l1j2i/2()10 13 44 94S1SB1603 GRLVlAITl IiCB2l:l fl 001/058

Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 1 of 58

Exhibit 1

, ,
1012~/2(l1:,l '8.44 134:;1:6137603 lJR~..vTA:::TZ #01129 P (102/058
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 2 of 58
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May , _ you _ ..... Se<md. MucIl cI<arer phoWgrap!'.

Sotl'j fI> be • pest; I am not normally, but. lot depends on It
Neil Sankey
Investigator.
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CONFIDENTIALITY NOnCE: This communication conta1ns lega/fy privrle9E1c

information sent solely fur tl-:e t~se Of the Intended rectpient If you are '1ot the
of trns commUf1lcaUon you are :1ot authorized to US'a' tt in a"y manner, except
destrO"y it and notify ma ser"l!::ltltt.

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10/21/2(;:0 13:!l5 943ie87S03 ORLYT!\ITZ itCB22 p, OC3/059

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From: Nell SANI\EY <n'ol!!!!?@¥llilQg.='
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Subject FYI: How about iIIis one JIm?

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My PhOtos
My Attachn.j"ts
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SUbject:: I'E; How """'" tIliS one Jim?

A...""PNfS okier, out Y6$, that's L1e Usa LitEr!: ! knOVl.

James R Secord
Deputy Distnct Attorney
Asset Forfeiture unit
San 8e~ino COul'!!)'
(9091 SSl·3301 fax :.;,.
--... """.-. ... ,,......... ........891·3626
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From; Noll SANKEY [maiItD;nllill"",@y~J

Son!: Wednesclily. s.pt_ 29. 2010 3:23 PM
To:_._
Subject: Haw about1hisone Jnn?

.. I _ .
10/21/26 10
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13:45 949 1 667803 ORLYTAITZ
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 4 of 58
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10/21/2010 13:45 8487887803 ORLYTAITZ #0829 P 005/058
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 5 of 58

Exhibit 2

10/21/2010 13 45 9497667603 ORLVTAITZ #0829 P 006/058

Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 6 of 58

, Affidavit of Edgar S. Hale lit

1. My nan. is Edgar S. Hale11f. I am over 18 years ok( I am a resident of
TeXllS, I not suffer from any menial impairment or disease, I have
personal of the following : .
,
1. I pen;~lly s:;rw Usa Uberi on AUgust 7,2009 during an emergency
motion 'ng in Liberi efiil v Tallz et al In front of Honorable Judge
Eduardo in the U.S. Federal District Court , Eastern DisIrict of
iPensylava ia.

2. Usa U " who is depided on the attached mug shot, is the same Usa
Liberi, who present at the hearing, and who stated in her complaint.
Usa Liberi. convicted in California, that she is a different
woman, an Innocent woman. residing in Pennsylvania, who was defarnecI
by the nts.

3. During hearing, Which was open to the public, which included several
observers, no driver's license nor any other documents were given to
Judge RoI~1O by eiIta" Usa Liberi or Iler attorney Phitip BeIg.
4. Lisa' . and Phitip Berg left the courtroom at the same time as I left
the COUIrtroql/ll
under the penalty of petjury
Signed the 8"' day of October, 2010

dcl~
~" ..

. thiS Ihe 8"' day of October, 2010, appeared Edgar S. Hale III,
who signed this document in my presence.

.•

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.
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.
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;:OOO/ZOOO~ 6906ltt90S XVd 9S:g1 Ol06 01181

 O~LVTI\HZ 1i0929 p _ C07/058
Case 2:09-cv-01898-ER Document 147
Filed 10/21/10 Page 7 of 58

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.---'----­
10121/2010 '3 45 9491861803 OflLvlAITZ #0825 P.OOE/058
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 8 of 58

Exhibit 3

lC/21/2010 13 45 34E
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 9 of 58

1. My name is caren Siei Hale. I am aver 18 years aid, lam a resIcIent of T_, I do not SIllIer
from any _ I, n.....' ' _ ordioe...., I ' - """""'" ~oflhe ~ :
,
1. I perIIOIl8Ityrsaw Usa Uberi on Augu$I 7, 200IiI dIIrir1g an eme<gency _
h••dIU ., Uberi
et at vT"IUI~ in front of Honoi_ JLKIge Eduardo Robmno., lhe U.S- F«IeralIlllllrlct caurt
, EaoIIIm ilIIIIrjct of iPensylavania . '
I
2. Usa LbIri, ""'" is dopicIed on lhe _ mug shot, is lhe '"""" Usa Llberi, wtK:Iwao
pmd ..... !-Ing. _ _ _ In I10r CClllII*IIr1l, lhaI_1s not Usa Llberi, cor.._ in
caIIIornI9, '_joe _ _. an " " - ' 1 - . nooicing in~, who
.... defamed !he deiencIan!s. ,
_ _ opentolhepublic, _ _ _ ....._ - . . . "" ~

dr-.o oor any _ _ ....... gMen 10 JLKIge ROOn!no by _ _ Usa Llberi or

I10r aIiIlmey 8eog.
I
4. Usa Uberi' PhIlp BeI1J leftlha <XlI1rimam at the sane lime _I left"'" <XlI1rimam

CUM «:ti~
~f}L ~ ~o.fJJL
,,
,

i
B4IfmI me on _the f1' day of 0cI0ber, :11)10, "I'I'NI'!'d C - SieIi HaIEo, who signed this
d!lCUmen1 in n\Y """"""",.
1(/21120'0
.t0929 p 010/C5B
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 10 of 58

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 Case 2:09-cv-01898-ER Document :nu
10/21/2C'O 13 46 S487$S1803
147\11 AIIZ
Filed 10/21/10 Page 11 of:09:::9
58 l' _011/059

Exhibit 4

10/21/2010 13 46 9451657603 OilL YfAIfl #C823 P Dl2/C5S

Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 12 of 58

AffIdavit of Dr. OrivTalU. ESQ

,
I, orty Taitz, .fn
an attorney, licensed In the State of Q\1ifQm1a. 9'" cirrult court of appeals. Third
Cimlit Court lof Appeals and admltted to practice before the Supreme COort of the United
States. In lh~ above action I represent myself and Defend Our freedoms Foundation, where I
serve as the Pre~ident. I am over 18 years okl, do not suffer from any mental impairment, have
I
"""""",IImo\l'ledge of the foregoing facts and declare under penolty of perju<y:
,

1. In "nd around April of ~009 I was alerted by my support.... that an ...mail address
I
coon"l'led In the pay-pal on my old web site 'Defend our Freedoms" was changed,
2. Ilmmtdiately repQlted that fact to FBI and police.

3, My former volunt••r web master Usa Ostlllia demanded that I tal:e back my complaint,

as it I~oks bad for her as a web master. She threatened, that if I do not take back my
comp~int, she will not serve as my web master. rrefu!:ied to take back my complaint tlnd
annoJoced to Ostlllla, thl>t I will be looking for a new web master.
4. 0stllI1lI1ocked
, me out of my _b site and continued soIidting donations. usine the web
site imy fuundetion and redirected the donations to her prWate pay pal aa:ount. A1
the me time Ostell. started _Ing With Phil Iklrg and used the web site of my
found ion, not only to divert funds but also to denigrate me and promote Berg. This
info ,_ tion was reported to the F8l and police: as weU.
5, In and around the ""me time I was ""Rrad.d by Unda Belcher. who stated that she
knew ~rg for some 10 yea.... that sh<! was. voIunt.er researcher for him. She recently
found lout that one, Usa Uberi, who _ as Berg's paralegal and manages hi> web site
and p pal .c<ount. Is actually is • convicted document forger and thief on probation,
~~ed that my recent problems were connected to Uberl.
6. Ucensed Investigator Neil Sankey to check this tnfonnatkm.
7. provided • MtaUed report thot confirmed thot Uberi indeed WI•• convicted
eot forger and thief and was currently on probation.
S. ng that attorney Berg d_ not know about llberrs past, I e-malled him and
adI~~ him and forwatMd t<> him a transcript of Uberi's felony convictions and _
him. t he should not submit t<> court dO<lJments, prepared by • convicted forger and
n01 do fundraislng while working with • convicted thief
9. v@r responded and filed current legal action against me and a number of other
indivi ab csod plaintiffs~ daiming that he ;;;tld Uberl and Ostella were defa.rned, and that
she is not a convicted felonJ who assists him via e-mail and phone.. but an innocent
worn • a different Lisalibeti, who resides in PA and physically works In his office,
1()' On Ju' e Ii 2010 Judge Robreno ordered the case """",ed and transferred to 1)( and CA..
11.10 my subsequent motion to dismiss I a~ that the court did not have jurisdiction
Ollf'.f t e case, as the case was filed based on diversity, For diVersity each party needs to

Uberi v Tait.l 10.0',10 Affidavit of OMV fait: 1

10/?1/201J 13 4~ 9~S7ge1808 Ofll'tTATTZ flC82fJ P 013/058
Case 2:09-cv-01898-ER
I Document 147 Filed 10/21/10 Page 13 of 58
,

