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

Sterngard Friegen · **Posted:** Tue Apr 19, 2011 1:40 am

This board requires you to be registered and logged-in before you can view hidden messages

raicha · **Posted:** Tue Apr 19, 2011 1:58 am

Sterngard Friegen wrote:

This board requires you to be registered and logged-in before you can view hidden messages

CalperniaUSA · **Posted:** Tue Apr 19, 2011 9:09 am

CalperniaUSA · **Posted:** Tue Apr 19, 2011 9:17 am

CalperniaUSA wrote:

This board requires you to be registered and logged-in before you can view hidden messages

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23596

Orly's been bizzy.

New Docket Entry...

Quote:

04/25/2011 178 NOTICE OF MOTION AND First MOTION to Dismiss Case under 425.16 AntiSLAPP DEFEND OUR FREEDOMS FOUNDATIONS, INC., ORLY TAITZ. [highlight]Motion set for hearing on 5/23/2011 at 10:00 AM before Judge Andrew J. Guilford[/highlight]. (Attachments: # 1 Appendix part 2 AntiSLAPP, # 2 Exhibit criminal record of 23 charges and 10 felony convictions of Plaintiff Lisa Liberi, # 3 Exhibit testimony of Detective Liebrich regarding 19 prior criminal charges of Plaintiff Lisa Liberi, # 4 Exhibit letter from web master Geoff Staples regarding Liberi handling credit cards of the donors, # 5 Exhibit Affidavit of Linda Belcher regarding Liberi's access to merchant accounts, # 6 Exhibit memorandum by Judge Robreno)(Taitz, Orly) (Entered: 04/26/2011)

There's a lot to upload/download post/link, so give me a little time. Links as soon as possible.

Edit: ETA: Further complicating and delaying the process, downloading from PACER is running at a snail's pace, for some reason.

Sorry for the delay... was the best I could do with the speed of PACER and Scribd.

CalperniaUSA · **Posted:** Tue Apr 26, 2011 11:37 am

realist wrote:

Further complicating and delaying the process, downloading from PACER is running at a snail's pace, for some reason. :

PACER has been like that all morning.

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23596

I got everything downloaded from PACER and now Scribd is throwing a slower than a snail's pace fit. :((

kate520 · **Posted:** Tue Apr 26, 2011 12:00 pm

Yesterday when I was reading Obly's "intervener" crapola on Scribd, most of the pages had a large grey box obscuring the second half of the page. Not that it matters with Obly, it's all the same old, same old, but...what's that box about?

RTH10260 · **Posted:** Wed Apr 27, 2011 4:46 am

realist wrote:

Orly's been bizzy.

New Docket Entry...

Quote:

04/25/2011 178 NOTICE OF MOTION AND First MOTION to Dismiss Case under 425.16 AntiSLAPP DEFEND OUR FREEDOMS FOUNDATIONS, INC., ORLY TAITZ. [highlight]Motion set for hearing on 5/23/2011 at 10:00 AM before Judge Andrew J. Guilford[/highlight]. (Attachments: # 1 Appendix part 2 AntiSLAPP, # 2 Exhibit criminal record of 23 charges and 10 felony convictions of Plaintiff Lisa Liberi, # 3 Exhibit testimony of Detective Liebrich regarding 19 prior criminal charges of Plaintiff Lisa Liberi, # 4 Exhibit letter from web master Geoff Staples regarding Liberi handling credit cards of the donors, # 5 Exhibit Affidavit of Linda Belcher regarding Liberi's access to merchant accounts, # 6 Exhibit memorandum by Judge Robreno)(Taitz, Orly) (Entered: 04/26/2011)

But but but ..... that looks very professional, all those legal quotes etc.

Who assisted our dentist in writing this paper ? She got another candidate for her chair of love ? Or did Yosi force her to take the assisting lawyer from the CEL3 charges to finally get rid of all the crap she has been picking up over the years ?

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23596

Well, here's a big surprise. :lol:

New Docket Entry...

