Documentos de Académico
Documentos de Profesional
Documentos de Cultura
Petitioner – Appellant,
v.
Respondents – Appellee.
_____________ Ο _____________
Please Take Notice that Appellants, Lisa Liberi [hereinafter “Liberi”]; Philip J. Berg,
Esquire [hereinafter “Berg”], the Law Offices of Philip J. Berg; Evelyn Adams a/k/a Momma E
[hereinafter “Adams”]; Lisa Ostella [hereinafter “Ostella”]; and Go Excel Global by and through
their undersigned counsel, Philip J. Berg, Esquire, hereby submit this Emergency Request for
Judicial Notice of Appellee Orly Taitz, et al Filing of a letter dated December 2, 2009, with
falsified information, slander, libel, false accusations, amongst many other things about
Appellants Lisa Liberi and Philip J. Berg, Esquire filed in the United States District Court,
Central District of California, Southern Division in the case of Barnett, et al v. Obama, et al,
Case Number 09-cv-00082-DOC, attached hereto as EXHIBIT “1”; The Docket of Barnett, et
al v. Obama, et al, Case No. 09-cv-00082-DOC showing the letter filed as Docket entry number
100, attached hereto as EXHIBIT “2”; and a picture of Appellee Taitz, et al letter posted on the
internet at SCRIBD prior to its filing in the United States Federal Docketing System in the case
of Barnett, et al v. Obama, et al, Case No. 09-cv-00082, attached hereto as EXHIBIT “3”.
Appellee Orly Taitz, et al Filed her famous Dossier #6, which contains falsified
information about Appellant Liberi, her Social Security number, date of birth, and other private,
confidential and personal information in the case of Barnett, et al v. Obama, et al, Case No. 09-
cv-00082 filed in the United States District Court, Central District of California, Southern
Division before Judge Carter. Counsel herein sent a letter to Judge Carter and requested the
sealing of Appellee Taitz, et al Filing of Dossier #6 as it violated the Federal Rules of Civil
Procedure and the California local rules. Judge Carter in turn issued an Order Sealing the Court
Filing of Dossier #6 and Ordered Appellee Taitz, the attorney in the Barnett Case, to re-file her
documents with all Social Security numbers, date of birth’s and other personal information
Case: 09-3403 Document: 00319937503 Page: 3 Date Filed: 12/08/2009
redacted as he, Judge Carter, was concerned about the confidentiality of Liberi, her spouse and
other individuals private confidential information being made public. This September, 2009
Court Order of Judge Carter has been filed with this Court by Appellants’ with a Request for
Judicial Notice.
Here, two [2] months later, Apellee Orly Taitz, et al Filed the attached letter in the
Federal Docketing System and placed it on the World Wide Web at Scribd prior to its filing in
the Federal Docketing System. Neither Appellant Liberi nor Appellant Berg have anything to do
with the Barnett case filed in California and the only reason these documents have been Filed by
Appellee Orly Taitz, et al is to use the Federal Docketing System to further her illegal, harmful,
damaging behaviors towards Appellant Liberi, Appellant Berg and any party associated with
them. It is imperative that this Court take Judicial Notice of these documents as it shows the
continued deceptions, fabricated statements and stories and dishonesty of Appellee Orly Taitz, et
al as the statements made by Appellee Orly Taitz’s in this letter contradict her statements and
filings to Judge Robreno in the lower Court, U.S. District Court, Eastern District of
Pennsylvania. In addition, this letter of Appellee Orly Taitz’s also proves the allegations which
Appellants’ have pled against her and the other Appellees herein.
Moreover, Appellants’ requested Leave from Judge Robreno in the lower Court, U.S.
District Court, Eastern District of Pennsylvania on November 29, 2009 to file their Motion
requesting Transfer of the within Diversity Action to the United States District Court, Central
District of California, Southern Division located in South Orange County at 411 West Fourth
Street, Santa Ana, CA 92701-4516 with telephone number (714) 338-4750, see EXHIBIT “4”,
which is the very Court that Appellee Orly Taitz, et al filed this December 2, 2009 letter. Thus,
Appellants’ are concerned that Appellee Orly Taitz, et al may be attempting to conflict out the
Case: 09-3403 Document: 00319937503 Page: 4 Date Filed: 12/08/2009
Judges in the United States District Court, Central District of California, Southern Division. To
date, Judge Robreno has not granted or denied Appellants’ request for leave to file their Motion.
“A judicially noticed fact must be one not subject to reasonable dispute in that it is either
(1) generally known within the territorial jurisdiction of the trial court or (2) capable of accurate
and ready determination by resort to sources whose accuracy cannot reasonably be questioned.”
Fed. R. Evid. §201(b); Easy Sportswear, Inc. v. Am. Econ. Ins. Co., 2008 U.S. Dist. LEXIS
51402 (D. Pa. 2008); Nationwide Life Ins. Co. v. Commonwealth Land Title Ins. Com., 2005 U.S.
Dist. LEXIS 24479 (E.D. Pa. 2005); In re NAHC, Inc. Sec Litig, 306 F.3d 1315 (3d Cir. 2002)
“[a] court shall take judicial notice if requested by a party and supplied with the necessary
information.” Fed. R. Evid. 201(d) (emphasis added) Easy Sportswear, Inc., 2008 U.S. Dist.
It is firmly established that Requests for Judicial Notice are proper “only to the extent
that the noticed facts are relevant to an issue” that is before the Court. Each of the Exhibits that
Appellants are requesting Judicial Notice of are of the type that have previously been admitted
by Judicial Notice in the Third Circuit. This includes documents integral to or explicitly relied
upon in the Appellants’ Complaint and the reasons Appellants’ were forced to bring suit against
the Appellees. All Exhibits Appellants are requesting Judicial Notice of are directly related to
this within action and are relevant to the issues herein. In re Ravisent Techs., Inc. Sec. Litig.,
For the above aforementioned reasons, Appellants’ respectfully request this Honorable
Court to take Judicial Notice of Appellee Orly Taitz, et al letter of December 2, 2009 attached
showing Appellee Taitz’s letter filed as Docket entry 100 attached hereto as EXHIBIT “2”; and
Case: 09-3403 Document: 00319937503 Page: 5 Date Filed: 12/08/2009
the picture of SCRIBD website showing Appellee Orly Taitz posted this letter on the world wide
web prior to its filing in the Federal Docketing System, attached hereto as EXHIBIT “3. ”.
Respectfully submitted,
s/ Philip J. Berg
Dated: December 8, 2009 ____________________________
Philip J. Berg, Esquire
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
(610) 825-3134
Petitioner – Appellant,
v.
Respondents – Appellee.
_____________ Ο _____________
CERTIFICATE OF SERVICE
I, Philip J. Berg, Esquire, hereby certify that a copy of Appellants’ Request for Judicial
Notice was served this 8th day of December 2009 electronically upon the following:
Orly Taitz
Defend our Freedoms Foundation, Inc. (unrepresented)
26302 La Paz Ste 211
Mission Viejo, CA 92691
Email: dr_taitz@yahoo.com
Neil Sankey
The Sankey Firm, Inc. a/k/a The Sankey Firm (unrepresented)
Sankey Investigations, Inc.
2470 Stearns Street #162
Simi Valley, CA 93063
Email: nsankey@thesankeyfirm.com
Case: 09-3403 Document: 00319937503 Page: 7 Date Filed: 12/08/2009
Ed Hale
Caren Hale
Plains Radio
KPRN
Bar H Farms
1401 Bowie Street
Wellington, Texas 79095
Email: plains.radio@yahoo.com; barhfarms@gmail.com;
ed@barhfarnet; and ed@plainsradio.com
s/ Philip J. Berg
________________________
PHILIP J. BERG, ESQUIRE
Case: 09-3403 Document: 00319937504 Page: 1 Date Filed: 12/08/2009
EXHIBIT “1 ” 5
Case
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12.02.09.
Your honor,
Under rule 83-3.1.12 you have the inherent power to investigate any misconduct perpetrated
upon this court during proceedings.
L.R. 83-3.1.12 Powers of an Individual Judge to Deal With Contempt or Other Misconduct Not
Affected . Disciplinary proceedings under Rule 83-3.1 shall not affect, or be affected by, any
proceedings for criminal contempt under the U.S. Criminal Code, nor shall anything contained in
this Rule 83-3.1 be construed to deny any judge of this Court said judge’s inherent power to
maintain control over the proceedings conducted before said judge, nor to deny the judge those
powers derived from any statute or rule of court. Misconduct of any attorney in the presence of
a court or in any manner in respect to any matter pending in a court may be dealt with directly
by the judge in charge of the matter or at said judge’s option, referred to the Committee, or
both.
There was a concerted and a well orchestrated effort by a number of individuals to assassinate
my character, endanger my law license and ultimately derail my case against Mr. Obama. A
number of criminal activities were perpetrated upon this court. I request urgent investigation of
the following activities:
1. Perjury committed by Lucas Smith in his letter to your honor, claiming that I have
suborned perjury, as I have never suborned perjury and only asked Mr. Smith to
authenticate the declaration that he has signed previously under the penalty of perjury
and later recorded on videotape by filmmaker Mr. William Waggener.
2. Perjury committed by Larry Sinclair in his letter claiming that I suborned perjury, as I
have never suborned perjury and simply asked Mr. Sinclair to authenticate an affidavit
submitted by him to the Chicago police and published in his book “Barack Obama &
Larry Sinclair Cocaine, Sex, Lies & Murder?” by Lawrence W. Sinclair .
3. A letter by attorney Philip Berg on behalf of his client Lisa Liberi submitted with
improper purpose to this court. Ms. Liberi is not only Mr. Berg’s client, but also his legal
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assistant, who according to Mr. Berg’s numerous radio interviews prepared a similar
case involving Mr. Obama. As Your Honor could see in dossier #6 submitted to this
court and Department of Justice, specifically Attorney General Eric Holder, as well as US
attorney’s office in this district, Ms. Liberi is a convicted felon, with 10 convictions of
forgery of documents, forgery of an official seal and grand theft. She was convicted in
January 2008 of all of the above felonies and received 8 year prison term. Miraculously
in spring of 2008 her 8 year prison term was reduced to probation only, which she was
allowed to serve in Santa Fe, NM, to be close to her father and step mother. Shortly
after her prison term was reduced from 8 years in prison to probation, she started
working with attorney Phillip Berg from PA on Obama eligibility case and in August of
2008 they submitted to US district court in the Eastern district of PA a case Berg v
Obama. This case contained some sworn affidavits from Kenya, testifying to Mr.
