Case Numbers: 11-56079 and 11-56164

(Consolidated February 3, 2012)

UNITED STATES COURT OF APPEALS
FOR THE NINTH CIRCUIT
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LISA LIBERI, et al,
Plaintiffs/Appellees
vs.
ORLY TAITZ, DEFEND OUR
FREEDOMS FOUNDATIONS, INC., et al,
Defendants/Appellants

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On Appeal from the United States District Court,
Central District of California, Southern Division
Case No. 8:11-cv-00485
Honorable Andrew Guilford
APPELLEES REPLY TO APPELLANT DEFEND OUR FREEDOMS
FOUNDATIONS, INC. RESPONSE IN OPPOSITION TO APPELLEES
MOTION TO STRIKE APPELLANTS REPLY BRIEF AND EXHIBITS;
Philip J. Berg, Esquire (PA Bar No. 09867)
Law Offices of Philip J. Berg
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
Ph: (610) 825-3134
Attorney for Appellees Lisa Liberi, Lisa
Ostella, Go Excel Global, Philip J. Berg,
Esquire and the Law Offices of Philip J.
Berg
FOR SANCTIONS; FOR ATTORNEY FEES AND COSTS
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i
TABLE OF CONTENTS
Pages
TABLE OF CONTENTS.......i
BRIEF, EXHIBITS 1, 2, 3 FILED THEREWITH;
V. THE COURT ORDERED a CONSOLIDATED REPLY
VI. SANCTIONS AGAINST ORLY TAITZ, ESQUIRE are
IV. APPELLATE COURTS ONLY CONSIDER the RECORD
UNOPPOSED and THEREFORE, MUST BE GRANTED ..2-4
for SANCTIONS; for ATTORNEY FEES and COSTS is
BEFORE the DISTRICT COURT on APPEAL.....4-6
BRIEF, if a REPLY was FILED.6-7
WARRANTED.7-10
TABLE OF AUTHORITIES....ii-vi
I. INTRODUCTION...1
II. STATEMENT OF FACTS..1-2
III. APPELLEES MOTION TO STRIKE DOFFS REPLY
VII. CONCLUSION............10
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ii
TABLE OF AUTHORITIES
Cases Page(s)
Aloe Vera of America, Inc. v. United States,
376 F.3d 960 (9
th
Cir. 2004)10
B.K.B. v. Maui Police Dept.,
276 F.3d 1091, 1107-08 (9
th
Cir. 2002)...9, 10
Carmen v. San Francisco Unified Sch. Dist.,
237 F.3d 1026, 1030 (9
th
Cir. 2001)..5
Cedano-Viera v. Ashcroft,
324 F.3d 1062, 1066 n.5 (9
th
Cir. 2003)....4
cf. Carrigan v. Cal. State Legislature,
263 F.2d 560, 564 (9
th
Cir. 1959)..9
Chambers v. Nasco, Inc., 501 U.S. 32, 45-50 (1991)..10
Eberle v. City of Anaheim, 901 F.2d 814, 818 (9
th
Cir.1990)....4
Estate of Blas, 792 F.2d 858, 860 (9
th
Cir. 1986)......9
Fink v. Gomez, 239 F.3d 989, 993-94 (9
th
Cir. 2001)..10
Graves v. Arpaio, 623 F.3d 1043, 1048 (9
th
Cir. 2010).4
Greensprings Baptist Christian Fellowship Trust v. Cilley,
629 F.3d 1064 (9
th
Cir. 2010)3
In re BioLase Tech. Sec. Litig.,
th
Janes v. Wal-Mart Stores, Inc., 279 F.3d 883, 887 (9
th
Cir. 2002)...5
No. 04-947 DOC (C.D. Cal. Jan. 27, 2003)..5, 6
In re Lehtinen, 564 F.3d 1052, 1061 n.4 (9 Cir. 2009)...9
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iii
TABLE OF AUTHORITIES - Continued
Cases Page(s)
Kirshner v. Uniden Corp. Of America,
th
th
Lentini v. Cal. Ctr. for the Arts,
th
MacDonald v. Grace Church Seattle,
th
th
New Alaska Dev. Corp. v. Guetschow,
th
th
Panawiew Door v. Window Co. v. Reynolds Metal Co.,
255 F.2d 920, 922 (9
th
Cir. 1958)..5
Peterson v. Highland Music, Inc.,
140 F.3d. 1313, 1321 (9
th
Cir. 1998).5
Smith v. Marsh, 194 F.34d 1045, 1052 (9
th
Cir. 1999)..5
Taitz v. Dunn, Orange County Superior Court,
United States v. $22,474.00 in U.S. Currency,
th
United States v. Elias, 921 F.2d 870, 874 (9
th
Cir. 1990)..5
Koerner v. Grigas, 328 F.3d 1039, 1048 (9 Cir. 2003)....3, 4
842 F.2d 1074, 1077 (9 Cir.1988).....5, 6
869 F.2d 1298, 1306 (9 Cir. 1989)...9
246 F.3d 1212, 1218 (9 Cir. 2001)...5
Padgett v. Wright, 587 F.3d 983, 985 n.2 (9 Cir. 2009)..5
Case No. 30-2010-00381664.........2
457 F.3d 1079, 1086 (9 Cir. 2006)...............5
370 F.3d 837, 843 n.6 (9 Cir. 2004).........4
Morrison v. Hall, 261 F.3d 896, 900, fn.4 (9 Cir. 2001).........................5
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TABLE OF AUTHORITIES - Continued
Cases Page(s)
United States v. Rearden,
349 F.3d 608, 614 n.2 (9
th
Cir. 2003)4
