Case: 10-3000 Document: 003110424383 Page: 1 Date Filed: 02/01/2011

No. 10-3000

UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT

____________________

LISA LIBERI, et al.,

Plaintiffs-Appellees,

vs.

ORLY TAITZ, et al.,

Defendant-Appellants.
__________________

District Court No. 09_cv_01898_ECR

Eastern District of Pennsylvania
__________________

APPELLANT'S REQUEST FOR JUDICIAL NOTICE OF THE

OFFICIAL TRANSCRIPT OF THE 12.20 10 HEARING IN LIBERI V
TAITZ AND SUBSEQUENT ORDER DENYING APPELLEES'
PETITION FOR TRO, AS WELL AS JUDICIAL NOTICE OF THE
SUMMARY OF CRIMINAL CONVICTIONS IN THE STATE OF
CALIFORNIA OF THE APPELLEE LISA LIBERI, OFFICIAL
LETTER OF THE DISTRICT ATTORNEY OF SAN BERNARDINO
COUNTY, CALIFORNIA, ATTESTING TO LIBERI'S CURRENT
STATUS AS ONE ON PROBATION WITH SAN BERNARDINO, CA
PROBATIONS DEPARTMENT, RECORD OF 02.23.2011
DISCIPLINARY HEARING AGAINST PHILIP BERG

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DR. ORLY TAITZ, ESQ.

CSB #223433
Attorney Pro Se &
Attorney for Defend Our Freedoms Foundation
29839 S. Margarita Pkwy. Rancho Santa Margarita CA 92688
ph. 949-683-5411
fax 949-766-7603

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Appellants Dr. Orly Taitz ESQ and Defend Our Freedoms Foundation, hereinafter

"Appellants" respectfully request this honorable court to take judicial notice of the

following documents under Federal rule of Evidence 201.

1. Official transcript of the TRO hearing held on 12.20.10 by Judge Eduardo

Robreno in Liberi v Taitz, pursuant to Appellees' request for TRO. Exhibit 1

2. 12.23.10 Order by Judge Robreno denying Appellees' request for TRO against

the Appellants. Exhibit 2

3. Official transcript of Liberi's conviction and terms of probation, allowing her to

reside in CA or NM only, but not any other state Exhibit 3

4. OFFICIAL letter from San Bernardino Ca District Attorneys' office attesting to

the fact that the Appellee Lisa Liberi is still on probation under the supervision of

San Bernardino probation department. Exhibit 4

5. Pennsylvania Disciplinary Board 3 member panel disciplinary hearing against

attorney Berg scheduled for 02.23.2011 Exhibit 5

These documents are relevant to the determination of the current appeal for

following reasons:

A DURING THE 12.20.2010 PROCEDING IN LIBERI V TAITZ

APPELLEE/ PLAINTIFF LISA LIBERI ADMITTED UNDER PENALTY

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OF PERJURY THAT SHE IS INDEED A CONVICTED FELON,

CONVICTED IN THE STATE OF CALIFORNIA IN 2008 OF THEFT.

Above document was obtained recently from the court reporter. It is relevant to the

current Appeal. Appellants are stating that Judge Robreno has assumed jurisdiction

over this case in error, based on fraudulent statements by Appellee Lisa Liberi.

Judge Robreno erroneously decided that there is diversity in this case, stating in his

order that Liberi is a resident of PA. In her prior pleadings Liberi claimed that she

is not a convicted forger from CA, that she is a different person. She gave her

Attorney Philip J Berg's business address as her address and based on that he ruled

that she is a resident of PA and the case can proceed in diversity. During the

12.20.2010 hearing Liberi admitted that she is indeed a convicted felon from CA,

that she was convicted recently, in 2008. Taitz submitted a copy of Liberi's

criminal conviction and terms of probation, showing that she is not allowed to live

in any other state but CA or NM. As such, an order by Judge Robreno was made in

error. It needs to be reversed and the case needs to be dismissed due to lack of

jurisdiction. There is no documentary evidence of Liberi being the resident of PA.

