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Case: 10-3000 Document: 003110242718 Page: 1 Date Filed: 08/06/2010

Case #10-3000
UNITED STATES COURT OF APPEALS
FOR THE THIRD DISTRICT
____________________________________

Liberi et al –Appellees
V
Defend Our Freedoms Foundation, Taitz and Belcher –appellants

Appellants’ Taitz, Belcher and Defend Our Freedoms Foundation


Response to Motion to Dismiss, filed by the appellees prior to appellants
opening brief

Dr. Orly Taitz ESQ


29839 Santa Margarita Pkwy, ste 100
Rancho Santa Margarita CA 92688
949-683-5411
Attorney for the Appellants

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Background of the case

1. In an around of April of 2009 Attorney Orly Taitz, who is also a president of

Defend Our Freedoms foundation was forced to start a new website for her

foundation, when her former volunteer web master Lisa Ostella without any

authorization took over the website of her foundation and continued soliciting

donations from supporters, whereby diverting funds from the foundation, while at

the same time denigrating Taitz and promoting attorney Philip Berg.

2. At the same time Taitz was contacted by Linda Belcher, former volunteer for

Attorney Philip Berg, whereby Belcher disclosed that assitant for Berg, Lisa

Liberi, has a long wrap sheet of 10 felony convictions of forgery of documents,

forgery of an official seal and grand theft.

3. Taitz and licensed investigator Sankey did their due diligence conducted

multiple interviews of Liberi's arresting officer, District attorney on the case,

James Secord, probation officer, victims, pulled all the public records and verified

that indeed assitant for attorney Berg, is Lisa Liberi, an individual, convicted in

CA in 2008, who received eight years prison term, which was reduced to

probation until March of 2011. According to the terms of her probation, she is

allowed to reside only in CA or NM. Exhibit 6-3 Superior court of San Bernardino

County, CA printout of case FWV028000, defendant 1608112 Lisa Renee Liberi,

aka Lisa Courville Richardson, aka Lisa Courville Rich, aka Lisa Richardson.

showing 10 felony convictions. Exhibit 6-4 Superior Court of CA, San Bernardino

County counts of indictments FSB044914 for Lisa Liberi and Exhibit 5 Superior

court of CA, San Bernardino County Case FWV082000 indictments for Lisa

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Liberi. Indictments show multiple schemes, where through forgery and fraud

Liberi effectuated grand theft.

4. In and around April of 2009 Taitz has contacted Berg by two e-mails, forwarded

to him Liberi's conviction summary and advised him that she is aware of Liberi's

past, that she is aware that Liberi assists Berg by preparing documents for him and

mailing those to him and that she had a number of concerns. She was concerned

about the fact that Berg and Liberi went on a number of radio shows, where they

announced that Liberi was an able assistant for Berg, that she has prepared his

case Berg v Obama, that contained affidavits from Kenya, attesting to Obama's

birth there. Taitz asked Berg to allow her and forensic document expert to examine

the original documents from Africa, to make sure that those are not forged, as it

was possible in light of Liberi's convictions just a year earlier. While Taitz believes

that Mr. Obama needs to unseal his original birth certificate with the name of the

hospital and doctor, she was concerned about those affidavits from Africa, as those

will only undermine the case, and disclosure had to be made. In light of the fact

that Berg and Liberi were conducting a nation wide fundraising for that case

(Exhibit 6-6 Example of advertising of fundraising), Taitz advised Berg, that

according to terms of her probation Liberi cannot be associated with any

fundraising and cannot handle credit cards of others. Additionally Taitz advised

Berg, that his association with Lisa Ostella, Taitz former web master constitutes

diversion of funds from her foundation.

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5. Berg never responded to Taitz, but instead continued his attacks on her, never

granted her right to see original affidavits from Africa, used in Berg v Obama and

continued fundraising.

6. Taitz forwarded to the Department of Justice and FBI Liberi's summary of

convictions and all the above information and published Liberi's summary of

convictions to warn the public.

7. On 05.04. 2009 Berg filed current legal action 09-1898 in the Eastern District of

PA, based on diversity and claimed Libel, Assault and Slander. Berg sued all of the

parties who blew the whistle on him, Liberi and Ostella. He sued Taitz, her

foundation, Salt Rock Christian publishing, Licensed investigator Sankey, former

volunteer Linda Belcher, talk show host Ed Hale, Hale's radio station and Hale's

wife Caren and a number of other entities . Berg, also included in this case a

separate conflict that talk show host Evelyn Adams aka Momma E had with Ed

Hale. The essence of his allegation was, that Lisa Liberi, who works for him, is a

different Lisa Liberi, that she is an innocent woman, residing in PA, and she is not

Lisa Liberi, who was convicted in CA. While Berg included residential addresses

of all the parties, he never provided any address for Liberi in the state of PA, but

instead provided his business address as her address.

8. From May of 2009 until now, for over a year, Berg has never provided a shred

of evidence, proving that Liberi resided in PA at the time he filed the law suit.

9. Defendants filed motions, stating that prior to even getting into the essence of

the case, it needs to be dismissed due to lack of jurisdiction.

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10 . While the issue of jurisdiction was being considered by the court Berg filed a

motion for temporary restraining order, seeking a de facto gag order on any and

allow information about the plaintiffs. This motion was denied by the court after

hearing on August 7, 2009.

11. In August of 2009Berg filed an appeal.

12. On February 17, 2010 Third Circuit Court of Appeals received a United States

Government Memorandum from Joan Carr, from USDC in the Eastern District of

PA. (Exhibit 6-1). This memorandum was docketed as Document 003110023894

case;09-3403. It stated: “On September 24, 2009 David Hayes left a voice

message for counsel regarding the transcripts requested. Counsel was also notified

that the proceeding held August 7, 2009 was under seal and an order of court

would be necessary to unseal the proceeding and have a transcript produced. To

date our office has not received payment, a motion to unseal has not been docketed

nor has a transcript purchase order form been submitted to the District Court.

Taitz was concerned about the fact that an order to seal the transcript was issued

by Judge Robreno, but never docketed. Taitz, as a party, was never notified of such

seal of records, and there was never any explanation given, as to why was the

transcript sealed, as clearly there was no justification for it.

13. On 07.02. 10 Taitz filed an appeal of a different order and filed a motion to un

seal the transcript.

On 07.09.10 Berg filed a Response in opposition to unseal transcript, claiming that

all the parties were notified that the transcript was sealed due to the fact that it

contained personal information of Lisa Liberi.


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14. On 07.14.10. Judge Robreno issued an order, denying the motion to unseal the

transcript, stating that the transcript was not sealed. Clearly there was a

contradiction. The same Federal Judge cannot issue an order to seal the transcript,

whereby a special motion would be necessary to unseal it, and later deny such

motion, stating that the transcript was never sealed. Berg filed yet another motion

to keep the transcript under seal. Finally, yesterday, on August 4 2010, nearly a

year after the hearing Judge Robreno issued an order, stating that the transcript was

not sealed and Taitz was finally able to get the transcript. Berg continuously

defrauded the defendants, clerks and judge Robreno by claiming that the transcript

was sealed, trying to de facto achieve the gag order he desired, by stating the same

lie time and again to the clerks and judges, so that they would believe it.

15. The same United States government memorandum contained a second page,

"Transcript Purchase Order", which was earlier filed by Berg on 08.29.2009 as

document 00319790342 Exhibit 6-2. It contained a statement "This is to certify

that satisfactory financial arrangements have been completed with the court

reporter for payment of the cost of the transcript. The method of payment is private

funds. signature Philip Berg. Date August 28, 2009. Petitioner (Appellant)

Telephone 610-825-3134.

16. On 07.21.10 Taitz was finally able to talk to clerk David Hayes from US

district court for the Eastern District of PA. Taitz asked why the cost of transcript

was $1,100, a high fee for a copy, in light of the fact that according to certification

of Berg, he already made financial arrangements with the court reporter to pay for

the transcript back in August of 2009, and the copy should be less expensive. Mr.
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Hayes checked the records. Philip Berg never made any financial

arrangements. He never paid a cent. For nine month Berg and his clients and co-

appellants harassed all of the defendants/ appellees by claiming that they have an

emergency, they have filed hundreds and thousands of pages of unrelated

prejudicial and inflammatory material with both the District Court and the Court of

Appeals, in a scheme to prejudice both judges of the District Court and the Court

of Appeals against the defendants, while knowing all along that they never paid

for the transcript and never ordered the transcript and defrauded both courts and

the defendants.

17. During the same conversation Taitz inquired if there was any order from Judge

Robreno to delete from the electronic docket exhibits that she filed on 06.14.10.

which included Liberi's filing for banruptcy in Ca, her declaration made in her

criminal case in Ca and summary of her criminal convictions. All of the documents

were brought with the proper purpose of showing her being subject to the

juridiction of the state of CA and showing that there was no diverisity with Taitz,

also a resident of Ca, therefore grounds for dismissal due to lack of diversity and

lack of jurisdiction. Those documents also showed Liberi's signature, being the

same as filed with her original verified complaint. Mr. Hayes knew of no such

order from judge Robreno. No other clerk knew of any such order. Exhibit 6-7 Lisa

Liberi's Bankruptcy Court, Central District of CA filing. brought with the proper

purpose to show Liberi's pattern of handwriting and her address in Rancho

Cucamonga, San Bernardino county CA, where she was arrested and convicted.

For the purpose of this filing social security number of Liberi was redacted to show
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only the four last digits, however defendants can provide an unredacted copy,

which is also readily available to the public in the bankruptcy court.

18 Taitz inquired with the clerks, if there was any order from judge Robreno to

seal the initial verified complaint, filed by Berg on behalf of the plaintiffs,

containing a sample of Liberi's hand writing, which was the same handwriting as

shown on her filing for bankruptcy and her declaration made in the Superior court,

which were filed by Taitz as Exhibits in document 121, which were deleted from

the electronic docket as well. No clerk could provide an answer, why the complaint

was not available on the electronic docket.

19. During a year of litigation Berg repeatedly signed certifications, claiming that

he served all of the defendants, including defendant Linda Belcher and that her

silence is a sign of her agreement with all of Berg's allegations and demands.

20. In June of 2010 Taitz was contacted by Belcher, who forwarded to Taitz a

copy of her written statement, made under penalty of perjury (Exhibit 6-8), that

she did not receive any pleadings from Berg since her attorney Mr. Hoppe

resigned in Summer of 2009. Ms. Belcher stated in her letter, that was mailed and

faxed to the court, but never docketed, that she refused to be served by e-mail due

to malware on Berg's computers and she was never served by mail.

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20. In her letter under penalty of perjury Belcher stated, that Lisa Liberi has

personally asked Belcher to file fraudulent complaints against Taitz and against

another attorney Theresa LaLoggia from the firm Dickstein Shapiro. Ms. LaLoggia

is a member of PA bar. Again, under penalty of perjury Belcher stated that she was

present on a three way phone call, when Liberi asked another individual, Larry

Sinclair, who has an extensive criminal record to file such complaint against Taitz.

Sinclair filed a fraudulent complaint against Taitz with Judge Carter, fraudulently

claiming that Taitz has asked him to state something that was not true, accusing

Taitz of suborning perjury. That undermined Taitz case in front of judge Carter,

who included mention of this complaint in his ruling. Later Berg and Liberi

included this decision from judge Carter in their pleading in front of judge Robreno

to claim that Taitz does not have a good character for veracity, that she suborns

perjury and that her pleadings are not to be trusted. This Exhibit #6-8 was brought

for the proper purpose, as an example of how a licensed attorney Berg used

convicted criminals in order to defraud and manipulate two federal judges: Judge

David O. Carter in Ca and judge Eduardo Robreno in PA, in order to achieve his

purpose of framing and undermining Taitz, a person, who blew the whistle on him

and his assistant Liberi. It is brought for the proper purpose of supporting a motion

for an order to show cause, why sanctions should not be assessed against Berg and

the rest of the plaintiffs for fraud on the courts.

20. Exhibit 6-9, Printout of the transcript of the testimony of Investigator Liebrich,

given under penalty of perjury during preliminary hearing before judge John M.

Pacheco, superior court of CA case # FSB-044914 and testifying to authenticate


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audio tapes # 04073420299 of phone conversations of Lisa Liberi, recorded on

07.29.04 during her incarceration. This exhibit is brought for the proper purpose

of showing a common scheme and modus operandi of Liberi committing fraud and

engaging in conspiracy of using fellow criminals and framing and undermining

innocent individuals. In the testimony inspector Liebrich is testifying about a

conversation Lisa Liberi had with her husband Brent Liberi where she is planning

a "hit", a "green light" on her own sister Cheryl Richardson after Ms. Richardson

cooperated with the police and disclosed 19 previous charges against Lisa Liberi.

Liebrich:"... she was going to have somehow get her arrested and then spread

through the jail system that she was quote unquote "a rat" and she told her husband

Brent, "You know what they do to rats in jail?" ...

Question from the court: "And what happens when inmates discover that another

inmate is a snitch?

Answer: There is what is known as a contract, a green light on time. Different

things: they are attacked and or killed. In fact, you brought up L. A. County, in the

last year five have been killed within the jail system". Exhibit 6-10 shows a

photograph of Lisa Liberi with her husband Brent Liberi, and judge Robreno can

see, that it is the same woman, who appeared in front of him on August 7, 2009

and claimed that she is an innocent woman, who was never convicted of any

crimes and was slandered and defamed by the defendants (picture of her son was

removed from the photograph for his privacy).

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21. Exhibit 6-11Shows a declaration under penalty of perjury Lisa Liberi made

on September 21, 2006 in the Superior Court of San Bernardino county in

her motion to Recuse the Office of the district of the County of San

Bernardino. Her social security number is redacted to show only the last

four digits. Only the first and last pages are filed with the current motion,

full document was previously filed with the document 121, where the

document was removed from the electronic docket, but is supposed to be in

the hard copy with the court. Exhibit 6-12 is the signature page of the

verification filed by Liberi in her motion for TRO filed on July 15, 2009 by

her attorney Berg in the current action for defamation and slander. These

last two exhibits show the same signature. One can see the signature of

Lisa Liberi, who is on trial in CA with a total of 23 charges and 10

convictions and with a testimony of officer Liebrich regarding 19 prior

charges and the same signature of Lisa Liberi, who filed this action for

defamation, claiming under penalty of perjury, that she is an innocent

woman, resident of Pennsylvania, who does not have a criminal record

and was slandered and defamed by the defendants. It also shows that she is

using multiple social security numbers, which reinforces the statement by

volunteer Belcher, regarding Social security violations.

Memorandum of points and authorities

I. Motion to dismiss was filed prematurely

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Appellants just recently filed this appeal. Marcia Waldron, the clerk of

this court recently issued an order to the district court to release the

transcript by August 23, 2010. The Appellants will have at least 40 days

until beginning of November 2010 to file an opening brief. Appellees

have improperly jumped the gun and filed a premature Motion to dismiss

before Appellants had time to fully review the transcript and file a proper

Appellant‟s brief. Appellants filed a request for transcript and it was

provided only yesterday, on July 4, 2010. At the same time as the

Appellees filed their motion to dismiss in this court, they filed a motion

to keep the transcript under seal. This motion to dismiss prior the

Appellant brief is premature, improper, filed to simply harass the

Appellants and waste their time and to try to keep hidden from the

tribunal evidence of fraud committed by the appellees and their attorney

Berg.

II. All of the orders being appealed are relating to one issue.

Collateral Order Doctrine

Under Cohen v Beneficial Industries Loan Corp. 337 US 541 (1949) „an

interlocutory appeal is allowed if it finally determine claims of right separable

from and collateral to rights asserted in the action, too important to be denied

review and too independent of the cause itself to require that appellate

consideration be deferred until the whole case is adjudicated” Id., 337 US at 546.

While several orders are listed, in reality those are representing a continuation of

one order, as only one issue was decided in the District court for the Eastern
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District of Pennsylvania, specifically the issue of jurisdiction, whether there is

diversity and jurisdiction. Plaintiffs, by virtue of fraud on the court and perjury

claimed that their lead Plaintiff Lisa Liberi is a resident of PA, an innocent woman,

residing in PA, who was never convicted of any crimes and was defamed by the

defendants who posted her criminal wrap sheet in CA. Plaintiffs claimed that

Liberi was never convicted in CA. It is a well established doctrine, that residency

for the purpose of jurisdiction and diversity is viewed based on preponderance of

evidence. In case at hand the docket does not show any shred of evidence of Liberi

residing in PA. There is only a statement by her and her attorney and co-plaintiff

Berg and Berg‟s business address given as Liberi‟s address. District court

completely disregarded any and all evidence brought by the defendants showing

that Liberi did not reside in PA and could not reside in PA based on the conditions

of her probation.

The main issue of the appeal, is whether a district court has power to decide an

issue of diversity and jurisdiction without any shred of any evidence? This matter

was separate from the issue of defamation and slander, which is the basis of the

law suit, but it is extremely important to be disregarded or postponed until the

final appeal in a different jurisdiction, as it would be grounds of the case at hand in

PA. Defendants Taitz and Defend Our Freedoms Foundation were seeking

dismissal of the case based on lack of jurisdiction. Since the plaintiffs did not

provide any factual evidence of Liberi’s residence in PA, the court had no

basis to establish diversity of citizenship; therefore it did not have any basis to

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assume jurisdiction based on diversity. As such the case was supposed to be

dismissed in PA.

Third Circuit Court of appeals established a three prong test to evaluate the

issue of Collateral order:

1. conclusively determines the disputed issue. At issue here is whether the

party to the district and attorney for the party can defraud the tribunal,

by simply claiming that a party has residence in a certain state by giving

her Attorney’s business address in that state, and the court completely

abandoning the doctrine of the preponderance of evidence, deciding the

residency of the party based on a perjured statement given by her

attorney, in this case Philip J. Berg? If the answer is no, than the case

goes back to the District court for proper evidentiary hearing in regards

to the residency of the plaintiff or the case is dismissed due to lack of

Jurisdiction to establish diversity.

2. resolves an important question that is unrelated to the merits of the

underlying case. This matter is extremely important to be left without

an appellant review, as it will open a Pandora’s box of forum shoppings

and will encourage plaintiffs attorneys to simply lie about the residency

of their clients, as they would know, that they can do it with impunity

3. would effectively be unreviewable on appeal from a final judgment. If

this order will be allowed to stand, and the case is severed and

transferred to Ca and TX, it would be taken at it’s face value, the courts

there will assume that the district court in PA has held evidentiary
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hearing and established the matter based on preponderance of evidence,

and the Circuit courts of Appeals there will not be able to review those

orders, as the 9th circuit court of Appeals in CA and the 5th circuit court

of Appeals in TX do not have jurisdiction to review the orders coming

from PA, therefore this matter needs to be reviewed now and the Third

Circuit court of Appeals is not only a proper forum , but is the only

proper forum based on Carr v Am. Red Cross 17 F 3d 671, 675 (3d Cir

1994).

As such current appeal is proper and brought in the proper jurisdiction of the Third

Circuit Court of Appeals, as it is originating in the Eastern District of PA.

Additionally, this is not a purely transfer order, but an order of severance of the

case after the plaintiffs used it as a dumping ground for prejudicial, inflammatory

and unrelating filings of thousands of pages, as such In re United States, 2001 US

App. Lexis 25231 (3rd Cir 2001) (Quoting Nascone v Spudnuts,) brought by the

appellees will not be relevant and will not be applicable.

Defendants provided ample evidence of Liberi, being convicted in CA, currently

on probation with the probation department of the state of CA and allowed to live

intermittently either in CA or New Mexico, but not any other state. Since

defendants Sankey, Taitz, Sankey firm and Defend our Freedoms Foundation are

residents of Ca, there was no Diversity and the case had to be dismissed due to lack

of diversity. Additionally, Defendant Sundquist was a resident of New Jersey,

plaintiffs Ostella and GoExcelGlobal were also residents of New Jersey. Sundquist

sought an order to dismiss with prejudice. Court dismissed him without prejudice,
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therefore the disposition regarding Sundquist was not final and Berg can refile a

legal action against him at any time. Additionally, the court improperly pressured

Sundquist to agree to be dismissed without prejudice in order to assist the plaintiffs

in creating diversity, which never existed. The court showed bias in favor of the

plaintiffs when it improperly completely ignored Liberi‟s residency and included

in it‟s order a statement “Liberi is a resident of PA” without a shred of evidence to

this effect and completely ignoring a mountain of evidence presented by the

defendants, showing that to be a complete fraud on the court. Therefore, the orders

were not barred and had to be seen as interrelating to one and only issue decided,

issue of diversity and citizenship of the parties. The court showed improper

abuse of it‟s judicial discretion by stating that Liberi‟s residence was in PA. As

such all of the orders need to be seen as interrelated or as a basis to the final order

in documents 123 and 124, as well as order relating to the Motion for

reconsideration (document 125), therefore there was no violation of Rule 3 or 4.