pro~s state residence based on evidence and lacts. Utle,; never provided any
eviden , to prove her .Ilegations, that she is • resident of PA. '" ;ucb the """ needs 10
be issod.
12. On JU*
30 2010 Uberi and Berg fiied an opposition to my motion, wile,.. tbey stated
in
that Ju~e Robreno's statement RUbert is a resident of Pennsylvania' his June 6, 2010
order Was baSiQd on vital records.. tholt she 'SUbmitted to judge Rohreno during 08.07.09
em.rg~"cy h••ring. Liben specifically mtnd that they provided her driver's Ii<ense and
other ~ments.
13. 1 filedla response and demanded to see that Libert's PA drivers license, as it wa$ not
irodud¥! with the transcript of the hearing.
14. Uberi' d Berg filed a motion to have Ubt':!n's drtver's lkense 5e(I1ed, as they claimed
that " is afraid for her lire and without" shred of evidence tbey claimed that Uber;
bel' that I tried to hire • hit man to !:ill her and her famlly and that is the reason.
why e shQuid not provide her drivers lice_ to show her state reslden<:e.
dee*" under penalty of perjury, that I did not .ttempt to hire any hit men. This is a
preposterous. malicious accusation made witbout iii $Orad of evidence. I demand
.5<Incti s against the ptaintifu and O!ttomey Berg for malieiously fding wtth wort
=~on, (If capital <Times withQut any "vident<! and for improper purpose of
coveri~g up the fact, that Utensed PA attorney Philip Borg Is continuously workinG with
ed document forger and thief who is currently Of! probation.
16. I ' usly submitted to this court Uberi'. photograph with sworn affidavit .f
ator Sankey and sworn affldavrts by Caren and Ed Hale, who tdantlfied Uberi l!\S
the man, who appeared before judge Robt1!nn 00 08.07.09 In Liberi v T.itz and the
same raph .... identified by tiberi's arresting officer Monrison, as one convicted
in CA. I am additionally submitting tlberf. recent mug shot, whid> claarly shows that it
is th~ same person, who _Bred before judge Robn!no on 08.07.1l!t and I am
subm~ing an e-mail from her prosecuting distritt Attorney James Secordt assistant
Distridt Atlemey 01 the San Bernardino County CA. verifying that this is ind~ the mug
shot ~usa Ubtri, Convicted in CA and not allowed to reside in any other state, but CA
and N aecording tt) terms of her probation. t forwarded Uberfs Mug shot to ED and C8ren
H.aJe~ , ho Signed sworn affidaVfts¥ that the woman on this mug shot IS il'ldeed Usa Uberl, who
appea,ed b@fore judge fiubr~no 01'\ OS.07.09 for emelP'flCY hearing in Uberf et aI v Taltz et ai,
clalmi,", that she is an ioooCflnt WOJru;ln residing in PA# who was newr oomricted of any crimes.
who .... defamed by the dei\Inda"" and who cannot unseal har PA ~ license because sha
is arr.J;
, for ker tim ,
17.1 filed the motioIl, demanding ,eIe..., of Uberi'. license with the proper purpose to
asce+in Libe,,', stale rsskIen<:e at the time 01 fi"ns this action. As evidentiary proof of
resid1nce is tne. basi$ to assume- jurisdiction, I am entitled to obtain such evidene~.

Ube.; v Taitz 10.07.10 Affidavlt of Oriy Toitz 2

1C/21/2010 18-41 9421661603 ORL'tTAHZ #(;829 P ()14/0S8
Case 2:09-cv-01898-ER
I Document 147 Filed 10/21/10 Page 14 of 58

18. , pr~ a letter from Joff Staples .nd Affidavit from unda _ with the _
pu~ of showing that the plaintiffs and Libeti .,. refusing to provi<:fe 1Jberi', proof of
,
PE!nnsyfvania residence not because of their baseless and matk:ious tKcusations of fear
f", rut me, but because they h.... guilty mind, because Bert! kIIow'.'SIY worI<ed end
cOl1tlralous to w...... with the convicted document forger and thief, and because Liberi
kno..,." thot proof of ..... fraud on the court and pe!jury, as _ as om!SS to _ credit
_ w i l l ......... eroundsfo< _afher~ and_cerotIon
to her aJsht year prison term. Ber!! knows, that proof of the fact that IIb.ri did
(;OI)Jd not have a valid Pennsylvania driver's license vAil not onlv serve as

groun for dismissal of this case, but also as grounds for sever. sanctions against Berg
for
tho
E' fraud em the COUrt, perjury, USe of court for improper purpose to defraud
bation department, us Dlslrlct Court for the Eastern District of Pennsylvania,
Third. ·rcuit Coort of Appeal$, C1lifo<nia SUperior Court, slander, defamation and
intcntfonal inflictiOn of seve'" emotional dlslres$ to the plaintiffs.
19. This <turt received hundreds of pages of affidavits from Libeti's mother Shirly Waddell,
wher~5he swears that her daughter is an innocent woman, who was defamed by mel
1
when provided her criminal record to public. I am p!'(I\lidlng with this affidavit. """
and ~ copy of the tronstlipt from San Bern.r<lloo County CA, SUperior Court case
FS~914. It >h<:>w, that Shirley Waddell not only knew .Isout her daughters crimin.1
reoot1. but she ako was the one who paid for the bail bond. Tnis tfaO'J(:l'ipt is brought
for the proper purpose of showing that the plaintllf. witness Shirley Waddell
comrrltted
, fraud on the court and perjury and need, to be severely sanctioned for it
20. On ."merous prior O<CaSions Berg and Uberi d_ed her records s.alod and
~Iy this court, as W1III as the tourt of Appeals refused to do so. I .vffered
.no~'us emotional distress and financial hardship haYing to respond to thousands- of
pages of maUcious slander by Plaintiff> and I!e<g, _",by they malidously without any
shred, f evidence aC<:U5l!d m. of attempting to hire a hit man, of forgery and akeration
01 d~ments. None of those altegatkms are true and I demand severe sanctions against
the p Intlffs and llerg for maliciously accusing me of crimes.
21. Uberi nd Berg ,howed Ii pattern of acctlsH1g' number of innocent people of crimes.
lhoy bsed a decorated polite officer and ti"""'ed investigator Neil Sankey of braking
into ~e computeI' of liberi, and of Stalking her, they accused Desert storm veteran
P.~ Bamett of forging document, tIley .«used researcher Lind. Belcher of h''''ng a
erimi~.' record, theyacctlsed Ed and C1ren Hale of st",Ufll: and forging documents.
None ~f those malicious accusations is true, I submitted to this court sworn affidavits of
alllhEj above indMduals, attesting to thot.
,

Ulxlrl v Taitz lOJ)7,lO Affidavit of Orly Tailz

10/21/2010 47 8497887803
13Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 15 of 58
I

22. The o~ ImOW" aImlnal in tills action I. Usa Liberi, who mastem'linded ,his frtvolous
and nfHdOUS ~I action~ in order to intimidate the whlstte: blower and avoid
rwooajoo' n of her probatiOn.
I declare und r tile penalty of perjury, and under tlIe law, <:>f the state of CA ,hot .11 of the
above is true d correct and to the best of my kn~dge

Slgti .,~.

Dr.OrlyTait1,rSU
10.20.10 I

Uberi vr.az 101)7.10Affldavit afOriv Taitt 4

10/21/2010 12:47 849 7 GS7S0j ORL VT AIiI #0929 P 018/05S
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 16 of 58

Exhibit 5

10/21/2010 13 47 94S1S87B03 ~RlVTi\IiZ #0829 P 011/059

16/21/2010 CaseFAX'
13;.{$ 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 17 of 58
,, ijJ 001
,

Eastern ~ct of Pennsylvania

Case N . 2-09-cv-01898 ECR

S. Belcher, appearing Pro Se in lhis action. I residE< at 201 ParI$ 6t.,

. . • I am infonning !he court that Berg hU not semod _ with

I,
copiee 1 any of his pleadings for over a yooar including those flied -V.

I QIlIy oovr healsay infarmation about spurio\l$ acouaations Berg oontinues to

make ~inst me. Illy ConstiIuIioneJ tfghts COlItinue to lie ~
vkiIIItIId ' Y Berg under the 14" AmendI1lent II> Due procesg !I!ld Equal
ProI!i!CIi<:np!Ml!l1hough I have c:ompIalned numerous times in writing, in fi!Ing$,

telephone calls II> \he court clet!<'s offioe !I!ld Your HonQf's chambenI

~ allegations If I am not provided copies. of what I am accused? I

4
have

willfully +- furoe<j into a position of gross disadvan\Qge when Berg is iIIIowed to

my rights !epeatedly for mer a year and nothing is done about it.

I Hy found some of the pleadings on a website C$1Ied Sc!ibed

<_. ib<;I,com» on Monday evening, but I have no way of kn<IwIng if

10/2'/2610 13,47 S497E67603 '0929 P 01Sn6F.
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 18 of 58
10/2l/2GI0 1~!4S F~ @loOZ

they""" 1eIe, or _ e<l1tIiId, poslI!d by an unknOWn using the ~ name

s.v must be ordeI'ed to send me copJu of his

_Ie
of romisewtruth.

plaadh:~ It i6 his jOb to a/llIII/IIJndIInt's " - copies.

It.

complaint. In It, he appanmIly _ _ I have faIsi!ietI evidern:e

andIc!' notary Mal 011 affidavits I supplied to the PA federal cour!s. All my
'" notarized at the same buslMM In Me<llna County. TX. Upon

request, I • provide the notary contacIlnfOrmation to the judge. It must be

held seal as Berg and Uberi have a lOng hisloly of harassing, Ih~

III,

Aitomey IeiJaIly counseled me many tin'Ie$. over the years we we... friends
and !hen Vio/!!Ied my aItomey-dient confidentiality I9Iated to my idenIIIy and

location ~ divulging p~ !nformaIIon publicly and in pleadings with lIlis

I
court.. Lit:Oeri obIliIiruad !his infDtmation repnl8&nllng hooIelf as his paralegal and

me me. Berg and iJbefj discIoseQ 1!lis confidential infDtmation

Publicly lie they defamed me along with lIleir wIInessIagents, by each

of t1I1minal wrongdoing, They also aIfege I spent lime in prison

which Is

prison, or,ever committed the act of forging a noIary seal in my sworn

,i
10/21/2010 13:': 94$7687803 OR~ YTAITl
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 19 of 581t0929 P 0 HI/C58
101%1/2010 13:45 R~
1i!I ••,

~ 1 this court, or ever mMUfaetUl't!d any evidence!

Libeti, + Berg and 1Jwir wiInessIagents have defamed me, alleging I was II
COI'IYieIed' mlnel wIlo wfV9C! I!TnG in prison _ an _ ,..,.,.,.a goinQ back
I have numerous Climlna! aliase8, that I was evicied sevmal times

fnarlied 10 times, alleging lenibIe lhlngs, ere,. eIe. Uberi OOIlVInced a

person 9 1Jw alias Dr Ron PoIari< whose !rue _ is Ron Pollard It> make

one or poIIIS online acouelng me of havlng " record It block long! A former

moderaIo of 86rg's website whom Uberi banned (and Berg blamed me of

"stealing"~) posted the lin!< on my webSite to the site wheno PolaIIk's

!rue
,

j was 1'e'ie8/ed and then Berg blamed me of e>cpOSing himl They haw
I!lIseIy

about + imed I spent aD of 2004 in prison When I was doing radio shows taII<lng

scandals I have r""""""'" and exposed. I can prove a direct link

between aM U- faille allegations posted in numerous piaQes anima and Libeti.

