Gov Uscourts Cacd 497989 751 0

Case 8:11-cv-00485-AG-AJW Document 751 Filed 10/14/17 Page 1 of 17 Page ID #:18346
1 J.B. Lorenzo
2 Lorenzo Law Firm, P.A.
P.O. Box 11253
3 Tallahassee, FL 32302
4 admin@lorenzolawfirm.com
tele. No. 855.757.2757
5 Attorney for Plaintiff Lisa Ostella
6
7
UNITED STATES DISTRICT COURT
8 FOR THE CENTRAL DISTRICT OF CALIFORNIA,
SOUTHERN DIVISION
9
: Case No. 8:11-cv-00485-AG (AJW)
10 :
LISA LIBERI, et al, :
11 : SECOND AMENDED COMPLAINT
:
12 :
Plaintiff, : 1- FALSE LIGHT PUBLICITY-
13
: INVASION OF PRIVACY
:
14
vs. : 2- APPROPRIATION OF NAME
: INVASION OF PRIVACY (Cal.
: CIV. CODE 3344(A) (2013).
15 :
ORLY TAITZ, et al, : 3- CYBER HARASSMENT
16 : BULLYING
: CAL. C. CIV. PROC. 527.6 &
17 :
Defendants. : CAL. PEN. CODE 653.2
18 :
: 4- DEFAMATION PER SE/ LIBEL
19 : CIV. CODE, 45A.
:
20 :
: REQUEST FOR JURY TRIAL
21 :
: Honorable Andrew J. Guilford
22 : Location: Courtroom 10D
: Date filed: May 5, 2009
23 :
: Pre-Trial Conf. February 26, 2018
24 :
: Trail Date: March 27,2018
25 :
:
26
Page 1 of 17
27
SECOND AMENDED COMPLAINT
28 By Plaintiff, Lisa Ostella
LORENZO LAW FIRM, P.A.

1 Introduction and Parties

2
1. The only remaining Plaintiff is Lisa Ostella (hereafter referred to as
3
4
Plaintiff or Ostella). Plaintiff Lisa Ostella, submits this second amended
5 complaint against ORLY TAITZ, the remaining defendant. TAITZ entered into
6 settlement agreements with previous plaintiffs and they withdrew their claims
7 against TAITZ. TAITZ remains as the sole defendant, after Ostella voluntarily
8 withdrew claims against named aliases and entities of TAITZ, to which Ostella did
9 not have claims against. This matter is between Plaintiff Lisa Ostella and
10 Defendant ORLY TAITZ.
11
2. Lisa Ostella brings this amended complaint asserting four [4] claims
12
against TAITZ: i). False Light Invasion of Privacy;1 ii). Appropriation of Name
13
Invasion of Privacy;2 iii). Cyber Harassment/Bullying; and iv). Defamation Per Se/
14
Libel. Ostella asserts that TAITZs written statements were published on
15
TAITZs Internet blog (a). with willful disregard for the truth, (b). with malice, (c).
16
17
calculated for commercial interest, (d). without First Amendment protection or
18 privilege applying, (e). without public import or public interest value, (f). without a
19
20
21
1 False Light Publicity (1) the defendant caused to be generated publicity of the plaintiff that
was false or misleading; and (2) the publicity was offensive to a reasonable person.
22 Scott v. Saxon Mortg. Servs., 2013 U.S. Dist. LEXIS 146988, at *17 (N.D. Cal. Oct. 10, 2013).
23
2 Appropriation of Name Invasion of Privacy - The appropriation of the name and likeness
24 brings injury to the feelings, that concerns one's own peace of mind, and that is mental and
25 subjective. Dora v. Frontline Video, Inc., 15 Cal. App. 4th 536, 541-42 (1993); accord Aroa
Marketing, Inc. v. Hartford Ins. Co. of Midwest, 198 Cal. App. 4th 781, 789 (2011).
26
Page 2 of 17
27

1 basis in truth, (g). by invading Ostellas privacy, (h). by misappropriating Ostellas