III. Order being appealed represents a de facto final order of the case with the

current number or parties and relation to the parties

Case at hand was filed by the plaintiffs against numerous defendants residing in Ca

and TX. For over a year The Plaintiffs continued filing hundreds and by now

probably thousands of pages of entangled defamatory material about all of the

defendants, while the court was waiting for the results of the interlocutory appeal

filed by the Plaintiffs. The Plaintiff and the attorney for the Plaintiffs Philip J. Berg

defrauded the District Court and the Third Circuit Court of Appeals by claiming

that he ordered the transcript of the hearing and made financial arrangements. In
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reality he never made any arrangements, he never paid a cent, but simply used the

District Court as well as the Court of Appeals as a dumping ground for irrelevant,

inflammatory, defamatory and prejudicial information. One of the main points of

this appeal is the fact, that this is a an appeal of “de facto” final order as far as

current action is concerned, as the case was severed in two and forwarded to TX

and CA. The order states, that current action contained two distinct separate

disputes arising out of two nuclei of events. As the case was severed, Ca

defendants will no longer be defendants in TX case and TX defendants will no

longer be defendants in CA case, however the file is full to the brim with hundreds

of pages of prejudicial filings about all of the defendants, which will make it

extremely difficult for the presiding judge in CA or TX to make sense of. Current

Motion to Dismiss, that is being opposed is stating that it is not a final judgment, it

is an interlocutory appeal and claims that it is untimely and improper. First of all,

there is no prohibition against interlocutory appeals, and in August of 2009 the

Plaintiffs-Apellees in this appeal, themselves filed and interlocutory appeal of 2

orders, denying their TRO/injunction requests, orders that were issued in August of

2009 and in two months earlier in June of 2009. Additionally, as argued herein,

this is a de-facto final order of the current case, since the only issue decided in

PA was jurisdiction, and the appeal is stating that the court erred in this order by

denying the appellants motion to dismiss, and creating two cases full of entangled

evidence, the proper order was supposed to be dismissal of the case 09-1898 in

PA, as filed in improper jurisdiction with prejudice or in the alternative without

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prejudice, requiring the Plaintiffs to file in proper jurisdictions with proper

defendants.

IV. Appellees and their attorney Philip J Berg should not be allowed to profit

from the fraud on the Third Circuit Court of Appeals and the District court

and perjury that they committed

As stated previously, appellees and appellee‟s attorney Berg has committed

multiple counts of fraud on the court and perjury:

1. they claimed that the lead plaintiff Liberi resides in PA, while indeed she did not

reside in PA, and was not allowed to reside in PA or any other state except CA or

NM according to her probation.

2. Berg defrauded this court and the District Court by claiming that he made

financial arrangements to purchase the transcript, while in reality he did not pay a

cent and never ordered any transcript.

3. Berg defrauded this court and the District court by claiming that the transcript of

August 7, 2009 hearing was sealed, while in reality it was not sealed, and it took

the appellants nearly a year to finally get the transcript.

4. Appellees/plaintiffs continuously defrauded this court and the District court by

making fraudulent and highly prejudicial and untrue statements, claiming that the

defendants and specifically Doctor and Attorney Orly Taitz made statements where

she stated that she will “purge the plaintiffs”, “she will take them down,” that she

hired a criminal to hack into her own pay –pal account to steel money from herself

in order to kidnap the son of the plaintiff, convicted document forger and thief

Liberi and children of her former webmaster Ostella, who was diverting funds
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from the Defend Our Freedoms Foundation, CA foundation, where Dr. Taitz is a

president.

Berg simply arrogantly loaded the docket in both the District Court and the court

of Appeals with all this slanderous untrue material built on fraud and perjury and is

trying to draw profit out of it. It would be against the public policy to grant his

motion based on fraud and perjury. Berg‟s diabolical lack of Conscience and

complete disregard for the truth is staggering and can be only matched by the

diabolical disrespect for the truth by his lead plaintiff and paralegal, convicted

document forger and convicted thief Lisa Liberi. Berg is completely defrauding

this tribunal. For example, he brought forward the case of Rhodes v MacDonald,

the only case where Taitz was ever sanctioned, but he is not disclosing to the

tribunal the fact that in Rhodes the decision to sanction her was a political decision,

due to the fact, that she dared to represent two military officers, questioning their

deployment, and her pro-bono legal action interfered with the deployment, that this

is not a settled case, and it is being currently appealed in the Supreme Court of the

United States. On the other hand Berg does not mention two cases, where he

actually was sanctioned specifically for what he is doing in this case, defrauding

the court. Berg is the one who should be sanctioned for bringing both the original

case and the appeal based on fraud, in order to cover up his prior illegal dealings

with Liberi, who happened to be a convicted forger and thief on probation. He

harassed all the defendants for a year and a half with a frivolous law suit based on

fraud on the court and his own perjury , and he is demanding sanctions against

Taitz. Fed RAP 46 c and Walsh v Schering-Plough Corp., 758 F2d at 896-897
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apply to Berg and his despicable behavior “ We, together, with other courts are

charged with maintaining at least that level of honesty …” Taitz brings forward

exhibits 1-6 with sworn statements by a decorated military officer and a Desert

storm veteran Pamela Barnett, decorated Scotland Yard Officer and licensed

investigator Neil Sankey, Berg‟s own volunteer Linda Belcher, Talk show host Ed

Hale, his wife Caren Cieli Hale, all of whom depict Berg and/or Liberi as

complete and/or pathological liers. Not only Berg has to be severely sanctioned for

a year and a half of fraud on the District court and the Court of Appeals, but both

of them and the rest of the plaintiffs need to be criminally prosecuted for repeated

fraud on the court.

V. Appellees submitted improper “evidence” and showed disrespect for the

tribunal

Appellants would like to draw the attention of this court to improper evidence

routinely and continuously submitted by the Appellees.

Page 15, 16, 17 of this motion to dismiss contains screen shots of a blog Politijab,

which contains defamatory statements by an anonymous party, going under the

name “Foggy”, claiming that defendant Linda Belcher is “full of shit”. It is mind

boggling that a licensed PA attorney Philip Berg would bring such “evidence” as

basis for his motion to dismiss. Submitting such evidence shows total disrespect

for the tribunal and the system of Justice and shows that Appellees and their

attorney Berg have submitted this motion with an improper purpose to simply

harass the appellants and waste their time. Additionally, Berg was warned in his

prior appeal to stick to the issues and refrain from attacks. He continues his
20
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completely unprofessional behavior by engaging in personal attacks, and writing

“that Taitz filed a bunch of ramblings that amounted to nothing” p.6 of current

motion. He completely disregards the truth and the facts. For example, in the prior

appeal of this very case filed by Berg as #09-3403, Liberi v Taitz Third circuit

court of Appeals Berg has filed a total of 11 motions and requests for judicial

notice, containing hundreds of pages of unrelated inflammatory and defamatory

material, all of which were promptly denied by this court and Berg finally

withdrew his appeal after an order to show cause was issued. So, who is the one,

filing a bunch of ramblings that amount to nothing? Based on the history in this

very court, it is PA attorney Philip J. Berg.

Additionally, 90% of the statements in the current motion are either fraudulent

statements or misrepresentation of the truth. Respondent cannot address each one

in the framework of the answer to the motion to dismiss, as 90% of the issues

brought in this motion are not related to the appeal itself, and again Berg failed to

stick to the issues at hand as was warned by this court.

VII Time to submit the appeal was tolled and extended by the fact that Berg

didn’t serve the defendant Belcher

Belcher is an indigent and had only limited representation in the District Court for

2 months only in June, July of 2009. After that time Berg was supposed to serve

her personally. Belcher refused to be served by e-mail due to the malware threat

and she was never served by Mail. As a matter of fact the defendant/appellant

Belcher, according to her sworn testimony, was not served by Berg with any

pleadings from the end of July. The court‟s own docket showed that in December
21
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2009 an order was mailed from the court to Belcher, but came back around

January of 2010 as undeliverable, with a wrong address. Belcher has written to the

District court, complaining that she was not served and the orders from end of July

of 2009 need to be set aside, due to the fact that she was denied her 14 th

amendment rights of Due process and Equal Protection. Her letter, mailed and

faxed to the court was not docketed and was not considered. Due to the fact that

there was no service of process to the defendant Belcher, the time to respond to the

orders will toll till the time she first knew about the orders, which was May-June

2010. Other defendants/appellants were, also, negatively affected by the fact that

Berg did not serve Belcher. Belcher was an insider, who knew both Berg and

Liberi. Belcher was in contact with Berg for some 12 years, much of the

information the rest of the defendants had, came from the information, supplied by

Belcher, therefore the time frame to respond will toll for the rest of the defendants/

appellants and is not time barred for any of the orders.

VI Order to file a leave of court prior to filing motions did not bar this appeal

This is probably the most ridiculous argument of the whole motion. As Berg

continued to harass the defendants with hundreds of pages of filling of defamatory

and prejudicial material, the defendants pleaded with the district court to stop this

paper avalanche, used to burry the defendants and simply harass them. The district

court issued an order to file a motion for leave of court on any filings with this

district court. This order has nothing to do with the Appeal with the Court of

Appeals. District court cannot take away from a party it‟s 14 th Amendment due

process right to file an appeal. If that would be a case, every judge will issue such
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orders and no party will be able to appeal any of the decisions of the District court

judges. Additionally, District court released this case and ordered it transferred,

therefore the motion to file for the leave of court became moot as to the District

court in the Eastern District of PA.

VII. Appellees should be sanctioned for repeated acts of fraud on the court

As explained in prior paragraph, Berg –one of the Plaintiffs/Appelles and an

attorney for the appellees committed multiple acts on fraud upon this court, and the

District court, which warrants sanctions against him. Only one of multiple

examples of such fraud is the Exhibit 6-2, Transcript Request order filed by Berg

in his appeal in case 09-3403 Liberi v Taitz that he filed with this very court in

August of 2009. The transcript order form clearly states that not making financial

arrangements is grounds for dismissal of appeal or sanctions. After Berg used

this court for over half a year as a dumping ground for prejudicial and

inflammatory material, when he was finally ordered to show cause, as to why he

did not obtain the transcript, he simply withdrew his appeal leaving the defendants

with a loss of hundreds of hours, loss of thousands of dollars and severe

emotional distress due to horrific defamatory allegations made by Berg and the rest

of the Plaintiffs. Apellees and particularly Berg should not be rewarded for their

fraud, perjury, uttering and diabolical disregard of the truth and the system of

Justice, they should be ordered to pay sanctions.

Wherefore

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The appellants move this court to deny Appellees “Motion to Dismiss” as

premature, frivolous, improper and unsupported by law and fact and grant

the appellants fees and costs

Respectfully submitted,

/s/ Dr. Orly Taitz, ESQ

I certify under penalty of perjury, that I served above pleadings on following

parties :

Philip Berg

555 Andorra Glen Court, ste 12

Lafayette Hill PA 19444-2531

Neil Sankey

2470 Stearns str #162

Simi Valley, CA 93063

Linda Belcher

201 Paris

Castroville TX 78009
24
Case: 10-3000 Document: 003110242718 Page: 25 Date Filed: 08/06/2010

Ed and Caren Hale

1401 Bowie Str

Wellington TX 79095

Exhibits
1. Liberi v Taitz Motion for leave of court to file a surreply and Affidavit
by Pamela Barnett
2. Affidavit of Caren Cieli- Hale
3. Affidavit of Edgar Hale
4. Affidavit of Neil Sankey
5. Affidavit of Linda Belcher
6. 60 B Motion for Reconsideration

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Dr. Orly Taib, Esq


Attorney Pro Se & Attorney
For Defelld Our FreedolDl Foundation
29839 Santa Margari1a Parkway, Suite 100
Randlo Sata Margarita CA 92688
Tel: (949) ~5411; Fax (949) 7"-7603
E-Mail: dr_ tait7@.yshoo.eom

Il5J [§ © [§ U'\'i' ~ - (\
,.,
JUL 2 8 2010
J
IN THE UNITED STATES DISTRICT COURT :::
FOR THE EASTERN DISTRICf OF PENNSYLVANIA

LISA LmERI, et at., ) Response to tbe 07.26.10. emergency motion by the


plaintiffs to keep tnmscnp. ts under
seal
) Motion for clarification and motion-request
) for order to show cause, wby sanctions shouldnot - '
) be assessed against parties defrauding the courts c'
"
)by ciaivtiog that Judge Robreno issued an
, .­
Pla.iD.tiffs )"order" to seal transcript of Liberi v Taitt j..... ;

) forwarded to the Third Circuit court of Appeals ~)


v. )
) District Court ease # 09-cv- 01898-ER ',... __.t
ORLY TAITZ, et at, ) Court ofAppeals number case #09-3403 ;:!i"~'
) aad other repeated ads oftraud "~,,fl)' c", 6,
DefendaDts.. ) 60 B motion AW/CJrJ.. ~- ~ ~ {J (. {J .
-z -......,~. "- III
~~. "(,/"~
BaCkground of the ease . '~O"'1Ji-
~
Due to the great importance of this. matter. and fraud being perpetrated on the US District

Court as well as the Court of Appeals, and due to the fact that the plaintiff here Lisa

Liberi is cur.rently on probation in the state of CA as a result of 10 felony convictions of

forgery, forgery of an official seal and gmnd theft, this motion is addressed to the

presiding judge The Hon Eduardo Robreno; as well as the Chief Judge of US District

Court for the Eastern District of Pennsylvania The Hon Harvey Bartle, ill; and the Chief

Liberi v Taitz Motion for Clarification 1


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Judge for the Third Circuit Court of Appeals~ The Hon Randall Ray Rader. It is cc-ed to

the Public Integrity Unit of the Department ofJustice, Civil Rights Commission in

Washington DC, the PA State Bar, the Philadelphia DA, Audrey B. Collins.. the Chief

Judge of the Centtal District of CA, Judge David O. Carter Centml District of CA, San

Bernardino County, the California Probation Department, and the San Bernardino

County District Attorney James Secord,

1. In an around April of 2009 Attorney Orly Taitz, who is also a president of Defend

Our Freedoms foundation, was forced to start a new website for her foundation,. when her

former volunteer web master Lisa Ostella - without any authorization ~ took over the

website of her foundation and continued soliciting donations from supporters. whereby

diverting funds from the foundati~ while at the same time denigrating Taitz and

promoting attorney Philip Berg.


( .....

2. At the same time Taitz was contacted by Linda Belcher. a former volunteer ~r
-1
Attorney Philip Berg, whereby Belcher disclosed that assistant for Berg.- Lisa LibeJi;­
-... .

has a long"Wl'ap sheet of 10 felony convictions of forgery of documents, forgery o~

official seal and grand theft

3. Taitz and licensed investigator Sankey did their due diligence by conducting multiple

interviews of Lieberi's arresting officer, District attorney on the case. James Secor~

probation officer. victims, and pulled all the public records and verified that indeed the

assistant for attomey Berg, is Lisa Liberi, an individual. convicted in CA in 2008, who

Liberi v Taitz Motion for Clarification 2


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received an eight years prison tenn, which was reduced to probation until March of

2011. According to the terms of her probation., she is allowed to reside only in CA or

NM. Exhibit l Superior court of San Bernardino County, CA printout of case

FWV028000, defendant 1608112 Lisa Renee Liberi, aka Lisa Courville Richardson,. aka

Lisa Courville Rich, aka Lisa. Richardson. showing 10 felony convictions. Exhibit 4

Superior Court of C~ San Bernardino County counts of indictments FSB044914 for

Lisa Liberi and Exhibit 5 Superior court of C~ San Bernardino County Case

FWV082000 indictments for Lisa Liberi. Indictments show multiple schemes, where

through forgery and fraud Liberi effectuated grand theft.

4. In and around April of 2009 Taitz contacted Berg by two e-mails, forwarded to him

Uberils conviction snmmary and advised him that she is aware of Liberi's past. that she is

aware that Liberi assists Berg by preparing documents for him and mailing those to him.

and that she had a number of concerns. She was concerned about the met that Berg aDd

Liberi went on a number ofradio shows, where they announced that Liberi. was an ~Je
c.)
assistant for Ber~ that she has prepared his case Berg v O~ that contained affida:l4fs

from Kenya" attesting to Obama's birth there. Taitz asked Berg to allow her and'l:D!!r
CAi
w
forensic document expert to examine the original documents from Africa, ro make sure
that those are not forged, as it was possible in light of Liberi's convictions just a year

earlier. While Taitz believed, that Mr. Obama needs to unseal bis original birth certificate

with the name of the hospital and doctor, she was concerned about those affidavits from

Africa, as possibly being forged and undermining the case Taitz bas incorporated this

evidence in her legal actions and wanted to make sure she didn"t tmknowingly

Liberi v Taitz Motion for Clarification 3


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incorporate something that was forged. Additionally Berg and Liberi were conducting a

nation wide fimdraising for that case (Exhibit 6 Example of advertising of fundIaising).

Taitz advised Berg, that according to tenns of her probation. Liberi cannot be associated

with any fundraising and cannot handle credit cards of others. Additionally, Taitt advised

Bergt that his association with Lisa Ostella. Taitz former web master, constitutes

diversion of funds :from her foundation.

5. Berg never responded to Taitt, but instead continued his attacks on her. never granted

her right to see the original affidavits from Africa, used in Berg v Obama and continued

fimdraising.

6. Taitz forwarded to the Department of Justice and FBI Liberi's summary of convictions

and all the above information and published Liberi's summary of convictions to warn the

public.

7. On 05.04. 2009 Berg filed current legal action 09-1898 in the Eastern District of:PA,
"
~ .­-
r ...
based on diversity and claimed Libel. Assault and Slander. Berg sued all of the paAjes
C)

who blew the whistle on him, Liberi and Ostella. He sued Taitz, her foundation. Salt ~k
......
-..,;,
Christian publishing, Licensed investigator Sankey. former vohmteer Linda Belcher,lYk
w
show host Ed Hale, Hale's radio station and Hale's wife Caren and a number of other

entities . Berg, also included in this case a separate conflict that talk show host Evelyn

Adams aka Momma E had with Ed FIale. The essence of his allegation was, that Lisa

Liberi, who works for him, is a different Lisa Liberi, that she is an innocent woman,

residing in PA, and she is not the same Lisa Liberi. who was convicted in CAw While

Liberi v Taitz Motion for Clarification 4


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Berg included residential addresses of all the parties, he never provided any address for

Liberi in the state ofP A. but instead provided his business address as her address.

8. From May of 2009 until now, for over a year, Berg has never provided a shred of

evidence, proving that Liberi resided in FA at the time he filed the Jaw suit.

9. Defendants filed motions. stating that prior to even getting into the essence of the case,

it needs to be dismissed due to lack ofjurisdiction.

10. While the issue of jwisdiction was being considered by the court, Berg filed a motion

for a temporary restraining order, seeking a de faciO gag order on any and all information

about the plaintiffs. This motion was denied by the court after hearing on August 7, 2009,

11. In August of 2009Berg filed an appeal.

,
" .
12. On February 17,2010 the Third Circuit Court of Appeals received a United S~
,-, ,
'-,~.1

Government Memorandum from Joan Carr, from USDC in the Eastern District of !!J.\.
---
......It ; , "

(Exhibit I). This memorandum was docketed as Document 003110023894 case;t!2~,


w
3403. It stated: "On September 24, 2009 David Hayes left a voice message for counsel

regarding the transcripts requested. Counsel was also notified that the proceeding held

August 7, 2009 was UDder seal and an order of court would be ~ to unseal the

proceeding and have a transcript produced. To date our office has not received payment,

Liberi v Taitt Motion for Clarification 5


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a motion to unseal has not been docketed nor has a transcript purchase order form been

submitted to the District Court. Taitz was concerned about the fact that an order to seal

the transcript was issued by Judge Robreno, but never docketed. Tai1z. as a party, was

never notified of such seal of records, and there was never any explanation given. as to
why was the transcript sealed, as clearly there was no justification for it.

