LIBERI, et al. v TAITZ, et al. (C.D. CA)

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23580

NOT docketed yet, but Mr. Good Authority sez... Orly is going to have a madz...

[TENTATIVE] ORDER DENYING MOTION TO
TERMINATE

Quote:

After reviewing all papers and arguments submitted, the Court DENIES the Motion.
Because Berg is not licensed to practice law in California, he will need to seek admission
pro hac vice to represent the Plaintiffs in this matter. [highlight]Berg has not yet filed his pro hac vice application[/highlight]. [highlight]Thus, the Court has not yet ruled on whether to admit Berg pro hac vice for this matter,[/highlight] and the Motion is premature. The Court will consider the arguments raised by Defendants when ruling on Berg’s pro hac vice application, if and when he chooses to file one.

Berg needs to file for pro hac vice. $\:D/$

Maru · **Posted:** Fri May 06, 2011 3:06 pm

realist wrote:

NOT docketed yet, but Mr. Good Authority sez... Orly is going to have a madz...

[TENTATIVE] ORDER DENYING MOTION TO
TERMINATE

Quote:

After reviewing all papers and arguments submitted, the Court DENIES the Motion.
Because Berg is not licensed to practice law in California, he will need to seek admission
pro hac vice to represent the Plaintiffs in this matter. [highlight]Berg has not yet filed his pro hac vice application[/highlight]. [highlight]Thus, the Court has not yet ruled on whether to admit Berg pro hac vice for this matter,[/highlight] and the Motion is premature. The Court will consider the arguments raised by Defendants when ruling on Berg’s pro hac vice application, if and when he chooses to file one.

Berg needs to file for pro hac vice. $\:D/$

What? The court hasn't heard of the term "heading them off at the pass"?

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23580

Maru wrote:

realist wrote:

NOT docketed yet, but Mr. Good Authority sez... Orly is going to have a madz...

[TENTATIVE] ORDER DENYING MOTION TO
TERMINATE

Quote:

After reviewing all papers and arguments submitted, the Court DENIES the Motion.
Because Berg is not licensed to practice law in California, he will need to seek admission
pro hac vice to represent the Plaintiffs in this matter. [highlight]Berg has not yet filed his pro hac vice application[/highlight]. [highlight]Thus, the Court has not yet ruled on whether to admit Berg pro hac vice for this matter,[/highlight] and the Motion is premature. The Court will consider the arguments raised by Defendants when ruling on Berg’s pro hac vice application, if and when he chooses to file one.

Berg needs to file for pro hac vice. $\:D/$

What? The court hasn't heard of the term "heading them off at the pass"?

I think it only exists on Orlylaw BS 2nd 2011.

Paul Lentz · **Posted:** Fri May 06, 2011 8:43 pm

So, fellow Oily-law seers, what do you think it'll be:

1. Motion for reconsideration?
2. Interlocutory appeal?
3. Both filed simultaneously?

:?:

Sterngard Friegen · **Posted:** Fri May 06, 2011 8:45 pm

Paul Lentz wrote:

So, fellow Oily-law seers, what do you think it'll be:

1. Motion for reconsideration?
2. Interlocutory appeal?
3. Both filed simultaneously?

:?:

Pfffft. You aren't thinking outside the box, like the Chaleria.

Show Spoiler

TexasFilly · **Joined:** Mon Sep 28, 2009 12:52 pm **Posts:** 10657

realist wrote:

Maru wrote:

What? The court hasn't heard of the term "heading them off at the pass"?

I think it only exists on Orlylaw BS 2nd 2011.

Actually, "heading them off at the pass" is borrowed from the NJ geniuses of Purpura et al., n'est-ce pas?

Mr. Gneiss · **Joined:** Sat Jan 01, 2011 1:37 am **Posts:** 567

My name is Orly Taitz, people call me Dr. Orly Taitz, Esq.

What a maroon! She will be squealing to the Orlyites any minute now

Mikedunford · **Posted:** Fri May 06, 2011 9:26 pm

I was just reading through Berg's opposition to Taitz' anti-SLAPP motion. I have a limited amount of sympathy for some of Berg's co-Plaintiffs, none whatsoever for Berg, and less than that for O'rly. Anyway, I was also watching a MASH re-run at the time, and a very, very apropos quote came on while I was reading:

DR. FREEMAN: You're a victim too, Flagg. But you're such an unbelievable example of walking fertilizer, it's hard for me to care.