Vess v.Ciba-Geigy Corp. USA, 317 F.3d 1097 (9
th
Cir. 2003)..3
Verizon Delaware, Inc. v. Covad Comms. Co.,
377 F.3d 1081 (9
th
Cir. 2004)3
Yagman v. Republic Ins. Co.
th
Yniguez v. Arizonans for Official English,
th
FEDERAL STATUTES
Page(s)
28 U.S.C. 17345
28 U.S.C. 17355
FEDERAL RULES OF APPELLATE PROCEDURE
Page(s)
Rule 10(a).6
Rule 10(e).5
Rule 10(a).6
987 F.2d 622, 626, fn 3 (9 Cir. 1993).5
42 F.3d 1217, 1221, n. 3 (9 Cir. 1994)...4
28 U.S.C. 1927............9
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TABLE OF AUTHORITIES - Continued
FEDERAL RULES OF APPELLATE PROCEDURE
Page(s)
Rule 25(a)(4)..6
Rule 27(d)(1)(E)8
Rule 27(d)(2).8
NINTH CIRCUIT LOCAL RULES
Page(s)
FEDERAL RULES OF CIVIL PROCEDURE
Page(s)
Rule 11(c)(2)..8
Rule 32(a)(5).8
Rule 32(a)(6).8
Rule 27(a)(D).8
Rule 32(a)(7)(B)(ii)..7
Rule 11...8
Rule 30-1.......8
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vi
TABLE OF AUTHORITIES - Continued
MISC.
Page(s)
Blacks Law Dictionary, Third Edition, May 2006, at p. 136...6
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I. INTRODUCTION:
Appellees Lisa Liberi, Lisa Ostella, Go Excel Global, Philip J. Berg, Esquire
[Berg], and the Law Offices of Philip J. Berg, [Appellees] file the within Reply to
Appellant Defend our Freedoms Foundations, Inc. [DOFF] Opposition to Appellees
II. STATEMENT OF FACTS:
Taitz, Counsel for DOFF, filed DOFFs Reply Brief and three [3] Exhibits on
April 19, 2012, which was rejected by the Court. DOFF refiled their Reply Brief on
April 30, 2012, without the Exhibits, and at the same time filed a Motion for Judicial
Notice of the three [3] Exhibits. See ID 8158987, Docket Numbers [DN or DNs]
47-1, 47-2, 47-3 and 47-4.
On April 24, 2012 Appellees filed a Motion to Strike DOFFs Reply Brief and
Exhibits 1, 2 and 3 filed April 19, 2012, DNs 35-1, 35-2, 35-3, and 35-4 as
DOFFs Reply Brief had new arguments pertaining to each of Appellees Causes of
Action in their original complaint; and the Exhibits did not pertain to DOFFs Anti-
SLAPP Motion or this Appeal, nor were these new arguments and Exhibits provided
to the District Court in DOFFs Anti-SLAPP proceedings or with their Appellants
Opening Brief, thus they are Waived.
DOFFs Opposition, filed by Orly Taitz [Taitz], further proves DOFFs
Reply Brief and Exhibits 1, 2 and 3 filed therewith were filed in bad faith and
Motion to Strike; for Sanctions, Attorney Fees and Costs; and Appellees Opposition
to DOFFs inappropriate combined Motion for Sanctions.
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must be Stricken; Sanctions are warranted and Appellees are entitled to Attorney Fees
and Costs. DOFFs Opposition is unintelligible, pertains to the Motion to Strike
Appellant Orly Taitzs Reply Brief and not Appellees Motion to Strike DOFFs Reply
Brief and Exhibits. DOFFs Opposition is nothing more than a slubby mass of
words N/S Corp. v. Liberty Mut. Ins. Co., 127 F.3d 1145, 1146 (9th Cir. 1997). Just
like in the Dunn Case
1
, Taitzs Opposition filed on behalf of DOFF is fraught with
red herrings, inapplicable citations and wandering legal arguments.
Taitz on behalf of DOFF failed to address any of the arguments raised in
Appellees Motion to Strike DOFFs Reply Brief and Exhibits filed therewith;
Appellees Request for Sanctions against Taitz and DOFF; and/or Appellees Request
for Attorney Fees and Costs. Therefore, Appellees Motion is unopposed and must be
Granted.
III. APPELLEES MOTION TO STRIKE DOFFS REPLY BRIEF,
EXHIBITS 1, 2, 3 FILED THEREWITH; for SANCTIONS; for
ATTORNEY FEES and COSTS is UNOPPOSED and THEREFORE,
MUST BE GRANTED:
Appellees in their Motion moved to Strike DOFFS Reply Brief as it contained
new arguments and Exhibits 1, 2 and 3 filed therewith in which DOFF failed to
raise before the District Court or in DOFFs Appellants Opening Brief.
Instead of addressing the issues raised in Appellees Motion to Strike DOFFs
Reply Brief, Exhibits 1, 2and 3, for Sanctions against Orly Taitz, Esquire,