13. On 07.02. 10 Tai1z filed an appeal of a different order and filed a motion to unseal the

transcript. On 07.09.10 Berg filed a Response in Opposition to unseal the transcript,

clainring that all the parties were notified that the transcript was sealed due to the fact that

it contained personal information ofLisa Liberi.

14. On 07.14.10. Judge Robreno issued an order, denying the motion to unseal the

transcript; stating that the transcript was not sealed. Clearly there was a contradiction.

The same f'ederal Judge cannot issue an order to seal the transcript. whereby a special

motion would be necessary to unseal i4 and later deny such motion, stating that" the
c:::.;;

transcript was never sealed.

15. The same United States government memorandum contained a second p~,
c..~
"Transcript Purchase Order'*, which was earlier filed by Berg on 08.29.2009 as cIocutrleht

00319790342 Exbibit 2. It contained a statement "This is to certify that satisfactory

:financial arrangements have been completed with the court reporter for payment ofthe

Liberi v Taitz Motion for Clarification 6


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cost of the tl.':anscript. The method of payment is private funds. signature Philip Berg.

Date August 28, 2009. Petitioner (Appellant) Telephone 610-.825-3134.

16. On 07.21.10 Taitz was finally able to talk. to clerk David Hayes from US district court

for the Eastern DiS1rict ofPA. Taitz asked why the cost of transcript was $I,l00~ a high

fee for a copy, in light of the fact that according to certification of Berg, he already made

finaneial arrangements with the court reporter to pay for the transcript back in August of

2009, and the copy should be less expensive. Mr. Hayes eheeked tile records. Plailip

Berg never made any financial1iU'l"allgements. He Dever paid a eeDt. For nine months.

Berg and his clients and co-appellants harassed all of the defendants/ appellees by

claiming that they have an emergency, they have filed hundreds and thousands of pages

of unrelated prejudicial and inflammatory material with both the District Court and the

Court of Appeals, in a scheme to prejudice judges of the District Court and the Court of

Appeals against the defendants, while knowing all along that they never paid for the
......
transcript and never ordered the transcript and defrauded both courts and the def~.

I''':
c.J
17. During the same conversation, Taitz inquired if there was any order from J4e
-,.
Robreno to delete from the electronic docket exhibits that she filed on 06.14.10. wbjjl,
w
included Liberi's filing for bankruptcy in Ca. her declaration made in her criminal case in

Ca and summary of her criminal convictions. All of the documents were brought with the

proper purpose ofshowing her being subject to the jurisdiction ofthe state ofCA and

Liberi v Taitz Motion for Clarification 7


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showing that there was 00 diversity with Taitt, also a resident of CEl, therefore grounds

for dismissal due to lack of diversity and lack of jurisdiction. Those documents also

showed Liberi~ signature, being the same as filed with her original verified complaint.

Mr. Hayes knew of 00 such order from judge Robreno. No other clerk knew of any such

order. Exhibit 7 Lisa Liberi's Bankruptcy Court, Cen1ral District of CA filing. brought

with 1he proper purpose to show Liberi's pattern of handwriting and her address in

Rancho Cucamonga, San Bernardino county CA, where she was arrested and convicted.

For the purpose of this filing social security number of Liberi was redacted to show only

the four last digits, however defendants can provide an unredacted copy, which is also

readily available to the public in the bankruptcy court.

18 Taitt inquired with the clerks if there was any order from Judge Robleno to seal the

initial verified complaint~ filed by Berg on behalf ofthe plaintiffs, containing a sample of

Uberi's hand writing, which was the same handwriting as shown 00 her filin~or
t"_",,
bankruptcy and her declaration made in the Superior court, which were filed by Tai*,as
1"':
exhibits in Document 121. which were deleted from the electronic docket as well. No
-0

clerk could provide an answer~ why the complaint was not available on the electro*. , ",'"

" \ ."

docket.

19. During a year of litigation Berg repeatedly signed certifications, claiming that he

served all of the defendants. including defendant Linda Belcher and that her silence is a

sign of her agreement with all ofBerg's allegations and demands,

Liberi v TaW: Motion for Clarification 8


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20. In June of 201 0 Taitz was rontacted by Belcher, who forwarded to Taitz a ropy of

her written statement, made under penalty of perjury (Exhibit 8), that she did not

receive any pleadings from Berg since her attomey Mr. Hoppe resigned in Summer of

2009. Ms. Belcher stated in her letter ( that was mailed and fuxed to the court,. but never

docketed) that she refused to be served by e-mail due to malware on Berg's computers

and she was never served by mail.

21. In her letter under penalty ofpetjUIY Belcher stated." that Lisa Liberi personalJyasked

Belcher to file fraudulent complaints against Taitz and against another attorney Theresa

LaLoggia from the fum Dickstein Shapiro. Ms. LaLoggia is a member ofPA bar. Again,

under penalty of perjury Belcher stated that she was present on a three way phone call.

when Liberi asked another individual, Larry Sinclair, who has an extensive criminal

record, to file such complaint against Taitz. Sinclair filed a fraudulent complaint against
t::;'>
Taitz with Judge Carter, fraudulently claiming that Taitz asked him to state somethi~

that was IIDt true, accusing Taitt of suborning peljury. That undermined Taitz's ~

front of judge Carter, who included mention of this complaint in his ruling. Later BeiS
..
--~
and Liberi included this decision from Judge Carter in their pleading in front of judrt,

Robreno to claim that Taitz does not have a good character for veracity, that she suborns

perjury and that her pleadings are not to be trusted. This Exhibit 8 was brought fOf the

proper purpose~ as an example of how a licensed attorney - Berg - used convicted

criminals in order to defraud and manipulate two federal judges: Judge David O. Carter

Liberi v Taitz Motion for Clarification 9


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in Ca and Judge Eduardo Robreno in PA. in order to achieve his purpose of framing and

undermining Taitz, a person, who blew the whistle on him and his assistant Liberi. It is

brought for the proper pmpose of supporting a motion for an order to show cause, why

sanctions should not be assessed against Berg and the rest of the plaintiffs for fraud on

the courts.

22. Movant presents Exlaibit 9, a printout of the. transcript of the testimony of

Investigator Liebricht, given under penalty of perjury during preliminary hearing before

Judge Jolm M. Pacheco, superior court of CA ease # FSB-044914 and testifying to

authenticate audio tapes # 04073420299 of phone conversations of Lisa Liberi~ recorded

on 07.29.04 during her incarceration. This exhibit is brought for the proper purpose of

showing a common scheme and modus operandi of Liberi conunitting fraud and

engaging in conspiracy of using fellow criminals and ftaming and undennining innocent

individuals. In the testimony, inspector Liebrich is testifying about a conversation ~sa --7'

~""

Liberi had with her husband Brent Liberi where she is planning a "hit", a "green light., ( >

r"":

on her own sister Cheryl Richardson after Ms. Richardson cooperated with the police iiid
4J

disclosed 19 previous charges against Lisa Liberi. Liebrich:" ... she was going to ~ .!);

c:,.)

somehow get her arrested and then spread through the jail system that she was quOte

unquote "a rat" and she told her husband Brent, "You know what they do to rats injail'r

Question fr()Jll the court: "And what happens when inmates discover that another inmate

is a snitch?

Liberi v Taitt Motion for Clarification 10


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Answer: There is what is known as a conttact, a green light on time. Different things:

they are attacked and or killed Tn fact, you brought up L. A. County, in the last year five

have been killed within the jail system". ExIu"bit 10 shows a an authenticating

Declaration and a photograph of Lisa Liberi with her husband Brent Liberi, and Judge

Robreno can see, that it is the same woman, who appeared. in front ofhim on August 7,

2009 and claimed that she is an innocent woman. who was never convicted of any crimes

and was slandered and defiuned by the defendants (picture of her son was removed from

the photograph for his privacy).

23. Exhibit 11 shows a declaration under penalty of perjury Lisa Liberi made on

September 21,2006 in the Superior Court of San Bernardino county in her motion to

recuse the Office of the District of the County of San Bernardino. Her social security

number is redacted to show only the last four digits. Only the first and .last pages are filed

with the cummt motion. full docwnent was previously filed with the docmnent 121,
--'
where the document was removed from the electronic docket, but is supposed to be in~e

hard copy with the court. Exhibit 12 is the signature page of the verification fil~y
C)

LiOOri in her motion for 'fRO filed on July 15.2009 by her attorney Berg in the c~
-.... ,j ".'.'..,."
action for defamation and slandet- These last two exhibits show the same signature. QBe

can see the signature of Lisa Liberi. who is on trial in CA with a total of 23 charges and

10 convictions and with a testimony of officer Liebrich regarding 19 prior charges and

the same signature of Lisa Liber4 who filed this action for defamation, claiming under

penalty ofpeIjury. that she is an innocent woman, resident of Pennsylvania, who does

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not have a criminal record and was slandered and defamed by the defendants. It also

shows that she is USiDg multiple social security numbers, which reinforces the statement

by volunteer Belcher, regarding Social security violations.

MeRlOrandlllll of Points and Authorities

Respunse to motion by the plaintiffs to seal the record and deny the defendants

aeeess to the record.

Apparently Berg believes ~ if you tell a lie often enough, people will start believing in

it Berg filed yet another emergency motion and Taiz is responding the next day on July

27, 2010 and apologizes to the court for the fact that this response could use more polish.

however since at a prior occasion this court bas granted Berg's motion within one day.

before Taitz could respond, this response is being faxed and filed with the court next day

to make sure there is no order to grant Pla:intifI's motion before defendants had an

opportunity to respond. Exhibit 2 shows" Transcript purchase order" filled out and

certified by Berg on August 29,2009. h is similar to one filed out by Taitz recently. If~

transcript was really sealed, Berg would not be filing a Tmnscript purchase order ~.~

".., ,

purchase the transcript of August 7, 2009 hearing. He would be :tiling a motion willi
""',
judge Robreno to unseal it first. Berg didn't do it, since he knew that the transcript was ..
c....!'
never sealed. Berg wanted to seal it, as Berg wanted to seal the lips of the defendantt

who were the whistle blowers, he wanted to silence them, but there was no seal. The only

difference between Berg's purehase order and Taitz purchase order, is the fact that Berg

committed yet another fraud on the court Not only the transcript was not sealed, but Berg

never purchased it, he never paid a cent, even though he certified it Taitt actually paid

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for the transcript and sent to the elm of the court David Hayes, a check for $1, 100 for

the purchase. Taitz inquired with both Joan Carr and David Hayes. what happened, why

Berg claimed there was a seal. why a letter from Joan. Carr stated that there was a seal,
but the order :from Judge Robreno states that there was no seal. Mr. Hayes checked the

record and left a message on Taitz phone recording machine (available for review) that

there was no seal, it was an error. In the conversation Hayes stated that he checked the

record, and it only shows a request by Berg to seal the record, but DO such order by Judge

Robreno.

This appear to be one of the schemes by Berg and possibly Liberi, where they are

submitting fm:udulent statements often enough to induce the parties to believe that those

are true. This is an egregious violation of the code of professional ethics by an attorney.

Additionally. in his motion Berg is reviewing the weaknesses of the appeal by Taitt and

trying to justify his request for the court to deny Taitz her right to purchase a transcript

based on the weaknesses ofthe appeal.

This is a totally frivolous notion, not based on law or fact. Strength or weakness of the

appeal, is the matter to be decided by the Third Circuit Court of Appeals, not the ~
. ......~

court. Berg wants the trial court to deny the defendants right to purchase a copy ofrthe
C)

transcript of the hearing, which is a basis of the appeal in the first place; and b~n

which the appeal will be decided by the court of appeals. Such order by the District ct.Brt
,

would be a Bagrant violation of Taitz 14111 amendment rights to due process and equal
..
~

protection under the law. Berg is an attorney and knows that such order would be totally

unconstitutional, and his Emergency motion to deny Tai1z her right to purchase a

transcript of the hearing needs to be denied as totally frivolous, and an order to show

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cause should be issued "Why Berg and plaintiffs should not be sanctioned for repeatedly

defrauding the District Court and the Court of Appeals" and for bringing frivolous

motions.

Rule 60 B motion

Rule 60. Relief from Judgment or Order

(b) Mistakes; Inadvertence; Excusable Neglect; Newly Discovered Evidence; Fraud. Etc.

On motion and upon such terms as are just, 1he court may relieve a party or a party's

legal representative from a final judgment, order. or proceeding for the foUowiDg reasons:

(1) mistake, inadvertence~ surprise. or excusable neglect; (2) newly discovered evidence

which by due diligence could not have been. discovered in time to move for a new trial

under RCFC 59(b); (3) fraud (whether heretofore denominated intrinsic or extrinsic),

misrepresentatio~ or other misconduct of an adverse party; (4) the judgment is void; (5)
-'
the judgment has been satisfied. released, or discharg~ or a prior judgment upon w:&ith
t,,_
.. ­
it is based has been reversed or otherwise vacated, or it is no longer equitable that;.t!le
cu
judgment should have prospective application; or (6) any other reason justifying ~f

from the operation of the judgment The motion shall be made within a reasonable ti5~~

and for reasons (1), (2), and (3) not more than one year after the judgmen~ order. or

proceeding was entered or taken. A motion wder this subdivision (b) does not affect the

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finality of a judgment or suspend its operation. This rule does not limit the power of a

oourt to entertain an ind.ependent action to relieve a party from a judgment. order. or

proceeding, or to set aside a judgment for fraud upon the court.

As stated previously, there is new infonnation. showing multiple oounts of fraud on the

court

1. Fraud was commi~ when the Court of Appeals and the District Court were told

that there was a seal on transcrip~ when no such seal ever existed.

2. Fraud on the court was committed when Attorney Berg certified a statement that he

made satisfactory :financial arrangements to purchase the records, when no such

arrangements were ever made.

3. Fraud was oommitted by Attorney Berg and the plaintiffs in their claim thai plaintiff

Liberi is a resident of PA.

4. Fraud was committed by Liberi) when she solicited a fraudulent complaint agaifiit
-"~

Attomey Taitz. to be made by Larry Sinclair and this fraudulent complaint was later wi&l
i'"'.:
C)
by Attorney Berg and. Liberi to prejudice two judges: Judge Carter and Judge Ro~

against Taitz. -..


e,..;"
5. Fraud was committed when Berg claimed that he served defendant Belcher and sh~-
agreed with his allegations, when he did not in fact serve her. and she did not have an

opportunity to respond.

Due to the fraud on the oourt, the court erroneously included in its Order to Sever the

case a statement that Lisa Liberi is a resident of PA. This statement is based on fraud on

the court and perjury by Liberi and Berg.

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Residence of a party for the purpose of diversity needs to be resolved on preponderance

of evidence. The party e1ainring diversity of citizenship bas the burden to show such

diversity by preponderance of evidence. The following cases show that when a party

c]airning diversity did not show citizenship of the parties by preponderance of evidence.

the cases in federal courts were indeed dismissed. not severed and transferred.

In cases in which jurisdiction is based on diversity of citizenship. plaintiff has burden to

show, ~ that applicable statute confers jurisdiction, and, second, that assertion of

jurisdiction is consonant with oonstitutionallimitatioDS of due

process. Weight v Kawasaki Motors Corp, (J985, ED Va) 604 F Supp 968.

Party·s mere alleptiOQ of diversity c:annot satisfy m bdn:len of establishing distriet


........
c::om1t s jurisdiction; citizenship of each real party in interest mllSt be established!,!

preponderance of evideu.ee. Roche )1 Lincbhl. pop. Co. (lON, CA.4 Va) 373 F3d 610:..",

-,.
-­ ~ , " \'

Complaint alleging that defendant's corporate citizenship was in a state other thai[;
.. ~

California but failing to allege that plaintiffs were all citizens of California was not

sufficient to give District Court jurisdiction since pleadings did not otherwise resolve

issue of citizenship. Bautista v Pan American World Airlines. 1rt.c. (J987. CA9 Cal) 828

F2d 546. 126 BNA LRRM 2559. 107 CCH LC P 10159. Court lacked jurisdiction over

patienfs claims because he fiilled to establish diversity jurisdiction bef;ause at time he

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filed complaint both he and hospice were citizens of State. Olsen y Quality Continuum

Hospice. Inc_ (2004.DC NM) 380 F SUVP 2d 122J._

Complaint against John Doe defendant alleging Internet defamation was dismissed for

lack of subject matter jmisdiction because there was risk that if John Doe's identity were

discovered there could have been no diversity, and court's jurisdictional authority would

have disappeared; court declined to read amended language of28 uses § 1441
into 28 uses § 1332 because it would have accomplished much broader result of

allowing case with only one party and only state law claims to proceed initially in federal

court. McMann v Doe (2006, DC Mas~i 460 F Supv 2d

In motorist's personal injury lawsuit ~ inter alia, owners of property adjacent to

private railroad-track crossing where car-train accident occurred,. pursuant to 28 uses §


...->
1447(4). appellate court lacked jurisdiction to review remand that implicitly was b~ on

lack of subject mattel' jurisdiction; district court clearly was addressing jurisdi~
Cd

issue5-divenrity of citizenship, 28 uses § 1332. and fraudulent joinder-and when ~g


, ,,
so, it properly declined to decide doubtful question of state law and, instead" reso~
..­
ambiguity (lack of state law directly on point) in motorist's favor. Filla v HOWl! &

Southern Ry. (2003. CA8 MQ) 336 F3d 806.

Where record creates doubt as to jurisdiction, trial ~ourt must detenniue whether

there are adequate grounds to swstaiD its jurisdiction over subject matter.

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SIulhI!l9011 11lf!.Blries, Inc. 1l'Impmdo (l9f!4. C4J NI) 338 F24 149. 9 FR Serv 2d

12&227 Cast! 2.

Court has duty to look to its own jurisdiction aDd lack of subject matter jurisdiction

Dlay be asserted by court, sua sponte, at any time. Jeter v r"" WqIter HotIfA Inc..
(1976...WD OW 414 F SIII!p 791.259. dedded by a preponderance of evideDee.

PJ.aintiffs did not present any evidence, not a shred of evidence, showing Liberi to be a

resident of PA. Defendants have shown that according to her probation she can reside

only in CA or NM, she is subject to the jurisdiction of CA, therefore the case at hand has

to be dismissed as citizenship of Liberi was not provided to resolve the issue of diversity

to allow it to proceed in Federal court. AdditionaJly, statement "Liberi is a :resident of

PAil has to be removed from the order. as it is significant to the essence of the case and

was never proven by the plaintiffs by preponderance of evidence as required for the _c

PUIpOse5 of diversity or even by any shred of evidence. This case in front of the counis

for slander and defamation: Plaintiffs claim that at the time the case was filed, Liberi ~
-on
not the person" who was convicted in CA and was residing in New Mexico. bu~
.. ,
'r'
.'
.

different person. an innocent woman, .residing in PA, who was never convicted of ~ .

criminal offenses. Previous order by this comt to sever and transfer this ~ states that
Uberi is a resident of Pa and for purposes of jurisdiction and diversity it makes no

difference whether Liberi is a resident ofCA or New Mexico. However, when this court

includes in its order and simply repeats a fiaudulent and perjured stateJ:nent by the

plaintiffs. that Liberi is a resident of PA, it :makes an assertion of fact, which may be used

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by two federal judges in 'IX and CA to decide against the defendants. The court is de

facto rewarding Berg and Liberi for their fraud and pajury~ VYhi1e in reality this court

should have sanctioned them for it and demanded from th.em a payment of the costs and

fees incurred by the defendants. Doe to this e.....r by the court, whieh was induced by

frau colDDlitted by the plaintiffs and exacerbated by some employees ofthis very court,

defendants seek: a dismissal of the case or in the alternative change in the order to sever,

whereby the residency of Liberi is to be determined by the court and a bearing to

establish Libert's residency at the time tms legal action was :fil~ so that the defcn<lants

will be able to subpoena Uberi's probation officer and prosecuting district attorney to

testify to the fact that the plaintiffs defrauded the court and that Libert did not reside in

PA at the time this legal action was filed, therefore the whole action was totally frivolous,

not grounded in fact or law. Due to other legal actions Taitz will not be available to

attend such action until August 16 and will not be available on August 17, 18 and 20. She
-'
o
will be available on other dates for such a hearing, to establish residency of Liberi ~

on preponderance of evidence for the pmposes of diversity and in order to correct ~

error made in "Order To sever and Transfer" from 06.04.10. and order of06.23. 10
-"

CJ~tion is Decessary due to fnod on the court

As fraud was committed on the court, there is a need to ascertain, whicb parties were

involved. and what is their culpability

[l] The United States Court ofAppeals for the Sixth Circuit has set forth five elements of

fraud upon the court which consist of conduct: Ill. On the part of an officer of the court;

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2. That is directed to the 'judicial machinery' itself; 3. That is intentionally false, willfully

blind to the truth., or is in reckless disregard for the truth; 4. That is a positive averment or

is concealment when one is under a duty to disclose; 5. That deceives the COurt"

Demianjuk 11. Petruvs1fy. 10 F3d 338, 348 (6th Cir.1993).

