LIBERI V TAITZ (C.D. CA) - 190.18 - Plaintiffs Exhibits 91-95 To Amended Complaint.190.18

Case 8:11-cv-00485-AG -AJW Document 190-18 Filed 05/20/11 Page 1 of 51 Page ID
#:5184
EXHIBIT “91”
#:5185
Exhibit "91"
Pg. 682
Why is Lisa Liberi not back in prison? Why is District Attorney not schedu... http://www.orlytaitzesq.com/?p=15376
http://www.orlytaitzesq.com/?p=15376 #:5186
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Dr. Orly Taitz Esquire

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WHEN THE PEOPLE FEAR THEIR GOVERNMENT,
THERE IS TYRANNY.
WHEN THE GOVERNMENT FEARS THE PEOPLE,
THERE IS LIBERTY.
- Thomas Jefferson
The articles posted represent only the opinion of the writers, do not necessarily represent the opinion of Dr. Taitz, ESQ, and Dr. Taitz, ESQ has no means of
checking the veracity of all the claims and allegations in the articles.
Why is Lisa Liberi not back in prison? Why is District

Attorney not scheduling a hearing for revocation of
probation? Answer below will shed some light into
why the system is not working
Posted on | November 6, 2010 | Comments Off
Exhibit "91"
Pg. 683
1 of 11 5/2/2011 1:25 AM
#:5187
Exhibit "91"
Pg. 684
2 of 11 5/2/2011 1:25 AM
#:5188
LIBERI , LISA
Case FWV028000 – Defendants
Seq Defendant Next Court Date Status Agency / Arrest Date Count 1 Charge Violation Date
DR Number
RA
1 LIBERI , LISA R 05/18/2001 PC 115(A) 05/18/2001
110013759
ALIAS: LIBERI, LISA R
ALIAS: COURVILLERICHARDSON, LISA
ALIAS: LIBERI, LISA A
ALIAS: RICHARDSON, LISA C
ALIAS: COURVILLERICH, LISA
ALIAS: LIBERI, LISA RENEE
ALIAS: LIBERI, LISA
ALIAS: RICHARDSON, LISA RENEE
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Status
Custody N/A
Filing Type Held to Answer Filing Date 05/09/2003
Ordered Bail $0.00 Posted Bail $0.00
D.A. James R. Secord Defense Dean Pitcl (Court Appointed)
Next Action: Deputy Report #: RA-RC 110013759
Warrant Type Status Issued Affidavit

NONE N/A N/A
Probation Type Granted Expiration
Formal 03/21/2008 03/21/2011
Sentence Convicted Date County Jail CTS
01/25/2008 26 Days 26 Days
State Prison Max Sentence
N/A N/A
Fine and Penalty Restitution Fine Restitution to Victim
0 N/A
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Charges
Arrest Charges
Violation
Count Charge Severity Description Plea Status
Date
1 PC 459 F BURGLARY 05/18/2001

Filed Charges
Exhibit "91"
Pg. 685
3 of 11 5/2/2011 1:25 AM
#:5189
Violation
Date
GRAND THEFT: PROPERTY/ETC OVER

1 PC 487(A) F 05/18/2001 HTA
$400
2 PC 470(D) F FORGERY 05/18/2001 HTA
3 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 HTA
OFFER/ETC FALSE/FORGED
4 PC 115(A) F 05/18/2001 HTA
INSTRUMENT TO FILE
5 PC 487(A) F 05/18/2001 HTA
$400
6 PC 470(D) F FORGERY 05/18/2001 HTA
8 PC 115(A) F 05/18/2001 HTA
INSTRUMENT TO FILE
9 PC 487(A) F 05/18/2001 HTA
$400
10 PC 487(A) F 05/18/2001 HTA
$400
PC GRAND THEFT:
11 F 05/18/2001 HTA
487(D)(1) AUTOMOBILE/ANIMAL/ETC
12 PC 487(A) F 05/18/2001 HTA
$400
PC GRAND THEFT:
13 F 05/18/2001 HTA
14 PC 487(A) F 05/18/2001 HTA
$400
PC GRAND THEFT:
15 F 05/18/2001 HTA
16 PC 487(A) F 05/18/2001 HTA
$400
17 PC 487(A) F 05/18/2001 HTA
$400
Infor Charges
Violation
Date

1 PC 487(A) F 05/18/2001 GUILTY CONVICTED
$400
PC
2 F NONSUFFICIENT FUNDS: CHECKS 05/18/2001 GUILTY CONVICTED
476A(A)
3 PC 470(D) F FORGERY 05/18/2001 DISMISSED
4 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 DISMISSED
INSTRUMENT TO FILE
$400
Exhibit "91"
Pg. 686
4 of 11 5/2/2011 1:25 AM
#:5190
MAKING, POSSESSING, UTTERING
7 PC 476 F 05/18/2001 DISMISSED
FICTIOUS INSTRS
9 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 GUILTY CONVICTED
10 PC 115(A) F 05/18/2001 DISMISSED
INSTRUMENT TO FILE
$400
$400
PC GRAND THEFT:
13 F 05/18/2001 DISMISSED
14 PC 487(A) F 05/18/2001 DISMISSED
$400
PC GRAND THEFT:
16 PC 487(A) F 05/18/2001 DISMISSED
$400
PC GRAND THEFT:
$400
$400
INSTRUMENT TO FILE
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Probation
Probation Type: FORMAL Granted: 03/21/2008 Expire: 03/21/2011
SUPERVISED PROBATION GRANTED FOR A PERIOD OF 36 MONTHS ON FOLLOWING TERMS AND

CONDITIONS:
SERVE 26 DAYS IN A SAN BERNARDINO COUNTY JAIL FACILITY, WITH CREDIT FOR TIME
SERVED, A MATTER OF 26 DAYS, PLUS CONDUCT CREDIT PURSUANT TO 1-PC4019 ND
1)
ABIDE BY ALL RULES AND REGULATIONS OF THE FACILITY WITHOUT THE POSSIBILITY
OF COUNTY PAROLE.
2) VIOLATE NO LAW.
REPORT TO THE PROB OFFICER IN PERSON IMMEDIATELY 0- ND THEREAFTER ONCE
EVERY FOURTEEN (14) DAYS OR AS DIRECTED. REPORT TO THE PROB OFFICER IN
3)
PERSON IMMEDIATELY 0- ND THEREAFTER ONCE EVERY FOURTEEN (14) DAYS OR AS
DIRECTED.
COOPERATE WITH THE PROBATION OFFICER IN A PLAN OF REHABILITATION AND
4)
FOLLOW ALL REASONABLE DIRECTIVES OF THE PROBATION OFFICER.
Exhibit "91"
Pg. 687
5 of 11 5/2/2011 1:25 AM
#:5191
SEEK AND MAINTAIN GAINFUL EMPLOYMENT, OR ATTEND SCHOOL, AND KEEP THE
5)
PROBATION OFFICER INFORMED OF STATUS OF EMPLOYMENT, OR SCHOOL.
KEEP THE PROBATION OFFICER INFORMED OF PLACE OF RESIDENCE AND COHABITANTS
AND GIVE WRITTEN NOTICE TO THE PROBATION OFFICER TWENTY-FOUR (24) HOURS
PRIOR TO ANY CHANGES. PRIOR TO ANY MOVE PROVIDE WRITTEN AUTHORIZATION TO
THE POST OFFICE TO FORWARD MAIL TO THE NEW ADDRESS. PERMIT VISITS AND
SEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THE PROBATION DEPT. AND/OR
LAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCE WITH PERMIT
VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THE PROBATION DEPT.
AND/OR LAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCE WITH
PERMIT VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THE
PROBATION DEPT. AND/OR LAW ENFORCEMENT FOR THE PURPOSE OF ENSURING
6) COMPLIANCE WITH THE TERMS AND CONDITIONS OF PROBATION; NOT DO ANYTHING
TO INTERFERE WITH THIS REQUIREMENT, OR DETER OFFICERS FROM FULFILLING THIS
REQUIREMENT, SUCH AS THE TERMS AND CONDITIONS OF PROBATION; NOT DO
ANYTHING TO INTERFERE WITH THIS REQUIREMENT, OR DETER OFFICERS FROM
FULFILLING THIS REQUIREMENT, SUCH AS ERECTING ANY LOCKED FENCES/GATES THAT
WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE ANY ANIMALS ON THE
PREMISES THAT WOULD REASONABLY DETER, ERECTING ANY LOCKED FENCES/GATES
THAT WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE ANY ANIMALS ON THE
PREMISES THAT WOULD REASONABLY DETER, THREAT THREATEN THE SAFETY OF, OR
INTERFERE WITH, OFFICERS ENFORCING THIS TERM. EN THE SAFETY OF, OR INTERFERE
WITH, OFFICERS ENFORCING THIS TERM.
NEITHER POSSESS NOR HAVE UNDER YOUR CONTROL ANY DANGEROUS OR DEADLY
7)
WEAPONS OR EXPLOSIVE DEVICES OR MATERIALS TO MAKE EXPLOSIVE DEVICES.
SUBMIT TO A SEARCH AND SEIZURE OF YOUR PERSON, RESIDENCE AND/OR PROPERTY
UNDER YOUR CONTROL AT ANY TIME OF THE DAY OR NIGHT BY ANY
LAW-ENFORCEMENT OFFICER, WITH OR WITHOUT A SEARCH WARRANT, AND WITH OR
WITHOUT CAUSE (PEOPLE -V- BRAVO).
NEITHER USE NOR POSSESS ANY CONTROLLED SUBSTANCE WITHOUT MEDICAL
9) PRESCRIPTION. A PHYSICIANS’S WRITTEN NOTICE IS TO BE GIVEN TO THE PROBATION
OFFICER.
SUBMIT TO A CONTROLLED SUBSTANCE TEST AT DIRECTION OF PROBATION OFFICER.
10)
EACH TEST IS SUBJECT TO AN $11.00 FEE, TO BE COLLECTED BY CENTRAL COLLECTIONS
11) NOT POSSESS ANY TYPE OF DRUG PARAPHERNALIA, AS DEFINED IN H&S11364.5(D)
PARTICIPATE IN A COUNSELING PROGRAM AS DIRECTED BY THE PROBATION OFFICER,
SUBMIT MONTHLY PROOF OF ATTENDANCE AND/OR SUCCESSFUL COMPLETION TO THE
12)
PROBATION OFFICER AS DIRECTED AND BE RESPONSIBLE FOR PAYMENT OF ALL
PROGRAM FEE(S).
NOT ASSOCIATE WITH KNOWN CONVICTED FELONS OR ANYONE ACTIVELY ENGAGED IN
13)
CRIMINAL ACTIVITY B-OR CODEFENDANT(S) OR VICTIM(S).
NOT ASSOCIATE WITH KNOWN ILLEGAL USERS OR SELLERS OF CONTROLLED
14)
SUBSTANCES,
NOT MAINTAIN A CHECKING ACCOUNT OR COMPLETE OR ENDORSE ANY CHECKS
15) UNLESS MADE PAYABLE TO YOU AND NOT HAVE ANY BLANK CHECKS IN YOUR
POSSESSION WITHOUT PERMISSION OF THE PROBATION OFFICER.
SUBMIT A RECORD OF INCOME AND EXPENDITURES TO THE PROBATION OFFICER
16)
QUARTERLY.
NEITHER POSSESS NOR USE ANY CREDIT CARD WITHOUT PERMISSION OF THE
17)
PROBATION OFFICER.
Exhibit "91"
Pg. 688
6 of 15 5/2/2011 1:25 AM
#:5192
NOT DRIVE OR POSSESS KEYS OR DOCUMENTATION TO ANY MOTOR VEHICLE UNLESS
18) LEGALLY REGISTERED TO YOU OR AN IMMEDIATE FAMILY MEMBER, EXCEPT IN THE
COURSE OF EMPLOYMENT.
REPORT ALL MOTOR VEHICLES REGISTERED TO YOU TO THE PROBATION OFFICER
19)
WITHIN SEVEN (7) DAYS OF ACQUISITION.
SUBMIT TO AND COOPERATE IN A FIELD INTERROGATION BY ANY PEACE OFFICER AT
20)
ANY TIME OF THE DAY OR NIGHT.
CARRY AT ALL TIMES A VALID DRIVERS LICENSE OR DEPARTMENT OF MOTOR VEHICLES
IDENTIFICATION CARD AND DISPLAY SUCH IDENTIFICATION UPON REQUEST BY ANY
21)
PURPOSE WITHOUT FIRST NOTIFYING THE PO. CONTAINING YOUR TRUE NAME AGE AND
CURRENT ADDRESS
ENROLL IN THE DRUG TREATMENT PROGRAM AT THE DIRECTION OF THE PROBATION
22) OFFICER, AND SHOW PROOF OF ENROLLMENT TO THE PROBATION OFFICER WITHIN
SEVEN (7) DAYS.
MAKE RESTITUTION TO THE VICTIM(S) (SEE PROBATION REPORT) IN THE AMOUNT OF
23) $9223.77 PLUS A 10% ADMINISTRATIVE FEE, TO BE PAID THROUGH CENTRAL
COLLECTIONS
MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORT) IN THE AM OUNT OF
24) $35000.00 PLUS A 10% ADMINISTRATIVE FEE, TO BEPAID THROUGH CENTRAL
COLLECTIONS
MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORT) IN THE AMO UNT OF
COLLECTIONS
PAY A RESTITUTION FINE IN THE AMOUNT OF $200.00, PLUS A TEN PERCENT (10%)
26)
ADMINISTRATIVE FEE THROUGH CENTRAL COLLECTIONS.
THE DEFENDANT IS NOT TO FILE ANY LAWSUIT/LEGAL ACTION WITHOUT PRIOR
27)
CONTACT WITH PROBATION OFFICER.
DO NOT APPLY FOR CREDIT OR A LOAN WITHOUT PRIOR CONTACT WITH PROBATION
28)
OFFICER.
29) COMPLY WITH ANY COURT-ORDERED PAYMENT SCHEDULE.
MAKE RESTITUTION TO VICTIM (SEE PROBATION REPORT) IN AN AMOUNT TO BE
30)
DETERMINED BY PROBATION.
31)
PROBATION MAY BE SERVED THROUGH INTER STATE COMPACT AGREEMENT IN THE
32)
STATE OF NEW MEXICO UPON APPROVAL FROM PROBATION.
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA (Eastern Division – Riverside)
CIVIL DOCKET FOR CASE #: 5:05-cv-00309-UA l
Lisa Liberi v. West Valley Detention Center et al Date Filed: 04/15/2005

