Case 2:11-cv-00090-J Document 201-11

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Law Offices of: PHILIP J. BERG, ESQUIRE Identification No. 09867 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Ph: (610) 825-3134 Fx: (610) 834-7659 Email: philjberg@gmail.com EVELYN ADAMS, Plaintiff c/o PHILIP J. BERG, ESQUIRE 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Ph: (610) 825-3134 Fx: (610) 834-7659 Email: philjberg@gmail.com

Attorney in pro se

In Pro Se.

LISA OSTELLA, and GO EXCEL GLOBAL, Plaintiffs c/o PHILIP J. BERG, ESQUIRE 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Ph: (610) 825-3134 In Pro Se. Fx: (610) 834-7659 Email: philjberg@gmail.com LISA LIBERI, Plaintiff c/o PHILIP J. BERG, ESQUIRE 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Ph: (610) 825-3134 Fx: (610) 834-7659 Email: philjberg@gmail.com

In Pro Se.

U.S. DISTRICT COURT, NORTHERN DISTRICT OF TEXAS AMARILLO DIVISION _____________________________________________ : LISA LIBERI, et al, Plaintiffs, : CIVIL ACTION : vs. : : Case No. 2:11-cv-00090-J : LINDA SUE BELCHER, et al, : Honorable Mary Lou Robinson : Defendants. :
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Case 2:11-cv-00090-J Document 201-11

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DECLARATION OF KELLY STREBEL I, Kelly Strebel am over the age of eighteen and am not a party to the within action. I have personal knowledge of the facts herein and if called to do so I could and would completely testify. I am making this declaration under the penalty of perjury of the Laws of the United States pursuant to 28 U.S.C. 1746. 1. I have recently learned that Edgar and Caren Hale have filed and

declared Bankruptcy in the state of Texas. I have also come to learn that Ed & Caren Hale failed to properly disclose Lisa Liberi, Lisa Ostella, Go Excel Global, Evelyn Adams and Phillip J. Berg as Creditors in their Bankruptcy case as they are the plaintiffs who are currently suing Mr. & Mrs. Hale, Bar H Farms, Plains Radio Network, Inc. and KPRN AM 1610 in the case of Lisa Liberi, et al VS Linda Sue Belcher, et al case No. Robinson. 2. Because of their filing it is important to notify this court as well as the 2:11-cv-00090-J before the Honorable Mary Lou

Trustee of the Local Bankruptcy court and the US Bankruptcy Court Trustee of possible issues and attempts of the Hale Defendants to commit a fraud upon the court and to hide assets in an attempt to make an improper declaration to the court regarding their no asset Chapter 7 Bankruptcy. Defendants Edgar and Caren Hale are attempting to seek a discharge of all their debts based on fraud by failing to list their assets in their Bankruptcy as mandated by law.
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Case 2:11-cv-00090-J Document 201-11

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3.

During the course of time in or about May of 2009 up through the

year 2011 Mr. Hale as stated numerous times both on his Radio programs on Plains Radio Network, Inc. through KPRN AM 1610 radio Tower, which he owns and operates and failed to declare as an asset in his Bankruptcy filings, that he was going to file bankruptcy in order to make sure that none of the plaintiffs get anything from this lawsuit. This statement was made many times while on air and within his website located at http://www.plainsradionetwork.com and http://www.plainsradio.com. 4. I am in daily contact with Plaintiff Lisa Liberi. Lisa was very upset

that neither she nor any of the other Plaintiffs were properly noticed regarding the Hales bankruptcy. Lisa or any of the other Plaintiffs were not listed as creditors, as they should have been. Lisa told me that the Hales Meeting of the Creditors was set for December 15, 2011, but the Plaintiffs were unable to locate the Hales bankruptcy until mid-December 15, 2011, as they did not have the case number. Lisa was happy to learn that the Hales failed to attend their Meeting of the Creditors and the date was reset to January 10, 2012. 5. Based on evidence now obtained from Court Records and Tax filings

with Collingsworth County, Texas and the fact that Mr. Hale stated he would file bankruptcy and that the plaintiffs would get nothing, that he has now attempted to do what he threatened with filing his Bankruptcy case along with his wife Caren, it
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appears they have now attempted to move assets around by changing ownership and not declaring assets in an attempt to commit a fraud upon the court in order to keep what should legally be an liquefiable asset or assets to satisfy debts owed. The Hales have attempted to deprive the Plaintiffs by hiding and moving their assets and failing to list all their assets with the bankruptcy Court. The Hales have many assets including but not limited to farm land, 160 acres; the home they reside in located on Bowie Street in Wellington, Texas, two (2) rental properties in Wellington, Texas which I have heard Caren state on their Radio program that she has to collect the rents for these properties, which is also income, the AM radio tower, windmills, paid advertisements on their websites and radio programs, donations and monies received through Plains Radio, the sale of beef Caren and Edgar have discussed on their radio show, land rentals for hunting, etc. The Hales have other liquefiable assets such as Radio equipment and computers used to broadcast with and through KPRN 1610 AM radio and Plains Radio Network, Inc., a/k/a Plains Radio. 6. Edgar and Caren Hale during several of their radio shows, including

but not limited to June 18, 2009, September 10, 2009, August 16, 2011 and others that their farm land is worth over half a million dollars. The Hales have also bragged in their radio shows that they have 2-1/2 million listeners. Plains Radio Network, Inc. is broadcast through their AM radio tower through all AM Stations.
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The more listeners the radio show has, the more the radio program is worth. In 2009, Edgar Hale was selling stock to his listeners for donations. 7. As previously expressed to this Court, Mr. Hale has lifted signatures

from documents and used them on the Internet without permission from the owners of those signatures, therefore I along with the Plaintiffs in this case am submitting an Electronic Signature on this Declaration and have provided a signed copy of this document to Philip J. Berg Esq., who is Pro Se and council for the Plaintiffs in this case before it transferred to Texas and as Counsel for Plaintiffs in the California portion of this case.

I declare under the penalty of perjury of the Laws of the United States and Texas that the foregoing is true and correct. Executed this 16th day of December, 2011.

I have authorized Mr. Berg to sign my name electronically, which I have initialed so he is able to file my Declaration electronically and not provide the Defendants with my full signature for the reasons outlined herein. /s/ Kelly Strebel Kelly Strebel, Declarant

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