Obama’s Kenyan birth. As those were sworn affidavits submitted to federal court, I have
used this evidence by incorporation in a number of cases, including Lightfoot et al v
Bowen (vice presidential candidate Gail Lightfoot v secretary of state of CA Debra
Bowen ) submitted to the Supreme court of CA and the Supreme Court of the United
States and in this case Barnett et al v Obama, in the original pleadings submitted in
January 21, on the inauguration day and before Mr. Mr. Obama’s oath of office was
taken. ( the oath of office was actually taken the next day, as the first time it was
administrated improperly). Sometime in Spring of this year I received information that
Ms. Liberi has multiple convictions of forgery, used multiple social security numbers and
there is a real concern that the affidavits submitted to court by attorney Berg could have
been forged. I have written to Mr. Berg and asked him to either employ a forensic
document expert to check those documents for authenticity or give me an opportunity
to review those documents together with a forensic document expert in order to make
sure those documents are not forged, as I included them by reference in my pleadings in
this court. I thought Mr. Berg was not aware of Ms. Liberi’s past and would cooperate.
Instead Mr. Berg decided to keep me quiet by filing a totally frivolous legal action
against me, my investigator and a number of other parties. Mr. Berg was seeking a
restraining order on any information about Liberi and millions of dollars. US district
Judge Robreno promptly denied the TRO and issued an order to Berg to show cause,
why his case should not be dismissed due to lack of jurisdiction over the defendants in
the Eastern District of Pa. I am expecting this case to be dismissed shortly, as Mr. Berg
has never presented any evidence of jurisdictions over the defendants. I have also
removed from the first amended complaint in this case any mention of any evidence
coming from Berg and Liberi. I am greatly concerned that there was a concerted effort
to cloud the case against Mr. Obama by the evidence prepared by the convicted forger
Liberi. I believe someone has used this whole connection of Berg-Liberi as sort of an
insurance policy, in case this case goes to trial, it will be tainted. Additionally, I was
amazed by total paralysis of law enforcement to investigate any suspected criminal
activity by Berg and Liberi. According to San Bernardino District Attorney James Secord
Liberi is on disability and according to the terms of her probation she is not allowed to
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handle any credit cards of other individuals. According to the letter submitted to SSA by
former volunteer for Attorney Berg, Linda Belcher, Liberi has constantly handled credit
cards of individuals, who donated to Mr. Berg’s effort to expose Mr. Obama. Ms.
Belcher has also described routine practice of Mr. Berg paying Liberi’s earnings to her
husband Brent Liberi, which constituted fraud upon Social Security Administration and
IRS, perpetrated by Liberi and Berg, as Liberi was getting social security as a disabled
individual, and it was a violation of her probation. While all of this was reported, there
was no action by law enforcement yet.
4. From 11.11.09. to 11.22.09. I had the honor to be a delegate at the Continental
Congress 2009. One of the guest speakers for the Continental Congress was a former
Immigration officer and currently a private investigator in CO, Mr. John Samson. I have
stated to Mr. Samson that I need to tie some loose ends and I was wondering if as a
former immigration officer, Mr. Samson would be privy to the information, that other
investigators couldn’t obtain. In my presence Mr. Samson used his password and logged
into the Database “Intelligator’, and he printed out a document attached as an exhibit. It
shows that Mr. Obama’s immigration records show one more birthdate: 08.01.61 and
in the area of Ethnic origin it stated Equatorial Guinea. The rest of the information was
the usual, showing Michelle Obama as the spouse and the rest of the information that
we are used to see. This document provides significance in a number of areas: A. It
shows that with the minimal inquiry assistant US attorneys representing Mr. Obama in
this case knew or should have known, that not only there are 39 different social security
numbers that he used according to the databases, none of which were issued in Hawaii,
not only there are statements of forgery of his selective service certificate and
certification of life birth and his refusal to unseal the original birth certificate and
original birthing file from the Kapiolani hospital, there are additional doubts to his
citizenship, due to the presence of different date of birth and different origin. This
constitutes sufficient reason to doubt Mr. Obama’s citizenship status, where the US
attorney’s office and department of justice representing United states of America had
an obligation to withdraw from representation of Mr. Obama in this case and the fact
that it was not done, represents a clear violation of the professional ethics by the US
attorneys representing Mr. Obama in this case. B. This piece of information provided
another piece to the puzzle, as numerous articles have reported that some 500
Columbia university students from the same graduation year were questioned and
didn’t remember Mr. Obama as a student at Columbia, however at the same time there
was an article published in Seattle, Washington, regarding one, Roman Obama, an
exchange student from Equatorial Guinea (same origin listed in Mr. Obama’s
immigration records) studying in the university of Patrice Lumumba in Moscow. (this
university was known as a basis of heavy Communist indoctrination and rumored to be
the hunting ground of communist recruiting by the KGB). This university is very similar
to the university of Karl Marx, attended by Mr. Obama’s cousin, current prime minister
of Kenya Raela Odinga. C. It provided yet another connection between Mr. Obama and
the law clerk of this court Mr. Velamoor, as similarly there are conflicting accounts of
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Page 4 of 14
Mr. Velamoor’s legal education in Martindale and WestLaw directories: one pointing to
Columbia university, while the other to the Comenis law school in Bratislava, Slovakia. It
appears that both might have been part of the same program with the Columbia
university. Additionally there is a geographical connection as both Mr. Obama and Mr.
Velamoor came from the same tiny community of Mercer Island WA. While Mr. Obama
in his memoirs writes that his mother was married to Mr. Obama Sr. and lived in Hawaii
in and around his birth, the registrar records show that she dropped out of the
university of Hawaii around December 1960 and reappeared some nine months later
enrolled in the university of Washington from August 1961, shortly after Mr. Obama’s
birth. This coupled with the fact that Mr. Velamoor is still listed as an employee of
Perkins Coie, the law firm, representing Mr. Obama in eligibility litigation, shows that
there had been some ethics violation and Mr. Velamoor had to disclose all of the
connections and conflict of interest and had to be recused from assisting your owner.
Lastly, after the order of 10.29.09 became public, it became a source of hounding and wilding of
me and my family. As an example, a teacher has approached one of my children, pointed to a
newspaper article and commented that the judge says “your mother tells witnesses to lie”.
There are daily death threats against me and my family, tampering with my car and my
husband’s car and there is no assistance from either police or FBI. I believe that the justice
department, Attorney General Eric Holder and Assistant US attorneys representing both United
States of America and Mr. Obama are guilty of obstruction of Justice, as they do not investigate
and simply burry any and all illegal activity by Mr. Obama, but they also stop and burry all the
investigation of death threats against me and my family as well as any and all acts along the
lines of those threats. The only way this illegal activity will ever be investigated and prosecuted,
is not from initiative of Mr. Holder, but rather pursuant to a court order from you Your Honor.
There is an urgent need for your honor to start the investigation of perjury, violation of ethics
and possibly other illegal actions committed by the parties listed above upon this court. Speedy
investigation and resolution is paramount not only for my family, but for the country as a whole.
Respectfully submitted
I certify under penalty of perjury that the copies of the above letter were electronically served
upon all the parties in this case.
I solemnly swear under penalty of perjury that all the facts stated and circumstances described
above are true and correct statements. Further declarant saith naught.
12.03.09.
Attachments:
An example of daily death threats. The IP addresses of most of the individuals making death
threats were traced to WA state.
Nantucket Oh, Your “pastor” friend wiley drake can WISH the president dead but I can’t wish
track this IP? It
ptn@aol.com YOU dead orly? YOU ARE SUCH A HYPOCRITE!!!! sounds like a
I WISH YOU NOTHING BUT DEATH AND MISERY. I WISH YOUR CAR WILL CRASH
71.112.191.144 death threat to
BECAUSE SOMEONE TAMPERED WITH IT, AND YOU WILL BURN AND BE IN THE
WORST AGONY OF YOUR LIFE. I WISH AND PRAY FOR THE MOST AWEFUL DISEASE me
TO INFLICT YOUR WHOLE FAMILY. I WISH FOR ALL RIGHT WINGERS TO DROP
6 #
DEAD NOW, FOR THE ARE THE SEEDS OF HUMANITIES DESTRUCTION. I WISH
SOMEONE WOULD TAKE YOU OUT BEHIND A SHED AND BEAT YOU TILL YOU START
MAKING SENSE. I WISH YOU WOULD STOP LYING AND TWISTING RUMORS INTO
SO-CALLED “FACTS” … I WISH A LOT OF THINGS EVIL TO COME YOUR WAY. I
LEARNED IT FROM RIGHT WINGERS LIKE WILEY DRAKE AND COMPANY.
At the class reunion, our 20th reunion five years ago, who was
asked to be the speaker of the class? Me.
No one ever heard of Barack! And five years ago, nobody even
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knew who he was. The guy who writes the class notes, who's kind
of the, as we say in New York, the macha who knows everybody,
has yet to find a person, a human who ever met him. Is that not
strange?
http://en.wikipedia.org/wiki/Wayne_Allyn_Root#column-one
NOTE: Root graduated as Valedictorian from his high school, Thornton-Donovan School ,
then graduated from Columbia University in 1983 as a Political Science major (in the same
class as President Barack Obama WAS SUPPOSED TO HAVE BEEN IN)
Attachment: two different curriculum vitae for Mr. Velamoor. One shows JD from
Columbia University, another JD from Comenis University, Bratislava, Slovakia
An October 18th item focused on Siddharth Velamoor showing up in Judge Carter's court as his
new clerk. It turns out that Velamoor has multiple CVs.
Siddharth Velamoor
Perkins Coie
1201 Third Avenue
Suite 4800
Seattle, WA 98101-3099
London School of Economics and Political Science, 2005, M.Sc., Major: International Relations
From: Martindale.com
Siddharth Velamoor
Associate
Perkins Coie LLP
1201 Third Avenue, Suite 4800
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Seattle, Washington
11/17/2009 0532
#553 P.001!002
From:
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2
Paqe I~ Search Criterion: Barack Obama STATE = IL Search Results: Name: BARACK H OBAMA
Address: 5046 S GREENWOOD AVE CHICAGO IL 60615 (Google maesl Verified address: No County: COOK
Phone: OOB: 08-01-1961 Age: 48 Gender: M Education: Graduate School Occupation Group:
Professionalffechnical Occupation: Unknown Ethnic Code: Equatorial Guinea Ethnic Group: F Language Code: E
1 Marital status: Unknown Business owner: Record 10 #: Possible nicknames:
None Found Possible Relatives and associates: MICHELLE OBAMA Age: 45 Neighbors;
Name: ,IMAMES B
Latitude:
41.803120 City: CHICAGO
Case
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10 of 14
Longitude: -
87.599107 State: IL
Dwelling unit
size: N/R Zip: 60615
Homeowner/renter:
Unknown County: COOK
FIPS: 17
227.13 FIPS Place: 1400
Loan
Type: N/R Purchase date: N/R
Estimated value:
$969,000 Mortgage Lender: N/R
Mortgage
term: N/R Date of refinance: 0000-00-00
http://www-inteligator.com!advanced/xweb/index.php?xpath=premium _ usinfo&cisrestyp...
11/16/2009
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If your search returned too many items, try a new search with narrower terms.