Assigned to: Judge Unassigned Date Terminated: 04/28/2005
Demand: $280,000,000 Jury Demand: Plaintiff
Cause: 18:1961 Racketeering (RICO) Act Nature of Suit: 470 Racketeer/Corrupt
Organization
Jurisdiction: Federal Question
Plaintiff
Lisa Liberi represented by Michelle D Strickland
Michelle D Strickland Law Offices
P O Box 2238
Colton, CA 92324
Exhibit "91"
Pg. 689
7 of 11 5/2/2011 1:25 AM
#:5193
951-782-8555
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
V.
Defendant
West Valley Detention Center
Defendant
San Bernardino County Sheriffs
Department
Defendant
Gary Penrod
San Bernardino County Sheriff
Defendant
Paul Morrison
Defendant
Doe Deputies
assigned to West Valley Detention Center
Defendant
Doe Nurses
Defendant
Dr Shin Yin Liong
MD
Defendant
Doe Contractors
Defendant
John Heary
Nursing Supervisor
Defendant
Brian Fratt
Deputy
Exhibit "91"
Pg. 690
8 of 11 5/2/2011 1:25 AM
#:5194
Defendant
County of San Bernardino
Defendant
San Bernardino County District
Attorneys Office
Defendant
James Secord
Deputy District Attorney
Defendant
Mike Leiberich
Defendant
V L Hamilton
Defendant
Michael A Ramos
District Attorney
Defendant
Joan Borba
Judge
Defendant
Craig Wyatt Zibell
individually and
doing business as
Allways Allways 4U Bail Bonds
also known as
Allways For-U Bail Bonds
Defendant
Angelo Michael Verlingo
Defendant
Bar Triangle Bail Bonds Inc
doing business as
Boones Bail Bonds
Exhibit "91"
Pg. 691
9 of 15 5/2/2011 1:25 AM
#:5195
Defendant
Seneca Insurance Company Inc
Defendant
John Mark Allen
Defendant
US Federal Credit Union
also known as
United Services of America
Defendant
Melinda Rosas Wevely
Defendant
Julie Misleh
Defendant
Houts & Associates
Defendant
Randolph C Houts
Defendant
Rob Henderson
Defendant
DOES
1 through 10 inclusive
Date Filed # Docket Text

04/15/2005 LODGED COMPLAINT submitted by plaintiff fwd to Duty Magistrate Judge: (SGL)., filed
by plaintiff Lisa Liberi.(am, ) (Entered: 04/27/2005)
04/15/2005 1 REQUEST to Proceed In Forma Pauperis, Declaration in Support filed by plaintiff Lisa
Liberi. (am, ) (Entered: 04/27/2005)
04/15/2005 2 MOTION for Leave to Proceed in forma pauperis, waiver of filing fees, costs and service of
process by the US Marshall filed by plaintiff Lisa Liberi. Lodged Lodged Orders. (am, )
(Entered: 04/27/2005)
Exhibit "91"
Pg. 692
10 of 11 5/2/2011 1:25 AM
#:5196
04/25/2005 PLACED IN FILE – NOT USED re Order for leave to proceed in forma pauperis and
service of process by the US Marshal submitted by plaintiff Lisa Liberi. (am, ) (Entered:
04/28/2005)
04/28/2005 3 NOTICE OF CLERICAL ERROR: Case number has been corrected. The correct case
number is CV 05-3015 VAP (SGLx). All previosly filed documents under ED CV 05-309 will
be docketed and housed under case number CV 05-3015 VAP (SGLx). This case is closed.
Case opening clerk assigned this to Magistrate Judge Larson in error. (la, ) (Entered:
04/29/2005)
You can see, that Lisa Liberi harassed the county, the judge, the DA office , policemen, correctional institution,
where she was incarcerated, and other with a frivolous law suit, demanding 280 million dollars from all of the
county officials. Her case was dismissed, for failure to prosecute, but it looks like this harassment was enough
for the DA and the judge to ultimately reduce her 8 year prison term for 10 counts of forgery and theft to 3 years
probation. Now Liberi with the help of her attorney Philip J. Berg is slandering and defaming multiple innocent
individuals. They filed yet another frivolous law suit in PA claiming her to be an innocent woman residing in PA.
and not the same Liberi, who was convicted in CA. The judge got the mug shot and could see, that it is the same
person. The witnesses identified her as the same person. When Liberi and Berg were asked to produce her PA
driver’s license, they came up with an insane an slanderous accusation that her PA drivers license cannot be
produced because Attorney Orly Taitz tried to hire a hit man to kill her. Even though Liberi is the one who is
a convicted forger and thief, Liberi and Berg accused multiple individuals, who never committed any crimes of
multiple acts of forgery and theft. District Attorney’s office was supposed to revoke her probation long time ago
and send her back to prison to serve her 8 year prison term. They were supposed to prosecute Philip J. Berg
for aiding and abetting felon on probation to violate terms of her probation, for filing a legal action with the
purpose of harassment. It has been a year and a half and they were not prosecuted yet.
You may ask why? The reason is simple: we have now the criminals telling the government what to do by virtue of
filing RICO law suits against governmental officials as Liberi filed her RICO suit against everyone in the county in
2005. The end result is that such officials don’t want to bother with such criminals and let them get away with
murder. Please, help end this nightmare and this enormous waste of my time and money, that I should be using for
better purposes. Please demand from the San Bernardino District Attorney’s office and San Bernardino county
Grand Jury to finally do their job and prosecute Liberi and Berg. There has to be an end to this. You can now
understand, why others are not prosecuted for commission of crimes. If a common criminal like Liberi is allowed to
do what she wants, you can understand, how they are intimidated of others. We have to end this. Please, demand
that the San Bernardino, CA District Attorney do his job. If he is intimidated by common criminals and not willing
to do his job, then he needs to resign and a new DA has to be appointed. Our government should be there to protect
us from criminals, not aiding and abetting criminals and their unscrupulous attorneys in terrorising innocent
individuals, who happen to be whistle blowers.
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CAMPAIGN FLIER for Orly Taitz as CA SOS
CAMPAIGN FLIER for Orly Taitz as CA SOS, 2 Per Page
How to contact public Integrity unit
See The PDF File Here
Exhibit "91"
Pg. 693
11 of 11 5/2/2011 1:25 AM
#:5197
EXHIBIT “92”
#:5198
Exhibit "92"
Pg. 694
Why is Lisa Liberi not back in prison? Why is District Attorney not schedu... http://www.orlytaitzesq.com/?attachment_id=15377
http://www.orlytaitzesq.com/?attachment_id=15377
#:5199
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Santa Margarita CA, 92688 – Copyright 2010

THERE IS TYRANNY.
THERE IS LIBERTY.
- Thomas Jefferson
Lisa Liberi mug shot

Posted on | November 6, 2010 | Comments Off
Exhibit "92"
Pg. 695
1 of 1 5/2/2011 1:33 AM
#:5200
EXHIBIT “93”
#:5201
Exhibit "93"
Pg. 696
Why it is important to go after criminals | Dr. Orly Taitz Esquire http://www.orlytaitzesq.com/?p=15393
Case 8:11-cv-00485-AG -AJW Document 190-18
http://www.orlytaitzesq.com/?p=15393 Filed 05/20/11 Page 19 of 51 Page ID
#:5202
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THERE IS TYRANNY.
THERE IS LIBERTY.
- Thomas Jefferson
Why it is important to go after criminals

Posted on | November 7, 2010 | 4 Comments
Submitted on 2010/11/06 at 5:25pm Why is Lisa

