58_2009!06!11_motion to strike # 36 taitz-doff opposition to tro

8/14/2019 58_2009!06!11_MOTION to Strike # 36 Taitz-DOFF Opposition to TRO

1/38

Z:\Liberi, et al, Taitz, et al, Plaintiffs Motion to Strike1

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LISA LIBERI, et al,

Plaintiffs,

vs.

ORLY TAITZ, et al,

Defendants.

:

:::::::::

Case No.: 09-cv-01898-ECR

ORDER

THIS CAUSE came before the United States District Court Judge, Honorable Eduardo

C. Robreno on Plaintiffs Motion to Strike Defendants Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law

Offices of Orly Taitz a/k/a www.orlytaitzesq.com a/k/a www.repubx.com a/k/a Orly Taitz, Inc.

and Defend our Freedoms Foundation, Inc. Opposition to Injunction. Having reviewed the

Motion and any Response thereto and for good cause shown, it is hereby

ORDERED that Defendants Orly Taitz, et al. and Defend our Freedoms Foundation,

Inc., Opposition to Injunction is STRICKEN from the record. It is furtherORDERof this

Court that Plaintiffs Injunction or Restraining Order is hereby GRANTED.

IT IS SO ORDERED

Dated: June _____, 2009 _____________________________

Hon. Eduardo C. Robreno

United States District Court JudgeFor the Eastern District of PA


2/38


Law Offices of:Philip J. Berg, Esquire555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531Identification No. 09867(610) 825-3134 Attorney for Plaintiffs



LISA LIBERI, et al,

Plaintiffs,

vs.

ORLY TAITZ, et al,

Defendants.

::::

::::::


PLAINTIFFS MOTION TO STRIKE

DEFENDANTS, ORLY TAITZ, et al and DEFEND OUR FREEDOMS

FOUNDATION, INC. OPPOSITION TO INJUNCTION

Plaintiffs Lisa Liberi [hereinafter Liberi]; Philip J. Berg, Esquire [hereinafter Berg],

the Law Offices of Philip J. Berg; Evelyn Adams a/k/a Momma E [hereinafter Adams]; Lisa

Ostella [hereinafter Ostella]; and Go Excel Global by and through their undersigned counsel,

Philip J. Berg, Esquire files the within Motion to Strike Defendants, Orly Taitz a/k/a Dr. Orly

Taitz a/k/a Law Offices of Orly Taitz a/k/a www.orlytaitzesq.com a/k/a www.repubx.com a/k/a

Orly Taitz, Inc. [hereinafter Taitz] and Defend our Freedoms Foundation, Inc. [hereinafter

DOFF] Opposition to Injunction on the following grounds:


3/38


Taitz and DOFFs Motion is an improper Motion. Taitz and DOFF fail to support

their Opposition to Injunction without any type of Statute or supporting Law.

Taitz and DOFFs Motion fails to give any good cause for granting the requested

relief;

Taitz and DOFFs Opposition to Injunction should be completely stricken as it

is not proper; it fails to address any claims in Plaintiffs Complaint and/or Emergency

Motion for an Injunction and/or Temporary Restraining Order [TRO] and is nothing more

than conclusions of law; hearsay statements; immaterial, impertinent, and scandalousstatements and material and is completely irrelevant, impertinent and immaterial to the

within action; and fails to give any type of legally sufficient defense; Taitz only filed this

nonsense to prejudice the Plaintiffs.

Taitz and DOFFs illegal, threatening, harassing and dangerous behaviors have

continued and have escalated. Therefore, Plaintiffs Injunction or Restraining Order must

be granted.

Respectfully submitted,

Dated: June 11, 2009 _____________________________

Philip J. Berg, EsquireAttorney for Plaintiffs

s/ Philip J. Berg


4/38





LISA LIBERI, et al,

Plaintiffs,

vs.

ORLY TAITZ, et al,

Defendants.

::::

::::::


MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFFS MOTION TO STRIKE

DEFENDANTS, TAITZ AND DOFFS OPPOSITION TO INJUNCTION

I. STATEMENT OF FACTS

Plaintiffs hereby incorporate in by reference their pleadings in their Motion for an

Emergency Injunction and/or Temporary Restraining Order and their Complaint as if fully set

forth herein.

This case sets forth the facts that Defendants, Orly Taitz a/k/a Law Offices of Orly Taitz

a/k/a Orly Taitz, Inc [hereinafter Taitz]. and Defend our Freedoms Foundation, Inc.

[hereinafter DOFF] have sent Plaintiff Lisa Liberis Social Security number and personal data

via e-mail in mass mailings, media groups, internationally and to tens of thousands of

undisclosed recipients, requesting the information to be posted on websites across the internet

and have been harassing Plaintiff Lisa Liberi, Philip J. Berg, Esquire and the Law Offices of


5/38


Philip J. Berg, Lisa Ostella and her family and have filed falsified police and law enforcement

reports against Lisa Ostella and Lisa Liberi regarding supposed hacking of Defendant Orly

Taitz, et al websites and PayPal accounts. Lisa Liberi and her husband were also accused of

hacking and tampering with Defendant Orly Taitzs website and PayPal accounts. Taitz and

DOFF have been slandering Plaintiffs herein, their staff and their businesses; posting libel

regarding the Plaintiffs, their staff and their businesses on the internet and through mass mailings

on the internet; and harassing the Plaintiffs, their staff and their businesses.

As a result, Plaintiffs filed suit and an Emergency Motion for an Injunction and/or

Temporary Restraining Order against Taitz, DOFF and other Defendants as a result of the

illegal, tortuous, injurious, harassing, slanderous, libelous behaviors; invasion of privacy,

violations of the First and Fourteenth Amendment of the United States Constitution and

violations of State and Federal laws distributing Liberis full Social Security number and other

personal identifying information on May 4, 2009. Taitz was served with the Summons,

Complaint and Motion for the Emergency Injunction and/or Temporary Restraining Order

[hereinafter TRO] on May 4, 2009 and DOFF was served on May 5, 2009. Taitz and DOFF

failed to timely respond to Plaintiffs Complaint and their Motion for the Emergency TRO.

Plaintiffs filed Request for the entry of Default; Default was entered May 27, 2009. May 28,

2009, Plaintiffs filed a Request for a Judgment by Default to be entered. Taitz and DOFFs

Answer to the Complaint; Motion to Dismiss; and this Objection to Plaintiffs Injunction was

also filed on May 28, 2009, however, not docketed until May 29, 2009.