ARTICLE 1 OF 1
For nearly a decade, Roman Obama's life at Patrice Lumumba University was almost paradise. He studied for free and got warm clothes
and cheap airline tickets that let him see the world.
"We had so many possibilities. Maybe it was not a luxurious life, but we could travel and do things," said Obama, a 31-year-old law
student from Equatorial Guinea.
The former Soviet Union spent huge sums of money over the past few decades to educate tens of thousands
"Ben" <btc@nycap.rr.com>
To:
dr_taitz@yahoo.com
http://www.foxnews.com/story/0,2933,391882,00.html
Don't know how much of this is new to you, suggests that birth announcements in
Hawaii are fakes due to incorrect letter spacing not used by the era's linotype
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machines around paragraphs 32-34 1st sentence "On August 13, 1961, nine days after
his birth, an Obama birth" http://www.oilforimmigration.org/facts/?p=2187
It seems if you can connect Patrice Lumuba Friendship University, it may prove a
national security threat:
http://www.thefreelibrary.com/The+Soviet+roots+of+terrorism:+scratch+any+%22Islamic
%22+terrorist+group...-a0208218572
"The PLO/Fatah movement remains true to its communist roots today, with Moscow-
trained Mahmoud Abbas serving as chairman of the PLO. Abbas studied for a doctorate
from Patrice Lumumba University in Moscow, finishing in 1982. KGB defector Yuri
Bezmenov explained back in 1984 that Patrice Lumumba University was "under the
direct control of the KGB and [the] Central Committee, where future leaders of the so-
called 'National Liberation Movements' are being educated and selected carefully....
They were dispatched back to their countries to be leaders of the so-called 'National
Liberation Movements,' or, to be translated into normal human language, leaders of
international terrorist groups." Abbas then defended his thesis at the Oriental Studies of
the Soviet Academy of Sciences, which was then headed by former KGB General
Yevgeny Primakov."
Somewhere, deep within the site: www.Newzeal.blogspot.com you may be able to find
info that will lead you in a helpful direction. There are about 90 write-ups of Obama's
Socialist and Communist connections under the heading "The Obama Files" (right side,
a couple scrolls down.) I've been doing a little research for the author, he's in the states
right now, think he's heading to CA right now.
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and finally:
http://gunnyg.wordpress.com/2009/09/20/barack-obama-russian-plant-new-evidence/
links to:
http://www.wnd.com/index.php?pageId=88439
and
http://pub44.bravenet.com/forum/static/show.php?usernum=3764075825&frmid=6712&msgid=10
71062&cmd=show
http://nl.newsbank.com/nl-
search/we/Archives?p_product=WA&p_theme=wa&p_action=search&p_maxdocs=200&
p_field_label-0=title&p_text_label-0=lumumba&p_field_label-1=Section&p_bool_label-
1=AND&p_field_label-2=Author&p_bool_label-
2=AND&s_dispstring=headline%28lumumba%29%20AND%20section%28*%29%20AN
D%20date%282/14/1992%20to%202/14/1992%29&p_field_date-
0=YMD_date&p_params_date-0=date:B,E&p_text_date-
0=2/14/1992%20to%202/14/1992%29&xcal_numdocs=20&p_perpage=10&p_sort=YMD
_date:D&xcal_useweights=no
For nearly a decade, Roman Obama's life at Patrice Lumumba University was almost
paradise. He studied for free and got warm clothes and cheap airline tickets that let him
see the world.
"We had so many possibilities. Maybe it was not a luxurious life, but we could travel and
do things," said Obama, a 31-year-old law student from Equatorial Guinea ."
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EXHIBIT “2 ” 6
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As of: 12/03/2009
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Date
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(ANx), APPEAL, CLOSED, DISCOVERY, MANADR
Plaintiff
Wiley S Drake represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Gary G Kreep
United States Justice Foundation
932 D Street, Suite 2
Ramona , CA 92065
760−788−6624
Fax: 760−788−6414
Email: usjf@usjf.net
ATTORNEY TO BE NOTICED
Plaintiff
Captain Pamela Barnett represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Lieutenant Colonel Richard Norton represented by Orly Taitz
Bauerbach (See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Captain Robin D Biron represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Colonel John D Blair represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Case:
Case:09-3403
8:09-cv-00082-DOC-AN
Document: 00319937505
As of: 12/03/2009
Page: 312:17
Date
PMFiled:
PST 12/08/2009
2 of 17
Plaintiff
Mr David L Bosley represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Ms Loretta G Bosley represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Captain Harry G Butler represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Representative Glenn Casada represented by Orly Taitz
Tennessee (See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Jennifer Leah Clark represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Representative Timothy Comerford represented by Orly Taitz
New Hampshire (See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Charles Crusemire represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Representative Cynthia Davis represented by Orly Taitz
Missouri (See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Chief Warrant Office Thomas S represented by Orly Taitz
Davidson (See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Matthew Michael Edwards represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
Case:
Case:09-3403
8:09-cv-00082-DOC-AN
Document: 00319937505
As of: 12/03/2009
Page: 412:17
Date
PMFiled:
PST 12/08/2009
3 of 17
ATTORNEY TO BE NOTICED
Plaintiff
Lieutenant Jason Freese represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Mr Kurt C Fuqua represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Officer Clint Grimes represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Julliett Ireland represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
D Andrew Johnson represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Israel D Jones represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
State Representative Timothy Jones represented by Orly Taitz
ESQ, MO (See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Commander David Fullmer LaRoque represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Gail Lightfoot represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
MIL Officer Lita M Lott represented by Orly Taitz
US Army (See above for address)
Case:
Case:09-3403
8:09-cv-00082-DOC-AN
Document: 00319937505
As of: 12/03/2009
Page: 512:17
Date
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4 of 17
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Major David Grant Mosby represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
MSGT Steven Kay Neuenschwander represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
State Representative Frank Niceley represented by Orly Taitz
Tennessee (See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Retired Senator Jerry ONeil represented by Orly Taitz
Montana (See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
SFC E7 Robert Lee Perry represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Colonel Harry Riley represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Markham Robinson represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Gary G Kreep
(See above for address)
ATTORNEY TO BE NOTICED
Plaintiff
Sergeant Jeffrey Wayne Rosner represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
MSGT Jeffrey Schwilk represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
Case:
Case:09-3403
8:09-cv-00082-DOC-AN
Document: 00319937505
As of: 12/03/2009
Page: 612:17
Date
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5 of 17
ATTORNEY TO BE NOTICED
Plaintiff
Captain David Smithey represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Lieutenant Commander John Bruce represented by Orly Taitz
Steidel (See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Commander Douglas Earl represented by Orly Taitz
Stoeppelwerth (See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Thomas J Taylor represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Representative Eric Swafford represented by Orly Taitz
Tennessee (See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Captain Neil B Turner represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Richard E Venable represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
LCDR Jeff Graham Winthrope represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Lieutenant Colonel Mark Wriggle represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
V.
Defendant
Case:
Case:09-3403
8:09-cv-00082-DOC-AN
Document: 00319937505
As of: 12/03/2009
Page: 712:17
Date
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Barack Hussein Obama represented by David A DeJute
SAUSA − Office of US Attorney
300 North Los Angeles Street Room 7516
Los Angeles , CA 90012
213−894−2574
Fax: 213−894−7819
Email: USACAC.Civil@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Roger E West
AUSA − Office of US Attorney
Civil Division − Federal Building
300 North Los Angeles Street Suite 7516
Los Angeles , CA 90012
213−894−2461
Fax: 213−894−7819
Email: USACAC.Civil@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Defendant
Condoleeza Rice
in her capacity as Secretary of State
TERMINATED: 07/15/2009
Defendant
Robert Mueller
in his capacity as Director of the Federal
Bureau of Investigation
TERMINATED: 07/15/2009
Defendant
Michael W Hager
in his capacity as Acting Director, Office
of Personnel Management
TERMINATED: 07/15/2009
Defendant
Michelle LR Obama represented by David A DeJute
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Roger E West
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Defendant
Hillary Rodham Clinton represented by David A DeJute
Secretary of State (See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Roger E West
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Defendant
Case:
Case:09-3403
8:09-cv-00082-DOC-AN
Document: 00319937505
As of: 12/03/2009
Page: 812:17
Date
PMFiled:
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Robert M Gates represented by David A DeJute
Secretary of Defense (See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Roger E West
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Defendant
Joseph R Biden represented by David A DeJute
Vice−President and President of the (See above for address)
Senate LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Roger E West
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
conflicts or differs from that which counsel entered on Court's e−docket; therefore,
the following document(s) shall be stricken from the record and shall not be
considered by the Court: MOTION to Expedite authentication MOTION for Issuance
of Letters Rogatory for authenticity of Kenyan birth certificate 34 . (rla) (Entered:
08/06/2009)
08/07/2009 36 NOTICE of Change of Attorney Information for attorney Roger E West counsel for
Defendants Michelle LR Obama, Hillary Rodham Clinton, Robert M Gates, Joseph R
Biden, Barack Hussein Obama, Interested Party UNITED STATES OF AMERICA.
Changing e−mail to roger.west4@usdoj.gov. Adding Roger E. West as attorney as
counsel of record for Defendants for the reason indicated in the G−06 Notice. Filed by
Defendants Barack H. Obama, et al. (West, Roger) (Entered: 08/07/2009)
08/18/2009 37 DECLINED STATEMENT OF CONSENT TO PROCEED before the assigned
Magistrate Judge filed by plaintiff Alan Keyes PhD. (Taitz, Orly) (Entered:
08/18/2009)
08/19/2009 38 NOTICE NOTICE OF MANUAL FILING filed by plaintiff Markham Robinson,
Wiley S Drake. (Kreep, Gary) (Entered: 08/19/2009)
08/19/2009 39 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents. The
following error(s) was found: Incorrect event selected, correct event is Review and
Incorrect category selected, correct category is Motion RE: Consent to Proceed
(CV−11C) DECLINED before US Magistrate Judge MJ Pilot 37 . In response to this
notice the court may order (1) an amended or correct document to be filed (2) the
document stricken or (3) take other action as the court deems appropriate. (rrp)
(Entered: 08/19/2009)
08/19/2009 40 NOTICE OF FAILURE BY PLAINTIFFS TO PROPERLY EFFECT SERVICE OF
PROCESS; DECLARATIONS OF DAVID A. DeJUTE AND FLABIA DE LA
ROSA filed by Defendants Michelle LR Obama, Hillary Rodham Clinton, Robert M
Gates, Joseph R Biden, Barack Hussein Obama, UNITED STATES OF AMERICA.
