Documentos de Académico
Documentos de Profesional
Documentos de Cultura
NO. 10-3000
__________________________
Plaintiffs / Appellees,
v.
Defendants / Appellants.
__________________________________________________________________
APPELLEES APPENDICE II
__________________________________________________________________
APPENDICE II
TABLE OF CONTENTS
Page(s)
TABLE OF CONTENTS.......................................................................................i-ii
CERTIFICATE OF SERVICE...........................................................................iii-iv
i
Case: 10-3000 Document: 003110340417 Page: 3 Date Filed: 11/07/2010
APPENDICE II
TABLE OF CONTENTS - Continued
Page(s)
ii
Case: 10-3000 Document: 003110340417 Page: 4 Date Filed: 11/07/2010
CERTIFICATE OF SERVICE
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.
Neil Sankey
4230 Alamo Street
Simi Valley, CA 93063
By USPS Mail with Postage fully prepaid
iii
Case: 10-3000 Document: 003110340417 Page: 5 Date Filed: 11/07/2010
s/ Philip J. Berg
________________________
PHILIP J. BERG, ESQUIRE
Attorney for Appellees
iv
Case: 10-3000 Document: 003110340416 Page: 1 Date Filed: 11/07/2010
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
09 1898
LISA UBERI
and CIVIL ACTION NO.
Plaintiffs, :
vs.
1:\FOR1vlS\Liberi, Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages
Page A1
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 3 DatePage
05/04/09 Filed:
2 11/07/2010
of 45
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
1:\FORMS\Liberi, Berg, Law Offices of pm, Adams and Ostella Complaint tor Damages
2
Page A2
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 4 DatePage
05/04/09 Filed:
3 11/07/2010
of 45
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
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
I:\FORMS\Liberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A3 3
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 5 DatePage
05/04/09 Filed:
4 11/07/2010
of 45
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
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
III. PARTIES
address of 555 Andorra Glen COUli, Suite 12, Lafayette Hill, PA 19444-2531;
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
I:\FORMS\Liberi, Berg, Law Offices ofPJR Adams and Ostella Complaint for Damages
Page A4 4
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 6 DatePage
05/04/09 Filed:
5 11/07/2010
of 45
10. Defendant, Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices ofOrty Taitz, aIkIa
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;
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,
12. Defendant Y osef Taitz [hereinafter "Yosef'] is an adult individual with a home
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;
J:\FORMS\Liberi, Berg. Law Offices of PJB. Adam:,; and O:,;tella Complaint for Damages
Page A5 5
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 7 DatePage
05/04/09 Filed:
6 11/07/2010
of 45
Sankey Investigations, Inc. is owned and operated by Neil Sankey and is a private
Box 8298, Mission Hills, California 91346 and 2470 Stearns Street, #162, Simi
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;
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
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
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;
I:\FORMS\Liberi. Berg, Law Offices of PJB, Adams and Ostclla Complaint for Damages
Page A6 6
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 8 DatePage
05/04/09 Filed:
7 11/07/2010
of 45
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,
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
operated by Defendants, Edgar (Ed) and Caren Hale with a principal address of 1401
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
25. 1n or about November 2008, the name orty Taitz appeared as filing legal
and against the Calitornia Secretary of State and other Defendants regarding the
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.
I:\FORMS\Liberi. Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages
Page A7 7
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 9 DatePage
05/04/09 Filed:
8 11/07/2010
of 45
plagiarized the work of Philip J. Berg, his Assistant Lisa and his law practice, Law
26. Orly Taitz set up the business name of Defend our Freedoms Foundation, Inc. as a
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
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
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
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~
I:\FORMS\Liberi, Berg, Law Offices of PJB. Adams and Ostella Complain! for Damages
Page A8 8
Case: 10-3000 Document: 003110340416
Case 2:09-cv-01898-ER Document 1 Page:05/04/09
Filed 10 Date Filed:
Page 11/07/2010
9 of 45
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
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".
reseller account. This domain did not point to a website, it pointed to a blog.
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
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
I:\FORMS\Liberi. Berg. Law Offices of PlB, Adams and Oslclla Complaint for Damages
Page A9 9
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 11 Date
05/04/09 Filed:
Page 10 11/07/2010
of 45
"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
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
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.
"." (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
I:\FORMS\Liberi, Berg. Law Offices ofPJB. Adams and Ostella Complaint for Damages
Page A10 10
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 12 Date
05/04/09 Filed:
Page 11 11/07/2010
of 45
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
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
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
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!~)(
I:\FORMS\Liberi, Berg, Law Offices ofPJB. Adams and Ostella Complaint for Damages
Page A11 \l
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 13 Date
05/04/09 Filed:
Page 12 11/07/2010
of 45
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,
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
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
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.
I:\FORMS\Liberi. Berg. Law Offices ofPJB. Adams and Ostella CompJaint t()r Damages
Page A12 12
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 14 Date
05/04/09 Filed:
Page 13 11/07/2010
of 45
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
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
Ms. Ostella,
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
I:\FORMS\Liberi. Berg. Law OtTices of PJB, Adams and Ostella Complaint for Damages
Page A13 13
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 15 Date
05/04/09 Filed:
Page 14 11/07/2010
of 45
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
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",
I:\FORMS\Liberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A14 14
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 16 Date
05/04/09 Filed:
Page 15 11/07/2010
of 45
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
To: info@goexcelglobaLcom
On February 11, 2009, Lisa, was advised that the PayPal button links do
Andrew S.