Paul Lentz · **Posted:** Fri May 06, 2011 10:02 pm

Sterngard Friegen wrote:

Paul Lentz wrote:

So, fellow Oily-law seers, what do you think it'll be:

1. Motion for reconsideration?
2. Interlocutory appeal?
3. Both filed simultaneously?

:?:

Pfffft. You aren't thinking outside the box, like the Chaleria.

Show Spoiler

Of course! And, if I recall correctly (and I do), Oily has a boilerplate motion for that, originally written by CELIII, which she has already submitted to two different courts...

Show Spoiler

DaveMuckey · **Posted:** Fri May 06, 2011 10:11 pm

Mikedunford wrote:

I was just reading through Berg's opposition to Taitz' anti-SLAPP motion. I have a limited amount of sympathy for some of Berg's co-Plaintiffs, none whatsoever for Berg, and less than that for O'rly. Anyway, I was also watching a MASH re-run at the time, and a very, very apropos quote came on while I was reading:

DR. FREEMAN: You're a victim too, Flagg. But you're such an unbelievable example of walking fertilizer, it's hard for me to care.

Took me a moment... Col. Flagg; what a maroon.

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23580

I don't remember a hearing being scheduled, but apparently there was one yesterday. [thus the reason for the Court sending out the tentative ruling last week, I suppose].

New Docket Entries...

Quote:

05/09/2011 189 MINUTES OF Motion Hearing held before Judge Andrew J. Guilford: re: MOTION TO TERMINATE COUNSEL PHILIP J. BERG. TheCourt orders that the tentative ruling shall become the ruling of this court. Motion DENIED. Court Reporter: Denise Paddock. (rla) (Entered: 05/10/2011)

05/09/2011 188 MINUTES (IN CHAMBERS): ORDER by Judge Andrew J. Guilford: denying 172[RECAP] Motion to TERMINATE: Court DENIES the Motion. Because Berg is not licensed to practice law in California, he will need to seek admission pro hac vice to represent the Plaintiffs in this matter. Berg has not yet filed his pro hac vice application. Thus, the Court has not yet ruled on whether to admit Berg pro hac vice for this matter, and the Motion is premature. The Court will consider the arguments raised by Defendants when ruling on Bergs pro hac vice application, if and when he chooses to file one. (rla) (Entered: 05/10/2011)

verbalobe · **Posted:** Tue May 10, 2011 9:48 pm

Quote:

05/09/2011 188 MINUTES (IN CHAMBERS): ORDER by Judge Andrew J. Guilford: denying 172[RECAP] Motion to TERMINATE: Court DENIES the Motion. Because Berg is not licensed to practice law in California, he will need to seek admission pro hac vice to represent the Plaintiffs in this matter. Berg has not yet filed his pro hac vice application. Thus, the Court has not yet ruled on whether to admit Berg pro hac vice for this matter, and the Motion is premature. The Court will consider the arguments raised by Defendants when ruling on Bergs pro hac vice application, if and when he chooses to file one. (rla) (Entered: 05/10/2011)

I haven't gone back to find it, but I have the weirdest recollection that someone here on TFB predicted precisely this outcome... hmmmm... could that be? How strangely prescient a knowledgeable person can be when they think logically through the applicable law, the rules, and the timeline. :-k

A Legal Lohengrin · **Joined:** Tue Oct 26, 2010 9:56 pm **Posts:** 9395

verbalobe wrote:

I haven't gone back to find it, but I have the weirdest recollection that someone here on TFB predicted precisely this outcome... hmmmm... could that be? How strangely prescient a knowledgeable person can be when they think logically through the applicable law, the rules, and the timeline. :-k

By that, I hope you meant to say "when they've been told by Soros how it's going to turn out, and paid by Soros to predict that outcome." =))

verbalobe · **Posted:** Tue May 10, 2011 9:57 pm

A Legal Lohengrin wrote:

verbalobe wrote:

I haven't gone back to find it, but I have the weirdest recollection that someone here on TFB predicted precisely this outcome... hmmmm... could that be? How strangely prescient a knowledgeable person can be when they think logically through the applicable law, the rules, and the timeline. :-k

By that, I hope you meant to say "when they've been told by Soros how it's going to turn out, and paid by Soros to predict that outcome." =))

D'OH!!

Of course that's what I meant. Mea culpa, mea maxima minimis culpa.

Suranis · **Joined:** Sat Nov 20, 2010 8:04 am **Posts:** 5253

verbalobe wrote:

Of course that's what I meant. Mea culpa, mea maxima minimis culpa.

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23580

New Docket Entry...