Although other United States Courts of Appeals have not articulated express elements of

fraud upon the com as the Sixth Circuit did, the doctrine has been characterized "as a

scheme to interfere with the judicial machinery performing the task of impartial

adjudication, as by preventing the opposing party from fairly presenting his case or

defense." In re Coordinated PretrinJ.. Proceedings, in Antibiotic An'IitnqJ ActUms. 538

F,2d 1801 195 (8th Cir.I976) (citations omitted); see also Rozier)'. Ford Motor Co., 573

F:2d 1332. 1338 (jth Cir.1978) (holding "only the most egregious misconduct. such as

bribery of a judge or members of a jmy. or the fabrication of evidence by a ~

which an attomey is impli~ win constitute a fraud on the courtlt). Additionally, fr~d
r,
upon the court differs from fraud on an adverse party in that it "is limited to fraud which
-t)

seriously affects the integrity of the nonnal process of adjudication."

Gleason)'. J~&.. 860F,2d556. 559 (2dCir.1988).

Other United States Courts of Appeals expressly require that fraud upon the court must

involve an officer ofllie court. See 660. P. Reintjes Co. )'. Riley Stoker CorD:, 71 F3d

44, 48 (1$1 Cir.J995); Demianluk. 10 F3d at 348. The Ninth Circuit noted that "one

species of bud upon the court occurs when an 'officer of the court' perpetrates fraud

affecting the ability of the court or jury to impartially judge a case." PUlnJ2Jrrev Y.

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Thompson Tool Co.. 62 F.3d 1128, 1130 (!!th Cir.1995); see also Weese v. Schukm.an. 98
F.3d 542, 553 (lOch Cir.1996) (noting that "fraud on the court should embrace only that

species of fraud which does or attempts to, subvert the integrity of the court itself, or is a

fraud perpetrated by officers Qfthe court") (citation omitted); Kerwit Med Prods., Inc. v.

N. & H Instruments. Inc.. 616 F.2d 833t 837 (lith Cir.1980> (same).

Party that was seeking to seal the transcript were the Plaintiffs, as during the hearing on

August: 7, defendant Hale) Internet Radio talk show host brought to court records of his

radio shows, where he demonstrated that Berg and the rest of the plaintiffs repeatedly

defrauded the court by taking out bits and pieces of his radio programs. putting those

together and claiming defamation. During purported "seal" of the ttanscript Berg and

rest of the plaintiffs used the DisUict Court and the Court of Appeals as the dumping

ground, where they dumped hundreds and thousands of pages of unrelated, inflammatory

and defamatory material, among them forged documents, perjured and fraud~
,r".'
! !~ . . '
-~. t >

statements., all in an effort to prejudice both courts against the Defendants. T$itz
I'.:
C}
complained repeatedly that forged documents and perjured and fraudulent statements
-n
were used, demanded criminal investigation, but nothing was done. Taitz and the rest of·
~

the defendants have suffered damages in the form of severe emotional distress ana-­

damages to their reputation due to those filings.

On 07.09.10 Berg filed response in opposition to motion filed by Taitz, where he c1aimed

yet again that the transcript was sealed., even though there was no such seal. Finally Berg

filed a motion on 07.26.10 claiming that the transcript was seal~ while indeed it was not

sealed.

The issue of order to "seal the tnmsc.ript" clearly showed that fraud was committed.

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Such actions cannot go on in the Federal Court, and Taitz demands investigation and

sanctions against the guilty party, as welJ as compensation for damages suffered. This is

particularly important as one of the plaintiffS in this case, Lisa Liberi. an assistant to

attorney Berg, is a convicted document forger. In 2008 Liberi was convicted in San

Bernardino County, in the state of CA of ten counts of forgery of documents, forgery of

an official seal, grand theft and got eight years in prison. (Prosecuting Assistant DA-

James Secord). Her eight year prison term. was reduced to time served and probation

until MaICh of 2011. Liberi is allowed to ser\le her probation only in CA or in NM. where

her family resides. When Taitz and other defendants provided this infonnation to publi~

plaintiffs filed a frivolous law suit, where they claimed that Liberi resided in P~

however th~ never pNVided a shred of evidenu to prove tIl_t Liberi resided in P A.,

they gave Berg's office ad<kess as her address, while defendants provided court records

from CA showing that according to her probation she is not allowed to live anywhere ~

CA and NM. On July 9. 2010 Berg filed a motion in opposition. to unseal the transcrik ( .' .
claiming that the transcript was sealed, even though there was no such seal. Moreover, ~
-0
never responded to the issue of Liberi's residency, trying to avoid the issue and stating m:..
-
his 07.09.2010 pleadings that Liberi showed up at the hearing and showed a docum~

that she is not a resident of CA or TX. He never responded to a simple request to show

that sbe resided in PA at the time current KnOll was filed. This matter goes to the

essence of the case, as Berg and Liberi filed this whole legal action, claiming that Liberi

is not the criminal who was convicted in CA of forgery and grand theft., and resides in

either CA or NM, but rather she is an innocent WOrnaIl; who resides in PA, and she and

Berg were defam~ when it was disclosed by the defendants that she is a convicted

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document forger, who prepared or handled documents for Berg via mail and fax. and

participated in nation wide donations drive_

Defendant in this ease, Linda Belclter, has repeatedly mailed ad faJ:ed to Judge

Robleno a letter, where she stated that Attorney :oer. defrauded the court by
stating under penalty of peljnry, that he served the defendant Belcber. (Filed Notice

of Appeal with letter from Belcher, exhibit 2) Belcher stated that she refused service by

e--mail due to maIware in Berg's computers. She stated that she was never served by mail.

Her letter stated., that Berg committed double :fraud on the co~ not only by not serving

Belcher wnh pleadings, but also claiIning, that the fact that she did not respond meant

that she agreed with the allegations in Berg' 8 pleadings. Belcher stated that her rights to

due process were violated. she demanded to vacate all. orders made based on any .and all

pleadings by Berg submitted after June 2009, the time, when her attorney, Mr. Hoppe

resigned, since her rights to due process were violated.

Additionally, in her sworn statement Ms. Belcher alerted the court that she ~a
-n
volunteer researcher for Berg, had multiple phone conversations with Berg and Li~
-....

and that Liberi approached her and others, including one Larry Sinclair, requesting to •

furudulent complaints about Taitz. Belcher stated that she personally was on a three way

conference call with Liberi and Sinclair, where Liberi asked Sinclair to file such

fraudulent complaint about Taitz. Larty Sinclair indeed filed such fraudulent complaint

about Taitz in the Central District ofC~ case 09-cv-82, presiding judge David O. Carter.

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Of utmost con~ was the fact that Belcher repeatedly demanded to docket her letter

and repeatedly she was denied such oppOrtunity. Belcher stated that she faxed her letter

to the chambets of Judge Robreno, called the chambers and was told by the clerks that

the letter was submitted to Judge Robreno, and it is up to him whether to docket her

letter.

Taitz demands investigation and clarification. Was Belcher's letter ever forwarded to

Judge Robreno by the clerks? Why was she denied her 14t1l Amendment Constitutional

rights of due process and equal rights to have her response docketed and get a response

from the judge? Belcher is an indigent; residing in Texas. She has no access to pacer and

cannot afford an attorney. She was victimized by actions of Berg and did not get any

reliefftom the ooWi.. When Taitz included Belcher's letter, that was forwarded to her, in

her July 2,2010 motion, it was completely ignored by the court. While Taitz does not

represent Belcher, the fact that Belcher's letter to the court was never docketed and was

complexly ignored, negatively affected all of the defendants, including Taitz and Defel!<i
':"-'

Our Freedoms foundation. . ~~:


"

, ~-;. "

Taitz was deeply concerned and perplexed by the arrogant, brazen fraud being commimct
-;-1
.....­
by Berg and the rest of the plaintiffs. Of outmost concern is behavior by Liberi. Just bQ;
..
c..l' •
Crinrinal Record of case FWV028000 shows 23 criminal charges and 16"

convictions.{Exhibit 3) Acconling to the testimony of inspector Leibrich she had

previously 19 more charges (Exhibit 9). Why isn't she afraid of going back to prison?

Why isn't Berg afraid to be disbarred in light of his two prior sanctions? Why isn't he

afraid to be criminally prosecuted together with Liberi? '

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It is a known fact that FBI, Department of Justio.'l use convicted cri:mina1s as informers

and agitators. Recent trial of talk show host Hal Turner gave public a glimpse of how

"patriot" leaders are used as informers and agitators. Is this a situation where criminals

are brazen, because they know, that they have a back and they will not be convi~ no

matter how much fraud on the court they commit, how much pajury or forgery do they

commit? Taitz is requesting a clarification from the court, whether indeed the court is

aware of any special informer status with the department ofJustio.'l given to the plaintiffs

and Berg? The defendants are requesting a clarification, if there is a ~ck" for Liberi

and/or Berg and other defendants represented by someone in this court? That would

exp~ why Berg and Liberi are so brazen and submit pleading after pleading with bold

lies, defrauding the courts time and again. This might explain, why Linda Belcher's

response was never docketed. This would explain, why somebody deleted from the

electronic docket some of the exhibits, submitted by the defendans, why the original

complaint is not available on pacer. why the court docketed on 01.21.10 a letter ~

Berg,. his response to Taitz request fOT sanctions; which contained hundreds of pages'R!
o.J
irrelevant, defamatory, inflammatory material; but refused to docket actual request f~
~

sanctions or the reply to the letter by Berg from 01.20.10; why a letter was sent by Joan-..
...-
v·~

Carr to the court of Appeals, stating that according to clerk David Hayes the transcript

was seal~ while in fact it was not sealed. Taitz requests clarification. whether there is

an individual (s) in the US District Court for the Eastern District of Pennsylvania, who js

(are) providing a "back" to Berg, Liberi and the rest of the plaintiffs. by manipulating the

docket and undermining the defendants.

Liberi v Taitz Motion for Clarification 25


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Taitt is seeking clarification, if the woman pictured on the Exhibit 10, photograph of

Brent Liberi and Lisa tiberi, who was convicted of 10 criIninal counts in 2008 in CA, is

indeed the woman that your Honor, Judge Eduardo Robreno saw right in front of him on

August 7. 2009 during the motion hearing in Liberi et al v Taitz et al when she claimed

that she is an innocent resident of Pennsylvania, who had no convictions and was

slandered and defamed when the defendant published an official report of criminal

convictions in CA for Lisa Liberi?

Taitz is seeking clarification, if the woman pictured on the Exhibit 10, photograph of

Brent Liberi and Lisa Liberi, who was convicted of 10 criminal counts in 2008 in CA. is

indeed the woman that court reporter Joseph Matkowski saw right in front of him on

August 7, 2009 during the motion hearing in Liberi et al v Taitz et at when she claimed

that she is an innocent resident of Pennsylvania, who had no convictions and was
(~';:)

slandered and defamed when the defendant published an official report of criminal;:: ,.." ,"'.
; I ~, .­
'-', "
j ','.

convictions in CA for Lisa Liberl?


-u

Taitz is seeking clarification, if the woman pict:un::d on the Exhibit 10, photograph
-..
o:L~
en
Brent Liberi .and Lisa Liberi~ who was convicted of 10 criminal cotmfs in 2008 in CA, is

indeed the woman that the clerk: for Honorable Judge Eduardo Robreno saw right in front

ofhim on August 7.2009 during the motion bearing in Liberi et al v Taitz et at when she

claimed that she is an innocent resident ofPennsylvania, who had no convk.1ions and was

slandered and defamed when the defendant published an official report of criminal

convictions in CA for Lisa Liberi?

Liberi v Taitt Motion for Clarification 26


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Taitz is seeking clarification. if the woman pictured on the Exhibit 10. photograph of

Brent Liberi and Lisa. Liberi. who was convicted of 10 crimina1 counts in 2008 in CA,. is

indeed the woman that the bailiff for honorable Judge Eduardo Robreno saw right in

front of him on August 7. 2009 during the motion hearing in Liberi et at v Taitz et a1

when she claimed that she is an innocent resident of Pennsylvani~ who bad no

convictions and was slandered and defamed when the defendant published an official

report of criminal convictions in CA for Lisa Liberi?

Taitz is seeking clarification, if the woman piCtured on the Exhibit 10, photograph of

Brent Liberi and Lisa Liberi, who was convicted of 10 criminal counts in 2008 in CA, is

indeed the woman that secret service officer in the courtroom. ofJudge Eduardo Robreno

saw right in front of him on August 7, 2009 during the motion hearing in Liberi et a1 v

Taitz et at when she claimed that she is an innocent resident of Pennsylv~ who 1Jad.no
o
convictions and was slandered and defamed when the defendant published an 0ff?~ial
. "
""',
~'~ ­

report of crimioal convictions in CA for Lisa Liberi?

..
__ ~

C;'i
: I ••

Did the member of PA bar and the Bar of the US District Court for the Eastern Dist:foit\
of PA and the Third Circuit Court of Appeals, Attomey Philip J. Berg defraud both the

US District Court and the Court ofAppeals by claiming that the transcript was sealed in

order to cover up for the fact that he is working with a convicted document forger Lisa

Liberi. currently on probation in CA, and to cover up that he previously defrauded both

US District Court and the Court ofAppeals by claiming that she is a d.i:ffurent Lisa Liberi,

Liberi v Taitz Motion for Clarification 27


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not a convicted forger from CA, when he signed the complaint in this case claiming

Liberi was residing in PA while he knew that not to be true?

Did Attorney Berg defraud the court of Appeals ?

Did the CIMs forward to Judge Robreno letters, faxed by defendant Linda Belcher,

where she stated that the member of PA bar and US District Court and the Court of

Appeals PA attorney Philip J. Berg repeatedly defrauded the court by claiming that he

served Belcher with pleadings and that her silence meant acquiescence with his

allegations, when in reality he did not serve her?

Request for order to show c::aase wily sanetiOdS should not be asserted. against

parties who 4»m.mitted mud 011 three coarts:

Among those parties Attomey Berg, plaintiffs and employees of the District Court ofthe
-,
.+
Eastern District of Pensylvania, who were involved in the above mentioned fraud. ~

case is akin to precedent of CHAMBERS v. NASCOJNC 501 us. 32 (1 9911NQ_ 90­

256.SllDreme Court afthe United States, ,Argued Februmy 27, 1991. Decided June 6,

1991 CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR TIIE

FIFTIl CIRCUIT. JUSTICE WHITE delivered the opinion of the Court. "This case

requires us to explore the soope of the inherent power of a fede.ml court to sanction a

litigant for bad-faith conduct. Specifically, we are asked to determine whether the District

Court, sitting in diversity, properly invoked its inherent power in assessing as a sanction

Liberi v Taitz Motion for Clarification 28


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for a party's bad-faith conduct attorney's fees and related expenses paid by the party's

opponent to its attomeys. We hold that the District Court acted within its discretion, and

we therefore affirm the judgment of the Court of Appeals." Similarly, in Whitehead v

Food Max: of Mississippi, inc.. 332 F.3d 796 (5th Cireuit 2003) the court found that

action not grounded in fact and law is sanctionable.

In this case actions by the eotm.Sel Philip Berg represented a reprehensible egregious

violation of professional code of ethics. While in some situations an attorney

unknowingly and inocently relies on the affidavit by a party, who might be committing

ftaud, in this case Attorney Berg clearly knew that Liberi does not reside in PA, that she

does not show up for work in his office, yet he maliciously defrauded the defendants and

three courts: US District Court of PA, Third Circuit Court of Appeals and US District

Court in CA, and harassed the defendants with a frivolous law suit in order to continue

fundraising with tiberi, recently convicted thief on probation, and to continue filing i!ih

this court documents prepared by a convicted forger Liberi and to undennine and silente
r<
c.)
Taitz, who blew the whistle on him. Berg exhibited the same behavior, as he exhlb~

previously before Honorable Curtis Joyner in this very district, for which he waS
V' .
CJ1
sanctioned over $10,000 to cover the attorneys fees of the opposing party.

U.s. District Judge J. Curtis Joynets to-page opinion in Holsworth v. Berg. as seen

below and as was thoroughly covered in Intelligencer. which is brought with a proper

purpose of showing modus operandi in Berg repeatedly defrauding the court and bringing

frivolous legal actions with the sole purpose ofharassing the opponents.

Liberi v Taitt Motion for Clarification 29


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Holsworth v. Berg, 322 Fed. Appx. 143 (3rd Circuit 2009); Holsworth v. Berg, 2005

U.s. Dist. LEXlS 15393 (ED PA 2005) was packed with criticism of the conduct of

Attorney Philip Berg of Lafayette Hill, Pa

"Other attorneys shQuld look to Mr. Berg's actions as a blueprint for what not to do when

attempting to effectively and honorably perform the duties of the legal profession,tI

Joyner wrote:"lbis court has grown weary of Mr. Berg's continuous and brazen

disrespect toward this court and his own clients. Mr. Berg's actions ... are an enormous

waste of judicial time and teSOurces that this court cannot, in good conscience. allow to

go lUlplmisbed."

In the suit, Berg is accused of legal malpractice by former clients who claim his failure to

respond to an ERISA claim against them led to a default judgment

But the sanctiOIlS against Berg stem from his decision to file a third~party counterclaim.,of
l~

fraud against a pension fund that had sued his former clients. 2(;COrding to court • .
1"';
Joyner blasted Berg for filing the fraud claim, calling it an "irresponsible decisi6rl."

because the claim was "uttedy barren of any scintilla of legal principl€="
..
c,.5 '
In the ERISA suit, Bergts former clients Richard Holsworth and his compai9.

Richard1s General Contracting -- were sued by a group ofpension funds led by the

CarpentelB Health and Wel:fure Fund of Philadelphia and Vicinity.

Carpenters Health claimed that Holsworth and his company had failed to make required

payment offringe benefit contributions.

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According to court papers, Joyner found that Berg "neglected to file a response to

[Carpenter Health's] claim or provide any legal defense whatsoever for his client It

Even after a default judgment was entered against Holswo~ Joyner found that Berg

"remained silent." In April 2002 - two months after the default judgment was granted

and 11 months after the suit was first fiJed Joyner fomtd that Berg "broke his silence"

by filing a petition to strike the judgment or to open the default judgment.

Bergts motion was rejected and a default judgment of more than $5,300 was entered

against his clients. The judgment swelled to more than $10,000 when Carpenters Health

later successfully moved for a supplemental judgment to recover more than $4,700 in

attorney fees for its efforts in responding to Bergts untimely motions.

Holsworth and his wife later filed a legal malpractice suit against Berg in the Philadellbia

County Court of Common Pleas, alleging that Berg negligently failed to represent theitf
r<
in the Catpenters Health case.

.,
-'
c.,..,,~ I

A year later, in February 2005, Berg moved to join Carpenters Health as a third-~
defendant in the malpractice suit demanding more than $20t OOO in damages.

In his counterclaim. Berg alleged that the ERISA suit filed by Carpenters Health in 2001,

which led to the malpractice claim against him, was "a fraud upon the court and a

fraudulent taking from the Holsworths"

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~~ Health's 'lawyers removed the case to federal court and filed a motion to

dismiss the claim. Joyner ~ finding that Berg's fraud claim was "frivolous" and was

motivated by an intent "to harass Carpenters Health and the Holsworths. as well as to

delay and disrupt the administration ofjustice

The claim was fatally flawed,. Joyner found, because Berg had no standing to bring suit

against Carpenters Health and had "failed to conduct even a minimally reasonable inquiry

before filing his complaint.

Granting snmmary judgment in favor of Carpenters Health, loyner said he found it

"wholly unnecessary" even to consider the facts of the ERISA case because it was

"abundantly clear" that Carpenters Health was entitled to a judgment as a matter of law. <..,.,.,)

Joyner invited Carpenters Health to file a motion for Ru1e 11 sanctions. When it diCi, i _

Joyner found that Berg "continued his trend of unprofessional conduct by, once again, c>

failing to file a timely response," ..