1
Damon Dunn in a Reply to Taitzs Opposition in the matter of Taitz v. Dunn, Orange County
Superior Court, Case No. 30-2010-00381664 stated Taitzs Opposition was fraught with red
herrings, inapplicable citations and wandering legal arguments.
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attorney for DOFF; for Attorney Fees and Costs, DOFF further argues the District
Courts Denial of Appellant Orly Taitzs Anti-SLAPP Motion and the Anti-SLAPP
statute. DOFF also raises arguments about Appellees Answering Brief and the cases
Verizon Delaware, Inc. v. Covad Comms. Co., 377 F.3d 1081 (9
th
Cir. 2004), Vess v.
Ciba-Geigy Corp. USA, 317 F.3d 1097 (9
th
Cir. 2003), and Greensprings Baptist
Christian Fellowship Trust v. Cilley, 629 F.3d 1064 (9
th
Cir. 2010) as the basis for
Appellees Motion to Strike
2
. This is not what Appellees asked this Court to Strike in
DOFFs Reply Brief.
DOFF argues issues that were not present in its Reply Brief or in Appellees
Motion to Strike, but instead were present in Appellant Taitzs Reply Brief filed by
her attorney, Jeffrey Cunningham, Esquire. DOFF has copied word for word the
arguments of Jeffrey Cunningham, Esquire in Appellant Taitzs Appeal in Opposition
to Appellees Motion to Strike parts of Appellant Taitzs Reply Brief, thus DOFFs
arguments do not pertain to Appellees Motion to Strike DOFFs Brief and the three
[3] Exhibits attached thereto.
The new statements, quotes, requests and Exhibits filed by DOFF for the first
time in their Reply Brief, which are outlined in Appellees Motion, were not presented
to the District Court, nor were they presented in DOFFs Opening Brief, and
therefore, they must be Stricken. See Koerner v. Grigas, 328 F.3d 1039, 1048 (9th