I haw married and divorced twice. I have two children, Mer I married and
child, I became a volunteer for many community acIMties. lwas
Com Chloir of the local Cub Scouts and Boy Scouts. re<X)lding sectetaIY of

the Club and a totmder in \ha loCal Ok! Fasiriooed Chrislmas. a local
festival , Id on the town square he!e each year. AM of these _ positions I

held aIlBrt983 When 1hey claim my Climinal histOlY began. Thi$ sun and

aft the s have cause(! lenibIe pain and strife for me and my family,

inc! • e
for my 1 year Old son at high schooi.

IV.
10/21/2010 :3 47 9487B&1603 JRLYTAIll #(1829 P 020/058
CaseFAl
10/21/Z010 13:4$ 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 20 of 58 IlJU04

me she was manually entering credit card transactions·for Betg's

obalTJa(~IS . com website while we were on the phone. Uberi had TOTAl
CONTR and ACCESS 10 this inf<mnation and of the donations(io IIioIation of

the terms + her probatioo UIlbel<nawnst to me at the time) ThIs can be proven

wiItl the k>Ilin logS whk:h will shcw her IP number while ~ accounts
,
online. $U~ can be issued to deteImi!Ie if I speake the truth. .

.., v.

Kelly IiIe<I a new affidavit with this 00Uft in Sep!emI>er 201 O. Strebel
could only have personal knowledge of events afIer he became involved as
web at Obatnacrlmes.com in February 2009. He is ~ to e _ that
occurred the befOre he had any involWment, while Geoff Staples was

web , and aftet Gall Frye was interim webmaster. He had no ditecl

~ in eetIlng up Berg's Paypal Of UnIq>oint merohant accounts for

~.com and can not know if LIberi set them up or had liICCI!$$.

VI.

Slrebe!'iII d aIl19fS dairn& of alleged fear of hafm are false. I hean1 Uberi
l"dsllll$ on .. Ihree way phone call to tell ~ she talked to how
was Ed Hate would harm her. LibarI,,1ated 8h9 _ trying \0 get

VnISlad. Adams agreed to follow her direclion$. I _ on a series of

way phone calls that night where Uberi asked me not to say anything

when • called the FBI in Amarillo. TX and the local constable In Wellington. TX
10/21/2013 13.'8 8481BG7S03 tlRll''rAITZ #0228 P 021j05f.1
CasePAX
1'0/21/:24'110 13:46 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 21 of 58 ItJ005

at first tl) home with his wife afKI then tl) the consIab!!i> on his cell phone wIIo

Is Ii hatm/68.s /eddy bear wOO gm_ a lot, but w-.'t do

anythfngf '\ mrnembef" QhIIIIng oommant Llberi made tl) Adams tl) "IlU$I/IW

and do as say I've done /his beforo.· 1110 case was dropped, so I tool< no
,

:::j
ful'\ller actJ:m. lJberi told me she had also called the sheriff in Welfington, TX

he laughed and basically ¥aid simAar lI'Iings about Hale being

Plaintiff's ~ their wiInesse$ are maIdng wtki accusations of fur""", hatm

wIl/ch smJ"y does not exist. UfJellIIIIId the 0/henJ _ _ beet> In any
danger. eIIy Sflebel's affldav~ I$I1ea/$ay and must be disrega!tled. Adams

aI!IdavIt Is hearsay and must be dlsMgarded.

V11.

Your rvIad that L1berl rwsitIM in PA. All we csnligure 8$ the besI$ for

that I$lhat the drivers Iioens& lJberi claims tl) have shown Your HOIlOf

must he been issued by PA In on:Ief tl)r Your Honor tl) maJ\e $\lOll an

l!O!I'OI1eoUO!l stalement I do have direct knowledge of Llberfs resldence. Her

't"" phone number,

iandrme
,
!$sued In the name of her hooband Brent Uberl

appea10n wemy call"'r id and spoke every day, numerous tirnee.1t was not a
PA ph""" number. The pacQge I _ shipped tl) lJbefj and anlved at her home

ilia _~ day air. It was NOT sent to PA. Libell does not reside in PA.

V111.
10!21/2Q10 13 40 9497987603 OfLVTAITI P _ 022/058
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 22 of#092E
58
10/21/2010 1~:46 F~ III 006

she opened the third Paypa! """",,<It in her husband Brent's name

er the first two were ehut down beeause of the number of donaIion$

+ng, ,
for Bslll

he was leal11Eld Berg was taI<ing in betWeen $10,000 and $20,000 II

day. We r on the phone when liberi $IIid she was opening the aooount

Subpoen"l' of Wbefj's phone hICOrds and Paypal wit! show the times overlapping
whe" she ~ logged in and """"'ing the account Also the thme '*"'I phone

calla myself, Wbefj and \IliIElov$ othelS IIlICh as Lany Sioo!air. Evelyn

AdamS, Amarillo, TX FBI and the Weltingtoo, TX consIabIe''I' home wIIh his
to his cell phone.

IJt
i

I beIIe\/e Serg included me in this soil to disCredit me wIIh cWf8rnato<y commen1s

agairnIt ~- He
,
!(new I had inaid9r information lila! woulQ reI>Utt false allegations

when he.i.ed the other defendants. I know lillie about 0steI1a, except lila! she

and liberil_ communicating in ema;1s befono 0sIe1la beCame Dr. Tatiz

1t>Iebma8tEt. After Ostefta hijacked Dr.TaiIz....ebslle, a nUlllbe< of people roch 8$

ohlhart and otheIS toIQ me !hey were SUddenly gelling soiicIIatWnII

for Berg updaIes on his aClMlles when1hey had been banned by Liberi, 100.

x.

Kelly + s1ated Liberi and I did not have a chat wIIh me on Janus'Y 2. 200S

abolJt Ed rIEl. He n!!IIidea in Utah and could not know what chats WEI had, or

what ~es liberi received for Xmas in 2006, He was no! even inVOlved wiih
,
10/2 1/2010 13:489~876B7G03
Case 2:09-cv-01898-ER Document ORL
10/21/2010' U:4fi FAlj
147 HAlT!
Filed 10/21/10 Page 23 of#0523
58 P 023/058
~O()7

any ollIS n these _ OCCUlTed. This ohat _ saved on my computer

months beiofe I made CO/Itact with the HaI6$ in May 2009 after SIIIVice of the
this suit

IooI!18ic$ exomlflalion of my oompU!er will show that ohat (and many

other i~ i1ems) ware all _ en my ""mlmler LONG befono there I

knew the'1- even .. problem _ ' " " mEl and Berg or UbEIIi. Sbebel knows I

have very oomputer tedmQIogioal skills. His ClaIm I forged eVidence IS

false. I ldn'l begin \() know how 10 do !he Ihlngs he cIainlI> I forged.

XI.

l!erg's, "s and Slrebel's Insane allegations _inst Dr TIIibt areludicrou&.

Though I not inllOl\Ied with Taitz em a felIUlar ba.... ~ for lhls suit. I have

_ . anylhlnllin her behavior to cause me to doubt her integrity, Of

I
pmfessiOnptl ethics. In fact, she htIs always s!n!ssed caution and V«aCiIy in

tkl I
my repHes/1O this court, especially EII'I1p/1asIzin I dfffemntiale betwee!>_1

know or PfO"& to be true Of false versus what merely believIod.

This is in ~ contrast to events I have wltnessed fltslIumd. How easily Berg

s _ to ' Is to the ooW1$lhat he knows or oI1oold ~now are untrue and

vIcIoUSly efames people. In my opinion, and I've koown Be!!! sinoEl1998. I've

plafesslotjally and ethically bankropt He should be disbaITed and in\Ie$IigatEId

.
for felony . ury. fraud OI1lhe court, conspiracy to commit SS ftaud, actual Ss
lC!21/20'O 18 46 64B'€S7833 ORL,'7,\rz k0028 P 024/058
CaseF2:09-cv-01898-ER
10/%1/2010 13:4$ Document 147 Filed 10/21/10 Page 24 of 58
IilIMS

and abetting a convicted felon in violating the terms of her probation

this felon to IIave III:008S to supporters credit cald infotmaIIon and

donatio....;1 pray Your Honor refers this case to the SUpreme Court of PA

boaro for lO<:tion and the PA AItomey General. ! am willing to

seeing Berg be held _ntabIe fOr his actions.

xu.

Defenda characters me not the issue, though Berg has proven he woukl

knowingly the court and smear U$ with vile lieS to distract from the facts.

The • n Is wIIGIher Uberi .-ides In PA and produced .. PA driwr's

court on Aug 7"', 2009 thatwaslssuod to ' - prior to May 4"',

2009whklllYour Honor ~ youratnomentthat "Liberi I1!I$Idas In PAN.

Ut.ri CA court onIered ms1rietIo.... on when> she may nosIde until •

COftI,plaajo probalIon sometime in 2011, and ifelle has paid ' - restilulion

Wilhout . producing a PA drivers license, this court has nO Jurisdiction and

Berg has time and defrauded everyone along with the court fOr II year

and a while viOlating my Conetllutlonal right; and maIIcIouSfy smearing

deliendlenls. wihich has """" indulged by !hill court.

XlI.

_, and pIainfIfl"s /IIImJtbiId In p/Nd1ngs, LIbetI does not

)II. There hu bMn NO dtiII'amation. Defendaots ant the ~

1CJ21/201C 13:49 9491887803 O~l'iTAITl #Ol?29 P 025/058
101',1,.,. CaseF'1
13,'7 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 25 of 58 iglOOS

I,

llt/Il18d~rtN... not plaln!lll's. Your Honor must !>Old Berg _ b l e for

defmudi !he PA courts and defendants, and violating my Constitutional

rights to Process and Equal Protection in not serving me caples of his

,
1
I, Linda 8. Belcher, do he!lIby solemnly swear 10 the following. that J am over the
age of 21 1'8, that all statemenm In thts doc:urne!lt _!lUe and """""*10 !he
best of knowIeodge made under penalty of perjury IiICCOIdlng to the laws of the
SliM of l' wheIe I reside.

LindoS,~

c{J.d:, l a! ,(),9J 0
date ! I
,

'~~;~~
10/2'12~10 13 43 949

Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 26 of 58

Exhibit 6

;0/2112(nO 13 43 £L91S67SC3 CRLYTAIT! ~OS2a F 027!;)S8

Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 27 of 58
10fOS/201~ 15;28 81916S1603 IlRlVTAITZ l0170P,001l01t
,.
!, .