Quote:

05/20/2011 190 SUPPLEMENT to MOTION for Leave to file First Amended Complaint ; Memorandum of Points and Authorities in support ; Declaration of Philip J. Berg; Certificate of Service; and Proposed Order 181[RECAP] ; Certificate of Service filed by Plaintiffs PHILIP J. BERG, GO EXCEL GLOBAL, Lisa Liberi, LISA M. OSTELLA, THE LAW OFFICES OF PHILIP J. BERG. (Attachments: # 1 Exibit "A" Plaintiffs 1st Amended Complaint Table of Contents, # 2 Exhibit "A" Plaintiffs 1st Amended Complaint, # 3 Plaintiffs 1st Amended Complaint Exhibits "1" thru "13", # 4 Plaintiffs 1st Amended Complaint Exhibits "14" thru "20", # 5 Plaintiffs 1st Amended Complaint Exhibits "21" thru "26", # 6 Plaintiffs 1st Amended Complaint Exhibits "27" thru "35", # 7 Plaintiffs 1st Amended Complaint Exhibits "36" thru "44", # 8 Plaintiffs 1st Amended Complaint Exhibits "45" thru "47", # 9 Plaintiffs 1st Amended Complaint Exhibits "48" thru "50", # 10 Plaintiffs 1st Amended Complaint Exhibits "51" thru "54", # 11 Plaintiffs 1st Amended Complaint Exhibits "55" thru "57", # 12 Plaintiffs 1st Amended Complaint Exhibits "58" thru "59", # 13 Plaintiffs 1st Amended Complaint Exhibits "60" thru "65", # 14 Plaintiffs 1st Amended Complaint Exhibits "66" thru "67", # 15 Plaintiffs 1st Amended Complaint Exhibits "68" thru "75", # 16 Plaintiffs 1st Amended Complaint Exhibits "76" thru "83", # 17 Plaintiffs 1st Amended Complaint Exhibits "84" thru "90", # 18 Plaintiffs 1st Amended Complaint Exhibits "91" thru "95", # 19 Plaintiffs 1st Amended Complaint Exhibits "96" thru "104", # 20 Plaintiffs 1st Amended Complaint Exhibits "105" thru "112", # 21 Plaintiffs 1st Amended Complaint Exhibits "113" thru "118", # 22 Plaintiffs 1st Amended Complaint Exhibits "119" thru "126", # 23 Plaintiffs 1st Amended Complaint Exhibits "127" thru "131", # 24 Plaintiffs 1st Amended Complaint Exhibits "132" thru "138", # 25 Plaintiffs 1st Amended Complaint Exhibits "139" thru "140", # 26 Plaintiffs 1st Amended Complaint Exhibits "141" thru "142", # 27 Plaintiffs 1st Amended Complaint Exhibits "143" thru "145")(Berg, Philip) (Entered: 05/20/2011)

I'm going to attach the motion, but not all the "exhibits," for obvious reasons. I will, however, post a log of what they are. If anyone just can not live without one/some, lemme know and I'll see about downloading it/them. I have no idea what some of the are, so...

Quote:

Attachment Description
1 Exibit "A" Plaintiffs 1st Amended Complaint Table of Contents 22 pages 166 kb
2 Exhibit "A" Plaintiffs 1st Amended Complaint 198 pages 0.7 mb
3 Plaintiffs 1st Amended Complaint Exhibits "1" thru "13" 48 pages 4.6 mb
4 Plaintiffs 1st Amended Complaint Exhibits "14" thru "20" 44 pages 4.1 mb
5 Plaintiffs 1st Amended Complaint Exhibits "21" thru "26" 70 pages 4.1 mb
6 Plaintiffs 1st Amended Complaint Exhibits "27" thru "35" 44 pages 4.0 mb
7 Plaintiffs 1st Amended Complaint Exhibits "36" thru "44" 43 pages 4.0 mb
8 Plaintiffs 1st Amended Complaint Exhibits "45" thru "47" 29 pages 2.9 mb
9 Plaintiffs 1st Amended Complaint Exhibits "48" thru "50" 25 pages 3.0 mb
10 Plaintiffs 1st Amended Complaint Exhibits "51" thru "54" 41 pages 4.3 mb
11 Plaintiffs 1st Amended Complaint Exhibits "55" thru "57" 35 pages 4.3 mb
12 Plaintiffs 1st Amended Complaint Exhibits "58" thru "59" 21 pages 3.3 mb
13 Plaintiffs 1st Amended Complaint Exhibits "60" thru "65" 34 pages 3.3 mb
14 Plaintiffs 1st Amended Complaint Exhibits "66" thru "67" 23 pages 3.5 mb
15 Plaintiffs 1st Amended Complaint Exhibits "68" thru "75" 35 pages 3.2 mb
16 Plaintiffs 1st Amended Complaint Exhibits "76" thru "83" 41 pages 3.8 mb
17 Plaintiffs 1st Amended Complaint Exhibits "84" thru "90" 40 pages 3.6 mb
18 Plaintiffs 1st Amended Complaint Exhibits "91" thru "95" 51 pages 4.1 mb
19 Plaintiffs 1st Amended Complaint Exhibits "96" thru "104" 40 pages 3.7 mb
20 Plaintiffs 1st Amended Complaint Exhibits "105" thru "112" 64 pages 4.3 mb
21 Plaintiffs 1st Amended Complaint Exhibits "113" thru "118" 37 pages 3.4 mb
22 Plaintiffs 1st Amended Complaint Exhibits "119" thru "126" 47 pages 3.8 mb
23 Plaintiffs 1st Amended Complaint Exhibits "127" thru "131" 29 pages 3.1 mb
24 Plaintiffs 1st Amended Complaint Exhibits "132" thru "138" 51 pages 3.6 mb
25 Plaintiffs 1st Amended Complaint Exhibits "139" thru "140" 35 pages 4.2 mb
26 Plaintiffs 1st Amended Complaint Exhibits "141" thru "142" 26 pages 1.4 mb
27 Plaintiffs 1st Amended Complaint Exhibits "143" thru "145" 37 pages 1.9 mb