Quote:

04/28/2011 179 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: First MOTION to Dismiss Case under 425.16 AntiSLAPP 178[RECAP] . The following error(s) was found: Hearing information is not timely. Other error(s) with document(s): Local Rule 11-6 Memorandum/brief exceeds 25 pages. In response to this notice the court may order (1) an amended or correct document to be filed (2) the document stricken or (3) take other action as the court deems appropriate. You need not take any action in response to this notice unless and until the court directs you to do so. (ln) (Entered: 04/28/2011)

And of course we all know Orly will completely ignore the instruction that she need do nothing unless the Court directs her to, so... she'll screw it up again... at least once anyway.

$\:D/$

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23596

New Docket Entries...

Quote:

04/29/2011 181[RECAP] NOTICE OF MOTION AND 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 filed by Plaintiffs PHILIP J. BERG, GO EXCEL GLOBAL, Lisa Liberi, LISA M. OSTELLA, THE LAW OFFICES OF PHILIP J. BERG. Motion set for hearing on 5/31/2011 at 10:00 AM before Judge Andrew J. Guilford. (Attachments: # 1 Memorandum, # 2[RECAP] Declaration of Philip J. Berg, Esquire, # 3[RECAP] Certificate of Service, # 4 Proposed Order)(Berg, Philip) (Entered: 04/29/2011)

04/29/2011 180 EX PARTE APPLICATION for Leave to File a First Amended Complaint ; Memorandum of Points and Authorities in support ; Declaration of Philip J. Berg; Certificate of Service; and Proposed Order filed by Plaintiffs PHILIP J. BERG, GO EXCEL GLOBAL, Lisa Liberi, LISA M. OSTELLA, THE LAW OFFICES OF PHILIP J. BERG. (Attachments:# 1 Memorandum, # 2 Declaration of Philip J. Berg, Esquire, # 3 Certificate of Service, # 4 Proposed Order)(Berg, Philip) (Entered: 04/29/2011)

Lots to download/upload... links as soon as possible.

Edit: ETA: I hope it's all linked correctly. I got busy and was multitasking, so if there's any problem with the links or docs, let me know and I'll correct it.

GreatGrey · **Posted:** Fri Apr 29, 2011 6:53 pm

Hee, this page just cracks me up:

ZekeB · **Posted:** Fri Apr 29, 2011 7:07 pm

Too bad it is not a felony to practice law in CA without a brain.

A Legal Lohengrin · **Joined:** Tue Oct 26, 2010 9:56 pm **Posts:** 9407

ZekeB wrote:

Too bad it is not a felony to practice law in CA without a brain.

Which reminds me of this probably apocryphal cross examination exchange.

Lawyer: Doctor, before you performed the autopsy, did you check for a pulse?
Witness: No.
Lawyer: Did you check for blood pressure?
Witness: No.
Lawyer: Did you check for breathing?
Witness: No.
Lawyer: So, then it is possible that the patient was alive when you began the autopsy?
Witness: No.
Lawyer: How can you be so sure, Doctor?
Witness: Because his brain was sitting on my desk in a jar.
Lawyer: But could the patient have still been alive nevertheless?
Witness: It is possible that he could have been alive and practicing law somewhere.

I suspect it's apocryphal, because I've never seen a cite to anything for it, and I've also seen it end "practicing law in California."

Sterngard Friegen · **Posted:** Fri Apr 29, 2011 9:12 pm

What I love most about the recently filed papers is the settlement overture made by Phil NOT Berg. If Orly would agree to retract everything, and undertake superhuman efforts to extirpate the information she put on the net about Misses Ostella and Liberi, and pay the pittance of $45,000,000 to the two plaintiffs, then HEY!, we have a settlement! It's as easy as that.

Berg in his settlement "proposal," also cites a California statute relating to agency misconduct for his authority that an individual who posts private information has financial liability. Interesting. And wrong. (But, he also tells us, this case has nothing to do with California law and Taitz's anti-SLAPP motion under Code of Civil Procedure section 425.16 has no basis. Taitz, in an effort to out-stoopid Berg, had previously told him she was filing a motion under "Rule 425.")

I expect an anti-filing order soon from Judge Guilford.

