Liberi V Taitz Appendice II Cover Exb A - I

Case: 10-3000 Document: 003110340417 Page: 1 Date Filed: 11/07/2010
NO. 10-3000
__________________________
UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT
__________________________
LISA LIBERI, LISA OSTELLA, EVELYN ADAMS, PHILIP J. BERG, ESQ.,

LAW OFFICES OF PHILIP J. BERG and GO EXCEL GLOBAL
Plaintiffs / Appellees,
v.
ORLY TAITZ, DEFEND OUR FREEDOMS FOUNDATIONS, INC., et al
Defendants / Appellants.
__________________________________________________________________
APPELLEES APPENDICE II
__________________________________________________________________
On Appeal from the United States District Court

For the Eastern District of Pennsylvania
Case No. 09-cv-01898-ECR
__________________________________________________________________
Philip J. Berg, Esquire

LAW OFFICES OF PHILIP J. BERG
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
Ph: (610) 825-3134
Fx: (610) 834-7659
Email: philjberg@gmail.com
PA I.D. No. 09867
Attorney for Appellees

APPENDICE II
TABLE OF CONTENTS
Page(s)
TABLE OF CONTENTS.......................................................................................i-ii
CERTIFICATE OF SERVICE...........................................................................iii-iv
EXHIBIT "A" May 4, 2009 Complaint against Defendants/

Appellants……………………………………………..A1 - A84
EXHIBIT "B" June 25, 2009 Order of Judge Robreno

Dismissing James Sundquist and
Rock Salt Publishing without Prejudice……………………...B1
EXHIBIT "C" June 25, 2009 Order of Judge Robreno

Issuing an Order to Show Cause upon
Plaintiffs/Appellees as to why the Case
Should not be dismissed for lack of
Jurisdiction; Why the case should not be
Severed; and Why the case should not
Be transferred to the Defendants States……...…………C1 - C2
EXHIBIT "D" June 4, 2010 Memorandum of Judge

Robreno severing and transferring
the Case to California and Texas……………….………D1 - D9
EXHIBIT "E" June 4, 2010 Order of Judge Robreno

Severing and transferring the case
to California and Texas…………………………...…….E1 - E2
EXHIBIT "F" June 23, 2010 Amended Memorandum

of Judge Robreno severing and
transferring the Case to California
and Texas………………………………………………..F1 - F6
i
APPENDICE II
TABLE OF CONTENTS - Continued
Page(s)
EXHIBIT "G" June 23, 2010 Amended Order of Judge

Robreno severing and transferring the
Case to California and Texas…………………………...G1 - G2
EXHIBIT "H" August 4, 2010, Defendant/Appellant

Orly Taitz's posting of the August
7, 2009 Transcript on her website
at www.orlytaitzesq.com/?p=12814…………..………..H1 - H4
EXHIBIT "I" September 8, 2010 Defendants/Appellants

Orly Taitz and Defend our Freedoms
Foundations, Inc. Motion Request for
Documents Missing from an Incomplete
Transcript of 8/7/09 Hearing and not
Provided to Defts and the Third Circuit
Court of Appeals and 60B Motion for
Reconsideration due to new evidence……………….…..I1 - I23
EXHIBIT "J" September 14, 2010, Plaintiffs/Appellees

Opposition to Defendant Taitz's Motion
for Missing Docments, etc………………………....…..J1 - J281
EXHIBIT "K" October 26, 2010 Letter from Plaintiffs/

Appellees Counsel, Philip J. Berg, Esq.
To Judge Robreno and all parties being
Improperly served by Defendant Orly
Taitz and Taitz's Obstruction of
Justice………………………………………………...K1 - K27
ii
CERTIFICATE OF SERVICE
I, Philip J. Berg, Esquire, hereby certify that a copy of Appellees Appendice
II was served this 7th day of November, 2010 electronically upon the following:
Further Four (4) hard copies were sent to the U.S. Court of Appeals for the Third
Circuit.
Orly Taitz, et al.

31912 Monarch Crest
Laguna Niguel, CA 92677
Email: dr_taitz@yahoo.com
Defend our Freedoms Foundation, Inc. a/k/a

Defend our Freedoms Foundation
26302 La Paz, Suite 211
Mission Viejo, CA 92691
Email: dr_taitz@yahoo.com
The Sankey Firm, Inc.

2470 Stearns Street #162
Simi Valley, CA 93063
By USPS Mail with Postage fully prepaid
Neil Sankey
4230 Alamo Street
Sankey Investigations, Inc.

4230 Alamo Street
iii
Linda Sue Belcher

201 Paris
Castroville, Texas 78009
Email: starrbuzz@sbcglobal.net and
Email: Newwomensparty@aol.com
Ed Hale
Caren Hale
Plains Radio
KPRN
Bar H Farms
1401 Bowie Street
Wellington, Texas 79095
Email: plains.radio@yahoo.com; ed@plainsradio.com; and
barhfarms@gmail.com
s/ Philip J. Berg
________________________
PHILIP J. BERG, ESQUIRE
Attorney for Appellees
iv
EXHIBIT "A"
Case: Case
10-3000
ER
2:09-cv-01898-ER
Document: 003110340416
Document 1 Filed
Page:05/04/09
2 DatePage
Filed:
1 11/07/2010
of 45
~'7.:;-O Law Offices of

555 Andorra Glen Court, Suite 12
Lafayette Hill, P A 19444-2531 Attorney for: Plaintiffs
Identification No. 09867
(610) 825-3134
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
09 1898
LISA UBERI
and CIVIL ACTION NO.

and
JURY TRIAL DEMANDED
THE LAW OFF1CES OF PHILIP J. BERG

and
EVELYN ADAMS a/k/a MOMMA E
and
LISA M. OSTELLA
and
GO EXCEL GLOBAL
Plaintiffs, :
vs.
ORL Y T AITZ, a/k/a DR. ORL Y TAITZ, a/k/a :

LAW OFFICES OF ORLY TAITZ; a/k/a
WWW.ORLYTAITZESQ.COM a/k/a
WWW.REPUBX.COM a/k/a ORLY TAITZ,
INC.
and
DEFEND OUR FREEDOMS
FOUNDAnONS, INC.
and
YOSEFTAITZ
and
THE SANKEY FIRM
and
SANKEY INVESTIGA TlONS, INC.
and
NElL SANKEY
and
JAMES SUNDQUIST
and
ROCK SALT PUBLISHING
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and
LINDA SUE BELCHER a/k/a LINDA S.
BELCHER alk/a LINDA STARR; alkla
NEWWOMENSPARTYa/kia
STITCHENWITCH alk/a EVA BRAUN alk/a .
WEB SERGEANT alk/a KATY alk/a .
WWW.OBAMACITIZENSHIPDEBATE.ORG
and
EDGAR HALE alk/a JD SMITH;
and
CAREN HALE;
and
PLAINS RADIO NETWORK, a/ka PLAINS
RADIO NETWORK, INC. a/k/a PLAINS
RADIO;
and
BARH FARMS;
and
KPRN AM 1610;
and
DOES 1 through 200 Inclusive,
Defendants. :
PLAINTIFFS COMPLAINT
I. PRELIMINARY STATEMENT
NOW COMES, Lisa Liberi, Philip J. Berg, Esquire, the Law Offices of Philip 1. Berg,
Evelyn Adams alk/a MommaE, Lisa M. Ostella and Go Excel Global, Plaintiffs by and through
the undersigned counsel and brings this Complaint seeking injunctive relief and damages against
the Defendants, Orly Taitz alk/a Dr. Orly Taitz alkla Law Offices of Orly Taitz alk/a Orly Taitz,
Inc; Defend our Freedoms Foundation; Yosef Taitz; Neil Sankey; The Sankey Firm, Sankey,
Sankey Investigations, Inc., James Sundquist; Rock Salt Publishing; Linda Sue Belcher aIkIa
Linda S. Belcher a/k/a Linda Starr alk/a Newwomensparty alk/a Stitchenwitch alkla Eva Braun
alkJa Web Sergeant a/k/a Katy a.lkla www.ohamacttizenshiptiehate.m:g; Edgar (Ed) Hale alkla
JD Smith; Caren Hale; Bar H Farms; Plains Radio Network, Inc. alkJa Plains Radio; and KPRN
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AM 1610; individually and collectively, for their illegal acts against the Plaintiffs, their staff and
their businesses. This is a case that sets fC111h the facts that Defendants, Orly Taitz alk:/a Law
Offices of Orly Taitz alkla Orly Taitz, Inc., Defend our Freedoms Foundation, Inc., The Sankey
Finn, Sankey Investigations, Inc., and Neil Sankey, have sent Plaintiff Lisa Liberi's Social
Security number and personal data via e-mail in mass mailings, media groups, internationally
and to 1000's of undisclosed recipients, requesting the infonnation to be posted on websites
across the internet and have been harassing Plaintiff Lisa Liberi, Philip J. Berg, Esquire and the
Law Offices of Philip J. Berg. Defendants James Sundquist and Rock Salt Publishing have sent
mass e-mailing with Lisa Ostella's home address, phone number and maiden name through the
internet to an unknown number of undisclosed recipients slandering and harassing Lisa Ostella
and her family and have filed falsified police and law enforcement reports against Lisa Ostella
regarding supposed "hacking" of Defendant Orly Taitz, et al websites and PayPal accounts. Lisa
Liberi and her husband were also accused of "hacking" and tampering with Defendant Or1y
Taitz's website and PayPal accounts. Defendants' are well aware it is Orly Taitz, et al who has
placed JS Kit software which is a "tracking" and "hacking" software on her Defend our
Freedoms Foundation, Inc. websites and blogs in order to "track" and "hack" individuals and
their computers who have visited her websites. Defendant Yosef Taitz has a server in Orly Taitz,
et al and his home in order to complete their illegal activities. Defendants' have been slandering
Plaintiffs herein, their staff and their businesses; posting libel regarding the Plaintiffs, their staff
and their businesses on the internet and through mass maiJings on the internet; and harassing the
Plaintiffs, their staff and their businesses. Detendants DOES 1 through 200 are Defendants
internet providers, phone companies, e-mail providers, streamlines and unknown Defendants
who have allowed Defendants', Orly Taitz alk/a Dr. Orly Taitz a/k/a Law Offices of Orly Taitz
alk/a Orly Taitz, Inc., Defendant our Freedoms Foundation, Inc., The Sankey Finn, Sankey
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Investigations, Inc., Neil Sankey; Linda Sue Belcher alk/a Linda S. Belcher alkla Linda Starr
alk/a Newwomensparty a/k/a Stitchenwitch alk/a Eva Braun aIk/a Web Sergeant alkla Katy aIk/a
www.obamacitizenshipdebate.org, Plains Radio Network alk/a Plains Radio Network, Inc. aIkIa
Plains Radio and Mr. and Mrs. Hale, to continue their illegal and dangerous behaviors against
Plaintiffs, their staff and their businesses. As a result, Plaintiffs, their staff and their businesses
have been severely damaged as outlined herein.
II. JURISDICTION AND VENU:f~
1. This case involves diversity of citizenship and this Court has jurisdiction pursuant
to 28 U.S.c. § 1332(a).
2. This case further arises under the Constitution and laws of the United States and
presents a federal question within this Court's jurisdiction under Article III of the
Constitution and 28 U.S.C. § 1331.
3. Venue is proper in this Court under 28 U.S.c. § 139l(b).
III. PARTIES
4. Plaintiff, Lisa Liberi [hereinafter "Liberi"] is an adult individual with a business
address of 555 Andorra Glen COUli, Suite 12, Lafayette Hill, PA 19444-2531;
5. Plaintiff, Philip J. Berg, Esquire [hereinafter at times "Berg"] is an adult
individual with a business address of 555 Andorra Glen Court, Suite 12, Lafayette
Hill, P A 19444-2531;
6. Plaintiff, The Law Offices of Philip J. Berg is a law firm, with a staff, owned and
operated by Plaintiff PhiJip J. Berg, with a business address of 555 Andorra Glen
Court, Suite 12, Lafayette Hill, PA 19444-2531;
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7. Plaintiff: Evelyn Adams [hereinafter at times "Adams"] is an adult individual with
a residential address of Route 1, Box 106 BB, Wynnewood, Oklahoma 73098;
8. Plaintiff, Lisa M. Ostella [hereinafter "Ostella"] is an adult individual with a
residential address of2227 US Highway 1, #245, North Brunswick, NJ 08902-4402.
9. Plaintiff Go Excel Global is a Web Communications company owned and
operated by Lisa M. Ostella with a business address of 2227 US Highway], #245,
North Brunswick, NJ 08902-4402;
10. Defendant, Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices ofOrty Taitz, aIkIa
WWW.ORLYTAr(ZESQ.COM alk/a WWW.REPUBX.COM a/k/a orty Taitz, [nco
[hereinafter "Taitz"] is a licensed Attomey with a business addresses of 26302 La
Paz, Suite 211, Mission Viejo, CA 92691 and 29839 S. Margarita Pkwy, Rancho
Santa Margarita, CA 92688, and a home address of 31912 Monarch Crest, Laguna
Niguel, CA 92677;
11. Defendant, Defend our Freedoms Foundation, [nco is incorporated as a non-profit
organization owned and operated by Defendant Orly Taitz a/k/a Dr. Orly Taitz a/k/a
Law Offices of Orly Taitz with a business address of 26302 La Paz, Suite 211,
Mission Viejo, CA 92691;
12. Defendant Y osef Taitz [hereinafter "Yosef'] is an adult individual with a home
address of 31912 Monarch Crest, Laguna Niguel, CA 92677;
13. Defendant, The Sankey Film [hereinafter "Sankey Firm"] is owned and operated
by Neil Sankey. The Sankey Finn has a business address of 2470 Steams Street,
# 162, Simi Valley, Califomia, 93063 and Post Office Box 8298, Mission Hi11s,
Califomia 91346;
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14. Defendant Sankey Investigations, Inc. is incorporated in the State of California.
Sankey Investigations, Inc. is owned and operated by Neil Sankey and is a private
investigation Company. Sankey Investigations has a business address of Post Office
Box 8298, Mission Hills, California 91346 and 2470 Stearns Street, #162, Simi
Valley, California, 93063;
15. Defendant, Neil Sankey [hereinafter "Sankey"] is an adult individual and owner
of The Sankey Firm and with an business address of 2470 Stearns Street, #162, Simi
Valley, California, 93063 and Post Office Box 8298, Mission Hills, California 91346;
16. Defendant James Sundquist [hereinafter "Sundquist"]~ is an adult individual,
owner and operator as Director of Defendant Rock Salt Publishing, with a business
address of 55) Valley Road, Suite 123, Upper Montclair, New Jersey 07043;
17. Defendant Rock Salt Publishing [hereinafter "Rock Salt"] is a company owned
and operated by James Sundquist, as Director with a business address of 551 Valley
Road, Suite 123, Upper Montclair, New Jersey 07043;
18. Detendant, Linda Sue Belcher a/k/a Linda S. Belcher alk/a Linda Starr a/k/a
Newwomensparty alkla Stitchenwitch alk/a Eva Brau a/k/a Web Sergeant alk/a
www.obamacitzenshipdebate.org [hereinafter "Linda"] is an adult individual with a
home address of20 1 Paris Street, Castroville, Texas 78009-4516;
19. Defendant Edgar (Ed) Hale [hereinafter at times "Mr. Hale"] is an adult individual
with a residential and business address of 1401 Bowie Street, Wellington, Texas
79095;
20. Defendant Caren Hale [hereinafter at times "Mrs. Hale"] is an adult individual
with a residential and business address of 1401 Bowie Street, Wellington, Texas
79095;
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21. Defendant, Plains Radio Network a/k/a Plains Radio Network, Inc. a/k/a Plains
Radio,] hereinafter at times "Plains Radio"] is a business and owned and operated by
Defendants Edgar (Ed) and Caren Hale with a principal address of 1401 Bowie Street,
Wellington, Texas 79095;
22. Defendant, Bar H. Fanns [hereinafter at times "Bar H" is a business owned and
operated by Defendants Edgar (Ed) and Caren Hale with a principal address of 1401
Bowie Street Wellin!:,11:on, Texas 79095;
23. Defendant, KPRN AM 1610 [hereinafter "KPRN"] is a business owned and
operated by Defendants, Edgar (Ed) and Caren Hale with a principal address of 1401
Bowie Street, Wellington, Texas 79095; and
24. Defendants, DOES I through 200 are unknown Defendants who provide the
internet access, streaming, e-mail, broadcasting, etc., for Plains Radio, KPRN, Bar H
Fanns and Mr. and Mrs. Hale.
IV. FACTUAL ALLEGATIONS RELATING TO ORLY TAITZ alkla

DR. ORLY TAlTZ alkla LAW OFFICES OF ORLY TAITZ alkla
WWW.ORLYTAITZESQ.COM alkla WWW.REPlJBX.COM alkla
ORLY TAITZ, INC., DEFEND OUR FREEDOMS FOUNDATION,
INC. and YOSEF TAITZ
25. 1n or about November 2008, the name orty Taitz appeared as filing legal
complaints in Sacramento, California on behalf of Alan Keyes and other Plaintiffs
and against the Calitornia Secretary of State and other Defendants regarding the
Ban'y Soetoro a/k/a Barack H. Obama citizenship issues'. Ironically, Taitz
I Ambassador Dr. A/an K!!J!gs. el al. v. Calif(mlia SecrelaT}, o(Stale Debra Bowen, et ai. Superior Court of the State
of CaHfomia for the County of Sacramento, Case No. 34-2008-80000096-CU-WM-GDS, which was recently
dismissed.
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plagiarized the work of Philip J. Berg, his Assistant Lisa and his law practice, Law
Offices of Philip 1. Berg.
26. Orly Taitz set up the business name of Defend our Freedoms Foundation, Inc. as a
non-profit Organization with a Federal Tax Identification number of 26-4328440.
However, when you attempt to verify the Federal Tax Identification number it comes
back invali(f.
27. Taitz had a website at drorly.blogspot.com, which did have some nefarious
functions and Taitz authorized those functions. At this time, Ostella assumed it was
because Taitz did not understand the internet. There was a third [3 rd ] party program
added to drorly.blogspot.com. This program was collecting information from
everyone who was visiting and posting at Taitz website (drorly.blogspot.com) and
transferring the individuals' private data to an unknown server. Taitz was well aware
of these functions as she authorized them and had the head web master install the
software on December 24,2008.
28. The data transfer took place via a java sctipt program plus a put command that
enabled FTP transfer. The java program is what caused trouble with people using
Taitz's website located at drorly.blogspot.com. Most computers are set up with
security tirewalls that do not allow easy data collection.
29. Ostella purchased and owned the defendourfreedoms. us and
defendourfreedoms.org, web sites and she maintained them on the server that she
(OsteIla) paid for. Ostella allowed Taitz to use said websites. Ostella supported Taitz
and has always been involved with politics, campaigns and causes. So when Ostella
saw the antics with the java script program on the other blog (drorly.blogspot.com),
2 h\!P...:!1!y"'\£\'y~IDgIL~~~~t~!;,l,'<::91]!lQ.Q.~.IJQ~11Jl5J>.:2?jJ2~"2~:'..U_~8-=HCJ~~gIQmiJl=.S ubml~
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and it was never clear on how much Taitz realized was going on, Ostella took Taitz
over here to use Ostella's accounts. All of the DefendOurFreedoms domain names
were and are on Ostella's web accounts.
30. DefendOurFreedoms.org, owned by Lisa Ostella was and is hosted at Ostel1a's
server. It is a stand-alone server on rack rental at HE.Net. Ostella had and has full
access to this server and no other accounts are on this server but hers. Ostella verified
her IP lugs to ensure the website was not "hacked". The IP Address logs show every
IP address, which is a computer's identification that entered the website and/or server.
There has never been any other IP addresses that have appeared on the IP logs other
than Ostella's. Hence, the website and/or server have never been "hacked".
31. As for DetendOurFrecdoms.us, that was hosted at GoDaddy under Ostel1a's
reseller account. This domain did not point to a website, it pointed to a blog.
Specifically, it pointed to QuickBlogcast. This is very important to understand. A
blog is not a website. The domain points to a database label. If the blog had been
"hacked", someone would have had to break into GoDaddy's database files and know
what customer number the database files was under. This would have compromised a
number of other accounts with more damage other than a change in the e-mail
address. GoDaddy would have had to issue a notification to all customers. Of
course, GoDaddy never issued such a notification because the blog was never
"hacked".
32. None of the DefendOurFreedoms website were ever hacked or sabotaged, as Taitz
claimed. Being unable to access a website due to network latency does not equal
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"hacking". Traffic, congestion, line repairs affect network flow and all can always be
3
checked on the Internet Traffic RepOlt .
33. Another webmaster who goes by "creativeogre" and Ostella called Taitz and
explained to Taitz her websites had never been hacked.
34. On or about March 9, 2009, another issue arose with Taitz and her PayPal
account. Taitz had volunteers with access to the coding of her PayPal account on her
blogs. One of Taitz's volunteers or Taitz herself changed 1'aitz e-mail address
associated with her PayPal account oriy.taitz(lzJ,gmail.com to
oriy.taitz@gmail.org.
35. Bob Stevens, Taitz's Head Webmaster created four [4] e-mail accounts for Taitz.
Taitz was supplied all her e-mail accounts which included, amongst others,
Qr.tall?c@grrmiL~om. Despite knowing this was her own e-mail address, Ta1tz sent a
mass e-mailing out with the below statement and posted the statement on her website,
knowing it to be false.
Breaking and entering into my Paypal account