.....;
c.,." ,
c:.n

In a footnote, Joyner said Berg's response to the sanctions motion was due on May 26. In

a phone call to chambers on May 31, Joyner said, Berg's assistant requested permission to

move for an extension oftime, saying Berg had been out oftown for two or three weeks

and would not be rettnning Wltil June 9.

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Joyner said he agreed to acapt such a request if it were filed the next day, but none was.

Instead, Joyner said. a letter signed by Berg's assistant was faxed to chambers on June 2.

requesting that the deadline be extended until Iune 27

his professional obligations. this court was not inclined to permit Mr- Berg to further

delay the review ofCarpenters Health's ripe motion.»

In a June 2 opinion. Joyner found that Berg had violated Rule 11 by "filing a complaint

completely devoid ofany basis in met or law, as would be apparent to any reasonable

attoroey after the slightest inquiIy."

Berg's :fraud claim, Joyner said, was "inadequately pled., not grOlmded in fact; -_$.
time-­ ,

barred, and utterly irrelevant to the pending malpractice action against him. tt

-r.l
In his sanctions order, Joyner ordered Berg to reimburse Carpenters Health the $10#;8
..
-'
in attorney fees and costs it incurred in defending the claim. He also ordered Beiji to
complete six credits of ethics courses certified by the Pennsylvania Board of Continuing

Legal Education, and recommended that Berg be investigated by the Pennsylvania Bar .

Association's Committee on Legal Ethics and Professional Responsibility.

Liberi v Taitt Motion for Clarification 33


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On June 16, Berg filed amotion for reconsideration urging that the sanctions imposed on

him should be forgiven due to "extenuating circumstances," including health problem.s~ a

three-week European business trip and financial difficulties.

Berg conceded in his brief that "there were numerous procedural errors,untimely

responses and omissions," but said he "did not do so with intention or defiance. t!

Joyner flatly rejected the motion, saying "in no way, shape or form do the 'extenuating

circUlllStaJJ.ces' proffered by Mr. Berg even begin to justify, excuse, or explain his

unprofessional and unethical course of conduct throughout this matter. These transparent

excuses are not only patently insufficient to meet the legal standard for a motion(~!?r

reconsideration, they are insulting to this court and demeaning to the legal profession. "'::~,
"""
Wherefore defendants respectfully request the court:

1. to deny the plaintiffs July 26, 2010 Emergency Motion c.,..'),


c.n
2. To grant defendants motion for clarification

3. To grant defendants 60 B motion for reconsideration and dismiss with prejudice

current action 09-1898 due to multiple acts of fraud on the court and perjury by

the Plaintiffs and their attorney and for filing a frivolous action, not ground in fact

or law. In the alternative Defendants are seeking a motion to dismiss without

prejudice. In the alternative Defendants seek correction of the order to sever and

transfer and deletion from the order a notation "Uberi is a resident of PA" and

Liberi v Taitz Motion for Clarification 34


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requesting an evidentiary hearing to ascertain Liberi's residendency by

preponderance of evidence in order to resolve the issue of diversity to be held

after August 20th. Defendants request a subpoena to be issued by this court for

Mr. James Secord, assistant District Attorney for San Bernardino county CA,

Liberi's prosecuting DA. as well as her probation officer, to testify at such fact

finding hearing on the issue of diversity.:in order for the defendants to be able to

prove by preponderance of evidence that Liberi did not reside in PA and current

action was bro'Ught for impmper purpose of harassing and silencing the

defendants.

4. Defendants are tequesting this court to issue an order for plaintiff's attorney

Philip Berg, as well as the plaintiffs and other possible culpable parries to show

cause, why they should not be saoctioned for repeated acts of fraud on the court,

perjury and filing a frivolous action with the sole purpose to harass the

defendants.
1'..:

J
,
,
'.
w:
c.n

lsi Dr. Orly Taitz, ESQ

07.27.10.

I certify under penalty of perjury. that I served above pleadings on following parties and

authorities:

Liberi v Taitz Motion for Clarification. 35


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HonRandallRayRader

Chief Judge of the Third Circuit Court ofAppeals

21400 US Court ofAppeals

601 Market street

Philadelphia PA 19106

Hon Harvey Bartle, UI

Chief Judge US District Court for the third District of PA

601 Market street

Philadelphia PA 19106

""',.'""
~ , .I'

~ ..~: ~ L/" '~.


Philip Berg
c.;
555 Andorra Glen Court. ste 12

---....
--:')
-~

Lafayette Hill PA 19444-2531

Neil Sankey

2470 Steams s1r#162

Simi Valley, CA 93063

Linda Belcher

201 Paris

Liberi v Taitt Motion for Clarification 36


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Filed:

Castroville TX 78009

Ed and Caren Hale

1401 Bowie Slr

wellington TX 79095

Philadelphia District Attorneys' office

3 South Penn square

Philadelphia, PA

US Attorneys' office

Eastern District ofPA

615 Chestnut str, ste 1250

Philadelphia PA 19106-4100 C"jI.


tn

James Secord

Assistant District attorney

San Bernardino County

316 North Mountain view

Liberi v Taitz Motion for Clarification 37


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San Bernardino CA 92415-0004

909-387-8309

www.co.san-bemardino.ca.uslda

San Bernardino County, CA

Probation Department

175 w. Fifth str. 4th floor

S. Bernardino, CA

Audrey B. Collins

Chief Judge

US District Court

411 W. Fourth str

Santa Ana CA 92701

Judge David O. Carter -

..
-'
USDC Central Dis1rict of CA

411 West Fourth Str

Santa Ana CA 92701

US Commission on Civil Rights

624 Ninth Street, NW

Liberi v Taitz Motion for Clarification 38


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Was~ DC 20425 C

Public Integrity Section

Department of Justice

950 Pennsylvania Ave, NW

Washington DC 20S3()..O()()l

Office of the United Nations High Commissioner for Human Rights (OHCHR)

Special Rapporteur on the Situ.a.tion ofHuman Rights Defenders

The Honorable Mrs. Margaret Sekaggya

Palais des Nations

CH-1211 Geneva 10, Switzerland


en
International Criminal bar Hague
..

-!

United Nations Commission for

Civil Rights Defenders

Orsolya Toth (Ms)

Human Rights Officer

Civil and Political Rights Section

Special Procedures Division

Liberi v Taitz Motion for Clarification 39


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Office ofthe High Commissioner for Hwnan Rights

tel: + 4122 917 9151

email: OWth~
lsI OrlyTaitz ~
07.27.10.

Proposed order

I"":
c;

..
-' , ,
c,..""
,(11

Law offices of

Liberi v Taitz Motion for Clarification 40


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Dr. Orly Taitt, ESQ

29839 Santa Margarita CA 92688

Pro se and for Defend Our Freedoms Foundation

UNITED STATES DISTRICT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Lisa Liberi, et aI ) Case # 09-cv-Ol898-ECR

Plaintiffs ) Assigned to Honorable Edu.ardo C. Robreuo

v )

0rIy Taitt et aI )

Defendants
~-l C~,
ORDER ~.-, r

-n
day of JuJ;y 2010 after consideration of Plainti~·
AND NOW, this,_ __
c..:.
..
emergency motion for clarification or in the alternative Motion for Reconsideration CfJf

this courts July 13, 2010; and after consideration of the defendants response to the

Plaintifrs Motion as well as Defendant's motion for clarification and Reconsideration.

Plaintiffs Motion is deJlied..

Defendant' 8 Motion for Reconsideration and Clarification is granted.

Liberi " Taitz Motion for Clarification 41


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Plaintiff and attorney for plaintiffs Philip J Berg is ordered to show cause, why he should

not be sanctioned for repeated acts of fraud on' this court as well as on the Third Circuit

Court of Appeals and for filing a frivolous legal action not based on fact and law.

IT IS SO ORDERED

Eduardo C Robreno, J

_.: '1

-..,.
.

Uberi v Taitz Motion for Clarification 42


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f;ase: 09-3403 Document 003110023894 Page: 1 Date Filed: 02117/2010
i
!
i
\

UNlTED'STATES GOVERNMENT

MOIORANDUM

TO; c;LBRK usa


If'ROM;

~: I
February 17, 2010

RE: lUJLB 'to ,·SlfOW CA.VSB -- v. Orl.y Te,its ... ,et AL


lJJi U; 'Liberi.
Civil Action JiO. 09-~S98
trSCA 0:9-3403

...
1: am w:r:1:t.iJlg' in xe.8pOll88 to Your R.u.le To Show" cause :i.n
t:.:be above ,captioneCl case ..

em Septe.nJber 24" 2009 David Bayes l.eft ill. voice :midl


l\enage for c:ouD8el. regard1ug the t4anScttiptB requested.. eovnae1
was al.lJO ~fied that the proceeding ~l.d Augwat "1,. 200.9 was under
seal and. aD. ord.Etlt of' court would be necessary to 1maeal the.
proaeedi.ug :and have a transcript prodUced. ,,~::' -1" ('


To date our office has DOt received payment ... a motiOn to
UD.8eal bas not be~ d:ocket.ed nor has a. transcript purchase o~:r;
fom beeD. sW::mdtted to the :District Court. '"'fi
--'

..­
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Case: 09-3403 Document 003110023894 Page: 2 Date Filed: 02117/2010


case:Q9..3403 Document 00319790342 Page: 1 Date Filed: 08I29l2OO9

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MJ."K£ pIK)MPT....'iA-m'iFACT'<~y FINANt."lAL ARRANGEMENTS FOR TRANSCRIPT ARE GROt llItl)5 Ftm .-"
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~29.2g09 • -..
.

Pe!iIiptm lApps!tan!sl

(SiC} 825-3134

Put m. NO'nFICATlON fllA.1''T1I.AH8aJJTIfAI...,lItUiDlfma . cr.. ,•• ,1•••.,-...,..... . ..,


...........~c-L Nili.IifIiIII_ _........e.nGf.AJlpclil. . . . . .4IIIl.J

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M4JIII. . . . ., . . ..w.a__.fIIY-..._ _ __

09/17/2029Case:
08:09
Case
10-3000
2:09-cv-01898-ER
Document: 003110242721
Document 136 Page:
Filed 07/29/10
45 DatePage
Filed: #0483
51 P.045/0BO
4508/06/2010
of

Wherefore, defendants respectfully motion for the judgment for the complaint be dismissed
due to lackof venue and jurisdiction, together with the costs and disbursements ofthis action.

Dated 06.08.09.

Dr. Orly Taitz ESQ

26302 La Paz, ste 211

Mission Viejo, CA 92691

Pro Se and on behalfof Defend our Freedoms Foundation and as a president of Defend Our
Freedoms Foundation

Addendum 1 Case FWV028000 - Defendants .,

'S~~fD~knd;~t -·..·-·..irN;;·C~~rlD;i;'fSt;;,:,sIA9;~~Y/··:iArrest Date ,ICount 1 Charge.j Vio/~ti~;;'D~te I


·1 ,; :! ilDR Numberl ,! :l i

:1 ,~ . ,.. '1 . . . . .- t.. .--..... ~ . . _J ..-.--..--..-.. ;~==.cc~.;; j


T'~IBERI , LISA R :., ~j'!RA :j05/18/20011PC l' 5(A) ',.!,OSf1812001
'h10013759~1
',:.i,.,.·,

:1 .' ., ;1 '
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.IALlAS: COURVILLERICHARDSON. LISA

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, LIBERI, LISA A f
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;iALlAS: UBERI, LISA !
!
\ALIAS: RICHARDSON, LISA RENEE-----~....---~.. ~.. --··--~··'....-··­
i
I

... ,....... ,.. ,,'_..*'-,.


!

6
OB:09
09/17/2029Case:
Case 2:09-cv-01898-ER
10-3000 Document 136
Document: 003110242721 Filed 07/29/10
Page: 46 DatePage 51 P.04B/080
10493
4608/06/2010
Filed: of

Case FWV028000 Defendant 1.608112 L1BERI, LISA RENEE - Status

Custody N/A .

Filing Type Held to A.nswer Filing Date 05109/2003

Ordered Bail $Q.oo Posted Bail


$0.00

D.A. James R. Secord Defense Dean Pitel (Court Appointed)

Next Action: Deputy Report #: RA-RC 110013759

....,......- . - ...... ~ ...-... ·....·-···.. · ..·,,··r',,- ·····..•·..- ..,,·····--;F==''''··- ... !


Wllllant :!Type ~!Status j/ssued fiAffidavit j

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1,.
i

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;====-'----.;....;.;;~
· prObation;!Type .jGranted ilEXPiration
,,~ .! .. ".. .,_~t_~~,,_.~...

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, j :j

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· Sentence~jConvicted Date 1jCounty Ja.il ~IGTS

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·"·-"·---"·""fState Prison "jMax Sentence ;f


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~---'.

Case FWV028000 Defendant 1608112 lIBERI, LISA RENEE" Charges

· Arreat Charges

7
09/17/2029 08:09 #0493 P. 047/080
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110242721
Document 136 Page:
Filed 07/29/10
47 DatePage
Filed:
4708/06/2010
of 51

~
.... ..'.{i
".~

..... ... "' .,,_....­


~-."

.Co;;;'i li:5harge :i
!Viofation Tp,~""-'!Status
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~'"-~'''''-'''-''''.''' ,..._·...·...······_···_'~'_n~. '"'~'"~''' \''''',,,-, ..' _..__ ...~"."~ .':, .... - ... ,.~ .. !

.1 :105/18/2001. 'j
;;

;3 !PC 472 ,jF .(05/1812001 .~


" ~
:i ! '~
~.:!:p611-5(A} . :F'I· F=·· ·=···=·······=·····'jO·FFERIETC··FALSEIFORGED-·_·'·····
· '!.,05118/2001'·-.~··· ...-.u-iHTA-.---·.. ·-.·!
" :~ ,i ~
"j '!INSTRUMENT TO FILE '! .L_...... ...'i :
5 '~PC 487(A)···.iF-·_··..·_-·!G RAN-D-THEFT':"p'Ro'p~Rrr/E-rc--''''';1p=05l='''''=1'e'::''-'/200=
..- ,--Cf':,I=~=-:Ir=H=T'-A----O;-=-:::"";'-"'i'j
"i~OVER $ 4 0 0 1 "

'-6- fpc 470(0) :IF :IFo~ERY . .--fci5l1 W2oo1i-l-----"·=.. .~-HTA ~<.:; ,:~.",. ;- -"-·,~ l,
:-1 -f .... ~:r!
"iF'--"-";lFORGE OFFICI.AiSEAL-- - - .........- 8/=2=00=1'-'-"'---- 'ifHTA . -~;:~

, :!

7 :lpc 472 ... 'j';:':=o5=-'i1=-

" ••,.. ~,.,. _ ......._ .. "~W_,.,.: t.. "_~" .., .'.'. ~t~. ~. . _,. ,.'"".~'"' _,_. . .._.. _._. .__._. .~_._.. "._.~·l. ,. , ~,. . .,~.~., ~. ,." .'" -~ ....~. ___...:.t ... \. ,..,,_,.~~{.,; '~"'"~
8 !PC 115(A)-!F ;iOFFERIETC FALSE/FORGED .,.i.•05/18/2001! ,!HTA ~ ;
: '
:; , , ' ;
:\lNSTRUMENT TO FILE
, ,!
, i '
,j ; -...
ii
i........ ,.,.. ~ ... ~~,_u:l, ~.,. . _~"" . "'.,,~."",....""~M_·.'~ -~:j .. ',!;--~=l==-....,. ~:" ..- ·i

9 j"-P-C-4-87""';'(A-)-'-,jFiGRAND THEFT: PROPERTY/ETC ·105118/200-1" j H T A C' ,


I ' . ,' ,1
i : 'lOVER $ 4 0 0 ) : ! ;

·10 --~lpc·487(A).j-F . . -_· . '·;GRAND THEpf-;'PROPERTY/ETC ····;05/18/20011


~~ , ,; ,! ~~
..
n . .- · . . . . ~I,,...-'H=TA=='-.....;... 1
=
.. ·

, ! :lOVER $400 :li


:1 .j ..-A... n . . . . . . . . . ._ ••• ­ i....__ ..._.......... , .. _~: ........ .1 __ . . _......_..
'. 11 "IPC ;!F 'iGRANO THEFT: !05/1812001 _;.' ';HTA

.t~~~~~1.) :1 .... __ t~TOMOBILE:~~.~.~~~~~ ,..,.,."........


,L. :: .. __ ..... 1.,....... . . ,;

:1F'H=T""'A"-""";';;;;=4!
12 !PC 487(A) jF jGRAND THEFT: PROPERTY/ETC :05118/2001 q
~~ .~
'. 'lOVER $400
,j .. :
i
J ..... ! " ,~,~.: i.~,. ~ .. ,

09/17/2029 OS: 10 #0493 P.048/080


Case: Case
10-3000
2:09-cv-01898-ER
Document: 003110242721
Document 136 Page:
Filed 07/29/10
48 DatePage
Filed:
4808/06/2010
of 51

•·13·_·--!Pc;fF··_····· ·'i.·GRAN[)'THEFT:
it
:\487(D)(1)i .,;AUTOMOBILE/ANIMAUETC :i
".. . . . _.._.'t, . __.~. . , . . . ~·-t_._., _" . ,___,lL.._,. ,. __ ....~".\'\ . _.""'.'". ,'___.._.. _.,',."".,.. . . _."'~,_,_, .~
14 'ipc 487{A) :IF ·F:':iG==R~A,.;;..N~D=T~H=E=FT;;...:-P-R;.:;.::O=P=E=R~TY:=I=ET=C=-......:.;:::.lO::::5/=1~8f=20=O'-1-j-··--··-·:HTA· . l
• ·r
J
/~ J~
lOVER $400 '! -j :1 ,
i
.« • •, . ~---,.~. :! .".,_,_"l., ,.,,_r_ .. __ '~ .. ~. __"" ...,.....j

: 15;;PC '-"""1!F!GRAND THEFT:lO&-'-81-20-0---'1=.!


:l487(D}(1)I ;~AUTOMOBILElANIMAUETCl'
. . _.. . . . . . ·i J .....---.................... ... .-.-.-.~..-...........-. . ._............_..........···_·w"".•....••......... 'r-l..;.;...==....::;.:;_...;.:::.•. 1""...::-.~
.____ ,,·l___._. ...=-.=-.~
... =.-.c::::;
'16!PC 487{A).JF ;!GRAND THEFT: PROPERTY/ETC :105/18/2001 ': :lHTA

~- -""==:..:...:.:;.l..
. ., .......:F"L-=....-"-...;.. . =--=ji:;;;.;..".;....:.=='rl°::::..:.V:....E-:.;;R==$=40=O="'--_..;;.;;;;:;=====:..;,i-
.17.iPC 487(A} '!F:GRAND'TH'E-Fr: PROPERTY/ETC'····"",j05/18/20011
1

..
~l

··fHTA·· j .
: 'lOVER $ 4 00;!i
'. • •• __ • • • •n ••••• : t ,,",., '"" ~ ..__... .~ "."," __.. ~. '~." ,~._~
t •• ",,. •__""", ..__"__ •.• ___ ...... u ••, . . .,, _ _ _ ."':L. ~ ~: j,_,__ ""~_,, \" :: ~
, Infor Charges
." .. ....... ...... ..

.fVi~i;ti~~-'-
, "--~~ "",,-,.~, ,,

, Count!Charge 'J Severity\Descnption '1 Plea - ·····iI$r;t~s


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··1··· l."PC 487(A) dF


n

:iGRAND THEFT; PROPERTY/ETC ;\06/18/2001 ;IGUILTY :lCONVICTED !


!; ~iOVER $400 ;i', '.. i

. _..."._:_...._m.__ .
2 apc
td . . __._"..i!" ... ",... .
IF
u ...._........._,.
lNONSUFFICIENT FUNDS: CHECKS105l1812001;GUILTY :jCONViCTEO,:'(

.__ .•-..... ! .._•... ,t.._......... ,!.~--'.-'I- . ,..1

:i
476A(A) ': ~I ~! .- ;!i~: ::1 '
... ~ __ ._._.,_... 'i j ~" :,~ r~": ~
~lpC 470(D)jF jFORGERY "_ _ m H05/1'812001-- .!OISMIWsED 1
.. ..-'"'-' ...
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~ .,
".-.' '
"'__ ~_""~'.""'\'\" ......"'"'M_'_" ., • ,""......." •• ,.~."."._.u"".."_"" "'''' '\,"'_""'~_'.__.~:_..... . .,."_,,,~~t.,~, ,;t... ~"'; '. _,__,. . ,f

,___
4,.lpC 472!Fl!FORGE OFFICIAL SEAL 105/1812001 ,I:
't
'lolsMISSED ',':
t r . ••

:-5'·' .... ~;PC 115(A)-';;F ··-io5/1·'8;2001·-·IGU'LTY··lc6Nvi~Eo1


q

;;OF·FERfETC'··FALSElFORGED •

i • 'hNSTRUMENT TO F I L E ! ,.; !
::1 .j :.i;l "1

6 .. ··;PC·487(A)·iF"·-·'-·-jGRANDTHEFr';-·PROPERTY/ETC -105/18/2001 iIGU,LTY ~lCONVICTED l

I -'lOVER $400
.J,
. :1.' 'i. . .