1
SUPER~R COURT OF THE STATS OF CALlPORNIA
2
Fer 'III! COUl'lTY OP SAl'! BERNARDINO
3
;- DEPAR~T 3: . HOtr. JOlIN M. PAc:asco. JUDGE

. I

,;;- PEOPLE olii TIIB STAT!< )

rr C1ILU'ORllIJI/, )

6
: I Plaintiff. )

7
iI l) SIlPIlIUOR COUR11
CASE NO, PSB-044914

II

, I
lSA uLBERI 1'CRARDSON.
;

10
Defendant. )

11

*.-~--~~----------)
12

13
TRANSCRIPT OP PR8LIMINARY HEARING
ANP ~IL/OR HEARING
AUGUST 4. 20Q4
1$

16

1.7
i

T:RR PROPJ8!t MIC1IAl!L RAMOS

18
I ~ist%1ct Attorney
BY. JAllIiiS SECOIW
19
I, Deputy District Attoruey
1 . I

~R 'rD DBI1~'I:'
20

IIDI M.O. PlIAL

21
; I
Attorney at Law
22

23 .

24

~5
i

.
;
I

26

.~.
,

\- .
.:r
27

~PQRTEI) BY: I
COLLEBN sOUTHWICK

CSR-RPR NO .. 9949

28
,I

!
..,
"
"
"
10/21/2010 13 48 9437667603 ORl.'lTCTZ 40829 P. 028/058
,
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 28 of 58
1;)/06/~(ll(1 15.30 S4~.768?M3 OfllVT,tITl .t0110 1'>.0021018

. - . 1 i INDEX OF WITNESSES
2 PAGE

3 . lltOA R.O",,~
,roect ~iltion by Mr. Secord 2
4 ~osa~BXam~n~t~on by Mr. Faal 7
~dir~ce Examina~ion by Mr. Secord 9

~r~ct axam;1ltion ~.
5

by Seqard 11'

7 !!i+-!l.!i.,.J,oI~J!.ID!
~r~ct Examination by ~r. Secord 1S
8 ~rect Examl~tion (Cont'd) by Mr. Secord 37
. ss-Exa~ination by Mr. Faal 40
9 ~ir~ct Exa1ination by Mr. Secord 46
10 ~~!III!!~Y~_ I
"irect secord
Eltami ation by Mr. 62
11 ~&a-Bxa~in tion by Mr. 7~al GO
jod!T""t!lrQ nation by Mr _ se"ord 82
12 oT~$s~Exam nation by MI. Faal 84
. 'ther Redi eat ExamiMtion by 'Mr. secord 96
13
COTTMEHR
14 ~rect KxamirlatiQn by Mr. ~aal 90
-~SS-Exam~ntion by Mr~ Secord. lH
15 direot Rxa 'nation by Mr~ Faal 100
1tcro~uJ-EX nation by Kr. Secord 102
16 '; tner Redi~t Exa~i~tion by Mr. Faal 103

17
~rect Bxami atian by Mr. Secord, 105
18 rosa-Bxamin tion by Mr. Vaa1 10a
I:
19
)lrrect Exam! atlon by Mr. SecQrO
20 Foss-Exa~n tion by M~. Faal

21

22
III

24

25
26 ,~
),
i·
27
2$
, ..

I'

10/2~/2010 '3'48 9497807003

10/0SIZ0'0 15:S. 9'~ieele.3 (l:Rt¥TAITl
OfLYIA:rz 10823 P,02E/053
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 29 of 58
1t1?,> P,l)OCSlfltg
,

', ...
!
1

2
I

4 COURT! Sir t dQ you have ~- has ol:Ii bond

poata4 on t.h~ Ms. Lisa·~~nee Richa~dson caSe?

4
ut I'm not he previoue bOnding compahy.

5
By the way~ my name is Scott Mehr with Steven
G oot;; t "eh. Sri lbonds..

7
MR. p~~: CAn you tell the judge _

8
MRI SECORD: Why don't •• have him come to

9
~& stand, p~eaae.

10
: I
SCOT!' !<lEaR 1

11
'J)~ lled. as a fitness on be.b.a.ll of tiw defonse, wa.e SWQ:nl

12
~d testifie4 as follows:

13
nJ CLnK~' Do you sole1l'lnly state that tbe

14
~idence you are abou~ to give in this matter now
~S rending hefQ~e this Court shall be th. truth# the whole
·;ruth, and nJthing but the
I .
trut.h~ J?Q help you God?

17
THE WITNESS, Yes,! w~ll.

18
TIl,I CLlIRK, T!utnl< you. Please have a seat.

19
Please state your full na~ and apell yuu~
"" ,I .

20
~ret and la,t name Ior the reoord.
21
THB WITNESS; Scott Mehr, M-e-h-r.
22
TID I COURT, You have SomA questions?
23
MR FAAL. Yes~ Yes. r~w qu~&tione~

34

25
DIRECT EXAMINATION
2.
Y MIL PA1ill: I,

27
Si" ~hat company do you work for?

28
l'~ co-owner of Ste"en Scott Moh", baill.>onds.

 10/2~/2013 '3 49 8497887303 ORLVTAITZ -tOfl2S p 1J30}05B

Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 30 of 58
10/0tj201~ 15:30 9491GS7603 URLVTAllZ 10110 tl' _O(l4,ora

91

~.
1 (l. IJ your company willing and prepared to post

2 00<'\ on
Dehl f of 11$, Lisa Liberi?

3 A. Ye , , we are.

I, ,,
• Nor",
~ou quoted ai fCQ for· the
Q. as far as the bong J.a eoneerned. ha.ve

5 bond?
..
6 A. YE:r- t we, b..,.ve.
7 II. An _hat 1& the amount th~t you've eharged?
8 J'- Th $10Q~OOO band we are chargi~9 $8,000 with

9' bail Cotnll sion r~b<).te of 20 percent due t...., Pr<;>p 103,
Q.

11 A.
12 0.
13 harging?
14 A.
15 onditiOllS.
1~ II f the total charges come to $28~010; a~ 1
17 orrect?
A. $2 ,oao, eorrect.
I
Q. $2~,020. Now, hay. yVu received payment ..
20 TIlf CO~T: Khor. ~1d you get the other 10?

21 ". 000 plus $20,010.

i
22 TlIT WITNESS: $8.000 plus 10. One borv.:l l><>in!jJ
23 J lOt....,
.. for $IOO,QOO will he ~8,010.

24 T!!~ ~T: Oh.

25 THE WITNESS. The other bond for $250,000

26 uld he $20j010 dollar".

.I
27 TIll! ~T, All right.

28 T!!* WITNESS: Combined $28,020.

10/21/2010 13.48 2:09-cv-01898-ER

Case 9~878S1803 ORLYTAlTZ
Document 147 ItCa2S
Filed 10/21/10 Page 31 of 58 P 031/050
tO/OG/20l0 , 15 ;30 94 76S76'f/3 !')~I."'U;In; tQ710 P.005I018 •

,
1 92
1 o. B'r :MR. PAAL: Nnw~ have you "received:' payment
2
,
or ~hia $28 "020'
J A~ 1I
We have r~ceived the $8,010 payment via a

4 4edit Qaxd irom the defendant 'a mother. Me hove a

~py of a Ch,Ck being sent tQ ~5 for $9,5UQ via her

•
ttorney,
I
At~orney Strickland, ~nd a $4.$QO check being
7 ent when shJ returns from vaea.t.ion tn one week.
8 Q~ OkJy . The $9,500 is ~ cheek earning f.om
9 1vil attorn~y, Michelle $trickl~nd, am I cQ~~.c~?
10 A. Co~rect.
11 2. ~ did MB~ Strickland provide you with
12 (bc:!umentatior t.o :;,how wht're she obtained t.hat money
13 1m..?
14 A. 'las, ahe did.
Il. Di( t.be doCUl'tlQnt indicate that Ms~ Liberi had
, &coeived on a ci~il ease she has from a
17
.mdlng
,,
18
A.
19
Q. :::, tne fund1n~ company provided advaftoes
tptalling mor~ than $~O,OOO?
A. I tr· ink $~7,7'5.
Q. _ And what's th. n&me of the funding.company?
A~ The_! fun~in9 oompe.ny is Inlat,l-d 2n.,.-gy LLt;l a
24 {If v.d. li1ftiter liability compar~y.

25 Q. O~ay. And that advance~ of course t wo~ld he

I
26 F id with intrust that is being compounded.
27 <: rrect? YQU rv@ received dQ(a~m.entat:ion show.ing that
28 t e funding ctmpany would be paid from wbateve~
i,!
 'O/21/20~O 13:49 849 7 687603 DfLV TAn z: #01329 p, 032/05B
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 32 of 58
lQIOBI201~ 15:30" 1£&1G03 ORlYTAttl IOTfO' p. (lOS/OHI

r+----+-~~~ ~---~---~~ . _ _,
I

1
roceeda M. -!1.ib<>ri collects from her 1~w8uitt

2 1\, correct.
I
o. Okry . So that's where the $9~500 wa~ coming
rom. The $~.SOO is also coming from Ms~ Strickland'8
5 '''Ilene trustj aCcolIDt; am I correct?
.A. corre.et.
7 Q~ An~ that's Also coming frQ~ the a~v.nce that
8 e. L;beri ~tceived?

9
A. Correct.

10
Q• o.ly. Thank you.
11

I. 6~OOO
A.
H~
fvom
Ye.
r. about did you receive an additional
~i~rit8 father?

~,
, 1.4 2. OkrY~ And whAt's hilil name? Is it: John
J.5 iclUlt:daon? I

16
A. I think it is. f don' t'. know i £ I have thAt
17 ivce of p&ptr with me. We have not r~c@ived the
heek~ He ~t it in the mail so r have not phyeically
. t the chec~ back.

Q. aUf he has promised to send you the $5,0001

21 A. cQhect~

22
MRt BAAL: Okay. Okay. Thank you. I have
33 thlZl9 :u.rt:per~
I .
THE COURT: Cross.
MR~ S£tokO: . Thank yQU, yQ~~ Honor.
26
I
27 I
l8 i
10/2'/2010 Case
"3 2:09-cv-01898-ER
49 9497667603 Document 147 Filed 10/21/10 Page 33 of 58
JRL'1iAI';Z #082& P.038/05B
15:3{) 9.~1ae16~a

i
1Ci/08/201Q ORtvTAtrz fo"Uo P,OQ1tI)H~

n----~--------_~ ____.._,
94
1

2
3 Q. Mr~ Nehr, have you contactftd Mr. (inaudible)
4 t Inland gn~rg1e8, LLC?
A. :WO; I have not.
Q. YO¥'ve not spokan to him about the trueness
7 aCcurateness
, of th~ dQ~umentn you r.c~ived from

A.

