Professional Documents
Culture Documents
Liberi Taitz Request For Default 2009-06-02
Liberi Taitz Request For Default 2009-06-02
:
PHILIP J. BERG, ESQUIRE, et al, :
:
Plaintiffs, :
:
vs. : Case No.: 09-cv-01898-ECR
:
ORLY TAITZ, et al, :
:
Defendants. :
Plaintiff, the Law Offices of Philip J. Berg, by and through its undersigned counsel,
Philip J. Berg, Esquire, hereby request that Entry of Judgment by Default be entered for a sum
collectively, jointly and severally, Defend our Freedoms Foundation, Inc. a/k/a Defend our
Freedoms Foundation, pursuant to Federal Rule of Civil Procedure 55(b). In support of this
request, Plaintiff relies upon the record in this case and the Declaration of Counsel submitted
herein.
Respectfully submitted,
s/ Philip J. Berg
Dated: June 2, 2009 ____________________________
PHILIP J. BERG, ESQUIRE
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
Attorney for Plaintiffs
Z:\Berg, Request for Entry of Judgment by Default against Defend our Freedoms Foundation, et al 1
Law Offices of:
Philip J. Berg, Esquire
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
Identification No. 09867
(610) 825-3134 Attorney for Plaintiffs
:
PHILIP J. BERG, ESQUIRE, et al, :
:
Plaintiffs, :
:
vs. : Case No.: 09-cv-01898-ECR
:
ORLY TAITZ, et al, :
:
Defendants. :
I, Philip J. Berg, Esquire being first duly sworn under oath, state the following:
1. I, Philip J. Berg, Esquire, Counsel for Plaintiff, the Law Offices of Philip J. Berg,
in the above-entitled action am familiar with the file, records and pleadings in this matter.
2. The Complaint was filed and the Summonses were issued on May 4, 2009.
3. Defendant, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms,
was personally served with a copy of the Summons and Complaint on May 5, 2009, as
4. Defendants, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms,
or incompetent person.
10. Plaintiff requests that the Clerk of the Court enter Judgment by Default in favor of
Plaintiff, the Law Offices of Philip J. Berg, and against the Defendant, collectively,
jointly and severally, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms
Respectfully submitted,
:
PHILIP J. BERG, ESQUIRE, et al, :
:
Plaintiffs, :
:
vs. : Case No.: 09-cv-01898-ECR
:
ORLY TAITZ, et al, :
:
Defendants. :
CERTIFICATE OF SERVICE
I, Philip J. Berg, Esquire, hereby certify that a copy of the Law Offices of Philip J. Berg’s
Request for Entry of Judgment by Default; Declaration in Support of Request for Entry of
Judgment by Default; and Proposed Default Judgment were served this 2nd day of June 2009 via
United States Postal Service with postage fully prepaid upon the following:
s/ Philip J. Berg
________________________
PHILIP J. BERG, ESQUIRE
Attorney for Plaintiffs
:
PHILIP J. BERG, ESQUIRE, et al, :
:
Plaintiffs, :
:
vs. : Case No.: 09-cv-01898-ECR
:
ORLY TAITZ, et al, :
:
Defendants. :
DEFAULT JUDGMENT
The Defendant, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms,
having failed to plead or otherwise defend in this action, and Default having heretofore been
Entered; and counsel, for The Law Offices of Philip J. Berg, having Requested Judgment
against the Defaulted Defendant, collectively, jointly and severally, and having filed a proper
Request and Declaration in accordance with Federal Rule of Civil Procedure, Rules 55(a) and
(b) and upon the Declaration of Philip J. Berg, Esquire, that Defendant, Defend our Freedoms
Foundation Inc. a/k/a Defend our Freedoms, is indebted to Plaintiff, The Law Offices of
Philip J. Berg in the principal sum of Forty-Six Million [$46,000,000.00] Dollars plus
interest thereon; that Defendant, Defend our Freedoms Foundation Inc. a/k/a Defend our
Freedoms, had been Defaulted for failure to appear pursuant to Rule 55(a) of the Federal
Rules of Civil Procedure; and that the claim is for a sum certain or for a sum which can by
1
ORDERED, ADJUDGED and DECREED that Plaintiff, The Law Offices of Philip J.
Berg, recover of the Defendant, Defend our Freedoms Foundation Inc. a/k/a Defend our
Freedoms, collectively, jointly and severally, the sum of Forty-Six Million [$46,000,000.00]
Dollars, plus costs and interest according to law from the date of this Judgment until the
This Judgment is entered by the Clerk of the Court at the request of The Law Offices of
Philip J. Berg and upon Declaration of Philip J. Berg, Esquire, Counsel for the Plaintiff, that
said amount, outlined in Plaintiff’s Complaint, is due, in accordance with Rule 55(b)(1) of
By: ___________________________
Deputy Clerk