:')LaT),:;":" H<!f.}~.~ ·x'.:!! (;;; !·i~!< ~~')UI/::-, /,..:~ ,"i.)1! ~,~p:~",.·, I t~::,','~j::-1
1,;.+1-:; ~nc ~" 1,,~·1. 'V.'l:<nf.i F,.;'j.fh<!:'nt ':.,r(\~!:~:~
"." (1:
, .,l
36. As a result, 1'aitz was not recelvmg her donations. Donations received were
rejected by PayPal as the e-mail address was incorrect and no such e-mail address
3 http://www.internettrafficreport.com
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existed. Since the e-mail address did not exist, PayPal rejected the donations and sent
them back to the contributors. Hence. the donations were not stolen or misdirected as
Taitz claimed, which Taitz was well aware.
37. Despite the fact Taitz was well aware her websites and PayPal accounts had
never been "hacked" or tampered with, 011 or about April 2. 2009, Taitz wrote to the
U.S. Supreme COUl1 Justices 4 seeking help in an investigation regarding a criminal
complaint she had tiled with the Federal Bureau of Investigations regarding hacking
into her websites and tampering of her PayPal accounts, and other things. Taitz sent
this same letter to the Secret Service and other Governmental Law Enforcement
Agencies. Taitz was aware the infornlation she gave to the Federal Bureau of
Investigations was tillse and she was wen aware she was filing a false report.
38. As a result of the false report made by Orly Taitz to the Federal Government,
Ostella informed Taitz that she must clear up the false reports or Ostella was
removing Taitz from her websites and server. Taitz refused to clear this matter up
and refused to retract her falsified police reports. When Taitz refused to clear up this
report, Ostella told Taitz she had to move her sites. Taitz asked Ostella to give her
thil1y [30] days so she would be able to find a new host.
39. Instead of Taitz locating a new server, she gave an interview to World Net Daili
on April 4 th , 2009 elaborating on her scheme to mislead the public and law
4 A copy of the letter Orly Taitz sent to the U.S. Supreme Court, which was posted by Orly Taitz on April 2. 2009 at
4:20 p.m. can be located at: h1trE(/defcndour.fi~~@,!!!;i.l1et!~J!09!04lQ'yJ;lJ?~J).:J!m"r~19-thc-w[eme-courtrequest-of
£.QQI1c rat iQ!l=-~j.ili~ th!:Clb i ~j!!'y_~.s I j gaJ it )D"i!~)(
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enforcement into believing her wcbsitcs and PayPal accounts were "hacked" and
"sabotaged". Again, Taitz was well aware none of these events took place.
40. Although Ostella continued infonning and explaining to Taitz her websites had
never been "hacked", Taitz continued to spread the falsified story. As a result,
Ostella told Taitz she had to immediately move her sites.
41. Taitz found a person by the name of Jesse Smith who was to be her new web host.
She authorized Ostella to transfer the domains to him. Jesse Smith first contacted
Ostella on April 9,2009. Ostella told him to initiate the transfer. Jesse Smith started
the initiation on April 10, 2009 through Network Solutions. Ostella accepted the
transfer request and the transfer process started.
42. Now, remember, the site was not a wehsite. It is a blog. The domain pointed to a
database label. Normally, when a domain is transfened from a website, the domain
just switches from the one site to the new site smoothly. It will leave the old site still
showing; but with the virtual host name. In order to move a blog site, which is a
database, the account would delete when the transfer activates. To protect al1 the
data, Ostella moved the account onto DefendOurFreedoms.Net, then unlocked the
domain and authorized the transfer. For whatever reason, this outraged Taitz and
Taitz accused Ostella of being defiant.
43. On April 12, 2009, Taitz went on the Evil Conservative Blogcast 6 and told the
audience that Ostella had threatened her and altered the focus of her story onto the
PayPalaccount.
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44. For protection purposes, Ostella locked the website access of all of her (Ostella's)
websites. Ostella changed the PayPal script in the donations button to reflect her own
account and removed Taitz's accounts from the site. Ostella placed notifications on
all her webpages that the sites were no longer 1'aitz's Defend our Freedom
Foundation, Inc. and Ostella posted the following links to ensure people understood
1'aitz's sites were never"hacked".
• Understanding the lnternet 101

hUn:!/clefcndollrfreeQor!l~J.et!20Q9I.Q1LL;;llwderstanding-the-intClllet-191.aspx
45. Once Ostella posted the above, she received the following Ceizc [sic] and Desist
from 1'aitz, which was untrue. Ostella at all times owned the domains and servers
that the domains were located.
"Ceize and Desist

04.13.09.
Ms. Ostella,
This is a Ceize and Desist Letter, advising you to stop immediately

operation of sites and shut down DefendOurFreedoms.net;
DefendOurFreedoms.US; DefendOurFreedoms.Org, and
DefendOurFreedoms.Com and any other relating sites that you have been
operating after I requested transfer. You have used those sites for
defamatory purpose of me and my foundation and you have used my
hkeness and my material without my permission. If you do not shut down
above sites immediately, fmiher actions wi11 be taken.
Sincerely,
Dr. Or1y 1'aitz Esq

26302 La Paz ste 211
Mission Viejo Ca 92691"
46. Moreover, 1'aitz, placed JS Kit software which is a "tracking" and "hacking"
software on her Defend our Freedoms Foundation, Inc. websites and blogs, this
softwith the exception of the DefendourFreedoms websites owned by Lisa Ostella, in
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order to "track" and "hack" individuals and their computers who have visited her
websites. Defendant Yosef has a server in Taitz, and his home in order to complete
their illegal activities.
47. Unfortunately, Liberi's computer was infected with Taitz's JS Kit Software and a
remote server was placed on Liberi's home computer by accessing Taitz website.
48. Taitz began changing her story to focus on "hacking" of her PayPal account, even
though it never happened. Taitz was literally telling people that her PayPal account
was "hacked", knowing this to be false. In fact, there is no way Taitz's PayPal
account could have been hacked. PayPal's servers that hold individuals' private data
are not connected directly to the internet. There are servers in between. So the server
an individual logs into in order to access their PayPal account, is not the same server
that houses the infomlation. If someone was able to break into that system, PayPal
would have had to notify all customers of a breach and shut all processes down to
investigate. Taitz literally had people thinking that her e-mail address was changed
from within the PayPal account, again knowing this information to be false.
49. Taitz never launched an investigation with PayPal in reference to her "hacking"
allegations. Instead, Taitz made blatant statements saying money was stolen out of
her account. Again, the entire time knowing this infonnation was false.
50. Because of Taitz false statements regarding her PayPal account being "hacked",
Ostella posted the following:
• Understanding the Internet 102 - PayPalGate
b.!.tQ)Idcfcndourireedoms.net/2009/04/ 14!understand ing-thc-intcrnet-I 02-

PayPalgale.asPK
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51. The change was in the e-mail address on the blogsite. Originally, the PayPal
donate code on the blogsite was in an encrypted script that PayPal makes available for
copying and pasting into blogs and websites. But GoOaddy made some updates in
the design in February 2009. The updates didn't function with the PayPal script
encryption. See the below e-mail received from GoOaddy.
Subject: Script Issue With Quick Blogcast
From: "Andrew" <achristensen@godaddy.com>
Date: Tue, April 21, 2009 6:40 am
To: info@goexcelglobaLcom
On February 11, 2009, Lisa, was advised that the PayPal button links do
not work on the sidebar within the Quick Blogcast.
Andrew S.
Team Sapphire
Customer Care Center
52. Taitz is no stranger to falsifying stories and falsely claiming to be the victim of
"hacking" of her websites. On December 12, 2009 Taitz and Bob Stevens, Taitz
Head Webmaster, began telling people that "Obama thugs" had her business/dental
site, dnaii/"com. shut down. They wanted this infonnation immediately posted on the
blogs. Ostella stopped the posting of this intonnation by looking up the domain and
finding Taitz's prior host data. In short what Taitz had done was switched her own
domain off the website. Taitz told Ostella she (Taitz) was signing up for a web tramc
program. Taitz told Ostella she (Taitz) was going to give Ostella access to get her
domain back and Ostella would be her new hired webmaster for Taitz's dental
websites. Ostella was never given access. Taitz's dental websites are up and running
and Ostella is unsure who Taitz's webmaster is.
53. On April 12, 2009, Ostella received the following e-mail containing false and
incomplete infonnation further slandering Ostella. This e-mail was sent to an
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unknown number of undisclosed recipients as well as carbon copied to Ostella and
the Chicago FBI:
----- Original Message ----
From: Orly Taitz
To: chuckolb
Cc: Li~a Ostell.S! ; Chicago FBI
Sent: Sunday, April 12, 20092:55 PM
Subject: Re: IMMEDIATE I Dr. Orly Taitz I Redirect

defendourfreedoms.net I Phil - therightsideoflife.com - the Conservative
Sanctuary
no, things are not right it is being investigate by the FBI. I cannot post
anything at the moment, Lisa Ostella, web master, has blocked me out
of my own blog and refuses to give me codes for my own
blog
Orly Taitz DDS Esq
Mission Viejo Ca 92691
29839 S. Margarita Pkwy
Rancho Santa Margarita Ca 92688
ph. w 949-586-8 I 10 c-949-683-5411
fax 949-586-2082
54. It was also discovered Taitz had authorized placement of JS Kit Software on all
her Defend our Freedoms Foundation, Inc. websites and blogs. Again, this does not
include the DefendourFrcedome websites owned and operated by Ostella. JS Kit
software is tracking software used in "hacking" websites and personal computers. In
the J S Kit software is a function that places remote servers on individual and
company computer systems in order to allow the person using JS Kit software, in this
case, Taitz, Yoself and other unknown individuals on their behalf to illegally enter the
individuals and company computers to steal and transfer data. This remote server
function was located on Liberi's computer.
55. Yosef, Taitz husband and Taitz have implemented their own server in their home
located in Laguna Niguel to utilize the "tracking" and "hacking" of individual and
company computers who have visited Taitz websites and blogs. Yosef is assisting his
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wife, and their companies, Orly Taitz. Inc., Defend our Freedoms Foundation, Inc.,
and Taitz, in her illegal activities. I-fence, it is not Plaintiffs Ostella or Liberi
"hacking" Taitz andlor Defend our Freedoms Foundation, Inc. websites, blogs andlor
PayPal accounts, it is Taitz, her husband Yosef and other unknown named individuals
on their behalf who are "hacking" the computers of the Plaintiffs and other
individuals and companies who have visited any oftheir websites andlor blogs.
56. On or about April 12,2009, Berg received an e-mail from Taitz stating he was to
"Ceize and Desist" [sic] from using Taitz's Quo Warranto, which Taitz claimed was
sent to Berg inadvertently. In this same e-mail, Taitz made false allegations claiming
his (Berg's) Paralegal, Lisa Liberi had an extensive criminal record involving
amongst other things identity theft. Taitz went on further in her e-mail to Berg that
Libert's husband was currently on parole and he had sct up two (2) accounts
accepting credit cards on Berg's "charitable toundation", again all of which was
falsified and fabricated by Taitz. Taitz in her e-mail stated as an officer of the Court
she was obligated to send the information to the "FBI", Attorney General of
California and San Bernardino County District Attorney since Lisa Liberi had an
eight [8] year conviction in San Bernardino County, California. Taitz in her e-mail
infonlled Berg that she believed that Berg, as an Officer of the Court, as well and a
fonner Assistant Attorney General of Pennsylvania, should join her in issuing a joint
Complaint and demand for investigation from the authorities. Taitz then forwarded
the e-mail addressed to Berg to an undisclosed number of recipients.
57. Liberi then received an e-mail from Mr. Hale claiming Lisa Liberi was stealing
money from Taitz's PayPal account. Mr. Hale's e-mail was forwarding an e-mail
sent out by mass mailing by Taitz stating, "/ also received information that her
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husband. "1'/10 is cllrrent(v on parole. is an owner of 2 of'accolll1tS. accepting credit
cards on your charitable foundation web site." At all times, Taitz and Mr. Hale were
well aware this infonnation was false and untrue.
From: Ed Hale <ed(d)barhfarms.net>

~--~ .. ~-.-
Date: Mon. Apr 13, 2009 at 9:58 PM

Subject: Fwd: Ceizc and Desist demand to file a joint FBI complaint
To: Lisa Liberi <lisaliberiu~gmail.com>
"Well. I sure hope that you \\'ill enjoy your time in prison. We now have
you as \VC ahve undercover where you diverted funds from Dr Orly to
your website, We have had :2 people come t()rward witb Pay Pal rcciepts
proving you arc a their. Now me and Plains radio have been proven right
You and your whole bunch will wind up in jaih. "rhis is a great day for
Plains Radio and Ed Hale."'
----- Forwarded Message ----

From: "Orly Taitz" <dr taitz(iilyahqg.com>
To: "mark westmann" <!Il\vestJlwnn 13(c/Jgmail.com>, "Ed Hale
PlainsRadio" <parhfarms(a{gmail.com>
Sent: Monday, April13, 2009 11:01:25 PM (GMT -0600)
America/Chicago
Subject: Fw: Ceize and Desist, demand to file a joint FBI complaint
Orty Taitz DDS Esq
26302 La paz ste 211
ph. w Y49-586-SII 0 c-949-683-5411
fax 949-586-2082
--- On Sun, 4112/09, Orly Taitz <<lr lait{g~y{thoQ:~onl> wrote:
From: Orly Taitz <dr taitz(~vvahoo.eom>
Subject: Ceize and Desist, demand to file a joint FBI complaint
To: "Phil J Berg Esq (pvt)" <P)JiJ.!ll~Ig(alg!}1ail.coJn>
Cc: "Orly Taitz" <dr taitziii)yahoo.con}>
Date: Sunday, April 12,2009, 10:01 AM
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04.12.09.
Mr. Phillip Berg,
"this is to infOlID you that a few days ago I have forwarded my quo
warranto pleadings to Mr. John Hemenway, since he agreed to be my local
co-counsel in Washington DC. This was a confidential communication
and Mr. Hemenway stated, that mistakenly he has forwarded those
pleadings to you. Shortly thereafter you have sent a press release, stating
that you will be filing Quo Warranto action. This is a Ceize and Desist
letter, demanding that you do not use my pleadings and confidential
information in any way, shape or f()fJTI, as you received those in elTor
without my authorization.
Additionally, I received information from a licensed Private
investigator, with 20 years of experience with Scotland Yard and 12 years
of experience in US, that your paralegal Lisa Liberi has an extensive
criminal record, involving fraud, forgery of documents and identity theft.
See attached file. I also received infonnation that her husband, who is
currently on parole, is an owner of 2 of accounts, accepting credit cards on
your charitable foundation web site. As an officer of the court I am
obligated to forward this information to the authorities: FBI, Attorney
General of California and San Bernardino County Distict Attorney, since
Lisa Liberi had a 8 year conviction in San Bernardino County, California.
I believe that you, as an officer of the court, as well and a former Assitant
Attorney General of Pennsylvania, should join me in issuing a joint
complaint and demand for investigation from the above listed authorities.
Dr. Orly Taitz Esq"


ph. w 949-586-8110 c-949-683-541I
fax 949-586-2082
58. It should be noted, Berg does -not have a charitable foundation website. He does
~
have a website with a donation button which allows people to donate one (1) of two
(2) ways, PayPal or by a separate credit card company, which Berg is the only party
with access.
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59. Moreover, Liberi has nothing to do with the web mastering of his (Berg's)
website, Taitz website or any other website. The coding for the donate buttons and
the accounts which donations go into are all done by a third party webmaster and is
all traceable.
60. Berg never received the "supposed" Quo WalTanto Taitz is refelTing to above, nor
has he seen it. However, what Liberi received from Allan Edward Buck, was a Writ
of Mandamus and a Writ of Quo Warranto that he himselfhad drafted and did all the
work on. If this is what Taitz is spreading around, it is not her work, but yet the work
of another party.
61. Plaintiffs then learned Orly Taitz had people go onto among others, Berg's
website at obamacrimes.com, download all the briefs investigated and prepared by
Berg and his assistant, copy the contents and Taitz then filed the briefs in Court
claiming the work to be hers, again whieh is plagiarism of Berg's and his assistant's
work, which is owned by the Law Offices of Philip J. Berg.
62. On or about April 14, 2009, Liberi received an e-mail from a third party that
contained a post on Plains Radio owned by Mr. and Mrs. Hale 7• The post was made
by Defendant Katy and states she received an e-mail from Taitz stating the following.
This same e-mail was also sent to an unknown number of undisclosed recipients:
Dr. Orly's site has been taken over by Obots!! E-mail from Orly
'This is an e-mail I recieved from her this afternoon:
Katy"
"This is a nightmare. I had hacking into my Pay Pal account. (see dossier #5 in
attachment), the e-mail address on my PayPaJ account was changed, sol would not be
able to get donations. It was reported by a number of donors and I have filed a complaint
with the FBI. My blog was set up by a volunteer Lisa Ostella. She is the web master and
I:\FORMS\Liberi. Berg. Law Offices ofPJB, Adams and OstelJa Complaint for Dflmages
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:o;hc has the codes for the blog. She demanded that [ take back my complaint to FBI,
claiming that the change of e-mail address was done by a volunteer by name Fran, that
she banned Fran from the site, that it took care of the problem and [ need to take back my
complaint of hacking with FB\. as it gives her. as a web master a bad name. I refused
to do so, stating that it is a legitimate complainl, I want them to investigate. At that time
she stated that I will need to get my blog of her server, if [ don't take back the FBI
complaint.
r found somebody else to host the blog, however according to volunteers she never
forwarded the release and the codes to the platfonn company Go Daddy, she locked me
out of my own foundation site and refuses to give me the access codes. She has posted a
defamatory statement, claiming that r authorized hacking into my own account and that I
made bogus claims. This is totally ridiculous in light of the fact that I have statements
from the donors and I lost donations. The FBI agent in charge of this investigation is
Nathan Le, Orange county. CA, FBI, cyber crimes unit, phone 714-245-5328; 310-710
3459.
orty Taitz DDS Esq

I
2()302 La Paz ste 211
Mission Viejo Ca 92()91
ph. w 949-Sg6-811 0 c-949-683-5411
fax 949-586-2082 "
63. Again, Taitz was aware all this information was false. Ostella is a Webmaster by
trade, Taitz was maliciously slandering and posting libel about Ostella to punish and
harm Ostella for telling the truth, which has effected Ostella's company, Go Excel
Global.
64. On or about April 17, 2009 at approximately 9:31 a.m. Taitz sent out a mass e-
mailing of slander and libel pertaining to Liberi, Ostella, Berg and the Law Offices of
Philip .r. Berg. Liberi received an e-mail which contained Taitz Dossier No. Six (6)
which was nothing more than a vicious attack on Ostella and Liberi. Taitz fabricated
false allegations about both Ostella and Liberi. Taitz, gave personal identifying
information regarding Liberi including her entire Social Security. Taitz made many
false statements including but not limitt:d to the following: Ostella locked Taitz out of
her website instead of transferring the access codes and domains; Ostella posted
Page A21 21
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bizarre defamatory statements that Taitz authorized hacking into her own account;
Taitz claimed she received reports that some defamatory comments were made under
alias usual1y used by Lisa Liberi, assistant for Attorney Philip J. Berg; Taitz
insinuated Ostella was taking monies donated to her; Liberi had an extensive criminal
record going back to 1990; Liberi, among other things. engaged in falsification of
police reports, manipulation of credit bureau reports; counterfeiting of court
documents; Liberi had Twenty-One Thousand [$21,000] Dollars per month in
restitution; several sources confinned that Liberi lives in N M; they confirmed her
date of birth and appearance as matching the ones on file with the San Bernardino,
CA district attorney; Libert launched vicious attacks against Taitz and then states
Liberi disagreed with her and this was the vicious attack. The list goes on. Dossier
No.6 by Taitz own admission was an open letter posted on the internet and forwarded
to 26,000 outlets of US and international media. In addition, Taitz sent this e-maiJ to
an unknown number of undisclosed recipients asking them to post the information on
their website. Again, included in this was Liberi's full Social Security number that
Taitz obtained without a permissible purpose from Defendants, Neil Sankey, The
Sankey Finn and Sankey Investigations, Inc. Moreover, Taitz sent this Dossier No.6
to Attnrney General Eric Holder; Solicitor General Elena Kagan; Director of FBI
Robelt Mueller; FBI Cyber Crime division, Orange County CA. Officer Nathan Le;
Director of Secret Service Mark Sullivan; Chief of Security of the Supreme Court,
Officer Christine Giaccio; Chief Justice of the Supreme Court John Roberts; and
Legal Counsel to the Chairman of Joint Chiefs of Staff Admiral Mullen, Captain
Crawford. Taitz was well aware this information was false, and it was illegal to
transmit a third (3fd) pa1ties personal identifying infOimation, including their Social
I:\FORMS\Liberi. Berg. Law Offices ofPJB. Adams and Ostella Complaint for Damages
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Security number which Taitz had absolutely no permissible purpose to obtain;
distribute via the internet, bye-mail and posting a person's private confidential
information on wcbsites. A copy of Taitz Dossier No.6 will be provided to the
Court; with a request that it be placed "u"del' ~;eal". Taitz also posted this on her
website at Defend our Freedoms.s Below is only one of the many e-mails Taitz sent
on this date
-------OrigiI/{II Alessagc------
Dale: Fri. 17 Apr 2009 09: 10:41 -0700

Fra In: "'--'-'" -'-'~~L'!.CC'""""~:':'"
Suqject: More explosive information dossier #6
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26302 La Paz ste 21 I
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Rancho Santa Margarita Ca <!2688
ph. w 949-5116-8110 c-949-6l\3-541I
fax 949-586-20112
Dossier #6 new.doc
89601( \{ie',;_5t..'::JjJ~~IJ" 12.Q..'Y!1IQ£1.Q
65. April 13,2009, Taitz was on a blog talk radio station, The Dame Truth 9 , which is
an internet blog talk radio program. The entire time Taitz was on the air she did
nothing but slander Liberi with the above referenced information.