2
Taitz claims these three [3] cases cannot be introduced because Appellees did not present
them to the District Court. Appellees cited to these three [3] cases pertaining to the appealability
of the Anti-SLAPP Order, which is not a final Order, when Leave to Amend is Granted.
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Cir. 2003). Issues raised for the first time in an Appellants Reply Brief are
considered Waived, the Court routinely refuses to consider them. See, e.g., Lentini v.
Cal. Ctr. for the Arts, 370 F.3d 837, 843 n.6 (9th Cir. 2004); United States v. Rearden,
349 F.3d 608, 614 n.2 (9th Cir. 2003); Cedano-Viera v. Ashcroft, 324 F.3d 1062, 1066
n.5 (9th Cir. 2003): Graves v. Arpaio, 623 F.3d 1043, 1048 (9th Cir. 2010) (per
curiam); Eberle v. City of Anaheim, 901 F.2d 814, 818 (9th Cir.1990).
For the reasons outlined in Appellees Motion to Strike and herein, DOFFs
duplicative Consolidated Reply Brief filed in Case No. 11-56164, DN 35-1 and
Exhibits 1 through 3, DNs 35-2, 35-3 and 35-4 attached thereto must be Stricken
in their entirety.
IV. APPELLATE COURTS ONLY CONSIDER the RECORD BEFORE
the DISTRICT COURT on APPEAL:
DOFFs entire Opposition is copied from and premised on Appellant Orly
Taitzs Arguments presented in Opposition to Appellees Motion to Strike part of
Appellant Taitzs Reply Brief and Supplemental Excerpt of Record, which does not
apply, address or pertain to the Motion Appellees filed to Strike DOFFs Reply Brief
and Exhibits 1, 2 and 3 filed therewith in their entirety.
The Appellate Record cannot include factual allegations or supposed
evidence unsupported by the District Court Record. Yniguez v. Arizonans for Official
English, 42 F.3d 1217, 1221, n. 3 (9
th
Cir. 1994). The creation of the record on appeal
occurs solely in the District Court. Appellate Courts consider only the record before
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the trial judge when his decision was made (emphasis in original), Kirshner v.
Uniden Corp. Of America, 842 F.2d 1074, 1077 (9
th
Cir.1988); United States v.
$22,474.00 in U.S. Currency, 246 F.3d 1212, 1218 (9
th
Cir. 2001). Neither the
Appellant nor the Appellee can add to or enlarge the record on Appeal to include
material that was not before the District Court. Morrison v. Hall, 261 F.3d 896, 900,
fn.4 (9th Cir. 2001). The rule prohibiting enlargement of the record is strictly
construed. Panawiew Door v. Window Co. v. Reynolds Metal Co., 255 F.2d 920, 922
(9
th
Cir. 1958). The only exceptions to this rule is when a mistake in the reporters
transcript has occurred (FRAP 10(e); 28 USC Sections 1734, 1735), Yagman v.
Republic Ins. Co., 987 F.2d 622, 626, fn 3 (9
th
Cir. 1993), none of which apply herein.
Issues, defenses and arguments not raised at the District Court cannot be raised
in the Appeal. This Court reviews the lower Court's application of the law to the facts
as presented. Janes v. Wal-Mart Stores, Inc., 279 F.3d 883, 887 (9
th
Cir. 2002);
MacDonald v. Grace Church Seattle, 457 F.3d 1079, 1086 (9th Cir. 2006); Smith v.
Marsh, 194 F.34d 1045, 1052 (9
th
Cir. 1999); Padgett v. Wright, 587 F.3d 983, 985
n.2 (9
th
Cir. 2009) (per curiam); United States v. Elias, 921 F.2d 870, 874 (9
th
Cir.
1990).
For the reasons outlined in Appellees Motion and herein, DOFFs new
arguments and Exhibits filed for the first time in its Reply Brief must be Stricken. See
Peterson v. Highland Music, Inc., 140 F.3d. 1313, 1321 (9th Cir. 1998) and Carmen v.
San Francisco Unified Sch. Dist., 237 F.3d 1026, 1030 (9th Cir. 2001). See also In re
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BioLase Tech. Sec. Litig., No. 04-947 DOC (C.D. Cal. Jan. 27, 2003) n1; Fed. R. App.
P. 10(a); and Kirshner v. Uniden Corp. of Am., 842 F.2d 1074, 1077 (9th Cir. 1988).
Accordingly, this Court should Strike DOFFs Reply Brief and Exhibits filed
therewith, that [were] not presented to the district court. Kirschner, supra, 842 F.2d
at 1078.
V. THE COURT ORDERED a CONSOLIDATED REPLY BRIEF, if a
REPLY was FILED:
DOFF argues on behalf of Taitzs Opposition to Appellees Motion to Strike
portions of Appellant Taitzs Reply Brief and Supplemental Excerpts of Record,
instead of the issues raised to Strike DOFFs Reply Brief and Exhibits filed therewith
in their entirety. DOFF argues that despite Commissioner Peter L. Shaws Order of
February 3, 2012, that the Court instructed them to file a separate brief and their brief
was accepted by the Clerk of Court.
3
Commissioner Peter L. Shaw stated in his Order of February 3, 2012 on page
one that the Court sua sponte consolidates Appeals No.s 11-56079 and 11-56164.
Commissioner Shaw stated on page 2, The amended briefing schedule is as follows:
the consolidated answering brief is due March 7, 2012; the consolidated optional
reply brief is due within 14 days after service of the consolidated answering
brief. [emphasis added]