,
12 A. Na~ion&r AUt:omohile and Ca'Gualty In$urance

13 ny which, is now International Pidelity Insuranc.

14 _ny.

lS
Q. At'4f you awat'e: of w~$tber or noe they Mve an
1. reement on ifile with the Department of Insu.rance
17 I arding ~ thelr !:>aU pr@trtiu;m ~s for matters ove::r;
18
19
~
,
OO?
A.
i

I Yet!.
20 Q,
j A.
Wh~t
, ~s that agreement?
n" cOlru1\issioned
TbEiy thLough t:he Department.
22 ~ Insurance ~t .0 percent.
23 o. No~~ you are writing this for le.~ than 10
24 rcent?
25 A. Co*,ect.
Q. N~t with regard ~o ehe $8tOOO~ you said that
,
27 t~s e~~in~ from a credit card advance from th$
28 fendant'B mpth~r?
_________.___....________________________.__________
L
-it----------~

I'
, I,
1012112010 "3 49 9491BB1BC3
, aRL r "Ill #3829 P 034/050
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 34 of 58
14/o,S12010 15:30 ,. 76ST803 tlRlYUnZ '0170. 9.002/01£ 1

95
f. A.
1 Cqrrect,

Q, o~Y.
, And that advanc~ is Lo~ the purpose of

3 the $1QO,OOq bail, correet?

,
,." Cqrredt,

. Add
, you w~re aware tha~ there's a 127S~1
6 :order in pl*e \It'ith respect to that. adV~e, correct?
'1 .
7 A. Cq,t':t:1!tct •

• Q, OJ<:ay, NQw~ have you ihlHll, t with 1275~1 orders

" ..fQr&?

10
A, uls,
, I have~

II Q, okjay. What understanding do you hav@ of whae

12 1275.1 ordfr i~?

13
~. PAAL; Your HODor, I ohject. That's a
,
14 egal quest *n.

15
~. SKCORD, 1'm asking his understanding.
i
16 ~. FAAL: It'D irrelevant, his

17
fn4erstandinp.
'TB~ COURT~ Mol it's not iii legal question.
;
19 tl.8 SQMthi~ th.. t he probably woulQ have 1;.0 de..l with
. ;
20 'n his cuat~ and practice and trade~
I
21 IS; ~hat somsthlng you have to deal with?
22 Tn WITNESS, wen, yes, .. H75,
i
23 eriodically! they want to know that the money ~ing

34 ~.~dl the ~1SSione tQ the bail bon4s~n# 1$ not from

2S 11 gotten 9~ins from any activities du~ to the

Q. 'Y!MR,.SBCORD: All r!ght. So ic Would be

28 "'Proper for;, that money to be disguised in any way to
 10/21/2010 13 43 9497£87£03
lOJORI2010
Case 2:09-cv-01898-ER
1S:3~
I
9••1681803
Document 147
DRlVTAITZ
Filed 10/21/10 Page 35 of 58
IjRI,.VUlTl
#0823 P 035/05S
'0170 P"GG9/0tS
,
,
I,,
,

f 1
"ry' and hide! it from the Cou:rt dur'ing a 1275 hearing;
2 iii that corr.ct?
,
A. Co::rrect.
Isn't it true that on July 29th~ I

i.
Q. Ok.y.
5 palievQ it i~; of this y.3~; t believe that WGS la$t
6 ednesday; that correct.? July 2S~h. excuse me.
7 es. it"= th~ 28th.
a Ls,'t i~ ~rue that on July 28~h which would
, Wedn.adAy ev~n~
•
yQU had a ~~l~phone
10 onver.aCioDjw~th K$. Libert concer~ng the $8 OOO that r

, 11 er mom was ~vancin9?

12 A. Wi~h her huaband~

13 Q. With her husband?

I

14 A. Yeq.

l.S o. ·
Dickn'f1;. you also have a conversation with
I

16 s. Liberi?
A. Sh~ three~wayed, 1 tb1nk. I had several
envaraat10~ with a~ent and I thLnk theze was one
•,

hraa way wj;h har on the phone, but we got cut off~

~ere was a ~hort conversation.

21
o. Iri't
I
it true that wring tbs course of the
i
2Z
·• .
onversation!with Ms. Liberi you entered into an

,
24 rom the $S.~OO?

25
A. I '.~d that t~e money cannot be any monies
26 ~X':ived f-t"Qmlill gatt'en gains.

27
'MRI SECORD, If I may, your lIonor, this is

28 ~ethin9 th~t bas recently come ,neo my possession. It

 lC121/2010 i3 49 S4S7B87S0S ORlvr':'!Tl #0829 P _038/058
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 36 of 58
10/0S/2010 15:3Q 84 t861e03 {)Rllfi"nz .011$ ".OlO/918

,
,

1
!
s _ tape re10rding of a jail call between the bail
i
J ndsman andl~$. Liberi and her husband that I would
I

)
ike to plaY~for Mr. Mebr ~o refreshe his recolleQtion
I .
• oncerning t~~ phone call that
i
he had .
5 MRi, PAAL:
. Your Honor. I'll Qbj.~t~ If
,
G o~nsel has ~hatr thi~ i$ trial by ambush. That wa~ a
I
ong time a9~.
7

6 lea of prop.~
,
If he haa • tape like that, there are
responsibility that you give to
I
9 pposing ccurtsel, buc sdt.t1ng here just . pull ing a taJ?"e~
,,
10 hat'. not ~ne today, that type of practice. Just
11 tape rirom yg~~ pocket and say here's a tcpe.
12 ets ~ot n;wI lawyers praetice~

13 TH, COURT: Mr. Secord~ first of all l I

14 lnderstand t~.t if this is played. there's no way my
,,
15 ..n report* c..n take this down.
I
16 K1U SllC¢lUl: vmierstooo z your Honor~
,I
17 'I'll"! COl,JRT, All right. And if you want it to
,

l' ~ ~~t ~f the record, you're goiuS to hav. to

i
l~ Qduce A ~e~itied transcript of that recording.
i
20 Do !you unde&5tand that?
!
21 I!!R j SBCORD: Yes, I do, yo~ Konor~

22 'l'II>I (;OIlRT, With th.t underBtanding~ t want

i~ t.o. respo~ to' his objeotio:n~

24
I
MR41 SECORD; Your Honor, this is
,
ro•• -exa.'~tion.
25
, Thi$ ia also a chance for me to
2~ ...,h the witnese. ! do-nit have to give hi..
~1 ,
ac::unattt rtiat-erial
,
<Ahead of time.
28 Ml.l FAAL: Your lIonor _. ,

~
..... "'_._,.."'''' ,j
10/21/2010 13.50 B4B7BB?BOS ORLV;,HTZ ;1'0229 P. 0371<)58
Case 2:09-cv-01898-ER
, Document 147 Filed 10/21/10 Page 37 of 58
. 10/(1$12(110 15.31 $1•• 1881603 Qm,VTAITl lOTiO f'.0"'!1018

08
1 MR~
, SSCORD! And this is al~o not trial~
2 his is a bail hea:ring. D1eeoveJ:Y in a criminal matter
3 a gove.ued ~ 9tatut~ and by statute ¢nly and thi$ is
4 n regards t~ w~t h~s to be disclosed 30 days before
I
5 r141 and w&!are rtot there yet.
I
6 MR~, PAALt Your Honor, I have a problem with
,
7 hat~ ,
You are not allowed tQ set a witness up just for
S he purpoa. ?f impeaching the witneeA. The Court ~~y

9­ ,hiftk that'sinot what's happening hex-e_ That~s what's

I .
.10 the ias:uQ hare i:iiJ if Mr ~ SJ!:!cor<i has
11 v~d.nc~ that the money is being diegui&ed. he bas
I ..
12 ry right ~o briug that evidence! but that's not the
13 ,oundatiQll I!had.
14 Thk foundation I had w.s about so~ possible
~5 scuss10n ~ut th.t »eing done~ t~t is d1sguiaing
16 he ~n~, b~t he's not making any offer ¢f proof ~hat
1
17 ·be money wa~ actually b91ng disguised 80 because of

16 n-t hela attempting to ~~trod~ce m«terial thac has no

i
19 eg1timate p+TPQ*e other than to prejudice the Court or
,
20 1..,,&.. bias w~en. in fact, it doesn't go to the CQre

,
22 Tb~, core issue is dQes be: have proof that the
23 ney from tie
, e:rwit:
. card i!\l molUlry time i.n illegally
24 btained? If, the answer is yes. bring" that eviden~e.
lS f ~he anQvsr, is nO I end of story on that. ~his ia a
26 ide show.
27 ~ COURT: All righe. Mr. Seco.d, the tape
U 8 , u • .o for impeachment purposes?
going to ~
10/21/201C 13 50 SA97eS7eOS O~lVTAnz #OB23 P C3B/058
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 38 of 58
..VlfV f'."''::IVI'J

99
1 MIt; SECORD: Yes, your Honor.
2 THt COURT! NQt for reQQllection or
~ efreahing h~. memory?
4 JllRt SECORD; Yes, your Honor.
S ~ COli'R'P1 All 'f'ight. I ' l l allow it.
I,
MRi SHeORD, Thank you, your Honor~
i
(wleraupon
, th. audio tape vas pl.yQd and not

•
nl~rt.ed. )

9 Q. RY!MR. SECORD! Now sir, I ask you again. did

10 ou have a e~uversation the ~ven(ng of ~Jly 28th with
,
11 Q. Licari w~Q~a YQU agreed wihh M~. Liberi that you
,
12 Id rebatel$B~OOO back to h.r mom~a creQjt card b¥
11 sing Miche1~e Strickland's tru.t accOunt?
14 A. No~ , 110, not at all.
Mltl!
FAAI., Your Hono't", I Qbjeet. That IS IlOt
~hllt
, . ,,"
nJ
I

COURT, He said no.

l8 MRl,
FAAL, Thatllt you.