1o
66. Taitz then posted on her website Defend our Freedoms: "More on Lisa Liberi,
contact her probation officer in Santa Fe New Mexico 505-827-8627. She is not
allowed to be anywhere near other people's credit cards, By Orlytaitz April 17,2009"
67. On April 18,2009, Taitz posted further slander and libel about Ostel1a and Liberi,
on her website, Defend our Freedoms II:
Dr. Orly Taitz Esquire
Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA
92691. e-mail: drtaitz@yahoo.com
Every day I get such evidence of missing or misdirected funds
"Every day I get such receipts, showing that my former web master Lisa Ostella
(posts under name Calpernia) has redirected donations to herself, to her e-mail
address. Currently, as this was uncovered, she created new web sites Defend
our freedoms .org, .net and continues the scheme by making those sites similar
to myoid ones and using the foundation name to steal more donations. She
created a visa donation site with her e-mail account Go Excell Global,
underneath she posted a PayPal button showing my foundation Defend 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 foundation. even though all ties with
!O http://ZI6.22l.JJ!2.26&logger/Q9stLMore-ol!:~.is<t:!dJ~!i.-cont'!c..L~.b£!:~J2.r:.obat ion-o !licer-i n-Santa-F e- N ew- Mex ieo
505 -82 7-8627-S.he- iS..:DDt -all9Yic.:l-to-l;!c-anywhcn:;:I1£ar-S!th.9J:J2<;Qru~s-(;Ied !J:.:f.<1!:.ds .asJ2~
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her were severed a couple of weeks ago, when I found out about this scheme
and I closed the Pay Pal account completely. Any person, whose donations were
stolen by Lisa Ostella aka Lisa Current aka Calpernia is asked to report this to
his local police or sheriff's department. As I found out, she appears to be
connected to Lisa Liberi, who is still working for attorney Phillip Berg. Please see
my dossier #6, Lisa Liberi aka Lisa Richardson aka Lisa Courvelle has a long
criminal record, that includes grand theft, forgery of documents, forgery of seal,
falsification of police reports and credit statements, where financial institutions
were defrauded out of thousands of dollars. She claims to be a different Lisa
Uberi, living in PA, however she lives in NM and her probation officers are
Joanne Martinez 505-827-8627 and Dawn Helling (not sure about spelling) 505
476-2359."
68. Taitz then set-up another blog l2 where she was slandering and posting libel about
Ostella. Taitz set up the blog, orlytaitz.com and posted the following:
Don't be fooled
"My former web master Lisa Ostella has created an account that she called Defend Our
Freedoms Network and is soliciting donations, praying on unsuspecting readers that
would not notice the difference between Defend Our Freedoms Foundation and Defend
Our Freedoms Community. Please notice, your donations there will not go to the
foundation, they will go to her personal bank account. connected to her personal e-mail
address GoExceliGlobal. She posted underneath a PayPal logo with my e-mail address,
however I have closed the pay-pal account. If you want to give donations to the Defend
Our Freedoms Foundations, please, mail them to Defend Our Freedoms Foundation
26302 La Paz ste 211, Mission Viejo CA 92691"
This entry was posted on Saturday, April 18th, 2009 at 5:27 pm and is filed under
• !' . You can follow any responses to this entry through the
?fl feed. You can , or '"-"C":.~=.""",,:- from your own site."
69. On April 20, 2009, Mr. Hale had a radio show on at 9:00 p.m. Mr. Hale's Guest
was Orly Taitz. Orly Taitz did nothing but slander Ostella and Liberi on Mr. Hale's
radio show with the false allegations outlined above. Mr. Hale then went on falsely
stating Lisa Ostclla and Lisa Liberi were one and the same person and she was a
criminal.
12 http://www.orlytaitzesq.com/blog1I?p=71
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70. On April 21, 2009, Taitz posted the tollowing slander and libel against Ostella,
Liberi, Berg, the Law Offices of Philip 1. Berg and Adams on her website 13 :
"Dear Mr. Barrs,

I have reported the matter to the Sheriff's department and FBI. See below the receipt for
the police report with the name and phone number of the detective. The name of the FBI
agent is John Haas- supervisor of the cyber crimes unit 714-542-8825. Please spread the
word and give everybody the new web address for the Defend Our Freedoms
Foundation, which is
Please post this web address in as many blogs and sites as you can, so it will be picked
up quickly by different search engines and can be seen by all my readers. I have closed
my pay pal account and did not receive any pay pal or visa donation since 04.11.09. If
you or anybody else has given any donations after this date, using pay-pal, visa,
MasterCard, American Express and so on, believing that these donations were received
by the Defend Our Freedoms foundation, please demand a refund and report it to the
Sheriffs department, FBI and IRS as funds stolen from the non profit organization. I have
sent a Cease and Desist letter to Ms. Lisa Ostella, demanding that she forward to me the
access codes for the domains and the e-mail address list of the readers and stop
fraudulently operating under the name DefendOurFreedoms and stop drawing financial
profit from the Defend Our Freedoms name. I have also sent a Cease and Desist letter to
Evelyn Adams aka Momma E, talk show host David Levin and other parties who are
fraudulently advertising on the foundation website and drawing profit from it or from
reader lists given or sold to them by Ms. Ostella. Ironically Ms. Ostella has accused me of
collecting information on the readers. In reality I did not have any such information and
could not reach most of the readers, aside from ones whose names were in my
9LJi:.it:;;(c!{.l.3.tI99:..Qprne-mail account. Ms. Lisa Ostella is the one, who collected names
and e-mail addresses and she is currently fraudulently sending e-mails to these readers
using DefendOurFreedoms name. If you get such e-mail. please demand that she
immediately stop this practice and forward the list to me. as the president of the
foundation.
My primary goal is to expose all the fraud committed by Obama and removing him out of
office as an usurper, litigation against Ms. Ostella is secondary. I also need to get full
information in regards to full damage to the foundation and me, stemming from actions of
Ms. Ostella and parties that patronage her site and are aiding and abetting her.
I, also, sent an e-mail withdossier#6toMr.Phil Berg, advising him of lengthy criminal
record of grand theft, forgery, forgery of seal and other related crimes, committed by Ms.
Lisa Liberi, his paralegal and assistant, who reportedly was managing his fund raising
efforts. I believe Mr. Berg should not be using a person with such past in his fund raising
efforts and legal practice and should issue a statement advising the donors and
supporters, that Ms. Lisa Liberi is no longer employed by him or his foundation and that
he is reviewing all donations and all legal records handled by Ms. Lisa Liberi. I believe the
donors to Mr. Berg foundation should get assurances that their donations were used for
litigation and the cause and not to reimburse victims of Ms. Liberi's prior
schemes, reported to add to $21,000 per month.
Sincerely,
Dr. Orly Taitz, ESQ"
04.21.09.
- -......- . - -
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71. Unfortunately, Taitz continued sending out the above false statements and her
falsified Dossier No.6, every day since to websites and undisclosed recipients
requesting the posting of the infonnation along with her requests for everyone out
there to contact the FBI, the Orange County Sheriff's Department, a probation officer
in Santa Fe, New Mexico and report this infom1ation. It was nothing more than
harassment of Liberi, Ostella, Berg and the Law Oftlces of Philip J. Berg.
72. Taitz distributed this information including Liberi's full Social Security number,
date of birth, residcncy, ctc. to in excess of Two Hundred and Fifty Thousand
[250,000] individuals and businesses.
V.FACTUAL ALLEGATIONS RELATING TO DEFENDANTS' NEIL

SANKEY, THE SANKEY FIRM AND SANKEY INVESTIGATIONS
73. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth
herein at length.
74. Defendant Neil Sankey is a licensed private investigator and owns and operates
the Sankey Firm and Sankey Investigations, Inc. Sankey is aware aware of the State
and Federal laws peliaining to disclosure of third party information: the posting of
Social Security numbers; the disclosure of Social Security numbers and personal
identifying information; the permissible purpose requirement before disclosing any
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paliies Social Security number, date of birth, where they reside or any personal
information at all; the transmittal of Social Security numbers; State and Federal laws
against endangering, harassing, threatening and attempting to destroy any person's
life and/or reputation.
75. Despite knowing these very laws, Sankey through his investigation finns, the
Sankey Finn and Sankey Investigations, Inc. conspired with Taitz to destroy Liberi
and violated every privacy protection law; State and Federal laws for the disclosure,
posting, and transmitting a person's Social Security number and personal identifying
infonnation; and violated the permissible purpose rule. In so doing, Sankey through
his investigation finns, the Sankey Firm and Sankey Investigations, Inc. just to
mention a few, violated Liberi's First Amendment Rights to Privacy, First and
Fourteenth Amendment pertaining to invasion of privacy, a right to be safe, etc. See
below which is a copy of Neil Sankey's e-mails from the Sankey Film and Sankey
Investigations, Inc.
76. Neil Sankey, by his own admission received from Defendant Linda statements
that Liberi had a long criminal record going back to the 90's and Liberi had been
convicted of among other things, real estate fraud, falsification of police reports,
manipulation of credit burcau reports, and counterfeiting of documents, which is
completely false. Without bothering to investigate thc information sent by Linda,
Neil Sankey through his finns, the Sankey Finn and Sankey Investigations, Inc. sent
an e-mail out with the false information as if it were true. Since this e-mail was sent
Neil Sankey admitted to two [2] separate individuals that he did not investigation the
infonnation and could not verify it was in fact Liberi. See below.
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From: =~=~c=~~~~~~.==~·~
To: lisaostella@hotmail.com; ~ir taitz(d)yahoo.com

Subject: FW: »»»»»Urgent IMPORTANT INFO SAME
SUBJECT««<Date: Mon, 16 Mar 2009 14:57:13 -0700
PLEASE NOTE THE LAST LINE!
Thursday, April 10, 2008
New Mexico Woman Sentenced in Identity Theft: and Real Estate Fraud
Lisa Liberi, aka Lisa Richardson, 42, New Mexico, was sentenced in connection
with felony charges involving identity theft and forged > documents. Liberi
appeared in San Bernardino County. Rancho Cucamonga, Superior Court, on
March 21,2008. She was sentenced to a state prison term of 8 years, imposed but
stayed, and placed on supervised probation tor 3 years as part of a plea agreement.
Liberi was sentenced on ten felony counts ranging from Grand Theft, Forgery,
and Filing False Documents.
From 2000 to 2004, Liberi engaged in a complex fraud involving falsification of

police reports, manipUlation of credit bureau reports, loan fraud, and
counterfeiting of c0U11 documents resulting in hundreds of thousands of dollars in
losses to banks and credit unions.
In 2002, San Bernardino County Sheriffs Department personnel arrested> Liberi

on theft by false pretense charges. In July 2004. Investigators from the San
Bernardino County District Attorney's Real Estate Fraud Unit arrested Liberi at
the Ontario International Airport f()r additional felony charges while she was out
on bail.
She has an extensive criminal record going back to the 90's.
77. Instead of truly investigating the information, Sankey through his investigation
firms "The Sankey Film" and "Sankey Investigations" sent the information to Taitz
and a repmier with World Net Daily via e-mail along with Liberi's full social security
number, date of birth and where she resided. Also included, was Liberi's private
confidential information.
78. Sankey sent false and incorrect intormation claiming it to be associated with
Liberi. See below, Liberi's full Social Security has been replaced with X's in order to
protect the confidentiality of her Social Security number, however, in the original e-
mail her full Social Security number is disclosed:
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From: Neil SANKEY

Subject: FW: LISA LIBERI etc
To: dr taitz:Cl!yal19.9-,-gm:J
Date: Monday. April 13. 2009, 7:04 PM
Here is the Liberi stuff you requested. This is also what r sent to Bob Unruh
From: Neil SANKEY [mailto:nsankcy@thesankeyfinn.com] Sent: Friday, April
10, 2009 10:0 I AM To: Bob Unruh Subject: LISA LIBERI etc Bob here are some
bare facts about Berg's assistant. See below and attachments I don't know how
much of the story you have already, but is essentially about WHO she really is
and the questions that unfortunately brings up about Berg. Call, if you need to, at
your convenience. Neil Sankey Investigator & Consultant. THE SANKEY FIRM
Simi Valley, California 93063 nsankey@thesankeyfinn.com 805 520 3151 8] 8
2127615cel1
(Addendum)
LlSA RENEE UBERI. Bn 5/28/1965. 462-45-xxxx, XXX-XX-XXXX (& others)
According to the Police she was born COURVILLE and married a Richardson
(Possible Alan Douglas Richardson, currently residing in Las Vegas .) IF it was
the other way around, then the Courville is Bill Marshall Courville 11110/61 of
Houston, Tx. 457-7\-x I have several SS#'s for her and a LOT of AKA's. Her
rca] SS# is probably 462-45-xxxx. Most prominent otherwise are 563-60-xxxx,
572-17-x, 622-19-x She went BK in 2002 Her brother is probably Lawrence E
Morris of Fontana and Rancho Cuc, CA. He was born 1116/64 Her Husband,
Brent J, a Parolee, I have not researched that. Is probably Brent J McConnack
563-77, also uses 331-02-x There is also a Jerry HELLER and Douglas Cramer
look interesting, but where do you stop?
From: Neil SANKEY Subject: Bergs PayPal To: dl' taitz@yahoo.com Date:
Monday, April 13,2009, 7: 15 PMIt comes as no surprise to learn that the link to a
Visa donation to Berg, (as opposed to PayPal) has been removed. Neil
79. Sankey through his investigation finns, the Sankey Finn and Sankey
Investigations, Inc., did not have a pennissible purpose to obtain Liberi's Social
Security number or any other personal identifying infonnation of tiberi.
80. Moreover, Taitz did not have a pe1l11issible purpose to obtain or receive Liberi's
Social Security number and personal identifying infonnation. This was nothing more
than a complete l1bellslander and invasion of privacy not to mention it violated state
and federal laws.
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81. Furthelmore, Sankey through his investigation finns, the Sankey Finn and Sankey
Investigations, lnc., did not have any permissible purpose to disclose Liberi's Social
Security number to any third parties including a Reporter with World Net Daily.
82. In so doing, Sankey through his investigation fimls, the Sankey Finn and Sankey
Investigations, Inc., have severely endangered Liberi, her son and husband. Liberi
was given a confidential address as a result of her and her son be.ing victims of
domestic violence. Sankey, through his investigation finns, the Sankey Finn and
Sankey Investigations, Inc., have now disclosed Liberi's private personal information,
full Social Security number, date of hirth and where she lives and has allowed said
infonnation to be posted all over the internet hy Taitz and sent across the United
States and Internationally, by Taitz own admission.
83. Sankey through his investigation finns, the Sankey Finn and Sankey
Investigations, Inc., conspired with Taitz to ensure Liberi's Hfe was endangered and
ruined. Sankey was well aware ofTaitz threat to destroy Liberi to get to Berg and his
law practice.
84. Sankey through his investigations finns, the Sankey Firm and Sankey
Investigations, Inc., had a duty to abide by the California privacy Jaws. Because
Sankey through his investigation finns, the Sankey Finn and Sankey Investigations,
Inc., failed to ensure Taitz had a permissible purpose, which she did not, the fact
Sankey himself distributed Liberi's Social Security number and private personal
identifying infonnation through e-mail to a Reporter and Taitz, since Sankey and his
investigation firms failed to ensure and sign a contract with Taitz and the Reporter
with World Net Daily to ensure the confidentiality of Liberi's Social Security
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number, date of birth, and other private personal identifying infonnation, he is liable
for all the mass e-mailing Taitz did as ifhe sent the e-mails personally.
VI. FACTUAL ALLEGATIONS RELATING TO DEFENDANTS'
JAMES SUNDQUIST and ROCK SALT PUBLISHING
herein at length.
86. James Sundquist through his company, Rock Salt Publishing, accessed Ostella's
home address and began sending mass e-mailing with her private confidential
intonnation to an unknown number of undisclosed recipients. In so doing, Sundquist
through Rock Salt listed Ostella's phone number as his personal phone number in
order to entice people to call and harass Ostella. The original e-mail from James
Sundquist at Rock Salt Publishing is below, however, the X's placed were done so to
protect Ostella and are replacements from the actual address and phone number. The
X's were not part of the original e-mail and only added as this complaint will be
pubIi c record.
From: ".r ames S undquist" <H!~IS,sJIJ.t!illy_t.:I:iZJ)J1.11t;t>

Subject: re Lisa Ostella
Date: Tue. April 21. 2009 6:40 am
To: ~Q!lt!S;l@rtQriL!J~.!llfQ@h!~~~t~IY.il~&Ql:D
Dear Tom O'Neill & North Brunswick Republican Organization and
Breederville Director.
I need to alert you to the fact that Lisa Ostella has defrauded Dr.
Orly Taitz and has hijacked her website. I have just spoken at length
to Dr. Taitz.
You can call her to verify this. Dr. Taitz tel number is 949-683-5411.
I live in New Jersey and have written two books and have a massive
database in which I am able to expose what Lisa Ostella did to Dr.
Orly Taitz. including approximately a thousand radio stations whicll r
ti'equent as a guest.
Ms. Ostella's address and tel # are:
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Ostella, Lisa
brecdervi ILc-,-colJl
xxxxxxxxxxxxxxxxx
North Brunswick. New Jersey OR902
United State~
***
Sincerely,
James Sundquist
Director
Rock Salt Publishing
(732) xxx-xxxx
87. Sundquist through his company Rock Salt tiled false police reports with the
Brunswick, New Jersey FBI and local authorities falsely accusing Ostella of hijacking
Taitz's websites and diverting funds from Taitz's PayPal accounts.
88. Sundquist. through his company Rock Salt, posted on Taitz's website,
orlytaitz.com, that Ostella had hijacked Taitz's website and was diverting Taitz's
PayPal funds and that he had reported to the Brunswick, New Jersey FBI and local
authorities. In addition, Sundquist, through his company Rock Salt, also posted
Ostella's home address and telephone numbers. 14

Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691 Copyright
2009
Official Blog of Dr. Orl}' Taitz Esquire

April 22nd, 2009
Welcome to the OFnCIAL Dr. Orly Taitz Esquire blog.
Please Note: I am NOT using PayPal anymore at this time for donations,
Please mail your donations to:
Defend Our Freedoms Foundation
26302 La Paz stc 211
Mission Viejo CA 92691.
e-mail: 9''..Jil!tz@Y.<lhoo&Q!1l
From .James Sandquist, director of Rock Sail Puhlising

April 23rd. 2009
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Fwd: Lisa Oste-Jla Inte-md .'raud in North Brunswick, N.J
Thursday, April 23, 2009 6:44 AM
From:
"James Sundquist" <rock~~mJ1@lyerizon.net>
V ie\~'_~gl1jacl JjgJJliJ~
To:
"Orly Taitz" <Qx..Jillg@ym:1gO.<;QIl]>
Begin forwarded message:
From: James Sundquist <mck.§jl1!@yerizon.:I!~.t>
Date-: April 23, 2009 9:39:46 AM EDT
To: il;;kconsum~[ilffaL~((lllps.li1ate-,nj .tlS
Subject: Lisa Ostella Internet Fraud in North Brunswick, NJ
Dear Director of Consumer Affairs and the FBI for New Jersey.
You should be alerted to the following report regarding North Brunswick resident Lisa Oslella.
Because this also involves interstate commerce. the FBI needs to know about this too!
I need to alert you to the fact thai Lisa Ostella has defrauded Dr. Orly Taitz and has hijacked her
website. r have just spoken at length to Dr. Taitz.
You can call her to verify this. Dr. Taitz tel number is 949-6R3-54 I 1.
WORLONETDAILY has just run a national story on this:
~JlJ2;l~'"-:':.,:!,~"\UJ.Qsorrr{jJ1d~~J2hn'?j}1~e.t\,i; E,jli.~_~~(~Jmg~q=2,~:2~2
I live in New Jersey and have written two books and h(lve a massive database in which) am able
to expose what Lisa Ostella did to Dr. Or1y Taitz. induding approximately a thousand radio
stations which r frequent as a guest.
Ms. Ostella 's addres~ and lel # are:
Ostella, Lisa
12r""~Jj,,-[yjJkSOr!l
xxxxxxxxxxxxxx
North Brunswick. New Jersey 08902
United States
***
I hope that you will do what you can do to wam your community about Lisa Ostella!
Sincerely,
James Sundquist
Director
Rock Salt Publishing
http://rockAO-salt.s..!,'phasministry.cQJni
89. Sundquist, through Rock Salt is known to make terrorist threats through the
intemet against individuals in order to intimidate them and scare them on behalf of
others when the individuals do not a!:,J'fce in their cause and/or stand up for
themselves.
90. Sundquist, through his Company Rock Salt, Taitz and Defend our Freedoms
Foundation, Inc., have placed Ostella in fear for her children and family. Moreover,
Sundquist, through his company Rock Salt, Taitz and Defend our Freedoms
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Foundation. Inc., have caused OstcUa and her family to be harassed and have placed
their lives in danger. Ostella and her family have heen repeatedly harassed by
individuals on behalfofTaitz, Defendant our Freedoms, Sundquist and Rock Salt.
91. Sundquiest, Rock Salt, Taitz and Defend our Freedoms Foundation, Inc. are well
aware Ostella has never "hacked" anything and their reports are all falsified. They
are well aware Taitz and Defend our Freedoms Foundation, Inc. have never been
hacked. Instead, it is Taitz and her associations on her behalf who have installed JS
Kit software which is a "hacking" and "tracking" software on Taitz's Defend our
Freedoms Foundation, Inc. in order to "track" and "hack" individuals and their
computers who have visited Taitz and Defend our Freedoms, Tnc. websites and blogs.
VII. FACTUAL ALLEGATIONS RELATING TO LINDA SUE

