Gmail - Plaintiffs Altemative Rule 26(f) Report Page 1 of4

Case 8:10-cv-01573-AG -PLA Document 42-1 Filed 02/15/11 Page 1 of 16 Page ID

#:1063

t** I$ Orly Taitz <orly.taitz@gmail.corn>

Plaintiffs Alternative Rule 26(f) Report

10 messages

Charles Lincoln <charles.lincoln@rocketmail.com> Mon, Feb 14,2AM at {2:26 AM

To: Jonathan Ross <jross@bglawyers. com>, orly. taitz@gmail. com
Cc: William Pallares <pallares@lbbslaw.com>, Bart Becker <BECKER@lbbslaw.com>, "Mark l. Melo"
<mmelo@bglawyers.com>, Arnold Levine <alevine@bglawyers.com>, philjberg@gmail.com, usjf@usjf.net

Dear Dr. Taitz & Messrs. Becker, Levine, Melo, Pallares, & Ross:
Because counsel Gary Kreep has appeared for me I have substantially
altered the Rrrle 26(f) Report and have prepared it to be submitted with
my counsel together as a "Plaintiff s Report" tomorrow.
Chcrles E. Lincoln, III
tktre zimpie
Tel: 5 72.968.25OO
Deo Vindice
"God be uith Uou,
and uith thg spirit!"

. .-. 1 0-cv{)1573-AG_LINCOLN_Plaintiffs_RULE_26{f}_Report_02-14-2011 .pdt

'-: 214K

Orly Taitz <orly-taiE@gmail.com> llJlon, Feb 14,2Afl at 1:{6 AM

To: Pamela Barnett <pb_realestate@yahoo.com>, Ken and Betsey Allen <kenandBetseyAllen@msn.com>
this was sent to me now by Creepy Kreep, Berg an Lincoln
Just a bunch of creeps

[QuoteC texi hiiicien]

Dr Orly TaiizESQ
29833 Santa Margarita pkrvy. ste -"100
Rancho Santa Margarita. CA 92688
ph 949-683-541'1 fax949-766-76C3
orlytaitzesq.com

; n| 0-cv{1
1 573-AG_LINCOLN_Plaintiff s_RULE 26(f)_Report_02-1 4-20{ 1 . pdf
214K

Orly Taitz <orly.taitz@gmail.com> Mon, Feb 14,2011at 1:51 AM

To:YosiTaitz-

https://mail.google.com/mall/?ui:2&ik:a3a25723cf&viewlt&search:inbox&th=12e234... 2ll5l20I1
 Case 8:10-cv-01573-AG -PLA Document 42-1 Filed 02/15/11 Page 2 of 16 Page ID
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1 Gary G. Kreep, Esq.

United States Justice Foundation
2
932D Street, Suite 2
3 Ramona, CA92065

4
Tel: 760-788-6624
Fax: 760-788-6414
J Email: usjf@usjf,net
Philip J. Berg, Esq. (subject to applicatiorrpro hae vice)
6
Law Offices of Philip J. Berg
7 555 Andora Glenn Court, Suite #12
Lafayette Hill, PA 19444-2531
8
Tel: (610) 825-3134
9 Emai : ph i lj b_er g(@, gmail. q onq
1

Attorneys for Plaintiff Charles Edward Lincoln, III

10

11
UNITED STATES DISTRICT COIJRT
t2 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
13

14
CHARLES EDWARD LINCOLN, III, CASE NO. 8: I 0-cv-01 573-AG-PLA
15
Plaintiff, RULE 26(f) Plaintiffs Report on
t6 Joint Scheduling Conference held by
t7 v. telephone on Thursday
February 3,2011
18
DAYLIGHT CHEMICAL
L9 INFORMATIO}{ SYSTEMS,
INCORPORATED, YOSEF T AITZ,
20 ORLY TALTZ, [NC., APPEALTNG
DENTISTRY, LAW OFFICE OF ORLY
21 TAITZ(RICO Entemrise), DR. ORLY
TAITZ: ESO.. D.D.S.. J.D.. DEFEND
22 OUR T'NAEDOVIS FOLTNDATION, ANd
all JOHN & JANE DOES l-10,
23
Defendants.
24
't<

26 PLAINTIFF'S REPORT OF FEBRUARY 3,2011,26(f) CONFERENCE

27 Pursuant to Federal Rules of Civil Procedure 26(f), as modified by Local

28 Rule 26-1 and this Court's Order Setting Rule 16(b) Scheduling Conference, the
IEwr CASE NO. CV10-01573-AG (PLAx)
BRISBOI RULE 26(0 PLAINTIFF'S
s REPORT
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1 Plaintiff hereby submits his report of the early meeting of counsel, conducted by
2 telephone on February 3,2011 at which point Plaintiff was not represented by
3 counsel. Plaintiff had repeatedly requested that opposing counsel agree to a
4 postponement of the meeting until his counsel had appeared, but Defense counsel

5 steadfastly refused. As a result, the conference conclusions cannot be called'Joinf'

6 or "agreed" in any meaningful sense.