2 name for commercial gain, and (i). by harassing and bullying.
3 3. TAITZ has posted about Ostella eleven times in 2009 on TAITZs blog,
4
i.e., www.orlyTAITZesq.com web blog. They remain into 2017 on the Internet
5
and on TAITZs blog continuing over eight [8] years. TAITZ owns and administers
6
the following emails: dr_TAITZ@yahoo.com, orly.TAITZ@gmail.com, and
7
orly.TAITZ@hushmail.com that are used by TAITZ to publish comments about
8
Ostella. TAITZ is involved in displaying Ads, seeking contributions, along with
9
posting about Ostella on TAITZs blog www.orlyTAITZesq.com.
10
11 Jurisdiction and Venue
12 4. The amount in controversy, exclusive of interest and costs, exceeds

13 $75,000, for each of the individual claims asserted by Ostella.
14
5. This Court has jurisdiction, by diversity of Jurisdiction, over this
15
action pursuant to 28 U.S.C. 1332(a), since Ostella resides in New Jersey and
16
TAITZ resides in California.
17
18 6. Venue is proper before this Court in this action because the
19 Defendant, ORLY TAITZ resides in Santa Ana, California.
20
21 Background
22
7. Ostella provides web development services and owns a library of
23
domains to offer clients along with providing website hosting for clients.
24
8. TAITZ sought Ostellas services in the Fall of 2008.
25
26
Page 3 of 17
27

1 9. Ostella purchased the domain defendourfreedoms (DOFF) and its

2 suffixes .com, .net, .info, .org, and .us in December 2008, as she was developing a
3 blog for TAITZ, using the domain defendourfreedoms.org (doff.org).
4
10. Ostella remains the sole owner of this domain and suffixes.
5
6 11. Because TAITZ did not have a valid FEI number for DOFF, Ostella
7 transferred the PayPal donate button code to TAITZ for the donate function, so that
8 TAITZ could then establish the account using her own social security number and
9 be controlled by TAITZs email orly.TAITZ@gmail.com for authentication and
10 access with a password, only known by TAITZ. As of the December 2008 transfer
11 of the PayPal donation code to TAITZ, Ostella no longer had control over the
12 PayPal donation feature as the account was set up using TAITZs social security
13 number.
14 12. When donors claimed in March of 2009 that they received error
15 messages, TAITZ posted on her blog that her PayPal account to the
16 defendourfreedoms.us blog was hacked by outside sources.
17
13. Ostella had previously informed TAITZ of the technical reasons the
18
blog was not hacked, since the web blog was hosted on Ostellas server account
19
and the PayPal account had nothing to do with the blog nor its hosting.
20
21 14. Contrary to TAITZs claim that donations were diverted, donations
22 continued to be processed into TAITZs bank account associated with the PayPal
23 account owned by TAITZ.
24
25
26
Page 4 of 17
27

1 15. Contrary to TAITZs claim of being hacked, the donations glitch was
2 due to an email suffix error of TAITZs own email and not a blog hacking and
3 Ostella made TAITZ aware of the reason it was not a hack.
4
16. TAITZ disregarded Ostellas explanation and posted that her site was
5
hacked and she filed a cybercrime report with the FBI seeking an investigation
6
based on TAITZs narrative.
7
8 17. Ostella discussed with TAITZ why she needed to correct her
9 statements to the FBI and her posting on the blog.
10
18. When TAITZ refused to retract or correct the statements and claims
11
to the FBI, Ostella told TAITZ that TAITZ needed to secure another webmaster.
12
19. TAITZ filed the report with Orange County Sheriffs Office (OSCO)
13
after Ostella had told TAITZ that she needed to get another webmaster because of
14
TAITZs false FBI report. TAITZ posted that an Orange County Cybercrimes
15
Unit agent was assigned to investigate. TAITZ also posted her police report that
16
17
stated that Ostella and Lisa Liberi were one and the same, having a criminal
18 record, and claiming that Ostella took $10,000 of donations from TAITZs
19 foundation.
20 20. Contrary to TAITZs written post and claims that Ostella blocked her,
21 Ostella ended the transfer of the domain code to TAITZs new webmaster and
22 ended access to the defendourfreedoms.us blog, that was in the process of
23 transferring content to defendourfreedoms.net, to allow for an investigation. Prior
24
to ending access, Ostella was coordinating with TAITZs new webmaster to
25
26
Page 5 of 17
27