BELCHER alkJa LINDA S. BELCHER alkla LINDA STARR a/kJa
NEWWOMENSPARTYa/kJa STITCHENWITCH a/kJa EVA
BRAUN a/k/a WEB SERGEANT a/kJa KATY a/kJa
WWW.OBAMACITIZENSHIPDI'3BATE.
herein at length.
93. Defendant, Linda contacted Berg in or about August 2008 regarding the questions
into Barack H. Obama's citizenship status. Berg and his staff investigated the Mr.
Obama's citizenship and found there were genuine questions as to his Constitutional
qualifications to run for and serve as President of the United States.
94. Due to some unauthorized credit card charges by Geoff Staples, double billing
and failure to maintain Berg's website, in or about November 2008, Berg fired Gcoff
Staples as webmaster and hired another third party, Gail Fry, to take over the website.
Due to the expense involved, Linda was allowed to be a moderator.
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95. In or about the end of January 2009, Linda began causing the webmasters and
administrators problems with Berg's website. Linda was warned to calm down
numerous times, however failed to comply. Linda felt she was in charge of Berg's
website and sent e-mails to the website moderators deten'ing anyone from contacting
Berg, Berg's assistant or the webmaster. Linda even stated she was in charge. As a
result. Linda's moderator status was removed. However, she was stil1 capable of
posting on the blogs at obamacrimes.com.
96. In or about early February 2009, Berg on behalf of Adams had all the Defendants
herein served with a cease and desist in attempts to stop the Defendants from their
illegal and dangerous behaviors against and towards Adams.
97. Linda began posting on Berg's blog that individuals who were assisting with
Berg's website were hacking Berg's website. Linda even posted on the blog a third
p31iy blog called Politijab had hacked Berg's site. All of this was unfounded and
untrue.
98. In or about the end of February 2009, Linda called Berg's assistant and asked her
to attend a conference call. Berg's assistant, Lisa, told Linda she was not available to
call Berg. Linda called Berg and called Lisa back excited that Berg had agreed.
During the conference call, Berg gave out his e-mail address and told folks with
questions they could e-mail him. Berg hung up the call. One individual mentioned
he had some important material to send to Berg, Linda immediately stated "send the
e-mail to me at ncwwomensparty@;ml.com and I will make sure Berg gets it. Linda
told the caller not to send it to Berg's e-mail address." Berg never received the e
mail.
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99. On or about March 4, 2009, Linda began calling all the webmasters, moderators
and past volunteers of Berg's website telling thcm that Lisa, Berg's assistant was a
liar, she was deleting Berg's e-mails and phone messages, no one could reach Berg
and slandering Berg's assistant, she was hostile with some and harassing others. Berg
and his staff received numerous complaints regarding Linda's unacceptable
behaviors. Berg's assistant statcd she would quit, as the false rumors of Linda's were
not helping thc cause. Berg cut all ties with Linda at that time.
100. On or about March 6, 2009, Linda continued her unacceptable behaviors,
badmouthing Lisa, Berg's Assistant, badmouthing and slandering Berg, harassing
people from Berg's blog, etc. Linda made derogatory remarks about Berg and Berg's
assistant, Lisa, on Berg's website blog. Linda's last post was:
Re.~t{~J;lL.DisQ)SS ioo.J.Q12i.~..Lrm11VJ22..:_Q3.LOj'j.Q_~
. by Linda Starr on Today, 23:23

I am done with all the lies, false accusations, trashing and
vicious crap that has been done to me since January by
certain people around here. They tell me my services are no
longer needed and I am not welcome here. I spent all these
months doing nothing but working my butt off for Phil and this
cause and I'm out. No explanations except for more lies told
about me...and Phil won't even talk to me after over a 10
year friendship!! How's that one? Lisa wants the trolls to take
over and everyone knows Phil jumps to her tune, or so she tells
it.
101. As a result, Linda was completely banned. Before being banned, Linda took
Berg's blog database of e-mail addresses. After being banned, Linda sent the
following c-mail out via her nc\v\vomcnS12artY(llli!.Q].com e-mail address as a mass
mailing on several different datcs to hundreds of people including Berg's Expert
Witncsses, Berg's supporters, attomey's Berg works with on other cases, Berg's
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contributors. Defendants Orly Taitz, Mr. & Mrs. Hale, etc. only a few are attached for
this Honorable Court's review:
Original Message ----

From: NewwomensRarty@aol.com
To: newwomensRarty@yahoogrouRs.com
Sent: Saturday. March 07,2009 1:26 AM
Subject: I am sorry to tell you aiL ..
but my affiliation with Obamacrimes.com and Phil J Berg has

come to a unhappy parting of the ways. I cannot abide the
lies, false accusations and trashing of me when I discovered
some less than honest dealings were going on. One lie after
another has been told to me and about me! I have given
this cause and Phil everything in my being since last July,
when my research really began in June.
Maybe in a few days I will be able to talk about if,

but my stomach is churning tonight and I am heartbroken at
the betrayal of me after a 10 + year friendship was ended
tonight, where Phil was not even willing to listen to me or even
tell me what it is I am supposed to have done, this time. I will
try to make a more complete statement in a day or two.
I am certain that Barry Soetoro is not a US citizen, but we

need people with more integrity to pursue this cause.
Jlda __Starr
JowuL'" new Wonwn& Parlg
Feminism: (noun) the radical notion that women are people.
Well behaved women seldom make history!
On Sat, 3/7/09. Newwomensparty@aol.com
<Newwomenspariy@aol.com> wrote:
From: Newwomensparty@aol.conl
<~ ewworne-'1sparty@aol.~orn>
Subject: Re: Fw: I om sorry to tell you all ...
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She didn't like it that I could reach Phil and she wanted to
shut off that line of communication. I got him on your call
and she didn't like that at all. And the fact that I defied her
and did it anyway ticked her off a lot. She wants all the
attention I am guessing. I found out things about her that
were just awful from Kat who quit 3 days ago.
She wouldn't say what she found, she told me to do a search

for "Lisa Liberi" maiden name of Richardson out of
NM formerly of San Bernadino, CA
An honest person doesn't stand a chance against a lying charlatan.
JJndaStarr
:JoumL,., new WomeIU Pari1l

--- On Sat, 317109, Newwomensparty@aol.com

<Newwomensparty@ao/.com> wrote:
From: Newwomensparty@aol.com <Newwomensparty@aol.com>

Subject: Re: Fw: I am sorry to tell you all ...
No one can reach him. she controls all his e-mail and all his
phone messages. she deletes what she doesn't want him to
see or hear.
J!inlo. __~arr
:JoumL'" new WonwIU pari,!

Newwomensparty@aol.com <Newwomensparty@ao/.com>
wrote:

Subject Re: Fw: I am sorry to tell you all...
I shouldn't tell you what Kat found out about her and told me
to search for today, It is shocking, but there is a problem with
MY credibility? This explains why she doesn't become
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a licensed attorney in her own right. Convicted felons can't.

Do NOT let either Phil or Lisa know I told you about this. No
telling what that nut would do to me or my family.
Mortgage Fraud Blog - New Mexico Woman Sentenced in

Identity Theft and_Real El>tate Frqud
Thursday, April 10, 2008

New Mexico Woman Sentenced in Identity Theft and Real
Estate Fraud
lisa Uberi aka lisa Richardson, 42, New Mexico, was
t
sentenced in connection with felony charges involving

identity theft and forged documents. Liberi appeared in San
Bernardino County, Rancho Cucamonga, Superior Court, on
March 21, 2008. She was sentenced to a state prison term of
8 years, imposed but stayed, and placed on supervised
probation for 3 years as part of a plea agreement. Uberi was
sentenced on ten felony counts ranging from Grand Theft,
Forgery, and Filing False Documents.
From 2000 to 2004, liberi engaged in a complex fraud
involving falsification of police reports, manipulation of credit
bureau reports, loan fraud, and counterfeiting of court
documents resulting in hundreds of thousands of dollars in
losses to banks and credit unions.
In 2002, San Bernardino County Sheriffs Department
personnel arrested Uberi on theft by false pretense charges.
In July 2004, Investigators from the San Bernardino County
District Attorney's Real Estate Fraud Unit arrested Uberi at the
Ontario International Airport for additional felony charges
while she was out on bail.
l
; ;; i
JJnla _){arr
.?. ounde,., new WomeM pari,!
Feminism: (noun) the radical notion that women are people,

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Subject: New site www.ObamaCitizenshipDebate.com
To: newwomensparty@yahoogrouPS.COIll
Date: Wednesday, March 18,2009,6:45 PM
As you've probably noticed, there have been changes to the OC Board
discussions lately. Everything from additional Agents, to subtraction of
Agents and members, to Obots being allowed back to the board and to
be placed into positions of trust as Moderators/Agents. A lot has been
going on behind the scenes, as well as on the OC board itself.
I'm sure you're not happy with what's going on. We aren't, either. It's
counter productive to having discussions, when you're busy rehashing 6
month-old arguments with people who are purposely derailing every
discussion. So a group of us got together, including former
Moderators/ Agents, and decided it was time to do our own thing.
We've decided to create our own board. It will be an atmosphere that is
Obot-FREE. Our core group want nothing more than Justice for the
usurper in our Office. We can have flowing discussion, like we had
before the changes at OC. Also, there may be some pleasant surprises in
store, on the new board. Surprises that will definitely be a HUGE benefit
for this cause. We aren't limiting ourselves to discussions of anyone
attorney or effort. We want to raise public awareness of all the efforts
to expose the truth and remove the Usurper from office.
We'd like to have you join us at our new site, if you are interested in
truth and justice. Please invite others to join, but only invite those who
you're SURE are with US, not THEM. This will ensure progress in our daily
discussions. We are implementing a screening process to insure only like
minded individuals are accepted into our ranks. Welcome to our friends.
Thanks.
The Administration Team at ObamaCitizenshipDebate
oflnda Starr
:JQunler, new Womeru pari"
Lisa
to
Liberi
date Mar 20,20099:48 PM
subject
mailed-by
Lisa, below is the e-mail Linda sent to Amboy Duke, the guy she thinks is
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Ted Nudgent. Amboy Duke is not Ted Nugent but someone from another
blog.
Thank you for responding. I am glad to hear from you again. I was
beginning to think you got frustrated and quit. I have a new effort
and site that is very exciting to a lot of people who are following me,
having gotten disgusted with Phil.
We just got the new site up and plan to raise public awareness for
all the cases. This way I have not publicly gone against Phil, whose
efforts I truly do not want to harm, or diminish his chances to win
any of his cases. He deserves credit for all his hard work when he
was the only one willing to take action and the first to file suit. He
has worked tirelessly, but unfortunately, he won't win because there
is a serious problem with Lisa and Barry's people are going to hurl it
out in the court and that'll be it for all the cases.
Berg supporters know something very bad happened to make me

leave (which it did), but I do not intend to make it a public issue.
Many of them did and a lot of people left and convinced me to do
my own campaign and are following me now. It's because I was
accused of terrible things by Lisa that are simply not true and I
defended myself, but only with a handful of people. Phil believed
her and I was forced out. Then he wrote me another nasty e-mail
basically trying to intimidate me into silence about Lisa, which
wasn't necessary because I wasn't the one who exposed her issues
as I was accused of doing. I didn't even know it, but she has some
major credibility problems that I don't want to get into.
We believe our time is better spent raising public awareness for the
efforts of everyone. Phil shouldn't be slamming Orly Taitz just
because she's making a lot of noise and getting a lot of attention. I
told him not to be slamming her, but now that I'm forced out, he is
listening to Lisa. It looks like sour grapes. My role was both
cheerleader and attack dog since I could do that as a volunteer.
Lisa has allowed trolls to take over and even become moderators. I
don't know if she's getting blackmailed by them or what, but it's a
very toxic environment and people just don't want to be there, and
that includes financial supporters who wonder now how their
donations have been spent. It got so bad that you saw the results
when you kept asking questions. And it's was never that way
before. Posters welcomed the chance to answer questions. My site
will be like that and we will have a section that isn't up yet, to list the
facts and answer most of the pertinent questions. You will be able
to go to one place and get answers without having to sort through
1000's of blogger posts.
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I used to be a guest on a lot of radio shows talking about my

findings exposing various scandals and crimes. I am going to start
doing that again to reach a larger audience. Me and the others who
came with me to start this new effort feel that if we can raise the
public awareness to a level that 100 million people are demanding
Barry produce the proof, or that the DOJ arrest and remove him to
prosecute for all his many crimes in illegally usurping office as
POTUS.
My efforts will not conflict with Phil's, but I feel compelled to say,
please don't get involved with him. I no longer trust Phil or his
Judgment after he was willing to listen to outright lies about me
made by Lisa. You don't throw someone under the bus after being
friends for more than 10 years, especially not your main
cheerleader who fires people up to support the cause. Like I said
before, this is no catfight. It's a major integrity issue. Lisa is a
pathological liar and it really pains me to say that, but it's true. I
can't, in good conscience, possibly recommend you get involved
with Phil after what I learned. I don't want to say more in writing.
In answer to your second e-mail, no one contacted me on your

behalf. And if someone does, I will answer their questions in detail.
I have enough knowledge to do that and speak coherently on the
subject. In fact, I have been dOing that all along except for a few
legal questions. Now I know the answers so we don't necessarily
need anyone else to answer. I am raising funds to wage a media
campaign to raise public awareness, buying media ads and such.
And if you decide to help us, you will know exactly what we are
doing. My site is moving to another server today that is a better
place for our bloggers and security. My site is going to be bigger
than Phil's because a lot of the supporters who had another favorite
and scattered when their efforts failed, will join me and we'll support
them ALL
I look forward to speaking to you or someone on your behalf soon.
J:inda .slarr
Jountk,., new Women& ParlV
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t02. On March 7, 2009, Linda caned the otlice and left a message for Berg stating
"Lisa is sending vial things out about me, she is bad mouthing me, she is deleting my
e-mail to you and she sent me e-mails admitting it." Knowing the entire time these
were alllics and fabricated stories.
103. Linda called Berg and told him his Liberi had a criminal record and was stealing
Twelve Thousand [$12,000.00] Dollars per month from Berg's PayPal account and
was sending "vial" things around the internet about Linda. Linda went on further
stating Liberi had a criminal record going all the way back to the 1990's, all of which
Linda knew was false. Berg told Linda to send him an e-mail with all these e-mails
attached. Berg thcn called Liberi and asked for the same thing. Liberi sent Berg
thirty-seven [37] pages. Linda sent nothing.
104. As time went on, Berg sent e-mails to Linda asking for her list. Berg finally
received another nasty e-mail about Lisa stating Lisa didn't like what Linda had sent
on Thursday so Lisa deleted it. Berg asked Linda numerous times to resend the
"supposed" e-mail, Berg never received anything. Instead, Linda blocked Berg's e
mail address.
105. Linda sent the same accusations outlined above via e-mail to a private
investigator named Neil Sankey with The Sankey Finn and Sankey Investigations,
Inc. Instead of investigating the information Sankey e-mailed the infonnation along
with Liberi's Social Security number, date of birth and where she lived to a Reporter
at World Net Daily and to Orty Taitz. [see above under "Factual Allegations
pertaining to Orly Taitz, et al" and Factual Allegations pertaining to Sankey, et a1."]
106. Linda's behaviors continued and she then began contacting moderators on Berg's
website blog. Linda was attempting to lure all of Berg's moderators over to her new
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website. Linda was also attempting to steal Berg's supporters. It was later
discovered Linda was in fact the individual with an extensive criminal record dating
back to ] 992 through 2007 for Theft, Fraud, and Fraud by Check, etc., according to
the Texas Depmiment of Public Safety and according to a criminal background check
run on her by her Social Security number.
VIII. FACTUAL ALLEGATIONS RELATING TO EDGAR (ED) HALE,

CAREN HALE, PLAINS RADIO NETWORK a/ka/ PLAINS RADIO
NETWORK, INC. a/kla PLAINS RADIO, a/kla BAR H FARMS and
KPRN AM 1610
herein at length.
108. Defendants, Mr. and Mrs. Hale began operating a radio pro !:,Tfam, Plains Radio,
through a tower, which they own, KPRN. The Radio show is an internet radio show
that is broadcast through different stations. Plains Radio also has a website and chat
room located at plainsradio.com. that Mr. and Mrs. Hale worked.
109. In or about June 2008. Mr. and Mrs. Hale contacted Evelyn Adams and requested
she co-host their radio shows on Plains Radio Network, an internet radio show. Mrs.
Adams quit and left Plaintiffs radio show on or about August 21, 2008. Defendants
Hale banned Mrs. Adams computer IP address from his website located at
http://vv'w\v.plainsradio.com, thus Adams could not access his website at all as she
was permanently banned.
110. Shortly thereafter, Adams began hosting another show, Momma E Radio Rebels
and co-hosted shows on Monks Media. Once Adams began with her own show,
Defendants Mr. & Mrs. Hale began slandering Adams name on their radio show,
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Plains Radio through their Tower, KPRN, on their chat room site at
http://www.plainsradio.com and by mass mailings of e-mails from Bar H.
111. The Defendants Hale behaviors intensified. Mr. Hale through Bar H Farms sent
the following e-mail to one of Adams website moderators on her website located at
http://countrvfirst.bravehosLcom regarding Adams website:
"From: "Ed Hale" barhfamls(ii~gmail.com

Date: 8/2612008 12:31 :35 AM
To: "jeff justjeff' greybeard41..1 (£i{yahoo.com"
"I hope you don't need much sleep cause your forum is going to be
atacked 24 hours a day. I was just sent a e-mail telling me that. Hope you
and Momma E have a great timewith your new forum and radio show. It
will not last 2 weeks from what I have been told. so have a great day.
Enjoy your backstabbing while you can. Ed"
112. On August 21, 2008 Berg filed the first lawsuit against Barry Soetoro aJk/a
Barack H. Obama. At this time, Linda referred Berg to her friend, Geoffrey Staples
to set up and maintain a website for the lawsuit.'s
113. During this same time, Mr. & Mrs. Hale requested the appearance of Philip J.
Berg on their radio show, Plains Radio through their tower KPRN. Berg was the first
attorney who field suit against Barry Soetoro a/k/a Barack Hussein Obama regarding
his citizenship issues. Berg agreed to appear several times.
114. Berg's office than received caBs regarding donations that Mr. Hale was seeking
on behalf of Berg. The callers were concerned and wanted verification that Mr. Hale
was in fact authorized to seek donations on behalf of Berg. The callers were notified
that Mr. Hale was never authorized by Berg or his law firm to accept donations on his
behalf.
15 Geoffrey Staples created the website for Berg ~~.()bamacrimes.com
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115. When Berg would no longer attend Mr. Hale's shows and refused
communications with him, Mr. and Mrs. Hale became extremely angry. Mr. and Mrs.
Hale through Plains Radio, KPRN began making horrible slanderous statements
against Plaintiffs, Adams and Berg.
116. Defendants' behaviors continued and Adams continued receiving nasty e-mails
from Mr. Hale at Bar H Farms. Although, Plaintiffs have a stack of the abusive,
threatening and nasty e-mails, only a few are posted herein for this Honorable Court's
review:
------Original Message------
"From: Ed HaJ~
Date: 111120095:47:42 PM
To: Evelyn/MommaE
Subject: why"
"Why in the hell are you steaJing my host and telling Iyes about me. I am about
to come down on you like stink on shit. This is bullslhit. I will have attorney on
your butt tomorrow. You have gone to far this time old lady. You have nothing
but a pissant radio show and maybe a 25 listener if your lucky. You say the same
old shit day after day. No good guest will come on your show. You get lairs like
Sammy from API and that crook Phil Berg on your show. Then you beg for
money for them and get people to give to something that an't worth a damn. [will
see you in court. Ed"
-------Original Message------
"From: -Ed -Hale

-
Date: 11412009 I :35:08 AM
To: Evelvn/MommaE
SubJect: yoru in for it now"
"hey bitch: I can prove that those document you have on your web site that
you and berg have had for month is not true. They are my document and
you remove plains radio off 0 them. I am going trash you and Berg
Monday night on my show. Your nothing but a fucking crook bitch and
now 1 got you. 1 put secret codes in those document and that code is in
your. You such a low life fucking good for nothing bitch. I am going to
sue you fucking whore. those document were copyright protected and now
I have you and you son of bitches. Ed"
-------Original Message------
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From: xxxxx (name removed for protection)
Date: 113120095:57:05 PM
To: mammaE
Subject: Ed Hale mouthing
attachment: 16
117. Mr. and Mrs. Hale on their radio programs on Plains Radio through their tower,
KPRN, stated Berg was a crook, he was conning and scamming people. Mr. Hale
was cussing Berg, calling him a shyster and falsely claiming Berg had lied that he in
fact had the Kenyan Birth Certificate of Barack H. Obama because he (Mf. Hale) had
obtained it for him, that Berg's law license was going to be taken away, etc., all the
time knowing these statements were false. Mr. and Mrs. Hale and others on their
behalf also sent out this false information across the internet and through mass
mailings from Bar H.
118. At the same time Mr. and Mrs. Hale through their radio program, Plains Radio
and their tower, KPRN, began calling Adams heinous names including but not limited
to "Bitch," "Whore," "Worthless Piece of Shit," "a Fraud," "a Liar," a "Thief~" etc.
These remarks were broadcast through KPRN AM 1610 in Wellington, Texas,
through talkstreamlive.com, posted on Hale's internet website blogs and sent out by
Hale's via the internet by mass mailing through Bar H.
119. Mr. and Mrs. Hale used their radio show, Plains Radio, through
talkstreamlive.com, the internet, and KPRN AM 1610 encouraging many individuals
to call into Adams radio shows and tell Adams how stupid she was and what a liar
she was. Mr. & Mrs. Hale gave out Mrs. Adams Radio show internet website. Mr. &
Mrs. Hale went further and encouraged individuals to obtain the can in number from
I() This chat was taken from Defendants, Mr. and Mrs. Hale and Plains Radio website at plainsradio.com at which
time was an open public area and is about Plaintiff, Philip J. Berg, Esquire
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Adams radio show so they are able to call into the show and harass Adams, which
they did.
120. Mr. and Mrs. Hale through Plains Radio and KPRN had listeners and staffs
publish Mrs. Adams home address and telephone number on the internet, which
resulted in Mrs. Adams receiving threatening, harassing and degrading phone calls at
all hours of the day and night stating Mrs. Adams "should stop trashing Ed Hale and
leave Ed Hale alone." Defendants, Mr. and Mrs. Hale were well aware Adams has
never harassed or trashed them.
121. Mr. and Mrs. Hale have repeatedly used their radio show through
talkstreamlive.com, the internet, and KPRN AM 1610 giving false statements
regarding Mrs. Adams which includes but is not limited to her radio shows; falsely
accusing Adams of "trashing" them; falsely accusing Adams of stealing written
documents, being the "Obama" divorce papers; falsely accusing Adams of defrauding
the State of California for her disability, etc.
122. Mr. and Mrs. Hale have used their radio show through talkstreamlive.com, the
internet and KPRN AM 1610, to post on their intemet website blog and sent mass e
mailings from Bar H falsely accusing Adams of "stealing" their "Obama" divorce
records. Mr. and Mrs. Hale falsely claim they have their copy of the "Obama"
divorce papers copyrighted when in fact Adams had possession of the said records
prior to Mr. and Mrs. Hale's receipt of said divorce papers, which they were well
aware of
123. Mr. and Mrs. Hale have used their radio show through talkstreamlive.com, the
internet, and KPRN AM 1610, to advise they have posted on their internet website
blog and sent mass e-maiHngs through Bar H falsely accusing Adams of having a
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criminal record; and falsely claiming Adams has a history of lying and stealing. Mr.
and Mrs. Hale also falsely claimed that Adams hides who she is on her radio shows;
Mr. Hale even went as far as making the open threat, "your day is coming you piece
of shit," referring to Adams. Tn furtherance of this, Mr. Hale attached an unknown
and unidentified printout of a woman by the name of Evelyn A. Adams with a date of
birth of November 9, 1937, whom he was aware, was a completely different person.
124. Unfortunately, this did not stop the Defendants Hale. Once the Defendants were
served with the Cease and Desist, which was on February 2,2009, Mr. and Mrs. Hale
immediately, just to name a few, posted on their radio show webpage at
plainsradio.com and on their radio program, Plains Radio through KPRN the
following:
Ed Hale
IP: 75.91.201.231
Feb 2, 09 - 3:33 PM
"Phil Berg is going to sue me"
"Phil Berg has send us a letter stating that if we do notO retract everything
that we said about him, he will sue us. Ok Mr Berg, I ret act all the lies I
said about you. Hope this makes you happy and now I will continue to tell
the truth about you. In my opinion, you have not won any case in court
because you don't have any evidence to back up what your case is about.
You just grab something out of the air and try to make it look good so
people will donate more money to you. I was on your web site the other
day and you were asking people to donate $50 or get 5 of their friend to
donate $10 each. Mr. Berg, we raised $10,000 for Steve Pidgeon and he
still has money to use. How many $1 OOO's have you received and what did
you do with that money? Have you published a report about where you
spent their money? Why will you not tell the people who donate to you
what is going on with your cases? Why did you send Oprah a letter? Was
this a way to raise more money? The courts has turned down you cases as
fast as you file them. Wonder why that is so Mr Berg? Mr. Berg, I will
give you the entire 4 hours this Friday night to come on my show and
answer these question and others. The problem is you will not do it
because you know I will ask the hard question. This is your chance to set
the record straight. You will have 1000's of people listening and here is
your chance to make your case to them, teh American people. If you think
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1 have not told the truth aobut you, then come on the air and prove me
wrong. Now Mr. Berg, you have the ball, what are you going to do with
it? I will bet anyone a $100 to a dollar you will not show up. Ed Hale,,17
Ed Hale
IP: 75.91.201.231
Feb 2, 09 - 8:04 PM
"I jsut recieved a copy of the letter"
"Yes it appears that Mr Berg is now licenced in the state of Oklahoma