Liberi not
I agree with you that having a convicted felon help a lawyer is a bad back in
thing. But what should Lisa Liberi be in jail now? What has she done prison? Why
since she was put on parole? Complained that you were harassing her? is District
sf67463@smegma.gov
Is that a crime? Attorney not
67.159.56.162
explanation from Orly: scheduling a
hearing for
Liberi and Berg did not just complain, they filed a law suit in revocation of
Philadelphia for nearly a billion dollars against me, investigator probation?
Exhibit "93"
Pg. 697
1 of 3 5/2/2011 1:38 AM
Sankey, owner of a Christian publishing house James Sundquist, talk
#:5203
show host Ed Hale, his wife, his radio station, Mr.Sankey’s firm and so
on.
The basis of their law suit was slander and defamation of character.
they claimed that Lisa Liberi , working for Berg does not send
information to Berg from out of state, but rather lives in PA. they said
that she is a different woman, who was never convicted of any crimes
and I defamed them by posting a criminal record of Liberi. They
claimed, that though she has the same first, middle and last name and
the same birth date she is a different person. I produced her mug shot.
The judge could see, that the woman, who appeared before him is the
same woman, who was convicted in CA. In spite of the fact, that I
provided her mug shot, identical signature from CA,
information, pointing out the same first, middle, last name, same birth
dates, these criminals are still claiming, that she is not the same woman
and continue harassing me with the same law suit. They are committing
perjury, fraud on the court and they committed a number of other
crimes, which I will not list at the moment. Violation of law is grounds
for revocation of her probation
Not only they filed a frivolous law suit based on perjury and fraud, Berg
and Liberi viciously defamed multiple individuals in order to cover up
the fact, that a convicted forger and thief Lisa Liberi is employed by
attorney Philip J. Berg. They are refusing to provide her PA driver’s Answer
license to prove, that she is indeed a resident of PA. They are trying to below will
justify this refusal by claiming that she is afraid for her life because I shed some
tried to hire a hit man to kill her. Berg is acting like a criminal. He is light into why
accusing an innocent person of crimes in order to cover up a fact, that the system is
he is working with a criminal, that he is conducting a Nation wide not working
donation drive by using a convicted thief on probation as his assistant.
He should be disbarred for doing this. Just as he accused me, he
accused multiple individuals of stalking, perjury, forgery and so on.
People like this should not be allowed to practice law. It is true, that
sometimes people of questionable character contact public figures and
volunteer their help. It happened to me and it happens to everybody,
however, after it is found, that such person is doing illegal things, it is
up to the lawyer to disassociate himself from such individuals. that what
I did. that is what Berg was supposed to do a year and a half ago.
Instead he and Liberi engaged in cover up and have been harassing me
and many others with a frivolous law suit for nearly a billion dollars,
they slandered and defamed multiple innocent individuals. Their
behavior was criminal. This is not about one woman saying something.
this is about a criminal behavior. My question is, why are the courts
allowing this to go on? Presiding Judge Eduardo Robreno was supposed
to get a verification of her PA citizenship for the purpose of diversity. If
a party refuses to provide her prove of citizenship, a law suit based on
diversity cannot go on. It is supposed to be dismissed. If this would be
allowed, any criminal would commit any crimes and claim that he is a
different person.
Why didn’t Robreno demand her prove of PA citizenshio immediately?
Exhibit "93"
Pg. 698
2 of 3 5/2/2011 1:38 AM
#:5204
Why didn’t he dismiss this case and sanction them and didn’t report
Berg to the dpsciplinary board of the PA Supreme Court for
disbarment? Why didn’t he forward the pleadings to the DA in CA to
have her probation revoked? How could he stare at her mug shot of a
felon, convicted in CA that looks just like her and in good conscience
believe, that she is another woman in PA? You can see the level of
corruption. If this is not exposed and dealt with, each and every one of
you are at mercy of criminals. You can see, what was done to Lakin, to
Fitzpatrick.
You can see, that we lost the system of justice. We see the same people
serving as foremen of grand juries for 20 years, we see the judges not
following the law and completely disregarding evidence. You can see
attorneys like Berg allowed to continue to prctice law, while bringing
law suits clearly based on fraud and perjury and vicious defamation of
others, you can see the district attorneys offices and grand juries not
indicting dangerous criminals. We have to end this immediately, or any
one of you will be the next victim of this regime of
criminalsareus.org that replaced the system of Justice in U.S.
Yesterday I did a program for a European TV network with a reach to

120 million people. I am trying to bring to the attention of the
International community total lawlessness in U.S., which we saw lately.
Category: HOT ITEMS!, Legal Actions, Letters from Readers and Patriots, Letters/Feedback from Readers
Comments
4 Responses to “Why it is important to go after criminals”
1. Politijabber
November 7th, 2010 @ 10:51 am
So, to put the question differently, how is being a plaintiff in a civil lawsuit a violation of probation?
2. dr_taitz@yahoo.com
November 7th, 2010 @ 12:51 pm
committing crimes is a violation: perjury, fraud on the court committed in this case is a violation.
additionally she was not allowed to have any access to credit cards of others. according to witnesses
she had access and processed the credit card records of others.
3. Jim
If she didn’t notify her probation officer about filing the lawsuit, she is in violation of her probation. If
she did notify him, the n it is more proof that she committed perjury and fraud on the court by claiming
that she was not the same Lisa Liberi.
4. Jim
Exhibit "93"
Pg. 699
3 of 3 5/2/2011 1:38 AM
#:5205
EXHIBIT “94”
#:5206
Exhibit "94"
Pg. 700
Submitted yesterday in the Third Circuit Court of Appeals | Dr. Orly Taitz... http://www.orlytaitzesq.com/?p=15801
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THERE IS TYRANNY.
THERE IS LIBERTY.
- Thomas Jefferson
Submitted yesterday in the Third Circuit Court of

Appeals
Posted on | November 23, 2010 | 1 Comment
No. 10-3000
UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
____________________ Exhibit "94"

Pg. 701
1 of 16 5/2/2011 2:01 AM
#:5208
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 REPLY TO APPELLEES’ BRIEF
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
TABLE OF CONTENTS Exhibit "94"

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1. TABLE OF AUTHORITIES……………………………………………………………p3
2. CERTIFICATION OF COMPLIENCE……………………………………………p4
3. SUMMARY OF THE ARGUMENT…………………………………………………..p4
4. LEGAL ARGUMENT………………………………………………………………..p6
A. DECISION TO ASSUME JURISDICTION IN DIVERSITY WITHOUT VERIFICATION OF THE STATE

CITIZENSHIP GOES AGAINST PRIOR RULINGS OF THE THIRD CIRCUIT COURT OF APPEALS….p6
B.APPELLEE’S ATTACKS ON THE JURISDICTION OF THE THIRD CIRCUIT COURT OF APPEALS IS

FRIVOLOUS……………………………p12
C. STATE CITIZENSHIP IS AT THE CORE OF THE CASE……..………p13
D. APPELLEES COMMITTED FRAUD ON THE COURT AND PERJURY BY CLAIMING THAT THEY
PROVIDED LIBERI’S DRIVERS LICENSE TO JUDGE
ROBRENO…………………………………..……p17
E. APPELLEES DISCUSSION OF VENUE IS IRRELEVANT AND WAS DONE IN ORDER TO CREATE

CONFUSION, AS AT ISSUE IS THE FACT, THAT THERE WAS NO JURISDICTION FOR FEDERAL
COURT TO SIT IN DIVERSITY, REGARDLESS OF VENUE……p18
F. PUBLIC POLICY CONSIDERATIONS……………………………..p19
G. APPELLEES ARE MISREPRESENTING THE ISSUES ON APPEAL IN RELATION TO THE

DISMISSAL OF THE DEFENDANTS JAMES SUNDQUIST AND SALT ROCK
PUBLISING………………………..p20
H. FRAUD ON THE COURT BY BERG AND LIBERI COMMITTED, AS NO IDENTIFICATION

DOCUMENTS WERE ROVIDED……….……..p22
I. JUDGE ROBRENO’S FINDINGS WENT TO THE CORE OF THE CASE AND WERE IMPROPER TO
BE MADE WITHOUT THE EVIDENCEp25
J. APPELLANTS REQUEST FOR SANCTIONS IS PROPER AND SUPPORTED BY FACT AND LAW
AND NECESSARY TO STOP EGREGIOUS MISCONDUCT BY BERG AND THE PLAINTIFFS..p26
1. CONCLUSION…………………………………………………………p30
2. CERTIFICATE OF SERVICE…………………………………………………. p31
TABLE OF AUTHORITIES
1.Packard v Provident National Bank, 994 F. 2d 1039, 1045 (3d Cir. 1993)p8
2. Gould Electronics, inc v United states, 220 F. 3d 169, 176 (3d Cir.2000)p 8
3. J& R Ice cream Corp. v. California Smoothie Licensing, 31 F. 3d 1259, 1265 n.3 (3rd Cir
1994)……………………………………………………………..p8
4. 5C. Wright & A. Miller, Federal Practice and Procedure §1206, at 78-79 (1969 & Supp.
2005)………………………………………………………..p8
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5. Thomas v Board of Trustees, 195 U.S. 207, 210 (1904)……………….p8
6. Joiner v. Diamond M Drilling Co., 677 F. 2d 1035, 1039 (5th Cir 1982).p9
7.Weight v Kawasaki Motors Corp. (1985, ED Va) 604 F Supp 968……….p9
8. McMann v Doe (2006, DC Mass) 460 F Supp 2d ………………………..p10
9. Bautista v Pan American World Airlines, Inc. (1987, CA9 Cal) 828 F2d 546, 126 BNA LRRM 2559, 107
CCH LC P 10159………………………………….…p10
10. Roche v Lincoln Prop. Co. (2004, CA4 Va) 373 F3d 610……………….…p9
11.Olsen v Quality Continuum Hospice, Inc. (2004,DC NM) 380 F Supp 2d

1225………….…………………………………………………………………….……..p10
12.Filla v Norfolk & Southern Ry. (2003, CA8 Mo) 336 F3d 806……………….p11
13. Jeter v Jim Walter Homes, Inc. (1976, WD Okla) 414 F Supp 791.259……..p11
14. Shahmoon Industries, Inc. v Imperato (1964, CA3 NJ) 338 F2d 449, 9 FR Serv 2d 12B.22, Case
2………………………………………………………………………p11
CERTIFICATION
Reply brief does not exceed allowed 7,000 words
Hard paper copy of the reply brief is identical to the electronic copy
SUMMARY OF THE REPLY

This appeal revolves around the fact, that presiding Judge Eduardo Robreno erred, showed bias and abuse of
judicial discretion in assuming jurisdiction over this case and entering an order to sever and transfer the
case, with the notation that the plaintiff “Lisa Liberi is a resident of Pennsylvania” without a shred of
evidence of state residence of the lead plaintiff Lisa Liberi. During 08.07.09 hearing before Judge Robreno
Lisa Liberi and her attorney and Co-plaintiff Phil Berg promised to provide Liberi’s address and identifying
documents and file them under seal, however,- they defrauded the court and they never provided any
identifying documents. Transcript of the hearing in question and the docket show, that there are no
identifying documents submitted. The Plaintiffs/Appellees could resolve this matter by providing just one
page- a certified copy of Liberi’s PA driver’s license, they could resolve it by submitting it to the Third Circuit
Court of Appeals under seal. They never did it. Instead, they submitted over 900 pages of irrelevant,
inflammatory and defamatory material in order to obfuscate the fact, that they committed fraud, that Liberi
did not reside in PA at the time the law suit was filed, that PA attorney Philip J. Berg is employing as his
paralegal a convicted document forger and thief , Lisa Liberi, who was convicted in 2008 in CA, who is
currently on probation and not allowed to reside in any state aside from CA and NM. Berg yet again violated
the rules of professional discipline and filed this whole case with the purpose of harassing and
intimidating the defendants, who were whistle blowers and exposed Berg and Liberi to the public.
Actions of Judge Robreno represent error of fact and law and abuse of judicial discretion, in that he refused
to rule on the defendants multiple motions to dismiss due to lack of jurisdiction, he refused to take into
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consideration any and all identifying evidence, presented by the defendants, who are out of state defendants,
instead he ruled in favor of the Plaintiff and Plaintiff’s attorney Berg, who is a local Philadelphia attorney,
even though Berg did not provide a shred of evidence of Liberi’s PA residence. Judge Robreno, also, under
the color of authority, violated the Constitutional rights of due process of out of state pro se defendant Linda
Belcher, who repeatedly complained, that she was not served with the pleadings. Judge Robreno simply
ignored all of her letters and complaints, did not docket her letters and did not rule on her complaints.
(Appendix, Affidavit by Linda Belcher ) Additionally, District Court repeatedly did not docket important
exhibits and pleadings provided by the defendants, particularly ones, that were incriminating Berg and Liberi,
whereby showing bias.
LEGAL ARGUMENT
A. DECISION TO ASSUME JURISDICTION IN DIVERSITY WITHOUT VERIFICATION OF THE