(Attachments: # 1 Exhibit 1−5)(West, Roger) (Entered: 08/19/2009)
08/20/2009 41 opposition to magistrate filed by Plaintiffs Clint Grimes, Julliett Ireland, D Andrew
Johnson, Israel D Jones, Timothy Jones, David Fullmer LaRoque, Gail Lightfoot, Lita
M Lott, David Grant Mosby, Steven Kay Neuenschwander, Frank Niceley, Jerry
ONeil, Robert Lee Perry, Harry Riley, Markham Robinson, Jeffrey Wayne Rosner,
Jeffrey Schwilk, David Smithey, John Bruce Steidel, Douglas Earl Stoeppelwerth,
Thomas J Taylor, Eric Swafford, Neil B Turner, Richard E Venable, Jeff Graham
Winthrope, Mark Wriggle, Alan Keyes PhD, Wiley S Drake, Pamela Barnett, Richard
Norton Bauerbach, Robin D Biron, John D Blair, David L Bosley, Loretta G Bosley,
Harry G Butler, Glenn Casada, Jennifer Leah Clark, Timothy Comerford, Charles
Crusemire, Cynthia Davis, Thomas S Davidson, Matthew Michael Edwards, Jason
Freese, Kurt C Fuqua (Taitz, Orly) (Entered: 08/20/2009)
08/20/2009 42 REFERRAL OF MOTION to Disqualify Magistrate Judge Arthur Nakazatohas been
filed. Pursuant to GO 08.05 and Local Rule 72−5 MOTION for Review 37 is referred
to Judge David O. Carter for determination. (jal) (Entered: 08/20/2009)
08/20/2009 43 Amendment to MOTION to Expedite authentication MOTION for Issuance of Letters
Rogatory for authenticity of Kenyan birth certificate 34 filed by Plaintiff Alan Keyes
PhD. (Taitz, Orly) (Entered: 08/20/2009)
08/21/2009 44 MINUTES OF IN CHAMBERS ORDER by Judge David O. Carter: ORDER
SETTING SEPTEMBER 8, 2009 HEARING ONMOTIONS: (See document for
details.) In summary, the Court sets for hearing at 8:00 a.m. on September 8, 2009, (1)
the Discovery Motion, (2) the Service Notice, and (3) the Ex Parte Application. All
parties are ordered to be present. The Clerk shall serve this minute order on all parties
to the action. (rla) (Entered: 08/21/2009)
08/24/2009 45 EX PARTE APPLICATION to Vacate Plaintiffs' Voluntary Dismsisal filed by
plaintiff Markham Robinson, Wiley S Drake. (Attachments: # 1 Supplement Memo of
Points and Authorities, # 2 Declaration Declaration of Markham Robinson, # 3
Declaration Declaration of Wiley S. Drake, # 4 Declaration Declaration of Elliot
Wilson, # 5 Exhibit Exhibit 1 − Wiley Substitution, # 6 Exhibit Exhibit 2 − Markham
Substitution, # 7 Exhibit Letter from Dr. Taitz, # 8 Exhibit Notice of Dismissal, # 9
Case:
Case:09-3403
8:09-cv-00082-DOC-AN
Document: 00319937505
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Roger West, # 2 Exhibit 2nd response from the US attorney Roger West)(Taitz, Orly)
(Entered: 10/07/2009)
10/08/2009 83 MINUTES (IN CHAMBERS): ORDER by Judge David O. Carter: DENYING EX
PARTE MOTION FOR RELIEF FROM STAY OF DISCOVERY 82 : The Ex Parte
Motion is hereby DENIED. The Clerk shall serve this minute order on all parties to
the action. (rla) (Entered: 10/08/2009)
10/11/2009 84 Request for judicial notice filed by Plaintiffs Clint Grimes, Julliett Ireland, D Andrew
Johnson, Israel D Jones, Timothy Jones, David Fullmer LaRoque, Gail Lightfoot, Lita
M Lott, David Grant Mosby, Steven Kay Neuenschwander, Frank Niceley, Jerry
ONeil, Robert Lee Perry, Harry Riley, Jeffrey Wayne Rosner, Jeffrey Schwilk, David
Smithey, John Bruce Steidel, Douglas Earl Stoeppelwerth, Eric Swafford, Neil B
Turner, Richard E Venable, Jeff Graham Winthrope, Mark Wriggle, Alan Keyes PhD,
Pamela Barnett, Richard Norton Bauerbach, Robin D Biron, John D Blair, David L
Bosley, Loretta G Bosley, Harry G Butler, Glenn Casada, Jennifer Leah Clark,
Timothy Comerford, Charles Crusemire, Cynthia Davis, Thomas S Davidson,
Matthew Michael Edwards, Jason Freese, Kurt C Fuqua (Attachments: # 1 Affidavit
Expanded affidavit by Susan Daniels)(Taitz, Orly) (Entered: 10/11/2009)
10/14/2009 85 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents. The
following error(s) was found: Incorrect event selected RE: Miscellaneous Document
84 . In response to this notice the court may order (1) an amended or correct document
to be filed (2) the document stricken or (3) take other action as the court deems
appropriate. (twdb) (Entered: 10/14/2009)
10/16/2009 86 REQUEST FOR JUDICIAL NOTICE filed by plaintiffs Clint Grimes, Julliett Ireland,
D Andrew Johnson, Israel D Jones, Timothy Jones, David Fullmer LaRoque, Gail
Lightfoot, Lita M Lott, David Grant Mosby, Steven Kay Neuenschwander, Frank
Niceley, Jerry ONeil, Robert Lee Perry, Harry Riley, Jeffrey Wayne Rosner, Jeffrey
Schwilk, David Smithey, John Bruce Steidel, Douglas Earl Stoeppelwerth, Eric
Swafford, Neil B Turner, Richard E Venable, Jeff Graham Winthrope, Mark Wriggle,
Alan Keyes PhD, Pamela Barnett, Richard Norton Bauerbach, Robin D Biron, John D
Blair, David L Bosley, Loretta G Bosley, Harry G Butler, Glenn Casada, Jennifer
Leah Clark, Timothy Comerford, Charles Crusemire, Cynthia Davis, Thomas S
Davidson, Matthew Michael Edwards, Jason Freese, Kurt C Fuqua. (Attachments: # 1
Affidavit Expanded affidavit by Susan Daniels− use of ss number of the deceased by
Barack Obama)(Taitz, Orly) (Entered: 10/16/2009)
10/22/2009 87 REQUEST FOR JUDICIAL NOTICE filed by Defendants Michelle LR Obama,
Hillary Rodham Clinton, Robert M Gates, Joseph R Biden, Barack Hussein Obama,
United States of America. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(West, Roger)
(Entered: 10/22/2009)
10/25/2009 88 REQUEST FOR JUDICIAL NOTICE filed by plaintiffs Clint Grimes, Julliett Ireland,
D Andrew Johnson, Israel D Jones, Timothy Jones, David Fullmer LaRoque, Gail
Lightfoot, Lita M Lott, David Grant Mosby, Steven Kay Neuenschwander, Frank
Niceley, Jerry ONeil, Robert Lee Perry, Harry Riley, Jeffrey Wayne Rosner, Jeffrey
Schwilk, David Smithey, John Bruce Steidel, Douglas Earl Stoeppelwerth, Eric
Swafford, Neil B Turner, Richard E Venable, Jeff Graham Winthrope, Mark Wriggle,
Alan Keyes PhD, Pamela Barnett, Richard Norton Bauerbach, Robin D Biron, John D
Blair, David L Bosley, Loretta G Bosley, Harry G Butler, Glenn Casada, Jennifer
Leah Clark, Timothy Comerford, Charles Crusemire, Cynthia Davis, Thomas S
Davidson, Matthew Michael Edwards, Jason Freese, Kurt C Fuqua. (Attachments: # 1
Exhibit 2004 AP article "Kenyan born Obama...")(Taitz, Orly) (Entered: 10/25/2009)
10/29/2009 89 ORDER by Judge David O. Carter: REGARDING DEFENDANTS' MOTION TO
DISMISS 56 : (See document for details.) Defendants' Motion to Dismiss is
GRANTED. IT IS SO ORDERED. (MD JS−6. Case Terminated) (rla) (Entered:
10/29/2009)
11/09/2009 90 NOTICE OF MOTION AND MOTION for Reconsideration re Order on Motion to
Dismiss Case 89 filed by plaintiffs Clint Grimes, Julliett Ireland, D Andrew Johnson,
Israel D Jones, Timothy Jones, David Fullmer LaRoque, Gail Lightfoot, Lita M Lott,
David Grant Mosby, Steven Kay Neuenschwander, Frank Niceley, Jerry ONeil,
Robert Lee Perry, Harry Riley, Jeffrey Wayne Rosner, Jeffrey Schwilk, David
Smithey, John Bruce Steidel, Douglas Earl Stoeppelwerth, Eric Swafford, Neil B
Case:
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Document: 00319937505
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Turner, Richard E Venable, Jeff Graham Winthrope, Mark Wriggle, Pamela Barnett,
Richard Norton Bauerbach, Robin D Biron, David L Bosley, Loretta G Bosley, Harry
G Butler, Glenn Casada, Jennifer Leah Clark, Timothy Comerford, Charles
Crusemire, Cynthia Davis, Thomas S Davidson, Matthew Michael Edwards, Jason
Freese, Kurt C Fuqua. Motion set for hearing on 11/20/2009 at 09:00 AM before
Judge David O. Carter. (Attachments: # 1 Exhibit Declaration of Orly Taitz, # 2
Exhibit Coroners report of Donald Young, Affidavit of Larry Sinclair)(Taitz, Orly)
(Entered: 11/09/2009)
11/13/2009 91 REQUEST FOR JUDICIAL NOTICE re MOTION for Reconsideration re Order on
Motion to Dismiss Case 89 MOTION for Reconsideration re Order on Motion to
Dismiss Case 89 MOTION for Reconsideration re Order on Motion to Dismiss Case
89 MOTION for Reconsideration re Order on Motion to Dismiss Case 89 MOTION
for Reconsideration re Order on Motion to Dismiss Case 89 90 filed by plaintiffs Clint
Grimes, Julliett Ireland, D Andrew Johnson, Israel D Jones, Timothy Jones, David
Fullmer LaRoque, Gail Lightfoot, Lita M Lott, David Grant Mosby, Steven Kay
Neuenschwander, Frank Niceley, Jerry ONeil, Robert Lee Perry, Harry Riley, Jeffrey
Wayne Rosner, Jeffrey Schwilk, David Smithey, John Bruce Steidel, Douglas Earl
Stoeppelwerth, Eric Swafford, Neil B Turner, Richard E Venable, Jeff Graham
Winthrope, Mark Wriggle, Alan Keyes PhD, Pamela Barnett, Richard Norton
Bauerbach, Robin D Biron, John D Blair, David L Bosley, Loretta G Bosley, Harry G
Butler, Glenn Casada, Jennifer Leah Clark, Timothy Comerford, Charles Crusemire,
Cynthia Davis, Thomas S Davidson, Matthew Michael Edwards, Jason Freese, Kurt C
Fuqua. (Attachments: # 1 Appendix Third circuit court of appeals decision)(Taitz,
Orly) (Entered: 11/13/2009)
11/13/2009 92 OPPOSITION re: MOTION for Reconsideration re Order on Motion to Dismiss Case
89 MOTION for Reconsideration re Order on Motion to Dismiss Case 89 MOTION
for Reconsideration re Order on Motion to Dismiss Case 89 MOTION for
Reconsideration re Order on Motion to Dismiss Case 89 MOTION for
Reconsideration re Order on Motion to Dismiss Case 89 90 filed by Defendants
Michelle LR Obama, Hillary Rodham Clinton, Robert M Gates, Joseph R Biden,
Barack Hussein Obama, Interested Party United States of America. (West, Roger)
(Entered: 11/13/2009)
11/16/2009 93 NOTICE OF MOTION AND MOTION for Reconsideration re Order on Motion to