also. He is going to sue me for Momma E. Momma E does not like beign
told that she is a lair and a thief. An she has to do is prove that she has a
set of the orginal 1964 Obama divorce documents and 1 will retract all of
it. I can tell you this much we will find out who is laying about this.
Anyway stay tune it is going to get jucier.,,18
"Re: Ed Hale "Phil Berg is Going to Sue Mel!
"She's 72 years old ... alrlght... That picture she's got up there makes her
look like a beautiful young chick .. .l got news for you. She's fat, ugly,
brrey-headed, and shc has to use a walker to get around. And, you know
something? She's gonna be meetin' her maker real soon. I'm tellin' you
that. [sound effect of some kind of gun being cocked and shot.] Bitch! Ed
Hale.,,'9
125. In or about March 2009 Mr. and Mrs. Hale through Plains Radio filed a false
lawsuit against Adams. To further perpetrate their fraud and for further harassment,
Mr. and Mrs. Hale and Plains Radio did not have Adams served correctly and only
served her with the Collingsworth County Small Claims Citation.
126. As a result, Adams had to hire Berg to respond to the Defendants frivolous small
claims lawsuit. Liberi from Berg's Office called the Collingsworth County Small
Claims Court and infonned them Adams was not served with any type of Complaint.
17 This was posted on February 2. 2009 at 3:33 p.m. on Defendants website, plainsradio.com blog forum at
http://pub29.bravenet.com/forum/24428 ] 0] 29/show/972859 - Page URL2/2/2009ate
IR Posted February 2, 2009 at 8:04 a.m. at Plains Radio Network, Inc. at
htt£?:ilpllb29 .bravelJet.com/foruIn/244281 0 I29#bn-forum-l- J-24428] 9129/8. Plaintiffs' counsel maintains a copy of
this posting.
19 Posted on the internet February 2, 2009 at 9:06 p.m. Mr. Hale also stated this on his radio program; Plaintiffs
counsel has a copy of the audio file.
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The Justice read the Complaint on file and stated Mr. and Mrs. Hale through Plains
Radio claimed Adams stole their copyrighted "Obama" Divorce papers. Berg
responded to the Defendants frivolous lawsuit, supplied the Collingsworth County
Court with copies of the "Obama" divorce papers which were given to Adams.
127. Liberi, assistant to Philip J. Berg, Esquire, sent Ms. Adams a copy of the Obama
v. Obama, Hawaii D. No. 57972, Divorce Decree in the early morning of January 2,
2009, which Berg's Law Firm received from their Hawaiian Private Investigator via
e-mail and Federal Express.
128. Adams posted said divorce papers on her website, Country First, on January 2,
2009 at approximately 4:37 p.m. Eastern Standard Time, 3:37 Central Standard Time.
129. Ed Hale, owner and operator of Plains Radio Network, obviously obtained copies
of the same Obama v. Obama divorce decree from Hawaii. However, Mr. Hale
through Plains Radio Network did not receive the said divorce decree until January 2,
2009 at approximately 2:25 p.m. Central Standard Time and did not post said divorce
papers until approximately 8:00 p.m. Central Standard Time, by his own admission.
130. Mr. and Mrs. Hale were very unhappy with the fact Berg responded on behalf of
Adams to his frivolous lawsuit. Mr. and Mrs. Hale then prepared a letter, which they
claimed they sent to the Justice of the Peace of Collingsworth County stating it is a
fact Berg and Adams conspired to raise money for Berg; it is a fact that Berg is not
licensed to practice law within the state of Texas; Liberi' s e-mail sent to Adams with
the "Obama" divorce papers was a forgery; Liberi's e-mail was doctored; Berg and
Adams have partnered together and has collected thousands of dollars from people
based on lawsuits that had no chance of success; Berg has been proven to be a
shyster; Berg is under investigation by several Federal agencies; Berg and Adams
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have conned thousands of Americans out of hundreds of thousands of dollars, etc.
This very letter was never sent to Judge Henard, Justice of the
Peace of the Collingsworth County Court, Precinct One, Number One, instead Mr.
and Mrs. Hale posted it on their radio show website, plainsradio.com and sent it out in
mass e-mailing from Bar H which was nothing more than further slander and libel.
131. Mr. Hale continued his above behaviors and began sending harassing e-mails to
Liberi. In one of his e-maiIs.Mr. Hale went as far and threatened Liberi and Berg
stating, "You and berg are going to regreat getting illto tltis" [sic J20.
132. Mr. and Mrs. Hale then went onto their website, plainsradio.com through Plains
Radio and posted a statement in their open forum stating the following:
"Berg and Adams is under investigation !!!!"
"1 have been informed that Phil Berg and Evelyn Adams are under
investigation by the Federal Trade Commission and the FBI for conning
thousands of Americans out hundred of thousand of dollars. Adams used
her radio show to promote Berg lawsuits and asked for and received
money. These lawsuit were all dismissed. According to my source, Berg
had declared bankruptcy in July. He use this money to pay his personal
debts. The money was never used to fund the lawsuits as was promoted by
Adams and Berg. Berg has used thousands of dollar for his nightclub
drinking binge, throwing money around like a big shot. I have been told to
expect Berg to be arrested within a the next few days or weeks as the case
is nearing a end. Adams is also going to be charged under the Ricco act as
they conspired to defraud the American people out of hundreds of
thousand of dollars. This could not happen to 2 more deserving people.,,21
133. The above post was placed on an open forum for the internet world to see. This
posting was also carried over to another website, unassociated with the Defendants at
20E-mail sent from Defendant Edgar (Ed Hale) on April], 2009 at 10:42 a.m. from ~~!!:ht:ill1!!§Jl!tl to Berg's
assistant at LisaLiberi@gmaiLcom
21 Posted March 31, 2009 at 2:58 a.m. at Plains Radio Network, Inc. at
http://pub29.bravenet.com/1uf!lm/244281O l29#bn-forum-I-I-24428I 0129/8. Plaintiffs' counsel maintains a copy of
this posting.
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httn.;Lillglitiiah-.:.com/J2.hpBB3/index_ll@. None of which 1S true and was done
maliciously by Mr. Hale.
134. On April 14, 2009, Plaintiffs receive a copy of a mass e-mailing and a falsified
statement, sent out by the Defendants Hale and posted on the Defendants Hale
websites further slandering Liberi. The e-mails and postings, just to name a few,
stated:
Datc:Apr 14,10097:32 AM
Suhject: Secn Ed I laIc's Latest vs YOU
To: Ijsaliberi(~4mnail.com
Hi Lisa ............ seen this from Ed Hale's page:
Dr Or]y has been seamed by Lisa Liberia (Phil Berg assistant)
It appears that Lisa Liberi, who works for Phil Berg has been stealing
from Dr Orly. Tonight, 2 of our listeners have came forward with recipet
from paypay where they thought that they were donating to Dr Orly and
instead it went to this Lisa Liberi. At this point, we do not know if Phil
Berg is involued, but as my mother has stated "birds of a feather flock
together". These are e-mails that I received from DrOrly. As I have said
many times, Phil Berg was in this for nothing but money and also those
who helped him also. I can assure you that we have proof that Lisa Liberi
did in fact take money that was to go to Dr Orly. That whole bunch that
has accused me of stealing is now actually proved that they themselves are
thieves
Postings on Plains Radio:

http://pub29.bravenet.com/foruml244281 0 129#bn-forum-1-1-244281 0129/8/1 007326/show
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Ed Hale QuoteRepl)'
Dr Orly has beell .~camed by Lisa Liberia (Phil Berg assistallt)
It appears that Li.m Uberi, wllO worksfor Phil Berg has IJeI'1I stealillg/rom Dr Orly, TOllight, 1 ofol/l'/istel/as have call1eforward with
recipet from I'aypay where they thought that they were dOllatillg til Dr Orly ami illstead it Wellt to tllis Lisa Uberi. At tllis POillt, we do
Apr n,10{)9 IlOt kllow if Phil Berg is Im·oll/ed. IJIlt as my mother has stated "lJirds afa feather flock together", These are e-mails that I recieved
- 1':46PM from Dr Or/yo As 1110111' silid I/I(II~I' times. Pllil Berg ",as ill tllisfor I/othillg but mOlley al/(I also tl1f1se who helped Ilim also. I call a.,,~ure
yau that we IIm'e p/'aofthat Li.m Mberi Ilid ill filct take mOlley that was ta go ta Dr Orly. That wlwle bUl/ellthl1t has accused me of
stealing is 1I0W actllally p"OI'ed that they themselves (Ire thieves.
Froll/: Or~v Taitz

Subject: Ceize al/(I Desist. demalldtafifeajoillt FBI COII/plaillt
To: "Phil J Berg Esq (pl't) "
Ce: "Orly Tain"
Date: St/llday, April 12, 2009. 10:01 AM
04.12.tJ9.
Mr. Philli" Berg,
tltis is to ;,!form yOIl that a few days aga Iltal'e forwarded my quo warrlllltil pleadillgs to Mr• .101111 Hell/ellway, sillce III' agreed to be my
local co-collllsel ill Washingtoll DC. This was a cOlljidemial commUl/iCalioll aud Mr. Hemellway slated, that mistakellly he has
forwarded t"ose pleadillgs to YOIl. SI/(}rl~V thereafter YOIl hlll'e sellt a press release, statillg that YOII will be jilillg Quo Warrallto action.
This is a Ceize mill Desist letter. demalldillg that you do I/ot lise my pleadillgs alld conjidellfial ;IIfi}rmatioll ill allY way. slrape or form.
as you recej,'ell tho,ve ill error witllOllt myalltlrorh.atioll.
Additiol/ally. I receh'etl iliformatiilll from a licell.~ed Prh'ate illvestigator, witlt 20 years ofexperiellce with Scotlallil Yard allil 12 years oj
experiellce ill US, tll(lt your paralegal Lisa Libel'; has all extensive crimillal record, im'oll'illg fralld, forgery ofdOCUllIellfS alld idelltity
tlleft. See attached jile. I also received illformatioll that I,er Ilushaml, w"o is cllrrently Oil parole, is all oWller of 2 ofaccoUllfs, aceeptillg
credit cards all your charitable fiJUlldatioll web site. As all officer oftile court I am obligated to forward tllis i"formatioll to ti,e
autllorities: FBI, Attorney G'elleralilf Califomia and Sail Bernard/III) COIm(v Distict Attomey. si,/ce Lisa Libel'; "ad a 8 year cOl/victilJII
;1/ Sail Bemardil/o COIIII(V. Cttliforllia.1 believe thatYllII, as 1111 afficerofthe courl, as well aflll a former Assitant Attomey Gellerallif
Pem/sylvallia, shollld,;oill me ill issuing ajoillt cOlI/plaillt alld demalld filr illl'estigatitm from tile above listed autlrorities.
Dr. 01'1.1' Taitz Esq
16302 La Paz ste 1 f I

Missioll Viejo Ca 92691
Lisa Ostella
Delelld Our Freedams FOlllulatUJII
Ilttp:lldefelldourfreedams.org
Peace througll Strellgtll
frttp:llwww.bamjillfegri(v.conr
> From: IIsallkeyqiJthesal/keJ~firlll,colII

> To: Iisaostel/a@llOtlllail.com: dr_ taiti@yallOo.com
> Su~;ect: FW: »»»»»Urgellt IMPORTANT INFO SAME SlIB.lECT««<
> Date: MOil. 16 Mar 200914:57:13 -0700
>
> PLEASE NOTE THE LAST LINE!
>
> Thursday, April f 0, 2008
New Me.dco Wml/an Sentellced ill Idel/tity Theft alld Real Estate Fraud
>
>
> Lisa Liberi, aka Lisa RicllardslJII, 42. New Me.\:ico, was sm/mced ill
> cOlllreCfhm liIitll felollY cllllrges ill.,olving idelltity theft alld forget/
> documellts. Libel'; appeared ill Sail Berllardillo COI/llty, Rallclro Cucamollga,
> Superior Court, Oil March 21, 2(J08. She was sel/tel/ced to a state prison term
> of 8 years, imposed hilt stayed, 0111/ placed 011 supen'ised probatioll fO/' 3
> years as pal"t ofa plea agreemellt. Liberi was sentellce(1 Oil tell felollY
> coUllts rallgillg fro III Grund Theft, "orgery, alld Filillg False Do('Umellfs.
>
> From 2(100 to 2004, Uher; el/gaged ill II complex fralltl illl'oll,jllg falsijicatiOl/
> ofpolice rep0l1s, mallipulation ofcredit bureau reports, !tlllll fralld, alld
> coullterfeitillg ofcourt dllel/mel/ts resulting ill hUlldreds oftlwusulUfs of
> dollars illlo.\~~es to ballks alld credit ulliolls.
>
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> III 2002, Sail Bernardilla Coultty Sheriff's Departmellt persmlllel arrested
> Liheri 011 thlffr hy/aise pretellse charges. III July 2004, Im'estiglltorsfmlll
> the Sail Bemardilw COUII(V District Aftamey's Real Estate Fraud Vllif
> arrested Liher; at the Omario Illtenwtiallal Airportlor additiollal felOiIY
> charges while she was out ml bail.
>
> SlIe has al/ extellsiJ·e crimil/al recard gaillg back fQ tlte 90's.
From: Jolm IJ. Hemellway
Suhject: FW: Writ
To: dr_faitzti!)'alll1o.cO/ll
Date: SUllday, April 12. 20()9, II:fJ3 AM
April 12, 2()()9
lJear Or~v.
This 1V0uld illdicate tl/flt Usa Liberi received your Writ. It is !laf specified allli slle daes flOt say so alld it could refer to the earlier Writ
she said was ....rittell by a farmer illmate, hut I da lIot tlli!lk sa.
Best regards, JDH
From: Lisa Libel'; //IIlIilw:lisaliheri(ii}glllail.colII/

Sem: Fritlay. April 10, 2()09 1:()7 AM
To: J(JIIII D. lIemellway
Suhject: Writ
Jolm,
There are many I'mbiems with this Writ alQllo Warranfa. A Writ of Quo Warrallto is used ",hell a Govemmellt affiee ha~' heen
usurped. Furthernwre, you call/lOt go after a persOll as a Plaillliff uS;lIg Fedeml Crimillal Cod('~~ You call mellfioll them, however, you
can't go after the illdil'idual ulliess yau are a pmsecutor.
Lisa
Lisa Liheri
Assistant to Philip .I. Berg
LAW OFFICES OF PH/LIP J. BERG
State: Texas
Edllale QuoteReply
Proofthat Iwly is Lisa im·olllecl but lIIare
Hi folks: Look at tllis page from olle altile weh sites t/rat Lisa II(I.~ set lip alUl see w/ro is Iler Jlartllers ill tllis. Get ready far a slrock 011
tlte right haml .vide.
Apr 14. 2009
- 1:17AM
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State: Te.'(lI.~
Tollam/RCR QuoteReply
Re: Dr Or~" has heell seamed by lislI Liberia (PMI Berg assistant)
Before you g(1 too far with tflis, you might wallt to listell to a recordillg ofyau,. i"ten-iew witll Orty Tait7. It j,~ widely available 011 the
Internet (fyou dOIl't flflve a eO/~I-.
Apr 14,2009
.10:06AM In it, Orly seems to clear~y ,11ate tflat slle believes that the donatioll:; are goiug to Usa Ostcdla, he".former Webmaster. It is aften difficult
to Ullaerstana her speech, so that might /1(' the root oftile prohlem.
The (/ollatio"s heillg rollted I·ia Ostella might make sallie teelwleal sense, depelldillg IIpOIl how Orly set tllillgs up. OSlella was a
,'alllllteer fill' IIl'r alia el·it/e/lt~" IIIIS Web skills tllat 01'1.1' does /lot.
Orly daes not accuse Usa Liberi (Berg's associate) ofthis. YOllr postillg oftltis claim is wit/ely replicated Oil tlte Well, so it is gettillg
quite a bit ofexposure. That /IIay be the last thillg that you wal/t.
Yall also might want to illIte that there are mally Usa Liberi's ill the U.S. The o/le with the erimillaillistory is almost certai/l~V not
Berg'S assaciate.
Without mnlllll!lIfillg Oil O,.~V's cilarges agail/st Lisa Ostella, I would lIate that it is likely fhat, with Orly's help,. you have just gatten
yOl/rseff illta a real legal pickle. Beyond defamatio/l, when dit/ you start believ;'lg people wllo tell you that they have learned somethillg
frolll 01/ OIwnYlllous source?
It looks ta /lie as ifthose few who are still questiolliug OIJama's eligibility to sen'!! as Pres,ident are 110111 e/lgaged ill a mutually
destructil·e war. This was predietahle, because this is always what lIappells with extremists, particularly those wlw are remarkably
capable (!f dellyillg reality. It's nice f(} see it happell.
State: CT
Molly QuoteReply
Pitcher Re: Dr Orly has beell seamed by Lisa Liberia (PiliI Berg assistallt)
Tolal/dRCN,
1 have ple/lty ofpraofabout Obal1la~' fraud. His forgered COLBs, ltisfargea Selectil'e Sen-ice Registrafiall, IIis 11Itelligellce appointees
Apr 14, 2009 employee getting jllf(} Obal1la's pas.lport recorlls ta alter tilem.
IO:47AM
We are Itat extremists as J'Oll say..
I don't kilO'" abollt tile rep(Jrteti "theft" bllt [hope it is Iwt trlle.
State: co
kukalliloko QuateReply
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He: Dr Or{v has beell scamed by Usa Liberia (Pllil Berg assistallt)
Wl,y is it 110 .~/Iprise tllllt all the Mrlers are I/owfiglltillg a",Q/llIg tllemselves? It would be prudent at thisiul/cfure if you CUll a/l arrange
a team buiiJillg exercise - go Big Foot Hutltillg together or S(!mefltillg. May/u! at your 10 )'ear reulliQlI, you all can make afield trip to
Apr 14, 2009 tile Obama Pre.~idelltial Library.
-J2:42PM State: Dellial
135. As you can see from the above posts, Orly Taitz was accusing Lisa Ostella of
hacking and stealing from her PayPal account, not Berg's assistant, Lisa Liberi. Mr.
Hale aired the show where Taitz was accusing Lisa Ostella. However, as stated
above, Mr. Hale threatened Berg and his assistant that they would regret getting
involved in the matter regarding Adams. Mr. Hale's statements above were
statements to damage Berg, his assistant and his law practice, knowing the entire time
they were falsified statements. Mr. Hale obviously calTied out his threat to Berg's
assistant.
136. On April 20, 2009, Mr. Hale had a radio show on at 9:00 p.m. Mr. Hale's Guest
was Orly Taitz. Mr. Hale then went on falsely stating Lisa Ostella and Lisa Liberi
were one and the same person and she was a criminal, knowing the infonnation to be
false.
IX. FACTUAL ALLEGATIONS RELATING TO ALL DEFENDANTS
herein at length.
138. Plaintiffs are in possession ofthe Plains radio shows with the above information
as well as copies of the postings on the internet placed by Defendants Taitz, Defend
our Freedoms Foundation, Inc., Sankey, from the Sankey Firm and Sankey
Investigations, Inc., James Sundquist, Rock Salt Publishing, Mr. & Mrs. Hale, Plains
Radio, Bar H Farms and Linda and e-mails which were sent.
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139. The illegal acts of Defendants' Sankey through his investigation finns, the Sankey
Finn and Sankey Investigations, Inc., Taitz, Defend our Freedoms Foundation, Inc.,
and Y osef were all commenced under the laws of California and followed through
against Liberi in the State of California.
140. Defendants are and have been well aware their statements about Liberi, Berg, the
Law offices of Philip J. Berg, Adams and Ostella are falsified. The Defendants will
stop at nothing to destroy all Plaintiffs. Plaintiffs' counsel is in possession of all the
audio files of Taitz, Mr. and Mrs. Hale, Plains Radio, KPRN, and Bar H Fanns and
all radio shows they have done broadcastings further slandering the Plaintiffs.
141. Defendants' disclosure, posting on the internet, emailing, etc. of Plaintiffs'
personal identifying infonnation including but not limited to social security numbers,
names, address, and date of bilth Defendants actions also violated and were done in
violation of State and Federal Laws, e.g. the Social Security Act; California Privacy
Laws, Civil Code § 1798 et sequitur; Identity Theft and Assumption Deterrence Act,
18 U.S.C. §1028(a)(7); Pennsylvania Privacy Acts (74 Pa. Stat. Ann. § 201 (West
2006); California Business and Professions Code 22577(a); the Electronic
Communications Privacy Act, 18 U.S.C. §§2510-22, and the Stored Communications
Act, 18 U.S.C. §§2701-11~ Cyber harassment, Cyber stalking, etc. in violation of the
Women's Violence Act, Department of Justice Reauthorization Act of 2005, H.R.
3402, titled "Preventing Cyber stalking" and numbered as § 113, § 113(a)(3) provides
that Section 223 (a)(l )(C) applies to "any device or software that can be used to
originate telecommunications or other types of communications that are transmitted,
in whole or in part, by the Internet; Cyber-stalking and Cyber-harassment laws in
violation of the Communications Act, 47 U.S.C. § 223(a)(1)(C) and § 223(h)(I)(B).
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142. Defendants DOES 1 through 200 are Defendants internet providers, phone
companies, e-mail providers, streamlines, etc. who have allowed Taitz, Defend our
Freedoms Foundations, Inc., Neil Sankey with the Sankey Firm and Sankey
Investigations, Inc., James Sundquist, Rock Salt Publishing, Plains Radio, Mr. and
Mrs. Hale, Bar H Farms, and Linda to continue their illegal and dangerous behaviors
against Plaintiffs. DOES 1-200 also represent all unknown unnamed Defendants.
143. For the above-mentioned reasons, Plaintiffs herein are seeking immediate
injunctive relief and damages for the injuries caused by the Defendants illegal
behaviors.
COUNT ONE
VIOLATION OF THE FIRST AND FOURTEENTH AMENDMENT
OF THE UNITED STATES CONSTITU(ON and ILLEGAL DISCLOSURE
OF' AN INDIVIDUAL'S SOCIAL SECURITY NUMBER AND
PERSONAL IDENTIFYING INFORMATION
(Liberi v. Taitz, Defend Ollr Freedoms Foundation, Inc., Sankey,
the Sankey Firm and Sankey Investigations, Inc.)
144. PlaintifIs incorporate by reference all of the foregoing allegations as if set forth
herein at lenbrth.
145. Defendants Taitz, Defend our Freedoms Foundation, Inc., Sankey, the Sankey
Firm and Sankey Investigations, Inc., violated Liberi's right to privacy, right of
publicity, harassment, endangerment and publication of private facts.
146. Taitz had threatened to destroy Liberi and took every step to ensure she not only
destroyed Liberi but harmed and injured her in the process.
147. Taitz sought Liberi's Social Security number and personal identifying information
without a permissible purpose from Sankey with the Sankey Firm and Sankey
Investigations, Inc., information Taitz was not entitled too. Taitz had been spreading
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false criminal infonnation about Liberi over the internet, on radio shows and through
mass e-mailing an of which was done through her Jaw finn. Taitz published Liberi's
Social Security number, date of birth, where she resided, false infonnation about
Liberi's husband; false criminal information through mass e-mailing requesting
everyone to post the infonnation on their website. Taitz's e-mails and postings went
out to over Two Hundred and Fifty Thousand [250,000] people, all of which was
done through her law finn (business) with malice.
148. Sankey through the Sankey Finn and Sankey Investigations, Inc. obtained
infonnation from a third party. Without verifying said information and at the request
of Taitz, Sankey through the Sankey Finn and Sankey Investigations, Inc. obtained
Liberi's Social Security number, without a pennissible purpose.
149. Sankey through the Sankey Finn and Sankey Investigations, Inc. illegally e
mailed Liberi's Social Security number, date of birth, where she resided and
description and e-mailed it to Taitz and a Reporter with World Net Daily. Sankey
through the Sankey Finn and Sankey Investigations, Inc. was well aware the
infonnation would be posted on the internet and sent out by mass e-mailing. All of
these actions were done through Sankey's businesses and was done with malice to
injure and hann Liberi.
150. Liberi had a confidential address as a result of her child and her being victims of
domestic violence. The publication of Liberi's personal identifying infonnation by
Taitz, Defend our Freedoms Foundation, Inc., Sankey, the Sankey Finn and Sankey
Investigations, Inc. made sure anyone with internet had access to Liberi's Social
Security number, date of birth and where she resided, further placing Liberi, her son
and husband in further danger.
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151 . In so doing, Taitz, Sankey, the Sankey Firm and Sankey Investigations, Inc.
violated California Civil Code §1798.85 which states in pertinent part:
"(a) Except as provided in this section, a person or entity may not do any
of the following: (1) Publicly post or publicly display in any manner an
individual's social security number. "Publicly post" or "publicly display"
means to intentionally communicate or otherwise make available to the
general public."
152. If there had been a pennissible purpose for Sankey through he Sankey Firm and
Sankey Investigation, Inc. to disclose Liberi's confidential information including full
name, date of birth and Social Security number, which there was not, Sankey through
the Sankey Firm and Sankey Investigations, Inc. violated California Civil Code
§ 1798.81.5 (c) by not ensuring Liberi's private, personal and confidential information
was not maintained pursuant to the privacy laws and not maliciously disseminated via
the internet and mass e-mailing. California Civil Code § 1798.81.5(c) states in
pertinent part:
"A business that discloses personal information ...pursuant to a contract

