liberi v taitz - berg motion for injunction/tro - 3

8/14/2019 LIBERI v TAITZ - Berg Motion for Injunction/TRO - 3

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UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIA

LISA LIBERI, et al, Plaintiffs,

vs.

ORLY TAITZ, et al,Defendants.

::::::::::

Assigned to Honorable Eduardo C. Robreno

Case No.: 09-cv-01898-ECR

ORDER

AND NOW, this _____ day of June, 2009, it is hereby

ORDERED and DECREED that:

(1) A Restraining Order is issued. Defendants Orly Taitz a/k/a Dr. Orly Taitz

a/k/a Law Offices of Orly Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation;

Neil Sankey; The Sankey Firm, Sankey Investigations, Inc., Linda Sue Belcher a/k/a

Linda S. Belcher a/k/a Linda Starr a/k/a Newwomensparty a/k/a Stitchenwitch a/k/a Eva

Braun a/k/a Web Sergeant a/k/a Katy a/k/a www.obamacitizenshipdebate.org ; Edgar (Ed)

Hale a/k/a JD Smith; Caren Hale; Bar H Farms; Plains Radio Network, Inc. a/k/a Plains

Radio; and KPRN AM 1610 and all parties acting on their behalf are enjoined from airing

and/or publishing any defamatory or false statements about Plaintiffs, Lisa Liberi, Philip

J. Berg, the Law Offices of Philip J. Berg, Evelyn Adams, Lisa Ostella, the Plaintiffs

family members, etc. via the internet or any other print or electronic medium or

broadcasts and/or radio, from portraying Plaintiffs in a false-light via the internet or

Case 2:09-cv-01898-ER Document 66 Filed 06/23/2009 Page 1 of 37


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another print or electronic medium or broadcasts and/or radio, untrue statements about

the Plaintiffs;

(2) Defendants Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly

Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation; Neil Sankey; The Sankey

Firm, Sankey Investigations, Inc., and all parties acting on their behalf are enjoined from

disseminating, publishing, e-mailing, posting and distributing Liberis Social Security

number, date of birth, mothers maiden name, residency, place of birth and all other

personal identifying information;

(3) Defendants Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of OrlyTaitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation; Neil Sankey; The Sankey

Firm, Sankey Investigations, Inc., Linda Sue Belcher a/k/a Linda S. Belcher a/k/a Linda

Starr a/k/a Newwomensparty a/k/a Stitchenwitch a/k/a Eva Braun a/k/a Web Sergeant

a/k/a Katy a/k/a www.obamacitizenshipdebate.org ; Edgar (Ed) Hale a/k/a JD Smith;

Caren Hale; Bar H Farms; Plains Radio Network, Inc. a/k/a Plains Radio; and KPRN AM

1610 are enjoined from any further harassment; invasion of privacy; violation of rights to

privacy; cyber stalking; cyber harassment; cyber invasion of privacy; of the Plaintiffs;


Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation, Inc., are enjoined from the

filing and reporting of falsified criminal activity, etc;


Taitz a/k/a Orly Taitz, Inc., Defend our Freedoms Foundation, Inc., Neil Sankey, the

Sankey Firm and Sankey Investigations and any party who has published Lisa Liberis

confidential information and false accusations of criminal activities posted, published,



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disseminated about Lisa Liberi on their behalves to immediately retract and remove Lisa

Liberis private confidential information, including but not limited to her Social Security

number, date of birth, where she resides, mothers maiden name; fathers name; place of

birth; information about her husband, the false criminal accusations;


Taitz a/k/a Orly Taitz, Inc., Defend our Freedoms Foundation, Inc., and anyone on their

behalf are enjoined from disseminating, publishing, e-mailing, posting and distributing

Lisa Ostellas personal and confidential information, including but not limited to her

home address, telephone number and maiden name;(7) Defendants Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly

Taitz a/k/a Orly Taitz, Inc, Defend our Freedoms Foundation, Inc., and any party who has

published Lisa Ostellas confidential information and false accusations of criminal

activities posted, published, disseminated about Lisa Ostella on their behalves to

immediately retract and remove Lisa Ostellas private confidential information, including

but not limited to her home address, telephone number and maiden name and the false

criminal accusations;


Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation; Neil Sankey; The Sankey

Firm, Sankey Investigations, Inc., James Sundquist; Rock Salt Publishing; Linda Sue

Belcher a/k/a Linda S. Belcher a/k/a Linda Starr a/k/a Newwomensparty a/k/a

Stitchenwitch a/k/a Eva Braun a/k/a Web Sergeant a/k/a Katy a/k/a

www.obamacitizenshipdebate.org ; Edgar (Ed) Hale a/k/a JD Smith; Caren Hale; Bar H

Farms; Plains Radio Network, Inc. a/k/a Plains Radio; and KPRN AM 1610 are



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ORDERED to retract all slander and libel disseminated, posted, published and e-mailed

about Plaintiffs Lisa Liberi, Philip J. Berg, the Law Offices of Philip J. Berg, Evelyn

Adams, Lisa M. Ostella and Go Excel Global;

(9) Defendants Orly Taitz, Esquire a/k/a Orly Taitz a/k/a Dr. Orly Taitz a/k/a

Law Offices of Orly Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation are

ORDERED to issue a cashiers check in the amount of Twenty Thousand [$20,000.00]

Dollars payable to Lisa Liberi through this Court within seventy-two [72] hours;

(10) Defendants Orly Taitz, Esquire a/k/a Orly Taitz a/k/a Dr. Orly Taitz a/k/a

Law Offices of Orly Taitz a/k/a Orly Taitz, Inc; Defend our Freedoms Foundation areORDERED to pay Plaintiffs Counsel, Philip J. Berg, Esquire Attorney fees in the

amount of Five Thousand [$5,000.00] Dollars; and

(11) The Social Security Administration is ORDERED to immediately issue a

new Social Security number to Plaintiff Lisa Liberi in order to ensure her safety.

IT IS SO ORDERED:

Date: June _____, 2009 ______________________________ U.S. District JudgeEduardo C. Robreno, J.



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Z:\Liberi Injunction 06 09 1

Law Offices of:PHILIP J. BERG, ESQUIRE555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531 Attorney for: PlaintiffsIdentification No. 09867(610) 825-3134


LISA LIBERI, et al,Plaintiffs,

vs.