Team Sapphire
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
53. On April 12, 2009, Ostella received the following e-mail containing false and
I:\FORMS\Liberi. Berg, Law Offices of P.TB. Adams and Ostella Complaint for Damages
Page A15 15
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 17 Date
05/04/09 Filed:
Page 16 11/07/2010
of 45
To: chuckolb
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
blog
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
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
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
I:\FORMS\Liberi, Berg, Law Offices of P18, Adams and Ostella Complaint for Damages
Page A16 16
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 18 Date
05/04/09 Filed:
Page 17 11/07/2010
of 45
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
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
I:\FORMS\Liberi, Berg. Law Offices of p.m, Adams and Ostella Complaint for Damages
Page A17 17
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 19 Date
05/04/09 Filed:
Page 18 11/07/2010
of 45
cards on your charitable foundation web site." At all times, Taitz and Mr. Hale were
"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."'
PlainsRadio" <parhfarms(a{gmail.com>
America/Chicago
Subject: Fw: Ceize and Desist, demand to file a joint FBI complaint
fax 949-586-2082
1:\FORMS\Libcri, Berg, Law Offices ofPJB, Adal1h'l and Ostella Complaint for Damages
Page A18 18
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 20 Date
05/04/09 Filed:
Page 19 11/07/2010
of 45
04.12.09.
"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.
See attached file. I also received infonnation that her husband, who is
I believe that you, as an officer of the court, as well and a former Assitant
complaint and demand for investigation from the above listed authorities.
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.
I:\FORMS\Libcri. Berg, Law Offices ofPJB. Adams and Ostella Complaint for Damages
Page A19 19
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 21 Date
05/04/09 Filed:
Page 20 11/07/2010
of 45
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
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
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
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
Page A20 20
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 22 Date
05/04/09 Filed:
Page 21 11/07/2010
of 45
: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.
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
I:\FORMS\Liberi. Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages
Page A21 21
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 23 Date
05/04/09 Filed:
Page 22 11/07/2010
of 45
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
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
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
Page A22 22
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 24 Date
05/04/09 Filed:
Page 23 11/07/2010
of 45
distribute via the internet, bye-mail and posting a person's private confidential
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------
!!!.!;l.eJch~a?@yaDoo.CQ[n: !~JkL'LdlQ.(illl!ye.co!Jl;
tmn)!lvblog(£llya.b90 . canl;
nacomprollli.?.f.'YhelJ'y9ureright~4gmai1f.9J:.tl; evil~vilconservativeonlil1e.com;
lQ.rI1((vgoPJim~lQL~,com; .u:h;:@m.!!9nl ine,net; j!ic(li)e'!!1.hli.Il~~_net;
acaul!s:.r@wQ.r!dn.~!.l].l!j.h::.:.9.Qm; <.!!lf1agd.!!wald(ui.yahoo.com;
Q.i£.~JllQrri§,@illshm..9JIl!hc:.Q.lI!; drilllR~i/l,drlJdgercport.com;
~ditQL@!ll1e.!:h;an1l1ill~_eJ.:.I;QI!.1: c:.1ouigil'1lYQ.<iUynewgoln; gdescobaru/)aim.90m:
!!J.h~jiB;S?ig@JJm.LL.bgl!!j~QY; ~Y-;:t{iAQ.~ll.!.L)1l..r.&~r~om;
ifurD.h~':Yl1d,c:.(J.I1J; gth! 111 Ji;!lc i ,0 rg;
mhgi.!1.!.~!@c9.<JmcasL.Il~!; g1!Y!1.Qrl-tLkc(UJ,jloi.cQ!!l; Jlli!rickgibsonmail«({lgmail.com;
&1 enI1silt!p~(:n@_V';§.L ~Q 11]: jQIJill 1mo,2f!!!J!Stisom: ;!gf9jJ rlJ<:1I1@l1.i,fLC_l!!I!:
fQ!ri"~...J1J!.i.D Il(li) fo.9JlfIJ·.ii9!!!lJS'"gSl.Y ;1l.l.hL('.2Q@h~2tm'lU,.9Q!IJ;I;>£lrbJ,!Ul.1,<;I!Dg!1Jil i 1·.~9Jn:
flJ!t.hl'!!:@yLcjgrhill1.!)(Jll,c:..mn; tlSCJJl j 11l!~~flY@'!lm.iQI1<llr~.yj~~.c:.9m;
hhe~l!.t@hLlgj]hc\WJ·colT.!: !~rillJ.l)OI1@~i!r.L~.'d<;ww!-,ck~I'!Q·f..9.!l!; ftll,lIt0InYPQ.st.c:.Q!I!:
Y!!lJ!?.r:iii}iIlli?ilg.rUJ"lLcgm ;il1[Q@~'!H ,Q!.g: I,:1!iJQI:@iM<}fJill!itQ.~I,t;(l.!Jl; Q reggJ2s:.k?()I1((/)gmai I.cgm;
ll!.llil~'-W911JJJQ9.1C.~QIg: ji I.D,IIJ.ilIlz:inI()j:illgmiljL~9D.!;
produccr@in rQ~J]rs.com: roger(ZiJ.ai m .QIg; kevi n(7ildavllc1.org;
='.='="'-".='."="-=-~=' .t="-""=",'-'-'="'-"''-'--''-=--'''''-'-'" .j11 i I\gho (fCZvao L.com; c k(ev,cl1.arl es k rautham mer .cam;
!l1,;L~@£1'U)J:g: 9Ql1lmS!.U1~:11,1.f.!Z@rlaii.on(l.!.r~l~\y',-@JH; gevy_yh'cGJeartl:!.!i'11.J1et;
ltl:SQnl.<lig@§h!;:g.iQ.I;><!!,n<;!: MJ~6NQ BI;::.liI@1iH:.,glS:('QM: h'l[l}'j<jnKJi.Y<:.@<:DD .CQ!l1;
=~~-'--'=,=.::,,,:..:..~."-'.:'.='" ~~I]~]l.!lli..~k(ln..5i"gl: lette!'1i@!!)§JJI1~,-,Q!n: J~ttcE!@!!i!ti()l1alrcvicw,com;
Jm1&r~;()~:D,:j~,,-,-~~.,. ,-,="--",~"-"-,-""'-'.:.,,,,-,,,,!-,,,:.,,,,-,. J.s:Hers@!va~hQ2&-com:
''-'.'''-'-''-''-'.',-,",,,"-,,,-,!,,,:;:.;.,,,,,-,=.1-'--'-'-!-,-'''''-'-'!' ~.Yil1@epp.£,Q!:g,: ~ ru stlI2.Q£i:ikLQueLc mn:
= . '.-'-~'=.".,:,.,-,-""":;";:.;:e:::",,.!.!.:::-,,,-:~.,.' lJ.NIll:\ U,fJ'iI@ilQL£olJ1; ~J.oJ)5?p1Il!~1[Q!.1a Irev iew. com;
""-'!="-""-"'.!!.~~.'=~='''.'. ' ' llk'lLz.;Q.ergtalk(£I;g[)lailiom: 111ilD,;(U)webs~Ylcesmcdia.c()rrr;
C=:"-==';2"-,-~~=-:.'-"-"=' ~~~~~~~, vicll1.ord20Q I(li),vah<2o,com: nate.fredman(iiifoxnews.com;
I:\FORMS\Liberi. Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A23 23
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 25 Date
05/04/09 Filed:
Page 24 11/07/2010