Since the filing of Plaintiffs Complaint and personal service by a licensed process

service Company, upon Taitz and DOFF, Taitz through DOFF has continued her tortuous,

injurious, activities and behaviors including but not limited to harassment, violation of Privacy,


6/38


violations of the First and Fourteen Amendment, slandering, libelous behavior, continued

sending out Taitz Dossier #6 with Liberis full Social Security number and other personal

identifying information; Taitz Dossier #6 is also posted on her website at

http://www.orlytaitzesq.com/blog1/?p=8 and have published terrorist type threats against the

Plaintiffs. Moreover, Taitz through DOFF even called for individuals in the State which

Plaintiffs reside and has requested everyone in the cyber space world to dig on Plaintiff Liberi,

her husband, Evelyn Adams [hereinafter Adams] and locate their previous addresses, Social

Security numbers, even though she has Liberis, voting records; look for any criminal records,

etc. in an attempt to continue their illegal and dangerous behaviors against Plaintiffs, their staff

and their businesses. As a result, Plaintiffs, their staff and their businesses have been severely

damaged as outlined herein.

Taitz through DOFF has placed postings on her internet site www.orlytaitzesq.com

calling for volunteers to put together a Militia, calling for donations and money for guns, ammo

and communications. Taitz through DOFF has taken even further, she has labeled Plaintiffs

Obots; President Obama supporters; and claims Plaintiffs work for President Obama. The

purpose Taitz through DOFF made a point to label the Plaintiffs Obots, President Obama

Supporters and the claims Plaintiffs work for President Obama is to make Plaintiffs part of

President Obamas clique wherein Taitz through DOFF posted on her website at

http://www.orlytaitzesq.com/blog1/?p=36 that

Just like the country needs to be purged of Obama and his clique, that are in

power by virtue of forgery, fraud and concealment of vital records, the patriots ofthis country need to purge their ranks.


7/38


The word Clique in the English dictionary means a small, exclusive group of people1

and the word Purge in the political sense means, to put to death or otherwise eliminate

(undesirable or unwanted members) from a political organization, government, nation, etc.2

Shortly thereafter, Plaintiff Ostella received a phone call stating Defendant, Orly Taitz

was calling people and telling them that Professionals were going to kidnap Ostellas children.

Moreover, Taitz through her company, DOFF just posted the following on their website

located at www.orlytaitzesq.com3:

I am trying to stay away from Liberi-Berg issue, but i got more questions andhere is more info.

May 31st, 2009

I was asked by a number of people to explain why the name of Lisa Ostella is on the dossier #4.

When I was in Washington DC, I did not have an access to the Internet, as I was visiting the Director ofthe Selective Service William Chatfield and offices of several senators and was on the phone with theassistant and legal counsel for Admiral Malin. A lot of people asked me for an update and I called LisaOstella, the web master ,and asked her to post it on the Internet. As you can see, the fact that she signedDefendOurfFeedomsFoundations, and she put her name as an assistant to me, clearly shows that sheknew it is my foundation, under my name and she could sign as an assistant only as long as she washelping me. The moment I transferred to another webmaster, she had and has no right to advertise on

behalf of the DefendOurFreedoms foundation, solicit donations and pocket the money.

You can also see (in the attachment) that she was the one that contacted the private investigator Mr.Sankey, and provided him the information that Lisa Liberi , assistant to Phil Berg, has a criminal record.Based on her report Mr. Sankey has investigated and confirmed this information, that indeed Lisa Liberihas this lengthy record of forgery of documents and forgery of an official seal and grand theft. Lisa Ostellachanged her tune only after this whole issue with pay-pal came out. At first she and the rest of theplaintiffs came out with an outrageous lie that my husband was spying on people. Now they dismissedtheir law suit against my husband- and everybody knows that it was a manufactured charge.

As you can see, she was well aware about Liberis criminal record, as was Berg and Liberi herself. Theirlegal action is nothing but perjury and an attempted obstruction of justice. I have written in the pleadingsthat the only address that Liberi provided, was Bergs office address and the reason is that she indeed

resides in NM and is the Lisa Liberi with the criminal record. I received an e-mail recently that in the lastcouple of days Lisa Liberi has gotten a PA drivers license. If she got one in the last couple of days, that

1http://dictionary.reference.com/browse/clique2http://dictionary.reference.com/browse/purge

3http://www.orlytaitzesq.com/blog1/?p=1843


8/38


doesnt change the fact that she resided in NM and that all of them committed perjury. If anything, gettinga PA drivers license now is yet another attempt to obstruct justice.

As I have said before, I dont get intimidated by either Obama or by Berg. One cannot file a fraudulentand malicious legal action against me and expect to shut me up and make me stop reporting on illegaland criminal activity. All that these people are doing, is adding counts of fraud, perjury and obstruction of

justice. The only thing Berg can do, is come clean, disassociate himself from Lisa Liberi, who has arecord of forgery and he needs to hire a forensic document examiner to check all the records handled byLisa Liberi. We cannot win in court with forged records. This information was already on the blogs before Igot it and it will be on the blogs, his continuing denial of clear evidence has no merit and undermineseverybody in the resistance movement, everybody who wants to get to the truth. The only way to win, isby clean evidence, unsealing the vital records and letting the Supreme Court decide the issue of theNatural Born Citizen.

> From: [email protected]> To: [email protected]> Subject: RE: HELLO ??? (again)> Date: Sun, 15 Mar 2009 17:02:00 -0700>

> Indeed it would. If you would pass this on to Dr.O, I will go out to San Bdo> this week and have a look at the 2002 file, dontcha think?> N>> Original Message> From: Lisa Ostella [mailto:[email protected]]> Sent: Sunday, March 15, 2009 4:49 PM> To: Neil Sanky> Subject: RE: HELLO ??? (again)>> Hmm, if the forged documents actually came out of Phil Bergs office, well,> filing lawsuits would be an excellent cover, huh?>> Factcheck is in Pennsylvania.>> As is Phil Berg.>>> Lisa Ostella> Defend Our Freedoms Foundation> http://defendourfreedoms.org > Peace through Strength> http://www.barofintegrity.com >> > From: [email protected]> > To: [email protected]

> > Subject: RE: HELLO ??? (again)> > Date: Sun, 15 Mar 2009 16:35:46 -0700> >> > Yes but a SEAL !!, and HOW MANY aliases?> >> > Original Message> > From: Lisa Ostella [mailto:[email protected]]> > Sent: Sunday, March 15, 2009 3:46 PM> > To: Neil Sanky


9/38


> > Subject: RE: HELLO ??? (again)> >> > Insight, such as, Lisa Liberi (Phil Bergs assistant) really being Lisa

> > Richards, with a police record for ID theft?> >> > Mighty convenient talent to have when there are multiple identities flying

> > around.> >> > Ive not researched that insight yet. I didnt have a warm and fuzzy> > interaction with (redacted name of volunteer )So I dont know if this is planted info droppings> > or not.> >> >> > Lisa Ostella> > Defend Our Freedoms Foundation> > http://defendourfreedoms.org > > Peace through Strength> > http://www.barofintegrity.com > >

This entry was posted on Sunday, May 31st, 2009 at 2:19 pm and is filed underUncategorized. You can follow any

responses to this entry through the RSS 2.0 feed. You can leave a response, ortrackbackfrom your own site.