::::::::::



PLAINTIFFS EMERGENCY MOTION FOR THE ISSUANCE OF PLAINTIFFSINJUNCTION or RESTRAINING ORDER REQUESTED IN PLAINTIFFSMOTION FILED and DOCKETED as DOCUMENT NO. 3 ON MAY 4, 2009

NOW COMES the 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 and respectfully requests this Honorable

Court to grant their Emergency Injunction or a Restraining Order against Defendants,

Orly Taitz, Esquire a/k/a Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly Taitz

a/k/a Orly Taitz, Inc [hereinafter Taitz]; Defend our Freedoms Foundation; Neil

Sankey [hereinafter Sankey]; The Sankey Firm, Sankey Investigations, Inc; Linda Sue

Belcher a/k/a Linda S. Belcher a/k/a Linda Starr a/k/a Newwomensparty a/k/a



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Stitchenwitch a/k/a Eva Braun a/k/a Web Sergeant a/k/a Katy a./k/a

www.obamacitizenshipdebate.org [hereinafter Belcher]; Edgar (Ed) Hale a/k/a JD

Smith [hereinafter Mr. Hale]; Caren Hale [hereinafter Mrs. Hale]; Bar H Farms;

Plains Radio Network, Inc. a/k/a Plains Radio [hereinafter Plains Radio]; and KPRN

AM 1610, on the following grounds:

1. Plaintiffs filed for an Emergency Injunction or Restraining Order on May

4, 2009 appearing on the Docket as document number 3. To date, this Motion has

not been ruled upon and the Defendants behaviors have intensified. Inasmuch,

Plaintiffs have been suffering serious damages.2. Plaintiffs hereby incorporate by reference their original May 4, 2009

Motion for an Emergency Injunction [Doc. #3] and their Complaint filed May 4,

2009, [Doc. #1] as if fully set forth herein.

3. As set forth in detail below, Plaintiffs are in immediate need of an

Emergency Injunction or Restraining Order to prohibit further violations of the

following by the Defendants:

The disclosure, posting on the internet, sending through RSS

Feeds, e-mailing, etc. of Plaintiff, Lisa Liberis Social Security

number, date of birth, mothers maiden name, where she was born

and other confidential private information. in violation of State and

Federal Laws, e.g. the Social Security Act, California Privacy

Laws, Civil Code 1798 et sequitur; Identity Theft and

Assumption Deterrence Act, 18 U.S.C. 1028(a)(7); Pennsylvania

Privacy Acts (74 Pa. Stat. Ann. 201 (West 2006); California

Business and Professions Code 22577(a); the Electronic

Communications Privacy Act, 18 U.S.C. 2510-22, and the

Stored Communications Act, 18 U.S.C. 2701-11.



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Cyber harassment, Cyber stalking, etc. in violation of the

Womens Violence Act, Department of Justice Reauthorization

Act of 2005, H.R. 3402, titled "Preventing Cyber stalking" and

numbered as 113, 113(a)(3) provides that Section 223(a)(1)(C)

applies to "any device or software that can be used to originate

telecommunications or other types of communications that are

transmitted, in whole or in part, by the Internet; Cyber-stalking and

Cyber-harassment laws in violation of the Communications Act,

47 U.S.C. 223(a)(1)(C) and 223(h)(1)(B).

Slander and Libel.

Harassment. Calling for individuals in the locations which Plaintiffs reside.

4. Plaintiffs Counsel appeared before Your Honor on May 4, 2009 when he

filed the above referenced action seeking an Immediate Temporary Injunction and/or

a Temporary Restraining Order to prevent the harm the Defendants in the within

action have and continue to cause.

5. Your Honor stated once all the Defendants have been personally served

with the Summons, Complaint, the Emergency Motion for the Temporary Injunction,

Memorandum of Law in Support of the Emergency Motion for a Temporary

Injunction and/or Temporary Restraining Order to contact your chambers and inform

you service was complete and Your Honor would set a phone conference for Counsel

over this issue. Plaintiffs Counsel wrote to Your Honor on May 12, 2009 requesting

a telephone conference.

6. On May 11, 2009, Plaintiffs Counsel contacted your Honors chambers as

he was instructed to do to inform Your Honor all Defendants had been served with



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the exception of James Sundquist and Rock Salt Publishing. Counsel was instructed

to send a letter, which he did on May 12, 2009. Counsel never heard back from Your

Honors chambers.

7. On May 14, 2009, Plaintiffs Counsel sent a second [2 nd] letter to Your

Honors chambers Ex Parte as Defendant Taitz and Defend our Freedoms

Foundation, Inc.s behaviors were becoming more serious and Taitz had just released

the information on a Sealed case of Plaintiffs Counsel. On May 15, 2009,

Plaintiffs Counsel again called Your Honors chambers and was told Your Honor

was reviewing the letter and someone would be back in touch. To date, no one fromYour Honors Chambers has contacted my offices.

8. Plaintiffs Counsel has attempted to have this matter heard before

Plaintiffs suffered any further injury, unfortunately, Counsel has been unsuccessful.

9. All Defendants have been personally served. Despite being served, all the

Defendants, except James Sundquist and Rock Salt Publishing,have continued their

illegal and harmful behaviors. In fact, Defendant, Orly Taitz, an Attorney, somehow

obtained the information to a case of mine which was filed Under Seal and

published it on her website at www.orlytaitzesq.com . At that time I wrote to Your

Honor Ex Parte on May 14, 2009 requesting the entry of an Injunction or

Restraining Order.

10. Major additional problem that needs Emergency attention.

Yesterday, Monday, June 22, 2009, Defendant Orly Taitz, Esquire, et al has now

published where Lisa Liberi was born and her mothers maiden name . See

EXHIBIT 1. This coupled with the fact Ms. Taitz has published and still



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continues to publish Lisa Liberis full Social Security number and date of birth places

Mrs. Liberi in serious risk of theft, identity theft, people can pull Mrs. Liberis credit

file, etc., which Mrs. Liberi has absolutely no protections from.