19 Q. BYI MR .. SBCOltD: Do you is it your

20
!
that this ie not you in this tape?
,
21 A. That is me, bu~ I think you~re taking iL out
,

22 f c:ontext~ ;

, 1

23 Ohi

,
24 A. Yoil"re
, taking are you talking about the -­
,
O. I -I uet happen
i
A. ,
~ you saying th.t ~­
27
Q.' .-~I just happen to have the entire tape~
I,
28
Quld you li~e
, me to play it so it is in cont.~t~ sir?
10/2'/2010 '3.50 9497367803 tJRL VTfllTZ #08'28 ~ 039/056
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 39 of 58
tO/OS/~010 t5:31 $4 lGsre03 t'latYTAlT.z UHO P.o13/t)lB
1
100
1 A. A:r~ you sayirtg that. I am dOing it for less

2 I don't
3
4 Q. Ll~ trying to find out ~hAt you ~$ally ~act
S thi3~ Prom what ~hi. tape said r if ! understAnd you
6 orrectly• • ~r. you were going to GenQ $6.000 bAck ;Q
i iChella Str~cklandls trust account to repay the ~6,aQO

a hat was coming from the crQdit card; isntt that

9' r::roct?

10
A. That iB not oorrect.

11
Q. NO~. with respect to ~his ~- with respect ~o

13
,. ur Ro,pt"')r. ,

15 T1!1! COURT, 1'1... Paal.

t :

: .seiQns.
,

,
MK
~
FAAL, Your acnot', nothing. No

18 , TIlE COURT: NQ questions?

,
!4l>1 PUL, No, based on the testimony that

21 Yotr Honor, just for the reCQrd~ tIm sorry.

I
22
23 , REDIRECT EXAMINATION
24
25
~,

27
t
i

nou would
i
MR. FAAL::

0+

A,
.bitil 1611 t.ell

hi~e

No:
)1:$.

the souroe of the

:Uibe.1:i o;c: .nyana ale. that.

$8.000~

28 O~ay. Did you Qr have you ~one anything to

10/2i/Z01C
10)0$/2010
13.50 9491SS7B03
Case
15:31
2:09-cv-01898-ER Document
9411SG18&~
ORL HAUZ
147 Filed 10/21/10 Page 40
OglY!AfTl
#CS29 P C40/C5S
of 58
f0110 1'_&14/(\18
,

1 ide the SQurce of the $S.OOO?

2
A. NO~ and I will add when she t.lked about thi~

3 rust fund, i had asked her where the monieG were

" rrtvi,ng- frOin. and I never got - - 1 didn' t kllo"" it. was
5 ue to this loan in th. ~.~$t. I t.ied to que~tion

5 hat. Than I _aid itls e.s1er thaq takiAg th~ trust

7 or the $8.000 -- and I said it would be eaaier to USe

a t on a credi~ card with the mom or howev~r.

, Me, decided to do it that: way and there was no

10 efund of tbA~ $8~OOO back to tho tru~t. They were
11 o1ng to t.a:k~ -.- it WiiLS going to be done through the
.
12 ru$tt ~he $~,OOO o~iginal1y~ but it was easier to cake
13 he $8.000 tor the $100.000 bond and then take the
14 ifference of the truet to make up the difference ~t

15 hat time.

16 So;wben o.iqinally I wa. called on it. it w~s

17 100AOOO 127~ &0 it was easier to do it with a cr~dit

18 ~ than that l so it Wile. just making the money from

19 he tru3t f~d or doing it through the credit eard and
20 t turnea out to be a combination of both because 1 was
21 ~;i.Dg to allOw _... when I met with Hr ~ Sacor4 and

22 I"q,lained everything to hi.., he didn' t • • •"," offi"..

33 ~s ,oin, to.allow paymentB for up to ~ year~ Be did
24 L·t
~I want us to do that. So we end9d up having to go
2i 8.000 on th. credit card, and tben the t~st. ~nd th~

reaehed out·~o her father, bioiog1eal father for th.

, i
, '. , j:her
,
$6,000.

i o. Okay. Now, wh.n you agreed w.th Ms. Liber.

 10/2~/2310 "3.50 8491687;03 :JRlVH:TZ 10828 'J 011/059
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 41 of 58
10JOS/201Q 15"31 at 16S1G~3 U'Hl YfAlTl 11)710 P.t"5/t113

1 !nd h4;!r lOOt-het thtolt you would .oe pa1d with a credit

a ~rd tor $S~~OOI you did disoloae tbat to Mr. Secord~

3 1<1 :lOu not? :

t A. I disclosed every documents Gveryehing that

5 a. going on.:
6 Q. Th~ documents that you reo9ived from Michelle
7 ,t:rickland'e ;~ffice about the funding the loan that; Ms.
8 ~beri obtainea ~gainet her civil case. the ~dVance,

9 'm ~orry. the $dvance~ you .1so provided those

10 ~euments to :Mr# SecorQ# did you not?

11 A. Yes, I did.

13 14ft.: Flun, , Ok.ay. Thallk you.

13

14 RBCROBS-BXAMINATION

1.5 l! MR. SECOR!?,

16 Q. Isn't it true that you also disclosed ;~t

11 big money in Ma, Strictlandts trust account was

18 , r1g1nally p~rt of a tru.t ~n favor of the defendant's
19 ~~h&"1
20
21 ,bought that :this money was eoming from A truet where
22 he money ha~ been placed in Ms# stricklaftd*s account
:1.1 !y the defendantta mQther?
24 A. Y.ah, that was the confusion~ r did noe kn¢~

~5 t was dealing with the loan from thig eorporation~ I

-. 2' bought it _as • f.afly -­ wh$~ I first got this call.

27 thQught it ;was a family pool ot money to obtain a

28 ivil attorney.

10/21/2010 13 50 $437637603 ORLViAITZ .0823 P 042/058

Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 42 of 58
10/0$11010 1531 S4 TB81i~9 ORlvrAIn .0170 p.o1S/01$

1 MR. SECORD; Move to strike eve4Ything

2 after yes.

3
THE COURT, Grant.d.

4
Q. B~ MR. SECORD 1 SQ at enie point~ if I

5
unde'l"lu".l'lnd ~t C'o.1:TfH":t:1Yt tnere: .-4'. now at le~st two

diffe~&nt ~lanation.
, . tor wh~xe this rnon~y oue of
7 Mg~ Strickl~d's account i9 Comifig; is Chat CQrrect?
~. FAAL: Your Honor,' that t_s argUMent9tive.

16 T.SE COURT: It is somewh~t but 1"11 al19w it.

11 .~ ah....d.

12 THE WITNBSS; I never got a ¢lear anSwer

13 ~rom her hu~and Brent where the money was c~ing from.

14 I did nQt kdo. where the mQnies came from. I thought

1.5 p.t was part ~-- like! said.. part of a family pool that
l' pbtained the, civil attorney for her civil matt~~.

17 MR. SSCORD: Nothing further.

18
it : FURTHER RIIDlRller IDIAHI;HATIOII

20 FAAL;:

21 D~~ y~ ti~d out whethe~ 'Qr not Ms. Liberi'~

22 rotb~r waH ~so a client of M~. Strickland?
23 A~ N~.

24 Q. OtJ;, you didntt. Okay.

25 MI(. FAAL, Thank you. Nothing further.
26 T~ COURT. Thank ,you.

27, Ml4 SEeOl!!)' Nothing further.

.
28 MR;. l'AAL: Your Bonor < [ would like at this
;0/21/2010 13:50 9497687803 Cill 'frAITZ J01:l2(l P 043/05B
iO/O¥/~Q19
Case 2:09-cv-01898-ER Document
lS'Sl S4 r6S1G~3
147 Filed 10/21/10 Page 43
ORlVTAITZ of 58
IVlnl r.VIIIVlts

1Q4
1 oint in t1~ Mr. Secor4 to maybe assure me on the
2 cord that ~ telephone conversations with Ms~ Liberi
3 .re not a180 recorded.
4 MR. SECORD: Your Honor, what I can assure io
5 11 calls __ i as I understand it, .11 calls in and out
,. f ~he jail ~re reeorded. What I ~an assure counsel i~

7 b.~ ~hose ~11* which has his number and ehose calls
$ h~re hQ he WAS tbre.~wayed iute ~he CQn~r8A~ion have
9 t, by mysetf or to my knowlgdge by any other perso~

10 n the D.A_·s office t been li.ten~ to_ That w.~ a

11 reposition ~ndin9 thers. lIm sorry. HAve not been
l2 e have not listened to them.
13 MR'. I'AAL, Thank yo".
14 THE COURT: All right. Anything further?
15 MR~ SECORO: Yes, your Honor. I would call
16 n~sti98tor:ThQ~s Rice.
11 Your Honor* this ia th$ ~$cording that was
18 ust played ~nd we could lodge it wich the Court at
19 his time or; would the Court prefer that I make d
20 ertified tranacript of it and lOdge it with the Court
21 ater?
22 TIm COURT, Mr. Faal.
I
••
24
l" these
MIL VAAU,
p:r;QCe-edi.ngs~
Your Honor r

I be:lleve that:.
since it's being used
I'm etttit.lad to

25 th the tap~ a.nd the transcript.

:26 MR; SECORDt I will mak~ ~ copy Of both the
27 ape and the:transerlpt and forward a eopy to counsel
29 ~n4 lQ4ge both ~ith thQ CQurt within a week.
 lO/21/2C10 lJ:5~ 949 687903

7
OR:... 'ITA::: Tl 10/21/10 Page 44 of 58
Case 2:09-cv-01898-ER Document 147 Filed #0829 P. 044/058
lO/08!2{l10 15:31 8.~ren&(l3
, O:RLVTAITl ,ono f'.QHII018

...-!-----...+J,- - - - - - - - - - ' - - - - - - ,
105

1
~ COURT: And make Bure you send .. copy to

ouneel~

3
Yes.

4
~ COURT: OkaYT Thank YO,l.
5
TliOMAS RICE,
i

.a~led as ~ ,1
,, tneas
7
nd testifie? as follow$;:

8
THt, C~ERK; Do you solemnly stat. ~hat the

,
t
iden.ce YQUlare about: to give in this matte~' now
,
10
ding befote this COUIt shall be the truth. the whole
11
ruth, and n~th1n9
, hut the truth~ so help you God?
12
~i WlTNESS, 1 do.

I. tu, CLERK; Thank you. Please have a seat.

14

15

I Pl~ase st~te your full name and spell your

!
ir6\; and laTt name. for the reoord.
16
I ,
TH* WITNESS: 'thomas Rice* T~h-o~m~a"'liJt
17
-i-C'-e~

18

,
THII COURT. <l<> ..!lead.
19
MIt i Sl?CQRO; Thank rOll f your :Honor.
r.
20

21
DIRECT BXAMINATION

23
O. Mrl Rice# with wnom are y~u employed?
I

24
A. california DQpartment of lnsux.ance
I

nvestigatio~ div1sion.
I-- Q. 1n !... Mt capacity?
27
A. 11* anI

invastigato~~

2S
Q. An1 specifically do you hav$ any particu13r
 ORL VTAITZ
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 45 of 58
11'0829 p 04:5/059

GriyT.E
A"""""Y I'n> &A"""""Y
_ ... F"""","",.