This Court should note; the above emails posted by Defendant Orly Taitz are

Forged and Altered documents. See EXHIBIT A. Defendants, Neil Sankey and Taitz

through DOFF conspired to alter and forge emails of Plaintiff, Lisa Ostella. Four [4] of the five

[5] emails above have been and FORGED. Defendant Neil Sankey went onto Defendant, Plains

Radio at www.plainsradio.com, which is run and was hosted by Defendants Edgar and Caren

Hale, on May 28, 2009. Defendant Neil Sankey stated on the radio with Defendants Edgar and

Caren Hale that Plaintiff, Lisa Ostella, had sent him (Neil Sankey) an email claiming that Lisa

Liberi, Phil Bergs Assistants name was really Richards with a police record of ID theft, all of

which is completely false, libel and slander of Plaintiff Liberi. Plaintiff Ostella never sent any

such email, ironically three [3] days later, Taitz through DOFF posts on DOFFs website the

supposed emails and makes the very same statements. Plaintiff Ostella has reported these

crimes to her local police department located in North Brunswick, New Jersey. See the

Declaration of Plaintiff, Lisa Ostella, attached as EXHIBIT B.


10/38


All Plaintiffs are extremely concerned and scared of what all the Defendants especially

Taitz and Sankey, will due next. Especially, Plaintiff Liberi as Taitz has been sending all of her

personal identifying information, including full Social Security number to in excess of One

hundred and forty thousand [140,000] individuals and companies by way of mass emailing and

postings on internet sites, including her own. Taitz and Neil Sankey have admitted to having

Liberis personal information for a long time. Liberi recently learned by running a Lexis search

on her Social Security number, an individual by the name of Sholanda Nash is using her Social

Security number in Harris County, Texas, see EXHIBIT C (the Social Security number is Xd

out, however, the original document will be supplied to his Honor).

Taitz continues falsely accusing Ostella of stealing her domains, website and blogs.

Ostella purchased the name Defend our Freedoms prior to Taitz setting up the Corporation,

Defend our Freedoms Foundation, Inc. Furthermore, Ostella owned the domain names of

Defend our Freedoms, which she had copywrited prior to Taitz incorporating the name Defend

our Freedoms Foundation, Inc.. In addition, Plaintiff Ostella paid for the server prior to and

during the time she allowed Taitz and DOFF to use it. Other than the time Ostella donated to

Taitz; none of the other Plaintiffs worked with or had anything to do with Taitz and/or DOFF.

In fact, Berg, his law firm and Liberi refused to work with Taitz or have anything to do with her

as a result of her explosive actions.

Taitz Opposition to Plaintiffs TRO on page two [p.2], paragraph one [ 2] after the first

sentence has nothing at all to do with the within lawsuit and fails to address any of the

substantiated allegations plead in Plaintiffs Complaint and/or Motion for TRO. It is nothing

more than unsubstantiated allegations, conclusion of law, impertinent, immaterial and slanderous

remarks towards the Plaintiffs. Paragraph three [ 3], Taitz claims Plaintiffs admitted in their


11/38


own pleading that Taitz has sent a cease and desist email to Berg, Liberi and Berg learned of the

Cease and Desist by Taitz website posting. Furthermore the rest of this paragraph is nothing

more than conclusions of law; hearsay statements;documents which are hearsay; speculation;

conclusory statements hearsay, speculation, which are immaterial, impertinent, and scandalous

statements, and is completely irrelevant, impertinent and immaterial to the within action; and

fails to give any type of legally sufficient defense; and fails to embark upon or even address the

substantiated claims in Plaintiffs Complaint and/or Emergency Motion for a TRO. Paragraphs

four through sixteen [ 4-16] located on pages two through five [pp. 2-5] are nothing more than

conclusions of law; hearsay statements; documents which are hearsay; speculation; conclusory

statements hearsay, speculation, which are immaterial, impertinent, and scandalous statements,

and is completely irrelevant, impertinent and immaterial to the within action; which fail to give

any type of legally sufficient defense; and fails to embark upon or even address the substantiated

claims in Plaintiffs Complaint and/or Emergency Motion for a TRO. Taitz and DOFFs

unsubstantiated statements, are completely false and are merely set out to prejudice the Plaintiffs

and that unnecessarily reflects negatively on the moral character of the Plaintiffs.

Furthermore, since Taitz and DOFF failed to timely file their Opposition to the Plaintiffs

Emergency Motion for a TRO and does not respond to, offer any type of defense; does not assert

any type of affirmative defenses, it should clearly be stricken. Taitz is a licensed Attorney within

the State of California. Taitz is admitted to practice law in the United States District Court,

Central District of California. Taitz is aware of the Federal Rules of Civil Procedure as she

currently has a pending action in the United States District Court, Central District of California.

There is absolutely no excuse for her failure to send her and DOFFs documents to the Court for

timely filing and to file this nonsense with this Honorable Court.


12/38


For the above aforementioned reasons, Plaintiffs respectfully requests this Court to strike

Taitz and DOFF Opposition to Injunction [sic] or in the alternative, paragraphs two through

sixteen [ 2-16] and all attachments, issue Plaintiffs Emergency Injunction or a Temporary

Restraining Order immediately or in the alternative set an immediate hearing or conference.

II. THIS HONORABLE COURT HAS THE INHERENT POWER TO STRIKE

TAITZ AND DOFFS OPPOSITION TO INJUNCTION

Plaintiffs hereby object to Taitz and DOFFs Opposition to Plaintiffs Emergency Motion

for a TRO and asks this Court to Strike Taitz and DOFFs entire Opposition to Injunction, or

in the alternative paragraphs two through sixteen [ 2-16] and all attached documents as they

contain nothing more than conclusions of law; hearsay statements; hearsay documents;

speculation; conclusory statements immaterial, impertinent, and scandalous statements and

material, and are completely irrelevant, impertinent and immaterial to the within action; which

fail to give any type of legally sufficient defense; and fails to embark upon or even address the

substantiated claims in Plaintiffs Complaint and/or Emergency Motion for TRO. Taitz only

filed this nonsense to prejudice the Plaintiffs and to unnecessarily reflect on the moral character

of Liberi and Berg.