of 45
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
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,
Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA
"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
I:\FORMS\Liberi, Berg, Law Ortices of PJB, Adams and Ostella Complaint for Damages
Page A24 24
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 26 Date
05/04/09 Filed:
Page 25 11/07/2010
of 45
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
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,
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
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
I:\FORMS\Liberi. Berg, Law Office8 of P.lR Adams and Ostella Complaint for Damages
Page A25 25
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 27 Date
05/04/09 Filed:
Page 26 11/07/2010
of 45
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 :
- -......- . - -
l:\FORMS\Liberi, Berg, Law Offices ofPJB, Adams and OsleUa Complaint for Damages
Page A26 26
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 28 Date
05/04/09 Filed:
Page 27 11/07/2010
of 45
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
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
J:\FORMS\Uberi. Berg. Law Offices ofPJB. Adams and OSlella Complaint for Damages
Page A27 27
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 29 Date
05/04/09 Filed:
Page 28 11/07/2010
of 45
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
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
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,
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.
I:\FORMS\Liberi. Berg. Law Offices of P.JB, Adams and Os(ella Complaint for Damages
Page A28 28
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 30 Date
05/04/09 Filed:
Page 29 11/07/2010
of 45
From: =~=~c=~~~~~~.==~·~
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.
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-
I:\FORMS\Liberi. Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A29 29
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 31 Date
05/04/09 Filed:
Page 30 11/07/2010
of 45
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
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
I:\FORMS\Liberi, Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages
Page A30 30
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 32 Date
05/04/09 Filed:
Page 31 11/07/2010
of 45
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
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
I:\FORMS\Liberi, Berg, Law Offices ofPJB. Adams and Ostella Complaint for Damages Page A31 31
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 33 Date
05/04/09 Filed:
Page 32 11/07/2010
of 45
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.
85. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth
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
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.
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
ti'equent as a guest.
I:\FORMS\Liberi. Berg, Law Offices of pm, Adams and Ostella Complaint for Damages
Page A32 32
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 34 Date
05/04/09 Filed:
Page 33 11/07/2010
of 45
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
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
Please Note: I am NOT using PayPal anymore at this time for donations,
e-mail: 9''..Jil!tz@Y.<lhoo&Q!1l
I:\FORMS\Liberi. Berg, Law Offices of P JB, Adams and O~tclla Complaint for Damages
Page A33 33
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 35 Date
05/04/09 Filed:
Page 34 11/07/2010
of 45
From:
V ie\~'_~gl1jacl JjgJJliJ~
To:
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
You can call her to verify this. Dr. Taitz tel number is 949-6R3-54 I 1.
~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
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
I:\FORMS\Liberi. Berg, Law Offices ofPJB, Adams and Ostclla Complaint for Damages
Page A34 34
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 36 Date
05/04/09 Filed:
Page 35 11/07/2010
of 45
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
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.
92. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth
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
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.
T:\FORMS\Libcri. Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A35 35
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 37 Date
05/04/09 Filed:
Page 36 11/07/2010
of 45
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
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
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.
I:\FORMS\Liheri. Berg. Law Offices ofPJB. Adams and Oslella Complaint for Damages
Page A36 36
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 38 Date
05/04/09 Filed:
Page 37 11/07/2010
of 45
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
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.
people from Berg's blog, etc. Linda made derogatory remarks about Berg and Berg's
Re.~t{~J;lL.DisQ)SS ioo.J.Q12i.~..Lrm11VJ22..:_Q3.LOj'j.Q_~
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
Witncsses, Berg's supporters, attomey's Berg works with on other cases, Berg's
l:\FORMS\Liberi. Berg. Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A37 37
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 39 Date
05/04/09 Filed:
Page 38 11/07/2010
of 45
contributors. Defendants Orly Taitz, Mr. & Mrs. Hale, etc. only a few are attached for
Jlda __Starr
JowuL'" new Wonwn& Parlg
Feminism: (noun) the radical notion that women are people.