Dismiss Case 89 filed by plaintiffs Clint Grimes, Julliett Ireland, D Andrew Johnson,
Israel D Jones, Timothy Jones, David Fullmer LaRoque, Gail Lightfoot, Lita M Lott,
David Grant Mosby, Steven Kay Neuenschwander, Frank Niceley, Jerry ONeil,
Robert Lee Perry, Harry Riley, Jeffrey Wayne Rosner, Jeffrey Schwilk, David
Smithey, John Bruce Steidel, Douglas Earl Stoeppelwerth, Eric Swafford, Neil B
Turner, Richard E Venable, Jeff Graham Winthrope, Mark Wriggle, Alan Keyes PhD,
Pamela Barnett, Richard Norton Bauerbach, Robin D Biron, John D Blair, David L
Bosley, Loretta G Bosley, Harry G Butler, Glenn Casada, Jennifer Leah Clark,
Timothy Comerford, Charles Crusemire, Cynthia Davis, Thomas S Davidson,
Matthew Michael Edwards, Jason Freese, Kurt C Fuqua. Motion set for hearing on
12/7/2009 at 10:00 AM before Judge David O. Carter. (Attachments: # 1 Declaration
Declaration of Orly Taitz re basis for the motion for reconsideration, # 2 Declaration
Declaration of Orly Taitz, # 3 Declaration Declaration of Orly Taitz re attempt for
meet and confer, # 4 Declaration Coroners report and declaration of Donald
Young)(Taitz, Orly) (Entered: 11/16/2009)
11/16/2009 94 NOTICE OF APPEAL to the 9th CCA filed by Plaintiffs Markham Robinson, Wiley
S Drake. Appeal of Order on Motion to Dismiss Case 89 . (Filing fee $455, receipt
number 09730000000006158038.) (Attachments: # 1 Supplement Representation
Statement and Service List, # 2 Supplement 9th Circuit Court of Appeals Docking
Statement, # 3 Exhibit District Court Order Being Appealed)(Kreep, Gary) (Entered:
11/16/2009)
11/17/2009 95 NOTIFICATION by Circuit Court of Appellate Docket Number 09−56827, 9th CCA
regarding Notice of Appeal to 9th Circuit Court of Appeals, 94 as to Plaintiff
Markham Robinson, Wiley S Drake. (dmap) (Entered: 11/17/2009)
11/17/2009 96 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents. The
following error(s) was found: Incorrect event selected RE: MOTION for
Reconsideration 89 93 . In response to this notice the court may order (1) an amended
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or correct document to be filed (2) the document stricken or (3) take other action as
the court deems appropriate. (twdb) (Entered: 11/18/2009)
11/18/2009 97 Amendment to MOTION for Reconsideration re Order on Motion to Dismiss Case 89
MOTION for Reconsideration re Order on Motion to Dismiss Case 89 MOTION for
Reconsideration re Order on Motion to Dismiss Case 89 MOTION for
Reconsideration re Order on Motion to Dismiss Case 89 MOTION for
Reconsideration re Order on Motion to Dismiss Case 89 93 filed by Plaintiffs Clint
Grimes, Julliett Ireland, D Andrew Johnson, Israel D Jones, Timothy Jones, David
Fullmer LaRoque, Gail Lightfoot, Lita M Lott, David Grant Mosby, Steven Kay
Neuenschwander, Frank Niceley, Jerry ONeil, Robert Lee Perry, Harry Riley, Jeffrey
Wayne Rosner, David Smithey, John Bruce Steidel, Douglas Earl Stoeppelwerth, Eric
Swafford, Neil B Turner, Richard E Venable, Jeff Graham Winthrope, Mark Wriggle,
Alan Keyes PhD, Pamela Barnett, Richard Norton Bauerbach, Robin D Biron, John D
Blair, David L Bosley, Loretta G Bosley, Harry G Butler, Glenn Casada, Jennifer
Leah Clark, Timothy Comerford, Charles Crusemire, Cynthia Davis, Thomas S
Davidson, Matthew Michael Edwards, Jason Freese, Kurt C Fuqua. (Attachments: # 1
Declaration Declaration of Orly Taitz re basis for reconsideration, # 2 Declaration
Declaration of Orly Taitz re meet and confer, # 3 Declaration Declaration re Larry
Sinclair, his affidavit and book, # 4 Affidavit Coroners death cert. Donald Young;
Affidavit of Larry Sinclair)(Taitz, Orly) (Entered: 11/18/2009)
11/19/2009 98 OPPOSITION TO AMENDED MOTION FOR RECONSIDERATION re: MOTION
for Reconsideration re Order on Motion to Dismiss Case 89 MOTION for
Reconsideration re Order on Motion to Dismiss Case 89 MOTION for
Reconsideration re Order on Motion to Dismiss Case 89 MOTION for
Reconsideration re Order on Motion to Dismiss Case 89 MOTION for
Reconsideration re Order on Motion to Dismiss Case 89 93 filed by Defendants
Michelle LR Obama, Hillary Rodham Clinton, Robert M Gates, Joseph R Biden,
Barack Hussein Obama, Interested Party United States of America. (West, Roger)
(Entered: 11/19/2009)
11/30/2009 99 MINUTES (IN CHAMBERS): ORDER by Judge David O. Carter: taking under
advisement 90 Motion for Reconsideration. The Court finds matter appropriate for
decision without oral argument. Fed. R. Civ. P. 78; Local Rule 7−15. Accordingly, the
hearing set December 7, 2009 at 8:30 a.m. is removed from the calendar. Parties will
be served with the Courts ruling. (ade) (Entered: 11/30/2009)
12/03/2009 100 letter to judge Carter filed by Plaintiff Pamela Barnett (Attachments: # 1 Exhibit
Barack Obama background report)(Taitz, Orly) (Entered: 12/03/2009)
Case: 09-3403 Document: 00319937506 Page: 1 Date Filed: 12/08/2009
EXHIBIT “3 ” 7
Case: 09-3403 Document: 00319937506 Page: 2 Date Filed: 12/08/2009
http://www.scribd.com/doc/23612301/KEYES-BARNETT-v-OBAMA-100-letter-to-judge-Carter-filed-by-
Plaintiff-Pamela-Barnett-gov-uscourts-cacd-435591-100-0?autodown=pdf
Note, the above copy of Taitz 12/2/09 letter above is missing the PACER header assigned when a
document is filed on PACER. This can only mean that Defendant Orly Taitz, et al posted this letter
on the world wide web through SCRIBD prior to her filing it with the U.S. District Court, Central District
of California, Southern Division through PACER to ensure it spread like wildfire, which it did, across
the world wide web to ensure further damages to the Plaintiffs herein.
Case: 09-3403 Document: 00319937507 Page: 1 Date Filed: 12/08/2009
EXHIBIT “4 ”
Case: 09-3403 Document: 00319937507 Page: 2 Date Filed: 12/08/2009
LAW OFFICES OF
PHILIP J. BERG
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
PHILIP J. BERG
CATHERINE R. BARONE
BARBARA MAY
(610) 825-3134
Re: Liberi, et al. v. Orly Taitz, et al, Case No. 09-cv-01898 ECR
Leave to file Plaintiffs’ Emergency Motion to Transfer Venue of the within Case to the
United States District Court, Central District of California, Southern Division________
Pursuant to this Court’s Order of June 25, 2009 Plaintiffs’ are seeking Leave of this Court to
file the attached Emergency Motion to Transfer Venue of the within action to the United States District
Court, Central District of California, Southern Division located in South Orange County at 411 West
Fourth Street, Santa Ana, CA 92701-4516 with telephone number (714) 338-4750.
Plaintiffs’ bring to this Courts attention that all Defendants have prior hereto requested this
Court to transfer this case to California or Texas, although Plaintiffs’ are unaware of the Defendants
position to Plaintiffs’ request herein.
Thank you.
Respectfully,
Philip J. Berg
PJB:jb
Enclosures
Neil Sankey
The Sankey Firm, Inc. a/k/a The Sankey Firm
Sankey Investigations, Inc.
2470 Stearns Street #162
Simi Valley, CA 93063
Phone: (805) 520-3151and (818) 366-0919
Cell Phone: (818) 212-7615
FAX: (805) 520-5804 and (818) 366-1491
Email: nsankey@thesankeyfirm.com
Ed Hale
Caren Hale
Plains Radio
KPRN
Bar H Farms
1401 Bowie Street
Wellington, Texas 79095
Phone: (806) 447-0010 and (806) 447-0270
Email: plains.radio@yahoo.com and
Email: barhfarms@gmail.com and ed@barhfarms.net
ORDER
Emergency Motion to Transfer Venue; any responses thereto; and for good cause shown,
it is hereby
Venue to the United States District Court, Central District of California, Southern
IT IS FURTHER ORDERED that the Clerk of the Court shall transfer the
within Case to the United States District Court, Central District of California, Southern
Division located in South Orange County at 411 West Fourth Street, Santa Ana, CA
IT IS SO ORDERED:
NOW COMES the Plaintiffs’, Lisa Liberi [hereinafter “Liberi”], Philip J. Berg,
Esquire [hereinafter “Berg”], the Law Offices of Philip J. Berg, Evelyn Adams a/k/a
Global by and through their undersigned counsel and respectfully requests this Honorable
Court to grant their Emergency Motion to Transfer Venue of the within case from this
Court, the United States District Court for the Eastern District of Pennsylvania to the
United States District Court, Central District of California, Southern Division located in
South Orange County at 411 West Fourth Street, Santa Ana, CA 92701-4516 with
• Defendants Orly Taitz, Esquire a/k/a Orly Taitz a/k/a Dr. Orly Taitz
a/k/a Law Offices of Orly Taitz a/k/a Orly Taitz, Inc [hereinafter
“Taitz”], Defend our Freedoms Foundations, Inc. [hereinafter
“DOFF”], Neil Sankey [hereinafter “Sankey”], Sankey Investigations,
Inc. and the Sankey Firm, Inc. a/k/a The Sankey Firm own and
operate their businesses and own property within the United States
District Court, Central District of California, Southern Division;
• The Statute relied on by the Plaintiffs’ and the Statute the Plaintiffs’
are asking to be utilized and upheld is a California Statute, California
Civil Code 1798, et sequitur;
• All Defendants have asked this Court to transfer the within Case to
California and the Case must be tried together as there was a common
scheme in the actions of the Defendants which have severely harmed
and damaged the Plaintiffs.
their Motion and Transfer Venue of the within Case to the United States District Court,
Central District of California, Southern Division located in South Orange County at 411
West Fourth Street, Santa Ana, CA 92701-4516 with telephone number (714) 338-4750.