Moreover, Taitz and DOFF attached a document with the full Social Security number of

Plaintiff Liberi. The document is a hearsay document; and has absolutely no bearing to the case

at hand and no where in Taitz and DOFFs inappropriate Opposition to Injunction does Taitz

or DOFF explain why they would attach a document bearing a parties full Social Security

number. This document containing Liberis full Social Security number was filed with Taitz and

DOFFs Motion to Dismiss and their Opposition to Injunction. Unfortunately, this document

was placed in Pacer.


13/38


Federal Rules of Civil Procedure, Rule 12(f) states:

(f) Motion to Strike. The court may strike from a pleading an insufficientdefense or any redundant, immaterial, impertinent, or scandalous matter.

The court may act:

(1) on its own; or

(2) on motion made by a party either before responding to the pleading or, if aresponse is not allowed, within 20 days after being served with the

pleading.

Scandalous" generally refers to any allegation that unnecessarily reflects on the moral

character of an individual or states anything in repulsive language that detracts from the dignity

of the Court. Courts will typically strike so-called scandalous material only if it is irrelevant and

immaterial to the issues in controversy. See Cobell v. Norton, 224 F.R.D. 1, 5 (D.D.C. 2004)

(citing Moore's for proposition that statement may be stricken as "scandalous" only when it

contains allegation "that unnecessarily reflects on the moral character of an individual or states

anything in repulsive language that detracts from the dignity of the court"); 7th CircuitTalbot v.

Robert Matthews Distrib. Co., 961 F.2d 654, 664 (7th Cir. 1992) ("[a]llegations may be stricken

as scandalous if the matter bears no possible relation to the controversy or may cause the

objecting party prejudice").

The statements and material provided by Taitz and DOFF in paragraphs two through

sixteen [2-16] are extremely prejudicial to the Plaintiffs and have absolutely no bearing to the

within action. Further, the presence of the references sought to be stricken must be prejudicial to

the movant.Pelech v. Klaff-Joss, L.P., 828 F. Supp. 525, 536-37 (N.D.Ill.1993) (acknowledging

the seriousness implied in any poorly supported allegations); Robinson v. The Midlane Club,

Inc. et al., 1994 U.S. Dist. LEXIS 14790, 1994 WL 577219 *2 (N.D.Ill. Oct. 19, 1994)., see,

e.g.,Imperial Constr. Management Corp. v. Laborers' Int'l Union, Local 96, 818 F. Supp. 1179,


14/38


1186 (N.D.Ill.1993) (granting a motion to strike affirmative defenses because they only added

clutter to the case and because they were without merit, but upholding general rule disfavoring

such motions).

If Plaintiffs Injunction or Restraining Order is not granted, Plaintiffs will suffer severe

irreparable harm.

For the above aforementioned reasons, Taitz and DOFFs Opposition to Injunction

must be stricken from the record.

IV. CONCLUSION

For the above aforementioned reasons clearly outlined, Defendants, Orly Taitz a/k/a Dr.

Orly Taitz a/k/a Law Offices of Orly Taitz a/k/a www.orlytaitzesq.com a/k/a www.repubx.com

a/k/a Orly Taitz, Inc. and Defend our Freedoms Foundation, Inc. Opposition to Injunction

must be Stricken from the Record. In addition, Plaintiffs Injunction or Restraining Order must

be granted in order to give Plaintiffs some safeguard from Defendants Taitz and DOFF.

Respectfully submitted,

Dated: June 11, 2009 __________________________

PHILIP J. BERG, ESQUIREAttorney for Plaintiffs

s/ Philip J. Berg


15/38


EXHIBIT A


16/38

1

http://www.orlytaitzesq.com

/blog1/?p=1843

Dr.OrlyTaitzE

squire

DefendOurFreedomsFoundation26302LaPazste211,Missio

nViejoCA92691Copyright2009

FromreaderBobS.Didanyon

eseeHankPaulsoncomingout

ofhishouselately?

ReKeyesvObama

Iamt

ryingtostayawayfromL

iberi-Bergissue,

butigotmorequestionsandhereismor

einfo.

Iwasaskedbyanumberofpeopletoexplainwhythenameof

LisaOstellaisonthedossier#4.

WhenIwasinWashingtonDC

,Ididnothaveanaccessto

the

Internet,asIwasvisitingthe

DirectoroftheSelectiveServ

ice

WilliamChatfieldandofficeso

fseveralsenatorsandwason

the

phonewiththeassistantandlegalcounselforAdmiralMalin.A

lot

ofpeopleaskedmeforanupdateandIcalledLisaOstella,thew

eb

master,andaskedhertopost

itontheInternet.Asyoucan

see,thefactthatshesignedDefendOurfFeedomsFoundations,and

sheputhernameasanassistant

tome,clearlyshowsthatshekn

ew

itismyfoundation,undermy

nameandshecouldsignas

an

assistantonlyaslongasshe

washelpingme.Themom

ent

Itransferredtoanotherwebmaster,shehadandhasnorightto

advertiseonbehalfoftheDefendOurFreedomsfoundation,sol

icit

donationsandpocketthemoney.

Youcanalsosee(intheattach

ment)thatshewastheonethat

contactedtheprivateinvestigato

rMr.Sankey,andprovidedhim

theinformationthatLisaLiber

i,assistanttoPhilBerg,has

a

criminalrecord.Basedonherre

portMr.Sankeyhasinvestigate

d

andconfirmedthisinformation,thatindeedLisaLiberihasth

is

lengthyrecordofforgeryofdoc

umentsandforgeryofanofficial

sealandgrandtheft.LisaOstellachangedhertuneonlyafterth

is


17/38

2

wholeissuewithpay-palcame

out.Atfirstsheandtherestof

theplaintiffscameoutwithan

outrageousliethatmyhusban

d

wasspyingonpeople.Nowtheydismissedtheirlawsuitagain

st

myhusband-andeverybodykn

owsthatitwasamanufacture

d

charge.

Asyoucansee,shewaswellawareaboutLiberiscriminal

record,aswasBergandLibe

riherself.Theirlegalaction

is

nothingbutperjuryandanatt

emptedobstructionofjustice.

I

havewritteninthepleadingsthattheonlyaddressthatLiberi

provided,wasBergsofficeaddressandthereasonisthatsh

e

indeedresidesinNMandisth

eLisaLiberiwiththecriminal

record.Ireceivedane-mailrecentlythatinthelastcoupleof

daysLisaLiberihasgottenaPA

driverslicense.Ifshegotonein

thelastcoupleofdays,thatd

oesntchangethefactthatsh

e

residedinNM

andthatallofthem

committedperjury.