<Newwomenspariy@aol.com> wrote:
From: Newwomensparty@aol.conl
<~ ewworne-'1sparty@aol.~orn>
Subject: Re: Fw: I om sorry to tell you all ...
I:\FORMS\Liberi, Berg, Law Offices of PJB, Adams and Ostella Complainl for Damages
Page A38 38
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 40 Date
05/04/09 Filed:
Page 39 11/07/2010
of 45
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.
JJndaStarr
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
Newwomensparty@aol.com <Newwomensparty@ao/.com>
wrote:
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
l:\FORMS\Liberi. Berg, Law Offices ofP.TB, Adams and Ostella Complaint for Damages
Page A39 39
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 41 Date
05/04/09 Filed:
Page 40 11/07/2010
of 45
JJnla _){arr
I:\FORMS\Liheri, Berg, Law Oftices of PJB, Adams and Ostella Complaint for Damages
Page A40 40
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 42 Date
05/04/09 Filed:
Page 41 11/07/2010
of 45
To: newwomensparty@yahoogrouPS.COIll
Agents and members, to Obots being allowed back to the board and to
I'm sure you're not happy with what's going on. We aren't, either. It's
Obot-FREE. Our core group want nothing more than Justice for the
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
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
minded individuals are accepted into our ranks. Welcome to our friends.
Thanks.
oflnda Starr
:JQunler, new Womeru pari"
Feminism: (noun) the radical notion that women are people.
Well behaved women seldom make history!
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
I:\FORMS\Uberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A41 41
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 43 Date
05/04/09 Filed:
Page 42 11/07/2010
of 45
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.
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.
I:\FORMS\LiberL Berg, Law Offices oHm, Adams and OsteUa Complaint for Damages
Page A42 42
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 44 Date
05/04/09 Filed:
Page 43 11/07/2010
of 45
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.
J:inda .slarr
1:\FORMS\Liheri. Berg, Law Offices of PJB, Adams and Ostc11a Complaint for Damages
Page A43 43
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 45 Date
05/04/09 Filed:
Page 44 11/07/2010
of 45
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
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
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
I:\FORMS\Libcrl, Berg, Law Offices of PJB, Adams and Ostella Complaint for Damage~
Page A44 44
Case: Case
10-3000 Document: 003110340416
2:09-cv-01898-ER Document 1 Page:
Filed 46 Date
05/04/09 Filed:
Page 45 11/07/2010
of 45
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
107. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth
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
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
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,
I:\FORMS\Liberi, Berg. Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A45 45
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 1 Date Page
Filed 05/04/09 Filed:111/07/2010
of 40
Plains Radio through their Tower, KPRN, on their chat room site at
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
"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.
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
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
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.
I:\FORMS\Uberi. Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages
Page A46 46
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 2 Date Page
Filed 05/04/09 Filed:211/07/2010
of 40
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
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
-------Original Message------
To: Evelvn/MommaE
"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
-------Original Message------
I:\FORMS\Liberi. Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page 47A47
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 3 Date Page
Filed 05/04/09 Filed:311/07/2010
of 40
Date: 113120095:57:05 PM
To: mammaE
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
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.
through talkstreamlive.com, posted on Hale's internet website blogs and sent out by
119. Mr. and Mrs. Hale used their radio show, Plains Radio, through
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
I:\FORMS\Liberi, Berg, Law Offices ofpJB, Adams and Ostella Complaint for Damages
Page A48 48
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 4 Date Page
Filed 05/04/09 Filed:411/07/2010
of 40
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
121. Mr. and Mrs. Hale have repeatedly used their radio show through
regarding Mrs. Adams which includes but is not limited to her radio shows; falsely
documents, being the "Obama" divorce papers; falsely accusing Adams of defrauding
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
I:\FORMS\Liberi. Berg, Law Offices orPJB, Adams and Oslella Complaint for Damages
Page A49 49
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 5 Date Page
Filed 05/04/09 Filed:511/07/2010
of 40
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
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
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 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
I:\FORMS\Liberi, Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages
Page A50 50
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 6 Date Page
Filed 05/04/09 Filed:611/07/2010
of 40
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
"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
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.
I:\FORMS\Liberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages Page A51 51
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 7 Date Page
Filed 05/04/09 Filed:711/07/2010
of 40
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
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
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
I:\FORMS\Liberi, Berg, Law Offices of P.TB, Adams and Ostella Complaint for Damages
Page A52 52
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 8 Date Page
Filed 05/04/09 Filed:811/07/2010
of 40
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:
"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.
I:\FORMS\Liberi, Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages
Page A53 53
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 9 Date Page
Filed 05/04/09 Filed:911/07/2010
of 40
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:
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
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
I:\FORMS\Liheri. Berg. Law Offices of PIB, Adams and Ostella Complaint for Damages
Page A54 54
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 10 Date
Filed 05/04/09 Filed:
Page 1011/07/2010
of 40
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.
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.
Lisa Ostella
Delelld Our Freedams FOlllulatUJII
Ilttp:lldefelldourfreedams.org
Peace througll Strellgtll
frttp:llwww.bamjillfegri(v.conr
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.
>
I:\FORMS\Liberi, Berg, Law Offices of PJB, Adams and Oslella Complaint for Damages
Page A55 55
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 11 Date
Filed 05/04/09 Filed:
Page 1111/07/2010
of 40
> 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
>
> SlIe has al/ extellsiJ·e crimil/al recard gaillg back fQ tlte 90's.
