, probations department, not allowed to reside in Pennsylvania. Taitz demanded to see Liberis proof of state citizenship. Originally Plaintiffs claimed that they showed Judge Robreno Liberis drivers license during 08.07.2009 motion hearing. Taitz was not able to attend this hearing and requested the transcript. On July 30, 2010 Plaintiffs filed an emergency motion, where they demanded to keep
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the transcript sealed and accused the defendant and attorney for the defendants Taitz of trying to hire a hit man to kill Liberi and claimed that for this reason the transcript needs to be sealed. Judge Robreno ordered the transcript released to Taitz. The transcript showed that the Plaintiffs did not provide Liberis drivers license and actually during the hearing judge Robreno ordered Liberi and her attorney Berg TO FILE THE TRANSCRIPT WITH COURT. The docket shows that Liberi and Berg NEVER FILED LIBERIS DRIVERS LICENSE. and have been in contempt of court for two years now. As Plaintiffs never filed any competent evidence of Liberis state citizenship, and violated for two years an order by the court to file Liberi's identification records, this legal action is
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supposed to be dismissed under 12b1 as the plaintiffs did not provide documentary evidence of diversity and the court does not have jurisdiction over the case. This case was frivolously filed in the federal court and specifically in the federal court in Pennsylvania simply to intimidate the defendants and try to silence them. As the defendants are limited in the number of pages allowed for the 12 b motion, defendant files concurrently a joinder with further arguments brought by the "Defend Our Freedoms Foundation" and Orly Taitz and incorporates by reference all their arguments in furtherance of 12b (6) and 12(b)(1) motions to dismiss. Wherefore Defendants respectfully pray for following relief:
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Dismissal of the Complaint in its entirety against the defendant Orly Taitz, inc under 12(b)6 for failure to state a claim for relief and under 12b)(1)- lack of subject matter juridiction.
Dated this 07.19.2011 _______________________ Dr. Orly Taitz, ESQ Attorney for
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Defend Our Freedoms Foundation and Orly Taitz
07.19.2011 /s/ Dr. Orly Taitz, ESQ /s/ Orly Taitz CERTIFICATE OF SERVICE
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I declare under penalty of perjury that a true and correct copy of the above pleadings was served on 07.19.2011 via ECF on all parties and via e-mail on Neil Sankey and Sankey firm at nsankey@sankeyfirm.com /s/ Dr. Orly Taitz, ESq

LIBERI V TAITZ - 299.0 - NOTICE OF MOTION AND MOTION To Dismiss Case Filed by Defendant Orly Taitz, Inc - Orly Taitz, Inc. Motion To Dismiss.299.0

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Case 8:11-cv-00485-AG -AJW Document 299 Filed 07/19/11 Page 1 of 18 Page ID #:7080

US DISTRCT COURT CENTRAL DISTRICT OF CALIFORNIA

LIBERI ET AL, PLAINTIFF, VS. TAITZ AT AL, DEFENDANT

Liberi v Taitz motion to dismiss under 12b- 1

Liberi v Taitz motion to dismiss under 12b- 2

Liberi v Taitz motion to dismiss under 12b- 3

Liberi v Taitz motion to dismiss under 12b- 4

Liberi v Taitz motion to dismiss under 12b- 5

FIRST CAUSE OF ACTION IS WILFUL AND INTENTIONAL

Liberi v Taitz motion to dismiss under 12b- 6

Liberi v Taitz motion to dismiss under 12b- 7

Liberi v Taitz motion to dismiss under 12b- 8

Liberi v Taitz motion to dismiss under 12b- 9

Liberi v Taitz motion to dismiss under 12b- 10

Liberi v Taitz motion to dismiss under 12b- 11

FVW -028000, pled 316

page 122 of the FAC). Additionally, defendants

Liberi v Taitz motion to dismiss under 12b- 12

Liberi v Taitz motion to dismiss under 12b- 13

Liberi v Taitz motion to dismiss under 12b- 14

Liberi v Taitz motion to dismiss under 12b- 15

Liberi v Taitz motion to dismiss under 12b- 16

Defend Our Freedoms Foundation and Orly Taitz

Liberi v Taitz motion to dismiss under 12b- 17

Liberi v Taitz motion to dismiss under 12b- 18

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