7 Plaintiff (inpropiapersona, prior to the appearcnce of counsel) met and

8 conferred by telephone with Jonathan Ross, William Pallares, and Oriy Tattz while
9 traveling through Texas in an effort to comply with the Court's order for the parties
10 to meet and confer prior to February 7,2011. Because the Plaintiff was not

11 represented by counsel at that time, his statements and agreements to any joint
12 statement should not be binding on Plaintiff s now-appearing counsel Gary Kreep
13 and Philip J. Berg and Plaintiff files his report separately.

l4 1. Statement Of The Case

15 a. Plaintiffs Synopsis
t6 Plaintiff holds a J.D. from the University of Chicagol and externed or clerked
l7 for two Federal Judges (Hon. Stephen Reinhardt, 9th Circuit, Hon. Kenneth L.
18 Ryskamp, S.D. Fla.). He is currently a disbarred attorney, formerly admitted and

t9 licensed to practice in California (among other states). On or about May 30, 2009,
20 Plaintiff was offered contract work as a litigation consultant,legal assistant, or law-
2t clerk by Defendant Orly TaiIz, who at ail relevant times acted as de ifaclo albeit
,) unofficial servant andl or agent of and for Yosef T aitz and Daylight Chemical
23

24 1
Charles Edward Lincoln also received a B.A. from Tulane University (1980, where he graduated Phi Beta
25 Kappa, Magna cum laude), an M.A. from Harvard University in 1982, and a Ph.D. from Harvard
University in 1990. His Graduate Studies and Dissertation Research were supported by the National
26 Science Foundation and National Geographic Society as well as private funds including grants from the
late, Charles Pickering Bowditch Fund, the Harvard Peabody Museum, author James A. Michener and
27 Zemttrray Foundation of New Orleans.

28
bEwr RULE 26(0 Plaintifls Report Case #1 0-cv-0 1 573 -AG-(PLAx)
BRISBOI 26(fl REPORT on February 3 Phone Conference
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I Information Systems, Inc.. Plaintiff first met Dr. Orly Taitz on or about June 9,
2 2009, and began work.
3 From the beginning, DefendantTaitz sought to defraud Plaintiff by seeking to
4 have him work for free for herself and her shell organizations including Defend our

I Freedoms Foundation, Appealing Dentistry, Orly Taitz,Inc., and the Law Office of
6 Orly Taitz, all of which were actually shell-entities for Yosef Taitz and Daylight
7 Chemical Information Systems, Inc..

8 The scope of work which Dr.Taitz sought from Lincoln (and which Lincoln
9 agreed to perform) rapidly expanded and the parties developed an alternative plan

10 for compensation whereby in exchange for Lincoln's services as a litigation

11 consultant, quasi-political consultant, law clerk on numerous cases, and the

t2 relationship between Taitz & Lincoln became more complex on a personal and

13 professional level, with Taitz agreeing and contracting to appear as attorney on

l4 behalf of Lincoln as trustee for financially distressed estates and properties all over
15 the United States, and Orly Tartzbegan advertising her relationship with Lincoln

t6 and her involvement in Lincoln's mortgage redemption projects on her website and

t7 soliciting new clients. Taitz induced Lincoln to agree to work based on extravagant
18 promises and deceptive statements, all involving large amounts of money and care
19 and development of a personal and professional relationship, all relating to

2A information derived from foreign (especially Israeli) sources and information

21 relating to the constitutional illegitimacy of President Barack H. Obama to serve
22 under the U.S. Constitution of 1787.
23 Lincoln likewise advertised their relationship on his blog and both publicly,
24 personally, and specifically endorsed Orly Taitz' campaign against Obama and

25 announced his Trust and Foundation's (Tierra Limpia/Deo Vindice) institutional