with a nonaffiliated third party shall require by contract that the third party
implement and maintain reasonable security procedures and practices
appropriate to the nature of the infornlation, to protect the personal
infonnation from unauthorized access, destruction, use, modification, or
disclosure. "
153. Taitz hired Neil Sankey, The Sankey Firm and Sankey Investigations, Inc. to
illegally obtain Liberi's private and personal information, which Sankey through his
investigation finns, the Sankey Finn and Sankey Investigations, Inc. did. Thus, they
had a contract for work to be provided.
154. Taitz had a special "tracking" and "hacking" software on her websites and blogs
that attached a remote access on Liberi's computer. Yosef assisted Taitz in entering
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Liberi's computer, invading her privacy and taking documents which did not belong
to them.
155. California Civil Code §1798.84 states in pertinent part (b) stats a party injured for
violation of this title injured by a violation of this title may institute a civil action to
recover damages and ...(c) dictates a civil penalty over and above actual damages and
punitive damages for a willful, intentional, or reckless violation ...may recover a civil
penalty not to exceed three thousand dollars ($3,000) per violation ... (e) Any business
that violates, proposes to violate, or has violated this title may be enjoined ... (1) A
prevailing plaintiff in any action commenced shall also be entitled to recover his or
her reasonable attomey's fees and costs ...(g) The rights and remedies available under
this section are cumulative to each other and to any other rights and remedies
available under law.
156. Taitz Sankey, the Sankey Finn and Sankey Investigations, Inc. violated the
California privacy laws in excess One Hundred Forty-Four Thousand [140,000]
times.
157. Defendants' disclosure, posting on the intemet, emailing, etc. of Plaintiffs'
personal identifying information including but not limited to social security numbers,
names, address, and date of birth Defendants actions also violated and were done in
violation of State and Federal Laws, e.g. the Social Security Act; California Privacy
Laws, Civil Code § 1798 et sequitur; Identity Theft and Assumption Deterrence Act,
18 U.S.C. § 1028(a)(7); Pennsylvania Privacy Acts (74 Pa. Stat. Ann. § 201 (West
2006); Califomia Business and Protessions Code 22577(a); the Electronic
Communications Privacy Act, 18 U.S.C. §§251O-22, and the Stored Communications
Act, 18 U.S.c. §§270l-11; Cyber harassment, Cyber stalking, etc. in violation of the
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Women's Violence Act, Department of Justice Reauthorization Act of 2005, H.R.
3402, titled "Preventing Cybcr stalking" and numbered as § 113, §113(a)(3) provides
that Section 223(a)(l)(C) applies to "any device or software that can be used to
originate telecommunications or other types of communications that are transmitted,
in whole or in part, by the Internet; Cyber-stalking and Cyber-harassment laws in
violation of the Communications Act, 47 U.S.C. § 223(a)(l)(C) and § 223(h)(1)(B).
WHEREFORE Plaintifts' request:
A. An immediate Order enjoining Defendants Taitz, Defend our Freedoms
Foundation, Inc., Neil Sankey, the Sankey Finn and Sankey Investigations, Inc. and any
party on their behalf from disseminating Liberi's Social Security number, date of birth,
name, where she lives, etc.;
B. An immediate Order of retraction against Defendants Taitz, Defend our
Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations,
Inc. and any party who has published Liberi's contidential information on their behalves
to immediately retract and remove Liberi's private confidential information, including
but not limited to her Social Security number, date of birth, where she resides,
information about her husband, the false criminal accusations, etc;
An immediate Order of retraction against Defendants' Taitz, Defend our
Freedoms Foundation, Inc., Sundquist, Rock Salt Publishing, and anyone on their behalf
from distributing Lisa Ostella's personal and confidential infornlation, including but not
limited to her home address and telephone number;
D. Enjoin Defendant Taitz, Defend our Freedoms, Inc., Yosef and any party
operating on their behalf from any further "hacking" of the PI ainti ffs' computers;
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E. Enter Judgment against the Defendants, Taitz, Defend our Freedoms
Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc.,
collectively, jointly and separately, for civil penalties in the amount of Four Hundred
Thirty-Two Million [$432,000,000.00] Dollars separately per Defendant to be awarded to
Liberi as civil penalties pursuant to the California Privacy Laws, California Civil Code
1798, et sequitur. Pursuant to Taitz' own admission she has a total of Thirty-Six
Thousand [36,000] people on her media and individual mail lists, Taitz sent out a
minimum of four e-mails with in excess Thirty-Six Thousand [36,000] recipients,
including intemational which is a total of One Hundred Forty-Four Thousand [140,000]
e-mails multiplied by Three Thousand Dollars [$3,000.00] per e-mail, which Plaintiff
Liberi is entitled too pursuant to the California privacy laws, Califomia Civil Code 1798
et sequitur;
F. Enter Judgment, collectively, jointly and separately, against the
Defendants' for damages in the amount of One Million dollars [$1,000,000.00] per
Detendant to be awarded to Plaintiff Liberi;
G. Enter Judgment, collectively, jointly and separately, against the
Defendants' for compensatory damages in the amount of Five Hundred Thousand Dollars
[$500,000.00] per Defendant to be awarded to Plaintiff Liberi;
H. Enter Judgment, collectively, jointly and separately, against the
Defendants' for Punitive damages in the amount ofTen Million Dollars [$10,000,000.00]
per Defendant to be awarded to PlaintiffLiberi~
1. Attorney's fees, costs and interest for Plaintiff Liberi; and
J. Such other relief as this Court deems proper.
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COUNT TWO
DEFEMATION PerSe, SLANDER AND LIBEL
(Against All Defendants)
herein at length.
159. Defendants' Taitz, Defend our Freedoms Foundation, Inc., Yosef, Sankey with
the Sankey Firm, Sankey Investigations, Inc., Mr. & Mrs. Hale, Plains Radio, Bar H
Famls and Linda made false statements about Liberi claiming she had a criminal
record for convictions of amongst other things, identity theft, falsification of police
reports, falsification of credit reports, falsification of documents, claiming Lisa Liberi
and Lisa Ostella were one and the same, falsely claiming Liberi and Ostella were
diverting funds from Taitz's PayPal account; falsely claiming Liberi and Ostella were
working together; falsely claiming Liberi was diverting funds from Berg and the Law
Offices of Philip J. Berg; falsely claiming Liberi was posting on blogs under her
aliases; falsely claiming Liberi was committing crimes, falsely claiming Liberi was
"trashing" Linda; falsely claiming Liberi was "trashing Taitz", falsely claiming Liberi
had to pay Twenty-One Thousand [$21,000] Dollars per month in restitution, false1y
claiming Liberi was convicted of amongst other things, identity theft, falsifying
police reports, falsifying credit reports, counterfeiting documents, etc.
160. Defendants' Taitz, Mr. and Mrs. Hale, Plains Radio and Bar H Falms made false
statements about Adams claiming she had a criminal record; conning people out of
money; calling her horrible names; falsely accusing her of stealing the "Obama"
documents; threatening her, etc.
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161. Defendants' Taitz, Mr. and Mrs. Hale, Plains Radio, Bar H Fanns and Linda
made false statements about Berg and the Law Offices of Philip J. Berg claiming he
was under federal investigation; he was a shyster; conning money out of innocent
people, was only in it for the money, had a criminal working for him, etc.
162. Defendants Taitz, Yosef, Defend our Freedom Foundations, Inc., James
Sundquist, Rock Salt Publishing made false statements about Ostella that she hijacked
Taitz's website; was working with Liberi; was diverting funds from Taitz PayPal
accounts, she hijacked Taitz's websites, filing false police reports with the Orange
County Sheriffs Department, the FBI in California and New Jersey, claiming her
website and PayPal accounts had been hacked, etc.
163. Defendants' false statements about Plaintiffs were made across the entire internet
world; sent to unknown individuals by way of mass e-mailing; telephone
conversation; posting on the Defendants websites, etc.
164. At all relevant times, Defendants have acted with actual malice.
165. Defendants' defamatory statements about all Plaintiff., have severely injured the
reputation and honorable services provided by each one of them.
166. Defendants' defamatory statements about the Plaintiffs have caused Plaintiffs to
suffer mental anguish and impaired their personal and professional reputation and
standing in the community.
WHEREFORE Plaintiffs' request:
A. An immediate Order enjoining the Defendants' and all parties acting on
their behalf from airing andlor publishing any defamatory or false statements about
Plaintiffs, Lisa Liberi, Philip 1. Berg, the Law Offices of Philip J. Berg, Evelyn Adams,
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Lisa OsteUa and Go Excel Global, the Plaintiffs' family members, etc. via the internet or
any other print or electronic medium or broadcasts and/or radio, from portraying
Plaintiffs in a false light via the internet or another print or electronic medium or
broadcasts and/or radio, untrue statements about the Plaintiffs' enjoin the Defendants'
from posting and distributing Libeli's Social Security number and personal identifying
information; enjoin the Defendants' from any further harassment of the Plaintiffs', enjoin
Defendants' from the filing and reporting of falsified criminal activity, etc.;
B. An immediate Order enjoining Defendants, Taitz, Defend our Freedoms
Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any
C. An immediate Order of Retraction against Defendants, Taitz, Defend our
Freedoms Foundation, Inc., Neil Sankey, the Sankey Finn and Sankey Investigations,
Inc., and any party who has published Liberi's confidential information on their behalves
infonnation about her husband, the false criminal accusations, etc.;
D. An immediate Order of Retraction against Defendants', Taitz, Defend our
Freedoms Foundation, Inc., Sundquist, Rock Salt Publishing, and anyone on their behalf
from distributing Lisa Ostella's personal and confidential infonnation, including but not
limited to her home address and telephone number;
E Enjoin Defendants, Taitz, Defend our Freedoms, Inc. and Y osef, and any
party operating on their behalf from any further "hacking" of the Plaintiffs' computers;
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Defendants' for damages in the amount of One Million [$1,000,000.00] Dollars per
Defendant to be awarded to each and every separate Plaintiff herein;
Defendants' for compensatory damages in the amount of Five Hundred Thousand
[$500,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff
herein;
Defendants' for Punitive damages in the amount ofTen Million [$10,000,000.00] Dollars
per Defendant to be awarded to each and every separate Plaintiffherein;
I. Attorney's fees, costs and interest for each separate Plaintiff herein; and
COUNT THREE
FALSE-LIGHT INVASION OF PRIVACY
(Against all Defendants)
herein at length.
168. Defendants' defamatory statements about Plaintiffs' placed Plaintiffs' and their
staff in a false-light before the public.
169. The false-light in which Defendants' placed Plaintiffs' and their staff would be
highly offensive to a reasonable person.
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170. At all times Defendants' knew that their statements were false and/or acted in
reckless disregard of whether they were true or false.
17]. At all relevant times, Defendants' have acted with actual malice.
172. Defendants' defamatory statements about Plaintiffs' have had a deleterious
impact on Plaintiffs' and their businesses because they were forced to expend money
to defend against false statements and that they were embarrassed and humiliated.
173. Defendants' false statements about Plaintiffs' and their businesses have severely
injured the reputation and honorable services the Plaintiffs, their businesses and their
staff were providing.
their behalf from airing and/or publishing any defamatory or false statements about
Plaintiffs, Lisa Liberi, Philip J. Berg, the Law Offices of Philip J. Berg, Evelyn Adams,
Lisa Ostella, the Plaintiffs' family members, etc. via the internet or any other print or
electronic medium or broadcasts and/or radio, from portraying Plaintiffs in a false-light
via the internet or another print or electronic medium or broadcasts and/or radio, untrue
statements about the Plaintiffs'; enjoin the Defendants' from posting and distributing
Liberi's Social Security number and personal identifYing information; enjoin the
Defendants' from any further harassment of the Plaintiffs', enjoin Defendants' from the
filing and reporting of falsified criminal activity, etc.;
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party on their behalf from disseminating Liberi' s Social Security number, date of birth,
to immediately retract and remove Liberi's private confidential infonnation, including
information about her husband, the false criminal accusations, etc.;
Freedoms Foundation, Inc., Sundquist and Rock Salt Publishing and anyone on their
behalf from distributing Lisa Ostella's personal and confidential information, including
but not limited to her home address and telephone number.
E Enjoin Defendants, Taitz, Defend our Freedoms, Inc. and Y osef, and any
herein;
H. Enter Judb1ffient, collectively, jointly and separately, against the
Defendants' for Punitive damages in the amount ofTen Million [$lO,OOO,OOO.OO] Dollars
per Detendant to be awarded to each and every separate Plaintiff herein;
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l. Attorney's fees, costs and interest for each separate Plaintiff herein; and
COUNT FOUR
HARASSMENT
herein at length.
175. Defendants' have engaged in a longstanding and persistent campaign directed to
damaging the Plaintiffs, their staffs reputation and business by publishing on the
internet a massive volume of false statements and postings and broadcasting across
the internet and other channels false and defamatory statements regarding Plaintiffs'.
176. In conjunction with their campaign of internet disparagement, Defendants' have
further sent thousands of e-mails and other direct communications and has made
numerous phone calls making a variety of falsified statements, accusations about the
Plaintiffs' and Plaintiffs businesses and demands upon Plaintiffs' and their
businesses.
I 77. Plaintiffs' and their businesses have been alanned and felt threatened as a result
of the harassment and threats, which they have carried out, by the Defendants'.
178. Despite Plaintiff Adams reasonable efforts to address Defendants', Mr. and Mrs.
Hale and Plains Radio, allegations regarding the "Obama" divorce decree, Defendants
have persistently demanded additional information and for Plaintiff Berg to turn over
his certified set of the "Obama" divorce decree and demanding Plaintiff Adams to
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turn over Berg's certified set of his "Obama" divorce decree, Defendants Edgar (Ed)
and Caren Hale would go away.
179. Defendants have engaged in unreasonable and outrageous conduct directed to
harming the Plaintiffs' and their businesses unjustifiably and to coercing them to
accede to the Defendants demands.
180. Defendants have acted unlawfully and in violation of 18 U.S. C. §875(d), 47
U.S.C. §223(a), et ai, Texas Penal Code §42.07; the Women's Violence Act,
Department of Justice Reauthorization Act of 2005, H.R. 3402, titled "Preventing
Cyber-stalking" and numbered as § 113, § 113( a)(3) provides that Section
223(a)(1 )(C) applies to "any device or software that can be used to originate
telecommunications or other types of communications that are transmitted, in whole
or in part, by the internet; Cyber-stalking and Cyber-harassment laws in violation of
the Communications Act, 47 U.S.c. § 223(a)(1)(C) and § 223(h)(1)(B).
181. Plaintiffs' and their businesses have suffered losses and damages as a result of the
Defendants harassment.
WHEREFORE PlaintiffS' request:
their behalf from airing andlor publishing any defamatory or false statements about
electronic medium or broadcasts andlor radio, from portraying Plaintiffs in a false-light
via the internet or another print or electronic medium or broadcasts andlor radio, untrue
statements about the Plaintiffs' enjoin the Defendants' from posting and distributing
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Liberi's Social Security number and personal identifying infonnation; enJOIn the
C. An immediate Order of Retraction against Defendants Taitz, Defend our
Freedoms Foundation, Inc., Neil Sankey, the Sankey Finn and Sankey Investigations and
any party who has published Liberi's confidential infonnation on their behalves to
immediately retract and remove Liberi's private confidential infonnation, including but
not limited to her Social Security number, date of birth, where she resides, infonnation
about her husband, the false criminal accusations, etc.;
Freedoms Foundation, Inc., Sundquist and Rock Salt Publishing, and anyone on their
behalf from distributing Lisa Ostella's personal and confidential infonnation, including
but not limited to her home address and telephone number;
E Enjoin Defendants, Taitz, Defend our Freedoms, [nco and Y osef, and any
party operating on their behalf from any further "hacking" ofthe Plaintiffs' computers;
Detendants' for damages in the amount of One Million [$1,000,000.00] Dollars per
Detendant to be awarded to each and every separate Plaintiff herein;
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herein;
per Defendant to be awarded to each and every separate Plaintiff herein;
L Attorney's fees, costs and interest for each separate Plaintiff herein; and
COUNT FIVE
FALSE DESIGNATIONS AND DESCRIPTIONS OF FACTS
(Against all Defendants)
herein at length.
183. PlaintifTs' and their businesses have invested considerable effoli and expense in
establishing goodwill in their names and in promoting their careers and professional
reputation. Liberi in promoting her profession as a skillful and highly competent
Legal Assistant and Paralegal; Berg in promoting his profession as skillful and highly
competent provider as a prominent attorney with a professional staff and law finn;
Adams in promoting her profession as a skillful and highly competent radio
hostlbroadcaster; and Ostella and Go Excel Global in promoting her profession as a
skillful and highly competent Webmaster and a Website Hosting Company.
184. Defendants have published on the internet numerous statements in conjunction
with false and misleading designations and false and misleading descriptions and
representations of fact.
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185. Defendants' false and misleading statements about the Plaintiffs' and their
businesses are likely to cause and have caused public confusion regarding their
assoc1ations, intents and purposes. Those false and misleading statements further
have grossly misrepresented the nature, characteristics and quality of the Plaintiffs'
and their businesses services.
186. Defendants' false and misleading statements about Plaintiffs' and their businesses
have been designed to tarnish and have tarnished the Plaintiffs' and their businesses
names, reputation and business.
187. On information and belief, Defendants' have acted with an intent and design to
achieve publicity, fame and notoriety for themselves and thereby enhance the market
for the Defendants' regarding the Obama lawsuits.
188. The Defendants' false and misleading statements about Plaintiffs' and their
businesses have been designed to harm and have harmed Plaintiffs', and their
businesses and have caused losses and damages to the Plaintiffs' and their businesses.
] 89. Defendants' have engaged in unlawful conduct in violation of 15 U.S.C. §1125,
False designations of origin, false descriptions, and dilution forbidden.
Lisa Ostella, the Plaintiffs' family members, etc., via the internet or any other print or
via the internet or another print or electronic medium or broadcasts andlor radio, untrue
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statements about the Plaintiffs', enjoin the Defendants' from posting and distributing
Liberi's social security number and personal identifying information; enjoin the
B. An immediate Order enjoining Defendants Taitz, Defend our Freedoms
C. An immediate Order of Retraction against Defendants Taitz, Defend our
information about her husband, the false criminal accusations, etc.;
behalf from distributing Lisa Ostella's personal and confidential information, including
but not limited to her horne address and telephone number;
E Enjoin Defendants, Taitz, Defend our Freedoms, Inc. and Yosef, and any
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herein;
per Detendant to be awarded to each and every separate Plaintiff herein;
I. Attorney's fees, costs and interest for each separate Plaintiffherein; and
COUNT SIX
INJUNCTIVE RELIEF
herein at length.
191. The Defendants' defamatory statements about Plaintiffs' and their businesses
have damaged Plaintiffs' and their businesses reputation as well as Liberi's effective
and skillful law experience; Berg's law practice, Adams Radio Shows and Ostella's
Web Mastering and Web Hosting Company, Go Excel Global with false allegations,
misrepresentations of their character and publicity that placed them in false-light.
Such intentional and recklessly made statements have caused Plaintiffs, their staff and
their businesses ineparable harm for which there is no adequate remedy at law.
192. As a direct and proximate result of the Defendants' defamatory statements, the
Plaintiffs' and their businesses have lost present and future business opportunities,
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has suffered and will sutfer, irreparable harm to their reputation and standing in the
legal, radio, webmaster and web hosting communities, and have suffered and will
sufter restrictions on their ability to pursue support for future endeavors for which
there is no adequate remedy at law.
193. Plaintiffs' will likely succeed on the merits of its underlying case.
194. The injunctive relief sought will not adversely aftect the publics' interests.
195. As a direct and proximate result of the Defendants illicit actions, Plaintiffs' and
their businesses are entitled to an injunction against the Defendants'.
196. It has been necessary for the Plaintiffs' to retain the services of an attorney to
obtain redress, and Plaintiffs are entitled to reasonable attorney fees and costs
therefore.
Plaintiffs, Lisa tiberi, Philip J. Berg, the Law Offices of Philip J. Berg, Evelyn Adams,
via the internet or another print or electronic medium or broadcasts and/or radio, untrue
statements about the Plaintiffs' enjoin the Defendants' from posting and distributing
Libel1's Social Security number and personal identifying information; enjoin the
filing and reporting of falsified criminal activity, etc.~
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FOWldation, Inc., Neil Sankey, the Sankey Fiml and Sankey Investigations, Inc., and any
Freedoms Foundation, Inc., Neil Sankey, the Sankey Fiffil and Sankey Investigations,
Inc., and any party who has published Libert's confidential infonnation on their behalves
to immediately retract and remove Libert's private confidential infoffilation, including
infonnation about her husband, the false criminal accusations, etc.;
behalf from distributing Lisa Ostella's personal and confidential infoffilation, including
but not limited to her home address and telephone number;
E Enjoin Detendants, Taitz, Defend our Freedoms, Inc. and Yosef, and any
[$500,000.00J Dollars per Defendant to be awarded to each and every separate Plaintiff
herein;
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per Defendant to be awarded to each and every separate Plaintiff herein;
I. Attorney's fees, costs and interest for each separate Plaintiff herein; and
Date: May 04, 2009 Respectfully submitted,
Phi~;c;;z:s::
J. Berg,sclUire
Attorney for Plaintiffs
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VERIFICATION
1, Philip J. Berg, Esquire, hereby state that 1 am a Plaintitlin this action and verify
that the statements made in the foregoing Complaint are true and correct to the best of my
knowledge, information and belief. The undersigned understands that the statements
therein are made subject to the penalties of 18 Pa. C.S. Section 4904 and the laws of the
United States relating to unsworn falsification to authorities.
Dated: May 4,2009
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VERIFICATION
I, Evelyn Adams, hereby state that I am a Plaintiff in this action and verify that
the statements made in the foregoing .Complaint are true and correct to the best of my
Knowledge, information and belief. The undersigned upderstands that the statements