To: dr_faitzti!)'alll1o.cO/ll
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
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
I:\FORMS\Uberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint. for Damages
Page A56 56
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 12 Date
Filed 05/04/09 Filed:
Page 1211/07/2010
of 40
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
I:\FORMS\Liberi. Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages
Page A57 57
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 13 Date
Filed 05/04/09 Filed:
Page 1311/07/2010
of 40
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.
137. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth
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.
I:\FORMS\Liberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A58 58
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 14 Date
Filed 05/04/09 Filed:
Page 1411/07/2010
of 40
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
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.
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
Act, 18 U.S.C. §§2701-11~ Cyber harassment, Cyber stalking, etc. in violation of the
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
I:\FORMS\Liberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A59 59
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 15 Date
Filed 05/04/09 Filed:
Page 1511/07/2010
of 40
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
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
146. Taitz had threatened to destroy Liberi and took every step to ensure she not only
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
I:\PORMS\Liberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A60 60
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 16 Date
Filed 05/04/09 Filed:
Page 1611/07/2010
of 40
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
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
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
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
150. Liberi had a confidential address as a result of her child and her being victims of
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
I:\FORMS\Liberi. Berg. Law Offices of PJB, Adams and Ostella Complaint tor Damages
Page A61 61
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 17 Date
Filed 05/04/09 Filed:
Page 1711/07/2010
of 40
151 . In so doing, Taitz, Sankey, the Sankey Firm and Sankey Investigations, Inc.
"(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
general public."
152. If there had been a pennissible purpose for Sankey through he Sankey Firm and
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:
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
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
I:\FORMS'Liberi. Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page 62A62
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 18 Date
Filed 05/04/09 Filed:
Page 1811/07/2010
of 40
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
156. Taitz Sankey, the Sankey Finn and Sankey Investigations, Inc. violated the
times.
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
Act, 18 U.S.c. §§270l-11; Cyber harassment, Cyber stalking, etc. in violation of the
I:\FORMS\Liberi, Berg, Law Offices ofP.lB, Adams and Ostella Complaint for Damages
Page A63 63
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 19 Date
Filed 05/04/09 Filed:
Page 1911/07/2010
of 40
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
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,
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
but not limited to her Social Security number, date of birth, where she resides,
Freedoms Foundation, Inc., Sundquist, Rock Salt Publishing, and anyone on their behalf
from distributing Lisa Ostella's personal and confidential infornlation, including but not
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;
I:\FORMS\Liberi, Berg, Law Ofl-ices of PJB, Adams and Ostel1a Complaint for Damages
Page A64 64
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 20 Date
Filed 05/04/09 Filed:
Page 2011/07/2010
of 40
Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc.,
collectively, jointly and separately, for civil penalties in the amount of Four Hundred
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
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;
Defendants' for damages in the amount of One Million dollars [$1,000,000.00] per
Defendants' for compensatory damages in the amount of Five Hundred Thousand Dollars
Defendants' for Punitive damages in the amount ofTen Million Dollars [$10,000,000.00]
I:\FORMS\Liberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A65 65
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 21 Date
Filed 05/04/09 Filed:
Page 2111/07/2010
of 40
COUNT TWO
158. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth
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
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
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"
T:\FORMS\Liberi, Berg. Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A66 66
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 22 Date
Filed 05/04/09 Filed:
Page 2211/07/2010
of 40
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
163. Defendants' false statements about Plaintiffs were made across the entire internet
164. At all relevant times, Defendants have acted with actual malice.
165. Defendants' defamatory statements about all Plaintiff., have severely injured the
166. Defendants' defamatory statements about the Plaintiffs have caused Plaintiffs to
suffer mental anguish and impaired their personal and professional reputation and
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,
I:\FORMS\Liberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A67 67
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 23 Date
Filed 05/04/09 Filed:
Page 2311/07/2010
of 40
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.;
Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any
party on their behalf from disseminating Liberi's Social Security number, date of birth,
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
but not limited to her Social Security number, date of birth, where she resides,
Freedoms Foundation, Inc., Sundquist, Rock Salt Publishing, and anyone on their behalf
from distributing Lisa Ostella's personal and confidential infonnation, including but not
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;
I:\FORMS\Liberi. Berg, Law Offices of P./B, Adams and Ostella Complaint for Damages
Page A68 68
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 24 Date
Filed 05/04/09 Filed:
Page 2411/07/2010
of 40
Defendants' for damages in the amount of One Million [$1,000,000.00] Dollars per
[$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
I. Attorney's fees, costs and interest for each separate Plaintiff herein; and
COUNT THREE
167. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth
herein at length.
168. Defendants' defamatory statements about Plaintiffs' placed Plaintiffs' and their
169. The false-light in which Defendants' placed Plaintiffs' and their staff would be
I:\FORMS\Liberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A69 69
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 25 Date
Filed 05/04/09 Filed:
Page 2511/07/2010
of 40
170. At all times Defendants' knew that their statements were false and/or acted in
17]. At all relevant times, Defendants' have acted with actual malice.