-­

.1'0._0
:191139­ • Parlovoy, Saito 100
CA~U!l8
Tell~) 11;)'u (949) 166-768i1
E~MalI'4r_ ytd>oo.eom

IN THE UNITED STATES DISTRICT OOlJRT

FOR THE EASTERN mSTRICT OF PENNSYLVANlA

,
USA LIBE ,et oL, ) C"""II89-1S9S HOD Eduard& Robnoo prt:Siding
) Rl>pIy to lo.o7.HI motion by the Plaiulifllo
) _ant'. "",1leIIt1\)' lIle ....rt to _!U' luh_ pow...
to_lIle~
) Alto....")' PIIiIip J.Berg _ WI...... Sh;,tey Waddell for
.1'-­ ) ~ ads offraed .... the _ r i - perjll'Y
)
v. ) lIeqllellt w e:tpedIte produetloo ofLisa Libori'.
I P-.ylvaaia driv<!t'I L~ aIIepcIIy provided W court
) dmiJ!g the emergen,,), hea~ OIl 08#7.09.
)
)

RespoJJSeJ Plaintiff's 10.07.10 motion IIlId simulta"""us ""1- for this

court 1<> im Inbereat powers saaetion Plaintiff's Attonley Philip Bel"ll lOr

repeated t· offraad 011 the ..,art aad perjllry and ""I-t 1<> expedite

prodllCUo of Liberi'. PAdriv.er's!lee...."

This case i filed by plaintiffs on May 04., 2009. The case is fur defamatioo of

character. re essenre of the case is the sworn statement hy the Plaintiff Lisa
Liberi and co-plaintiff and attorney Philip J Berg, claiming that Lib<:ri is an

et al v Taitz et aI. Dererulants response to motion. Defundants d<mand for sanctions

against l'IainIiffS, witness Shirley Wadden and Anomey l'b.ilip J. Berg 1
10/21/2010 13'51 8497867603 3RLV~AITZ
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 46 of 58

innocent w residing in PA and physically working as a pamlegal for attomey

Philip I. and she WllS defumed, when Taitt published on ber web site a

transcript otlcriminal record ofLiberi, assistant of Berg, showing her being

convicted 0 multiple counts of:tbrgery ofdocuments and grand theft. Liberi and

Berg ~:!IWJ'rn¥ that Lisa Liberl is a different person, not one QQnvicted in CA. On
I
06.04.1O!hi court assumed juri.sdiction based on <Ii versity and included in its'

memorand a statement "Liberi is a resident ofPA". Taitt filed a m(}tion 10

dismiss due to lack ofevidence ofLiberi's state residence, necessary for this court

to asswne j ·sdiction in diversity. Berg and Liberi responded by filing 07.10.10

pleadings, t- they claimed that during 08.07.09 hearing they provided this

court with 'i1>eri,g drivers license, and based on that drivers license this court

issued a stal$mant in its memorandum, thet "Liberi i. a resident (}f Pensylvania"

Taitz~ded 10 see Libert's PA driver license. Libert and Berg without a shred
of evidenC~ made up a malicious and higWy defilmatory and slanderous accusation.
:

stating that /Liberi believes that attorney Taitz tried to biro a hit man to kill Li1>eri,

and for thaJ reason her PA drivers license needs 10 be kept sealed and this court is

supposed J lISSI.IIlW jurisdiction in diversity without any evidence ofLiberi'. state

residency.

Li et aI v Taitt, et aI. Do!i:udontS response to n><>tion. IJei\mdants det!lJlll<l fur sanctio,,"

agalmt PJaintiffil. wlbless Shirley Waddell and Attomey Philip 1. Berg 2
10/21/2010 13 5\ 9497067303 OR i...VTA FZ 10/21/10 Page 47 of 58
Case 2:09-cv-01898-ER
,
,
Document 147 Filed

Taitz is sub 'tting to this court an Exhibit l-Liberi's mug shot and an e-mail from

San Bernard no County, Ca assistant District Attorney James, Secotd, attesting that

this is a m shot ofLisa Liberi, convicted in CA.

Exhibit 2 davit of Ed Hale, and Exhibit 3 Affidavit of Canln Hale attesting to

e same mug shot is a mug .mot ofLisa Liberi, who appeared during

August 7,2,10 hearing in Liberi et v Taitz et aJ in PA, where severnl observers

I

were ~ where she claimed that .me was an innocent woman residing in PA,

not Li~.~ir who was convicted in CA, who was slandered and who is afraid
for bet life. '
i
The same davit slStes, !bat during the bearing IlD drivers license. nor any other

given by Liberi or any other Plaintiff or Attorney Berg to judge

Robreno. I
Exhibit 4 Ajudavit ofOrIy Taitz, declaring under penalty of pe1jury, that she did
hire any bit men, she did not attempt to hire any hit men to kill Lisa Liberi, she did

not commit any o!bllt crimes. she is being accused of.

,
Exhibit 5 SWorn and notarized affidavit ofLinda Belcher. assistant for Philip Berg,

declaring t .me did not commit any crimes, she was accused of by Liberi and

Berg. Dele er reiterated that she was on the phone and personally heard Liberi

coaching ~ to accuse innocent people ofcrimes and telliug that she did it

before.

Ubi:: . ct al v Taitz et al. Defendants response I() motion. Defendants demand for sanctions
against Plaintiffs, witness Sbirley Waddell and AIIomey Philip J. Berg 3
'0!2~/2010 lS'51 9491697603 OQLVTAlTl
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 48 of 58
It0828 P.043/05R

Uberi's er, Shirley Waddell has submitted to thi. oourt numerous affidavits,

her daughter was innocent and slandered, when h<1>r CA conviction

Taitz is pro~ding this court with Exhibit #6, copy of tbe trnnscrlpt from CA

Superior cob. case FSB-044914. This tranSCript shows, that Libert's mQther not
only knew, ~et her daughter committed crimes and ~1!S incarcereted in CA, she
I
was the one 'who paid the ree foc the bail1x>ruI in order to bail her daughter from

jail.

While none ,~f the defendants have any criminal records, Liberi is .. career criminal
,
,
with at 1 42 criminal charges and at least 10 criminal convictions offurgery and

theft. Plaint fr s accusations are nothing but malicious slander, brought forw..ro to

cover up fo the fact thet Attorney Philip J Berg is indeed employing a convicted

document lrgery liS his paralegal, and according to his own admission, she was

the one, w drafted multiple pleadings.. including pleadings in Berg v 01:>ama.

They are Jo committing fraud on the court and peljury

, to CQver up fur the filet.

that attorne' Berg is aiding and libeling a convicted felon 00 probation to violate

terms ofh probation. Defendants are asking this court to use it's inherent powers

to sanction,, laintiffs, witness Shirley Waddell and attorney Philip J. Berg

$200,000 e •mated in time and expenses in defending this case brought for

improper p'prpcose to defraud the court.

Ll1' et aI v 1aitz et aI. Defendants respome to motion. DofendanlS demand fur ,",,"'Ii.,..
"¥"ins! Plaintiffs, "itness Shirley Waddell and Attom<y Philip}. Berg 4
10/21/2010 '3.51 94r
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 49 of 58

'hieb jurisdiction is based on diversity of citi:reoship, plaintiff has

burden to. W, first, that applicable statute coofer.; jurisdiction, and, second, that

assertion of urisdictiOil is consonant with constitutional limitations ofdue

process. Iv. ght v KawasakiMQtQrs Corp. (1985, ED Va) 604 F Supp 968.

Party'~ m allegation of diver.;ity carmot satisfy its burden of establishing district

court's j . .ction; citizenship of eacb real party in interest must be <:litablished by

prejpoodenujce of evidence. Roche" LincQI1'l,Pr'lTJ, Co. aQQ4. C44 Va) 373 I'M

Complaint eging that defendant's COIpOOlte citizeuship was in a state other than

California fu.iling to allege that plaintiffs were all citizens ofCalifornia was not

sufficient give District Court jurisdiction since plea<lings did not otberwise

resolve

,
issue of citiZenship. Bautista v PanAmgicqn World Airlines. Inc. (1987, C49 Cal)

8]8 FZd 5 126 RNA LRRM 2559 107 CCH P 10159.

Court l~ jurisdiction over patienfs claims bccalll!e he flIiled to establish

diversity j . .ction because at tillle he filed complaint both he <md hospice were

Li . et al v Taitt et al. Defi:ndants response III motion. Defendalli:;. demand for sanctions
against Plainti.tlil" _ Shirley Waddell and Attorney Philip 1. Berg 5
~0/21/2010 13,5~ 9497SS7BC3 OR:..VTAI'!'Z
Case 2:09-cv-01898-ER
,
,
Document 147 Filed 10/21/10 Page 50 of 58
IIJB29 P (lSO/05B

citizens of S ; also patient only sought $ 10,000 in cost and W1SpC'Cified "",<>nOt

for other dalnages, which did not meet !UlIOWlt in controversy. Otsw v Qualit)(

con~~nc. (2004.IXNM) 380 F SI!DR2ri 1225.

,

c<:>mplaint ainst John Doe defendant alleging Internet defamation was dismissed

for lack of liject matter jurisdiction because there was risk that if John Doe's

discovered there could have ,been no diversity, and court's

jurisdictiQ 1 aufuority would have di~ court declined to read amended

language of 28 uses 1441

in/(} 28.M$lLill:l1 because it would have accomplished much broader result of

with only one party and only state law claims to proceed initially in

federal . McMann" Doe (2OW.IX MlM$)46() E.Supp 2d

In motorist' personal inju:ry lawsuit agajnst, inter alia, owners of property adjacent

to private rtilroad-trnclc crossing where cat-train accidcul occurred, ptlI'SUlU1t to 28

uses I 4.lidl.. appellate comt lacked jurisdiction to review remand that

implicitly based on lack of subject matter jurisdiction; district coun clearly

was addreS$ingjutlsdictional issues--diversity of citizenship, 28"USJ,.'S § 1332, and

I

fraudnient inder-and when doing

et oj" Taitt '" aI. Defendantsresporu;c tllmoUon. DefimdJmts demand for sanc1ions
again.... PlaintiJlS, witness Shirley Wad<leIl and Attomey Philip 1. Il«g 6
10/21/2010 ~3 52 S4~
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 51 of 58

so, it Iy declined to decide doubtful question of _ law and, instead,

iguity (lack of _law directly on point) in motorist's fiivor. Filla v

R 3 CAS Yo) 336 F3d 806.

creams doubt as w jurisdiction, trial court must determine whether

there are equate grounds to sustain its jurisdictioo over subject matter.

n tries nco v Ii rata 1964, Cd;! NJ) 3.38 F2d 449. 9 FR Serv 2d

Court has to look to its own jurisdiction and lack of subject matter jurisdiction

may be _okt,ld by court, sua spoote, at any time. Jeter J(.T11'II Walter Homes. Inc.

klaL 414 FSum 79US,9. decided by a preponder;an"" of eviden"".