v'""\ ./
.' J
Dated: April ~2009 - ,- ~~;d (~
EV-ELYN AD~Plaintiff
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VERIFICATION
I, Lisa M. Ostella, hereby state that I am a Plaintiff in this action and verify that
the statements made in the foregoing .Complaint are true and correct to the best of my
Knowledge, information and belief. The undersigned understands that the statements
Dated: April::£2009 ~h C?~

LISA M. OSTELLA, Plaintiff
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VERIFICATION
1, Lisa Liberi, hereby state that I am a Plaintiff in this action and verify that the
statements made in the foregoing .Complaint are true and correct to the best of my
Knowledge, information and belief The undersigned understands that the statements
Dated: April 25, 2009

LISA LIBERJ, Plaintiff
Page A85
EXHIBIT "B"
Case: Case
10-3000
2:09-cv-01898-ER
Document: 003110340419
Document 76 Page:
Filed 06/26/09
2 Date Page
Filed: 111/07/2010
of 1
IN THE UNITED STATES DISTRICT COURT

LISA LIBERI et al., : CIVIL ACTION

: NO. 09-1898
Plaintiffs, :
:
v. :
:
ORLY TAITZ et al., :
:
Defendants. :
O R D E R
AND NOW, this 25th day of June, 2009, it is hereby
ORDERED that Plaintiffs’ motion to dismiss Defendants James
Sundquist and Rock Salt Publishing (doc. no. 62) is GRANTED.
IT IS FURTHER ORDERED that Defendants James Sundquist
and Rock Salt Publishing are DISMISSED without prejudice.1
AND IT IS SO ORDERED.
s/Eduardo C. Robreno
EDUARDO C. ROBRENO, J.
1
To the extent that Plaintiffs have requested that Mr.
Sundquist and Rock Salt Publishing compensate them for the cost
of service in this case, that request is DENIED. The dismissal
without prejudice of Mr. Sundquist and Rock Salt Publishing is
not conditioned upon any payment to Plaintiffs.
Page B1
EXHIBIT "C"
Case: Case
10-3000 Document: 003110340420
2:09-cv-01898-ER Document 80 Page: 2 Date Page
Filed 06/26/09 Filed: 111/07/2010
of 2

LISA LIBERI et al., : CIVIL ACTION

: NO. 09-1898
Plaintiffs, :
:
v. :
:
ORLY TAITZ et al., :
:
Defendants. :
O R D E R
AND NOW, this 25th day of June, 2009, it is hereby
ORDERED that a rule is ISSUED upon Plaintiffs to show cause as to
why their Complaint should not be dismissed for lack of personal
jurisdiction.1
IT IS FURTHER ORDERED that a rule is ISSUED upon
Plaintiffs to show cause why this case should not be severed into
three (3) or fewer cases against the following groups of
Defendants: (1) Edgar & Caren Hale, Plains Radio Network, Bar H.
Farms and KPRN AM 1610; (2) Linda S. Belcher; (3) Orly Taitz,
Defend Our Freedoms Foundations, Inc., Neil Sankey, Sankey
Investigations, Inc. and The Sankey Firm.2
1
Plaintiffs must support their response with specific
facts, in the form of affidavits or other admissible evidence,
which support that the Eastern District of Pennsylvania is the
proper forum for this litigation as to each Defendant.
2
Plaintiffs must support their response with specific
facts, in the form of affidavits or other admissible evidence,
which demonstrate a common scheme or purpose among all of the
Defendants such that it would be appropriate to try these
Defendants in a single case.
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IT IS FURTHER ORDERED that a rule is issued upon
Plaintiffs to show cause why this case should not be transferred
to an appropriate district in either Texas or California,
pursuant to 28 U.S.C. § 1404(a).3
IT IS FURTHER ORDERED that these rules are returnable
on Plaintiffs by Monday, July 27, 2009. Defendants shall have
until Wednesday, August 26, 2009 to reply to Plaintiffs’
responses.
3
In their response, Plaintiffs must address the specific
public and private interests that apply in this case, as
articulated by the Third Circuit in Jumara v. State Farm Ins.
Co., 55 F.3d 873, 879-80 (3d Cir. 1995).
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LISA LIBERI, et al., : CIVIL ACTION

: NO. 09-1898
Plaintiffs, :
:
v. :
:
ORLY TAITZ, et al., :
:
Defendants. :
M E M O R A N D U M
EDUARDO C. ROBRENO, J. June 3, 2010
I. BACKGROUND
On May 4, 2009, Plaintiffs Lisa Liberi (“Liberi”),
Philip J. Berg, Esq. (“Berg”), the Law Offices of Philip J. Berg,
Evelyn Adams a/k/a Momma E (“Adams”), Lisa Ostella (“Ostella”),
and Go Excel Global (collectively, “Plaintiffs”) initiated this
defamation, libel and slander action against Defendants Orly
Taitz (“Taitz”), Defend our Freedoms Foundations, Inc. (“DOFF”),
Neil Sankey, The Sankey Firm and Sankey Investigations, Inc.
(collectively, "Sankey"), Edgar Hale, Caren Hale, Plains Radio,
KPRN AM 1610, Bar H. Farms, Plains Radio Network (collectively,
“the Hales”), and Linda Sue Belcher (collectively,
“Defendants”).1
1
Some of these parties have a long and complicated
litigation history. See e.g., Berg v. Obama, 586 F.3d 234 (3d
Cir. 2009); Rhodes v. MacDonald, 670 F. Supp. 2d 1363 (M.D. Ga.
2009) (imposing $20,000 sanction on counsel Orly Taitz for use of
the legal process for an improper purpose), aff'd Rhodes v.
MacDonald, 2010 U.S. App. LEXIS 5340 (11th Cir. Mar. 15, 2010).
This litigation appears to be part of this overall dispute among
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Plaintiffs allege that, though at one time the parties
worked together on a movement to prove that President Barack
Obama is not a natural-born citizen, Defendants allegedly
published personal and defamatory information in a “quest to
destroy” Plaintiffs.
Jurisdiction for this action is predicated upon
diversity of citizenship. 28 U.S.C. § 1332. The citizenship of
all parties is as follows. For Plaintiffs: Berg and Liberi are
Pennsylvania citizens, Adams is an Oklahoma citizen, and Ostella
and Go Global are citizens of New Jersey. For Defendants: Taitz,
DOFF, and Sankey are citizens of California, Sundquist and Rock
Salt Publishing are citizens of New Jersey, and Belcher and the
Hales are citizens of Texas.2
Here, Sankey, Hale, and Belcher have moved to dismiss
the case or, in the alternative, requested a transfer of venue,
pursuant to 28 U.S.C. § 1406(a), to the Western District of
Texas. Defendant Taitz moved to dismiss based on lack of
diversity jurisdiction, under Fed. R. Civ. P. 12(b)(1), and the
insufficiency of Plaintiffs’ claims. Plaintiffs filed responses
thereto, opposing each of Defendants’ motions to dismiss. This
Court denied all motions to dismiss without prejudice and
the parties.
2
On June 26, 2009, the Court granted Plaintiffs’ motion
to dismiss Defendants Sundquist and Rock Salt Publishing. See
doc. no. 76.
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subsequently, in order to focus the issues, issued a rule to show
cause as to why the action should not be severed and the claims
transferred to the home jurisdiction of each Defendant. The
parties have submitted multiple responses and replies thereto.
Pursuant to 28 U.S.C. § 1404(a), it is proper for a
district court to issue an Order to Show Cause as to why an
action should not be transferred. See, e.g., Minkoff v. Chubb
Corp., 2009 U.S. Dist. LEXIS 29137 (D.N.J. Apr. 6, 2009). Here,
the Court directed Plaintiffs to show cause as to why their
complaint should not be dismissed on any one of the following
three grounds. First, why this case should not be dismissed for
lack of personal jurisdiction. Second, why this case should not
be severed into three (3) or fewer cases against the following
groups or Defendants: (i) the Hales; (ii) Belcher; (iii) Taitz,
DOFF, and Sankey. Third, why this case should not be transferred
to an appropriate district in either Texas or California,
pursuant to 28 U.S.C. § 1404(a).3
3
On August 10, 2009, Plaintiffs appealed the Court’s
denial of their motion for an injunction or restraining order to
the Third Circuit. On December 9, 2009, this case was placed in
suspense pending determination of the appeal. See doc. no. 83.
On May 26, 2010, the Third Circuit granted Plaintiffs’ motion to
withdraw their appeal, pursuant to Fed. R. App. P. 42(b). See
Liberi v. Taitz, No. 09-3403, dated 5/26/10.
Throughout the period of time Plaintiffs’ appeal was

pending before the Third Circuit, the parties filed numerous
motions, seeking leave to file further pleadings. However, since
the case was in suspense and inactive, Plaintiffs’ many requests
for leave to file are denied as moot.
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The matter is now ripe for disposition.
II. DISCUSSION
First, the Court has subject matter and personal
jurisdiction over Defendants. A federal district court may
exercise diversity jurisdiction, under 28 U.S.C. § 1332, where
all parties are citizens of different states and the amount in
controversy sought exceeds $75,000. At the time of the filing of
the complaint, Plaintiffs Ostella and Go Global and Defendants
Sundquist and Rock Salt Publishing were citizens of New Jersey;
however, because their presence in the litigation would destroy
diversity, the New Jersey defendants were voluntarily dismissed
from the case by Plaintiffs. Therefore, all remaining parties
are diverse and there is no issue as to the amount in
controversy. Further, Plaintiffs had made out a prima facie case
for personal jurisdiction over each Defendant as the allegedly
defamatory statements at issue were directed towards Plaintiffs
in Pennsylvania and could be covered under the Pennsylvania long
arm statute. 42 Pa. C.S. § 5322(b) (providing that the
Pennsylvania long arm statute is coextensive with the due process
clause); Time Share Vacation Club v. Atl. Resorts, Ltd., 735 F.2d
61, 63 (3d Cir. 1984); Giusto v. Ashland Chem. Co., 994 F. Supp.
587, 592 (E.D. Pa. 1998) (“Moreover, defamation and libel may be
unique in that the act can be done in one place, but the effects
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may foreseeably be felt in some distant location.”).
Second, pursuant to § 1404(a) and in consideration of
“the convenience of parties and witnesses, [and] in the interest
of justice, a district court may transfer any civil action to any
other district or division where it might have been brought.” 28
U.S.C. § 1404(a). Section 1404(a) provides that “where a case
could have been brought against some defendants in the transferee
district, the claims against those defendants may be severed and
transferred while the claims against the remaining defendants,
for whom transfer would not be proper, are retained." D’Jamoos
v. Pilatus Aircraft Ltd., 566 F.3d 94, 110 (3d Cir. 2009) (citing
White v. ABCO Eng'g Corp., 199 F.3d 140, 144 (3d Cir. 1999)).4
Likewise, the Court may transfer all the severed claims to
different districts, provided each of the claims being
transferred satisfies § 1404(a). Id.
Pursuant to § 1404(a), “[o]nce a court determines that
venue would be proper in another district, the court must
consider ‘all relevant factors to determine whether on balance
the litigation would more conveniently proceed and the interests
of justice be better served by transfer to a different forum.’”
Sentry Select Ins. Co. v. LBL Skysytems, Inc., 486 F. Supp. 2d
4
In D’Jamoos, the Third Circuit contemplated a severance
and transfer of cases under § 1631, however the Circuit
specifically noted that, for purposes of inter-district
transferring, § 1631 and § 1404(a) were comparable. 566 F.3d at
110.
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496, 505 (E.D. Pa. 2007) (quoting Jumara v. State Farm Ins. Co.,
55 F.3d 873, 879 (3d Cir. 1995)). In considering a motion for
transfer under § 1404(a), the court should consider both private
and public interests. Jumara, 55 F.3d at 879-80.
In this case, severance and transfer are warranted.
First, the Court, in its Order to Show Cause, apprised “all
relevant parties . . . that the court is considering a transfer”
so opposition could be filed. Id. at 144. Therefore, each party
to the litigation was on notice and was afforded an opportunity
to be heard on the issue.
Second, similar to the claims asserted in D’Jamoos, a
prima facie case for personal jurisdiction has been made over
each Defendant in Pennsylvania, allowing for transfer to their
respective home states. 566 F.3d at 109.
Third, in applying § 1404(a), the Court is directed by
Jumara to consider both public and private factors warranting
severance and transfer. The “private interests” to consider
include: (1) the plaintiff’s forum preference as manifested in
the original choice; (2) the defendant’s preference; (3) whether
the claim arose elsewhere; (4) the convenience of the parties as
indicated by their relative physical and financial conditions;
(5) the convenience of witnesses, only to the extent that a
witness may be unavailable for trial in one of the fora; and (6)
the location of books and records, again only to the extent they
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may be unavailable in one of the fora. Jumara, 595 F.3d at 879.
Relevant “public interests” include: (1) the
enforceability of any judgment; (2) practical considerations that
could make the trial easy, expeditious, or inexpensive; (3) the
relative administrative difficulties in the two fora resulting
from court congestion; (4) local interest in deciding local
controversies at home; (5) public policies of the fora; and (6)
the familiarity of the trial judge with the applicable state law
in diversity cases. Id. at 879-880.
As to the private interests, other than the belief held
by all Defendants that President Barack Obama is not a natural-
born citizen, it appears that Defendants made the allegedly
defamatory statements independent of each other and not in a
concerted fashion. Further, under the facts alleged, each of
Defendants’ allegedly defamatory statements emanated from their
home jurisdictions.
Under these circumstances, private interests
overwhelmingly weigh in favor of transfer. Although Plaintiffs
initially sought this District as their forum, they have now
petitioned the Court to transfer the entire case to the Central
District of California. All Defendants have already made it
clear that they prefer to litigate in their home districts.
Therefore, the convenience of the parties and witnesses will be
served by transferring the case to a venue where the respective
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parties and witnesses reside.
As to the public factors, they also weigh in favor of
transfer. Issues revolving around the alleged defamatory
statements and the context in which they were made are best
decided by a local jury. Therefore, severance of the individual
claims and parties, and transfer to the home district of each of
the Defendants is warranted here.
III. CONCLUSION
After careful consideration of the convenience of the
parties and witnesses, interests of justice, judicial economy,
and private and public interests, the Court will SEVER the claims
into two independent actions and TRANSFER the cases back to the
appropriate jurisdictions.5
An appropriate order follows.
5
Claims against Defendants Linda Sue Belcher, Edgar
Hale, Caren Hale, Plains Radio Network, Bar H. Farms, and KPRN
A.M. 1610, Neil Sankey and Sankey Investigations, Inc. will be
transferred to the Western District Court of Texas, the
jurisdiction of which Belcher and the Hales are citizens. Claims
against Defendants Orly Taitz and Defend Our Freedoms Foundations
are transferred to the Southern Division of the Central District
of California, the jurisdiction of which Orly Taitz and Defend
Our Freedoms Foundations are citizens.
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: NO. 09-1898
Plaintiffs, :
:
v. :
:
:
Defendants. :
O R D E R
AND NOW, this 3rd day of June, 2010, it is hereby
ORDERED that to the extent that Defendants' motion seeks to sever
and transfer this case from the Eastern District of Pennsylvania,
the motion is GRANTED.
IT IS FURTHER ORDERED that this Court will now SEVER
the instant case into two separate, independent actions and
TRANSFER each action to the jurisdiction of the following
district courts. All claims pending against Defendants Linda Sue
Belcher, Edgar Hale, Caren Hale, Plains Radio Network, Bar H.
Farms, and KPRN A.M. 1610, Neil Sankey and Sankey Investigations,
Inc. are transferred to the Western District Court of Texas. All
claims pending against Defendants Orly Taitz and Defend Our
Freedoms Foundations are transferred to the Southern Division of
the Central District of California.
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IT IS FURTHER ORDERED that Defendants' motion to
dismiss or, in the alternative, motion to transfer (doc. no. 10)
is DENIED as moot.1
IT IS FURTHER ORDERED that this case shall be marked
CLOSED.
1
All requests for leave to file pleadings submitted
during the time the case was in suspense from December 9, 2009 to
June 2, 2010, and of which only one letter was made part of the
docket (see Berg Letter in Opp'n to Def. Taitz, dated Jan. 10,
2010, doc. no. 116), are denied as moot.
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: NO. 09-1898
Plaintiffs, :
:
v. :
:
:
Defendants. :
M E M O R A N D U M
EDUARDO C. ROBRENO, J. June 22, 2010
I. BACKGROUND
On May 4, 2009, Plaintiffs Lisa Liberi (“Liberi”),
Philip J. Berg, Esq. (“Berg”), the Law Offices of Philip J. Berg,
Evelyn Adams a/k/a Momma E (“Adams”), Lisa Ostella (“Ostella”),
and Go Excel Global (collectively, “Plaintiffs”) initiated this
defamation, libel and slander action against Defendants Orly
Taitz (“Taitz”), Defend our Freedoms Foundations, Inc. (“DOFF”),
Neil Sankey, The Sankey Firm and Sankey Investigations, Inc.
(collectively, "Sankey"), Edgar Hale, Caren Hale, Plains Radio,
KPRN AM 1610, Bar H. Farms, Plains Radio Network (collectively,
“the Hales”), and Linda Sue Belcher (collectively, “Defendants”).
On June 3, 2010, the Court severed the action and
transferred the claims to each Defendant’s home jurisdiction.
Before the Court is Plaintiff Berg’s motion for leave to file a
motion for reconsideration (doc. no. 120), Defendant Taitz’s
response (doc. no. 121) and Defendant Sankey’s response (fax
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dated 6/11/10). On June 18, 2010, Plaintiff Berg filed a motion
for leave to file a motion to strike Defendant Taitz’s response
(doc. no. 122).
II. MOTION FOR RECONSIDERATION
A. Legal Standard
A motion for reconsideration is treated as the
“functional equivalent” of a motion pursuant to Rule 59(e) which
seeks to alter or amend a judgment. Fed. Kemper Ins. Co. v.
Rauscher, 807 F.2d 345, 348 (3d Cir. 1986) (internal citation
omitted). The purpose of a motion for reconsideration is to
“correct manifest errors of law or fact or to present newly
discovered evidence.” Harsco Co. V. Zlotnicki, 779 F.2d 906, 909
(3d Cir. 1985). Reconsideration is appropriate where the party
seeking reconsideration establishes “(1) an intervening change in
the controlling law; (2) the availability of new evidence that
was not available when the court . . . [issued its previous
decision]; or (3) the need to correct a clear error of law or
fact or prevent manifest injustice.” Max’s Seafood Cafe ex rel.
Lou Ann v. Quinteros, 176 F.3d 669, 677 (3d Cir. 1999); North
River Ins. Co. v. CIGNA Reinsurance Co., 52 F.3d 1194, 1218 (3d
Cir. 1995); U.S. v. Cabiness, 278 F. Supp. 2d 478. 483-84 (E.D.
Pa. 2003) (Robreno, J.).
B. Proposed Grounds for Reconsideration
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On June 7, 2010, Plaintiff Berg faxed a motion for
leave to file a motion for reconsideration. See doc. no. 120
(docketed 6/13/10). Defendant Taitz responded by fax on June 10,
2010 and Defendant Sankey responded by fax on June 11, 2010. See
Taitz 6/10/10 Ltr., doc. no. 121 (docketed 6/14/10); see also
Sankey 6/11/10 Ltr. Mr. Sankey’s response was not filed of
record.1
In his letter, Plaintiff Berg lists eight purported
errors in the Court's 6/3/10 Order that severed the action and
transferred the claims to each of Defendants’ home jurisdictions.
Upon review, Plaintiff Berg actually raises only three discrete
issues. Importantly, Plaintiff Berg’s motion does not argue that
the legal conclusions set forth in the Memorandum were incorrect.
The three outstanding administrative errors raised by
Plaintiff Berg are grouped as follows.
1. Points 6, 8 and 9
Points 6, 8 and 9 are as follows:
1
Defendant Taitz’s response does not substantively
address Plaintiff Berg’s motion for leave to file a motion for
reconsideration, thus it is inapposite to the issues at bar.
Defendant Sankey’s letter disputes Plaintiff Liberi’s
assertions of Pennsylvania citizenship and argues that Plaintiff
Liberi is a citizen of New Mexico. See Sankey Ltr., dated June
11, 2010. However, diversity jurisdiction would only be
destroyed if Plaintiff Liberi was a citizen of either of the
states of which Defendants are citizens: California or Texas.
Thus, the issue is inapposite to Plaintiff Berg’s motion for
leave to file a motion for reconsideration and the legal
conclusions reached in this case.
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Point 6: There is a discrepancy in the Court’s Order of