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
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
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
Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any
I:\FORMS\Liberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A70 70
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 26 Date
Filed 05/04/09 Filed:
Page 2611/07/2010
of 40
party on their behalf from disseminating Liberi' s Social Security number, date of birth,
Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations,
Inc., and any party who has published Liberi's confidential information on their behalves
but not limited to her Social Security number, date of birth, where she resides,
Freedoms Foundation, Inc., Sundquist and Rock Salt Publishing and anyone on their
behalf from distributing Lisa Ostella's personal and confidential information, including
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;
Defendants' for damages in the amount of One Million [$1,000,000.00] Dollars per
[$500,000.00] Dollars per Defendant to be awarded to each and every separate Plaintiff
herein;
Defendants' for Punitive damages in the amount ofTen Million [$lO,OOO,OOO.OO] Dollars
I:\FORMS\Liberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A71 71
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 27 Date
Filed 05/04/09 Filed:
Page 2711/07/2010
of 40
l. Attorney's fees, costs and interest for each separate Plaintiff herein; and
COUNT FOUR
HARASSMENT
174. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth
herein at length.
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'.
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
I:\PORMS\Liberi, Berg, Law Offices ofPlB, Adams and Ostella Complaint for Damages
Page A72 72
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 28 Date
Filed 05/04/09 Filed:
Page 2811/07/2010
of 40
turn over Berg's certified set of his "Obama" divorce decree, Defendants Edgar (Ed)
harming the Plaintiffs' and their businesses unjustifiably and to coercing them to
U.S.C. §223(a), et ai, Texas Penal Code §42.07; the Women's Violence Act,
223(a)(1 )(C) applies to "any device or software that can be used to originate
181. Plaintiffs' and their businesses have suffered losses and damages as a result of the
Defendants harassment.
their behalf from airing andlor 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
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
I:\FORMS\Liberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A73 73
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 29 Date
Filed 05/04/09 Filed:
Page 2911/07/2010
of 40
Liberi's Social Security number and personal identifying infonnation; enJOIn the
Defendants' from any further harassment of the Plaintiffs', enjoin Defendants' from the
Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any
party on their behalf from disseminating Liberi's Social Security number, date of birth,
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
Freedoms Foundation, Inc., Sundquist and Rock Salt Publishing, and anyone on their
behalf from distributing Lisa Ostella's personal and confidential infonnation, including
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
1:\FORMS\Liberi, Berg, Law Offices ofPJB, Adams and Ostclla Complaint for Damages
Page A74 74
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 30 Date
Filed 05/04/09 Filed:
Page 3011/07/2010
of 40
[$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
L Attorney's fees, costs and interest for each separate Plaintiff herein; and
COUNT FIVE
182. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth
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
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;
with false and misleading designations and false and misleading descriptions and
representations of fact.
I:\FORMS\Uberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
Page A75 75
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 31 Date
Filed 05/04/09 Filed:
Page 3111/07/2010
of 40
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'
186. Defendants' false and misleading statements about Plaintiffs' and their businesses
have been designed to tarnish and have tarnished the Plaintiffs' and their businesses
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
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.
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
via the internet or another print or electronic medium or broadcasts andlor radio, untrue
I:\FORMS\Uberi, Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages
Page A76 76
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 32 Date
Filed 05/04/09 Filed:
Page 3211/07/2010
of 40
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
Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations, Inc., and any
party on their behalf from disseminating Liberi's Social Security number, date of birth,
Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey Investigations,
Inc., and any party who has published Liberi's confidential information on their behalves
but not limited to her Social Security number, date of birth, where she resides,
Freedoms Foundation, Inc., Sundquist and Rock Salt Publishing, and anyone on their
behalf from distributing Lisa Ostella's personal and confidential information, including
E Enjoin Defendants, Taitz, Defend our Freedoms, Inc. and Yosef, and any
party operating on their behalf from any further "hacking" of the Plaintiffs' computers;
Defendants' for damages in the amount of One Million [$1,000,000.00] Dollars per
I:\FORMS\LiberL Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages
Page A77 77
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 33 Date
Filed 05/04/09 Filed:
Page 3311/07/2010
of 40
[$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
I. Attorney's fees, costs and interest for each separate Plaintiffherein; and
COUNT SIX
INJUNCTIVE RELIEF
190. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth
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,
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,
I:\FORMS\Liberi, Berg, Law Offices of PJB, Adams and OsteHa Complaint for Damages
Page A78 78
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 34 Date
Filed 05/04/09 Filed:
Page 3411/07/2010
of 40
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
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
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.
their behalf from airing and/or publishing any defamatory or false statements about
Plaintiffs, Lisa tiberi, 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
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
Defendants' from any further harassment of the Plaintiffs', enjoin Defendants' from the
I:\FORMS\Liberi, Berg, Law Offices orPJB, Adams and Ostella Complaint for Damages
Page A79 79
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 35 Date
Filed 05/04/09 Filed:
Page 3511/07/2010
of 40
FOWldation, Inc., Neil Sankey, the Sankey Fiml and Sankey Investigations, Inc., and any
party on their behalf from disseminating Liberi's Social Security number, date of birth,
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
but not limited to her Social Security number, date of birth, where she resides,
Freedoms Foundation, Inc., Sundquist and Rock Salt Publishing, and anyone on their
behalf from distributing Lisa Ostella's personal and confidential infoffilation, including
E Enjoin Detendants, Taitz, Defend our Freedoms, Inc. and Yosef, and any
party operating on their behalf from any further "hacking" of the Plaintiffs' computers;
Defendants' for damages in the amount of One Million [$1,000,000.00] Dollars per
[$500,000.00J Dollars per Defendant to be awarded to each and every separate Plaintiff
herein;
I:\FORMS\Liberi, Berg, Law Offices of P18, Adams and Ostel1a Complaint for Damages
Page A80 80
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 36 Date
Filed 05/04/09 Filed:
Page 3611/07/2010
of 40
Defendants' for Punitive damages in the amount ofTen Million [$10,000,000.00] Dollars
I. Attorney's fees, costs and interest for each separate Plaintiff herein; and
Phi~;c;;z:s::
J. Berg,sclUire
Attorney for Plaintiffs
I:\FORMS\Liberi, Berg, Law Offices ofPJB. Adams and Ostella Complaint for Damages
Page A81 81
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 37 Date
Filed 05/04/09 Filed:
Page 3711/07/2010
of 40
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
Page A82
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 38 Date
Filed 05/04/09 Filed:
Page 3811/07/2010
of 40
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
Page A83
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 39 Date
Filed 05/04/09 Filed:
Page 3911/07/2010
of 40
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
therein are made subject to the penalties of 18 Pa. C.S. Section 4904 and the laws of the
Page A84
Case:Case
10-3000 Document: 003110340418
2:09-cv-01898-ER Document 1-1 Page: 40 Date
Filed 05/04/09 Filed:
Page 4011/07/2010
of 40
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
therein are made subject to the penalties of 18 Pa. C.S. Section 4904 and the laws of the
Page A85
Case: 10-3000 Document: 003110340419 Page: 1 Date Filed: 11/07/2010
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
O R D E R
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
Case: 10-3000 Document: 003110340420 Page: 1 Date Filed: 11/07/2010
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
O R D E R
jurisdiction.1
Plaintiffs to show cause why this case should not be severed into
Defendants: (1) Edgar & Caren Hale, Plains Radio Network, Bar H.