link to motion shortly

Sterngard Friegen · **Posted:** Fri May 20, 2011 3:34 pm

I smell a screech demand for sanctions! :lol:

verbalobe · **Posted:** Fri May 20, 2011 4:34 pm

Sterngard Friegen wrote:

I smell a screech demand for sanctions! :lol:

Reminds me of that great scene in Monty Python and the Holy Grail:

Quote:

GIRLS: Sanctions! Sanctions!
DINGO: You must sanction her well. And after you have sanctioned her, you
may deal with her as you like. And then, sanction me.
VARIOUS GIRLS: And sanction me.
And me.
And me.
DINGO: Yes, yes, you must give us all a good sanction!
GIRLS: Sanctions! Sanctions!

Taverl · **Posted:** Fri May 20, 2011 7:28 pm

verbalobe wrote:

Sterngard Friegen wrote:

I smell a screech demand for sanctions! :lol:

Reminds me of that great scene in Monty Python and the Holy Grail:

Quote:

GIRLS: Sanctions! Sanctions!
DINGO: You must sanction her well. And after you have sanctioned her, you
may deal with her as you like. And then, sanction me.
VARIOUS GIRLS: And sanction me.
And me.
And me.
DINGO: Yes, yes, you must give us all a good sanction!
GIRLS: Sanctions! Sanctions!

PLEASE tell me that after this, Dingo declares "And then, the disbarment!" (Girls: "The disbarment! The disbarment!").

'Cause if she returns to the original script... :shock:

Mikedunford · **Posted:** Fri May 20, 2011 9:21 pm

Does anyone have a link to the original complaint? I snagged the full 198 page amended complaint and I think he might have added a few defendants. I don't remember Daylight, Yosef, Oracle, Reed Elsevier, LexisNexis, etc. being defendants before, but I could be wrong. And PACER is down for the next couple of hours, so hard to check.

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23580

Mikedunford wrote:

Does anyone have a link to the original complaint? I snagged the full 198 page amended complaint and I think he might have added a few defendants. I don't remember Daylight, Yosef, Oracle, Reed Elsevier, LexisNexis, etc. being defendants before, but I could be wrong. And PACER is down for the next couple of hours, so hard to check.

Jack Ryan has all the prior pleadings in the case... On Scribd.

And no, those folks were not defendants in the original complaint. But he's not added them yet. He moved for leave to amend... Hasn't been granted. If IIRC, he's amended the complaint at least once already, in PA, of course.

This will get Orly's blood pressure up, though .

Mikedunford · **Posted:** Fri May 20, 2011 9:37 pm

realist wrote:

Mikedunford wrote:

Does anyone have a link to the original complaint? I snagged the full 198 page amended complaint and I think he might have added a few defendants. I don't remember Daylight, Yosef, Oracle, Reed Elsevier, LexisNexis, etc. being defendants before, but I could be wrong. And PACER is down for the next couple of hours, so hard to check.

Jack Ryan has all the prior pleadings in the case... On Scribd.

And no, those folks were not defendants in the original complaint. But he's not added them yet. He moved for leave to amend... Hasn't been granted. If IIRC, he's amended the complaint at least once already, in PA, of course.