Plaintiffs ,d not pIl'Se!1t any evidence, not a shred of evidence, showing Liberi to

of PA. Defendants have shown that according to her probation she

y in CA or NM, she is subject to the jurisdiotion of CA, therefure the

case at has to be dismissed as Citizenship of Liberi was not provided to

resolve the issue of diversity to allow it to proceed in Federal court. Defendants

have I t ' to gel a copy of such PA license, as it is maJ:erial in this case. Jfindeed

Liberi did not produce a PA drivers license or produced a forged PA drivers

Li et al v Tait:l et.1. Derendants response to ooooon. Defendants demand fur sanctions
agaiost Plaiotilfs, witness Shirley Waddell and Attorney Philip J Berg 1
10/21/2010 13:52 948'881603 Ofll vr;or fZ ItOS29 p.C52{05S
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 52 of 58

this court made an error of filet, it had no jurisdiction and the case has

due to lack ofjurisdiction. Decision lllfl& based on fraud is a valid

B reconsidemtion. All of Libert's allegations, that her license is

supposed to be soa1ed due to the filet that she is being threatened are not based on

any fuets, not base on any evidence, plaintiff provided nothing except slander,

defumation f c:b.aracter and insane tall tales. Liberi claims, that Taitz boxed her in.

In reality . did not box her in, Liberi's own lies caught up with her. If she

refuses to ovide her license, the case needs to be dismissed as the court has no

sit in div...-sity without proof of citizenship. If she produces a valid

license, it ill show her residing in CA or NM and will show that she is indeed the
i
same Lisa ,/..iberi, who committed 10 counts of forgety and fraud in CA and

allowed to reside only in ea or NM under the supervision of the probation

department It will show the court that the whole case fur slander and defumation,

that she by claiming to be resident of PA and an innocent vietbn of slander, is

frivolous d represents fraud on the court, which would be grounds for the

di.missal 0 the case and sanctions _inst the plaintiffS and their attorney Berg fur

the egregi fraud on the <;QUrt. As of today the documents on the docket, that

were provi ed to the defendants and to the Third Circuit Court of Appeals as a

certified ket, :show zero evidence ofany current threats to Liberi from either the

defendants or her ex lmsband or her ex boyfriend. On the contnuy, a letter from

Li . et at v Taitz et at. Defundants response to motion. Defendants demand fur san<;\WlIS

against PlaintiJIii, witness Shirley WarlrleIl and Atwmey Philip J. Berg 8
'0/21/2010 13 52 9.9~631G03 GRl 'HAITi
Case 2:09-cv-01898-ER Document 147 #0829 P,l)53/C5B
Filed 10/21/10 Page 53 of 58

web i Jooff Staples and IeI.tenI and affidavits from volunl_ political
,

researcher rlitlda Belcher, who knew Berg for over 10 years, show that Liberi was

engaged in .olation of the terms of her probation by handling credit card numbers

of others, t Attorney Berg knew about it and filed this legal actioo with the goal

ofharassin the whistle blowers and by fraudulently stating that Uberi is a resident

of PA and not the same Liberi, who was convicted in CA and currently on

probation. n defendants demanded proof of this alleg.ation, Berg and Liberi

committed . fraud on the oourt by claiming that Liberi's PA drivers license is

supposed be sealed, because she is in fear of her life and by falsely accusing

defendants of crimes or intent to commit crimes. Without any shred of evidcnee.

i
they falsel i accused of multiple crimes a number of individuals; Desert Storm

veteran, m er and wife Pamela Barnett, Licensed investigator Sankey, veteran

and retired . eer Neil Turner, retired engineer NOOIllIll Murray and Taitz, who

attomey and licensed doctor of Dental Surgery. Neill"'r one of these

committed any crimes. It is beyond egregious fraud on the court, it

is II depravk heart criminal behavior , for a licensc4 attorney Berg to make such
,

outrageous accusations of anempts to bite a hit man, kidnap children, wurder fur

hire witho any shred of evidence, with the only goal to cover up his pri .....

criminal vior of aiding and abetting a felon on probation, Lisa Liberi, to

violate of her probation. This type of behavior is beyond sanctionable, it is II

Libo . et al v Taitz et aI. Deleodants response to motion. Defendant$ <iMltuld for sonction.s
against I'laintiffu, witness Shirley Wadden and Attoml:y l'bilip J. Berg 9
10/21/201C 12:52 8497£87£03 oiU 'iT III TZ ~oe28 P 054/058
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 54 of 58

type ofbeh .or, that is grounds fur disbarment and criminal prosecutiml.

Is move this court to grant their motion and provide to !be

d include in !be record on appeal to be forwarded to the Third

Circuit Co of Appeals (case 1110-3000) PlaintiffLJsa LJberl's PA drivers

ch was sllegedly submitted to this court by LJberi's attorney Philip

t
the 08.07.09 motion hearing. but was not included in the transcript,

and which th~ basis ofthis court's decision to deny the Defendant's motion to
dismiss this., case due to lack ofjwisdiction and to include in !be 06.04.10 order a

finding "Liberl is a resident of PA"

'WIll licen.'ie for Liberi is available, Defendants are moving thls court

to dismiss qurrent action 09-1898 Liberi et ..1v Taitz et sl due to lack of

jurisdiction due to !be fact that Liberi never provided proof ofher PA residence,

and withe proofof state resideoc" no federal district court can assert diversity

jurisdiction

3. Defen Is request sanctions and damages in the amount of $200,000 awarded

to them du to egregious fraud on the court by the Plaintiffs and their attorney

Philip J. Jg ,
I,

Libe etal v Tailz ctal. Defendants response to motion. DeJi:ndantg demand fur sonctions
against Plaintiffs. witness Shirley Waddell and Att\'J!'lley Philip J. Berg 10
10/21/2010 13.52 2:09-cv-01898-ER
Case 949r Document 147 Filed 10/21/10 Page 55 of 58

lsi Dr. Or! Talrz, ESQ~

_____

07.28.10.

er penalty of peIjury, that 1 served above ple<t!llngs on full owing

oritiell:

Philip Berg i,
555 Andoni Glen Court, sle 12
Lafayette HjnPA 19444-2531

NeilS~
2470 ' str #162
Simi Valle CA 93063
Linda Belc
201 Paris
Castroville 78009

Pbi!adelphi~ District Attorneys' office

3 South P square
Philadelphi PA

US Attu ' office

Eastern Dil/trict ofM
615 Chestrlut str, ste 1250
Philadel . PA 19106-4100

Social Sec 'ty Administration

6401 Secu Blvd

e1 at v Taitt e1 aI. Defendants r _ to motion. Defundants demmd for .....mUllS

against plaintiffs, witness Shirley Wadddl and Attol'l"'Y Philip J. Bct:g 11
10/21/201C 13.52 8491887602 DflL \'T AITZ #0928 P,058/058
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 56 of 58

AudreyB.
ChiefJudge
US District t::otnt
411 W. F str
Santa Ana CA 92701
i
Judge Dav; , O. Carter
USDC District of CA
411 west F urth Str
SantaAna A 92701

Public 'ty Section

l)epanInentofJustice
950 Pe vania Ave, NW
Washingtnn DC 20530-0001
!

, United Nations High Commissioner for Human Rights (OHCHR)

" ~~~rteur OIl the Situation ofHuman Rights Defenders
01 Ie Mrs. Margaret Sekaggya
atioos
eva 10, Switzerland
Criminal bar Hague

al v Taitt et aI. De1imda:n1S response to motion. De1imdaa1s 00:aWld for sanctions

against Plaintif!ls. witness Shirley Waddell and Attorney Philip J. Berg 12
10/21/2010 13_52 949;
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 57 of 58

latjoJllS Commission for

Defenders

(Ms)

Human Ri 1;$ Officer

Civil and p Utica! Rights Section
Special Division
Office of High Commissioner fur Human Rights
tel:+4129179151
email:otol
IslOrlyTa
07.28.10.

Lawoffi of
Dr. Orly T .tz, ESQ
29839 San.or Defend
Pro se and
Margarita CA 92688
Our Freedoms Foundation

UNITED STATES DISTRICT

FOR THE EASTERN DISTRICT OF PENNSYLVAN!A

Lisa Li . et al ) Case # 09-cv"()1898-ECR

Plaintiffs ) Assigned to Honotllble Eduardo C.

Robreno

V )

al )

Li .. aI v Taitz et 01. DefOlldm!t9 ""'JlO1l5" to motion. Defendants demand fot $OllOIions

against plaintiffil. witness Sbidey Wadden and Attorney Philip I. Beti I,
10/21/20~O 19-59 9491GBIG03 IOS23 p, 05e/~5€
Case 2:09-cv-01898-ER Document 147 Filed 10/21/10 Page 58 of 58

Defendants

ORDER

i
AND NO",", this day of October 2010 after consideration of
i
Defendanl
motion-request for docwnents missing from August 7, 2009 transcript

and 60 B " On for Reconsideration ofthis coutts June 4 and July 13, 2010 otdet.
i
Defendant' 'Motion is granted. Plaintiffs 10,07.10 motion is denied.

Plaimiflil, 'tness Shirley Waddell and attorney fur pla.intiflS Philip J Berg is

otdeted to w cause, why they should no! be sanctioned for repeated acts of

perjury, fi:a on this court as well as on the Third Circuit Court ofAppeals and for

filing a . , OIlS legal action not based on fact and law.

IT IS SO obERED
,i

Eduardo C. bmw. J

Liberl at v Tai12 et at Defendants _ _ to motioll. Dei!o!dants demand fur sanctions

against Plaintiffs, witness Shirley Waddell and Attorney Philip 1. Berg 14