Respectfully submitted,
I. STATEMENT OF FACTS:
Investigations and the Sankey Firm have invaded the privacy of Liberi, Ostella, and
Adams by publicizing Liberi’s full Social Security number, date of birth, mother’s
maiden name, place of birth and other personal information of Liberi’s, including
information about Liberi’s medical conditions, child, husband, etc. and has targeted all
the work Liberi has performed for Berg in Pennsylvania. Taitz through DOFF has also
publicized Ostella’s name, address, maiden name, where her family resides, parents
names and where they reside, etc. and Taitz has also published Adams name, address,
husband’s information, etc. Taitz filed false law enforcement reports with the Federal
Bureau of Investigations (FBI); police departments; called for people where the
Plaintiffs’ reside; falsely accused Liberi and Ostella of “hacking” her paypal account and
website or forum; falsely accused Adams and Berg of diverting funds and making money
off of her company name; falsely accused Liberi of “murdering” her sister; falsely
accused Liberi’s husband of diverting funds from Berg; falsely accused Liberi of being
convicted of crimes including but not limited to identity theft, manipulation of police
reports, manipulation of credit reports, real estate crimes, etc., which has placed the
Plaintiffs’ in the false light before the publics eye; slandering the Plaintiffs’; harassed the
Plaintiffs; invaded the Plaintiffs’ seclusion; publicly disclosed private facts about the
Plaintiffs’; destroyed the Plaintiffs’ reputation; and interfered with the Plaintiffs’ business
associates, etc.
Shortly thereafter, the Hales had Taitz through DOFF and Sankey through Sankey
Investigations and the Sankey Firm on their radio show. Taitz continued her malicious
lies about Plaintiffs’ and Sankey continued his distribution of Liberi’s private
confidential information as well as Adams and Ostella’s. In fact, Sankey and Hale
announced on the radio show on May 28, 2009 that Liberi had recently taken out a loan,
which she had. The only way they would have known this is if they had illegally
accessed Liberi’s credit report or applied for and taken out credit in Liberi’s name.
Sankey, Taitz and Hale then altered and forged Ostella’s emails and published them on
the internet. Edgar Hale admitted in an email to Liberi that Taitz used him to assault
Liberi to get to Berg. The Hales also have viciously attacked, slandered, harassed and
threatened Adams. The Hales have admitted in writing that is on file with this Court,
Taitz, DOFF and the other Defendants used them to “assault” Liberi to take down Berg.
Belcher joined forces with Taitz in or about January 2009 in their attempts to
destroy Berg and Liberi. Belcher sent out mass emails with all kinds of false statements
about Liberi and Berg. Belcher filed false reports with the Social Security
Administration, manufactured emails and “chat logs” which she had filed with this Court;
As a result, Plaintiffs’ filed suit on May 4, 2009 of which all Defendants were
served. The Defendants’ Answers to the Plaintiffs’ Complaint were due May 26, 2009.
Taitz and DOFF failed to timely Answer Plaintiffs’ Complaint and therefore, default was
entered against them, and they waived their rights to raise any type of affirmative
defenses. Despite this, Taitz and DOFF untimely filed a one sentence denial as their
Since the time Plaintiffs’ filed suit, the Defendants actions and behaviors have
continued. Taitz, DOFF, Sankey, Sankey Investigations, Inc, and the Sankey Firm, Inc.
a/k/a the Sankey Firm are located in California. The majority of their Assets are located
in California. In addition, Taitz’s owns two [2] Dental Practices in the jurisdiction of the
United States District Court, Central District of California, Southern Division and she and
her husband own a Software Engineering company with their headquarters located in the
jurisdiction of the United States District Court, Central District of California, Southern
Division with offices over seas, in New Jersey and Santa Fe, New Mexico.
Southern District of Florida, Taitz was having a “love affair” with her law Clerk,
disbarred Attorney Charles Lincoln. Mr. Lincoln has filed his Affidavits claiming Yosef
Taitz has demanded that Orly Taitz sign all her rights to the Assets over to him (Yosef
Taitz), see EXHIBITS “A” and “B”. California is a community property state. Any
judgment obtained against the Defendants is also collectible against the Defendants
spouse and their assets, even if not in the other party’s name. Also in California, as well
as many other states today, it is illegal to transfer ownership of property or assets when
the party knows there is pending litigation against them. See the Uniform Fraudulent
Because there has been a threat of Taitz signing away her rights to the family
and based on the award of statutory penalties pursuant to California Civil Code 1798, et
sequitur, Plaintiff Liberi’s award pursuant to statute alone against Taitz and DOFF is in
excess of Eight Hundred and Seventy Million [$870,000,000.00] Dollars for just one
count. Thus, Plaintiffs’ are relying on the assets owned by Taitz, DOFF and her spouse,
Yosef Taitz, in order to collect against any judgment granted by the Court. For these
reasons, it may be imperative for Plaintiffs’ to move the United States District Court,
Central District of California, Southern Division for an Ex Parte Order freezing all of
Sankey, Sankey Investigations, Inc., and the Sankey Firm, Inc. a/k/a the Sankey
Firm are licensed in California, conduct business in and are located in Southern
California. In addition, Plaintiff Liberi has been speaking with and learned the California
licensing bureau of Private Investigators, the actions of Sankey through his corporations
are criminal in nature and therefore, Liberi was instructed to report Sankey’s illegal
actions to the County District Attorney where Sankey and his Corporations are located
Pennsylvania and the United States District Court, Central District of California,
Southern Division, located at 411 West Fourth Street, Santa Ana, CA 92701-4516 with
Honorable Court to Grant their Emergency Motion and Transfer the within action to the
United States District Court, Central District of California, Southern Division located
within South Orange County at 411 West Fourth Street, Santa Ana, CA 92701-4516 with
engage in a two-part test: (1) whether action might have been brought in proposed
transferee forum; and (2) whether transfer promotes convenience and justice. Excelsior
In a diversity action like this one, venue is proper "only in (1) a judicial district
where any Defendant resides, if all defendants reside in the same State, (2) a judicial
district in which a substantial part of the events or omissions giving rise to the claim
occurred, or a substantial part of property that is the subject of the action is situated, or
(3) a judicial district in which any Defendant is subject to personal jurisdiction at the time
the action is commenced, if there is no district in which the action may otherwise be
It is in the public and private interests that the Federal Laws be upheld pertaining
to venue and transfer of cases within the Federal Court systems. 28 U.S.C. §1404(a) only
provides for the transfer of a case where both the original and the requested venue are
convenience of the parties and presuppose that the Court has jurisdiction and that the case
has been brought in the correct forum. Lafferty v. Gito St. Riel, 495 F.3d 72, 77 (3d Cir.
Pa. 2007) citing Jumara v. State Farm Ins. Co., 55 F.3d 873, 878 (3d Cir. 1995).
circumstances for change of venue, but rather that all relevant things considered, the case
would be better off transferred to another district. Dominy v. CSX Transp., Inc., 2006
U.S. Dist. LEXIS 9422 (E.D. Pa. Mar. 9, 2006), supra., citing In re United States, 273
In determining whether to transfer a case, the court must first determine whether
the action "might have been brought" in the proposed transferee district. Banket v. GC
Am., Inc., 2005 U.S. Dist. LEXIS 23550 at *10 (E.D. Pa. Oct. 11, 2005), citing Van
Dusen, 376 U.S. at 616, 84 S. Ct. at 809. Assuming that this requirement has been
satisfied, which it has been herein, the court must then assess a number of private and
parties and witnesses and the interests of justice). Jumara v. State Farm Insurance
Company, 55 F.3d 873, 879 (3d Cir. 1995). Specifically, the private interests have
included: (1) the plaintiff's forum preference as manifested in the original choice; (2) the
defendant's choice of forum; (3) where the claim arose; (4) the convenience of the parties
as indicated by their relative physical and financial conditions; (5) the convenience of the
witnesses--but only to the extent that the witnesses may actually be unavailable for trial
in one of the fora; and (6) the location of books and records. In re Amendt, 169 Fed.
Appx. 93 at *8 (3d Cir. 2006), citing Jumara, at 879-80. The public interests have
included: (1) the enforceability of the judgment; (2) practical considerations that could
expedite or simplify trial; (3) the relative administrative difficulty in the two fora
resulting from court congestion; (4) the local interest in deciding local controversies at
home; (5) the public policies of the fora; and (6) in a diversity case, the familiarity of the
two courts with state law. Id. Rogal v. Skilstaf, Inc., 446 F. Supp. 2d 334, 336 (E.D. Pa.
2006).
It would be far easier for the United States District Court, Central District of
California; Southern Division to enforce any judgment’s obtained, as the bulk of the
Defendants assets are located in that Court’s jurisdiction. This particular Court that the
Plaintiffs’ are seeking the case to be transferred to is readily familiar with their own State
statutes, California Civil Code 1798, et sequitur, which the Plaintiffs’ rely upon. It is in
the public interest to see that California upholds its statutes when wrongs have been
committed; and the United States District Court, Central District of California, Southern
Honorable Court to Grant their Emergency Motion and Transfer the within action to the
United States District Court, Central District of California, Southern Division located
within South Orange County at 411 West Fourth Street, Santa Ana, CA 92701-4516 with
appropriately made when the Court can determine which issues will go to trial, Miller v.
Hygrade Food Prods. Corp., 202 F.R.D. 142, 145 (E.D. Pa. 2001). To address this issue
now is simply premature because this action has not proceeded beyond the pleading
stage, and the Court has yet to sort out the intricacies of the relationships among the
Defendants’, United States v. Private Sanitation Indus. Ass’n of Nassau/Suffolk, Inc., 793
F. Supp. 1114, 1154 (E.D. N.Y. 1992). Indeed, although Plaintiffs strongly disagree, this
case could possibly develop so that Plaintiffs cannot prove that Defendants acted in a
common way; however, because the record is not fully developed, it is premature to
foreclose Plaintiffs from pursuing that opportunity. Foreman Indus., Inc. v. Gen. Motors
The purpose of Rule 20(a) is to "promote trial convenience and expedite the final
determination of disputes, thereby preventing multiple law suits." 7 Charles Alan Wright,
et al., Federal Practice and Procedure § 1652 at 395 (3d ed. 2001); see also Formosa
Plastics Corp., U.S.A. v. ACE Am. Ins. Co., 2009 U.S. Dist. LEXIS 71712 (D.N.J. Aug.