1 transfer the domains code, in order to transfer the blog data. Ostella did not want
2 to obstruct an investigation that supposedly was underway.
3
4 21. Contrary to TAITZs written post and claims, Ostellas server has
5 been available for an investigation since TAITZs claim, on April 2, 2009, that an
6
investigation was underway. To Ostellas knowledge, no investigation has ever
7
taken place to date. The domain file has been in a static format on Ostellas
8
storage server since Go Daddy stopped supporting the Quick Blogcast software
9
format at the Go Daddy servers in 2014. Ostella has maintained the raw format
10
data of the site and it has not been viewable since.
11
22. Contrary to TAITZs written posts and claims, donations could not
12
have been redirected by Ostella since TAITZ remained in control of the PayPal
13
donate feature on her own blog www.orlyTAITZesq.com, from which TAITZ has
14
continuously operated to post and draw donations.
15
16 23. Contrary to TAITZs OSCO report claiming that Lisa Ostella and Lisa
17 Liberi were one and the same, TAITZ and Ostella were previously informed by
18 TAITZs retained private investigator about Lisa Liberis background record and
19 TAITZ had acknowledged in her emails that Ostella was her webmaster and not
20 Lisa Liberi. No reasonable person in TAITZs position would have asserted Lisa
21 Ostella and Lisa Liberi were one and the same.
22
24. Contrary to TAITZs OSCO report claiming that Ostella took
23
donations, TAITZ was aware of the email suffix glitch of TAITZs own email used
24
for the account and her own password, both under TAITZs control.
25
26
Page 6 of 17
27

1 25. Since 2009, TAITZs blog has had remarkable Internet viewer traffic
2 in the tens of thousands annually based on Internet traffic sources. The celebrity
3 and popularity of TAITZs blog aggravates the effect of TAITZs written
4 statements on Ostella.
5
26. TAITZ made eleven [11] statements on the following dates about
6
Ostella:
7
8
A. 4/17/2009 - More explosive Information dossier #6 a posting of
9 dr_TAITZ@yahoo.com email on www.orlyTAITZesq.com, stated:
10
I started receiving statements and copies of pay pal receipts,
11 showing instead of my email address, an e-mail address of Lisa
12 Ostella. Originally, I thought that maybe her address showed on the
receipt, since she was a web master on the account, however, when I
13
checked the names and dates on the receipts, . . . I could see that those
14 were not received by the foundation, those donations were missing.
15
B. 4/17/2009 TAITZs police report with OCSO stating:
16
17 learned that some monetary donations intended for Defend Our
Freedoms was redirected to Lisas personal email account; (2) in reality
18 donations were redirected to Lisa Ostellas (AKA: Lisa Liberi) personal
19 account; that the estimated loss was $10,000.
20
C. 4/18/2009 - Follow up on Lisa Liberi, paralegal to Phil Berg, posted
21 on www.orlyTAITZesq.com with caption and stated:
22
23 I have closed the PayPal account when I saw that Lisa Ostella
has redirected the Defend Our Freedoms blog and redirected the
24
paypal, -
25
26
Page 7 of 17
27