11. Mrs. Liberi will now suffer serious damages as a result of Mrs. Taitz

publication of Mrs. Liberis full Social Security number, date of birth, mothers

maiden name, where Mrs. Liberi was born, etc. To name a few, Mrs. Liberi is at

serious risk of:

a. Birth Certificates from Washington State are public record;Anyone now can obtain Liberi's birth certificate and completely

assume her identity. b. Anyone can now obtain Liberi's financial records; Social Security

records; credit file (which has Liberi's home address).

c. Anyone can obtain an Intellus report on Liberi now they have her Social Security number, date of birth, mother's maiden name, placeof birth and father's name and obtain all Liberi's financial records,assets, etc.

d. Anyone can apply for credit using Liberi's personal identifyinginformation. Mrs. Taitz has now given them every aspect requiredto obtain credit.

e. Mrs. Liberi must close all her current accounts and place freezeswhich means she will not have any open credit to use.

f. Mrs. Taitz has called for people where Liberi resides andhas called for the purging of Obama and his clique; she has calledfor Armed Rebellion against our Government; she has called for civilian militia that places Liberi, her kids and her husband insevere danger of bodily harm.

g. Mrs. Liberi must now move, which means her husband will haveto take off work, she will have to pay a large amount of money toget into a new residence, she will have to pay movers, plus pay to

break her current lease; Liberi will have to pay disconnect andreconnection fees and again with absolutely no available credit tohelp her.



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h. Mrs. Liberi must obtain a Court Order for the re-issuance of a newSocial Security number and the re-issuance of a new SocialSecurity number takes approximately 6-8 weeks and will not haveany availability to credit and will have to start all over building anew credit history.

i. Defendant, Orly Taitz should be immediately ordered to pay LisaLiberi Twenty Thousand [$20,000] Dollars within 72 hoursthrough this Court so Mrs. Liberi is able to take the above stepsnecessary to protect herself and family.

12. It is important to note, Mrs. Liberis Social Security number was

originally issued out of Texas, so no one was aware of where Mrs. Liberi was born,

her mothers maiden name, etc. It should also be noted, as a result of Orly Taitz,Esquire illegal actions, a woman in Texas is now using Mrs. Liberis Social Security

number, see EXHIBIT 2 .

13. Mrs. Liberis Social Security number was changed when she, her son and

her husband were issued a confidential address to protect them from further tracking

and domestic violence she and her son were victims of.

14. After service of the Complaint and other documents in this case,

Defendant Taitz continued sending our her Dossier #6, which has been previously

submitted to this Court, with Lisa Liberis personal identifying information, including

but not limited to name, date of birth and full Social Security number. Plaintiffs

hereby incorporate all Exhibits, Exhibits A through Q attached to their

Opposition [Doc. No. 63] to Defendant Orly Taitz, Esquire and Defend our Freedoms

Foundation, Inc. Second Amended Motion to Dismiss.

15. In addition, Plaintiff Lisa Ostella has lost every one of her clients as a

result of Mrs. Taitz illegal activities and falsified rumors. Plaintiffs have been



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harassed, their privacy completely invaded, their personal information posted on the

Internet, sent in mass e-mailing (Orly Taitz Dossier #6 with Mrs. Liberis full Social

Security number and other personal identifying information was sent to in excess of

140,000 individuals and companies, including internationally); Plaintiffs have been

placed in a false light before the public, etc. This information has continued since the

Defendants were served with the Complaint and Motion for an Injunction.

16. Moreover, Mrs. Taitz is continuing her attempts to show some type of

connection between Mrs. Liberi and President Obama, including President Obamas

family, which is a total lie. This is important because Mrs. Taitz has called for thepurging of President Obama and his clique, see EXHIBIT 3 .

17. Mrs. Taitz through Defend our Freedoms Foundation as well the other

Defendants actions includes, just giving a few, but are not limited to:

Publication of Lisa Liberis full Social Security number, date of birth,where she was born, mothers maiden name, etc.

The Hale Defendants & Sankey publicly announced Lisa Liberi hadrecently taken out a loan; The Hale Defendants stated they were givendocuments with Lisa Liberis confidential and private information by

Neil Sankey, which Sankey collaborated on the Hale radio shows;

Mrs. Taitz through Defend our Freedoms Foundation, Inc. and the SankeyDefendants conspired and illegally altered and forged e-mails of Plaintiff Lisa Ostella;

Mrs. Taitz through Defend our Freedoms has called for people in theareas that the Plaintiffs reside; have called for information regardingfinancials, Social Security numbers, where they live, previous addresses,voting records, associations, etc. of Lisa Liberi and her husband; andEvelyn Adams and her husband;

Mrs. Taitz through Defend our Freedoms Foundation, Inc. have filedfalsified law enforcement reports against Lisa Liberi and Lisa Ostellaclaiming these two Plaintiffs are one and the same and that they diverted



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funds from her PayPal Account; hacked her PayPal Account, stolenfrom her, the same allegations Mrs. Taitz made against President Obamaand his thugs; and Danny Bickell, U.S. Supreme Court Clerk;

Mrs. Taitz through Defend our Freedoms Foundation, Inc. have inferred

Plaintiffs are President Obamas clique and they are Obots, Mrs.Taitz through Defend our Freedoms Foundation, Inc. have called for the political purging of President Obama and his Clique. As this Court isaware, the definition of purge in the political sense is to Kill.

The Hales on their radio show, Plains Radio Network, Inc. have continuedtheir slander and libel of Plaintiff Evelyn Adams, calling her heinousnames, stating she is going to prison, falsely accusing Mrs. Adams of stealing their Obama divorce papers, falsely accusing Mrs. Liberi of removing the watermark from their divorce papers, falsely claimingPlaintiff Philip J. Berg is stealing peoples money, has no pending cases,

is a shyster, etc. Linda Sue Belcher, et al has continued her slander and libel of the

Plaintiffs by stating Plaintiff Berg and Mrs. Liberi lied on Affidavitswhich were filed in the Federal Courts; claimed something was going tohappen to Mrs. Liberi which will make Plaintiff Berg very unhappy;falsely inferred Plaintiff Berg is having affairs and stating she (Linda S.Belcher) was going to contact his significant other, Carol and tell her which will force Plaintiff Berg to call Mrs. Liberi a liar; threatening

bodily harm to Mr. Berg and Mrs. Liberi if they step foot in her (LindaBelchers) neck of the woods which is the Western District of Texaswhere Linda Belcher is attempting to have this case moved; falselyaccusing Mrs. Liberi and Mr. Berg of tapping her cell phone, etc.

18. All of the above has been filed with this Court in Plaintiffs Briefs in

Opposition to Mrs. Taitz and Defend our Freedoms Foundation, Inc. frivolous filings.

The events that took place prior to the filing of this lawsuit were included in

Plaintiffs Complaint and Motion for an Emergency Injunction or Restraining Order.