Farms and KPRN AM 1610; (2) Linda S. Belcher; (3) Orly Taitz,
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.
Page C1
Case: Case
10-3000
2:09-cv-01898-ER
Document: 003110340420
Document 80 Page:
Filed 06/26/09
3 Date Page
Filed: 211/07/2010
of 2
responses.
AND IT IS SO ORDERED.
s/Eduardo C. Robreno
EDUARDO C. ROBRENO, J.
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).
Page C2
Case: 10-3000 Document: 003110340421 Page: 1 Date Filed: 11/07/2010
EXHIBIT "D"
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340421
Document 117 Page:
Filed 2
06/04/10
Date Filed:
Page 11/07/2010
1 of 9
M E M O R A N D U M
I. BACKGROUND
“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
Page D1
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340421
Document 117 Page:
Filed 3
06/04/10
Date Filed:
Page 11/07/2010
2 of 9
destroy” Plaintiffs.
Salt Publishing are citizens of New Jersey, and Belcher and the
the parties.
2
On June 26, 2009, the Court granted Plaintiffs’ motion
to dismiss Defendants Sundquist and Rock Salt Publishing. See
doc. no. 76.
-2-
Page D2
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340421
Document 117 Page:
Filed 4
06/04/10
Date Filed:
Page 11/07/2010
3 of 9
cause as to why the action should not be severed and the claims
Corp., 2009 U.S. Dist. LEXIS 29137 (D.N.J. Apr. 6, 2009). Here,
three grounds. First, why this case should not be dismissed for
DOFF, and Sankey. Third, why this case should not be transferred
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.
-3-
Page D3
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340421
Document 117 Page:
Filed 5
06/04/10
Date Filed:
Page 11/07/2010
4 of 9
II. DISCUSSION
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
-4-
Page D4
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340421
Document 117 Page:
Filed 6
06/04/10
Date Filed:
Page 11/07/2010
5 of 9
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
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.
-5-
Page D5
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340421
Document 117 Page:
Filed 7
06/04/10
Date Filed:
Page 11/07/2010
6 of 9
496, 505 (E.D. Pa. 2007) (quoting Jumara v. State Farm Ins. Co.,
prima facie case for personal jurisdiction has been made over
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
-6-
Page D6
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340421
Document 117 Page:
Filed 8
06/04/10
Date Filed:
Page 11/07/2010
7 of 9
the familiarity of the trial judge with the applicable state law
home jurisdictions.
-7-
Page D7
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340421
Document 117 Page:
Filed 9
06/04/10
Date Filed:
Page 11/07/2010
8 of 9
statements and the context in which they were made are best
III. CONCLUSION
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
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.
-8-
Page D8
Case: Case
10-3000
2:09-cv-01898-ER
Document: 003110340421
Document 117 Page:
Filed10
06/04/10
Date Page
Filed: 911/07/2010
of 9
-9-
Page D9
Case: 10-3000 Document: 003110340422 Page: 1 Date Filed: 11/07/2010
EXHIBIT "E"
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340422
Document 118 Page:
Filed 2
06/04/10
Date Filed:
Page 11/07/2010
1 of 2
O R D E R
Farms, and KPRN A.M. 1610, Neil Sankey and Sankey Investigations,
Page E1
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340422
Document 118 Page:
Filed 3
06/04/10
Date Filed:
Page 11/07/2010
2 of 2
is DENIED as moot.1
CLOSED.
AND IT IS SO ORDERED.
s/Eduardo C. Robreno
EDUARDO C. ROBRENO, J.
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.
- 2 -
Page E2
Case: 10-3000 Document: 003110340423 Page: 1 Date Filed: 11/07/2010
EXHIBIT "F"
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340423
Document 123 Page:
Filed 2
06/23/10
Date Filed:
Page 11/07/2010
1 of 6
M E M O R A N D U M
I. BACKGROUND
Page F1
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340423
Document 123 Page:
Filed 3
06/23/10
Date Filed:
Page 11/07/2010
2 of 6
A. Legal Standard
Rauscher, 807 F.2d 345, 348 (3d Cir. 1986) (internal citation
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
-2-
Page F2
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340423
Document 123 Page:
Filed 4
06/23/10
Date Filed:
Page 11/07/2010
3 of 6
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
record.1
errors in the Court's 6/3/10 Order that severed the action and
1. Points 6, 8 and 9
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.