Foggy · **Posted:** Sat Apr 30, 2011 5:58 am

Sterngard Friegen wrote:

If Orly would agree to:

retract everything,
undertake superhuman efforts to extirpate the information she put on the net about Misses Ostella and Liberi, and,
pay the pittance of $45,000,000 to the two plaintiffs, then HEY!, we have a settlement! It's as easy as that.

Two plaintiffs?

Meaning that CalperniaUSA and Lea get throwed under the bus and don't get any of the $45 million?

Well, we warned them. ;;)

Quote:

retract everything

That's the deal killer, right there. I know Orly wouldn't mind giving Phil and Lisa L. the money; she could just redirect her PayPal button like CalperniaUSA did.

But how is she supposed to retract her accusation that Obama forced Lisa L. and Phil to work together to be false leaders of the constitutional eligibility movement, when Phil to this very day won't embrace the fake imaginary "two citizen parents" rule that doesn't exist? Are we supposed to believe that Obama didn't actually threaten to put Lisa L. in prison for 8 years unless she and Phil worked to undermine the birther movement as "false leaders"?

Lea · **Posted:** Sat Apr 30, 2011 9:37 am

Foggy wrote:

Sterngard Friegen wrote:

If Orly would agree to:

retract everything,
undertake superhuman efforts to extirpate the information she put on the net about Misses Ostella and Liberi, and,
pay the pittance of $45,000,000 to the two plaintiffs, then HEY!, we have a settlement! It's as easy as that.

Two plaintiffs?

Meaning that CalperniaUSA and Lea get throwed under the bus and don't get any of the $45 million?

Well, we warned them. ;;)

Quote:

retract everything

That's the deal killer, right there. I know Orly wouldn't mind giving Phil and Lisa L. the money; she could just redirect her PayPal button like CalperniaUSA did.

But how is she supposed to retract her accusation that Obama forced Lisa L. and Phil to work together to be false leaders of the constitutional eligibility movement, when Phil to this very day won't embrace the fake imaginary "two citizen parents" rule that doesn't exist? Are we supposed to believe that Obama didn't actually threaten to put Lisa L. in prison for 8 years unless she and Phil worked to undermine the birther movement as "false leaders"?

Good Morning Foggy,

Thank you dear one for being concerned about me and CalperniaUSA. I appreciate it and I'm sure she does also. CalperniaUSA is and always has been one of the Plaintiffs in the California part of the case. I, on the other hand have never been a Plaintiff in the California part, although OT keeps trying to involve me in it, by acusing me of diverting funds and stealing them from her so called foundation and a few other minor things.

Now the Texas part is entirely different, as I am and always have been the main Plaintiff in that part of the case, although the other 3 Plaintiffs are involved in that part of the case also. The Texas defendants went after all of the Plaintiffs, just not as hard as they did me.

OT on the other hand went after LL, LO and PB with everything she could do or think of, and just kept throwing me into the mix every now and then.

I do think you for caring about me and my well being, which is not really good right now and it is driving me bonkers!

's

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23596

Orly has not been spending all her time preparing for the Oral Argument of the century in her "high-profile case" that all the media of the world will be watching as she persuades the Ninth Circuit to oust the usurpin' mofo, and it's all Berg's fault, as he is deliberately distracting her from being fully prepared for her shining moment before the American people tomorrow.

New Docket Entry...

Quote:

04/30/2011 182 OPPOSITION to EX PARTE APPLICATION for Leave to File a First Amended Complaint ; Memorandum of Points and Authorities in support ; Declaration of Philip J. Berg; Certificate of Service; and Proposed Order 180[RECAP] filed by Defendant ORLY TAITZ. (Taitz, Orly) (Entered: 04/30/2011)

Bad Phil...

Quote:

2. Plaintiffs filed their motion on Friday April 29 and demand to shorten the defendants time to respond from 2 weeks to just 2 working days and demand an answer from the Defendants by Wednesday May 4, 2011.