STATE CITIZENSHIP GOES AGAINST PRIOR RULINGS OF THE THIRD CIRCUIT COURT OF
APPEALS
Appellees did not provide any response to the main question, why should the jurisdiction be asserted in
diversity without any evidence of the lead plaintiff’s state citizenship. Appellee’s argument can be
summarized to 2 points:
1. Decision to severe the case was proper in relation to venue

2. Precedents cited by the Appellants, who are CA residents, come from other circuits, mostly CA and not
Third Circuit Court of Appeals cases.
In response, the Appellants are stating, that Venue is not being appealed. Before the Venue is in play, the
Federal Court system as a whole is supposed to have jurisdiction over the case. This case was filed based on
Diversity jurisdiction, where the Appellees claim, that the lead plaintiff is a resident of PA, while the
defendants were residents of CA, TX and NJ. Appellees stated at 08.07.09. hearing that they will submit the
plaintiff Lisa Liberi’s identifying documents, however they defrauded the court and never submitted those
documents. Presiding Judge Eduardo Robreno, might have thought that those were submitted at some point,
however the docket shows, that at no time within a year and a half those were ever submitted. As such, the
Plaintiffs never established Liberi’s state citizenship for purposes of diversity.
In regards to the second point questioning the position of the- Third Circuit Court of Appeals in regards to
the state citizenship, it repeatedly ruled that it is upon the party, claiming diversity to show that it exists. It
has to be shown by the preponderance of evidence.
In the recent unpublished case of S. Freedman and Company, Inc v Marvin Raab, 180 Fed. Appx. 316 (3rd
Cir. 2006) not cited here as precedent, Third Circuit Court Judges Honorable Barry, Smith and Aldisert found
that under the precedent of Gould Electronics, Inc v United states, 220 F. 3d 169, 176 (3d Cir. 2000) the
Third Circuit court of Appeals had jurisdiction to review under 28 U.S.C. §1291 the issue of subject matter
jurisdiction as a basis for dismissal of the case. Third Circuit Court of Appeals also found that a District
Court has a duty to raise doubts about its jurisdiction at any time, and that the party asserting
jurisdiction “bears the burden of showing that the case is properly before the court at all stages of
litigation”. See Packard v Provident National Bank, 994 F. 2d 1039, 1045 (3d Cir. 1993) and similarly J& R
Ice cream Corp. v. California Smoothie Licensing, 31 F. 3d 1259, 1265 n.3 (3rd Cir 1994).
In its’ opinion in Freedman v Raab theThird Circuit proceeded to expand and reiterate that “the basis upon
which jurisdiction depends must be alleged affirmatively and distinctly and cannot be established
argumentatively or by mere inference” See 5C. Wright & A. Miller, Federal Practice and Procedure §1206, at
78-79 (1969 & Supp. 2005); Thomas v Board of Trustees, 195 U.S. 207, 210 (1904) (holding that diversity
jurisdiction, “or the facts upon which, in legal intendment, it rests, must be distinctly and positively averred in
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the pleadings, or should appear affirmatively and with equal distinctness in other part of the record”); Joiner
v. Diamond M Drilling Co., 677 F. 2d 1035, 1039 (5th Cir 1982) (“In order to adequately establish diversity
jurisdiction, a complaint must set forth with specificity a corporate party’s state of incorporation and its
principal place of business). “Fedco’s bald allegations that the corporate parties are citizens of certain states
are insufficient to carry its burden of pleading the diversity of the parties.”
In cases in which jurisdiction is based on diversity of citizenship, plaintiff has burden to show, first, that
applicable statute confers jurisdiction, and, second, that assertion of jurisdiction is consonant with
constitutional limitations of due
process. Weight v Kawasaki Motors Corp. (1985, ED Va) 604 F Supp 968.
Party’s mere allegation of diversity cannot satisfy its burden of establishing district court’s jurisdiction;
citizenship of each real party in interest must be established by preponderance of evidence. Roche v
Lincoln Prop. Co. (2004, CA4 Va) 373 F3d 610.
Complaint alleging that defendant’s corporate citizenship was in a state other than California but failing to
allege that plaintiffs were all citizens of California was not sufficient to give District Court jurisdiction since
pleadings did not otherwise resolve issue of citizenship. Bautista v Pan American World Airlines, Inc. (1987,
CA9 Cal) 828 F2d 546, 126 BNA LRRM 2559, 107 CCH LC P 10159.
In Olsen v Quality Continuum Hospice, Inc. (2004,DC NM) 380 F Supp 2d 1225
Court lacked jurisdiction over patient’s claims because he failed to establish diversity jurisdiction because at
time he filed complaint both he and hospice were citizens of State.
In McMann v. Doe (2006, DC Mass) 460 F Supp 2d complaint against John Doe defendant alleging
Internet defamation was dismissed for lack of subject matter jurisdiction because there was risk that if
John Doe’s identity were discovered there could have been no diversity, and court’s jurisdictional
authority would have disappeared; court declined to read amended language of 28 USCS § 1441into 28
USCS § 1332 because it would have accomplished much broader result of allowing case with only one party
and only state law claims to proceed initially in federal court Olsen v Quality Continuum Hospice, Inc.
(2004,DC NM) 380 F Supp 2d 1225.
In motorist’s personal injury lawsuit against, inter alia, owners of property adjacent to private railroad-track
crossing where car-train accident occurred, pursuant to 28 USCS § 1447(d), appellate court lacked
jurisdiction to review remand that implicitly was based on lack of subject matter jurisdiction; district court
clearly was addressing jurisdictional issues–diversity of citizenship, 28 USCS § 1332, and fraudulent
joinder–and when doing so, it properly declined to decide doubtful question of state law and, instead, resolved
ambiguity (lack of state law directly on point) in motorist’s favor. Filla v Norfolk & Southern Ry. (2003, CA8
Mo) 336 F3d 806.
Where record creates doubt as to jurisdiction, trial court must determine whether there are adequate
grounds to sustain its jurisdiction over subject matter. Shahmoon Industries, Inc. v Imperato (1964, CA3
NJ) 338 F2d 449, 9 FR Serv 2d 12B.22, Case 2.
Court has duty to look to its own jurisdiction and lack of subject matter jurisdiction may be asserted by
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court, sua sponte, at any time. Jeter v Jim Walter Homes, Inc. (1976, WD Okla) 414 F Supp 791.259.
decided by a preponderance of evidence.
In this case the Plaintiffs did not present any evidence, not a shred of evidence, showing Liberi to be a
resident of PA. Defendants have shown that according to her probation she can reside only in CA or NM, she
is subject to the jurisdiction of CA, therefore the case at hand 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. If the Federal court does
not have jurisdiction to hear the case, it is supposed to be dismissed. The court has no jurisdiction to
transfer to another Federal Court a case, where it did not have jurisdiction in the first place, as other
Federal Courts equally will not have jurisdiction.
B. APPELLEE’S ATTACKS ON THE JURISDICTION OF THE THIRD CIRCUIT COURT OF

APPEALS ARE FRIVOLOUS
Before the Appellants filed their opening brief, the Appellees filed a Motion to dismiss the Appeal, claiming
that this court has no jurisdiction to hear the appeal. Their motion was denied. Now, in their Appellee’s
response, the Appellees did not address the appeal itself and are engaged yet again in attacking the
jurisdiction of this court. This is frivolous, as the issue of the Jurisdiction of the Third Circuit Court of Appeals
to hear this brief was already decided and established. The Appellees did not bring one single case as a
precedent, supporting their position, that the District court could properly assert jurisdiction in
Diversity without the Plaintiff/Appellee submitting her identification documents, showing her state
citizenship. They did not provide any such precedents, because they simply do not exist. Instead, Appellees
are trying to confuse the court by discussing irrelevant issues and bringing precedents on irrelevant issues,
which are not on Appeal, such as Jurisdiction of the Third Circuit Court of Appeals and Venue. Similarly,
venue is not at issue, as without the jurisdiction in Federal Court system venue is irrelevant.
C. STATE CITIZENSHIP IS AT THE CORE OF THE CASE