26 commitment and support to Orly Taitz in July 2009. Defendant Orly Taitz agreed
27 and offered and attempted to appear in cases in U.S. District Courts in California,
28 Florida, and Idaho for Lincoln but only actually succeeded in appearing in a case in
!Ewr RULE 26(0 Plainti{f s Report 3 Case #10-cv-01573-AG-(PLAx)
BRISBOI 26(0 REPORT on February 3 Phone Conference
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I Orange County, California regarding which Orly Tartz failed to take any meaningful
2 action except withdrawing from representation in December 2009.
3 DefendantTartz did not initially disclose the degree of her abject dependence
4 upon both the financial support and direction of Yosef Taitz and the relationship
5 between her activities and his, but this gradually became apparent until Orly Tattz
6 terminated all her activities with Lincoln as a direct and proximate result of Yosef

7 Taitz' directions and orders.

8 Lincoln's association with Orly Taitz has severely injured his own
9 professional prospects for professional recovery and his own political aspirations,

10 his personalrcputation and even his personal and professional relationships with

11 others. Lincoln has been ridiculed and vilified in the on-line media and press, by
12 OrIy Taitz herself and by entities which may be related to or controlled by Yosef
13 Taitz, whose operation appears to be designed deceptively to defeat its own express
t4 pu{poses by incompetence and clownish misrepresentation.

15 b. Synopsis hy Defendant
16 i. Law Office of Orly Taitz and Dr. Orly Taitz, Erq., D.D.S.,
17 J.D.
r8 The core of the apparent employment and attorney-client relationship and the
t9 central places or institutions around which ail personal and professional interaction
20 took place. Dr. OrIy Tartz initiated a malicious prosecution of Lincoln for forgery
2T in relationship to one case in which she attempted and failed to appear in Florida,
'r) and she initiated this prosecution at the direction of and with the support of Yosef

23 Taitz & Daylight Chemical lnformation Systems, Inc.

24 ii. Daylight Chemical Information Systems, Inc. and Dr.
25 Yosef Taitz
26 The actual interested parties who controlled and directed all operations and
27 made the actual decisions of the Law Office of Orly Taitz and Dr. Orly Tait4 Esq.,
D.D.S., J.D., including but not limited to the decision to breach all contracts and
\LEW|
28

BRISBOI
RULE 26(0 Plainti{fs Report 4 Case #10-cv-01573-AG-(PLAx)
26(0 REPORT on February 3 Phone Conlerence
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1 agreements with Lincoln and the decision to maliciously prosecute him.

) Throughout their relationship, Dr. Orly Taitz was constantly receiving phone calls
3 from Yosef Taitz in which she said very little but listened and spoke exclusively in
4 Hebrew or Russian, neither of which Plaintiff understands beyond a handful of
5 words.

6 iii. Defend Our Freedom Foundation, Orly Taitz,Inc. and

7 Appealing Dentistry
8 Collateral entities and institutions organized at the same central place as the
9 Law Office of Orly Taitz and Orly Tattz, D.D.S., J.D.; Defend our Freedom
10 Foundation and Appealing Dentistryz in particular were used as vehicles to make

11 extravagant promises to Lincoln, seeking to induce his cooperation in a tangled web

t2 of possibly or potentially fraudulent activities, all of which promises were false and
13 most of which activities were either questionable or downright illegal, while Taitz &
t4 DOFD refused to honor their commitments to support Lincoln's mortgage work.
15 Many of the long-term staff employees of Appealing Dentistry speak Hebrew or

16 Russian.

t7 2. Subject Matter Jurisdiction

18 The parties dispute whether this Court has federal subject matter jurisdiction.
T9 Plaintiff contends there is federal subject matter jurisdiction pursuant to 28 U.S.C.
20 $$ 1331,1332 & 1367. Plaintiff was born in Texas and his maintained a residence

21 in Texas for most of his adult life. All his latest (past ten years') driver's license and
)", (exercised) voter's registration and voting were in Travis County, Texas.
23 All the Defendants are California residents or corporations. Diversity

24 Jurisdiction exists without any question whatsoever. Other states in which Lincoln
25 has recently resided would include Massachusetts and Florida. Lincoln's longest
26 recent presence in California was directly related to his work with and for Orly Taitz
27 and her associated organizations.
28 PlaintifPs RICO allegations will be amended within such time as allowed by
IEwr RULE 26(f) Plainti{?s Report Case #1 O-cv-01 573 -AG-(PLAx)
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1 the Court to provide full substantiation for the interstate and international
2 racketeering and tltreatof continuous criminal conduct which Defendants Yosef &
3 Orly Taitzhave engaged and continue to pose. With the basis of a federal claim for
4 subject matter jurisdiction, there is also a basis for supplemental jurisdiction under