If

anything,gettingaPA

driverslicense

now

isyetanother

attempttoobstructjustice.

AsIhavesaidbefore,Idontge

tintimidatedbyeitherObamaor

byBerg.Onecannotfileafraudulentandmaliciouslegalactio

n

againstmeandexpecttoshutm

eupandmakemestopreportin

g

onillegalandcriminalactivity.

Allthatthesepeoplearedoing,

isaddingcountsoffraud,perjuryandobstructionofjustice.Th

e

onlythingBergcando,iscomeclean,disassociatehimselffrom

LisaLiberi,whohasarecordo

fforgeryandheneedstohire

a

forensicdocumentexaminerto

checkalltherecordshandledb

y

LisaLiberi.Wecannotwinin

courtwithforgedrecords.Th

is

informationwasalreadyontheblogsbeforeIgotitanditwillb

e

ontheblogs,hiscontinuingdenialofclearevidencehasnomerit

and

undermines

everybody

in

the

resistance

movemen

t,

everybodywhowantstogettothetruth.Theonlywaytowin,is

bycleanevidence,unsealingthevitalrecordsandlettingth

e

SupremeCourtdecidetheissueoftheNaturalBornCitizen.

***ThefollowingEmailswiththeaboveposthavebeen

alteredandforged


18/38

3

FORGEDANDALTERNEDEMAILplacedonOrlyTaitzswebsite

ORIG

INALCORRECTUN-ALTER

EDEMAILWHICH

athttp://www.orlytaitzesq.c

om/blog1/?p=1843BYOrly

Taitz

WAS

SENTANDRECEIVED:

NUMBER1:

NUM

BER1:

>

From:nsankey@thesankeyfirm

.com

>From

:[email protected]

>

To:[email protected]

>To:[email protected]

>

Subject:RE:HELLO???(again)

>Subject:RE:HELLO???(again)

>

Date:Sun,15Mar200917:02:00-0700

>Date:Sun,

15Mar200917:02:00-0700

>

>

>

Indeeditwould.Ifyouwould

passthisontoDr.O,IwillgoouttoSanBdo

>IfyouwouldpassthisontoDr.O,

Iwillgo

outtoSanBdo

>

thisweekandhavealookatth

e2002file,dontchathink?

>this

>

>N

>

N

>

>N

UMBER2:

NUMBER2:

>OriginalMessage

>From:LisaOstella[mailto:[email protected]]

NOSU

CHEMAILEXISTSNEVERSENTNUMBER2ON

>Sent:Sunday,March15,20094:49PM

ORLYTAITZWEBSITEISACOMPLETEM

ANUFACTURED

>To:NeilSanky

ANDFORGEDEMAIL


>

>Hmm,iftheforgeddocumentsac

tuallycameoutofPhilBergsoffice,well,

>filinglawsuitswouldbeanexcellentcover,huh?

>>ornot.

>FactcheckisinPennsylvania.

>

>AsisPhilBerg.

>

>

>LisaOstella

>DefendOurFreedomsFoundatio

n

>http://defendourfreedoms.org

>PeacethroughStrength

>http://www.barofintegrity.com

>


19/38

4

NUMBER

3:

NUMBER

3:

>>From:nsankey@thesankeyfirm

.com

Actual

EmailNoAlterationsonthisdocument

>>To:[email protected]

>>Subject:RE:HELLO???(again)

>>Date:Sun,15Mar200916:35:46-0700

>>

>>YesbutaSEAL!!,andHOWM

ANYaliases?

>>

NUMBER

4:

NUMBER

4:

>>OriginalMessage

>>----

-OriginalMessage-----

>>From:LisaOstella[mailto:[email protected]]

>>Fro

m:LisaOstella[mailto:lisaostella@h

otmail.com]

>>Sent:Sunday,March15,2009

3:46PM

>>Sent:Sunday,March15,

20093:46PM

>>To:NeilSanky

>>To:NeilSanky



>>

>>

>>Insight,suchas,LisaLiberi(Ph

ilBergsassistant)reallybeingLisa

>>I've

notresearchedthatinsightyet.Idid

n'thaveawarmandfuzzy

>>Richards,withapolicerecordforIDtheft?

>>interactionwithSarah.

SoIdon'tknowifthisisplantedinfodroppings

>>

>>ornot.

>>Mightyconvenienttalenttohavewhentherearemultipleidentities

flying

>>

>>around.

>>

>>

>>LisaOstella

>>Ivenotresearchedthatinsight

yet.Ididnthaveawarmandfuzzy

>>DefendOurFreedomsFoundation

>>interactionwith(redactedname

ofvolunteer)SoIdontknowifthisisplantedinfo

>>De

fendOurFreedomsFoundation

droppings

>>http://defendourfreedoms.org

>>ornot.


>>

>>PeacethroughStrength

>>LisaOstella

>>http://www.barofintegrity.com



>>

Thisen

trywaspostedon

Sun

day,M

ay31st,

2009at

2:1

9pm

andisfiledun

der

Unca

tegorize

d.

Youcan

followanyre

sponses

tothisen

try

throug

hthe

RSS

2.0

feed.

Youcan

leavearesponse,

or

trac

kback

fromyourownsi

te.

Dr.

Orly

Tai

tzEsqu

ireis

prou

dlypowered

by

Word

Press

En

tries

(RSS)an

dCommen

ts(RSS).


20/38

5

***

NoteonNumber4:The

smileyintheforgedemailbearstheexactsamesmileyfaceuse

dbyOrlyTaitzonherwebsiteat

http://www.orlytaitzesq.com/blog1/?p=1445

***

NOTENEILSANKE

YWITHTHESANKEYFIR

MWASONPLAINSRADIO,www.plainsradio.comONMAY28,2009WHEREIN

NEILSANKEYSTATED:

IRECEIVEDANEMAILFROMLISAOSTELLASTATINGLISALIBERI(PHILBE

RGSASSISTANT)WAS

R

EALLYLISARICHARDSWITHAPOLICERECORDFOR

IDENTIFICATIONTHEFT.


21/38


EXHIBIT B


22/38

Z:\Liberi, et al v. Taitz, et al Decl of Lisa Ostella 1




LISA LIBERI, et al,

Plaintiffs,

vs.

ORLY TAITZ, et al,

Defendants.

::::

::::::


DECLARATION OF PLAINTIFF LISA OSTELLA

I, Lisa Ostella, 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 competently testify under oath.

I declare as follows:

1. I purchased the domain names defendourfreedoms.us;defendourfreedoms.net and defendourfreedoms.com in or about early December.

I am the rightful owner of said domain names.