As stated in the opening brief, the state citizenship of plaintiff Liberi is at the core of the case, as this case
was filed in the beginning of May 2009 after Defendants/Appellants published on the web site/blog of DOFF
foundation a copy of the verified criminal record of Lisa Liberi, assistant to attorney Philip J Berg, showing
that she was charged in CA in 23 counts of forgery of documents and grand theft and in 2008 was convicted
of 10 charges of forgery of documents, of forgery of the official seal and grand theft and she is currently on
probation, allowed to reside in CA or NM only. On May 4, only a few days after the publication of Liberi’s
criminal record, Berg and Liberi responded by filing their complaint, where they claimed that Lisa Liberi is a
different woman, who resides in PA, who is innocent and who was slandered and defamed by this publication.
As such, her state residence is extremely important not only for the purposes of diversity, but for the
resolution of the case. Plaintiffs cannot hide it. Taitz properly demanded to see Liberi’s PA drivers’ license.
Without any shred of evidence Liberi and Berg accused Taitz, the rest of the defendants and multiple other
individuals of committing multiple crimes, including stalking, forgery and attempt to hire a hit man to kill
Liberi. They claimed, that because of danger to her life Liberi’s drivers’ license cannot be shown. Judge
Robreno gave them an opportunity to file Liberi’s PA driver’s license under seal, Taitz agreed to accept a
redacted PA drivers’ license without the street address, with only the state information. That shows, that
nobody ever tried to hurt them. They never filed any drivers’ license with the court. The reason for not
providing Liberi’s PA drivers’ license, is not in the imaginary threats, but rather in the fact, that she does not
possess a PA drivers license, her PA residence was fraud on the court and perjury on part of Berg and Liberi,
and if they will have to provide her actual drivers license, it will show it to be either CA or NM license,
making it clear, that it is indeed the same Lisa Liberi, who was convicted in CA and allowed to reside only in
CA or NM. Additionally, Appellants filed a motion to strike and motion for sanctions against Appellees and
their attorney Berg, as without a shred of evidence Appellees repeatedly accused the Appellants of multiple
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crimes, whereby Berg showed egregious violation of the Code of professional ethics and egregious
misconduct by an attorney. Not only Berg was knowingly working with a convicted forger and thief, he
defamed innocent people and accused them of multiple serious crimes in order to cover his involvement with
a forger.
Additionally, Berg is trying to confuse this court and perpetrate his fraud further by making ambiguous
statements. P5 of the Appellees’ brief “Liberi… has not been convicted in, nor charged in, ten (10) separate
criminal cases”. At first glance it might look like she is an innocent woman, who was defamed. In reality Berg
is simply twisting the truth and the facts. As the Appendix (Appellant’s Appendix Liberi’s mug shot and
criminal record) shows, in 2008 a plea bargain was reached, where she was convicted of 10 felony counts out
of 23 charges against her in CA. Berg is saying that she was not convicted in 10 separate criminal cases,
creating an illusion that she was defamed, but it simply means, that there were 10 felony convictions within 1
case in CA. Docket document #136, also includes a transcript of a prior hearing in CA, where Detective
Liebricht testified regarding Liberi’s prior 19 criminal charges, mostly in TX.
Berg states, that Liberi’s middle name is not Renee, trying to put doubt in the minds of the Judges, to make
them believe, that she is a different person. In reality, the same criminal record shows that Liberi used 9
different aliases, where she used her prior married name Courville or maiden name Richardson or short for
Richardson- “Rich” or combination thereof as a middle name instead of her middle name Renee, sometimes
she used only letter R. Berg is trying to create an illusion of Liberi being a different person, while he knows
that she is indeed the same person, who was convicted in CA, and who is not allowed to reside in PA, he is
continuously and egregiously violating the requirement of candor before the tribunal and continuously and
repeatedly is defrauding the court. On the other hand
Defendants/ Appellants provided witness identification (Appendix to the opening brief, Affidavits of Ed Hale
and Caren Hale), stating that Lisa Liberi, who appeared in PA before judge Robreno, is indeed the same Lisa
Liberi, who is shown on the attached mug shots of Lisa Liberi, convicted in CA.
.Appellants, provided transcripts from CA, showing that Liberi’s mother, Shirley Waddell, who was filing
hundreds of pages of affidavits in PA in Liberi v Taitz, in support of her daughters legal action for defamation
and slander, claiming that her daughter is an innocent woman who was defamed and slandered by this
monster Attorney Orly Taitz, was actually the same Shirley Waddell, who paid bail bond premium to bail her
daughter out of prison in CA. (Appendix to Appellants’ opening brief, 2004 Superior Court of CA, San
Bernardino County transcript of the bail bond hearing of Lisa Liberi). Additionally, Taitz provided signature
samples from CA, showing that the same signature was used by Liberi to sign her motions in her criminal case
in CA. (Document 145, reply to opposition to Motion). Considering the fact, that Liberi’s state citizenship is
at the core of the case, the court had a heightened obligation to make sure that the Appellees provide Liberi’s
drivers’ license and prove her state citizenship. The court erred in not demanding such compliance and in
ignoring all the evidence, provided by the defendants.
D. APPELLEES COMMITTED FRAUD ON THE COURT AND PERJURY BY CLAIMING THAT

THEY PROVIDED LIBERI’S DRIVERS LICENSE TO JUDGE ROBRENO
a. In his response attorney Berg claims that he showed Judge Robreno Liberi’s Driver’s license, that Judge
Robreno’s decision to assume jurisdiction is based on the driver’s license, submitted to court on 08.07.09.
This statement constitutes fraud on this court. Transcript of 08.07.09 hearing states, that Berg asked Judge
Robreno, if he can provide Liberi’s license under seal, however the transcript does not state, that Berg
actually ever provided it.
b. Examination of the transcript shows, that there are no documents attached to it at all. There is no license
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under seal or not under seal. There is no notation from a court reporter, stating, that any documents were
given by Liberi or Berg to judge Robreno, there is only a promise by Liberi to provide her identifying
documents at some later time.
c. Affidavit of Ed Hale (Appellants’ appendix) states, that the plaintiffs did not provide Judge Robreno with
any documents and that they left the court room the same time as the defendants. He also states, that Lisa
Liberi, who appeared at the hearing in PA in front of Judge Robreno, is the same Lisa Liberi, as depicted on
the mug shot from CA.
d. . Affidavit of Caren Hale (Appellants appendix) states, that the plaintiffs did not provide Judge Robreno
with any documents and that they left the court room the same time as the defendants. He also states, that
Lisa Liberi, who appeared at the hearing in PA in front of Judge Robreno, is the same Lisa Liberi, as depicted
on the mug shot from CA
e. If arguendo Berg, who is a PA attorney, went to Judge Robreno at some later time and showed him some
document, some driver’s license, it would be an impermissible ex-parte communication and it violated the
rights of the defendants for an impartial hearing, particularly in light of the fact that Lisa Liberi has multiple
convictions for forgery of documents, and it is more likely than not that if Berg ever showed any document to
judge Robreno, it was a forged document. The defendants were entitled to see any documents provided by
Berg to Judge Robreno, examine those documents and make sure those documents were not forged. As
stated, there are no identifying documents anywhere on the docket. Berg, also, refers to statements by Kelly
Strebel, who is an unemployed truck driver in Utah and Evelyn Adams, aka Momma E, a retiree in OK, who
are claiming, that Liberi does not reside in CA or TX. No foundation was ever provided, as to how do they
know, where Liberi resides. Anybody can state anything. Their statements do not satisfy the best evidence
rule. Adams is a party to this action, Strebel is Liberi’s and Berg’s supporter and volunteer. State residence
needs to be established by proper identifying documents such as a drivers license. Judge Robreno requested it
during 08.07.09 hearing, Liberi and Berg promised to submit it and file under seal, but never submitted it.
There are no identifying documents anywhere in the file of this case, therefore the case has to be dismissed,
as Liberi’s state citizenship was never established.
E. APPELLEES DISCUSSION OF VENUE IS IRRELEVANT AND WAS DONE IN ORDER TO

CREATE CONFUSION, AS AT ISSUE IS THE FACT, THAT THERE WAS NO JURISDICTION FOR
FEDERAL COURT TO SIT IN DIVERSITY, REGARDLESS OF VENUE
Berg is trying to simply confuse this court by discussing venue. The venue is not at issue. Before venue is
discussed, at issue is jurisdiction. Did the federal court have any jurisdiction to sit in diversity and hear this
case. For purpose of diversity the plaintiffs had to provide evidence of citizenship of each and every party
and show it by preponderance of evidence. The Plaintiffs did not provide one single document, that it
evidentiary of Plaintiff Liberi’s state citizenship. The docket shows no evidence: there is no Pennsylvania
driver’s license anywhere in this docket. In order to cover up the fact, that there is no driver’s license,
plaintiffs made up outrageous slanderous accusations and committed fraud on the court and perjury by
accusing defendant Taitz of trying to hire a hit man to kill Liberi. This is an outrageous behavior by a
licensed attorney Berg. Taitz filed a separate motion to sanction attorney Berg for filing with court
accusations of capital crimes with the sole purpose of harassment of defendants. As no evidence of state
residence was ever provided, venue is irrelevant. the federal court system has no jurisdiction over this case
regardless of venue.
F. PUBLIC POLICY CONSIDERATIONS

This issue is so important, that it has to be decided by the court of Appeals and even Supreme Court, if need
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be. It is simply insane to believe, that a criminal can make up a story, harass whistle blower’s with a frivolous
law suit, make up outrageous allegations, that the victims are threatening this criminal , that any and all
evidence needs to be sealed because of an imaginary accusation, and based upon that, a judge makes a
decision without any shred of evidence. If this standard is allowed to stand, than it is de facto the end to the
system of Justice. It means, that any time anyone can accuse anybody of crimes and demand that the court
make a finding of fact based on such insane allegations of imaginary threats. Additionally, in this case Berg
has filed multiple motions, seeking a temporary restraining order to keep the case sealed. All of such motions
were denied by both the District court and the Third Circuit Court of Appeals. If the courts did not find any
value in Appellees claims of threats, than it was an error for Judge Robreno not to demand Lisa Liberi’s PA
driver’s license and not to provide it to the defendants in order to show Liberi’s citizenship for the purposes of
diversity.
G. APPELLEES ARE MISREPRESENTING THE ISSUES ON APPEAL IN RELATION TO THE