5 28 U.S.C. $ 1367, as all claims arise from the same common nucleus of operative

6 law and fact and the same time frame and focus (May 2009-July 2010).
7 In response to Defendant Daylight Chemical Information Systems, Inc.'s and
I Dr. Yosef Taitz'motion to dismiss, pursuant to Rule 12(bX1), Plaintiff contends
9 there is diversity jurisdiction pursuanlto 28 U.S.C. $ 1332. However, Defendants
10 contend thatPlaintiff cannot establish complete diversity because he recently

11 asserted in public documents that he was a citizen of the State of California.

12 3. Key Legal Issues

13 Whether OrIy Taitzwas at all times legally as well as de faclo agent for or

14 employee/servant of Yosef Tartz & Daylight Chemical lnformation Systems such

15 that all the actions of Orly Tattzas agent or servant should be imputed to Yosef

l6 Taitz as principal.
t7 Whether the multiple shell organizations operated by Yosef and Otly Taitz
18 were enterprises engaged in a pattern of racketeering activity within the meaning of
T9 18 U.S.C. $1961 et seq..
20 Whether Dr. Orly Taitz' partialperformance and long-term announcements
2l and advertising of her contractual promises and professional relationship with

22 Lincoln validates or constitutes evidence of the existence and validity of her

23 contractual agreement with Lincoln sufficient to support judiciai enforcement of
24 said contracts betweenTaitz and Lincoln.

25 4. Parties, Evidence, etc.

26 t. Parties
.,n
Plaintiff Charles E. Lincoln, III;
28 Defendant Law Office of Orly Tattz;
bEwr RULE 26(0 Plaintiff s Report Case #1 0-cv-0 1 573 -AG-(PLAx)
BRISBOI REPORT on F 3 Phone Conference
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 Case 8:10-cv-01573-AG -PLA Document 42-1 Filed 02/15/11 Page 8 of 16 Page ID
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1 Defendant Dr. Orly Taitz, Esq., D.D.S., J.D.;

) Defendant Daylight Chemical Information Systems, Inc.;
3 Defendant Dr. Yosef Taitz;
4 Defendant Defend Our Freedom Foundation;
5 Defendant Orly Tartz,Inc.; and
6 Defendant Appealing Dentistry

7 b. Percipient Wifnesses
8 Charles E. Lincoln, III;
9 Dr. Orly Taitz;
10 Dr. Yosef Taitz;
11 John & Jane Doe Employees/Independent Contrators/Consultants of
t2 Appealing Dentistry, Defend Our Freedoms Foundation, OrIy Taitzrlnc.,
13 Daylight Chemical Information Systems, Inc., and OrIy Taitz, Inc.
L4 c. Key Documents
15 (1) All e-mail communications between Orly Taitz and Charles Lincoln,

T6 including all versions of contractual negotiations and all legal documents prepared
t7 and edited, and all legal research.

18 (2) All professional or political e-mail communications between Orly

19 Taitz, Appealing Dentistry, Defend Our Freedoms Foundation, Orly Taitz" Inc., the

2A Law Office of Orly Taitz, and Yosef TaitzlDaylight Chemical Information Systems,
2t concerning Obama eligibility litigation, birth certificates, Lucas Daniel Smith,
)', mortgage litigation, and Charles Edward Lincoln, III, relating to those
23 communications which were non-privileged because they were discussed by Orly
24 Taitz with Charles Edward Lincoln, disclosed physically to Charles Edward Lincoln
25 or to the three children of Orly & Yosef Tattz, or to other parties.
26 (3) All communications between Orly & Yosef Taitz and anyone in the
27 Israeli or Chinese govemment or Secret Services (e.g. MOSSAD) or anyone
28 involved in the Obama elegibility litigation, mortgage litigation, birth certificates,
IEwt RULE 26(0 PlaintifPs Report 7 Case #10-cv-01573-AG-(PLAx)
BRISBOI 26(0 REPORT on February 3 Phone Conference
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1 Lucas Daniel Smith, or Charles Edward Lincoln III.