Hey, doesn't Phil realize it's all about ORLY!!! ;;)

3. As it was announced on TV and radio on multiple stations and in multiple newspapers, Plaintiffs are well aware that Defendant, Dr. Orly Taitz, (hereinafter Taitz) has an oral argument scheduled in the 9th Circuit court of Appeals in Pasadena on Monday, May 2nd, [highlight]in a high profile case[/highlight], =))

where Taitz is representing former UN ambassador Alan Keyes, 10 state representatives and 30 members of the military. Plaintiffs and their attorney Berg are well aware, that she has to spend the whole weekend preparing for this hearing, therefore [highlight]they filed this ex-parte without any valid reason and without any valid cause, simply to further harass Taitz and inflict further severe emotional distress, as they did in the past two years[/highlight], :lol:

demanding de facto, just one working day for her to respond to their motion.[/quote]

And she still does not get that sua sponte thing...

Quote:

WHEREFORE defendants request the following:
1. deny Plaintiffs ex-parte motion
2. sanction Plaintiffs for filing a frivolous ex-parte application with the only purpose to harass the defendants
3. Sanction sua sponte ](*,)

Pennsylvania attorney Philip J. Berg for unlicensed practice of law in the state of California and forward this information to the disciplinary Board of the Supreme Court of Pennsylvania, where Berg is currently tried, pursuant to the violation of ethics complaint.
Respectfully submitted,

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23596

DENINED!!... for now.

New Docket Entry...

Quote:

05/02/2011 183 MINUTES (IN CHAMBERS): ORDER by Judge Andrew J. Guilford: denying 180[RECAP] Ex Parte Application to file an amended complaint and request an order that no motions can be filed without first seeking leave of court. (rla) (Entered: 05/03/2011)

Phil's going to have to, ala Orly, ask his supporters for some frequent flier miles.

Quote:

The Court first addresses Plaintiffs’ request to file a first amended complaint. Plaintiffs
have filed a Motion for Leave to File a First Amended Complaint, which is set for hearing
on May 31, 2011. Plaintiffs either want the Court to shorten time on the Motion for
Leave or want the Court to allow Plaintiffs to file an amended complaint without a
hearing. But Plaintiffs have failed to demonstrate irreparable prejudice if the Motion for
Leave is heard on May 31, 2011, as currently scheduled. The prejudice cited is that
Defendants have filed a motion to dismiss for May 23, 2011, and back-to-back hearings
would require more travel expense for Plaintiffs. But this is not irreparable prejudice.
Plaintiffs have not demonstrated sufficient good cause to justify their ex parte request to
file an amended complaint. The Motion for Leave can be heard as a normally noticed
motion and does not require the special treatment that an ex parte application entails.
Thus, the Court DENIES Plaintiffs’ request to shorten time and DENIES Plaintiff’s
request to file an amended complaint without a hearing.

And I'm not instituting filing without leave... yet.

Quote:

And now, the Court addresses Plaintiffs’ request that all parties seek leave of Court
before filing any motions. The Court finds that this restriction is not necessary – yet. But
the Court will keep a close eye on the filings by all parties and may choose to implement
such restrictions as the case progresses in this Court

ZekeB · **Posted:** Tue May 03, 2011 5:22 pm

Is it just me or are others also seeing layers in that Scribd document? :-k

Maru · **Posted:** Tue May 03, 2011 5:28 pm

realist wrote:

Orly has not been spending all her time preparing for the Oral Argument of the century in her "high-profile case" that all the media of the world will be watching as she persuades the Ninth Circuit to oust the usurpin' mofo, and it's all Berg's fault, as he is deliberately distracting her from being fully prepared for her shining moment before the American people tomorrow.

New Docket Entry...

Quote:

04/30/2011 182 OPPOSITION to EX PARTE APPLICATION for Leave to File a First Amended Complaint ; Memorandum of Points and Authorities in support ; Declaration of Philip J. Berg; Certificate of Service; and Proposed Order 180[RECAP] filed by Defendant ORLY TAITZ. (Taitz, Orly) (Entered: 04/30/2011)

Bad Phil...

Quote:

2. Plaintiffs filed their motion on Friday April 29 and demand to shorten the defendants time to respond from 2 weeks to just 2 working days and demand an answer from the Defendants by Wednesday May 4, 2011.