3
The Court Clerks are not permitted to provide legal advice or interpretation of our laws. Our
Clerks cannot advise or instruct an individual to proceed in a manner that would violate a Court
Order. Nor can the Clerk of Court refuse to file a document, Fed. R. App. P. 25(a)(4). Whether a
document is in compliance with a Court Order is left to the Judge, not the Clerk.
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A consolidated Reply Brief means one brief, not two. The definition of
consolidated is, 1. The act or process the state of being united; 2. Civil Procedure,
the Court unification of two or more actions involving the same parties and issues into
a single action See Blacks Law Dictionary, Third Edition, May 2006, at p. 136.
See also Dictionary.com - consolidated brought together as a single wholeto bring
together (separate parts) into a single or unified whole; unite; combine: They
consolidated their three companies.
http://dictionary.reference.com/browse/consolidated?s=t.
A Reply Brief is allowed 7,000 words or fifteen [15] pages, Fed. R. App. P.
32(a)(7)(B)(ii). In this case, DOFF and Taitz together filed 14,000 words and in
excess of sixty-four [64] pages as their Consolidated Reply Brief, in violation of
Fed. R. App. P. 32(a)(7)(B)(ii).
VI. SANCTIONS AGAINST ORLY TAITZ, ESQUIRE are
WARRANTED:
DOFFs Opposition to Appellees Motion to Strike their Reply Brief, Exhibits;
for Sanctions; for Attorney Fees and Costs further upholds why this Court should
Sanction Orly Taitz, Esquire, attorney for DOFF. DOFFs Reply Brief and Exhibits
as well as their Opposition to Appellees Motion violates the Ninth Circuit Rules; the
Federal Rules of Appellate Procedure; is vexatious; includes irrelevant, immaterial
and unnecessary materials that have no relation to DOFFs Anti-SLAPP Motion or
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this Appeal, and was filed by DOFFs attorney, Orly Taitz, Esquire, to unreasonably
increases the cost of litigation on the Appellees.
DOFFs Opposition alone violates Fed. R. App. P. 27(a)(D) the margins
contain text other than page numbers; 27(d)(1)(E), 32(a)(5), 32(a)(6) as all the fonts
are not 14 pt. font and different font types are used; and 27(d)(2) in that it is over the
twenty [20] page limit.
DOFF also filed a combined Motion for Sanctions against the Appellees under
Fed. R. Civ. P. 11 in its Opposition, which is completely improper. Fed. R. of Civ. P.
11 mandates all Motions for Sanctions to first be served upon the opposing party; then
after 21 days if the errors complained of are not corrected, then and only then can the
Motion be filed. See Fed. R. Civ. P. 11(c)(2). Furthermore, any Motion for Sanctions
under Rule 11 must be brought by an independent Motion and not combined with any
other filing, Fed. R. Civ. P. 11(c)(2). DOFFs arguments in requesting Sanctions are
based on false arguments, false statements, false allegations, all of which were created
by DOFFs Attorney, Orly Taitz, Esquire and have nothing to do with this Appeal, nor
does this Appellate Court have jurisdiction. DOFFs Motion for sanctions is
frivolous and must be Denied.
Sanctions are proper when a party fails to Comply with Circuit Rule 30-1, by
including irrelevant materials in the Excerpts of Records or Exhibits filed with a
Brief [emphasis added]. The Ninth Circuit Local Rule 30-2 allows for Sanctions,
Costs and Attorney Fees against an Attorney who vexatiously and unreasonably
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increases the cost of litigation by inclusion of unnecessary material in the excerpts of
record or Exhibits,
4
as Orly Taitz, Esquire on behalf of DOFF has done.
28 U.S.C. 1927 allows this Circuit to Sanction an Attorney who so multiplies
the proceedings in any case unreasonably and vexatiously for those excess costs,
expenses, and attorneys fees reasonably incurred as a result of attorneys conduct.
Recklessness suffices under 1927, but the Court must find there was bad faith.
B.K.B. v. Maui Police Dept., 276 F.3d 1091, 1107-08 (9
th
Cir. 2002). The mere fact
DOFF refiled Exhibits 1, 2, and 3, after they were posted all over the Internet,
in a Motion for Judicial Notice, after being served with Appellees Motion to Strike
clearly evidences bad faith.
There is no question that Orly Taitz, Esquire actions of including new
arguments and Exhibits in their Reply Brief and their Opposition to Appellees Motion
to Strike, that were never provided to the District Court or in DOFFs Opening Brief,
which have no relevancy to the pending Appeal, using this Courts Docket as a
publishing ground to post the filings all over the Internet, was in bad faith and is
supported by DOFFs filings on April 19, 2012, April 30, 2012, May 3, 2012, and the
Internet postings, all of which is clear and convincing evidence. In re Lehtinen, 564
F.3d 1052, 1061 n.4 (9
th
Cir. 2009); New Alaska Dev. Corp. v. Guetschow, 869 F.2d
1298, 1306 (9th Cir. 1989); Estate of Blas, 792 F.2d 858, 860 (9th Cir. 1986); B.K.B.