DISMISSAL OF THE DEFENDANTS JAMES SUNDQUIST AND SALT ROCK PUBLISING.
James Sundquist in his pleadings and during 06.25.09 hearing before Judge Robreno repeatedly demanded to
have his motion to dismiss to be decided with prejudice. Both Appellants, who are CA residents, and James
Sundquist, NJ resident, in their pleadings and during the hearing requested for the court to ascertain the
residency of each party and to rule with prejudice. Judge Robreno never demanded proof of Liberi’s PA
residence and refused to rule with prejudice. Instead, during the hearing, he repeatedly applied pressure on
James Sundquist to agree to be dismissed without prejudice. Defendants already incurred expenses in
preparing responsive pleadings and traveling to PA. If Judge Robreno were to demand proof of Liberi’s state
residence on June 25, 2009, the case would have ended then and there, as Liberi and Berg had nothing to
show. Instead, Judge Robreno dismissed James Sundquist without prejudice and left him unable to collect
from Berg and plaintiffs and he left Sundquist exposed to further harassment form Berg, if Sundquist were to
speak up the truth about Berg and Liberi. Additionally, Judge Robreno allowed Berg to continuously terrorize
all of the defendants with slander by the Plaintiffs and Berg for a year and a half. The Appeal does not state
that judge Robreno had no discretion, it stated, that he acted with bias in favor of local attorney Berg and his
clients, even though Berg and his clients were clearly committing fraud on the court and perjury, the Appeal
states that judge Robreno abused his judicial discretion. Dismissal of Sundquist is part and parcel of the
issue of diversity, that was brought back by Judge Robreno after he lifted his order of suspension on
June 4, 2010. Additionally, Taitz was waiting resolution of Berg’s appeal, which he filed in August of 2009
with the Third Cicuit Court of Appeals and which he withdrew only in April of 2010, after an order to show
cause was issued by the Third Circuit Court of Appeals, and she was subject to order of suspension of the
case imposed by judge Robreno on 12.11.09 and lifted only on 06.04.10. Therefore, her appeal was timely
and proper.
Appellees made another fraudulent statement, claiming, that James Sundquist did not respond in writing.
Docket entry No 68 clearly shows, that on 06.24.09 James Sundquist together with Taitz filed a response in
opposition to Plaintiffs “ex Parte” motion to leave to dismiss, to “drop” defendants James Sundquist and
Rock Salt Publishing without prejudice. This is only one very vivid example, demonstrating how attorney
Berg continuously commits fraud on the court and simply enters in his pleadings fraudulent statements.
H. FRAUD ON THE COURT BY BERG AND LIBERI COMMITTED, AS NO IDENTIFICATION
DOCUMENTS WERE PROVIDED.
In their 11. 07.10 pleadings Appellees stated, that they simply showed judge Robreno Liberi’s driver’s license
and the finding that Liberi is a resident of PA was made based on the fact, that Liberi and her attorney Berg
showed her driver’s license during the hearing. This is a complete fraud on the court and is contradicted by
sworn affidavits of ED and Caren Hale and by the transcript itself. The transcript on page 19
“Mr. Berg: … her actual address I think would be detrimental
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The Court: “Well, the actual address we could do without it.
Mr. Berg: Okay. could that be on other people, too, or just on Miss Liberi?
The court: Well you could disclose it and file it with the court under seal.”
on page 47 of the transcript of the same hearing during direct examination of Liberi by Berg:
“Q. You heard my statement before. You will supply your correct address and identifying information which
we will give the court under seal, is that correct?
A Yes, sir.”
So both the sworn affidavits of Ed and Caren Hale and the transcript of the hearing show, that Liberi and
Berg did not show Judge Robreno any documents during the hearing. They both stated, that at some later time
they would provide Liberi’s identifying information under seal, however the transcript and the docket
(Appellants appendix) do not show any identifying information ever provided to the court, neither with the
transcript, nor at any time later. Berg and Liberi simply defrauded the court. They wanted her information
hidden, as they knew, that she was not residing in PA and this whole lawsuit was filed with the sole purpose to
harass. Judge Robreno denied Berg’s motion for temporary restraining order. Berg appealed to the Third
Circuit Court of Appeals and filed multiple emergency motions and requests for judicial notices. All were
denied by this court. The Third Circuit court of Appeals issued an order to show cause to Berg, why he did
not provide the copy of the transcript of the above hearing, that he was appealing. Berg knew, that his fraud
on the court is about to be discovered, the Third Circuit Court of Appeals will see, that Berg and Liberi
promised to file Liberi’s identifying documents, but never did it, so Berg abruptly withdrew his appeal of the
08.07.09 ruling. He demanded to transfer the case to CA. By that time, it was a year since the case was
originally filed, and ten months since 08.07.09 hearing, there were thousands of pages filed by Berg, so quite
possibly Judge Robreno did not remember or did not notice, that Berg never filed Liberi’s identifying papers,
so Judge Robreno issued an order to sever and transfer the case and noticed in his memorandum, that Liberi is
a resident of PA, probably believing that Berg was telling the truth and at some point filed the documents,
which of course was never done. At that point Taitz filed an appeal, as she knew, that no identifying
documents were ever filed. On 09.04.10. Taitz filed a motion with Judge Robreno “Motion-request for
missing documents”. Taitz was specifically asking for Liberi’s identifying documents. On 10.29.10 Judge
Robreno issued an order “That all future motions need to be addressed to the Third Circuit”. Request for
missing documents was denied without prejudice”. As such the transcript and the docket clearly show, that
Berg and Liberi were supposed to supply Liberi’s correct address and identifying information and provide it
to the court under seal, however they never did it. They defrauded the District Court and the Third Circuit
court of Appeals. They wasted hours and hours of time of two courts, they inflicted enormous financial
damage and enormous emotional distress, however, they knew full well, that they never provided any
identifying information. They acted in an egregious manner, accusing numerous innocent individuals of
multiple serious crimes, they caused an elderly individual Ed Hale to suffer a heart attack and they brought
many others to the brink of a heart attack, yet they knew all along, that they are committing an egregious
fraud.
This is the reason, why the Defendants/Appellants are asking not only for a dismissal of the case, but also for
severe sanctions against the plaintiffs and Attorney Berg.
I. JUDGE ROBRENO’S FINDINGS WENT TO THE CORE OF THE CASE AND WERE IMPROPER
TO BE MADE WITHOUT THE EVIDENCE
As stated previously, the core of the case, is Liberi’s claim, that she is a different Liberi, not one convicted in
CA, but one residing in PA. When Judge Robreno included in his 06.04.10 order and memorandum a
Exhibit "94"
Pg. 711
11 of 16 5/2/2011 2:01 AM
#:5218
statement, that “Lisa Liberi is a resident of Pennsylvania” he not only made a finding of jurisdiction, he made
a finding essential to the case, as Liberi claims to be a different person. Defendants are entitled to see the
evidence, based on which he made such a determination.
J. APPELLANTS REQUEST FOR SANCTIONS IS PROPER AND SUPPORTED BY FACT AND

LAW AND NECESSARY TO STOP EGREGIOUS MISCONDUCT BY BERG AND THE PLAINTIFFS
Case at hand is a $800 million legal action for Slander and Defamation of character, where Plaintiffs claimed
that the defendants/appellants defamed Berg and his legal assistant Liberi by “false criminal accusations”
(p77 Verified complaint Liberi v Taitz.) P66 of the complaint states, that “the defendants …”made false
statements about Liberi, claiming she had a criminal record of convictions”. Appellees claimed that Liberi is a
resident of PA, who was placed in false light. P75 of the complaint states “Plaintiffs and their businesses
have invested considerable effort and expense in establishing goodwill in their names and in promoting their
careers and professional reputation. Liberi in promoting her profession as a skillful and highly competent
Legal Assistant and Paralegal. Beg in promoting his profession as skillful and highly competent provider as a
prominent attorney with a professional staff and law firm”. They claimed that they were defamed by Taitz
publication of the record of Liberi’s criminal convictions of forgery and theft in CA. Taitz rightfully
demanded to see Liberi’s PA drivers’ license as a proof, that she is a different person. Berg filed a frivolous
action for $800 million dollars to simply cover up for the fact, that he works with a convicted forger and
thief. Taitz submits an article from “Legal Intellegencer’, showing that Berg repeatedly engages in such
conduct. Berg was previously repeatedly sanctioned.
In Re Berg, 2008 Bankr. LEXIS 322 (ED PA 2008);
Holsworth v. Berg
, 2005 U.S. Dist. LEXIS 15393 (ED PA 2005). Liberi has engaged in the same conduct as
well.
A July 25, 2005 article from The Legal Intelligencer, “Lawyer Slapped With $10K in Sanctions for ‘Laundry
List of Unethical Actions’ sums the situation here up:
“Finding that a Pennsylvania lawyer had committed a “laundry list of unethical actions,” a federal judge has
imposed more than $10,000 in sanctions and ordered the lawyer to complete six hours of ethics training. U.S.
District Judge J. Curtis Joyner’s 10-page opinion in Holsworth v. Berg is packed with criticism of the conduct
of attorney Philip Berg of Lafayette Hill, Pa.”Other attorneys should look to Mr. Berg’s actions as a blueprint
for what not to do when attempting to effectively and honorably perform the duties of the legal profession,”
Joyner wrote. “This court has grown weary of Mr. Berg’s continuous and brazen disrespect toward this court
and his own clients. Mr. Berg’s actions … are an enormous waste of judicial time and resources that this court
cannot, in good conscience, allow to go unpunished,” Joyner wrote. In the suit, Berg is accused of legal
malpractice by former clients who claim his failure to respond to an ERISA claim against them led to a default
judgment. But the sanctions against Berg stem from his decision to file a third-party counterclaim of fraud
against a pension fund that had sued his former clients, according to court papers. Joyner blasted Berg for
filing the fraud claim, calling it an “irresponsible decision” because the claim was “utterly barren of any
scintilla of legal principles.” Berg’s motion was rejected and a default judgment of more than $5,300 was
entered against his clients. The judgment swelled to more than $10,000 when Carpenters Health later
successfully moved for a supplemental judgment to recover more than $4,700 in attorney fees for its efforts in
responding to Berg’s untimely motions. Holsworth and his wife later filed a legal malpractice suit against Berg
in the Philadelphia County Court of Common Pleas, alleging that Berg negligently failed to represent them in
the Carpenters Health case. A year later, in February 2005, Berg moved to join Carpenters Health as a
third-party defendant in the malpractice suit, demanding more than $20,000 in damages. In his counterclaim,
Berg alleged that the ERISA suit filed by Carpenters Health in 2001, which led to the malpractice claim
against him, was “a fraud upon the court and a fraudulent taking from the Holsworths.”Carpenter Health’s
lawyers removed the case to federal court and filed a motion to dismiss the claim.Joyner agreed, finding that
Berg’s fraud claim was “frivolous” and was motivated by an intent “to harass Carpenters Health and the
Holsworths, as well as to delay and disrupt the administration of justice.” The claim was fatally flawed,
Joyner found, because Berg had no standing to bring suit against Carpenters Health and had “failed to
Exhibit "94"
Pg. 712
12 of 16 5/2/2011 2:01 AM
#:5219
conduct even a minimally reasonable inquiry before filing his complaint.” Granting summary judgment in
favor of Carpenters Health, Joyner said he found it “wholly unnecessary” even to consider the facts of the
ERISA case because it was “abundantly clear” that Carpenters Health was entitled to a judgment as a matter
of law. Joyner invited Carpenters Health to file a motion for Rule 11 sanctions. When it did, Joyner found that
Berg “continued his trend of unprofessional conduct “… “Berg’s fraud claim, Joyner said, was “inadequately
pled, not grounded in fact, time-barred, and utterly irrelevant to the pending malpractice action against
him.”…”In his sanctions order, Joyner ordered Berg to reimburse Carpenters Health the $10,668 in attorney
fees and costs it incurred in defending the claim. He also ordered Berg to complete six credits of ethics
courses certified by the Pennsylvania Board of Continuing Legal Education, and recommended that Berg be
investigated by the Pennsylvania Bar Association’s Committee on Legal Ethics and Professional
Responsibility.”
At the same time, in 2005-2006, when Liberi was incarcerated, she filed a frivolous RICO law suit for $280
million against the San Bernardino County, CA, West Valley Correctional facility, district attorneys, police
officers, police detectives, numerous law enforcement officials Lisa Liberi v West Valley Center et al 2:05-cv-
03015-VAP-SGL. In a similar modus operandi she accused multiple innocent individuals of committing
crimes. Her legal action was dismissed. Both Liberi and Berg have a history and modus operandi of filing
multimillion dollar law suits for the sole purpose of harassment. They caused immeasurable financial and
emotional damage to the defendants and they need to be stopped now. This court has inherent powers to
punish egregious misconduct by an attorney and Appellees. Dismissal of underlying legal action, sanctions,
award of attorneys’ fees and costs to the Appellants are appropriate. Sanctions in the form of reporting Philip
J Berg to the Disciplinary Board of the PA Supreme Court for sanctions or disbarment, as well as reporting of
Lisa Liberi to the San Bernardino, CA probation department for revocation of her probation and her return
to incarceration to serve her eight year prison term, will be appropriate in this case.
CONCLUSION
Appellees never provided any proof of Appellee Liberi’s PA state residency that they claim, that she had. The
Court erred, and abused its judicial discretion in assuming jurisdiction over the case without any evidence of
State Citizenship of Plaintiff Liberi. The Court also erred in refusing James Sundquist opposition-motion.
Court erred in completely ignoring multiple letters from
Defendant Belcher, where she stated, that she was not served with pleadings by the Plaintiffs.
As the State citizenship of the lead Plaintiff was never established by the court, the District Court had no
jurisdiction in diversity and the case needs to be dismissed due to lack of subject matter jurisdiction.
DATED: November 21, 2010
__/s/ Dr. Orly Taitz, ESQ_______
Dr. Orly Taitz, ESQ Appellant in Pro Se and as