19. It should be noted by this Court, with the exception of Defendants Orly

Taitz, Esquire, et al and Defend our Freedoms Foundation, Inc, none of the

other Defendants have opposed Plaintiffs Emergency Motion for an Injunction

or Temporary Restraining Order prohibiting these illegal behaviors. In fact, Ms.



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Taitz and Defend our Freedoms Foundation, Inc. did not have Standing to

file their Opposition to Plaintiffs Motion for the Emergency Injunction as Default

had been entered and Judgment by Default packages had been filed with this Court

prior to their late filings.

20. James Sundquist and Rock Salt Publishing were originally named in this

suit for two (2) e-mails they sent out pertaining to Lisa Ostella. Defendants James

Sundquist and Rock Salt Publishing are the only Defendants who have refrained

from their illegal and tortuous behavior. In addition, Plaintiffs have a pending

Motion for Leave to Dismiss Defendants James Sundquist and Rock Salt Publishing.21. Now that all Defendants have been personally served pursuant to this

Courts Order, and with the exception of the Defaulted Defendants, have entered their

appearances, and the continuance illegal behaviors of the Defendants which are

causing continued harm to the Plaintiffs, Plaintiffs through their counsel are

requesting the issuance of the Emergency Injunction and/or Restraining Order.

22. In addition, Plaintiffs through their undersigned counsel respectfully

request Five Thousand Dollars [$5,000.00] payable to Philip J. Berg, Esquire to cover

the research and drafting of this brief, preparation and hearing on this matter.

WHEREFORE , Plaintiffs respectfully prays that this Honorable Court:

A. Grant Plaintiffs Motion for an Emergency Injunction and/or

Restraining Order prohibiting the Defendants from any further slander and/or

libel;



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B. An immediate Order enjoining the Defendants Orly Taitz, Esquire

a/k/a Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly Taitz a/k/a Orly

Taitz, Inc; Defend our Freedoms Foundation; Neil Sankey; The Sankey Firm,

Sankey Investigations, Inc; Linda Sue Belcher a/k/a Linda S. Belcher a/k/a Linda

Starr a/k/a Newwomensparty a/k/a Stitchenwitch a/k/a Eva Braun a/k/a Web

Sergeant a/k/a Katy a/k/a www.obamacitizenshipdebate.org ; Edgar (Ed) Hale

a/k/a JD Smith; Caren Hale; Bar H Farms; Plains Radio Network, Inc. a/k/a Plains

Radio; and KPRN AM 1610 and all parties acting on their behalf from airing

and/or publishing any defamatory or false statements about Plaintiffs, Lisa Liberi,Philip J. Berg, Esquire, the Law Offices of Philip J. Berg, Evelyn Adams, Lisa

Ostella, Go Excel Global, the Plaintiffs family members, etc. via the internet or

any other print or electronic medium or broadcasts and/or radio, from portraying

Plaintiffs in a false-light via the internet or another print or electronic medium or

broadcasts and/or radio, untrue statements about the Plaintiffs; enjoin the

Defendants from any further harassment of the Plaintiffs, enjoin Defendants

from the filing and reporting of falsified criminal activity, etc.

C. An immediate Order enjoining Defendants Taitz, Defend our

Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey

Investigations, Inc., and any party on their behalf from disseminating Liberis

Social Security number, date of birth, name, where she was born, mothers

maiden name, where she lives, etc.

D. An immediate Order of Retraction against Defendants Taitz,

Defend our Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey



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Investigations, Inc., and any party who has published Liberis confidential

information on their behalves to immediately retract and remove Liberis private

confidential information, including but not limited to her Social Security number,

date of birth, where she resides, her mothers maiden name, where she was born,

information about her husband, etc.

E. A Court Order directed at the Social Security Administration for

the Social Security Administration to issue Lisa Liberi a new Social Security

number;

F. An immediate Order that Defendant Orly Taitz, Esquire andDefend our Freedoms Foundation, Inc. immediately pay Twenty Thousand

[$20,000.00] Dollars within in seventy-two [72] hours through this Court payable

to Plaintiff Lisa Liberi for the relocation of Mrs. Liberi and her family as a result

of the private confidential information Mrs. Taitz has posted, sent out via e-mail,

sent out through the Internet RSS feed, etc.

G. Grant Plaintiffs Attorney fees in the amount of Five Thousand

Dollars [$5,000.00] payable to Philip J. Berg, Esquire within Seventy-Two [72]

hours and such other and further relief as the Court deems just and proper.

. Respectfully submitted,

s/ Philip J. BergDated: June 23, 2009 _____________________________ Philip J. Berg, EsquireAttorney for the Plaintiffs555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531Identification No. 09867(610) 825-3134



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Law Offices of:PHILIP J. BERG, ESQUIRE555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531 Attorney for: PlaintiffsIdentification No. 09867(610) 825-3134



vs.


:::::

:::::



PLAINTIFFS MEMORANDUM OF LAW IN SUPPORT OF THEIR EMERGENCY MOTION FOR THE ISSUANCE OF PLAINTIFFS INJUNCTION

or RESTRAINING ORDER REQUESTED IN PLAINTIFFS MOTIONFILED and DOCKETED as DOCUMENT NO. 3 ON MAY 4, 2009

Plaintiffs hereby incorporate by reference their Complaint filed May 4, 2009

[Doc. #1] and their Motion for an Emergency Injunction and Memorandum of law in

support thereto filed on May 4, 2009 [Doc. #3] as if fully set forth herein.

I. PLAINTIFFS MEET THE BURDEN FOR THIS COURT TOISSUE THE EMERGENCY INJUNCTION OR RESTRAININGORDER:

The traditional standard for granting a Preliminary Injunction requires the

Plaintiff to show that in the absence of its issuance he will suffer irreparable injury and

also that he is likely to prevail on the merits. It is recognized, however, that a district



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court must weigh carefully the interests on both sides, Doran v. Salem Inn, Inc ., 422 U.S.

922, 925 (U.S. 1975), Adams v. Freedom Forge Corp ., 204 F.3d 475, 482 (3d Cir. Pa.

2000), AT&T v. Winback & Conserve Program, Inc ., 42 F.3d 1421, 1427 (3d Cir. 1994);

Acierno v. New Castle Cty ., 40 F.3d 645, 653 (3d Cir. 1994); In re Arthur Treacher's

Franchisee Litig ., 689 F.2d 1137, 1143 (3d Cir. 1982). If relevant, the Court should also

examine the likelihood of irreparable harm to the nonmoving party and whether the

injunction serves the public interest. See AT&T v. Winback , 42 F.3d at 1427.