2 5. Damages
3 Lincoln alleges actual breach of employment contract damages in an
4 amount in excess of $100,000.00, actual trreach of attorney-client contract
5 damages in excess of $5001000.00, libel and defamation and IIED damages in an
6 amount in excess of $50010000, and racketeering damages in an amount in
7 excess of $10000,000.00.

8 6. Insurance
9 Defendants Law Office of Orly Taitz and Dr. OrIy Taitz, Esq., D.D.S., J.D.
10 are curently being defended by ZunchNorth America.

11 7. Likelihood of Motions
12 L. Plaintiff
13 Plaintiff anticipates filing motions to compel discovery of electronic and other
t4 documents from all Defendants, but especially from Yosef Taitz,Dayhght Chemical
15 Information Systems, Inc., Appealing Dentistry, Defend Our Freedoms Foundation,

t6 Orly Taitz, Inc.; Plaintiff contends that given Defendants' massive computer
1,7 sophistication, it will be necessary to examine all computer harddrives and storage
18 systems directly and physically due to possible "accidental loss" or "spoilage" of
t9 evidence, including regularly timed destruction of documents which at the present

20 time the Court should order to cease.

2l b. Defendants
,,J
Defendants Law Office of Orly Taitz and Dr. Orly Taitz, Esq., D.D.S., J.D.
23 state that they do not anticipate bringing any motions other than a motions for
24 summary judgment or partial summary judgment pursuant to Fed. R. Civ. Proc. 56
25 and motions in limine. But based on the February 3,2011, discovery conference,

26 Plaintiff expects that Defendants will file multiple and massive Motions for
)1 Protective Orders and to prevent electronic discovery.
-t

LEW| 28
s RULE 26(0 Plaintifls Report Case #1 0-cv-0 1 573 -AG-(PLAx)
BRISBOI 26(fl REPORT on February 3 Phone Conference
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1 8. Manual for Complex Litigation

2 It is unclear whether this case could evolve into a complex litigation situation

3 if further evidence of international governmental (or corporate) connections or

4 espionage is discovered. Accordingly, the Plaintiff cannot be certain at the present

5 time whether it would be helpful to utilize the Manual of Complex Litigation in this

6 case or not.

7 9. Status of Discovery
8 The Plaintiff agreed (without counsel) on February 3,2011, to serve his initial
9 disclosures on or before March 21,2011. Plaintiff s recently appearing counsel

10 cannot agree to such a foreshortened time frame and wouid ask until May 1, 2All,

11 or that the Court dispense with the requirement of initial disclosures all together.
12 The parties acknowledge their duties to supplement disclosures and discovery
13 pursuant to Federal Rules of Civil Procedure 26(e).

t4 10. Discovery Plan

15 a. Numbering
16 The parties agree to use a single, unified numbering system, numbering each

t7 deposition exhibit in consecutive numerical order. Plaintiffs proposes that his

18 documents shall be numbered 1 through 999. Defendant Orly Taitz' documents

19 shall be numbered 1001-1999; Defendant Yosef Taitz' documents should be

20 numbered 2A0 I -2999; Defendant Daylight Chemical Information Systems'

2l documents should be numbered 3001-3999; Defendant Defend Our Freedoms'
,,1
Documents Should be numbered 4001-4999; Defendant Orly Taitz' Inc's documents
23 should be numbered 5001-5999; Appealing Dentistry's documents 6001-6999;Law
24 Offrce of Orly Taitz' documents 7001-7999, etc.
25 b. Written DiscoverY
26 The parties anticipate propounding interrogatories, requests for production of
27 documents, and requests for admissions.
z8 c. Depositions
!Ewr 9 Case #1 0-cv-01 573-AG-(PLAx)
BRISBOI REPORT on Fe 3 Phone Conference
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1 The parties anticipate taking the following depositions: Charles E. Lincoln,

2 III; Dr. OrIy Tattz; and Dr. Yosef Tattz; Plaintiff anticipates taking depositions of
3 employees and agents of each of the individual and cotporate Defendants; during the
4 February 3, 2011, conference, Dr. Orly Tartz indicated that she wished to either sue

5 or take evidence from Plaintiff s associates (1) Peyton Yates Freiman, (2) Kathy
6 Ann Garcia-Lawson, (3) Elena K. Lincoln, and (4) Charles Edward Lincoln, IV, as

7 well as (5) Lucas Daniel Smith, and (6) Larry Sinclair.