1 D. 4/18/2009 Dont Be Fooled posted on www.orlyTAITZesq.com

2 stating:
3 My former web master Lisa Ostella has created an account that she
called Defend Our Freedoms Network and is soliciting donations,
4
praying on unsuspecting readers that would not notice the difference
5 between Defend Our Freedoms Foundation and Defend Our Freedoms
6 Community. Please notice, your donations there will not go to the
foundation, they will go to her personal bank account, connected to
7 her personal e-mail address GoExcellGlobal. She posted underneath a
8 PayPal logo with my e-mail address, however I have closed the pay-
pal account.
9
10 E. 4/19/2009 Every day I get such evidence of missing or misdirected
11 funds posted on www.orlyTAITZesq.com, caption stating:
12 Every day I get such receipts, showing that my former web
13 master Lisa Ostella (posts under name Calpernia) has redirected
donations to herself, to her e-mail address. Currently, as this was
14
uncovered, she created new web sites Defend our freedoms .org,net
15 and continues the scheme by making those sites similar to my old
16
ones and using the foundation name to steal more donations. She
created a visa donation site with her e-mail account Go Excell Global,
17 underneath she posted a paypal button showing my foundation Defend
18 Our Freedoms (without my consent) and my e-mail address (without
my consent) to look as if she is still connected to me and my
19 foundation, even though all ties with her were severed a couple of
20 weeks ago, when I found out about this scheme and I closed the Pay
Pal account completely. Any person, whose donations were stolen by
21
Lisa Ostella aka Lisa Current aka Calpernia is asked to report this to
22 his local police or sheriffs department. As I found out, she appears to
be connected to Lisa Liberi, who is still working for attorney Phillip
23
Berg.
24
25
26
Page 8 of 17
27

1 F. 4/20/2009 - About Lisa Ostella - dont patronage diverting funds

2 from a nonprofit, dont be part of slander posted an email on
www.orlyTAITZesq.com stating:
3
As I found a new web master, Ms. Ostella, who had the access codes
4
as a web master, instead of transferring all the domains, has locked me
5 and other volunteers out of the blog and transferred the account to
6 herself, and is using the name of my foundation fraudulently, without
my consent. She is using the pay-pal account that says Defend Our
7 Freedoms and my personal e-mail address fraudulently and she posted
8 numerous outrageous slanderous statements about me while pocketing
the donations,
9
10 G. 4/21/ 2009 Update on Lisa Ostella and Lisa Liberi, posted a letter
11 written to Mr. Al Barrs on www.orltyTAITZesq.com verifying the filed
OCSO report stating:
12
I have sent a Cease and Desist letter to Ms. Lisa Ostella, demanding
13 that she forward to me the access codes for the domains and the e-mail
14 address list of the readers and stop fraudulently operating under the
name Defend Our Freedoms and stop drawing financial profit from the
15
Defend Our Freedoms name. . . Ms. Lisa Ostella is the one, who
16 collected names and e-mail addresses and she is currently fraudulently
17
sending e- mails to these readers using Defend Our Freedoms name.
18
H. 5/5/2009 Check public records for yourself, see that I am providing
19
truthful information posted on www.orlyTAITZesq.com stating:
20
21 Ms. Ostellas actions as a web master in locking me out of my web
site, allowing several days of defamatory statements and later
22
defrauding the donors and my foundation, by sending e-mails and
claiming to represent foundation and soliciting donations for the
23
foundation are inexcusable and will have to be prosecuted in due
time.
24
I. 5/19, 2009 NJ Police posted on www.orlyTAITZesq.com blog
25 stating:
26
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27

Case 8:11-cv-00485-AG-AJW Document 751 Filed 10/14/17 Page 10 of 17 Page ID
#:18355
1 As you know my previous site, Defend Our Freedoms was taken over
2 by the web master Lisa Ostella. For over a month now Lisa Ostella
had no affiliation with Defend Our Freedoms Foundation, however
3 she has been sending e-mails from Defend Our Freedoms and
4 collecting donations.
5
J. 5/20/2009 TAITZs comment to May 20, 2009 to her own May
6
19, 2009 post NJ Police on www.orlyTAITZesq.com using the
7 dr_TAITZ@yahoo.com email, @ 7:36 am stating:
8
9 Defend our freedoms is a non-profit registered under my name. Lisa
Ostella, the web master, was supposed to register the domain under
10 my name, instead she entered her e-mail address Go Excell Global.
11 She keeps the domain and solicits donations by defrauding the non-
profit organization. When people donate, they believe, that they donate
12
to my effort, for me to travel to different states, lobby officials, file
13 legal actions, instead she is diverting the donations to her own pocket
14 by fraud and she and her husband benefit from defrauding me and my
foundation.This is a criminal matter
15
16 K. 3/3/ 2011 Who are these people in Germany threatening me?
posted on www.orlyTAITZesq.com blog stating:
17
18 I reported cyber-crimes, I reported that my volunteer web master
Lisa Ostella locked me out of my prior web site for my foundation,
19
that donations to my foundation were diverted,
20
21 27. TAITZs eleven postings from 4/17/2009 through 3/3/2011
22 demonstrate a consistent repetitive pattern and practice of using the Internet and
23 her blog to state untruthful and harmful statements about Plaintiff, Lisa Ostella.
24 28. As of a March 8, 2009 email to a donor, TAITZ admitted her
25 awareness that there was not a hacking but a glitch on her email suffix:
26
Page 10 of 17
27