Hey, doesn't Phil realize it's all about ORLY!!! ;;)

3. As it was announced on TV and radio on multiple stations and in multiple newspapers, Plaintiffs are well aware that Defendant, Dr. Orly Taitz, (hereinafter Taitz) has an oral argument scheduled in the 9th Circuit court of Appeals in Pasadena on Monday, May 2nd, [highlight]in a high profile case[/highlight], =))

where Taitz is representing former UN ambassador Alan Keyes, 10 state representatives and 30 members of the military. Plaintiffs and their attorney Berg are well aware, that she has to spend the whole weekend preparing for this hearing, therefore [highlight]they filed this ex-parte without any valid reason and without any valid cause, simply to further harass Taitz and inflict further severe emotional distress, as they did in the past two years[/highlight], :lol:

demanding de facto, just one working day for her to respond to their motion.

And she still does not get that sua sponte thing...

Quote:

WHEREFORE defendants request the following:
1. deny Plaintiffs ex-parte motion
2. sanction Plaintiffs for filing a frivolous ex-parte application with the only purpose to harass the defendants
3. Sanction sua sponte ](*,)

Pennsylvania attorney Philip J. Berg for unlicensed practice of law in the state of California and forward this information to the disciplinary Board of the Supreme Court of Pennsylvania, where Berg is currently tried, pursuant to the violation of ethics complaint.
Respectfully submitted,

Wow. She told Dwight and Phil (I was there but Orly doesn't talk to women... no fun to bat those lashes at a girl) that she had over 200 military. Has she lost 170 since November?

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23596

Mmm wrote...

Quote:

Wow. She told Dwight and Phil (I was there but Orly doesn't talk to women... no fun to bat those lashes at a girl) that she had over 200 military. Has she lost 170 since November?

I suspect, if anyone checked, that even of the 40(?) she lists on her pleadings, that a vast number of them have no idea they were parties to an appeal... and perhaps even to the original case.

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23596

New Docket Entry...

Quote:

05/04/2011 184 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: 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] . The following error(s) was found: Hearing information is not timely. In response to this notice the court may order (1) an amended or correct document to be filed (2) the document stricken or (3) take other action as the court deems appropriate. You need not take any action in response to this notice unless and until the court directs you to do so. (ln) (Entered: 05/04/2011)

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23596

New Docket Entry (and new dates for the calendar)

Quote:

05/04/2011 185 MINUTE ORDER IN CHAMBERS by Judge Andrew J. Guilford: CONTINUING hearings: Motions Hearing (re: dkt # 181 and 178) continued to 6/13/2011 at 10:00 AM before Judge Andrew J. Guilford. Scheduling Conference reset for [highlight]6/13/2011[/highlight] 09:00 AM before Judge Andrew J. Guilford. (rla) (Entered: 05/04/2011)

Orly objects to Judge Guilford continuing all the hearings (you know, sua sponte

) until June 13 in 3...2...

realist · **Joined:** Fri Jan 23, 2009 1:33 pm **Posts:** 23596

SURPRISE!!

New Docket Entry...

Quote:

05/05/2011 186[RECAP] OPPOSITION to First MOTION to Dismiss Case under 425.16 AntiSLAPP 178[RECAP] Memorandum of Points and Authorities; Declaration of Lisa Liberi; Declaration of Philip J. Berg, Esquire; Certificate of Service and Proposed Order filed by Plaintiffs PHILIP J. BERG, GO EXCEL GLOBAL, Lisa Liberi, LISA M. OSTELLA, THE LAW OFFICES OF PHILIP J. BERG. (Attachments: # 1[RECAP] Table of Contents, # 2[RECAP] Memorandum, # 3[RECAP] Declaration of Lisa Liberi, # 4[RECAP] Declaration of Philip J. Berg, Esquire, # 5 Certificate of Service, # 6 Proposed Order)(Berg, Philip) (Entered: 05/05/2011)

links shortly

Falsehoods unchallenged only fester and grow.

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

Who is online