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r--_~;f
..
..........._....._.. ~ . . _.... _._ ._....... r
I :-~
':.;...;.;:;:==­
1

7 '!PC 476~F :lMAKING, POSSESSING, UTTERING!05/18/2001 'r"~ i!DISMISSED

'1 :!!FICTIOUS INSTRS ' j l ,

.~ ", ........~_""" _.. ._~,~L. ~",., .~ :: '

:~_]~C470(D)(:iFO~_~~RY-- --- - __}5IimooiJ _~iS~EDj

•9 ~lPC 472 IF 'lFORGE OFF-icIAL SEAL '!05/1812001jGU ILTV :lCONVICTED ;


.~ .: ~ .: ' : ~ ; ~ ;
~ it .. .:.1. ~.,. . ...."..... _m·~ ••·_". _" _ • .., _ _ .1_" .! .. ·~-:t· -,.. .". .. ,,!

09/17/202908:10 #0493 P.049/080


Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110242721
Document 136 Page:
Filed 07/29/10
49 DatePage
Filed:
4908/06/2010
of 51

~1:'-'PC--=11=·5·(=A}=·;;~:F""'"-'---r.:::!O-;;:-PF=E=R:-:::/ET=C-=F:-:-AL:"":S:'::"E~;F:-::'O-=R7G=ED~'---""'"!:;-:-!05::-:/1-:-81-;-2-'-OO-'-1-=7'; '-'-clDISMISSED r
; ' I
'~ •
ilNSTRUMENT TO FILE
t!
,! , ! .i, I
'~ .; ::,~, .
~ :1 ,::~ ,.. :i_..
11"---·fpC ·487(A} j!F ,. ', . . "-·(GRAN·DTHEFT: PROPERTY/ETC'''''',. ~:,'05l;8J2001 ' ','",!;;<iuiLTY 'i!.;:::"C"::O---N---V~ICT~E:::':'D:.::::j!.,:,

12
J.. . . . . _ _. ,!!OVE~~~~_
lpC 487{Ar"F1GRAND THEFT: PROPERTYIETC
.:L . . . . .,'. . .
';r-:-'_ - - - - ' . - ' - ' - , { . , . .

. i,:.05/18/20011GUILTYiCONVicTED t

i ! :iOVER $400 .'.,'1 I,'


i
;1.,' "i .I '.t :1
.L~ __.___ :~ ; :
"t
"1

13 ,l""p"-'C"-'--';';;;;"IF '-".·jOSi1EV2001 '1


·.;-=!G:-::R=-=A;;;;;;:N=D:':::T':::'"H'=E=FT==··~="='·"="·'·=·-'='-'=--=·-·=".,'=,....:.:.;;.,,"-. '
-~iDisMISSED "~
:\487(0)(1)
,
'I';AUTOMOBILElANIMALlETC!i
~.. j - ,
~
,,,: i,", ,,\!,,, '"'" .",,' "_,,..........,:~..___""
'><,' ,."_,, _ _ .'._ ......... _.._.."_'._... ~'~_."~'" ....".,.""_,.. ""~,~,.". . _..,..~, . :L . ,_~.:'......,.. __ ~.",_,~ IL... .... _,"",';'
~;!PC 487(A)'F 'lGRAND THEFT: PROPERTY/ETC!05l18/2001 '! :~D[SMISSEO 1
';j 'i'IOVER $400 .1 'I ;
_~. ~.....,. ., .:. !_,_._. . . . . ."._,. .,. . . . 1
tH'" ._ _..................._'",,,... ,. . .~.~, *~_ ,,_ .. """'."_"....._..._..."_.,,..~_'.~,,."" ,,,',,,,, j t__.. . _ .~ _,,_. _". .~

151PC ;[F :!GRANDTHEFT:.l05/18/2001;!DISMISSED!

487

:1 (0)(1)1 ;iAUTOMOBIL~~I~~~~~_ ____ J_~_. :1'

'16 '" JpC-487(A) ;!F'" ·· .... ·-·;j'G·RAND THEFT: PROPERTY/ETC ;:05/1812001 , .. ·_-'I"D,SM,SSED....-l

;
!
'.,1 •::.OVER
. $400 :i,
I

't i,

.._._. . . . . . . . :.:... . . . _ ,_u~,t. .,.....~....... ~~ ._._ . _.~"._ . ~~, . . __ ._~_" . ,. ""_.. . . , ._. . , ~.,_ ... ,. '~i. !.... ;i j
.17 ,iPC .IF '!GRAND THEFT: '105/'812001 .--- "i!OISMiSSED -1
_.. _
: 18
j~~~D)(1}
;lpC 487(A):F
L.. _.__t~~~~~.BI_L~ANIMAUETCI I l, . _ .".1
PROPERTY/ETC---"~"j.!:05/18/2001iGUrLTY'lCONVICTED I
i1GRAND THEFT:
.. p ...

11 _lOVER $ 4 0 0 1 '! '


":;-g"---';1-PC-487(A} ·.rF---~lIGRANO THEFT': PROPERTYtETC ,~
- . 05118t2001lGUILTY-"!ooNVfu'rEO:,h
:1.'. '.,;,' ·loVER $ 4 0 0 \ d . '1,': ('"
; ~.'
~ -.. ~. ~ ,_...."'._..._.. _ ... 1,. . ~ j , . "'~_'"~_....,••,....~_ ~''"'''''~~,_.. ~. _._.,~. ""' .~_,~__.,~... ""~ .. ~, ..~ ~_""".
I
._. -;;;;;-...~.;,: =..=_~=_=-~."'" 'r;"""---":;';;;;'
i---....;.,;.,;,.-.;,'
.
L;;;;;..
__ _._;;;L."-::::;.:';;"';',,=:;J

20 i~PC 115(A) ,iF :lOFFERlETC FALSElFORGED\05/18/20Q1iGUILTY icoNvietED 1


; i
: i j
;jINSTRUMENT TO F l L E i
,
;1;,1,'
..
-0 1,:

'f ,: ';i '


.21 :-!P-C-4-'70..:;.;(;";'06=}TF----·"..·.. ;iFORGERY u - · _ - _ ....,·_..-···· .. ;'05/1·8/2001
:~ '-jDiSMIWD !'" ."
'-10,' ,

·it. 1 .i,l; en,


'22''''''"lPC470(D)!F . · . 'iFO·RGERy..··-'·,,- ' ' ' [ 0 5 / 1 al2001'-;" :!DISMISSED "'1
_','
_ _ "."_'
_ "','.'.,,' '." ...
_ ,"'.,,'..' ...... ,',J, ~.'
.' ~''''' :
l.." 1 ' ; ~ ".......
,... , '.___ i!.t __.. _....ji

.IF !
....._'...."."__ ,,..,,'" • ""'n""" 'n'" ........ .._.,_ _.._ ... _ ;,

23 "~PC472 :j"'F--O";;;R;';;';';GO;;:E:=O;;;;;'F;;;;;;'F=IC;;:':IA=L=S=EA=L=====!05/18/2001 ! ;!DlSMISSED


".' .. ~~.-.-- ,,,._"'-'""""'",' .'." ,.~,.~, ."'-,-- "-­

Case FWV028000Defendant 1608112 LlBERI, LISA RENEE - Probation

10

09/17/2029 0810 #0493 P.050/080


Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110242721
Document 136 Page:
Filed 07/29/10
50 DatePage
Filed:
5008/06/2010
of 51

Probation Type: FORMAL Granted: 03/21/2008 Expire: 03/21/2011

SUPERVISED PROBATION GRANTED FOR A PERIOD OF 36 MONTHS ON FOLLOWING TERMS


AND CONDITIONS;

') SERVE 26 DAYS IN A SAN BERNARDINO COUNTY JAIL FACILITY, WITH CREDIT FOR
TIME SERVED, A MATTER OF 26 DAYS, PLUS CONDUCT CREDIT PURSUANT TO 1­
PC4019 ND ABIDE BY ALL RULES AND REGLILATIONS OF THE I=ACILITY WITHOUT TH~
POSSIBILITY OF COUNTY PAROLE.

2) VIOLATE NO LAW.

3) REPORT TO THE PROB OFFICER IN PERSON IMMEDIATELY 0- ND THEREAFTER


ONCE EVERY FOURTEEN (14) DAYS OR AS DIRECTED. REPORT TO THE PROB
OFFICER IN PERSON IMMEDIATELY 0- ND THEREAFTER ONCE EVERY FOURTEEN
(14) DAYS OR AS DIRECTED.

4) COOPERATE WITH THE PROBATION OFFICER IN A PLAN OF REHABILITATION AND


FOLLOW ALL REASONABLE. DIRECTIVES OF THE PROBATION OFFICER.

5) SEEK AND MAINTAIN GAINFUL EMPLOYMENT, OR ADEND SCHOOL, AND KEEP THE
PROBATION OFFICER INFORMED OF STATUS OF EMPLOYMENT, OR SCHOOL

6) KEEP THE PROBATION OFFICER INFORMED OF PLACE OF RESIDENCE AND


COHABITANTS AND GIVE WRITTEN NOTICE TO THE PROBATION OFFICER TWENTY-_,
FOUR (24) HOURS PRIOR TO ANY CHANGES. PRIOR TO ANY MOVE PROVIDE ':: ,':, t;.,
WRITTEN AUTHORIZATION TO THE POST OFFICE TO FORWARD MAIL TO THE NEw
ADDRESS. PERMIT VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGfE..~TS
OF THE PROBATION DEPT. ANDIOR LAW ENFORCEMENT FOR THE PURPOSE OF -r-)
ENSURING COMPLIANCE WITH PERMIT VISITS AND SEARCHES OF PLACES OP-~
RESIDENCE BY AGENTS OF THE PROBATION DEPT. ANDIOR LAW ENFORCEM~
FOR THE PURPOSE OF ENSURING COMPLIANCE WITH PERMIT VISITS AND
O
c..'
SEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THE PROBATION DEPT. '
ANDIOR LAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCE WITH
THE TERMS AND CONDITIONS OF PROBATION; NOT DO ANYTHING TO INTERFERE
WITH THIS REQUIREMENT, OR DETER OFFICERS FROM FULFILLING THIS
REQUIREMENT, SUCH AS THE TERMS AND CONDITIONS OF PROBATION; NOT DO
ANYTHING TO INTERFERE WITH THIS REQUIREMENT, OR DETER OFFICERS FROM
FULFILLING THIS REQUIREMENT, SUCH AS ERECTING ANY LOCKED FENCES/GATES
THAT WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE ANY ANIMALS ON
THE PREMISES THAT WOULD REASONABLY DETER, ERECTING ANY LOCKED
FENCES/GATES THAT WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE
ANY ANIMALS ON THE PREMISES THAT WOULD REASONABLY DETER, THREAT
THREATEN THE SAFETY OF, OR INTERFERE WITH, OFFICERS ENFORCING THIS
TERM. EN THE SAFETY OF, OR INTERFER~ WITH. OFFICERS ENFORCING THIS TERM.

11
09/17/2029 06:10 #0493 P,051/0BO
Case:Case
10-3000
2:09-cv-01898-ER
Document: 003110242721
Document 136 Page:
Filed 07/29/10
51 DatePage
Filed:
5108/06/2010
of 51

7) NEITHER POSSESS NOR HAVE UNDER YOUR CONTROL ANY DANGEROUS OR


DEADLY WEAPONS OR EXPLOSIVE DEVICES OR MATERIALS TO MAKE EXPLOSIVE
DEVICES.

8) SUBMIT TO A SEARCH AND SEIZURE OF YOUR PERSON, RESIDENCE ANDIOR


PROPERTY UNDER YOUR CONTROL AT ANY TIME OF THE DAY OR NIGHT BY ANY
LAW·ENFORCEMENT OFFICER, WITH OR WITHOUT A SEARCH WARRANT, AND WITH
OR WITHOUT CAUSE (PEOPLE -V- BRAVO).

9) NEITHER USE NOR POSSESS ANY CONTROLLED SUBSTANCE WITHOUT MEDICAL


PRESCRIPTION. A PHYSICIANS'S WRITIEN NOTICE IS TO BE GIVEN TO THE
PROBATION OFFICER.

10) SUBMIT TO A CONTROLLED SUBSTANCE TEST AT DIRECTION OF PROBATION


OFFICER. EACH TEST IS SUBJECT TO AN $11.00 FEE, TO BE COLLECTED BY
CENTRAL COLLECTIONS

11 ) NOT POSSESS ANY TYPE OF DRUG PARAPHERNALIA, AS DEFINED IN H&S11364.5(D)

12) PARTICIPATE IN A COUNSELING PROGRAM AS DIRECTED BY THE PROBATION

OFFICER, SUBMIT MONTHLY PROOF OF ATTENDANCE ANDIOR SUCCESSFUL :-:::.:,

COMPLETION TO THE PROBATION OFFICER AS DIRECTED AND BE RESPONSIBl~

FOR PAYMENT OF ALL PROGRAM FEE(S). .

.~ ... ..:
13) NOT ASSOCIATE WITH KNOWN CONVICTED FELONS OR ANYONE ACTIVELY

ENGAGED IN CRIMINAL ACTIVITY B.QR CODEFENDANT(S) OR VICTIM(S).

14) NOT ASSOCIATE WITH KNOWN ILLEGAL USERS OR SELLERS OF CONTROLLED v,,\'

SUBSTANCES, 0"

15) NOT MAINTAIN A CHECKING ACCOUNT OR COMPLETI; OR ENDORSE ANY CHECKS

UNLESS MADE PAYABLE TO YOU AND NOT HAVE ANY BLANK CHECKS IN YOUR

POSSESSION WITHOUT PERMIsSION OF THE PROBATION OFFICER.

16) SUBMiT A RECORD OF INCOME AND EXPENDITURES TO THE PROBATION OFFICER

QUARTERLY.

17) NEITHER POSSESS NOR USE ANY CREDIT CARD WITHOUT PERMISSION OF THE

PROBATION OFFICER.

18) NOT DRIVE OR POSSESS KEYS OR DOCUMENTATION TO ANY MOTOR VEHICLE

UNLESS LEGALLY REGISTERED TO YOU OR AN IMMEDIATE FAMILY MEMaER,

EXCEPT IN THE COURSE OF EMPLOYMENT.

19) REPORT ALL MOTOR VEHICLES REGISTERED TO YOU TO THE PROBATION OFFICER

WITHIN SEVEN (7) DAYS OF ACQUISITION.

12
OS:Case
09/17/2029 Case: 2:09-cv-01898-ER
1010-3000 Document: Document 136-1 Page:
003110242722 Filed 107/29/10 Page 08/06/2010
Date Filed: 1 of 48 P.052/080
#0493

20) SUBMIT TO AND COOPERATE IN A FIELD INTERROGATION BY ANY PEACE OFFICER·


AT ANY TIME OF THE DAY OR NIGHT.

21) CAARY AT ALL TIMES A VALID DRIVERS LICENSE OR DEPARTMENT OF MOTOR


VEHICLES IDENTIFICATION CARD AND DISPLAY SUCH IDENTIFICATION UPON
REQUEST BY ANY PURPOSE WITHOUT FIRST NOTIFYING THE PO. CONTAINING
YOUR TRUE NAME AGE AND CURRENT ADDRESS

22) ENROLL IN THE DRUG TREATMENT PROGRAM AT THE DIRECTION OF THE


PROBATION OFFICER, AND SHOW PROOF OF ENROLLMENT TO THE PROBATION
OFFICER WITHIN SevEN (7) DAYS.

23) MAKE RESTITUTION TO THE VICTlM(S) (SEE PROBATION REPORT) IN THE AMOUNT
OF $9223.77 PLUS A 10"'/0 ADMINISTRATIVE FEE, TO BE PAID THROUGH CENTRAL
COLLECTIONS

24) MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORT) IN THE AM OUNT OF
$35000.00 PLUS A 10% ADMINISTRATIVE FEE, TOBEPAID THROUGH CENTRAL
COLLECTIONS

25) MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORT) IN THE AMO UNTOF
$06951.08 PLUS A 10% ADMINISTRATIVE FEE, TO BE PAID THROUGH CENTRAL
COLLECTIONS

26) PAY A RESTITUTION FINE IN THE AMOUNT OF $200.00, PLUS A TEN PERCENT (10%)
ADMINISTRATIVE FEE THROUGH CENTRAL COLLECTIONS. ~.

27) THE DEFENDANT IS NOT TO FILE ANY LAWSUITIlEGAL ACTION WITHOUT PRIQ,R
CONTACT WITH PROBATION OFFICER.

28) DO NOT APPLY FOR CREDIT OR A LOAN WITHOUT PRIOR CONTACT WITH
PROBATION OFFICER.
-..
../

29) COMPLY WITH ANY COURT-ORDERED PAYMENT SCHEDULE.

30) MAKE RESTITUTION TO VICTIM (SEE PROBATION REPORT) IN AN AMOUNT TO BE


DETERMINED BY PROBATION.

31) MAKE RESTITUTION TO VICTIM (SEE PROBATION REPORT) IN AN AMOUNT TO BE


DETERMINED BY PROBATION.

32) PROBATION MAY BE SERVED THROUGH INTER STATE COMPACT AGREEMENT IN


THE STATE OF NEW MEXICO UPON APPROVAL FROM PROBATION.

Case FWV028000 - Defendants


Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110242722
Document 136-1 Page:
Filed 207/29/10
Date Filed:
Page 08/06/2010
2 of 48
#0493 P.053/0tjlJ
09/17/2029 OS 11

=
. . =

...
--:r-- ;~
,
.....=
......._•._.;=::._.=
IDR Number!
.....,;.;;.
.. '---- ,---~.=.-.""'". . ....
,i
:.;;:='".... =.-. ~----=:="------'

;1

'~5;18/2001
!
m •• _'o<_..-:.t-.._•... ~""._ .. ". . •.•'"",~".
.,."'~" "'"~- •• ~""~-" ... ,.~,-~- .. ~! "'"

T!LlBERI , LISA R ',lRA"""""'-"""";'05/18J20O,'lpc'1'1S(Al


,j .

.! ':
..............1...

1110013759.1.... __ .1:
..-~--= ~;
jALlAS; L1BER!. LISA R
.,
.. "~-~:!-.-,-''''' .....

~ALlAS; COURVILLERICHARDSON, LISA

.!
:;:
~~ , ... ~ .... ,.,..-.......... -". -," ... -.---~."".-,-...,.... ~.~,, .. ---"".-...." ........­
. ~jALIAS; UBERI, LISA A
:i
I ......._................. . _~~. _ _ --"==_

'iALlAS:
., RICHARDSON, LISA C

.
'!ALlAS: COURVILLERICH, LISA
... .,·L......... ............"........ .__ ......... .

jALlAS: UBERI, LISA RENEE


f

'IAlIAS: LIBERt, LISA


';ALlAS~ RICHARDSON, LISA RENEE
i
;.~ ... ".. ~ ..,.." _•..•...• "

Case FWV028000 Defendant 1608112 LlBERI, LISA RENEE· Status -:"j

Custody N1A -'


..
Filing Type Held to Answer Filing Date 05109/2003

Ordered Bail $0.00 Posted Bail $0,00

D.A. James R. Secord Defense Dean Pitel (Court Appointed)

NB~Action; Deputy Report #: RA-RC 110013759

l
.1
W<_~'" I"'" "'.,,·.t'~_"~F'" ~, ...".'".

14

09/17/2029 Case:
08:Case
1110-3000
2:09-cv-01898-ER
Document: 003110242722
Document 136-1 Page:
Filed 307/29/10
Date Filed:
Page 08/06/2010
3 of 48 P.054/080
#0493

,pr~~~~:rypeji·;F"~:'-::ra-n-t-ed-:---=-""'. , _:'; ;.IC-~':-~-;'.~-t-io-n-~="


" ..

:- ~-----i

" ...".. '"_....__.. I~Onnal,,_ ..._..'' ' .!1~11lO~ . . . . ,.!1~~~~~1 !