-3-
Page F3
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340423
Document 123 Page:
Filed 5
06/23/10
Date Filed:
Page 11/07/2010
4 of 6
denied.
2. Points 1, 2, 3, 4 and 5
-4-
Page F4
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340423
Document 123 Page:
Filed 6
06/23/10
Date Filed:
Page 11/07/2010
5 of 6
California.
yet been transferred and the error has no impact on the legal
3. Point 7
Point 7 is as follows:
-5-
Page F5
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340423
Document 123 Page:
Filed 7
06/23/10
Date Filed:
Page 11/07/2010
6 of 6
See id. at 2.
III. CONCLUSION
-6-
Page F6
Case: 10-3000 Document: 003110340424 Page: 1 Date Filed: 11/07/2010
EXHIBIT "G"
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340424
Document 124 Page:
Filed 2
06/23/10
Date Filed:
Page 11/07/2010
1 of 2
AMENDED ORDER
follows. On June 25, 2009, the Court issued a rule to show cause
Hales; (ii) Belcher; (iii) Taitz, DOFF, and Sankey; and (3)
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.
Page G1
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340424
Document 124 Page:
Filed 3
06/23/10
Date Filed:
Page 11/07/2010
2 of 2
the Court will now SEVER the instant case into two separate,
Radio Network, Bar H. Farms, and KPRN A.M. 1610 are transferred
Neil Sankey, The Sankey Firm and Sankey Investigations, Inc. are
California.2
CLOSED.
AND IT IS SO ORDERED.
s/Eduardo C. Robreno
EDUARDO C. ROBRENO, J.
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
Case: 10-3000 Document: 003110340425 Page: 1 Date Filed: 11/07/2010
EXHIBIT "H"
Evidence of fraud on the court, perjury by Berg, Liberi, Ostella, fabricatio... http://www.orlytaitzesq.com/?p=12814
Case: 10-3000 Document: 003110340425 Page: 2 Date Filed: 11/07/2010
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
THERE IS TYRANNY.
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.
Page H1
1 of 7 11/4/2010 10:40 PM
Evidence of fraud on the court, perjury by Berg, Liberi, Ostella, fabricatio... http://www.orlytaitzesq.com/?p=12814
Case: 10-3000 Document: 003110340425 Page: 3 Date Filed: 11/07/2010
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
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.
Page H2
2 of 7 11/4/2010 10:40 PM
Evidence of fraud on the court, perjury by Berg, Liberi, Ostella, fabricatio... http://www.orlytaitzesq.com/?p=12814
Case: 10-3000 Document: 003110340425 Page: 4 Date Filed: 11/07/2010
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???
Russia and Saudi Arabia seem to act together in many world crises situations.
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.
6. dr_taitz@yahoo.com
August 5th, 2010 @ 5:48 pm
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
Page H3
3 of 7 11/4/2010 10:40 PM
Evidence of fraud on the court, perjury by Berg, Liberi, Ostella, fabricatio... http://www.orlytaitzesq.com/?p=12814
Case: 10-3000 Document: 003110340425 Page: 5 Date Filed: 11/07/2010
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”!
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
Dossiers (48)
Dr. Orly TV; Videos (102)
DUNNGATE (66)
Events (233)
Page H4
4 of 7 11/4/2010 10:40 PM
Case: 10-3000 Document: 003110340426 Page: 1 Date Filed: 11/07/2010
EXHIBIT "I"
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
2 Date Page
Filed: 111/07/2010
of 18
Page I1
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
3 Date Page
Filed: 211/07/2010
of 18
Page I2
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
4 Date Page
Filed: 311/07/2010
of 18
Page I3
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
5 Date Page
Filed: 411/07/2010
of 18
Page I4
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
6 Date Page
Filed: 511/07/2010
of 18
Page I5
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
7 Date Page
Filed: 611/07/2010
of 18
Page I6
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
8 Date Page
Filed: 711/07/2010
of 18
Page I7
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
9 Date Page
Filed: 811/07/2010
of 18
Page I8
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 10
09/08/10
DatePage
Filed:911/07/2010
of 18
Page I9
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
11 DatePage
Filed:
1011/07/2010
of 18
Page I10
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
12 DatePage
Filed:
1111/07/2010
of 18
Page I11
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
13 DatePage
Filed:
1211/07/2010
of 18
Page I12
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
14 DatePage
Filed:
1311/07/2010
of 18
Page I13
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
15 DatePage
Filed:
1411/07/2010
of 18
Page I14
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
16 DatePage
Filed:
1511/07/2010
of 18
Page I15
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
17 DatePage
Filed:
1611/07/2010
of 18
Page I16
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
18 DatePage
Filed:
1711/07/2010
of 18
Page I17
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143 Page:
Filed 09/08/10
19 DatePage
Filed:
1811/07/2010
of 18
Page I18
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143-1Page:
Filed2009/08/10
Date Filed:
Page 11/07/2010
1 of 5
Page I19
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143-1Page:
Filed2109/08/10
Date Filed:
Page 11/07/2010
2 of 5
Page I20
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143-1Page:
Filed2209/08/10
Date Filed:
Page 11/07/2010
3 of 5
Page I21
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143-1Page:
Filed2309/08/10
Date Filed:
Page 11/07/2010
4 of 5
Page I22
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110340426
Document 143-1Page:
Filed2409/08/10
Date Filed:
Page 11/07/2010
5 of 5
Page I23