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Law Offices of: PHILIP J. BERG, ESQUIRE Identification No. 09867 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Ph: (610) 825-3134 Fx: (610) 834-7659 Email: philjberg@gmail.com EVELYN ADAMS, Plaintiff c/o PHILIP J. BERG, ESQUIRE 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Ph: (610) 825-3134 Fx: (610) 834-7659 Email: philjberg@gmail.com

Attorney in pro se

In Pro Se.

LISA OSTELLA, and GO EXCEL GLOBAL, Plaintiffs c/o PHILIP J. BERG, ESQUIRE 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Ph: (610) 825-3134 In Pro Se. Fx: (610) 834-7659 Email: philjberg@gmail.com LISA LIBERI, Plaintiff c/o PHILIP J. BERG, ESQUIRE 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Ph: (610) 825-3134 Fx: (610) 834-7659 Email: philjberg@gmail.com

In Pro Se.

U.S. DISTRICT COURT, NORTHERN DISTRICT OF TEXAS AMARILLO DIVISION _____________________________________________ : LISA LIBERI, et al, Plaintiffs, : CIVIL ACTION : vs. : : Case No. 2:11-cv-00090-J : LINDA SUE BELCHER, et al, : Honorable Mary Lou Robinson : Defendants. :
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DECLARATION OF LISA LIBERI I, Lisa Liberi am over the age of eighteen and am a Plaintiff in the within action. I have personal knowledge of the facts herein and if called to do so I could and would completely testify. I am making this declaration under the penalty of perjury of the Laws of the United States pursuant to 28 U.S.C. 1746. 1. Mr. Berg on behalf of all the Plaintiffs emailed Defendants Edgar and

Caren Hale, KPRN AM 1610, Plains Radio Network, Inc. and Bar H. Farms on December 14, 2011 regarding this Courts Order of December 13, 2011 regarding mediation and attempting to set a telephone conference with all parties to comply with this Courts Order. I was bccd on the email as I am Mr. Bergs Paralegal. This email is attached to Plaintiffs Notice to the Court of Fraud by Defendants Edgar and Caren Hale [Plaintiffs Notice] as Exhibit 1. 2. Edgar Hale responded to the Email threatening Mr. Berg. Mr. Hale

stated that he had filed bankruptcy. Mr. Berg responded informing Mr. Hale that none of the Plaintiffs or the Court in this case had been noticed. Mr. Hale again responded stating that we had all been noticed and gave an attorneys name of Patrick Swindell located in Amarillo, Texas. Mr. Hales email is attached to Plaintiffs Notice as Exhibits 2, "3" and "4". 3. In the morning of December 15, 2011, I contacted Mr. Swindells

Office at (806) 374-7979 and spoke to Mr. Swindells secretary. It was confirmed
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that Edgar and Caren Hale had in fact filed a No Asset Chapter 7 Bankruptcy on November 3, 2011. Mr. Swindells office provided me with the Hales bankruptcy case number 11-20630, filed in the United States Bankruptcy Court, Northern District of Texas, Amarillo Division. 4. I called Plaintiff Lisa Ostella and informed her of the Hales

Bankruptcy filing. I provided Mrs. Ostella with the case number. Mrs. Ostella ran the case number through Pacer. I asked Mrs. Ostella to download the docket, which she did. The Hales Bankruptcy Docket is attached to Plaintiffs Notice as Exhibit 5. I also asked Mrs. Ostella to download the Edgar and Caren Hales Credit Matrix list of creditors and send it to me, which she did. Mr. and Mrs. Hales Credit Matrix list of creditors is attached to Plaintiffs Notice as Exhibit 6. I asked Mrs. Ostella to download Schedule A and the Bankruptcy Petition which she did. Mr. and Mrs. Hales Bankruptcy Schedule A is attached to Plaintiffs Notice as Exhibit 12 and their Chapter 7 Bankruptcy Petition is attached to Plaintiffs Notice as Exhibit 13. While Mrs. Ostella was downloading the documents, I went through the Credit Matrix List of creditors and learned none of the Plaintiffs or our case were listed as creditors, which explained why none of us had prior knowledge of any bankruptcy filings. I asked Mrs. Ostella to click the creditors link on the docket, copy and to send it to me, so I could compare the docket list with the Credit Matrix list of creditors, to ensure no creditors were later
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added. The Hales Bankruptcy Docket List of Creditors is attached to Plaintiffs Notice as Exhibit 7. 5. I then asked Mrs. Ostella to run a search in the United States