#:18356
1 I finally figured, what happened. Somebody tempered with my

2 ay pal account, actually went into account and changed it from
orly.TAITZ@gmail.com to orly.TAITZ@gmail.org - a non-
3 existant account for paypal. I guess it was done intermittently, so I
4 got some donations, but very little. Lisa Ostella, my web master
will report it to her carrier "go daddy", she will see if this e-mail
5
is not taken, we will add it. I will send an additional report to
6 Attorney General-Eric Holder, though he is Obama's appointee...
7
We are dealing with dirty mafia, running the country. Please, see
the letter to Attorney General, that I posted,..
8
9
29. TAITZ has with malicious intent, sought to destroy Ostellas
10 reputation, character, professionalism, and credibility by attributing criminality to
11 Ostella. Ostella had previously informed TAITZ in December 2008 that she could
12 not claim to be a nonprofit without registering for a federal identification number
13 and the State of California. Ostella had also informed TAITZ that for PayPal her
14 claimed business entity number was not valid. TAITZ had been receiving
15 donations as of October 2008 without registering as a charity in the State of
16 California and with the Internal Revenue Service.
17
18 CLAIM I: Invasion of Privacy False Light Publicity3
19
20
30. Ostella realleges and incorporates by reference paragraphs 1
21
22
3 False Light Publicity - Lee v. Penthouse Intl, No. CV 96-7069 SVW (JGx), 1997 U.S. Dist.
LEXIS 23893, at *21 (C.D. Cal. Mar. 20, 1997) (To state a cause of action for false light,
23 Plaintiffs must each plead and prove (1) that the defendant disclosed (2) to one or more persons
(3) information about or concerning Plaintiffs that was presented as factual but that is actually
24 false or created a false impression about Plaintiffs, and (4) that the information was understood
25 by one or more of the persons to whom it was disclosed as stating or implying something that
would have a tendency to injure Plaintiffs).
26
Page 11 of 17
27

#:18357
1 through 29, including sub-paragraphs as though fully set forth herein.

2
31. TAITZs written postings depict Ostella, in a false light in that: a).
3
They misrepresent Ostellas character, professionalism, responsibility, history, and
4
reputation;4 b). They are highly offensive to a reasonable person, depicting Ostella
5
as a criminal, having a criminal record, having committed fraud, and being
6
someone who stole donations; and c). They are a reckless disregard as to the falsity
7
of the publicized statements about Ostella;
8
9 32. TAITZs written statement about Ostella directly and proximately
10 cause harm to Ostella. Ostella did not divert funds, is not a criminal, and does not
11 have a criminal record.
12
CLAIM II: Invasion of Privacy - Appropriation of Name
13
Cal. Civ. Code 3344(a)
14
15 33. Ostella realleges and incorporates by reference paragraphs 1 through
16 32, including sub-paragraphs as though fully set forth herein.
17
34. Ostella did not give TAITZ permission to use Ostellas name on her
18
blog. TAITZs blog has a commercial and trade interest selling advertising.
19
35. TAITZ has financially benefited at the expense of Ostella, by
20
21
appropriating Ostellas name in a narrative on her blog so that potential donors
22 would have sympathy for TAITZ and her claimed causes.
23 36. TAITZ blog and written statements about Ostella are without
24 redeeming public interest, news, social importance, and truth.
25
26
Page 12 of 17
27