I The Parties anticipate the identity of third-party witnesses will be disclosed

9 during ongoing discovery and reserve the right to depose them.

10 d. Discovery Subject Matter
11 Plaintiff does not recall that the parties discussed whether to conduct
t2 discovery in phases on February 3,2011, or not. There are several reasons why this

13 might be a desirable strategy, but these will be discussed by counsel.

I4 e. Existing Or Issues To Arise
15 Electronic discovery will be a seriously disputed discovery issue; spousal
t6 privilege may be an issue for discovery concerning Orly & Yosef Taitz; national
l7 security may be an issue relating to discovery relating to Orly & Yosef Taitz &
18 Daylight Chemical Information Systems, Inc.; Attorney-Client privilege between

t9 Taitz and Lincoln no longer exists (for obvious reasons) but Attorney-Client

20 privilege between Taitz and Dr. Jonathan Levy may exist and yet Levy may be a

2t witness to certain relevant facts; Lincoln is willing to waive any claim of privilege
22 with Dr. Kathy Ann Garcia-Lawson although he sometimes rather informally

23 consulted with her in her capacity as a psychologist regarding his relationship(s)

24 with Dr. Orly Tartz and Orly Taitz' deeply troubled marriage to her husband Yosef.

25 f. Electronically Stored Information (Identification, Maintenance

26 And Production Agreements/Discussions)
,,,|
The parties have not entered into any agreements about electronically stored
28 information. Currently, the Plaintiff is anticipating extensive electronic discovery,
bEwr RULE 26(0 Plaintifls Report 10 Case #10-cv-01573-AG-(?LAx)
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I however, Defendants do not agree. However, should electronic discovery become

2 necessary, the Parties agree to cooperate as to time and cost saving protocols to

3 implement any foreseeable electronic discovery.

4 g. Limitations
5 The parties do not propose any changes to the limitations on discovery
6 imposed under the Federal Rules of Civil Procedure, and instead reserve the right to
7 stipulate or seek an order from the Court altering the limitations imposed by the
8 Federal Rules should the need arise.
9 11. Discovery Cut-Off
10 On February 3,2071, the parties tentatively discussed December 9,2An.
11 L2. Expert Discovery
t2 The Parties on February 3,2011 proposed the following tentative schedule for
13 expert discovery:
t4 Initial Expert Disclo sure : November ll,2011; and

15 Rebuttal Expert Disclosure : November 25,20tI

t6 13. Dispositive Motions
17 Defendants Law Office of Orly Taitz and Dr. Orly Taitz, Esq., D.D.S., J.D.

18 anticipate filing a motion for summary judgment as to the statue of limitation and
19 causation. Defendants Law Office of Orly Taitz and Dr. Orly Taitz, Ese., D.D.S.,
20 J.D. reserve the right to file on other grounds depending upon the disclosure of facts
2l during discovery.
22 14. Settlement
23 Plaintiff proposes mediation andlor mock/moot "trial-by-jury" as settlement
24 tecniques.

25 15. Trial Estimate

26 a. Jury Trial
27 The parties demand a jury tial
28 b. Witnesses
IEwr RULE,26(O Plaintiff s Report 11 Case #10-cv-01573-AG-(PLAx)
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1 The number of Witnesses has not yet been established for any party.

2 c. Time Estimate For Trial

3 The parties estimate a 5 to 6 day jury trial.
4 16. Trial Counsel
5 Plaintiffs trial counsel: Gary Kreep, Erq., & Philip J. Berg, Esq.
6 Defendants Law Office of Orly Taitz' and Dr. Orly Taitz, Esq., D.D.S., J.D.'s
7 trial counsel: Bartley L. Becker and William E. Pallares.
8 Defendants Chemical Information Systems, Inc.'s and Dr. Yosef Taitz' trial
9 counsel: Jonathan A. Ross;

10 Defendants Defend Our Freedom Foundation's, Orly Taitz, Inc.'s and

11 Appealing Dentistry's trial counsel: Dr. Orly Tartz.
12 Plaintiffs trial counsel, once approved for Pro Hac Vice will be: Philip J.