Bankruptcy Court, Northern District of Texas for bankruptcies under the name of Bar H Farms, Plains Radio Network, KPRN AM 1610 and Plains Radio. I asked Mrs. Ostella to take screen shots of the results. Bar H Farms, Plains Radio Network, KPRN AM 1610 and Plains Radio returned no results, see Plaintiffs Notice Exhibits 8 through 11 6. I compared the Credit Matrix list of creditors with the creditors list

from the pacer docket and they were identical. I then reviewed the Hales Schedule F looking for any of the Plaintiffs names and/or our case. Unfortunately, the Hales did not list any of the Plaintiffs or this case as creditors. 7. I then reviewed the Hales Schedule A to see if all the real estate

owned by the Hales and/or their companies appeared. Of course they did not. The only property listed on Exhibit A was the 160 acres the Hales inherited from Mr. Hales parents. The property Mr. and Mrs. Hale reside in was not listed; this property is located at 1401 Bowie Street, Wellington, Texas 79095. Mr. and Mrs. Hale also own two (2) rental properties, located on Belton and Haskell Streets in Wellington, Texas, which were also omitted from the Hales Bankruptcy Schedule A. The Hales also failed to report their income from their rental properties; the
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AM Radio Tower they own (KPRN AM 1610); the income they earn from their ecommerce advertising and websites; the income they earn from being Directors at the Wellington Community Radio Company; the income they earn from donations and collections on their Plains Radio Network website and through their PayPal account; the Hales also failed to list their PayPal account, which is a bank account; the Hales failed to include the income they earn from selling beef; and the Hales failed to list their income earned as journalists to the locals in or about Wellington, Texas. All of these things the Hales have continually bragged about on their radio programs. Also admitted were the value of their Radio Tower, KPRN AM 1610 and the value of Plains Radio Network, Inc. a/k/a Plains Radio, none of which was listed in their bankruptcy. 8. The Hales have been on numerous radio shows through Plains Radio

Network, Inc. also known as Plains Radio, since the filing of this suit May 4, 2009 through this year stating they have in excess of 2-1/2 million listeners, which raises the value of their Radio Station KPRN AM 1610 and Plains Radio Network, Inc. a/k/a Plains Radio. The Hales brag about the earnings they make from the lease of their land for hunting; rental income; claiming their land is worth more than a half a million dollars [$500,000.00]; and the Hales have told their listeners to donate money to own stock in Plains Radio Network, Inc., also known as Plains Radio. I do not see any of these values included in their bankruptcy.
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9.

The Hales, particularly Edgar Hale, have made many statements

through the years this case has been pending that Plaintiffs would not see one red cent and that he was going to file for bankruptcy to ensure none of the Plaintiffs obtain one cent from him, the latest being in August 2011. 10. On December 15, 2011, Mr. Berg received another email from Mr.

Hale, with a letter addressed to Your Honor in this Case attached. The letter to Your Honor was signed by both, Defendants Edgar and Caren Hale. Mr. Hale

stated he sent the letter to the Court. The Hales stated that Edgar Hale, Caren Hale, Plains Radio Network, Inc., KPRN AM 1610 and Bar H Farms all filed bankruptcy. This is not true. Only, Edgar and Caren Hale as debtor and spouse filed a no asset Chapter 7 Bankruptcy. In fact, on the Hales Bankruptcy Schedule H, the Hales checked the box stating there were no other co-debtors and signed the schedules and verifications. Mr. Hales email and his letter to Your Honor are attached to Plaintiffs Notice as Exhibit 19. 11. After I reviewed the Hales Bankruptcy schedules, I went to the Tax records available online at

Collingsworth

http://www.taxnetusa.com/texas/collingsworth to run the Hales property and name for assets in real estate. The first query I made was for the Hales residential property located on Bowie Street in Wellington, Texas. I was able to locate the property record which is attached to Plaintiffs Notice to the Court of Fraud by
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Defendants Edgar and Caren Hale [Plaintiffs Notice] as Exhibit 14. The Hales Residence was under the name of Bar H. Farms. My next query was for one of their rental properties located on Belton Street in Wellington, Texas, this property record is attached to Plaintiffs Notice as Exhibit 15, this property was also listed under Bar H Farms. I queried the Hales rental property located on Haskell Street in Wellington, Texas, this property record is attached to Plaintiffs Notice as Exhibit 16. My last query was under the Hales name. With this query I was able to pull the land and property record for their acreage which they call a farm. This land/property record is attached to Plaintiffs Notice as Exhibit 17. What was different was the farm land was under the name of Edgar S. Hale III and Caren Hale. It was also found that the Hales had placed their property they owned located at 1305 Ennis Street, Wellington, TX 79095 in the name of Bar H Farms, Inc. and then fraudulently transferred the property out of Bar H Farms, Inc. into the name of Stacy Lynn Andrews on September 16, 2010; see Exhibit 18 attached to Plaintiffs notice. 12. I contacted the Collingsworth County Clerk at the Courthouse at (806)