4
The Ninth Circuit Court has the inherent power to strike irrelevant material. Circuit Rule 30-1;
See also cf. Carrigan v. Cal. State Legislature, 263 F.2d 560, 564 (9th Cir. 1959) (discussing an
appellate courts inherent power to strike briefs and pleadings as either scandalous, impertinent,
scurrilous, and/or without relevancy).
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v. Maui Police Dept, 276 F.3d 1091, 1107-08 (9th Cir. 2002); Fink v. Gomez, 239
F.3d 989, 993-94 (9th Cir. 2001); Chambers v. NASCO, 501 U.S. 32 (1991).
Orly Taitz, Esquire, counsel for DOFF also violated the Courts February 3,
2012 Consolidation Order, by filing a secondary Reply Brief on behalf of DOFF,
which alone warrants Sanctions and an award of Attorney Fees and Costs to
Appellees, Aloe Vera of America, Inc. v. United States, 376 F.3d 960 (9th Cir. 2004)
(Sanctions are appropriate when a party purposely violates a Court Order) Id. at 966.
VII. CONCLUSIONS:
Appellees Motion to Strike DOFFs Reply Brief, Exhibits thereto, for
Sanctions, for Attorney Fees and Costs is unopposed. For the reasons outlined herein
and in Appellees Motion, Appellees Motion must be Granted. Appellant DOFFs
Reply Brief, Exhibits and Opposition, DNs 35, 35-1, 35-2, 35-3, 35-4, and 50 must
be Stricken; Orly Taitz, Esquire, counsel for DOFF, must be Sanctioned in an amount
determined by this Court; and Appellees awarded Attorney Fees and Costs in the
amount of $15,000.00. DOFFs Motion for Sanctions under Rule 11 must be denied.
Respectfully submitted,
Dated: May 5, 2012 /s/ Philip J. Berg
Philip J. Berg, Esquire
Attorney in pro se and for Appellees,
Lisa Liberi, Lisa Ostella, Go Excel
Global and the Law Offices of Philip J.
Berg
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LISA LIBERI, et al,