13 Berg, Erq., sponsored by local counsel, Gary G. Kreep, Esq.

t4 17. Independent Expert Or Master
15 The parties do not anticipate the need for the Court to appoint a master
t6 pursuant to Rule 53 or an independent scientific expert; the Plaintiff suggests that an
t7 independent expert regarding issues of national security and/or computer/electronic
18 data storage and retrieval MAY be necessary.
t9 18. Timetable
20 The Parties on February 3,20II, tentatively proposed the following dates
2l before the appearance of Plaintiff s counsel:
22 Discovery cut-off: December 9,2011;
23 Motion cut-off: January 30,2012;
24 Final Pretrial Conference: February 27,2012; and
25 Trial: March 12,2012.
26 19. Other fssues
27 At this time, the Parties do not anticipate any other issues.
28
bEwr RULE 26(0 Plaintiff s Report 12 Case #i0-cv-01573-AG-(PLAx)
BRISBOI 26(f) REPORT on February 3 Phone Conference
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1 Respectfully submitted,

2
DATED: February 14,2011 BY:
3 Gary G. Kreep, Esq.
United States Justice Foundation
4
932D Street, Suite 2
5 Ramona, CA,92065
Tel: 760-788-6624
6
Fax: 760-788-6414
7 Email: usif@)usif.net

I
9 DATED: February BY:
-!4,2011 Philip J. Berg
10
555 Andorra Glen Court, Suite 12
11 Lafayette Hill, PA 19444-2531
ohilibere@smail.com
12

13
DATED: February _14,2011 BY:
Charles Edward Lincoln, III
t4
Plaintfff fn Propia Persona
15

16

t7
18

t9
20

2l
22

23

24
25

26
27

28
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1 FEDERAL COURT PROOF OF SERVICE

Lincoln v. Daylight Chemieal Information - Case No. 10-cv-01573-AG (PLAx)
2
STATE OF CALIFORNIA, Orange County
3
At the time of service, I was over 18 years of age and not a party to the action.
4 My business address is 603 Elmwood Place, Suite #6, Austin, Texas 78705. I am
5 employed in the office of Plaintiff Charles Edward, Lincoln, III: Tierra Limpia/Deo
Vindice.
6
On February 14,20t 1, I served the following docurnent(s): RULE 26(F)
7
JOINT REPORT
8
Iserved the documents on the following persons by hand delivery in February
9 14,2011, or at the following addresses (including fax numbers and e-mail addresses,
10 if applicable):
11 Jonathan A. Ross, Esq. Dr. Orly Tartz,Esq.
Arnold S- Levine, Esq. 29839 Santa Margarita Parkway, #100
12 Mark I. Melo, Esq. Rancho Santa Margarita, CA 92688
Bradley & Gmelich . Tel: (949) 683-5411
13
700 North Brand Boulevard, to'h Floor rax: (9+9j rca-laoz
l4 Glendale, CA 91203 -1422 orly. taitaz@ gmail. com
Tel: (818) 243-5240 Attorney for Defend Our Freedoms
15 Fax: (818)243-5266 Foundation, Orly T aitz, Inc.,
Attorneys for Defendants Daylight Appealing Dentistry
16
Chemical Information Systems, Inc. and
t7 Dr. Yosef Taitz
Charles Edward Lincoln, III Gary G. Kreep, Esq.
18 603 Elmwood Place, Suite 6 United States Justice Foundation
Austin, TX78705 932D Street, Suite 2
T9 Tel: 512-968-2500 Ramona, CA 92065
charles. lincoln@rocketmaii. com
20
Plaintiff in Propia Persona Tel: 760-788-6624
2l Fax: 760-788-6414
Email: usjf@usjf.net
22
Philip J. Berg
23
555 Andorra Glen Court, Suite 12
24 Lafayette Hill, PA 19444-2531
phi lj berg@, gmai l. co rn
25 Courtesy Copy (subject to admission
pro hac Vice)
26 The documents were served by the following means:
27 tr By E-Mail on Monday Morning and by hand delivery in Court on February
14,2011.
28
bEwr RULE 26(0 Plaintiffs
1

CASE NO. CVl0-01573-AG (PLAx)

BRISBOI
s REPORT
 Case 8:10-cv-01573-AG -PLA Document 42-1 Filed 02/15/11 Page 16 of 16 Page ID
#:1078

I I declare under penalty of perjury under the laws of the State of California
that the foregoing is true and codect.
"l
Executed on February 14,2011, in Santa Ana, California.
3

4 Peyton Yates Freiman, for the Plaintiff

10

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13

t4
15

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t7
18

t9
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21.

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IEwr RULE 26(0 Plaintiffs CASE NO. CV10-01573-AG (PLAX)
BRISBOI
s REPORT