#:18358
1 37. TAITZs written statements created a narrative that Ostella

2 misdirected funds by embezzling from her foundation, that Ostella had a criminal
3 history, that Ostella committed fraud, and that TAITZ needed donor support to
4 fend off what she claimed Ostella did. TAITZ willfully violated Ostellas right to
5 privacy under California law. Cal. Civ. Code 3344(a) (2013).
6
38. TAITZs written statements about Ostella have directly and
7
proximately hurt Ostella for eight years and counting.
8
9 CLAIM III: Cyber Harassment/Bullying
Calif. Pen. Code 653.2. & Calif. C. Civ. Proc. 527.6:
10
11 39. Ostella realleges and incorporates by reference paragraphs 1 through
12 38, including sub-paragraphs as though fully set forth herein.
13 40. TAITZs written postings intentionally remain on the Internet.
14
TAITZ intentionally posted to the general public that Ostella had a criminal record,
15
that Ostella committed fraud, and that Ostella extorted donor money from the
16
foundation. TAITZs postings have an intentional harassing and bullying effect on
17
Ostella that any reasonable person5 can appreciate. Calif. C. Civ. Proc. 527.6 (3)
18
41. TAITZ intentionally repeated postings intimidating Ostella by
19
coaxing donors and followers to garner bad sentiments toward Ostella. Because of
20
21
5 Calif. C. Civ. Proc. 527.6: (3) Harassment is . . . a knowing and
22 willful course of conduct directed at a specific person that seriously alarms,
23 annoys, or harasses the person, and that serves no legitimate purpose. The
course of conduct must be that which would cause a reasonable person to
24
suffer substantial emotional distress, and must actually cause substantial
25 emotional distress to the petitioner.
26
Page 13 of 17
27

#:18359
1 TAITZs written posts about Ostella, Ostella has been reasonably placed in fear of
2 retribution by TAITZs followers and financial supporters. (Calif. Pen. Code
3 653.2)
4 42. TAITZ has intentionally and repeatedly placed Ostella in a threating,
5 hostile and harassing environment for eight years.
6
7 Calif. Pen. Code 653.2. (1) Harassment means a knowing and
willful course of conduct directed at a specific person that a reasonable
8
person would consider as seriously alarming, seriously annoying, seriously
9 tormenting, or seriously terrorizing the person and that serves no legitimate
10 purpose. (2) Of a harassing nature means of a nature that a reasonable
person would consider as seriously alarming, seriously annoying, seriously
11 tormenting, or seriously terrorizing of the person and that serves no
12 legitimate purpose.
13
14 CLAIM IV: Defamation Per Se - Libel Per Se
15 Calif. C. Civ. Proc. 45

16 43. Ostella realleges and incorporates by reference paragraphs 1
17 through 41, including sub-paragraphs as though fully set forth herein.
18 44. Ostella at all times has been a private citizen working as a webmaster.
19 TAITZs written posts at www.orlyTAITZesq.com published on the Internet about
20 Ostella stealing donations, having a criminal record, committing fraud with donors
21
contributions, taking a domain, hacking into the account are false, have been stated
22
without regard for truth, with malicious intent, seeking to destroy Ostella
23
personally and professionally as a webmaster.
24
45. TAITZs written statements about Ostella is libel and libel Per Se,
25
pursuant to Calif. C. Civ. Proc. 45.
26
Page 14 of 17
27