This will get Orly's blood pressure up, though .

Yeah, I was trying to find the orignal complaint there, but having difficulties for some reason. Probably because there are so many freaking documents in the case.

As far as the adding of defendants goes, I stand corrected on the difference between wanting to do something and actually being allowed to.

I kind of hope the court grants permission. Bringing lawyers from every major credit reporting firm in the country, plus Yosef, his company, and his insurance firm (again), has quite the amusement potential.

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23580

Mikedunford wrote:

realist wrote:

Mikedunford wrote:

Does anyone have a link to the original complaint? I snagged the full 198 page amended complaint and I think he might have added a few defendants. I don't remember Daylight, Yosef, Oracle, Reed Elsevier, LexisNexis, etc. being defendants before, but I could be wrong. And PACER is down for the next couple of hours, so hard to check.

Jack Ryan has all the prior pleadings in the case... On Scribd.

And no, those folks were not defendants in the original complaint. But he's not added them yet. He moved for leave to amend... Hasn't been granted. If IIRC, he's amended the complaint at least once already, in PA, of course.

This will get Orly's blood pressure up, though .

Yeah, I was trying to find the orignal complaint there, but having difficulties for some reason. Probably because there are so many freaking documents in the case.

As far as the adding of defendants goes, I stand corrected on the difference between wanting to do something and actually being allowed to.

I kind of hope the court grants permission. Bringing lawyers from every major credit reporting firm in the country, plus Yosef, his company, and his insurance firm (again), has quite the amusement potential.

Just FYI, I just heard from Jack and he now has ALL the documents that were filed with the Motion to Amend and the Amended Motion provided by a "friend of Fogbow." :-bd

He does not have time to post them at this time, but will do so at his earliest convenience (hopefully early Saturday morning).

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realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23580

Mikedunford wrote:

Does anyone have a link to the original complaint? I snagged the full 198 page amended complaint and I think he might have added a few defendants. I don't remember Daylight, Yosef, Oracle, Reed Elsevier, LexisNexis, etc. being defendants before, but I could be wrong. And PACER is down for the next couple of hours, so hard to check.

Mike:

Quote:

05/04/2009 1[RECAP] COMPLAINT against defts' ORLY TAITZ, DEFEND OUR FREEDOMS FOUNDATIONS, INC., YOSEF TAITZ, THE SANKEY FIRM, SANKEY INVESTIGATIONS, INC., NEIL SANKEY, JAMES SUNDQUIST, ROCK SALT PUBLISHING, LINDA SUE BELCHER, EDGAR HALE, CAREN HALE, PLAINS RADIO NETWORK, BAR H FARMS, KPRN AM 1610 ( Filing fee $ 350 receipt number PPE000127.), filed by plffs' GO EXCEL GLOBAL, LISA LIBERI, PHILIP J. BERG, THE LAW OFFICES OF PHILIP J. BERG, EVELYN ADAMS, LISA M. OSTELLA. ( FILED IN HARD COPY ) (gn, ) Modified on 5/5/2009 (gn, ). (Additional attachment(s) added on 8/4/2010: # 1 Part 2) (gn, ). (Entered: 05/04/2009)

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23580

It's going to take me some time to get all the documents under docket entry 190 entered here, but in the meantime...

New Docket Entry...

Quote:

05/20/2011 191 JOINT REPORT Rule 26(f) Discovery Plan ; Declaration of Philip J. Berg, Esquire; and Certificate of Service ; estimated length of trial 14 days, filed by Plaintiffs PHILIP J. BERG, GO EXCEL GLOBAL, Lisa Liberi, LISA M. OSTELLA, THE LAW OFFICES OF PHILIP J. BERG.. (Attachments: # 1 Declaration of Philip J. Berg, Esquire, # 2 Certificate of Service)(Berg, Philip) (Entered: 05/20/2011)

Quote:

Defendants, Orly Taitz, Defend our Freedoms Foundation, Inc., Neil
Sankey, Sankey Investigations, Inc. and The Sankey Firm, Inc. refused to cooperate with the Joint Fed. R. Civ. P. 26(f) report. See the Declaration of Philip
J. Berg, Esquire filed herewith.

As if that's any big surprise. Rules? Orly don't need no steeenkin' rules.

Edit: ETA: Based on Mr. Good Authority, information and belief, Judge Guilford, in a recent hearing, ordered Orly to cooperate with the joint report. Just sayin'.

Falsehoods unchallenged only fester and grow.

LIBERI, et al. v TAITZ, et al. (C.D. CA)

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