Plaintiffs are plainly entitled to an Emergency Injunction and/or Temporary Restraining

Order, pursuant to Rule 65 of the Federal Rules of Civil Procedure, to halt the dangerousand illegal behaviors of the Defendants.

Specifically, this Court must grant Plaintiffs Motion for an Emergency Injunction

or Restraining Order because: (1) there is reasonable probability that Plaintiffs will

succeed on the merits; (2) the Plaintiffs will suffer irreparable harm in the absence of

relief; (3) there will be little or no harm to the Defendants if relief is granted; and (4) the public interest demands a grant of relief. See, e.g. Swartzwelder v. McNeilly , 297 F.3d

228, 234 (3 rd Cir. 2002); Prison Health Servs., Inc. v. Umar , Civil Action No. 02-2642,

2002 U.S. Dist. LEXIS 12267 (E.D. Pa. May 8, 2002). The standards for a preliminary

injunction and a TRO are the same. Mertz v. Houstoun , 155 F. Supp.2d 415, 425 n.12

(E.D. Pa 2001); Bieros v. Nicola , 857 F. Supp. 445, 446-47 (E.D. Pa. 1994). While the

degree of probability of success on the merits required to obtain such relief varies among

Federal Courts of Appeals, the U.S. Court of Appeals for the Third Circuit requires only a

reasonable likelihood of success. See Johnson & Johnson Orthopedics, Inc. v.



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Minnesota Mining & Mfg. Co. , 715 F. Supp. 110, 112 n.1 (D. Del. 1989). Plaintiffs

easily meet each of the requirements for an Injunction or Restraining Order .

A. Plaintiffs have already suffered and will continue to sufferirreparable, un-repairable Harm without the issuance of theEmergency Injunction or Restraining Order:

The mere fact Taitz through Defend our Freedoms Foundation, Inc., Sankey, the

Sankey Firm, Sankey Investigations, Inc. have been distributing Liberis Social Security

number, date of birth and now Liberis mothers maiden name, where Liberi was born,

etc. Liberi is at serious risk of individuals using her information, illegally obtaining

credit, assuming Liberis identity, therefore this conduct must be stopped. More

concerning is the fact Sankey through Sankey Investigations, Inc. and the Sankey firm

admittedly furnished Liberis information to Defendants Edgar Hale, Caren Hale, Plains

Radio Network, Inc. KPRN AM 1610 and Bar H. Farms who has publicized they have

Liberis information on their Radio program, Plains Radio. Defendants Mr. Hale, Mrs.

Hale and Sankey have admitted Liberi recently took out a loan, how did they know this

unless they illegally pulled Liberis credit and/or applied for the loan themselves. This is

serious and the Defendants must be stopped.

As a result of Taitz through Defend our Freedoms Foundation, Inc. falsified

statements regarding Plaintiff Lisa Ostella, Ostella has lost all of clients. Unless and until

Taitz and Defend our Freedoms Foundation, Inc. are restrained from any further falsified

publications, Ostella will not be able to rebuild her clientele and therefore has no way of

earning a living.

Plaintiff Bergs damages and continued damages include loss of clients, he will be

unable to secure any clientele that reads all the fabricated statements of the Defendants,



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and the continued harassment of all the Plaintiffs, without the issuance of the within

Emergency Injunction Plaintiffs privacy will continue to be violated, their personal

family affairs broadcast and e-mailed through the Internet, they will continue to be placed

in the false light before the public, they will be raped of their rights to privacy, the

posting of their personal, private affairs as well as embarrassing facts will continue to be

published through mass e-mailing and on the internet and on Defendants Mr. and Mrs.

Hales radio program, Defendant, Plains Radio.

Moreover, Taitz through Defend our Freedoms Network, Inc. have indirectly

called for harm upon the Plaintiffs. Sankey has already threatened to release whereLiberi is located and now with the publication of Liberis Social Security number, date of

birth, mothers maiden name, etc., Liberi is very easy to be found and harmed, as well as

the other Plaintiffs. For the types of damages the Plaintiffs have already suffered and

the irreparable harm they will continue to suffer, Plaintiffs will never be able to be

compensated after the fact by monetary damages. In fact, Liberi is entitled to statutory

damages totaling Four Hundred and Thirty Two Million [$432 Million] Dollars per the

three [3] Defendants, Taitz, Defend our Freedoms Foundation, Inc; and the Sankey Firm

and this still has not stopped them.

In addition, a woman in Houston, Texas is already using Liberis Social Security

number. Moreover, with the danger imposed by Taitz and Defend our Freedoms

Foundation, Inc., this Court must grant Plaintiffs Motion and Order Taitz and DOFF to

immediately pay Twenty Thousand [$20,000.00] Dollars to cover all of Liberis and her

familys expenses to relocated Liberi, her son and husband to ensure Taitz and Defend

our Freedoms Foundation, Inc.s threats are not carried out. Liberi as well as the entire



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Plaintiffs are scared to death and are very concerned about their own lives, the lives of

their children and spouses. Counsel will provide this Court will a medical letter from

Plaintiff Liberis doctor under seal, as Liberi suffers from severe heart problems and this

type of stress is likely to end her life. This Court has the inherent power to grant this type

of immediate relief along with the Injunction. In Schalk v. Teledyne, Inc ., 751 F. Supp.

1261 (W.D. Mich. 1990), aff'd, 948 F.2d 1290 (6th Cir. 1991), for example, the Court

granted a preliminary injunction requiring the company to pay insurance premiums

pending suit in part because "the uncertainty posed by the lack of knowing just how much

money will be needed to cover medical expenses . . . poses irreparable harm in thefinancial planning burden which it places on plaintiffs," id. at 1268.

The irreparable harm requirement is met if a plaintiff demonstrates a significant

risk that he or she will experience harm that cannot adequately be compensated after the

fact by monetary damages. See Frank's GMC Truck Center, Inc. v. General Motors

Corp. , 847 F.2d 100, 102-03 (3d Cir. 1988) .

B. Plaintiff Has A Very Strong Likelihood of Success on the Merits of this Case and Plaintiffs will Suffer Irreparable Harm without theissuance of the Emergency Injunction or Restraining Order:

Defendants have violated Plaintiffs First and Fourteenth Amendment violations;

illegal disclosure of a persons Social Security number, date of birth, mothers maiden

name, where one was born, etc. (CA Civil Code 1798 et sequitur); Invasion of Privacy;

Right to Privacy; Right of Publicity; harassment; endangerment; publication of private

facts; false light invasion of privacy; slander; libel; false designations and description of



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facts in violation of 15 U.S.C. 1125, Cyber Harassment, Cyber Stalking, Cyber

Invasion of Privacy and Cyber Right to Privacy.