""'i
SentencelConvicted Date ;jCounty Jail :lcTS i
i ~ : ~ ; ~ f
~~~~~-·=····-~ ____.:..-.:..··~·····~···-·~·-~-··~'~1

l0112512008126 Days ;126 Days

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'·-,,!.i.8t~te Prison !Max Sentence !:1~---'


,I ~
"
~: t

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t
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, .
'\ ';

Case FWV028000 Oefendant·1608112 UBERI, LISA RENEE - Charges

.Arrest Charges

·c~~~;ich~"/g~··-··-F!s=·~=·;;;;.;e~=ity"-;:lr:D:-esc~·c.:;-·-;;;::$;;::t=j~"".'~"".".= . '. : :':'. : ;';.'='-'-""'-"'----'--·;;.::·-=-Tw~/~ti~~·


! i ! '!Date
: __.____ ..__"t __ ~"._._ .. _ . ~, ;~.._,_."......",.~.~.""....,: L~,~,. ,. .. "_,..____ , , .'"."._~~,~~. _,~ "__,,_.". .__., .__ ""..__.~_, . ~~~~_, _.. .: :~
•••• ­ •• ~"...:." . ., , - , . «,

filed .Charges

.....j
i
i
:1
--------------------, .,.
'IPC 487{A) t.1GRAND THEFr: PROPERTY/ETC .105/18/2001 .!.
------rl--------~
:;.I.HTA .t.:

;1; JOVER $400 'l­


, .......,/,.. _._ ...... __... _..._It_._.._........ 2'-::-:-,,":-.'.;:: ;.:,.'~":,,:,,,.:.:....-,-.:..:.;.;:";;';';';'""'.... .....;;::.: ·-:il_........~

. _.. ,. . l~~~1.~/~OO1 .L... . . _..


.._;;::-...;::
..;::.• :::;--;::-' ....""=:_.•:L;:.::==_=.=
..._::==..::=_.;;;:;...;;.:.. ...:::-::
....,-..

"'....- ......

'-2--;IPC 470(D)IF .. JHT :t~~~~~Y ~.,_ ... '..... -i


S-----:fPC--472" '!~F----'-:FORGE OFFICIAL SEAL1oS/1812001 : j 1HTA I
..

15

Case
09/17/2029 Case:
OS:11 2:09-cv-01898-ER
10-3000 Document 136-1 Page:
Document: 003110242722 Filed 407/29/10 Page 08/06/2010
Date Filed: 4 of 48 P.055/080

#0493

l4--:lPC , '-S(A) ;Ii-"'F~~''''-:''IF6='F=FE=-'RIET='­


''-'''''~C-FALSE7FORGED-'''-
" ; JINSTRUMENl TO FILE

;f :q ! :

·5·':P';P=C='4a='-"=i(='A=)'-J~F="""=·""=-"'-'--·=.,.-:!G.....RA-N~D..;,;;·T=-H::::::E=..Fr:.:::;'.. '.:...:;·P~'R~·'O: .:.:·"P.;.: ·Ec:.:'"R" " TY'=·iET=C==·riO="5t='1,;,;"a~/2-o-01---'j


=-" ",' "--'''·'''',:-:H:;;;;:,.=A=-'::'':':::''-'':::;.J
:1 :1 -lOVER $400 "~j! '
;I . " ': .i . .~

,~I .....~ ........ _,,:t.. "'" d

iPC 470(D):r--iF'-'-"---=--=',I'FORG'ERY '105/1812001, --':!-HT-A-";'::==-"--lj


.: .~ :; ~L ~!, :i
'r!.-=-,---,--:,',..!--..-,'1"':!~'.,;;;-';;;;.-:;;::;-""=.""::::'.".:;;;;.. '~"..:.::::;;;==";: :;" " : :;'- ;:;';'"=' ' =' ' ' ' ' ' ' =' ':': ' ' ' ; :;' '=' -=' ' ' F~' ; ; ';' ' ' ' ' ''''='.''-=-'''''='-''--,----~
' .. ;:::;:"" ." ',',,, ....--. '
'7 ;!PC 472 '!F1FORGE OFFICIAL SEAL j05/1812oo1 ! ! H T A

8 ;PC 115(A;iF--'fo~FERiETC FALSEiFoRGED . ··,','05118/2001',',,;,1....-...--.-" "",",i,',.HTi· ""~'1


':1 ".,' .j".._.. JI.~.~~~~~~~N~.,~~.~:,~~. _ . ."._. . . ,. ""L.. __j _J
.9 !PC 487(A) ':!F!GRAND THEFT: PROPERTY/ETC ;!05/1812001 'j
; [F'HT='--A=""';;";'''--=:::::::;

; : ! I O V E R $400 '!:1
H i:i .~~_. _."' . ". ." . . ",~,~"_" . ~ ~;-j__---'-==.::.;'
'lPC 487(A)~~IF----TGRAND THEFT: PROPERTY/ETC·'i05l1·8i2001·'·liHTA
" M•• ' " ' . , .. . . . . , , . , . .. " . .

! 10 '!
~!! 'IOVER $400 1'.1
~. ______.:L__ ...._._._..._,L...... _.)L ,.._. _____.__..... '·1
·11 jpc '!Fk~RAND THEFT: }:l5/i'S/200,'r" -'-':lHTA"''''-- ,
:1.487 (0)(1) ,! ~IAUTOMOBILE/ANIMALIETC l i 'I
",',., ........ __..)..._._ .......J........ ,.. ",, , " . ",.. ".,."."'."" .... _.;L.. . . . ""__._,_... L,.,,,.._....,.._.,_.'L . .-.- ";;,p..-...,,, .• ~.:

.12 ,jPc 487(A) ;!F -!GRAND THEFT: PROPERTvIETC :,1.-,05/1812001 '.,1,.; ',l,·HTA ,::.;, :"t:
') :l! '!oVER $400 . " Lt
i:

,! :~ j . j

13--!~;:;-ijF- --~~~~I:-~~~~~~-------~i05l1812001 .;l-:~A . ~::!


~I ) 1 i ". " ! .
.~ ..," ,.~" ...-:! ",~~ ..,..., d • • • •' .~ ... , , -.... ~L..... ,,." " - _:'; ~ ___ .._~. _... .do>.·L_......_,"_,_" ..__._...,__._,;,;_,,_ '. p, • •"" • • ,,.,.Jt . _··----.. 1
~ipc 487(A) '\F .!GRAND THEFT: PROPERTY/ETC[05/1812001!IHTA ;;~ ~

. ".. . j_.. ._._." . . . tl.._. _.J~~ER $400 ......_......_..... ____.....J"".. ," ." ___ . ._. :_ ..1_._.... 0 ' ,
'15 ;~pclF .!GRAND THEFT:!05/1812oo1i ;:HTA l
487
:1 (0)(1) <! ..... __ .tUTOMOBILEIANIMAlJETC 'j . 1., __.__. . J
:-'6'-"-:;PC 487{A)'iF :!GRANO THEFT; PROPERTY/ETC ,!05l1812001:jHTA­
· J ;, ;!OVER $ 4 0 0 , ; 1
___...____ L ... _.. _......._... 1...............J " ..". '_ .._".. . ...........__.._._ ...... .T . 'i .. _._~l_ .. ,._..__...
•17 :;,:.:,PC 487(A) ;,',I;F!GRAND THEFT: PROPERTY/ETC:06/1812001 .,1" ':lHTA
.; ;\ :jOVER $400 ': 1 ;!
•• , .' .;..... _.~ '_ •• _~n.~~.''' __ ' w,- 4•• ~ '"" _••_ .'_" 1, •• _ ". • ._ ....... ~" __ ,_~~,.._~.~". ,__ ,",_.,,~ __ ,,_, __ n •.••••..••: "_"4"""_"''''__ '''''_'~'" __''' .. J ,,,",.,,~ __, • .~

·Infor Charges
~"_,, .._ ·._...___" .... _ ........."·M'·' , . , " _ .," " •.-.'"'_,,_....._'" .._ ..... _",__,.,• . "",_,.~,

·Counfc!Charge qViolation .!Plea 'IStatus


, '!
, JDate 'j
:~ .""..___..._._.~.. , _..._..n_.~.~~.. ·f

16

09/17/2029 OS: Case


Case:11 10-3000
2:09-cv-01898-ER
Document: 003110242722
Document 136-1 Page:
Filed 507/29/10
Date Filed: 5 #0493
of 48 P.05S/080
Page 08/06/2010

·i ···-;fpc"487(A):iFiGRAND THEFT: PROPERTYIETC' :!05/18/20011GUILTY :;CONVlcTEI) I


.C!O $ ':j.~:i ~
,! ...~~~ ...~~~. ,.._........._.. . . '~

.,•...:.'" ',.1.

I ..__.3._.. . .j
~ ...···ire·"'---- :1r-F--'-;;';!NONSUFFICIENi FUNDS: CHECKS :1°5/1812001 ,!GUILTYi~C"';;;O"';;;N';":";'v=ic=T=--E-D":':';l
;;476A(A)ijl! '1 :1'

'1 ....,.J....•.__ ... .~ ......,......·.i...


-------'--'-'=,.='-'-'-- ~l~ ......-.. -... . .. .'1
j
IpC 470(0) -:jFORGERY :jF ;j05/18/2001' '; ',jDISMISSED I
..... ,.".. _~....",'~ ,. ___,:L,."._,. "_~_ ., .. ~". . ~L. "~"_'._'_~""" .• ~.,_~. _~.:;~ .. . . ,,_ -i,., .,."_,..,.,,' ...•~ ____., ..~!

'4 iiPC 472jFIFORGE OFFICIAL SEAL 105/18/2001 il!DISMISSED !


'-Ipc 11-S(A) ':F ---~;T~~~~~i:~RGEO··· ···:!Or;;8i2oo1iGuILr0icoNVKiTED i
....._..... iL,...... . . ! i ,j . , _.........,. . . . • . •_ .......__....... j . _......... I.. _.. ,. :1. ....".. ."..
6jPC 487(A)' ·fF .._· . ··· . . ,iGRANiJ THEFT: PROPERTY/ETC " I 8/ 001 'GUlLTY'CO '
:1 j 'lOVER $400 :!05 1 2 'i NVICTED 1 'j
,: ~

. . __.:l'SSEO--!

:- J ;: .j -1

7--:i.,p-C-4-76--;rl~r~~~~~i~~rNG~UmRrNG
.. !1::~1-r
-8-- !PC 470(0) :IF:!FORGERY''' ....... ,-",. ..,."... .....- ..... 1°5/1812001 :!DISMISSED

!____ •• __

-S-"jPC 472
._.;~ .. u, • • • , ••••

-r . . .".
_;L",,__,",. ~. . _~~; ."" __ .. ,.
·1.:~.~GE OFFICIAL'SEAL"'"-''''' .."..·.._.. ;[05/18/2001
';;
,tGLli'LTY·JI;;-C-":ON=V::;;;'-~C=-:;~!=,"E=·D::.:::i'L
'10""--fpc 115(A)IF 'IOFFERiErC FALSElFC>RGED ·[05/1812001;-..··_.. ·· ··.. jDISMI$$EO-''1'\I; ..
'.1 .\ ;iINSTRUMENT TO FILE ~! .1 '; r~, 1

';i ,." ..•,_"."__.. :~_ ", ......._.• "_,, •. ,0, ",,...:,,..., ..• -"••-.. -----,---.~L '. :.. .
H.- ,,".~~-,,. "-'-~ ~

;jF,...~!GRAND THEFT: PROPERTYIETC ~l05/18/2001 :fGUILTY .jCONVICT~D i


n ... "

: 11 .!pe 487(A)
,; .:1. lOVER $ 4 0 0 \ d',: - i
i ;1 j . i : -- ~
::, _.••_ .... _~ .. ":i,~.,,,'.,_,. '''':~" ____ ~,.,_,.._ ........:l....._.. ~,.,_~"...'' . _
u""'"_""-'_",,'L, ".. '''. ,... ,.------".~:!.,
,. . ....,...,;i,.".......• ,,' ~.-.-:u::.,.~
,., ........__ ••__ •_ _ _.. ¥ __

12!PC 487{A) 'iF :lGRAND THEFT: PROPERTY/ETC 'j05/18/2oo1 !GUILTY !jCONVIC leW 1

:i! 'iOVER $400 ij11 i

. .__.. ".~~L . ~. .
'13'jPC
_q..

t
'I·· ..... l.... . . . ,",....
;!GAAND THEFT:
-.. . ... . . , . _.. .'[,............. ,.".,... . ,_.L··..
;!05/1812001 ,!~
, i.. ,- . ·". lDISMISSED ~
c""-' i

'1487(D)(1 > lAUTOMOBILEIANI MALIETC j :;!


.~ 1_"""., l".. . . _" :~ -1 ~~ ~
'"14;jpc 487(A)jF 'jGRANDTH·E"FT: PROPERTYIETC 'jOfi/1"8i2oD1':-- '.'.',,!:.'D,SMissEri'l
,I :j ~10VER $ 4 0 0 1 ; ,
·15 "--"ljP-E'' ' '- IF '!;GRAND THEFT;"....·· . ·,,· ',.·i05/1812oo1'''I,,·.. ·...._·.. ·:blsMissED-1
.
;;487(D)(1) 'llAUTOMOBILEIANIMAUETC 'li.1 i

. , ,. . ", . . :~t ... . . ;~ ~_.


'w." •._ •.•__,_._,.".. ••. .; """d_ -.~" ~,•. . . . . . ~",,,,_,~,,,_u~·",,,,,,~ -.­ _..._,..._ .... _._.i,,_... :~~;.==:;;;·i~==-=~

: 16 HpC 487(A) ~IF,!GRANO THEFT: PROPERTYIETC l05/'812oo11 dDISMISSEO !


q',;,':OVER $ 4 0 0 : , ; \ :1
l .....-",... . ............ L ......_ . .,,_....1 ,
: 17 '!PC . . . _.JGRANDTHEFT: ~!F 105/18/2001 ;j---"jD-IS=M=IS=SED I

....... t~7~.D)(1) ....1,.".. _


. . . J~lJTOMOBILE/ANIMAU~~....... _.......... . L . : .. ,.. . L... .......... ,'_-'

17
09/17/2029 Case
Case:
OS:11 2:09-cv-01898-ER
10-3000
Document 136-1 Page:
Document: 003110242722 Filed 607/29/10 Page 08/06/2010
Date Filed: 6 #0493
of 48 P.0571080

~."-." .. ~-.'.~ .,.~., . ,' ~., """'....'..,, ..,,.... "--.0.-.- ..... ........... ___

18 :lpC 487(A} 'iF 'jGRAND THEFT: PROPERTY/ETC l05/18/2001 :lGUILTY :lCONVICTED i


':
":
! 1
,
~!OVER $400
.. ~ 'i l ! I
,. '._-'""-'~;"".'" ,.',.~~~-- .... '; ... _.. . .. iL ....._..... _ ......... , ....................._..........:!.. , ..............___ ..... J
19 :ipe 487(A}!F iGRAND
:.
THEFT: PROPERTYIETC :10511
:
B/2001!GUILTYicONVICTED
'f ':
1t
,I '~
,lOVER $ 4 0 0 1 H;i .
. . _.,,___ .,,~:.,,_."" ... " . .~' _ _ _-'-.;.;;:.
.... = -.. =.'~"_'_,,""r.,_"' ••• " , "~ ;t.,.. . . ,._. . :1 ;
,iPC 115(A} .ii=---lOFFERlETC FAlSElFORGED :r-!OS-'-1S-'2-00-1-;:lGUllTy-:rCONVICli"ol
~l ·l!INSTRUMENTTO F l l E l -l i 'I
21 "ipC 470(D)~IF"'-"" '--"~FORGERY'--' ."'-'--"''':,~":,o~=-''-'':105f18'2001. -L~,,,-.---='=+=D-='S-'-"M-'-'IS=S=ED~
;~ ::;

irc--~-4~.~~,,;;::~(~=~=~-'·:;;::r=-.:="-·=·"·""-"~0R·G~-ER-Y--....=....=......
... ==.. =.~. ="=·--=·"-=···="···="-""=- :iOM ~OO1 'l'-.­ . =.~···=~.~.=·:"l~~~.I.~SE~.....1
. 23 :iPC
,:
472 iF
;t
:,!;;;;;;F=O=R=G';"'E-O-F-F"':':IC;;;;:IA:::':L:::':S=E=A:;;;;:L===='i05l18/2001l 'IDISMISSED i
." ~._,. ~i _.. ,_~~,, __ ,."~ _~. " • .~
. j. . ...._ ~'_'_"I" ... , ... '''__'' ""~_.,. .. _ ..... ",,," " :1,w._,,_.,,", .__ ._. ,_.~'" ..."...:L ;i )

Case FWV028000 Defendant 1608112 UBERI, LISA RENEE - Probation

Probation Type: FORMAL Granted: 03121/2008 Expire: 03/21/2011

SUPERVISED PROBATION GRANTED FOR A PERIOD OF 36 MONTHS ON FOLLOWING TERMs-.:


AND CONDITIONS: GJ

1) SERVE 26 , DAYS

IN A SAN BERNARDINO COUNTY
,
JAil FACILITY, WITH CREDIT FOFC
TIME SERVED, A MATTER OF 26 DAYS, PLUS CONDUCT CREDIT PURSUANT TO , ..
_";;'i
PC4019 ND ABIDE BY ALL RULES AND REGULATIONS OF THE FACILITY WITHOUT ToWE
POSSIBILITY OF COUNTY PAROLE.

2) VIOLATE NO LAW.

3) REPORT TO THE PROB OFFICER IN PERSON IMMEDIATELY 0- ND THEREAFTER ONCE


EVERY FOURTEEN (14) DAYS OR AS DIRECTED. REPORT TO THE PROB OFFICER IN
PERSON IMMEDIATELY 0- NO THEREAFTER ONCE EVERY FOURTEEN (14) DAYS OR
AS DIRECTED.

4) COOPERATE WITH THE PROBATION OFFICER IN A PLAN OF REHABILITATION AND


FOLLOW ALL REASONABLE DIRECTIVES OF THE PROBATION OFFICER.

5) SEEK AND MAINTAIN GAINFUL EMPLOYMENT, OR ATTEND SCHOOL, AND KEEP THE
PROBATION OFFICER INFORMED OF STATUS OF EMPLOYMENT, OR SCHOOL

18
09/17/2029 Case:
Case
08:12 10-3000
2:09-cv-01898-ER
Document: 003110242722
Document 136-1 Page:
Filed 707/29/10
Date Filed: 7 #0493
of 48 P.058/080
Page 08/06/2010

6) KEEP THE PROBATION OFFICER INFORMED OF PLACE OF RESIDENCE AND


COHABITANTS AND GIVE WRITTEN NOTICE TO THE PROBATION OFFICER TWENTY­
FOUR (24) HOURS PRIOR TO ANY CHANGES. PRIOR TO ANY MOVE PROVIDE
WRITTEN AUTHORIZATION TO THE POST OFFICE TO FORWARD MAIL TO THE NEW
ADDRESS. PERMIT VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGENTS
OF THE PROBATION DEPT. ANDIOR LAW ENFORCEMENT FOR THE PURPOSE OF
ENSURING COMPLIANCE WITH PERMIT VISITS AND SEARCHES OF PLACES OF
RESIDENCE BY AGENTS OF THE PROBATION DEPT. ANDIOR LAW ENFORCEMENT
FOR THE PURPOSE OF ENSURING COMPLIANCE WITH PERMIT VISITS AND
SEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THE PROBATION DEPT.
ANDIOR LAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCE WITH
THE TERMS AND CONDITIONS OF PROBATION; NOT DO ANYTHING TO INTERFERE
WITH THIS REQUIREMENT, OR DETER OFFICERS FROM FULFILLING THIS
. REQUIREMENT, SUCH AS THE TERMS AND CONDITIONS OF PROBA"nON; NOT DO
ANYTHING TO INTERFERE WITH THIS REQUIREMENT, OR DETER OFFICERS FROM
FULFILLING THIS REQUIREMENT, SUCH AS ERECTING ANY LOCKED FENCES/GATES
THAT WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE ANY ANIMALS ON
THE PREMISES THAT WOULD REASONABLY DETER, ERECTING ANY LOCKED
FENCES/GATES THAT WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE
ANY ANIMALS ON THE PREMISES THAT WOULD REASONABLY DETER, THREAT
THREATEN THE SAFETY OF, OR INTERFERE WITH, OFFICERS ENFORCING THIS
TERM. EN THE SAFETY OF, OR INTERFERE WITH, OFFICERS ENFORCING THIs3;ERM;.l

7) NEITHER POSSESS NOR HAVE UNDER YOUR CONTROL ANY DANGEROUS OR· .;
DEADLY WEAPONS OR EXPLOSIVE DEVICES OR MATERIALS TO MAKE EXPLOSW
DEVICES.

8) SUBMIT TO A SEARCH AND SEIZURE OF YOUR PERSON, RESIDENCE AND/OR .:


PROPERTY UNDER YOUR CONTROL AT ANY TIME OF THE DAY OR NIGHT BY ANYv~'
LAW-ENFORCEMENT OFFICER, WITH OR WITHOUT A SEARCH WARRANT, AND wrm
OR WITHOUT CAUSE (PEOPLE ~V- BRAVO).

9) NEITHER USE NOR POSSESS ANY CONTROLLED SUSSTANCE WITHOUT MEDICAL


PRESCRIPTION. A PHYSICIANS'S WRITTEN NOTICE IS TO BE GIVEN TO THE
PROBATION OFFICER.

10) SUBMIT TO A CONTROLLED SUBSTANCE TeST AT DIRECTION OF PROBATION


OFFICER. EACH TEST IS SUBJECT TO AN $11.00 FEE, TO BE COLLECTED BY
CENTRAL COLLECTIONS·

11) NOT POSSESS ANY TYPE OF DRUG PARAPHERNALIA, AS DEFINED IN H&S11364.5{D)

12) PAR1"ICIPATE IN A COUNSELING PROGRAM AS DIRECTED BY THE PROBATION


OFFICER, SUBMIT MONTHLY PROOF OF ATTENDANCE ANDIOR SUCCESSFUL
COMPLETION TO THE PROBATION OFFICER AS DIRECTED AND BE RESPONSIBLE
FOR PAYMENT OF ALL PROGRAM FEE{S).

19

09/17/2029 06:12
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110242722
Document 136-1 Page:
Filed 807/29/10
Date Filed: 8#0493
of 48 P.059/080
Page 08/06/2010
OllamaCrimes.oom Page 1 of6

ObamaCrimes.com
by the La~~' Offic~s of Philip J. Ik.r.g I http://philjbcrg.com

[.~ _ _ _ _---JI~
OWma I;rime& Is UMllab!!It _ "" tho;! _ of
..... l. IIeIlI COIIOI!IftIftlI!:IIe i!tifIibiIity of Pr\lsicIent IMt.
Soetaro/OIIama. For _ on Phil). IJ4!rII. 'IIsIt;
laW 0I5C:e5 of Philip J. IJag
1ItIJ>;/I~aJm
for 1il1rT1E!dIaU! Release! - OS/2l!I2010 555 ~ GlEn Court. SuIte 12
FoI furlller Infb~ CQo1tJct; ~'HilI, PA 1944+2531
Philip J. genJ, E!QUire (610) 825-3134
$5 Andorra GIe"1 COUIt s..wte 12 (800) 993-I'kJt tl44!iJ
lafayel:!e HUl PA 19444-ml !'ox(610) 8'34. 7659

~'-' :~~
Cell (610) 662-3005
(610) 815·3134 -­
(BOO) 9W-PHlI. [1445]
Fax (610) 834-"1659 ~ ~
....:. 'z-"-c7
,,: ­
~jbC:f9@(lill1lm'lCnmes.rom ~,--.:.~.~ .~;:~~~
THE 06AMA BIRTH CEIlIIFICATE I IUGtBILlTY 1 OSAMACARE
All doMdons IlD oIfset!:lle otr.II: of ~....- COIIClMJII'9 !:lie
MARCIl ON WASHlN6TON DATE
eligibility of B.& SOeI:i:Irv/CItoIIIIIiI lIn!~. Beco_ a
HAS BEEN QIANG.ED
""'PP'lI'W'" of WI" effurt IlD ftnd tile tnJtII
frOm MeIIWJriId D;sy WeekeAd

j~1
I ~:,:,,7.1 :-:~,
(L.afa¥ette HIlI. PA - O5/7IJI10) - Philip J. Berg, E!lqUire, me ftm AI!DmI!y WIlO filed suit ~ ~8d< H.
Oi)aMa ~\g Qb.l"",'s1llCk of ·QUallftcaUons" to serve as Presi:Ient ~ tIwl: Unit<id ~ stilted lI1at
t = -iii''';U''O /vi!la. _sterCard . DiSc;over
"'WE THE FEOPtE" by and through Phliip J. Berg and Obamao:rime"",..J;;Om is SIX)IlSOr1I1g lhe OIIAMA ~ wilt '"'-i<can also be maiied IlCI the _ _ _
INImt camfICATE / WGl8ILlTYJ 0IIAMACAlt1! MM;h on washfl1!jtOO. IIbo¥e ~.
DQAadons _ _ _ 1lD 1IeIp!luppO<t dti:s ~ J
Out< \"Q ~1)Ilng ~ and lhe ImIlO!tiiOO! or this Marcil, ~ ~ ~ the OBAMA IIlRTIi
CERTIfICATE! t:uGl6lI..lTY! OlWIACARf MiII'd'I on W~ing\Qo _ pa;tponed from MemorIal Day -~.)

VV~ to someUme III ~/5eptemf:ler 2010. "ThI::...,., d;Itt: WlU be anrlO!.llO!!d shortlv.

All i~rs llEIItioPil!ln!l are lE!Clues1I!CI tD bring II copy off:lM:ir Birth Cet'llftcate,
the CI'Udai Issues AlgardMlg OIliIma. the 'IMPOSTOR", (:QnOnuc to grow. 1iOWe'II!r. me most impOo1iInt - ---
iSSUe IS otsma !lOt being CMStlWtiOn/jily eligible to be President~ 1) not bei<'lg "nawra.f oom"being tx:rn ifimyspace..
!!I Mombasa, Kenya; and Z) eM!IllllO<"E! i~!he I'ect \hat OOOma was ~ or ~
tl)' hiS ~, UllO soeIt;Jro, lind his scI>oo1 ro:ord m I.ndcInesfa IndiCaII!s lI"o! "lmpo$\OI',· ~ Il$
'8any SoetDro" and his naIIOOaIJty IleIIIg "IrIi:IOneSia", otl;!ma,!he T"'f'Q5tJ:lI"s legal name is -Sany
SQeIDro". Obama must be sIJ:lIJIle<I! WE THE PEOPLE call, bv W<1Y of thc largest mElIdl eYe!" on
Wilsi1lngtDn, oC ~ a "Peaa!fuI ReVoiu!ion' and I'Ort:e 0bIl..... It> pre-. he IS Q:in~lIy eI!!JIbIe or
f'<!SI!lf1 from offlar. vES WE CAN !

TIle a:.st or the ~ OIl WasllitogtTJn ~ Il!l<~\/!(t. We must ral!ili! FIfty TlIOtlsand l$SO.ooo.oo) DollarS to
(.::M!r tl\e (1)$1: of tl\e ~ ;ndudiFllJ ~ !his III1POlt!nt event

DooaU! tDday tll help crtIfN \he e:<pI!!l5I<S at !!liS Ma,en ~ ~ our ConstitutIon.

An updatllQ nier ~ our MM.h ;';~. ~ stiiIY tuned tD obamaaImes.oom ror tile MW date. N.st; ~'=:
PhUfp IlErQ
FQr CIIIIIies of;aU I'n!s8 ~ and cau.t: Pleadings" go to: =;,,,d~;

.maat~ ptuUD<lI"90(Jl11~U,

com
~~~t"...:::!>:
Nonll