2. In or about November 2008 to April 2009, I donated my time as one of thewebmasters to Orly Taitz, one of the within Defendants.

3. Orly Taitz stated she had been having problems with her blog atwww.drorlyblogspot.com, so I migrated her domain name defendourfreedoms.us

and moved her blog over to my account on GoDaddy, which I paid for.


23/38


4. In or about March 2009, someone changed the email address attached toOrly Taitzs PayPal account from [email protected] to [email protected].

This could have simply been a typographical error. Four separate individuals had

access to the scripting associated with the sidebar on the blog site.

5. In or about early March Orly began claiming her PayPal account andwebsite were being hacked. I and Charlie, another webmaster explained to Ms.

Taitz that her websites and PayPal account had not been hacked.

6. Despite this, Ms. Taitz filed a false report with the Orange CountySheriffs Department located in California and the Federal Bureau of

Investigations also located in Southern California.

7. I told Ms. Taitz if she did not retract the false report, she would have tofind another webhost and webmaster.

8. Ms. Taitz refused to retract her falsified police report, so I told her to finda new host.

9. Shortly thereafter, Ms. Taitz began falsifying stories about me stating Ihad hacked her PayPal account, websites and stole foundation monies, which is

and was completely false. My email address and phone number does appear on

Ms. Taitz PayPal account as I set up her PayPal Account for her. To date, Ms.

Taitz has not removed my email address. However, my email address is not the

email address funds are sent to.

10. Next, Ms. Taitz began claiming Plaintiff Liberi and I are the same person,the entire time knowing this was a false statement.


24/38


25/38


who took the report put the incident type/Offense as Terroristic Threats/Threat to

kill (2C:12-3B). This report was assigned to Detective Cano.

16. Now it appears Defendants Neil Sankey and Orly Taitz have conspiredtogether and not only altered and forged but created emails using my email

address and claiming I wrote the emails and sent them. See EXHIBIT 1.

17. Defendant Neil Sankey went onto Defendant Plains Radio on May 28,2009 which was hosted by Defendants Edgar Hale and Caren Hale. Neil Sankey

stated that I sent him an email claiming Lisa Liberi, Philip J. Bergs Assistant;

name was really Richards and had a Police Record for ID [sic

] theft. This is

completely false. I have never sent any such email to Neil Sankey or anyone else.

18. May 31, 2009, I received several emails, one from another webmaster,Charlie. In the email was the following post which Defendant Orly Taitz posted

on her website:


Dr. Orly Taitz Esquire

Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691 Copyright 2009

From reader Bob S. Did anyone see Hank Paulson coming out of his house lately?

Re Keyes v Obama

I am trying to stay away from Liberi-Berg issue, but i

got more questions and here is more info.

I was asked by a number of people to explain why the name of Lisa Ostella is on thedossier #4.


26/38


When I was in Washington DC, I did not have an access to the Internet, as I was visiting

the Director of the Selective Service William Chatfield and offices of several senators

and was on the phone with the assistant and legal counsel for Admiral Malin. A lot ofpeople asked me for an update and I called Lisa Ostella, the web master ,and asked her to

post it on the Internet. As you can see, the fact that she signed

DefendOurfFeedomsFoundations, and she put her name as an assistant to me, clearlyshows that she knew it is my foundation, under my name and she could sign as an

assistant only as long as she was helping me. The moment I transferred to another

webmaster, she had and has no right to advertise on behalf of the DefendOurFreedomsfoundation, solicit donations and pocket the money.

You can also see (in the attachment) that she was the one that contacted the privateinvestigator Mr. Sankey, and provided him the information that Lisa Liberi , assistant to

Phil Berg, has a criminal record. Based on her report Mr. Sankey has investigated and

confirmed this information, that indeed Lisa Liberi has this lengthy record of forgery ofdocuments and forgery of an official seal and grand theft. Lisa Ostella changed her tune

only after this whole issue with pay-pal came out. At first she and the rest of theplaintiffs came out with an outrageous lie that my husband was spying on people. Nowthey dismissed their law suit against my husband- and everybody knows that it was amanufactured charge.

As you can see, she was well aware about Liberis criminal record, as was Berg and

Liberi herself. Their legal action is nothing but perjury and an attempted obstruction of

justice. I have written in the pleadings that the only address that Liberi provided,was Bergs office address and the reason is that she indeed resides in NM and is the Lisa

Liberi with the criminal record. I received an e-mail recently that in the last couple of

days Lisa Liberi has gotten a PA drivers license. If she got one in the last couple of days,that doesnt change the fact that she resided in NM and that all of them committed

perjury. If anything, getting a PA drivers license now is yet another attempt to obstruct

justice.

As I have said before, I dont get intimidated by either Obama or by Berg. One cannot

file a fraudulent and malicious legal action against me and expect to shut me up and makeme stop reporting on illegal and criminal activity. All that these people are doing, is

adding counts of fraud, perjury and obstruction of justice. The only thing Berg can do, is

come clean, disassociate himself from Lisa Liberi, who has a record of forgery and heneeds to hire a forensic document examiner to check all the records handled by Lisa

Liberi. We cannot win in court with forged records. This information was already on the

blogs before I got it and it will be on the blogs, his continuing denial of clear evidencehas no merit and undermines everybody in the resistance movement, everybody who

wants to get to the truth. The only way to win, is by clean evidence, unsealing the vital

records and letting the Supreme Court decide the issue of the Natural Born Citizen.

> From: [email protected]

> To: [email protected]> Subject: RE: HELLO ??? (again)


27/38


> Date: Sun, 15 Mar 2009 17:02:00 -0700

>

> Indeed it would. If you would pass this on to Dr.O, I will go out to San Bdo> this week and have a look at the 2002 file, dontcha think?

> N

>> Original Message

> From: Lisa Ostella [mailto:[email protected]]

> Sent: Sunday, March 15, 2009 4:49 PM> To: Neil Sanky

> Subject: RE: HELLO ??? (again)

>> Hmm, if the forged documents actually came out of Phil Bergs office, well,

> filing lawsuits would be an excellent cover, huh?

>

> Factcheck is in Pennsylvania.

>> As is Phil Berg.

>>

> Lisa Ostella

> Defend Our Freedoms Foundation> http://defendourfreedoms.org

> Peace through Strength

> http://www.barofintegrity.com >

>

>>

>

>

>>

> > From: [email protected]

> > To: [email protected]> > Subject: RE: HELLO ??? (again)

> > Date: Sun, 15 Mar 2009 16:35:46 -0700

> >> > Yes but a SEAL !!, and HOW MANY aliases?