Plaintiffs are in possession of the postings, e-mails sent around the United States

and Internationally as well as copies of all the audio shows. Plaintiffs are also in

possession of Taitz Dossier #6, wherein she displays all of Liberis personal identifying

information including Liberis full Social Security number. Plaintiffs are in possession

of all the e-mails distributed by Taitz, Defend our Freedoms Foundation, Inc., Sankey,

the Sankey Firm, Sankey Investigations, Belcher, Mr. and Mrs. Hale, Plains Radio, Bar H

and KPRN.Taitz, Defend our Freedoms Foundation, Inc., Sankey, the Sankey Firm, Sankey

Investigations, Belcher, Mr. and Mrs. Hale, Plains Radio, Bar H and KPRN e-mails,

postings, publishings and radio shows not only have been dangerous to the Plaintiffs,

they are slanderous and libelous and not only placing Liberi and the other Defendants in

danger, they are damaging the Plaintiffs businesses.

Moreover, none of the Defendants have stated any type of defense nor have they

raised affirmative defenses that are now waived. Default was entered May 27, 2009

against three [3] of the Defendants, Taitz, et al, Defend our Freedoms Foundation, Inc.

and The Sankey Firm.

In addition, other than Taitz and Defend our Freedoms Foundation, Inc.s

untimely and inappropriate filings, none of the Defendants have filed any type of

Response or Opposition to Plaintiffs Motion for an Emergency Injunction and/or TRO.

As for Taitz and Defend our Freedoms Foundation, Inc., they were without Standing

before this Court to file any documents other than unliquidated damages, as Default had



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been previously entered. See Sierra Foods, Inc. v. Haddon House Food Prods., Inc .,

1992 U.S. Dist. LEXIS 16667 (E.D. Pa. Sept. 22, 1992) at *14 noting in MOORE'S

FEDERAL PRACTICE, "The defaulting party []loses his standing before the court and

his right to present evidence on issues other than unliquidated damages." 6 James W.

Moore, et al., MOORE'S FEDERAL PRACTICE, P 55.03[2] (2d ed. 1991). Thus, as

long as the Default remains in effect, the pleadings are closed and Defendants are not

entitled to put in issue their version of the facts alleged by Plaintiffs, which is the

substantive result of Taitz and DOFFs failure to timely Answer Plaintiffs Complaint on

the record of this case and the Entry of Default. See Kaplan v. Morse , 870 So. 2d 934(Fla. Dist. Ct. App. 5th Dist. 2004) at *5 (A default generally terminates a partys right

to further defend, except to contest unliquidated damages.); Dalton-Ingersoll Co. v.

Fiske , 175 Mass. 15, 20 (1899), ("[a] person defaulted has no standing in court except to

take off the default."); Thomson v. Wooster , 114 U.S. 104, 5 S.Ct. 788, 29 L.Ed. 105

(1885) (It is the law that once a default is entered, a defendant on default has no further

standing to contest the factual allegations of plaintiff's claim for relief).

By virtue of the Default, the truths of Plaintiffs well-pleaded allegations are

Admitted. They may not be contested on the merits, and have the same effect as if

established by proof. DIRECTV, Inc. v. Crumlish , 2004 U.S. Dist. LEXIS 13680 (E.D.

Pa. July 16, 2004); Comdyne I, Inc. v. Corbin, 908 F.2d 1142 (3d Cir. 1990) (quoting 10

Charles A. Wright et al., Federal Practice and Procedure, 2688 at 444 (1983) (citing

Thomson v. Wooster, 114 U.S. 104, 5 S. Ct. 788, 29 L. Ed. 105 (1885)) ; Duncan v. Lord ,

409 F. Supp. 687, 691 (E.D. Pa. 1976) quoting Trans World Airlines, Inc. v. Hughes, 38

F.R.D. 499 (S.D.N.Y. 1965) ; United States v. Borchers , 163 F.2d 347 (2 Cir. 1947)



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(When a Court determines, . . . that a defendant is in default, its liability to the plaintiff is

deemed established and the plaintiff is not required to establish his right to recover.). See

also I.C.C. v. Smith , 82 F.Supp.39 (D.C.Pa.1949). Defendant is deemed to have

Admitted all well pleaded allegations in the Complaint. At the most, all that

Defendant can do is question the extent of the damages suffered by the Plaintiffs. Trans

World Airline, Inc. v. Hughes, 332 F.2d 602 (2d Cir. 1964), reversed on other grounds,

409 U.S. 363, 93 S.Ct. 647, 34 L.Ed.2d 577 (1973).

See Caribbean Produce Exchange v. Caribe Hydro-Trailer, Inc. , 65 F.R.D. 46, 48

(D.C. Puerto Rico 1974) (subsequent to entry of default, defendant's argument of a late propounded affirmative defense was improper). Taylor v. City of Ballwin, Missouri, et al ,

859 F.2d 1330 (1988) (same), quoting Caribbean , supra and Thomson , supra .

An important factor animating our holding is our respect for the extraordinary

nature of the preliminary injunction power. We have repeatedly insisted that the use of

judicial power to arrange relationships prior to a full determination on the merits is a

weighty matter, and the preliminary injunction device should not be exercised unless the

moving party shows that it specifically and personally risks irreparable harm. See, e.g.,

Campbell Soup Co. v. ConAgra Inc ., 977 F.2d 86, 91 (3d Cir. 1992); Frank's GMC Truck

Center , 847 F.2d at 102-03. This clearly has been met as all the Defendants have

waived their right to any affirmative defenses and have failed to cite any type of defenses

in their Answers, thus the allegations in Plaintiffs Complaint are deemed admitted.



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B. There Will Be Minimal Harm to the Defendants if Relief is Grantedand The Public Interest Supports a Grant of Relief:

Granting Plaintiffs Motion for an Emergency Injunction or Restraining Order

will result in negligible harm, if any, to Defendants as Plaintiffs are merely attempting to

protect their private confidential information; their privacy; false information being sent out,

etc.