PlaintiIIs/Appellees
vs.
ORLY TAITZ, DEFEND OUR
FREEDOMS FOUNDATIONS, INC., et al,
DeIendants/Appellants

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On Appeal Irom the United States District Court,
Central District oI CaliIornia, Southern Division
Case No. 8:11-cv-00485
Honorable Andrew GuilIord

Philip J. Berg, Esquire (PA Bar No. 09867)
Law OIIices oI Philip J. Berg
555 Andorra Glen Court, Suite 12
LaIayette Hill, PA 19444-2531
Ph: (610) 825-3134

I, Philip J. Berg, Esquire, hereby certiIy that a true and correct copy oI
PlaintiIIs/Appellees Reply to Appellant DeIend our Freedoms Foundations, Inc.
Response in Opposition to Appellees Motion to Strike, Ior Sanctions, Ior Attorney
Iees and costs; and Appellees Opposition to Appellants combined Motion Ior
Sanctions was served this 5
th
day oI May 2012 electronically through the ECF
Filing system, upon the Iollowing:
Kim Schumann, Esquire
JeIIrey Cunningham, Esquire

3100 S. Bristol Street, Suite 400
Costa Mesa, CA 92626
Email: kschumannsrrlawIirm.comand jcunninghamsrrlawIirm.com

Orly Taitz, Esquire
29839 Santa Margarita, Suite 100
Rancho Santa Margarita CA 92688
Email: orly.taitzgmail.com and drtaitzyahoo.com

James F. McCabe, Esquire
MORRISON / FORESTER
425 Market Street
San Francisco, CA 94105
Email: jmccabemoIo.com




Marc Steven Colen, Esquire

5737 Kanan Road, Suite 347
Agoura hills, CA 91301
Email: mcolencolenlaw.com, lcolencolenlaw.com


/s/ Philip J. Berg
Philip J. Berg, Esquire