B. Order by Judge Robreno, denying Appellee's request for TRO is relevant to the

Appeal for following reasons:

1. Judge Robreno states in the order that Liberi conceded to the fact that she indeed

is a convicted felon from Ca, that she was convicted in 2008 in Ca

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2. Appellees originally requested TRO hearing in the Third Circuit Court of

Appeals, whereby the Appellees accused Appellants of multiple crimes. Presiding

Judge Robreno found no evidence of any crimes and denied the TRO motion

3. Judge Robreno found Appellees Liberi, Ostella and Berg to be evasive and not

believable as witnesses, which goes to the credibility of their statements on

appeal.

C. Superior court of CA summary of convictions and conditions of probation of

felon Lisa Liberi, showing that she is not allowed to reside in any other state, but

CA and NM, is brought with a proper purpose of showing that coupled with

Liberi's admission, she cannot be a resident of PA and that District Judge Eduardo

Robreno assumed jurisdiction in diversity in error

D. Letter from the District Attorney of San Bernardino County, CA was brought

with the proper purpose of showing that Appellee Lisa Liberi is in fact still on

probation and under supervision of San Bernardino, CA probation department.

E. summary of the disciplinary hearing of Attorney Philip J Berg is brought with a

proper purpose of showing that attorney Berg is subject to Disciplinary hearing to

be held shortly on 02.23.2011 and it makes his further representation of the parties

in this case questionable.

F Appellant submits her affidavit, authenticating exhibits 1-5

SUMMARY

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Due to all of the above the Appellants request judicial notice of the above

documents.

/s/ Orly Taitz

Dr. Orly Taitz, ESQ Appellant pro se

and counsel for the Appellant "Defend Our freedoms Foundation"

01.30.2011

AFFIDAVIT OF ATTORNEY ORLY TAITZ

I, Orly Taitz, am an attorney representing appellants in the current appeal, I am

duly licensed with this court as well as the Supreme Court of CA, Supreme Court

of the United States and a number of other courts of Appeals.

I am over 18 years old, do not suffer from any mental impairment and have a

personal knowledge of the following:

1. Exhibit 1 is a true and correct copy of the transcript of the 12.20.2010 hearing in

Liberi v Taitz 09-1898 US DC EDP, which was e-mailed to me by the court

reporter.

2. Exhibit 2 is a true and correct copy of the order by judge Robreno in Liberi v

Taitz 09-1898 which was posted on the electronic docket and available on pacer.

3. Summary of the criminal convictions and conditions of probation of the

Appellee in this case Lisa Liberi is a true and correct copy of such summary posted

on the internet by the San Bernardino county, CA Superior Court.

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4. Letter of the District Attorney of the San Bernardino County Ca, attesting to

Liberi's current probation status is a true and correct copy of such letter sent to me

by mail and e-mail by the district Attorneys' office

5. PA Disciplinary board announcement of the disciplinary hearing for attorney

Philip J. Berg is a true and correct copy of such announcement posted on the web

site for the disciplinary board of PA.

I certify under penalty of perjury and under the laws of the state of CA that all

foregoing is true and correct.

Affiant further says not

Dr. Orly Taitz ESQ

/s/ Orly Taitz

01.30.2011

ATTORNEY’S CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above pleadings
was served by ECF on 01.31.2011 on the following parties:

Neil Sankey
The Sankey Firm, Inc. a/k/a The Sankey Firm
Sankey Investigations, Inc.
2470 Stearns Street #162
Simi Valley, CA 93063
Phone: (805) 520_3151and (818) 366_0919
Cell Phone: (818) 212_7615
FAX: (805) 520_5804 and (818) 366_1491
Email: nsankey@thesankeyfirm.com

Linda Sue Belcher

201 Paris

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Castroville, Texas 78009

Home Phone: (830) 538_6395
Cell Phone: (830) 931_1781
Email: Newwomensparty@aol.com and
Email: starrbuzz@sbcglobal.net

Ed Hale
Caren Hale
Plains Radio
KPRN
Bar H Farms
1401 Bowie Street
Wellington, Texas 79095
Phone: (806) 447_0010 and (806) 447_0270
Email: plains.radio@yahoo.com and
Email: barhfarms@gmail.com and ed@barhfarms.net

Philip Berg, Esq.

Lisa Liberi c/o Law Office of Philip Berg
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444_2531
(610) 825_3134
FAX (610) 834_7659
E_Mail: philjberg@gmail.com

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