Consideration of the relative harm to the Defendant and the public interest also

weighs heavily in favor of Plaintiffs. See Adams , 204 F.3d at 484 (noting district court

should consider these two elements where relevant). First, the irreparable harm Plaintiffs

would suffer in the absence of a preliminary injunction substantially outweighs the harm to

the Defendants from the preliminary injunction ordered. Moreover, issuing a preliminary

injunction against the Defendants will not adversely affect the public interest. To the

contrary, the prevention of First and Fourteenth Amendment violations; illegal disclosure of

a persons Social Security number, date of birth, mothers maiden name, where one was

born, etc. (CA Civil Code 1798 et sequitur); Invasion of Privacy; Right to Privacy; Right of

Publicity; harassment; endangerment; publication of private facts; false light invasion of

privacy; slander; libel; false designations and description of facts in violation of 15 U.S.C.

1125, Cyber Harassment, Cyber Stalking, Cyber Invasion of Privacy, Cyber Right to Privacy,

even that affecting only private citizens, is in the general public interest." F.T. Int'l, Ltd. v.

Mason , 2000 U.S. Dist. LEXIS 14979 (E.D. Pa. Oct. 11, 2000), at *2. See also United States

ex rel. Rahman v. Oncology Assocs. , 198 F.3d 489, 496-97 (4th Cir. 1999).



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III. CONCLUSION

Plaintiffs have demonstrated a very strong likelihood of success that Plaintiffs

will suffer irreparable injury, if relief is denied; the balance of hardships imposes little

burden on the Defendants; and the public interest supports the granting of the requested

relief.

For the above aforementioned reasons, this Honorable Court should grant

Plaintiffs request for an Emergency Injunction or Restraining Order and Order the

following:

A. Grant Plaintiffs Motion for an Emergency Injunction and/or Restraining Order prohibiting the Defendants from any further slander and/or

libel;

B. An immediate Order enjoining the Defendants Orly Taitz, Esquire

a/k/a Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices of Orly Taitz a/k/a Orly

Taitz, Inc; Defend our Freedoms Foundation; Neil Sankey; The Sankey Firm,

Sankey Investigations, Inc; Linda Sue Belcher a/k/a Linda S. Belcher a/k/a Linda

Starr a/k/a Newwomensparty a/k/a Stitchenwitch a/k/a Eva Braun a/k/a Web

Sergeant a/k/a Katy a/k/a www.obamacitizenshipdebate.org ; Edgar (Ed) Hale

a/k/a JD Smith; Caren Hale; Bar H Farms; Plains Radio Network, Inc. a/k/a Plains

Radio; and KPRN AM 1610 and all parties acting on their behalf from airing

and/or publishing any defamatory or false statements about Plaintiffs, Lisa Liberi,

Philip J. Berg, Esquire, the Law Offices of Philip J. Berg, Evelyn Adams, Lisa

Ostella, Go Excel Global, the Plaintiffs family members, etc. via the internet or

any other print or electronic medium or broadcasts and/or radio, from portraying



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Plaintiffs in a false-light via the internet or another print or electronic medium or

broadcasts and/or radio, untrue statements about the Plaintiffs; enjoin the

Defendants from any further harassment of the Plaintiffs, enjoin Defendants

from the filing and reporting of falsified criminal activity, etc.

C. An immediate Order enjoining Defendants Taitz, Defend our

Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey

Investigations, Inc., and any party on their behalf from disseminating Liberis

Social Security number, date of birth, name, where she was born, mothers

maiden name, where she lives, etc.D. An immediate Order of Retraction against Defendants Taitz,

Defend our Freedoms Foundation, Inc., Neil Sankey, the Sankey Firm and Sankey

Investigations, Inc., and any party who has published Liberis confidential

information on their behalves to immediately retract and remove Liberis private

confidential information, including but not limited to her Social Security number,

date of birth, where she resides, her mothers maiden name, where she was born,

information about her husband, etc.

E. A Court Order directed at the Social Security Administration for

the Social Security Administration to issue Lisa Liberi a new Social Security

number;

F. An immediate Order that Defendant Orly Taitz, Esquire and

Defend our Freedoms Foundation, Inc. immediately pay Twenty Thousand

[$20,000.00] Dollars within seventy-two [72] hours through this Court payable to

Plaintiff Lisa Liberi for the relocation of Mrs. Liberi and her family as a result of



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the private confidential information Mrs. Taitz has posted, sent out via e-mail,

sent out through the Internet RSS feed, etc.

G. Grant Plaintiffs Attorney fees in the amount of Five Thousand

Dollars [$5,000.00] payable to Philip J. Berg, Esquire within Seventy-Two [72]

hours and such other and further relief as the Court deems just and proper.

Respectfully submitted,

s/ Philip J. BergDated: June 23, 2009 _____________________________

Philip J. Berg, EsquireAttorney for the Plaintiffs555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531Identification No. 09867(610) 825-3134



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EXHIBIT 1



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http://www.orlytaitzesq.com/blog1/?p=2522

Dr. Orly Taitz Esquire Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691Copyright 2009

Previous Post Ties to Everett, need help with research

,

You mentioned Everett, Wash. connection with Barack Obamas mothers family. Justwondering if you knew that connection went back for over a century

http://www.heraldnet.com/apps/pbcs.dll/article?AID=/20081026/NEWS01/710269867

Plus a bit more about the Wolfleys:http://www.santacruzsentinel.com/world/ci_12517525

So with a POTUS with a Muslim father and German roots mother, why shouldnt Israelis be worried?

If you do post this info, please dont mention my name or email.

Cheers

ResponseI am really concerned about several coincidences1. a man who threatened to shoot me and burn my body for the world to see was trackedto a computer server in Everett WA. Another person that threatened me was traced toChauhelis WA and yet another one to Canada (from what I understand not far from the

border with WA state). A few days after the threat there was a clamp missing and adisconnected fumes emissions hose in my car and my husbands car died, suddenly a fusewas missing.2. Obama does not talk about it, but his mother wasnt in HI when he was a baby, she wasenrolled in the U of Seattle WA from August 1961-till June 1962, which means that as a

baby he lived in WA.3. Lisa Liberi, assistant for Berg, who has a lengthy criminal record of grand theft,forgery of documents and forgery of official seal doesnt talk about it, but accordingto records she was born in WA state. From what I recall Bellview WA. (her name atbirth was Lisa Richardson. From what I recall father -Jack Richardson, motherShirley Wadell)



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4. Obama, Liberi and Obamas mother Stanley Ann Dunham- all have multiplesocial security numbers according to databases.5. Liberi was convicted of forgery of documents and according to experts, there aremultiple signs of forgery in Obamas documents.6. Stanley Ann Dunham also went by the name Shirley Ann Dunham.