> >

> > Original Message> > From: Lisa Ostella [mailto:[email protected]]

> > Sent: Sunday, March 15, 2009 3:46 PM

> > To: Neil Sanky> > Subject: RE: HELLO ??? (again)

> >


28/38


> > Insight, such as, Lisa Liberi (Phil Bergs assistant) really being Lisa

> > Richards, with a police record for ID theft?> >> > Mighty convenient talent to have when there are multiple identities flying

> > around.

> >> > Ive not researched that insight yet. I didnt have a warm and fuzzy

> > interaction with (redacted name of volunteer )So I dont know if this is planted info

droppings> > or not.

> >

> >> > Lisa Ostella

> > Defend Our Freedoms Foundation

> > http://defendourfreedoms.org

> > Peace through Strength

> > http://www.barofintegrity.com > >

This entry was posted on Sunday, May 31st, 2009 at 2:19 pm and is filed underUncategorized. You can

follow any responses to this entry through the RSS 2.0 feed. You can leave a response, ortrackbackfrom

your own site.

Dr. Orly Taitz Esquire is proudly powered by WordPress

Entries (RSS) and Comments (RSS).

19.

The above emails are altered and forged emails as broken down in

EXHIBIT 1. I did not authorize any party to alter, fabricate, draft or send out

emails using my email address, name and/or Company name.

20. I have also reported the crimes of Conspiracy to Commit a Felony andForgery to Detective Cano with the North Brunswick Police Department as a

result of Defendants Neil Sankey and Orly Taitz criminal activities.


29/38


I declare under the penalty of Perjury of the laws of the United States that the

foregoing is true and correct. Executed this 8th

day of June, 2009.

__________________________

LISA OSTELLA, Plaintiff

s/ Lisa Ostella


30/38


EXHIBIT 1


31/38

1

http://www.orlytaitzesq.com

/blog1/?p=1843

Dr.OrlyTaitzE

squire

DefendOurFreedomsFoundation26302LaPazste211,Missio

nViejoCA92691Copyright2009

FromreaderBobS.Didanyon

eseeHankPaulsoncomingout

ofhishouselately?

ReKeyesvObama

Iamt

ryingtostayawayfromL

iberi-Bergissue,

butigotmorequestionsandhereismor

einfo.

Iwasaskedbyanumberofpeopletoexplainwhythenameof

LisaOstellaisonthedossier#4.

WhenIwasinWashingtonDC

,Ididnothaveanaccessto

the

Internet,asIwasvisitingthe

DirectoroftheSelectiveServ

ice

WilliamChatfieldandofficeso

fseveralsenatorsandwason

the

phonewiththeassistantandlegalcounselforAdmiralMalin.A

lot

ofpeopleaskedmeforanupdateandIcalledLisaOstella,thew

eb

master,andaskedhertopost

itontheInternet.Asyoucan

see,thefactthatshesignedDefendOurfFeedomsFoundations,and

sheputhernameasanassistant

tome,clearlyshowsthatshekn

ew

itismyfoundation,undermy

nameandshecouldsignas

an

assistantonlyaslongasshe

washelpingme.Themom

ent

Itransferredtoanotherwebmaster,shehadandhasnorightto

advertiseonbehalfoftheDefendOurFreedomsfoundation,sol

icit

donationsandpocketthemoney.

Youcanalsosee(intheattach

ment)thatshewastheonethat

contactedtheprivateinvestigato

rMr.Sankey,andprovidedhim

theinformationthatLisaLiber

i,assistanttoPhilBerg,has

a

criminalrecord.Basedonherre

portMr.Sankeyhasinvestigate

d

andconfirmedthisinformation,thatindeedLisaLiberihasth

is

lengthyrecordofforgeryofdoc

umentsandforgeryofanofficial

sealandgrandtheft.LisaOstellachangedhertuneonlyafterth

is


32/38

2

wholeissuewithpay-palcame

out.Atfirstsheandtherestof

theplaintiffscameoutwithan

outrageousliethatmyhusban

d

wasspyingonpeople.Nowtheydismissedtheirlawsuitagain

st

myhusband-andeverybodykn

owsthatitwasamanufacture

d

charge.

Asyoucansee,shewaswellawareaboutLiberiscriminal

record,aswasBergandLibe

riherself.Theirlegalaction

is

nothingbutperjuryandanatt

emptedobstructionofjustice.

I

havewritteninthepleadingsthattheonlyaddressthatLiberi

provided,wasBergsofficeaddressandthereasonisthatsh

e

indeedresidesinNMandisth

eLisaLiberiwiththecriminal

record.Ireceivedane-mailrecentlythatinthelastcoupleof

daysLisaLiberihasgottenaPA

driverslicense.Ifshegotonein

thelastcoupleofdays,thatd

oesntchangethefactthatsh

e

residedinNM

andthatallofthem

committedperjury.

If

anything,gettingaPA

driverslicense

now

isyetanother

attempttoobstructjustice.

AsIhavesaidbefore,Idontge

tintimidatedbyeitherObamaor

byBerg.Onecannotfileafraudulentandmaliciouslegalactio

n

againstmeandexpecttoshutm

eupandmakemestopreportin

g

onillegalandcriminalactivity.

Allthatthesepeoplearedoing,

isaddingcountsoffraud,perjuryandobstructionofjustice.Th

e

onlythingBergcando,iscomeclean,disassociatehimselffrom

LisaLiberi,whohasarecordo

fforgeryandheneedstohire

a

forensicdocumentexaminerto

checkalltherecordshandledb

y

LisaLiberi.Wecannotwinin

courtwithforgedrecords.Th

is

informationwasalreadyontheblogsbeforeIgotitanditwillb

e

ontheblogs,hiscontinuingdenialofclearevidencehasnomerit

and

undermines

everybody

in

the

resistance

movemen

t,

everybodywhowantstogettothetruth.Theonlywaytowin,is

bycleanevidence,unsealingthevitalrecordsandlettingth

e

SupremeCourtdecidetheissueoftheNaturalBornCitizen.

***ThefollowingEmailswiththeaboveposthavebeen

alteredandforged


33/38

3

FORGEDANDALTERNEDEMAILplacedonOrlyTaitzswebsite

ORIG

INALCORRECTUN-ALTER

EDEMAILWHICH

athttp://www.orlytaitzesq.c

om/blog1/?p=1843BYOrly

Taitz

WAS

SENTANDRECEIVED:

NUMBER1:

NUM

BER1:

>

From:nsankey@thesankeyfirm

.com

>From

:[email protected]

>

To:[email protected]

>To:[email protected]

>

Subject:RE:HELLO???(again)


>

Date:Sun,15Mar200917:02:00-0700

>Date:Sun,

15Mar200917:02:00-0700

>

>

>

Indeeditwould.Ifyouwould

passthisontoDr.O,IwillgoouttoSanBdo

>IfyouwouldpassthisontoDr.O,

Iwillgo

outtoSanBdo

>

thisweekandhavealookatth

e2002file,dontchathink?