Counsel for Appellant Defend Our Freedoms Foundation
ATTORNEY’S CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the:
APPELLANTS REPLY
was served by ECF and ELECTRONIC MAIL on November 22,, 2010, on the following parties:
Exhibit "94"
Pg. 713
13 of 16 5/2/2011 2:01 AM
#:5220
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
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
Exhibit "94"
Pg. 714
14 of 16 5/2/2011 2:01 AM
#:5221
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444_2531
(610) 825_3134
FAX (610) 834_7659
E_Mail: philjberg@gmail.com
Disciplinary Board
Supreme Court of Pensylvania
820 Adams Ave, ste 170
Trooper, PA 19403
Philadelphia District Attorneys’ office
3 South Penn square
Philadelphia, PA
US Attorneys’ office
Eastern District of PA
615 Chestnut str, ste 1250
Philadelphia PA 19106-4100
James Secord
Assistant District attorney
San Bernardino County
316 North Mountain view
San Bernardino CA 92415-0004
909-387-8309
www.co.san-bernardino.ca.us/da
San Bernardino County, CA
Probation Department
175 w. Fifth str. 4th floor
S. Bernardino, CA
Exhibit "94"
Public Integrity Section
Pg. 715
15 of 16 5/2/2011 2:01 AM
#:5222
Department of Justice
950 Pennsylvania Ave, NW
Washington DC 20530-0001
Office of the United Nations High Commissioner for Human Rights (OHCHR)
Special Rapporteur on the Situation of Human Rights Defenders
The Honorable Mrs. Margaret Sekaggya
Palais des Nations
CH-1211 Geneva 10, Switzerland
International Criminal bar Hague
United Nations Commission for
Civil Rights Defenders
Orsolya Toth (Ms)
Human Rights Officer
Civil and Political Rights Section
Special Procedures Division
Office of the High Commissioner for Human Rights
tel: + 41 22 917 91 51
email: ototh@ohchr.org
/S/ Dr. Orly Taitz, ESQ
___________________________
Dr. Orly Taitz, Esq
11.22.10
Category: Uncategorized
Comments
One Response to “Submitted yesterday in the Third Circuit Court of Appeals”
1. F.A. Leonetti
November 23rd, 2010 @ 10:46 am
Some may find this a bit off the wall, but I enjoy reading legal briefs, and quite frankly, this rates and
Exhibit "94"
Pg. 716
16 of 16 5/2/2011 2:01 AM
#:5223
EXHIBIT “95”
#:5224
Exhibit "95"
Pg. 717
In spite of nearly 500 pages of horrific defamation of my character by Phil... http://www.orlytaitzesq.com/?p=16425
VIDEOS
Home


THERE IS TYRANNY.
THERE IS LIBERTY.
- Thomas Jefferson
In spite of nearly 500 pages of horrific defamation

of my character by Philip J. Berg, Lisa Liberi, her
mother Dorothy Waddell and the rest of their
accomplices, Third Circuit Court of Appeals denied
their motion for restraining order against me. I am
free to post this truthful information, showing that
Lisa Liberi, assistant for attorney Philip J. Berg, is
Exhibit "95"
Pg. 718
1 of 10 5/2/2011 2:11 AM
#:5226
a convicted document forger and thief, who got 8
year prison term in CA in 2008, and who is
currently on probation. The question remains: why
is licensed attorney Berg continuously working with
a convicted forger Liberi and submitting
documents to multiple courts ans viciously
attacking me and other innocent individuals?
Posted on | December 12, 2010 | 3 Comments
Exhibit "95"
Pg. 719
2 of 10 5/2/2011 2:11 AM
#:5227
Exhibit "95"
Pg. 720
3 of 10 5/2/2011 2:11 AM
#:5228
Case FWV028000 – Defendants
Seq Defendant Next Court Date Status Agency / Arrest Date Count 1 Charge Violation Date
DR Number
RA
1 LIBERI , LISA R 05/18/2001 PC 115(A) 05/18/2001
110013759
ALIAS: LIBERI, LISA R
ALIAS: COURVILLERICHARDSON, LISA
ALIAS: LIBERI, LISA A
ALIAS: RICHARDSON, LISA C
ALIAS: COURVILLERICH, LISA
ALIAS: LIBERI, LISA RENEE
ALIAS: LIBERI, LISA
ALIAS: RICHARDSON, LISA RENEE
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Status
Custody N/A
Filing Type Held to Answer Filing Date 05/09/2003
Ordered Bail $0.00 Posted Bail $0.00
D.A. James R. Secord Defense Dean Pitcl (Court Appointed)
Next Action: Deputy Report #: RA-RC 110013759
Warrant Type Status Issued Affidavit

NONE N/A N/A
Probation Type Granted Expiration
Formal 03/21/2008 03/21/2011
Sentence Convicted Date County Jail CTS
01/25/2008 26 Days 26 Days
State Prison Max Sentence
N/A N/A
Fine and Penalty Restitution Fine Restitution to Victim
0 N/A
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Charges
Arrest Charges
Violation
Date
1 PC 459 F BURGLARY 05/18/2001

Filed Charges
Violation
Date
Exhibit "95"
Pg. 721
4 of 10 5/2/2011 2:11 AM
#:5229
GRAND THEFT: PROPERTY/ETC

1 PC 487(A) F 05/18/2001 HTA
OVER $400
2 PC 470(D) F FORGERY 05/18/2001 HTA
4 PC 115(A) F 05/18/2001 HTA
INSTRUMENT TO FILE
5 PC 487(A) F 05/18/2001 HTA
OVER $400
6 PC 470(D) F FORGERY 05/18/2001 HTA
8 PC 115(A) F 05/18/2001 HTA
INSTRUMENT TO FILE
9 PC 487(A) F 05/18/2001 HTA
OVER $400
10 PC 487(A) F 05/18/2001 HTA
OVER $400
PC GRAND THEFT:
11 F 05/18/2001 HTA
12 PC 487(A) F 05/18/2001 HTA
OVER $400
PC GRAND THEFT:
13 F 05/18/2001 HTA
14 PC 487(A) F 05/18/2001 HTA
OVER $400
PC GRAND THEFT:
15 F 05/18/2001 HTA
16 PC 487(A) F 05/18/2001 HTA
OVER $400
17 PC 487(A) F 05/18/2001 HTA
OVER $400
Infor Charges
Violation
Date

OVER $400
PC
2 F NONSUFFICIENT FUNDS: CHECKS 05/18/2001 GUILTY CONVICTED
476A(A)
INSTRUMENT TO FILE
OVER $400
Exhibit "95"
Pg. 722
5 of 10 5/2/2011 2:11 AM
#:5230
MAKING, POSSESSING, UTTERING
7 PC 476 F 05/18/2001 DISMISSED
FICTIOUS INSTRS
9 PC 472 F FORGE OFFICIAL SEAL 05/18/2001 GUILTY CONVICTED
10 PC 115(A) F 05/18/2001 DISMISSED
INSTRUMENT TO FILE
OVER $400
OVER $400
PC GRAND THEFT:
14 PC 487(A) F 05/18/2001 DISMISSED
OVER $400
PC GRAND THEFT:
16 PC 487(A) F 05/18/2001 DISMISSED
OVER $400
PC GRAND THEFT:
OVER $400
OVER $400
INSTRUMENT TO FILE
Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Probation
Probation Type: FORMAL Granted: 03/21/2008 Expire: 03/21/2011
SUPERVISED PROBATION GRANTED FOR A PERIOD OF 36 MONTHS ON FOLLOWING TERMS