14, 2009) citing Mosley v. General Motors Corp., 497 F.2d 1330, 1332 (8th Cir. 1974)
(all 'logically related' events entitling a person to institute a legal action against another
particular factual situation meets the same transaction or occurrence test. See 7 Charles
Alan Wright, et al., Federal Practice and Procedure § 1653 at 409 (3d ed. 2001); Blood v.
Fed. Bureau of Prisons, 2009 U.S. Dist. LEXIS 21529 (M.D. Pa. Mar. 17, 2009) citing
Mosley, 497 F.2d at 1333. The test mirrors the one applied under Federal Rule of Civil
immediateness of their connection as upon their logical relationship.'" Mosley, 497 F.2d
at 1333 (emphasis added) (quoting Moore v. New York Cotton Exchange, 270 U.S. 593,
610, 46 S. Ct. 367, 371, 70 L. Ed. 750 (1926)); see also In re University Med. Ctr., 973
F.2d 1065, 1086 (3d Cir. 1992) (recognizing logical relationship test under Rule 13(a)).
Identifying each event is not demanded. See Mosley, 497 F.2d at 1333; King v. Pepsi
Here, the Defendants’ all joined forces with Taitz to destroy Berg and destroy his
paralegal, Liberi and get rid of her and any other parties associated with Berg and Liberi.
All of the Defendants’ went after the Plaintiffs, due to their association with Berg and his
Furthermore, none of the Defendants have raised the issue, cited or established
any legally cognizable prejudice as a result of hearing together all of the Plaintiffs’ claims
against all of them responsibly for Plaintiffs’ injuries; however, there would be great
prejudice to the Plaintiffs. First, severance would be a tactical boon to all Defendants. If
the case is separated and tried in different locations, the Defendants’ would then point to
the other Defendants’ not named in those particular actions if these claims were not tried
together, leaving the jury wondering why a claim had not been brought against the other
Defendants. e.g., The case against Taitz and Sankey is separated and moved to California
while the case against the Hale Defendants is moved to Texas. First problem with this is
all the Plaintiffs’ would have to travel to three (3) different locations and Hale would
blame Taitz for the actions, which would cause the jury to wonder why the Plaintiff failed
to name Taitz. The permutations of this prejudice are boundless. The jury might give a
compromise verdict, in which case Plaintiffs would not get the full value of their
damages. Next, there are many parties who are willing to be witnesses against the
Defendants named herein. Severance of these claims would cause each of the witnesses
to have to be brought to Court three (3) or more times in different States to testify to a
pattern of facts and opinions, where experts are concerned, which are common to all
Defendants. Not to mention the fact, Plaintiffs’ witnesses would have to be deposed
three (3) times if the case is severed. This would triple all costs associated with
Plaintiffs’ witnesses.
Severance would cause inconvenience and prejudice to the parties, especially the
contest the Defense case, in light of the fact that this triplication would burden all the
These are important reasons to try the case as a single, coherent whole, and
Plaintiffs’ urge the Court not to undermine that. Severance is an extraordinary procedure
and cannot be justified unless it will substantially further the ends of judicial economy,
prevention of delay and prejudice, and otherwise serve the ends of justice. This standard
has not been met in this case and therefore, the case should not be severed.
Honorable Court to Grant their Emergency Motion and Transfer the within action to the
United States District Court, Central District of California, Southern Division located
within South Orange County at 411 West Fourth Street, Santa Ana, CA 92701-4516 with
IV. CONCLUSION:
For the reasons stated herein, Plaintiffs’ respectfully request this Honorable Court
to grant their Emergency Motion and Transfer the entire case to the United States District
Court, Central District of California, Southern Division located in South Orange County
at 411 West Fourth Street, Santa Ana, CA 92701-4516 with telephone number (714) 338-
4750.
. Respectfully submitted,
EXHIBIT “A”
Z:\Liberi Motion to Transfer Venue to South Orange County, CA 11 28 09 16
Case 9:09-cv-81255-WPD
Case: 09-3403 Document:
Document00319937507
20 Entered on
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FLSD20Docket
Date11/13/2009
Filed: 12/08/2009
Page 19 of 37
Case 9:09-cv-81255-WPD
Case: 09-3403 Document:
Document00319937507
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FLSD21Docket
Date11/13/2009
Filed: 12/08/2009
Page 20 of 37
Case 9:09-cv-81255-WPD
Case: 09-3403 Document:
Document00319937507
20 Entered on
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FLSD22Docket
Date11/13/2009
Filed: 12/08/2009
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Case 9:09-cv-81255-WPD
Case: 09-3403 Document:
Document00319937507
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FLSD23Docket
Date11/13/2009
Filed: 12/08/2009
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Case 9:09-cv-81255-WPD
Case: 09-3403 Document:
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FLSD24Docket
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Case: 09-3403 Document: 00319937507 Page: 25 Date Filed: 12/08/2009
EXHIBIT “B”
Z:\Liberi Motion to Transfer Venue to South Orange County, CA 11 28 09 17
Case 9:09-cv-81255-WPD
Case: 09-3403 Document:
Document
00319937507
22 Entered on
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FLSD26Docket
Date11/17/2009
Filed: 12/08/2009
Page 6 of 30
MARSHA G. RIVERNIDER, §
ROBERT H. RIVERNIDER, §
CHARLES EDWARD LINCOLN, III, §
Plaintiffs, §
§
v. § Case No. 09-91255-CIV
§ HON. W.P. DIMITROULEAS
U.S. BANK NATIONAL ASSOCIATION, §
AS TRUSTEE FOR THE C-BASS §
MORTGAGE LOAN ASSET-BACKED §
CERTIFICATES, SERIES 2006-CBS, §
And all JOHN & JANE DOES 1-50 § AFFIDAVIT REGARDING
Defendants. § ALLEGATIONS OF FRAUD
§
§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§
AFFIDAVIT AND DECLARATION OF CHARLES EDWARD LINCOLN, III
1. My name is Charles Edward Lincoln, III. I am over the age of 18, of sound mind,
and have never been convicted of any crime of moral turpitude within the meaning of
Beltran-Tirado v. INS, 213 F.3d 1179, 1183 (9th Cir. 2000) and Quintero-Salazar v.
Keisler, 506 F.3d 688 (9th Cir. 2007); I write this affidavit from personal knowledge.
2. I have a J.D. from the University of Chicago in addition to a Ph.D. from Harvard
University and am a former judicial law clerk to the Honorable Kenneth L. Ryskamp in
this United States District Court for the Southern District of Florida, having applied for
3. I was later disbarred due to a December 1999 indictment, which I can only call
politically motivated and unjust, although I take full responsibility for my own errors. I
also apologize to this United States District Court, and in particular to the Honorable
Kenneth L. Ryskamp, for the dishonor my misfortunes may have brought to this court, in
the past and at the present time, by my failures and indiscretions, especially in light of the
honor which Judge Ryskamp bestowed upon me by hiring me as his law clerk.
4. Dr. OrIy Taitz was aware of all details of my background, and in May 2009, hired
me to work with her as a consultant and law clerk on a series of cases relating to the
Article II Constitutional eligibility of the current President of the United States, Barack
5. I prepared all the documents, which Dr. Taitz signed in this case, as I have been
preparing almost all (approximately 95-98%) the documents she has signed in all of her
recent cases pending in Federal court in any and every state where she has appeared. I
never caused any papers to be filed, in this or any other case, which she had not approved
6. I was responsible for delivering all papers in this case to Robert H. Rivernider for
filing. I certainly never gave him any documents, which I knew or suspected to be
fraudulent in any way, shape or form.
7. I never knowingly submitted any false documents to this Court nor did I submit
any documents I had any imaginable reason to believe were false. I submitted every
document signed by Orly Taitz or any other person only in the belief that these were
legitimate documents.
longer a licensed attorney I have been involved in real estate management and mortgage
9. What has happened here is that, much to our mutual discomfort I am sure, Orly
Taitz and I had an intense but adulterous love affair, which continued until November 4,
2009. I can say nothing in our defense except that I fell in love with Dr. Taitz and she
repeated on dozens of occasions that she loved me, but could not leave her husband
because she did not want to lose "her children and her life."
10. I am not proud of these facts, but put together they constitute the simple if
unremarkably tawdry background against which Dr. Taitz' behavior and accusations
against me/all the Plaintiffs in this case must be judged and evaluated.
11. Dr. Taitz terminated our relationship in the aftermath of the October 12, 2009,
disclosures made by one Lucas Daniel Smith on the internet which in rather grotesquely
vulgar and sensationalistic manner revealed my love affair with Dr. Taitz to the world,
and not coincidentally, to arly's husband Yosef Taitz, whom arly has consistently
her children or guests, and who becomes violently angry if his wife is not at home by
12. I provided copies of my affidavit to both Dr. Taitz and her attorney Dr. Jonathan
13. Dr. Levy warned me that I could expect "strong and vengeful" action from Dr.
Taitz' when I spoke to him last on Thursday, November 12, 2009, although he did not
condone such acts, and specifically qualified that he had absolutely nothing to do with
Dr. Taitz' prior letter to this Court Noted "Received" at Docket Entry 1 in this case.
14. I have no other explanation for what Dr. Taitz is doing in this case, but I will give
15. Dr. Taitz' letters to the court and her Sunday November 15, 2009, communication
to me bye-mail (a true and correct copy of which is attached as Exhibit A), are the acts of
an extremely unhappy woman who got caught having an adulterous love affair by her
husband and the entire world at the moment of maximum political and public exposure in
16. Dr. Kathy Garcia-Lawson's separate affidavit submitted alongside this one
17. Neither my affair with Dr. arly Taitz nor anything else which I have done
constitutes a fraud on this court, nor any other court, nor any reason for the Court to
18. It is terribly embarrassing and a professional disgrace when personal lives intrude
19. If this Court feels that the events have in any way colored this Court's perception
of the parties or ability to judge the facts of the case between the Plaintiffs and the
Defendants impartially, or if the Court feels that it will be prejudiced against the
Plaintiffs because of my and Dr. Taitz' love affair, which had NOTHING whatsoever to
Marsha G. Rivernider, and Charles Lincoln, this Court should consider recusal rather
Dr. Taitz may seem, it is merely reflective (at the absolute worst) of this Plaintiffs and
Dr. Taitz' emotional immaturity in the handling of their personal lives, and do not reflect
on ANY of the other matters raised in Plaintiffs' Response to the Court's Second Order
to Show Cause and the Defendant's Motion to Dismiss in any way, shape or form.