>this

>

>N

>

N

>

>N

UMBER2:

NUMBER2:

>OriginalMessage

>From:LisaOstella[mailto:[email protected]]

NOSU

CHEMAILEXISTSNEVERSENTNUMBER2ON

>Sent:Sunday,March15,20094:49PM

ORLYTAITZWEBSITEISACOMPLETEM

ANUFACTURED

>To:NeilSanky

ANDFORGEDEMAIL


>

>Hmm,iftheforgeddocumentsac

tuallycameoutofPhilBergsoffice,well,

>filinglawsuitswouldbeanexcellentcover,huh?

>>ornot.

>FactcheckisinPennsylvania.

>

>AsisPhilBerg.

>

>

>LisaOstella

>DefendOurFreedomsFoundatio

n

>http://defendourfreedoms.org

>PeacethroughStrength

>http://www.barofintegrity.com

>


34/38

4

NUMBER

3:

NUMBER

3:

>>From:nsankey@thesankeyfirm

.com

Actual

EmailNoAlterationsonthisdocument

>>To:[email protected]


>>Date:Sun,15Mar200916:35:46-0700

>>

>>YesbutaSEAL!!,andHOWM

ANYaliases?

>>

NUMBER

4:

NUMBER

4:

>>OriginalMessage

>>----

-OriginalMessage-----

>>From:LisaOstella[mailto:[email protected]]

>>Fro

m:LisaOstella[mailto:lisaostella@h

otmail.com]

>>Sent:Sunday,March15,2009

3:46PM

>>Sent:Sunday,March15,

20093:46PM

>>To:NeilSanky

>>To:NeilSanky



>>

>>

>>Insight,suchas,LisaLiberi(Ph

ilBergsassistant)reallybeingLisa

>>I've

notresearchedthatinsightyet.Idid

n'thaveawarmandfuzzy

>>Richards,withapolicerecordforIDtheft?

>>interactionwithSarah.

SoIdon'tknowifthisisplantedinfodroppings

>>

>>ornot.

>>Mightyconvenienttalenttohavewhentherearemultipleidentities

flying

>>

>>around.

>>

>>

>>LisaOstella

>>Ivenotresearchedthatinsight

yet.Ididnthaveawarmandfuzzy

>>DefendOurFreedomsFoundation

>>interactionwith(redactedname

ofvolunteer)SoIdontknowifthisisplantedinfo

>>De

fendOurFreedomsFoundation

droppings


>>ornot.


>>


>>LisaOstella




>>

Thisen

trywaspostedon

Sun

day,M

ay31st,

2009at

2:1

9pm

andisfiledun

der

Unca

tegorize

d.

Youcan

followanyre

sponses

tothisen

try

throug

hthe

RSS

2.0

feed.

Youcan

leavearesponse,

or

trac

kback

fromyourownsi

te.

Dr.

Orly

Tai

tzEsqu

ireis

prou

dlypowered

by

Word

Press

En

tries

(RSS)an

dCommen

ts(RSS).


35/38

5

***

NoteonNumber4:The

smileyintheforgedemailbearstheexactsamesmileyfaceuse

dbyOrlyTaitzonherwebsiteat


***

NOTENEILSANKE

YWITHTHESANKEYFIR

MWASONPLAINSRADIO,www.plainsradio.comONMAY28,2009WHEREIN

NEILSANKEYSTATED:

IRECEIVEDANEMAILFROMLISAOSTELLASTATINGLISALIBERI(PHILBE

RGSASSISTANT)WAS

R

EALLYLISARICHARDSWITHAPOLICERECORDFOR

IDENTIFICATIONTHEFT.


36/38


EXHIBIT C


37/38

Page 1

http://www.lexis.com/research/smb/tp/legalhome/?_b=0_421767556

View: Results List | Full

1 of2

Search: Locate a Person (Nationwide) Search > Search Results > Source Documents

1 OF 1 RECORD(S)

Historical Person LocatorThis data is for informational purposes only.

Finder InformationName: NASH, SHOLANDA

Address: 375 BALDWIN PYKATY, TX 77449HARRIS COUNTY

SSN:

Historical Person LocatorThis data is for informational purposes only.

Finder InformationName: NASH, SHOLANDA

Address: 375 BALDWIN PYKATY, TX 77449HARRIS COUNTY

SSN:

Important: The Public Records and commercially available data sources used on reports have errors. Data is sometimes entered poorly, processedincorrectly and is generally not free from defect. This system should not be relied upon as definitively accurate. Before relying on any data this systemsupplies, it should be independently verified. For Secretary of State documents, the following data is for information purposes only and is not an officialrecord. Certified copies may be obtained from that individual state's Department of State.

Copyright 2009 LexisNexis, a division of Reed Elsevier Inc. All rights reserved.

(03/2009-Current)

375 BALDWIN PY

KATY, TX 77449

HARRIS COUNTY

No. Full Name Address Phone SSN View Source Documents

HOUSTON, TX 77090-1502 Potential Moderate Risk

HARRIS COUNTY SSN linked to multiple people

Terms: ssn(XXX-XX-XXXX) state(ALL) radius(30) ( Edit Search |New Search )

XXX-XX-XXXX

XXX-XX-XXXX

1. NASH, SHOLANDA 910 CYPRESS STATION DR APT XXX-XX-XXXX(CA:2000)

ssn(XXX-XX-XXXX) state(ALL) radius(30) 2 Locate a Person (Nationwide) Search 06/01/2009 01:53:01 Re-Run/Edit


38/38


UNITED STATES DISTRICT COURT,


LISA LIBERI, et al,

Plaintiffs,

vs.

ORLY TAITZ, et al,

Defendants.

:::::

:::::


CERTIFICATE OF SERVICE

I, Philip J. Berg, Esquire, hereby certify that a copy of Plaintiffs Motion to Strike

Defendants, Orly Taitz, et al and Defend our Freedoms Foundation, Inc., Opposition to

Injunction was served this 11th day of June 2009 electronically upon the following:

Orly Taitz, et al.31912 Monarch Crest

Laguna Niguel, CA 92677

Email: [email protected]

Defend our Freedoms Foundation, Inc. a/k/a

Defend our Freedoms Foundation26302 La Paz, Suite 211

Mission Viejo, CA 92691

Email: [email protected]

________________________

PHILIP J. BERG, ESQUIREAttorney for Plaintiffs

s/ Philip J. Berg