AND CONDITIONS:
SERVE 26 DAYS IN A SAN BERNARDINO COUNTY JAIL FACILITY, WITH CREDIT FOR
TIME SERVED, A MATTER OF 26 DAYS, PLUS CONDUCT CREDIT PURSUANT TO
1)
1-PC4019 ND ABIDE BY ALL RULES AND REGULATIONS OF THE FACILITY WITHOUT
THE POSSIBILITY OF COUNTY PAROLE.
2) VIOLATE NO LAW.
REPORT TO THE PROB OFFICER IN PERSON IMMEDIATELY 0- ND THEREAFTER ONCE
EVERY FOURTEEN (14) DAYS OR AS DIRECTED. REPORT TO THE PROB OFFICER IN
3)
PERSON IMMEDIATELY 0- ND THEREAFTER ONCE EVERY FOURTEEN (14) DAYS OR
AS DIRECTED.
Exhibit "95"
Pg. 723
6 of 10 5/2/2011 2:11 AM
#:5231
COOPERATE WITH THE PROBATION OFFICER IN A PLAN OF REHABILITATION AND
4)
FOLLOW ALL REASONABLE DIRECTIVES OF THE PROBATION OFFICER.
SEEK AND MAINTAIN GAINFUL EMPLOYMENT, OR ATTEND SCHOOL, AND KEEP THE
5)
PROBATION OFFICER INFORMED OF STATUS OF EMPLOYMENT, OR SCHOOL.
KEEP THE PROBATION OFFICER INFORMED OF PLACE OF RESIDENCE AND
COHABITANTS AND GIVE WRITTEN NOTICE TO THE PROBATION OFFICER
TWENTY-FOUR (24) HOURS PRIOR TO ANY CHANGES. PRIOR TO ANY MOVE PROVIDE
WRITTEN AUTHORIZATION TO THE POST OFFICE TO FORWARD MAIL TO THE NEW
ADDRESS. PERMIT VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGENTS OF
THE PROBATION DEPT. AND/OR LAW ENFORCEMENT FOR THE PURPOSE OF
ENSURING COMPLIANCE WITH PERMIT VISITS AND SEARCHES OF PLACES OF
RESIDENCE BY AGENTS OF THE PROBATION DEPT. AND/OR LAW ENFORCEMENT
FOR THE PURPOSE OF ENSURING COMPLIANCE WITH PERMIT VISITS AND
SEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THE PROBATION DEPT.
AND/OR LAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCE WITH
6)
THE TERMS AND CONDITIONS OF PROBATION; NOT DO ANYTHING TO INTERFERE
WITH THIS REQUIREMENT, OR DETER OFFICERS FROM FULFILLING THIS
REQUIREMENT, SUCH AS THE TERMS AND CONDITIONS OF PROBATION; NOT DO
ANYTHING TO INTERFERE WITH THIS REQUIREMENT, OR DETER OFFICERS FROM
FULFILLING THIS REQUIREMENT, SUCH AS ERECTING ANY LOCKED FENCES/GATES
THAT WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE ANY ANIMALS ON
THE PREMISES THAT WOULD REASONABLY DETER, ERECTING ANY LOCKED
FENCES/GATES THAT WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE
ANY ANIMALS ON THE PREMISES THAT WOULD REASONABLY DETER, THREAT
THREATEN THE SAFETY OF, OR INTERFERE WITH, OFFICERS ENFORCING THIS
TERM. EN THE SAFETY OF, OR INTERFERE WITH, OFFICERS ENFORCING THIS TERM.
NEITHER POSSESS NOR HAVE UNDER YOUR CONTROL ANY DANGEROUS OR DEADLY
7)
WEAPONS OR EXPLOSIVE DEVICES OR MATERIALS TO MAKE EXPLOSIVE DEVICES.
SUBMIT TO A SEARCH AND SEIZURE OF YOUR PERSON, RESIDENCE AND/OR
PROPERTY UNDER YOUR CONTROL AT ANY TIME OF THE DAY OR NIGHT BY ANY
LAW-ENFORCEMENT OFFICER, WITH OR WITHOUT A SEARCH WARRANT, AND WITH
OR WITHOUT CAUSE (PEOPLE -V- BRAVO).
NEITHER USE NOR POSSESS ANY CONTROLLED SUBSTANCE WITHOUT MEDICAL
9) PRESCRIPTION. A PHYSICIANS’S WRITTEN NOTICE IS TO BE GIVEN TO THE
PROBATION OFFICER.
SUBMIT TO A CONTROLLED SUBSTANCE TEST AT DIRECTION OF PROBATION
10) OFFICER. EACH TEST IS SUBJECT TO AN $11.00 FEE, TO BE COLLECTED BY CENTRAL
COLLECTIONS
11) NOT POSSESS ANY TYPE OF DRUG PARAPHERNALIA, AS DEFINED IN H&S11364.5(D)
PARTICIPATE IN A COUNSELING PROGRAM AS DIRECTED BY THE PROBATION
OFFICER, SUBMIT MONTHLY PROOF OF ATTENDANCE AND/OR SUCCESSFUL
12)
COMPLETION TO THE PROBATION OFFICER AS DIRECTED AND BE RESPONSIBLE
FOR PAYMENT OF ALL PROGRAM FEE(S).
NOT ASSOCIATE WITH KNOWN CONVICTED FELONS OR ANYONE ACTIVELY
13)
ENGAGED IN CRIMINAL ACTIVITY B-OR CODEFENDANT(S) OR VICTIM(S).
NOT ASSOCIATE WITH KNOWN ILLEGAL USERS OR SELLERS OF CONTROLLED
14)
SUBSTANCES,
NOT MAINTAIN A CHECKING ACCOUNT OR COMPLETE OR ENDORSE ANY CHECKS
15) UNLESS MADE PAYABLE TO YOU AND NOT HAVE ANY BLANK CHECKS IN YOUR
POSSESSION WITHOUT PERMISSION OF THE PROBATION OFFICER.
Exhibit "95"
Pg. 724
7 of 10 5/2/2011 2:11 AM
#:5232
SUBMIT A RECORD OF INCOME AND EXPENDITURES TO THE PROBATION OFFICER
16)
QUARTERLY.
NEITHER POSSESS NOR USE ANY CREDIT CARD WITHOUT PERMISSION OF THE
17)
PROBATION OFFICER.
NOT DRIVE OR POSSESS KEYS OR DOCUMENTATION TO ANY MOTOR VEHICLE
18) UNLESS LEGALLY REGISTERED TO YOU OR AN IMMEDIATE FAMILY MEMBER,
EXCEPT IN THE COURSE OF EMPLOYMENT.
REPORT ALL MOTOR VEHICLES REGISTERED TO YOU TO THE PROBATION OFFICER
19)
WITHIN SEVEN (7) DAYS OF ACQUISITION.
SUBMIT TO AND COOPERATE IN A FIELD INTERROGATION BY ANY PEACE OFFICER
20)
AT ANY TIME OF THE DAY OR NIGHT.
CARRY AT ALL TIMES A VALID DRIVERS LICENSE OR DEPARTMENT OF MOTOR
VEHICLES IDENTIFICATION CARD AND DISPLAY SUCH IDENTIFICATION UPON
21)
REQUEST BY ANY PURPOSE WITHOUT FIRST NOTIFYING THE PO. CONTAINING YOUR
TRUE NAME AGE AND CURRENT ADDRESS
ENROLL IN THE DRUG TREATMENT PROGRAM AT THE DIRECTION OF THE
22) PROBATION OFFICER, AND SHOW PROOF OF ENROLLMENT TO THE PROBATION
OFFICER WITHIN SEVEN (7) DAYS.
MAKE RESTITUTION TO THE VICTIM(S) (SEE PROBATION REPORT) IN THE AMOUNT
23) OF $9223.77 PLUS A 10% ADMINISTRATIVE FEE, TO BE PAID THROUGH CENTRAL
COLLECTIONS
MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORT) IN THE AM OUNT OF
24) $35000.00 PLUS A 10% ADMINISTRATIVE FEE, TO BEPAID THROUGH CENTRAL
COLLECTIONS
MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORT) IN THE AMO UNT OF
COLLECTIONS
PAY A RESTITUTION FINE IN THE AMOUNT OF $200.00, PLUS A TEN PERCENT (10%)
26)
ADMINISTRATIVE FEE THROUGH CENTRAL COLLECTIONS.
THE DEFENDANT IS NOT TO FILE ANY LAWSUIT/LEGAL ACTION WITHOUT PRIOR
27)
CONTACT WITH PROBATION OFFICER.
DO NOT APPLY FOR CREDIT OR A LOAN WITHOUT PRIOR CONTACT WITH
28)
PROBATION OFFICER.
29) COMPLY WITH ANY COURT-ORDERED PAYMENT SCHEDULE.
30)
31)
PROBATION MAY BE SERVED THROUGH INTER STATE COMPACT AGREEMENT IN THE
32)
STATE OF NEW MEXICO UPON APPROVAL FROM PROBATION.
Exhibit "95"
Pg. 725
8 of 10 5/2/2011 2:11 AM
#:5233
Exhibit "95"
Pg. 726
9 of 10 5/2/2011 2:11 AM
#:5234
Category: HOT ITEMS!, Latest News, Legal Actions
Comments
3 Responses to “In spite of nearly 500 pages of horrific defamation of my character by Philip J. Berg, Lisa
Liberi, her mother Dorothy Waddell and the rest of their accomplices, Third Circuit Court of Appeals denied
their motion for restraining order against me. I am free to post this truthful information, showing that Lisa
Liberi, assistant for attorney Philip J. Berg, is a convicted document forger and thief, who got 8 year prison
term in CA in 2008, and who is currently on probation. The question remains: why is licensed attorney Berg
continuously working with a convicted forger Liberi and submitting documents to multiple courts ans
viciously attacking me and other innocent individuals?”
December 12th, 2010 @ 2:22 pm
no, within an hour they cancelled the remand and mandate. There is only denial of their motion
2. Politijabber
December 12th, 2010 @ 4:53 pm
You think publishing this is without legal consequence?
December 13th, 2010 @ 9:15 am
the only legal consequence is disbarrment of Philip J. Berg for fraud on the court and perjury and filing
this legal action for the purpose of harassment of me
!! IMPORTANT NOTICES – PLEASE READ !!
NEW! CA REP CENTRAL COMMITTEE LIST

CAMPAIGN FLIER for Orly Taitz as CA SOS
CAMPAIGN FLIER for Orly Taitz as CA SOS, 2 Per Page
How to contact public Integrity unit
See The PDF File Here
US Department of Justice has a special unit in their Criminal Division called the
PUBLIC INTEGRITY SECTION
Contact Orly!
email: dr_taitz@yahoo.com Urgent? Call: 949-683-5411
Recent Posts
For now the strategy worked for Obama: when you google him, you get the announcement first, then
obamacare, then birth certificate
I just did a TV interview. When it is available, I will post it
Is Obama wagging the dog today before he is going down tomorrow???
from supporter Chantal
Exhibit "95"
Pg. 727
10 of 10 5/2/2011 2:11 AM

LIBERI V TAITZ (C.D. CA) - 190.18 - Plaintiffs Exhibits 91-95 To Amended Complaint.190.18

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LIBERI V TAITZ (C.D. CA) - 190.18 - Plaintiffs Exhibits 91-95 To Amended Complaint.190.18

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Case 8:11-cv-00485-AG -AJW Document 190-18 Filed 05/20/11 Page 1 of 51 Page ID

Dr. Orly Taitz Esquire

World's Leading Obama Eligibility Challenge Web Site

WHEN THE PEOPLE FEAR THEIR GOVERNMENT,

WHEN THE GOVERNMENT FEARS THE PEOPLE,

Why is Lisa Liberi not back in prison? Why is District

Case FWV028000 – Defendants

Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Status

Warrant Type Status Issued Affidavit

Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Charges

1 PC 459 F BURGLARY 05/18/2001

GRAND THEFT: PROPERTY/ETC OVER

GRAND THEFT: PROPERTY/ETC OVER

Case FWV028000 Defendant 1608112 LIBERI, LISA RENEE – Probation

Probation Type: FORMAL Granted: 03/21/2008 Expire: 03/21/2011

SUPERVISED PROBATION GRANTED FOR A PERIOD OF 36 MONTHS ON FOLLOWING TERMS AND

Lisa Liberi v. West Valley Detention Center et al Date Filed: 04/15/2005

Date Filed # Docket Text

!! IMPORTANT NOTICES – PLEASE READ !!

NEW! CA REP CENTRAL COMMITTEE LIST

Dr. Orly Taitz Esquire

World's Leading Obama Eligibility Challenge Web Site

WHEN THE PEOPLE FEAR THEIR GOVERNMENT,

WHEN THE GOVERNMENT FEARS THE PEOPLE,

Lisa Liberi mug shot

Dr. Orly Taitz Esquire

World's Leading Obama Eligibility Challenge Web Site

WHEN THE PEOPLE FEAR THEIR GOVERNMENT,

WHEN THE GOVERNMENT FEARS THE PEOPLE,

Why it is important to go after criminals

Submitted on 2010/11/06 at 5:25pm Why is Lisa

Yesterday I did a program for a European TV network with a reach to

Dr. Orly Taitz Esquire

World's Leading Obama Eligibility Challenge Web Site

WHEN THE PEOPLE FEAR THEIR GOVERNMENT,

WHEN THE GOVERNMENT FEARS THE PEOPLE,

Submitted yesterday in the Third Circuit Court of

UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT

____________________ Exhibit "94"

LISA LIBERI, et al.,

ORLY TAITZ, et al.,

District Court No. 09_cv_01898_ECR

Eastern District of Pennsylvania

APPELLANT’S REPLY TO APPELLEES’ BRIEF

DR. ORLY TAITZ, ESQ.

Attorney Pro Se &

Attorney for Defend Our Freedoms Foundation

29839 S. Margarita Pkwy. Rancho Santa Margarita CA 92688

TABLE OF CONTENTS Exhibit "94"

A. DECISION TO ASSUME JURISDICTION IN DIVERSITY WITHOUT VERIFICATION OF THE STATE

B.APPELLEE’S ATTACKS ON THE JURISDICTION OF THE THIRD CIRCUIT COURT OF APPEALS IS

C. STATE CITIZENSHIP IS AT THE CORE OF THE CASE……..………p13

E. APPELLEES DISCUSSION OF VENUE IS IRRELEVANT AND WAS DONE IN ORDER TO CREATE

F. PUBLIC POLICY CONSIDERATIONS……………………………..p19

G. APPELLEES ARE MISREPRESENTING THE ISSUES ON APPEAL IN RELATION TO THE

H. FRAUD ON THE COURT BY BERG AND LIBERI COMMITTED, AS NO IDENTIFICATION

7.Weight v Kawasaki Motors Corp. (1985, ED Va) 604 F Supp 968……….p9

8. McMann v Doe (2006, DC Mass) 460 F Supp 2d ………………………..p10

11.Olsen v Quality Continuum Hospice, Inc. (2004,DC NM) 380 F Supp 2d

Reply brief does not exceed allowed 7,000 words

SUMMARY OF THE REPLY

A. DECISION TO ASSUME JURISDICTION IN DIVERSITY WITHOUT VERIFICATION OF THE

/s/ Dr. Orly Taitz, ESQ_____