447-2408 and spoke to Sharon. I explained to Sharon that I needed information and to confirm the property records I had located through their county website. Sharon explained to me that they do not have their records computerized in her department, but she said the Collingsworth County Assessors Office did and
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would be able to locate the information much quicker. Sharon gave me that Collingsworth County Tax Assessors number. 13. Friday morning, December 16, 2011, I contacted the Collingsworth

County Tax Assessors office at (806) 447-5172. I spoke to Kathy who was very helpful. Kathy pulled each of the property records attached as Exhibits 14, 15, 16, 17, and 18 to Plaintiffs Notice by their account numbers. provided me with the following information: Acct. No. 3891 Volume 479. Page 312 1401 Bowie Street Wellington, Texas 79095 Kathy

2/14/2006 Property transferred from the names of Edgar & Caren Hale to Bar H Farms. Edgar and Caren Hale homesteaded this property. Acct. No. 4856 Volume 479. Page 312 1001 Belton Street Wellington, Texas 79095

2/14/2006 Property transferred from the names of Edgar & Caren Hale to Bar H Farms Acct. No. 3977 Volume 479. Page 312 810 Haskell Street Wellington, Texas 79095

2/14/2006 Property transferred from the names of Edgar & Caren Hale to Bar H Farms Acct. No. 455 Volume 517. Page 22 AB 97 BLK 12 SEC 13 NW 4 160 Acre parcel of land

7/1/2010 Property transferred from Bar H Farms to Edgar Hale III and Caren Hale. The transfer was conducted by Defendants Edgar and Caren Hale.

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Acct. No. 4136

Volume 518. Page 111

1305 Ennis St Wellington, TX 79095

This property was transferred from Defendants Edgar S. and Caren Hale into the name of Bar H Farms, Inc. On 9/16/2010 this property was fraudulently transferred by Defendants Edgar S. and Caren Hale from Bar H Farms, Inc. to Tracy Lynn Andrews. There may be more real estate owned by Edgar S. and Caren Hale, and further fraudulent transfers, however, do to the urgent nature of notifying the Court, we have not been able to finish our investigation into the Hales assets. Karen with the Collingsworth County Tax Assessors office also wanted to make sure I understood that Edgar and Caren Hale owned Bar H Farms. 14. Defendant Edgar Hale is on Veterans Administration [VA] Mr.

disability as shown in his military records obtained through a FOIA request.

Hales military records are attached to Plaintiffs Notice as Exhibit 19. Mr. Hale listed his income as Retirement income from the Government. He did this because he is also fraudulently attempting to claim his farm land as an income source through the bankruptcy, thereby making it exempt as well as homesteaded. Mr. Hale cannot receive disability payments and income from working his farm. Mr. Hale does not reside on their farm land and there is no residence or building structure in which to reside. Mr. and Mrs. Hale reside at 1401 Bowie Street, Wellington, Texas 79095 as I have sent mail with signature required to his residence, which was signed for by Mr. or Mrs. Hale.
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15. schedules. 16.

Mrs. Hale works full time as a care taker according to her bankruptcy

The Hale defendants have caused me permanent damages as well as

substantial medical damages as a result of their harassment, cyber-stalking, sending people to my home, threatening me and my family, full identity theft, etc. And, now the Hales are attempting to defraud me and the other Plaintiffs out of any type of recovery for our damages. However, in so doing, the Hales have attempted to defraud this Court and have committed fraud upon the bankruptcy Court. 17. The Hales have attempted to block me and the other Plaintiffs from I intend on objecting to the

any redress for the damages they have caused.

Discharge of the Hales No Asset Chapter 7 Bankruptcy based on Fraud and reporting these individuals for the bankruptcy fraud they have committed. 18. I hope this Court holds the Hale Defendants accountable for their

perjured statements; attempted fraud upon the Court, and other illegal tactics. I declare under the penalty of perjury of the Laws of the United States and Texas that the foregoing is true and correct.

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Executed this 19th day of December, 2011.

I have authorized Mr. Berg to sign my name electronically, which I have initialed so he is able to file my Declaration electronically and not provide the Defendants with my full signature for the reasons outlined herein. /s/ Lisa Liberi Lisa Liberi, Plaintiff

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