June 3, 2010, docketed on June 4, 2010
appearing as Docket Entry No. 118;
Point 8: Amendment of this Court’s June 3, 2010 Order,

docketed June 4, 2010, appearing, as Docket
Entry No. 118 is proper. This Court has the
inherent Power to amend its Final Judgment;
and
Point 9: A proposed Order is attached to Plaintiffs’

Motion.
See Berg Mot. Reconsideration 2, doc. no. 120.
These notations are not relevant to the legal
disposition of this case. Therefore, Points 6, 8 and 9 will be
denied.
2. Points 1, 2, 3, 4 and 5
Points 1, 2, 3, 4 and 5 are as follows:
Point 1: This Court concedes on page two (2), second

(2nd) paragraph of the Court’s Memorandum
[Doc. No. 117] that the Sankey Defendants,
which would be Neil Sankey, Sankey
Investigations, Inc. and The Sankey Firm, Inc.
a/k/a The Sankey Firm are citizens and
residents of the State of California;
Point 2: Defendants Neil Sankey and Sankey

Investigations, Inc. are not within the
jurisdiction of the U.S. District Court,
Western District of Texas, but instead are
located in the Central District of California;
Point 3: Although in Default, the Court made no mention

of transfer as to Defendant, The Sankey Firm,
Inc. a/k/a The Sankey Firm. Is the Court
planning on keeping this one Defendant and
allowing Plaintiffs to enter Default against
them?; If not then,
Point 4: The Sankey Firm, Inc. a/k/a The Sankey Firm is

a California Corporation, in the U.S. District
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Court, Central District of California,

Southern Division jurisdiction. Therefore,
transfer of Plaintiffs’ claims against this
Defendant is only proper to the U.S. District
Court, Central District of California,
Southern Division; and
Point 5: Defendants Neil Sankey, Sankey Investigations,

Inc. and The Sankey Firm, Inc. a/k/a The
Sankey Firm conducted the offenses giving rise
to this suit from their office locations in
California.
See id. at 1-2.
The final Memorandum correctly identifies Defendants
Neil Sankey, The Sankey Firm and Sankey Investigations, Inc. as
citizens of California; however, the original Order, dated June
3, 2010, incorrectly transferred their case to Texas instead of
California. The enclosed Amended Order corrects this error and
transfers Neil Sankey, The Sankey Firm and Sankey Investigations,
Inc. to the Southern Division of the Central District of
California.
No prejudice has resulted because the cases have not
yet been transferred and the error has no impact on the legal
conclusions reached in this case. Therefore, Plaintiff Berg’s
motion for reconsideration is granted as to Points 1-5.
3. Point 7
Point 7 is as follows:
Point 7: None of the Parties to this Action asked for

severance of the Case; The Court’s Order
states Defendants Motion to Transfer is
Granted; and on page two (2) states
Defendants’ Motion to Dismiss or, in the
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alternative, Motion to Transfer (doc. No. 10)

is Denied as Moot. First, Doc. No. 10 is an
Affidavit of Service, not a Motion to Dismiss
or in the alternative to Transfer. It is
believed the Court meant Plaintiffs’ Motion to
Transfer is Granted, as Plaintiffs’ had a
pending Motion to Transfer the Case.
See id. at 2.
In Point 7, Plaintiff Berg requests that Defendants’
motion to dismiss or, in the alternative, motion to transfer
(doc. nos. 24, 25) be denied as moot. However, in its 6/25/09
Order, the Court already denied Defendants’ motion to dismiss or,
in the alternative, motion to transfer (doc. nos. 24, 25). See
Ct. 6/25/09 Order, doc. no. 77.
Currently, there are no motions pending that have not
been previously denied as moot. As such, Point 7 will be denied
as moot. See docket.
III. CONCLUSION
Plaintiff Berg’s motion for leave to file a motion for
reconsideration will be granted. Points 1, 2, 3, 4 and 5 of the
motion for reconsideration will be granted and Points 6, 7, 8 and
9 will be denied as moot.
Plaintiff Berg’s motion for leave to file a motion to
strike Defendant Taitz’s response will be denied as moot.
An amended Order follows.
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: NO. 09-1898
Plaintiffs, :
:
v. :
:
:
Defendants. :
AMENDED ORDER
AND NOW, this 22nd day of June, 2010, it is hereby
ORDERED that the Court Order, dated June 3, 2010, is AMENDED as
follows. On June 25, 2009, the Court issued a rule to show cause
upon Plaintiff as to why this case should not be (1) dismissed
for lack of personal jurisdiction; (2) severed into three or
fewer cases against the following groups or Defendants: (i) the
Hales; (ii) Belcher; (iii) Taitz, DOFF, and Sankey; and (3)
transferred to an appropriate district in either Texas or
California, pursuant to 28 U.S.C. § 1404(a).1 See Court Order,
doc. no. 80.
IT IS FURTHER ORDERED that, upon consideration of
Plaintiffs’ responses to the rule to show cause, Defendants’
1
On June 25, 2009, the Court issued an order that no
further motions shall be filled without prior leave of the Court.
See Court Order, doc. no. 78. No motions granted leave to file
are currently pending.
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2 of 2
replies thereto and Plaintiff Berg's motion for reconsideration,
the Court will now SEVER the instant case into two separate,
independent actions and TRANSFER each action to the jurisdiction
of the following district courts. All claims pending against
Defendants Linda Sue Belcher, Edgar Hale, Caren Hale, Plains
Radio Network, Bar H. Farms, and KPRN A.M. 1610 are transferred
to the Western District Court of Texas. All claims pending
against Defendants Orly Taitz, Defend Our Freedoms Foundations,
Neil Sankey, The Sankey Firm and Sankey Investigations, Inc. are
transferred to the Southern Division of the Central District of
California.2
IT IS FURTHER ORDERED that this case shall be marked
CLOSED.
2
All requests for leave to file pleadings submitted
during the time the case was in suspense from December 9, 2009 to
June 4, 2010, of which only one letter was made part of the
docket (see Berg Letter in Opp'n to Def. Taitz, dated Jan. 10,
2010, doc. no. 116), are denied as moot.
- 2 -
Page G2
EXHIBIT "H"
Evidence of fraud on the court, perjury by Berg, Liberi, Ostella, fabricatio... http://www.orlytaitzesq.com/?p=12814
http://www.orlytaitzesq.com/?p=12814
Home
1.4 million people saw this clip, send it to another 1.4 million
Appeal of Carter Case
elections fraud around the country
From reader Carol
Quo Warranto Filed and Served
US state dep is paying to restore mosques around the world

Defend Our Freedoms Foundation – 29839 Santa Margarita Pkwy, ste 100, Rancho
Santa Margarita CA, 92688 – Copyright 2010
World's Leading Obama Eligibility Challenge Web Site

Your donations to the cause are much appreciated.
WHEN THE PEOPLE FEAR THEIR GOVERNMENT,
THERE IS TYRANNY.
WHEN THE GOVERNMENT FEARS THE PEOPLE,
THERE IS LIBERTY.
- Thomas Jefferson
The articles posted represent only the opinion of the writers, do not necessarily represent the opinion of Dr. Taitz, ESQ, and Dr. Taitz, ESQ has no means of
checking the veracity of all the claims and allegations in the articles.
Evidence of fraud on the court, perjury by Berg,

Liberi, Ostella, fabrication of evidence and vicious
attacks on me by Berg
Posted on | August 4, 2010 | 7 Comments
Page H1
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Liberi-v-Taitz-Transcript-of-08-07-09-hearing.pdf
Category: Uncategorized
Comments
7 Responses to “Evidence of fraud on the court, perjury by Berg, Liberi, Ostella, fabrication of evidence and
vicious attacks on me by Berg”
1. Brianroy
August 4th, 2010 @ 10:56 pm
I went through the whole transcript.

I noticed that the pro-Berg witnesses on the stand contradicted themselves, and were given over to
sniping slander at every opportunity.
Further, Mr. Hale’s sound clips appeared to derail Berg’s presentation. Witnesses conveniently leaving
important data at home, not showing up with filed police reports in hand, saying that they spoke once
with someone and only once, in both February and in November, etc. And Berg used to be an Assistant
District Attorney? What a disappointment…no wonder he isn’t one anymore. He’s supposed to know
about preparing witnesses if he is any kind of competent lawyer…but clearly his own staff as witnesses
are clearly disgraceful.
I can tell you, if I was being harassed and had to go to Court, I would come with every bit of legal
material possible, from police reports to what have you, and go after the opposition as aggressively
legally and peacefully as the Court would allow me in the time allotted before the judge. There would
be no messing around like Berg and his staff did in the hearing…no I left it at home, or I didn’t bring
that, but somebody has it somewhere nonsense.
At one point in the transcript, when Mr. Hale objected to a Berg witness, the Berg witness answered in
such a way as if her statement, even though it was perjorious then and and it is perjorious now…well,
that doesn’t count, because it wasn’t then under oath or penalty of perjury? What kind of an answer is
that?
I have previously posted at the top of my blog to support your nomination to California’s Secretary of
State for the Republican Party in November 2010. It isn’t visited very much, but you do have
grassroots support morally by many of us who are considered poor and the peons of society.
I still await Damon Dunn’s removal as illegitimate, and after careful examination of the hearing
transcript of Berg, Liberi, Ostella…I still see no reason to either withdraw or be concerned in even the
least regarding designating you, Orly Taitz, as the one who should be California’s next Secretary of
State: one who will then truly have virtually uncontested legal standing from activist judges, being able
to sue on Healthcare and any number of other issues (using 333 US 640 @ 653 et al.) to expedite the
usurper Obama right out of the White House, reverse his entire usurpation of Office and all Laws back
to a status of Laws in effect on January 19, 2008; and truly help to save this nation (at least
temporarily) from the Communist-Socialists seeking to overthrow this Republic and replace it with
some kind of oligarchal dictatorship.
Thank you Orly, for your service to this your new home Country. Thank you for legally immigrating,
and being one of our more outstanding citizens. Bless you.
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2. Henry Tisdale
August 5th, 2010 @ 8:19 am
Boy, do I love Brianroy’s comments. This person if full of vim and vinegar as we used to say in the
Navy. I cannot help but ask, is he or has he ever been on the Bench? He is quite knowledgeable in this
law business.
I need some updating, Orly. What happens to your case against Dunn now that Justice Thomas has
denied your request for stay? Or has he officially denied it? Whatever support you need in this SoS
thing, let me know. If it is within my reach, I will do my best.
3. ch
August 5th, 2010 @ 12:20 pm
http://www.wnd.com/index.php?fa=PAGE.view&pageId=187797
Talk about Fraud. Ellen Kagan participated in blocking lawsuits. Unbelievable. What a character. I
wonder if anybody has a list of all the lawsuits across the nationa attempted to get to the truth. We need
that list and the list of judges who blocked. The picture would be pretty interesting.
4. ch
August 5th, 2010 @ 2:44 pm
Some background information on world situation, not related to Berg….Iran, Iraq and Russia are not
yet allowed in World Trade Organization. Is that not interesting?
Saudi Arabia was not allowed entry until 2005. (4 years after 9/11).
So at time of attack, those 4 countries were all not allowed in the World Trade Organization. Why???
The World Trade Towers attacked in 9/11.
Russia and Saudi Arabia seem to act together in many world crises situations.
Just food for thought as lines of connection are drawn.
5. Citizen Don in California

August 5th, 2010 @ 4:46 pm
Just a quick comment. Even if you are not on the ballot in Nov. I will be writing your name in as Sec.
Of State for California. I do believe that write in’s are still legal.
Keep up the good work!!
6. dr_taitz@yahoo.com
August 5th, 2010 @ 5:48 pm
I am supposed to get a date for trial in OC CA
7. Phil
August 6th, 2010 @ 8:41 pm
Lady Liberty:…
Just wanted to say “thanks” to Henry for his gracious words on one of my recent posts. I’ve had some
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3 of 7 11/4/2010 10:40 PM
problems with accessing the site and sometimes I don’t get a chance to take the time to post, as well.
As I have some tech problems at my end-(?) and it keeps me from posting, when I would like to post!
So…let this post say that I do appreciate your words! I’ve had you and another person (“RETRIED!”)
post on one of my posts and say some good, “Patriotic” support for my efforts. That’s great to read!
So thanks again…to both of you! And I will endeavor to begin to do this myself, as I think this is a
“great idea” to offer “support” and “encouragement” to all of the people who post on Orlys’ Site!
And I think that doing this, when we get the chance, will bring about a “cohesive,” political “unit” for
our fight. Which will also help all of us to “hang tough”!
Your friend, Davey Crockett…
!! IMPORTANT NOTICES – PLEASE READ !!
NEW! CA REP CENTRAL COMMITTEE LIST

CAMPAIGN FLIER for Orly Taitz as CA SOS
CAMPAIGN FLIER for Orly Taitz as CA SOS, 2 Per Page
How to contact public Integrity unit
See The PDF File Here
US Department of Justice has a special unit in their Criminal Division called the
PUBLIC INTEGRITY SECTION
Contact Orly!
email: dr_taitz@yahoo.com Urgent? Call: 949-683-5411
Recent Posts
Tea Party Nation thread-2012
Great news! One of my clients in eligibility case, prominent MO attorney timothy Jones become the
speker of MO house of representatives. Please, contact him and demand that he brings this issue to the
floor of the state house of rep-s.
Does anyone have Marco Rubio’s book “100 ideas for FL” on tape or printed?
there were flagrant violations of HAVA (Help America vote act) I believe we can have a legal action
on behalf of Sharron Angle and disenfranchised voters on HAVA violations
Please, forward this letter to each and every Congressman and Senator, demand an emergency hearing
and investigation of king Obama and Michelle-Antuanetta. If there is embezzlement of funds, demand
restitution and replenishment to the National treasury. Demand investigation of eligibility, to see, if he
is even Constitutionally eligible to sit there without a valid SS number and spend our money.
Categories
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Dr. Orly TV; Videos (102)
DUNNGATE (66)
Events (233)
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Case: 10-3000 Document: 003110340417 Page: 1 Date Filed: 11/07/2010

UNITED STATES COURT OF APPEALS

LISA LIBERI, LISA OSTELLA, EVELYN ADAMS, PHILIP J. BERG, ESQ.,

ORLY TAITZ, DEFEND OUR FREEDOMS FOUNDATIONS, INC., et al

On Appeal from the United States District Court

Philip J. Berg, Esquire

Attorney for Appellees

EXHIBIT "A" May 4, 2009 Complaint against Defendants/

EXHIBIT "B" June 25, 2009 Order of Judge Robreno

EXHIBIT "C" June 25, 2009 Order of Judge Robreno

EXHIBIT "D" June 4, 2010 Memorandum of Judge

EXHIBIT "E" June 4, 2010 Order of Judge Robreno

EXHIBIT "F" June 23, 2010 Amended Memorandum

EXHIBIT "G" June 23, 2010 Amended Order of Judge

EXHIBIT "H" August 4, 2010, Defendant/Appellant

EXHIBIT "I" September 8, 2010 Defendants/Appellants

EXHIBIT "J" September 14, 2010, Plaintiffs/Appellees

EXHIBIT "K" October 26, 2010 Letter from Plaintiffs/

I, Philip J. Berg, Esquire, hereby certify that a copy of Appellees Appendice

Orly Taitz, et al.

Defend our Freedoms Foundation, Inc. a/k/a

The Sankey Firm, Inc.

Sankey Investigations, Inc.

Linda Sue Belcher

~'7.:;-O Law Offices of

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

PHILIP J. BERG, ESQUIRE

THE LAW OFF1CES OF PHILIP J. BERG

ORL Y T AITZ, a/k/a DR. ORL Y TAITZ, a/k/a :

and to 1000's of undisclosed recipients, requesting the infonnation to be posted on websites

have been severely damaged as outlined herein.

II. JURISDICTION AND VENU:f~

Constitution and 28 U.S.C. § 1331.

3. Venue is proper in this Court under 28 U.S.c. § 139l(b).

4. Plaintiff, Lisa Liberi [hereinafter "Liberi"] is an adult individual with a business

5. Plaintiff, Philip J. Berg, Esquire [hereinafter at times "Berg"] is an adult

Court, Suite 12, Lafayette Hill, PA 19444-2531;

7. Plaintiff: Evelyn Adams [hereinafter at times "Adams"] is an adult individual with

a residential address of Route 1, Box 106 BB, Wynnewood, Oklahoma 73098;

8. Plaintiff, Lisa M. Ostella [hereinafter "Ostella"] is an adult individual with a

residential address of2227 US Highway 1, #245, North Brunswick, NJ 08902-4402.

9. Plaintiff Go Excel Global is a Web Communications company owned and

operated by Lisa M. Ostella with a business address of 2227 US Highway], #245,

North Brunswick, NJ 08902-4402;

WWW.ORLYTAr(ZESQ.COM alk/a WWW.REPUBX.COM a/k/a orty Taitz, [nco

[hereinafter "Taitz"] is a licensed Attomey with a business addresses of 26302 La

11. Defendant, Defend our Freedoms Foundation, [nco is incorporated as a non-profit

Mission Viejo, CA 92691;

address of 31912 Monarch Crest, Laguna Niguel, CA 92677;

14. Defendant Sankey Investigations, Inc. is incorporated in the State of California.

investigation Company. Sankey Investigations has a business address of Post Office

Valley, California, 93063;

16. Defendant James Sundquist [hereinafter "Sundquist"]~ is an adult individual,

Road, Suite 123, Upper Montclair, New Jersey 07043;

www.obamacitzenshipdebate.org [hereinafter "Linda"] is an adult individual with a

home address of20 1 Paris Street, Castroville, Texas 78009-4516;

Wellington, Texas 79095;

Bowie Street Wellin!:,11:on, Texas 79095;

23. Defendant, KPRN AM 1610 [hereinafter "KPRN"] is a business owned and

Bowie Street, Wellington, Texas 79095; and

Fanns and Mr. and Mrs. Hale.

IV. FACTUAL ALLEGATIONS RELATING TO ORLY TAITZ alkla

b.!.tQ)Idcfcndourireedoms.net/2009/04/ 14!understand ing-thc-intcrnet-I 02-

----- Original Message ----

Subject: Re: IMMEDIATE I Dr. Orly Taitz I Redirect

----- Forwarded Message ----

To: "mark westmann" <!Il\vestJlwnn 13(c/Jgmail.com>, "Ed Hale