#:18360
1 46. TAITZ has intently demonstrated total disregard for the truth as a
2 licensed professional and should have been reasonably aware of her own actions
3 and statements effects on Ostella.
4
47. TAITZ defamed Ostella by filing with false information a FBI report
5
and an OCSO report. False reporting is not protected public interest nor protected
6
speech. (See Lefebvre v. Lefebvre (2011) 199 Cal. App. 4th 696) [where the
7
8
defendants police report was determined to be false . . . against the Plaintiff])
9 48. With malice, disregard for the truth, and without any allowable
10 privilege, TAITZ willfully wrote and posted egregious harmful statements about
11 Ostella, attributing criminality to Ostella, to directly harm Ostellas reputation,
12 character, professionalism, and Ostellas personal identity and as a webmaster on
13 the Internet.
14
PRAYER FOR RELIEF
15
16 WHEREFORE, Ostella asks the Court to consider the duration of the harm
17 to date of TAITZs written postings and the time that it will take for the postings to
18 be removed and no longer be indexed by Internet search engines.
19
Also, Ostella respectfully asks for a judgment against TAITZ that would
20
issue an award as follows:
21
22 1. General damages in the amount of $10,000,000;
23
2. Exemplary (punitive) damages, in the amount of 10,000,000;
24
3. Special damages and presumed damages, to be determined at trial;
25
4. Equitable relief including but not limited to the relief requested
26
Page 15 of 17
27

#:18361
1 above;
2 5. Costs of suit incurred in this action, along with attorney fees;
3
6. Order requiring TAITZ to publicly state a retraction and apology on
4
the Internet of her false statements;
5
7. Order requiring TAITZ to remove from her blog and her blog
6
archives any and all posting about and naming Lisa Ostella, including
7
8
those referencing Lisa Liberi as associated to Lisa Ostella;
9 8. Order for injunctive relief prohibiting TAITZ from ever mentioning

10 Ostella or alluding to Ostella in her publications online and offline on
11 her emails;
12 9. Order for prejudgment and post-judgment interest; and
13
10. Order for other relief deemed by the Court as just and proper.
14
15
16 Respectfully submitted: October 14, 2017.
/s/ J.B. Lorenzo
17
18 LORENZO LAW FIRM, P.A.
19
Counsel for Lisa Ostella/ Plaintiff
20
21
22
23
24
25
26
Page 16 of 17
27

#:18362
1 CERTIFICATE OF SERVICE
2
3
I hereby certify that a true and correct copy of the foregoing has been
4
5
furnished to the following via CM/ECF on record and via electronic mail on this
6 October 14, 2017.
7
8 Jeff Cunningham, Esq.
9 Schumann Rosenberg
3100 Bristol Street, Suite 100
10 Costa Mesa, CA 92602
11 jcunningham@schumannrosenberg.com
Tel: (714) 850-0210, Ext. 268
12
Fax: (714) 850-0551
13 Counsel for Defendant Orly Taitz
14 /s/JB Lorenzo
15 Jose B. Lorenzo
16 2040 Delta Way
17 P.O. Box 11253
Tallahassee, FL 32302
18
admin@lorenzolawfirm.com
19 Counsel for Lisa Ostella/Plaintiff
20
21
22
23
24
25
26
Page 17 of 17
27

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Case 8:11-cv-00485-AG-AJW Document 751 Filed 10/14/17 Page 1 of 17 Page ID #:18346

LORENZO LAW FIRM, P.A.

1 Introduction and Parties

LORENZO LAW FIRM, P.A.

1 basis in truth, (g). by invading Ostellas privacy, (h). by misappropriating Ostellas

12 4. The amount in controversy, exclusive of interest and costs, exceeds

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1 9. Ostella purchased the domain defendourfreedoms (DOFF) and its

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1 D. 4/18/2009 Dont Be Fooled posted on www.orlyTAITZesq.com

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1 F. 4/20/2009 - About Lisa Ostella - dont patronage diverting funds

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1 I finally figured, what happened. Somebody tempered with my

10 reputation, character, professionalism, and credibility by attributing criminality to

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1 through 29, including sub-paragraphs as though fully set forth herein.

22 would have sympathy for TAITZ and her claimed causes.

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1 37. TAITZs written statements created a narrative that Ostella

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15 Calif. C. Civ. Proc. 45

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9 8. Order for injunctive relief prohibiting TAITZ from ever mentioning

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6 October 14, 2017.

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