We found a Dunham organization, owned by Shirley Ann Dunham; one locationwas in Seattle another in Bellview WA. They dealt with insurances, lawyers,mortgages- you can get ss numbers from all of these records.7. From what I recall, there was a discrepancy between Intellius records and Secretary of state records. According to the sec. of state a man owned that co. One of our volunteers

pulled court records in Bellview for the Dunham organization. This man, Mr. Dunham(dont remember first name) kept changing his middle initial in several court cases,which was suspicious by itself.8. There was a very strange newspaper article in WA (I believe Seattle), from what Irecall, when Obama supposedly was in Columbia. It stated that one, Roman Obamastudied at the university of Patrice Lumumba in Moscow, Russia, and had some financial

difficulties.9. When grandma Dunham got sick, a reporter from WA (I believe Seattle) has writen aninterview with Charles Payne, saying the grandma got a broken hip. She was dead of cancer a few days later. I was wondering, why did it come out in WA, and not HI or IL?10. Based on all of the above, I have a nagging feeling, that there is somebody there inWA, some relative of Obama, somebody who we might think is no longer with us.

This entry was posted on Monday, June 22nd, 2009 at 3:35 pm and is filed under Uncategorized . You canfollow any responses to this entry through the RSS 2.0 feed. You can leave a response , or trackback fromyour own site.

[emphasis added ]



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EXHIBIT 2



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

View: Results List | Full

1 of 2

Search: Locate a Person (Nationwide) Search > Search Results > Source DocumentsTerms: ssn( 622-19-xxxx ) state( ALL ) radius( 30 ) ( Edit Search | New Search )

SelectforDelivery

Historical Person LocatorThis data is for informational purposes only.

Finder InformationName: NASH, SHOLANDA

HARRIS COUNTY

Important: The Public Records and commercially available data sources used on reports have errors. Data is sometimes enteredpoorly, processed incorrectly and is generally not free from defect. This system should not be relied upon as definitively accurate.Before relying on any data this system supplies, it should be independently verified. For Secretary of State documents, thefollowing data is for information purposes only a nd is not an official record. Certified copies may be obtained from that individualstate's Department of State.

About LexisNexis | Terms & Conditions | Contact Us Copyright 2009 LexisNexis , a division of ReedElsevier Inc. All rights reserved.

View: Results List | Full

1 - 2 of 2

Search: Public Records > Locate a Person (Nationwide) Search > Search Results

Terms: ssn( 622-19-xxxx ) state( ALL ) radius( 30 ) ( Edit Search | New Search )

Select for Delivery or View Checked

No.

Full Name Address Phone SSN

View SourceDocuments

1. NASH,SHOLANDA

910 CYPRESSSTATION DR APTHOUSTON, TX 77090-1502HARRIS COU

622-19-XXXX (2000)SSN linked to multiplepeople

SSN: 622-19-XXXX

DR. APTHOUSTON, TX 77090-1502

Address: 910 CYPRESS STATION



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EXHIBIT 3



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

Dr. Orly Taitz Esquire Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691Copyright 2009

KY secretary of state Million Patriots march Follow up on Lisa Liberi, paralegal to Phil Berg

In regards to Lisa Liberi, assistant to Phil Berg. As I stated, she has an extensive criminalrecord of forgery, forgery of seal, grand theft and so on. Lisa Liberi was stating that it isnot her, that it is another Lisa Liber, and that she lives in PA and not NM, however this isnot true. She lives in NM, her home phone number and address is in NM and this can beverified with the probation officer Joanne Martinez fax 505-476-2368, phone 505-827-8627.

I corresponded with John Hemenway ESQ, who filed Hollister v Soetoro case in DC for Phil Berg and he stated that Lisa Liberi, who works for Berg lives in NM. When his sonwas buying a truck in NM, she told him, that she lives there and can assist.

One of former volunteers for Phil Berg has written a statement and went with me to FBIin San Antonio and reported that Lisa Liberi, who works for Berg lives in Santa Fe, NMand she sent Christmas presents to Lisa to NM. Today many employees andvolunteers work from home and correspond via e-mails and phone calls. This volunteer stated that Lisa Liberi corresponds via e-mails and phone. A person will not make areport with FBI and risk going to jail unless she provides a truthful statement. She alsorecorded this statement on video.

I had three confirmations from 3 independent sources of the findings of licensedinvestigator Mr. Sankey Before I posted dossier #6. After all the revelations the name of Lisa Liberi in Mr. Bergs site was changed to Agent88.

I believe, that when non-profit organizations are involved and donations are collected,one should not employ people that are questionable and particularly people that have alengthy criminal record that includes forgery, forgery of seals and grand theft.

I have closed the pay pal account, when I saw that Lisa Ostella has redirected the theDefend Our Freedoms blog and redirected the pay pal. Now there is no pay-pal for thisfoundation and there will not be any more questions. I will be setting a direct visa/creditcard donation button , where donations will go directly to the foundation, so there willnot be a problem of someone redirecting donations by changing the e-mail address on the

pay pal button.

Yet another important matter. So far none of Obama eligibility matters have gone to trialand we all are working hard to change it. But lets say one such case goes to trial. We



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dont want to be impeached by Obamas attorneys saying that we knowinglyemployed shady characters, who mightve supplied us with incorrect information. Justlike the country needs to be purged of Obama and his clique, that are in power byvirtue of forgery, fraud and consealment of vital records, the patriots of this countryneed to purge their ranks.

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[emphasis added]



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

UNITED STATES DISTRICT COURT,FOR THE EASTERN DISTRICT OF PENNSYLVANIA


vs.ORLY TAITZ, et al,

Defendants.

:::::::

:::


CERTIFICATE OF SERVICE

I, Philip J. Berg, Esquire, hereby certify that a copy of Plaintiffs Emergency

Motion for the Issuance of Plaintiffs Injunction or Restraining Order Requested

Plaintiffs Motion filed and Docketed as Document No. 3 on May 27, 2009 was served

this 23 rd day of June 2009 electronically upon the following:

Orly Taitz, et al.31912 Monarch Crest

Laguna Niguel, CA 92677Email: [email protected]

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

Defend our Freedoms Foundation26302 La Paz, Suite 211Mission Viejo, CA 92691

Email: [email protected]



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