Signed, declared under penalty of perj , and executed in Palm Beach Gardens,
By:~o----::,.JF---""--=~,.qq...~,-+-:£'-4-~~~---"oC=---
arIes Ed ara co n, III
c/o Peyton Yates Freiman
603 Elmwood Place, Suite #6
Austin, Texas 78705
Telephone: 512-968-2500
E-mail: charles.lincoln@rocketmail.com
Alternative Address:
c/o Kathy Ann Garcia-Lawson
2620 Nature's Way
Palm Beach Gardens, Florida 33410
Telephone: 512-968-2500/512-923-1889
Facsimile: 561-691-1423
NOTARY'S JURAT
Charles Edward Lincoln, III, appeared in person before me on this Monday the
16th day of November, 2009, in Palm Beach Gardens, Florida, and having been by me
duly sworn upon his oath he did verify the truth of all the statements of fact set forth
above, and did declare and acknowledge the statements of opinion made above and the
sincerity of their submission to the Court.
I am an officer authorized to administer oaths and take testimony under the laws
of the State of Florida, my principle place of bus' eing in Palm Beac County,
Florida.
ALEJANDRO VERA
Notary Public, State 01 Florida
Commisslon# 00812909
My comm. expires Aug. 7, 2012
Exhibit A:
Sunday, November 15,2009
E-Mail from
Dr. Orly Taitz, Esquire
Charles,
I received your two phone messages. In the first message your speech was extremely blurry, unclear, second message
sounded like you were a different person.
I believe that you need urgent evaluation and treatment by a psychiatrist. All of your behavior as of late, all of the e-
mails to me, my husband and my attorney suggest the same. You are hurting me, my husband, my children, your wife,
your son, Rverniders and yourself
I am sending a declaration to judge Dimitrious in FL, letting him know, that I believe you are in need of urgent
psychiatric evaluation and possibly treatment, and I believe that case needs to be stayed pending your evaluation and
treatment.
Dr. Orly Taitz ESQ
29839 Santa Margarita Pkwy ste 100
Rancho Santa Margarita Ca 92688
ph. 949-683-5411
fax 949-766-7603
orlytaitzesq.com
drtaitz.com
taitzofficesuites.com
AFFIDAVIT NUMBER 2:
Dr. Kathy Ann Garcia-Lawson, Ph.D.
MARSHA G. RIVERNIDER, §
ROBERT H. RIVERNIDER, §
CHARLES EDWARD LINCOLN, III, §
Plaintiffs, §
§
v. § Case No. 09-91255-CIV
§ HON. W.P. DIMITROULEAS
U.S. BANK NATIONAL ASSOCIATION, §
AS TRUSTEE FOR THE C-BASS §
MORTGAGE LOAN ASSET-BACKED §
CERTIFICATES, SERIES 2006-CBS, §
And all JOHN & JANE DOES 1-50 § Affidavit of Psychologist
Defendants. § Regarding Charles E. Lincoln
§
§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§
AFFIDAVIT OF DR. KATHY GARCIA-LAWSON
and technique followed by a two year postdoctoral residency at 45 th Street Mental Health
3. A true and correct (if slightly out of date) copy of my vita is attached as
4. Since 1995 I have engaged in the private practice of clinical psychology with
my current office location at 2401 PGA Boulevard, Suite 128, Palm Beach Gardens,
Florida 33410.
5. I have known Charles Edward Lincoln, III, since Saturday, May 11,2008,
when he called me to discuss my concerns regarding rampant abuses in the Family Law
as a competent and well-read student of the law and constitutional history and theory.
in some ways, I think his background makes him more useful and trustworthy than many
licensed attorneys who cannot criticize the system because they depend upon it and are
part of it.
the District of Columbia and Florida, as well as threatened with disbarment, because of
his criticism of the judiciary and the unconstitutional operation of the Family Courts
which routinely deny due process of law in an arbitrary and capricious manner, to the
great injury of spouses and children all over the United States.
against the constitutional eligibility of President Barack H. Obama. I made contact with
Dr. Taitz who indicated that she lacked competent assistance in her litigation, whose end
grounds, and I suggested to her that she contact Charles Lincoln and see whether they
night telephone call that he was involved in a very intense love affair with Orly Taitz as
well as working for her constantly to the exclusion of everything else in his life. Charles
said that he had been very lonesome since he separated from his wife Elena in late July
2002, and that Orly had made him "feel alive" and he believed that they could work
11. Although he was calling me and updating me as a friend, that night Charles
Lincoln at that time said that he was very disturbed by the events, which had transpired
with Orly, a married woman, and requested that I advise him as a psychologist. I spoke
to Charles about Orly about 3-4 times a week after that, sometimes more.
12. Charles has also come to visit me in Palm Beach Gardens on three separate
occasions since this started, and Orly is always on his mind, as are his concerns with their
relationship.
13. I should make it clear that Charles was never a formal patient of mine, never
paid me for services, and I consider our relationship still to be that of friends rather than
doctor-patient. I counseled him professionally as ifhe were a patient of mine, but more
14. I did my best to advise Charles to terminate his relationship with Orly, after
15. I had the opportunity to travel to Orange County, California, on the weekend
of October 2-6 in Orange County, California, and did spend some time meeting with Orly
17. I, like others close to Charles, were gravely concerned about the sincerity of
Orly's involvement with Charles or whether she was taking advantage of a lonely man in
18. I have no personal knowledge of any of the papers passing between Charles
and Orly in this case or any other case, but I cannot imagine any reason why Charles
would have needed to falsify documents from Orly because they worked together, very
intensely, for five months and I know he wrote more documents which she signed than
19. Charles copied me on almost everything he wrote for Orly, including his legal
research for her, and his output was nothing less than prodigious. I was concerned for his
well-being and his general health because Orly's demands on him sometimes seemed
excessive.
20. I have read arly's Sunday Novmeber 15,2009, e-mail attached as Exhibit A
to this affidavit and in my professional opinion, this tum of events seems to be rooted in
vindictiveness and hostility, and I find it suspect thatfher conduct and actions have so
radically changed in the immediate aftermath of the October 29,2009, dismissal of the
21. I have wondered whether arly's involvment with Charles was strictly a result
of her interest in using him on the Obama case, and I think that arly may have been
"leading Charles" on and that she never really intended to follow through on her
22. In my time of knowing Charles I have found him always to be forthright and
23. I would be happy to testify on his behalf or elaborate upon this affidavit in
response to any questions which the Court might have in the future.
24. I find it quite unfortunate that this inappropriate and personal relationship has
found its way to contaminate a significant case such as the present one, but I agree that
Charles had the need to be forthcoming and truthful regarding all the circumstances
loneliness, and I see no cause to recommend him for psychiatric evaluation of any kind.
26. I have also met Bob Rivemider and nothing in my observation of either
Lincoln or Rivemider suggests to me that they were likely to have been attempting to
falsify Orly's involvement in this case in any way. I am aware that Orly did appear or
attempt to appear in several other cases for Charles E. Lincoln involving mortgages and
Signed, declared under penalty of perjury, and executed in Palm Beach Gardens,
"
() -r-.';,-'..:::o.._'1,-"U=,,--v / ,} /1P .
BY:--:;-;:----,-;-=~,__-'-t::::-"-.'----;-' --:;:(,:;:-t:.(.&_'.:....t-.:..../'--
l..-;:::', . . - __
Kathy Ann Gar . -Lawson, Ph.D.
2401 PGA Boulevard, Suite 128
Palm Beach Gardens, Florida 33410
Office Telephone: 561-694-2772
Facsimile: 561-691-1423
NOTARY'S JURAT
Kathy Ann Garcia-Lawson appeared in person before me on this Monday the 16th
day of November, 2009, in Palm Beach Gardens, Florida, and having been by me duly
sworn upon her oath she did verify the truth of all the statements of fact set forth above,
and did declare and acknowledge the statements of her professional opinion made above
and the sincerity of their submission to the Court.
I am an officer authorized to administer oaths and take testimony under the laws
of the State of Florida, my principle place of business being in Palm Beach /ounty,
Florida.
ALEJANDRO VERA
Notary Public, State of Florida
Commission, 00812909
My oomm. ellplres Aug. 7, 2012
My Commission Expires:_--,-.t1.....;O<:::........:=G-,,-'-<l-7+-'.....c9--..D..L...:-42=~ _
Exhibit A:
Sunday, November 15, 2009
E-Mail from
Dr. Orly Taitz, Esquire
Charles,
I received your two phone messages. In the first message your speech was extremely blurry, unclear, second message
sounded like you were a different person.
I believe that you need urgent evaluation and treatment by a psychiatrist. All of your behavior as of late, all of the e-
mails to me, my husband and my attorney suggest the same. You are hurting me, my husband, my children, your wife,
your son, Rverniders and yourself
I am sending a declaration to judge Dimitrious in FL, letting him know, that I believe you are in need of urgent
psychiatric evaluation and possibly treatment, and I believe that case needs to be stayed pending your evaluation and
treatment.
Dr. Orly Taitz ESQ
29839 Santa Margarita Pkwy ste 100
Rancho Santa Margarita Ca 92688
ph. 949-683-5411
fax 949-766-7603
orlytaitzesq.com
drtaitz.com
taitzofficesuites.com
http://de.mg41.mail.yahoo.com/dc/launch?.gx=1&.rand=17q8i4v26j7li 11/15/2009
Case 9:09-cv-81255-WPD
Case: 09-3403 Document:
Document00319937507
22 Entered on
Page:
FLSD41Docket
Date11/17/2009
Filed: 12/08/2009
Page 21 of 30
Exhibit B:
Professional Vita
Kathy Ann Garcia-Lawson, Ph.D.,
In Psychology with specialty
In Psychoanalytic Technique
VITA
A. Personal Data
B. Educational Background
C. Professional Membership
D. Current Position
1
Case 9:09-cv-81255-WPD
Case: 09-3403 Document:
Document00319937507
22 Entered on
Page:
FLSD43Docket
Date11/17/2009
Filed: 12/08/2009
Page 23 of 30
F. Teaching Experience
G. Administration
H. Dissertation
I. Publications
Garcia-Lawson, Kathy (2000), Sudden Death ofthe Therapist: Effects on the Patient:
Journal of Contemporary Psychotherapy, 30(1) 85-103.
K References
2
Case: 09-3403 Document: 00319937507 Page: 45 Date Filed: 12/08/2009
CERTIFICATE OF SERVICE
Motion to Transfer Venue to the U.S. District Court, Central District of California,
Southern Division was served this 29th day of November 2009 electronically upon the
following:
Orly Taitz
Defend our Freedoms Foundation, Inc. (unrepresented)
26302 La Paz Ste 211
Mission Viejo, CA 92691
Email: dr_taitz@yahoo.com
Neil Sankey
The Sankey Firm, Inc. a/k/a The Sankey Firm (unrepresented)
Sankey Investigations, Inc.
2470 Stearns Street #162
Simi Valley, CA 93063
Email: nsankey@thesankeyfirm.com
Ed Hale
Caren Hale
Plains Radio
KPRN
Bar H Farms
1401 Bowie Street
Wellington, Texas 79095
Email: plains.radio@yahoo.com; barhfarms@gmail.com;
ed@barhfarms.net; and ed@plainsradio.com
________________________
PHILIP J. BERG, ESQUIRE