ConstlMlOn, IndOnesia., Media, News, OOStna'$ CiWetl!III'P. Pn:s& Rt-~ A.urnQrS, U~I>.@(j, vomr "1'IAAl Cn!iI!o: Your llddQO<

Ft'/~135(lJO"11f11e!ltS
Phil iler'!l is PI'Cud to ho: ~~ In Dr. Jawara King's 1a!e5t. boQk

NOIlI!

MiIlly ~ post:! hIt"'C i!p!1fSlI!lm;)1!! dales

• 1W'Pf!'l;ll.lRTH OF )lU!
• HAPP'!: FATtt:R'S DAY
09/17/202908:12
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110242722
Document 136-1 Page:
Filed 907/29/10
Date Filed:
Page 08/06/2010
9 110493
of 48 P.060/080
- ObaMaCrimes.oom Page 20f6

\MARCHONWASIDNG1oN
.• HIIR'I'
-~
Memorial Qaf
• May 31, ~:JQIn PhIIIpJ. a..g. eq. "" tI1e~

CJm1jdes SllOlIIWIIII !'aU Rtd1ard I'ra

.~on~

.. l'hlII*.yCOl ..... ~

"., """,~,~"~,,,,~_, __u,_,,_,,___ ~,_,~.,_,, __ ,_~,_,


~
__ _,"__

Thi$i$I'IOt\l'le~~~int • C!ses

.­.­
.~

OBAMA BIRTH CERllflC'A1'Il/liUGIelUTY f oeAMACAR:1!


.~

MARCH 01'1 WASliIMIiTON

Has ' - " pastpaned due ta SdIeduliIIg UlnftidS.

• ObaiIloil's 0ti1eiIsbic
New dati!! Ie be IIdiIOunCed ~.
.~
.. Pre!lS PI!IeaSeS
8ARAI;K 08ANA IS NOT !;UGIJlLIlIDSERVl!AS PRfSIDEJ'fT OFTHElJIItITI:I:I STATI1i$

• RQmOrl;
DUE TO THE FOLI.OWIMG: . ~

., "n1c Uni\l:d Stlm!. O:x..atution 1'OOildale!. I:llEo PNsiClent or tfie lkIitea stites must be a unl!ed SWtilS
• VoIJ!r RlIII<I
'nalllnll born" Cltizetl - Arti¢Ie IT, sectson I;

tar: --'~"'------~'-'~'-', ~

" Obama was born in ~, in ~ is. n(>w Kenya, AIiit'.a;

911forthetruth _00intI1iIaItY
• Obama i:I ~n ~ O~ as he wllS acJopblClIad<nOWIl!(Ige!l ~ tjs s!EpIiI!her, Lola ~, "" - . . - . . EIgiIiilr '*iYe boffl NaIIo'aI !IcI'/I NaIIo'aII!I>rn
InaooesIiID 0tImt; and ~Cbsna~

"!lM! ~ "'11 (Oba~) ligneCI itt!;) UlIN ~ Obama on Ma!tI\ 23, 20W IS UIIClIIIlSIibIII ObamaCrimesM1tn.! Pl*lpJ. Beog
and willable sinee ~ is in::IigibIe ~ ser;e 8$ ~ or fIW1lJtli!e<l stM. ~~~StIIIml,l5~
COO!adIon
For ~ ~ I'I\iIip J. !leIg, Esquire. Obamaalmes.com is 9POOSO!'iIlg IIle 'OBAMA IIRTIt
cmTIFICAlE I B.IGIBIUIY / OBAI'IACARIi" MardJ on washlngwnln w~, D.C. 'The MardI
wiD be: ~kj(! to !.ometime it1 AugUst I september 2010. .
,.
AlllndMduals partidpmi~ arc ~ to ,,"ng 8 W(ty or their 8irt/l Certifie8te.
~oc in

or
The oost I:llEo Mat!;!\ on WatihingIOO Is~. we must raise Rfty Tt100sand 00IIars ($50,000,00] to
Vl'llid XJo!frl.l

a:Ner tile mst t:t tile HaIth Indudin!i promoting tIi$ i~t event.

~'liblloClay to help a:Ner tile expenses of tl1Is March and dm!nd our ConstItuIioo.

DQIIATIONS to the. .............. NJ!!I)m ...... APPR!ClAlED.

-----
N~me:_ ...
c,,"
_J
Add~
City, S'Iltte{Zlp:
!!rna.;
rei like tIl help! _$20 _$~ _$100 _$loo _$250 _$1,000 $_ _~

for uPdamd inform;rtioo, ~ visit:

PhIlIp). ~, ~., ~s:; And"m! G:!fl Court Suite 12. I..1!fayet1& Hill, PA 19444·2531 (..lol S2~-3134

DQwnloast Flyer

~I(l(~, OboI....'s Ci\j:.ensl~J) Sly ~ l !l~

[:hil Berg~ Esq. on Time Out with Kevin ~~ilagher


I I'hilq:> .3. s."g. EsQ. was iIlteNiewed Wl ~ on II>c TIm(' out Show WI,*, -<:Yin Gollogher. This
II I/l1e'VieW WIll be aired In Danbury, cr Q!l Comal$t Ol<'Innc:l ],3, Fnoay 'I17317.()lQ at 8!30 P.M. EST ana on
~ following MoIxIiry. 'lI26/2010 at 11:00 A.M. EST.

I Ycu c;:In ..., the vicleO by clid:ing here:

htto:llobamacrimes.ooml 712112010
09/17/2029Case:
06:12
Case
10-3000
2:09-cv-01898-ER
Document: 003110242722
Document 136-1 Page:
Filed 10
07/29/10
Date Page
Filed:10
08/06/2010
of 48 P 061/080
#0493

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o ............_ ............b'fllCrllullunao~~ RSlZ-Z284!PC
r:xJ 1lIIbiIr... 1 , _ .... .,.....-~ .. ID!duIMt_....liilfl_. . ._ . . . t "'DB.BTOR:
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1UDGE: HON. P. Carroll - M5
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34tA. MTG:' C!JIlOl2OOl 11:00 USB
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08/17/2028Case:
08:12
Case
10-3000
2:09-cv-01898-ER
Document: 003110242722
Document 136-1 Page:
Filed 11
07/29/10
Date Page
Filed:11
08/06/2010
of 48 P.082/080
#0483

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10-3000 Document: Document 136-1 Page:
003110242722 Filed 14
07/29/10
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Filed:14 of 48 P.065/080
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08/06/2010

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Case 2:09-cv-01898-ER Document 136-1 Page:
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07/29/10
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09/17/2029 06 15 10-3000 Document: 003110242722 Page: 16 Date Filed: 08/06/2010

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:7

1 SUPERIOR COURT OF THE STATE OF CALIFORNIA.


2 FOR THE COUNTY OF SAN BERNARDINO
3 I?EPARTMENT 3 HON_ JOHN M. PACHECO, JUDGE

5 THE PEOPLE OF THE STATE )


OF CALIFORNIA, )
6 Plaintiff, )
)
7 v. ) SUPERIOR COURT
) CASE NO: FSB-044914
8 )
)
9 LISA LIBERl RICHARDSON, )

10 Defendant.
11
12

13 REPORTER'S TRANSCRIPT OF PRELIMINARY HEARING


AND BAIL/OR BEARING
14
AUGUST 4, 2004
15
OJ
16 APPBARANCES:
17 ,
FOR THE PBOPLE; MICHAEL RAMOS ~
18 District Attorne1!"
BY : JAMES SECORD OJ
19 Dep~ty District Attorney

20
FOR THE DEFENDANT: EDI M.D. FAAL
21 Attorney at Law

.22

.23

··24

REPORTED BY: COLLEEN SOUTHWICK


CSR-RPR NO. 9949
Case 2:09-cv-01898-ER Document 136-1 Filed 07/29/10 Page 21 of 48

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113

THE COURT: Withdraw that last question?


1
MR. FAAL: No, your Honor, at this point in
2
3 time I have no furt.her questions.
MR. SECORD: Nothing further, you~ Honor.

THE COURT; Thank you.

SECORD~
5

MR. For the recox.-d, yOUl:" Honor, I'm


6

7 tu:rning ove:r to defense. a copy of the jai1 tapes. They

8 are on CD. The copy is entitled Liberi, Lisa


9 04073420299. It bea.rS a d.ate of 7/29/04 but it has

~o jail conversations from the period of incax.-ceratio


11 through 7/28/04 for discovery purposes.
MR. FAAL: 'thank you.

12

THE COURt: Okay. Thank you. All

13

14
right. Anything further?

MR.- SECORD: On this issue I no, your lionor.

15
I would recall Investigator Liebrich to the stand for

16

our mot.ion to increase bail. . -r


17 ::::
MIKE. LEIBRICH, ..
........ j;

18

having previQuSlY been sworn as a witness. was recalled

19

20 on behalf of the People and testified further as

21 1:0110'IJ15:

MR. SECORD~ Thank you, your Honor.

22

24 DIRECT EXAMINA~ION

25 BY ~~. SECORD~

You realize you're still under oath?

26
Q.
A. That'S correct.

27
All right. In the course ot your
28
Q.
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1 inves.tigations I did you listen to conversations between


2 the defendant and her mother emanating cut .of the j.ail?
3 A. I listened to the majority of them, not all
4 of them.

5 Q. Okay. How many conversations in total were


6 there provided to you?

7 A. More than half a dozen.


8 Q. Let me rephrase it. On the disc that I just
9 gave Mr. Faal there's a significant number of

10 conversations; is that correct?

11 A. 63 in total.

12 Q. 63 in total. And of those do you have an


13 estimate as to how many you1va listened to~

14 A. Roughly 40, 45.


15 Q. And of those you've listened to are

16 conversations between the defendant and her mother?

17 A. That I S correct..

18 Q. okay. With respect to those conversations


19 between the defendant and her ffiQt.her ,has the defendant
20 indicated a desire to seek retribution against a family
21 member"P
22 A. Yes.

23 Q. Who is sbe seeking retribution against?

24 A. Her sister Cheryl.

25 Q. In the reports that were prepared with


26 respect to the case in which you testified at the
27 preliminary hearing earlier todaY1 was there a report
28 by an Officer Schreiber, Investigator Schreiber
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115

1 concerning an interview he had with Cheryl Richardson?

2 A. Yes, that report had to do with the previous


J:

3 19 charg.es r not the ones t.hat were di scussed today.

4 Q. All right. And was there an indication in

5 those conversations between the defendant and her

<5 mother an understanding by the defendant that she had

7 obtained, that the defendant had obtained a copy of

8 that police report?

9 It. Yes.

10 Q_ what did the de::endant indicate she wanted to

11 do with regard to her sister?

12 A. Actually as tar as harm, she discussed that

13 with her husband Brent. AS far as with her mother, she

1.4 was angry at her and was basically done with her

15 sister.

16 Q. And with respect to Brent, did she

17 indicate -- did she make threats about her sister? -0

18 A. Yes.
19 Q. What did she say?
A. First thi.ng was that she believed that her
20
21 sister had an outstanding warrant in the State of
Arizona. She was going to somehow get her arrested and
22
23
then spread throughout the jail system that she was
quote unquote 11a ratll and she. told her husband Brent,
24
25 uYou know what they do to rats in jail?"

26
Q. Investigator Leibrich{ you weX'e with the L.A.

27 county Sheriff's Department for a number of years,

:as correct?
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:2 Q. Did you evel:;' work the j,ai I?

3 A Oh , yes.

4: Q. And what happens when inmates discover that


5 another inmate is a snitch?
6 A. There is what is known as a oontract t a green
7 light on them. Different things; they are attacked
B and/or killed. In facti you brought up L.A. County,
9 in the last year five have been killed within the jail
10 system.

, 11 Q,; Did you also listen to any conversations


,.
.12 where the defendant indicated that she wanted to leave
13 the State of New Mexico?
... , 14 A. Yes.

15 Q. Okay. Did she -- were there conversations


.. ­
;
16 would you please describe what those conversations
17 consisted of?
18 A. She was speaking to her husband Brent who was
19 based out of New Mexico. She said she was quote
20 unquote "donel!, thatwheIl the lease was up at the end
21 of the month of August, that she wanted to leave. She

:;:, 22 was not going to tell anybody where she was going to
,~ ,
23 go.
'.:. 24 Q. Okay. Did she also indicate anything to her
25 husband about finding a new job?
26 A. She inquired of her husband that even though
",< 21 he liked his job , she ask~dhimt "You can find a
r
(" 28 trans.fe.r, can't you? We should leave. Letts go to
~-,

,.;,
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117
1 Georgia, Florida anywhere. 11

2
MR. SECORD: Nothing further.

3
THE COURT: Mr. Faal_

5 CROSS-EXAMINATION

6 BY MR. FAAL:

7 Q. Did Ms. Liberi say that she wanted to abscond

8 when ahe gets out on bail?

A. She did. not use the word abscond"

10 Q. She was talking a.bout relocating from the


11 State of New Mexico to the State of Georgia or the

12 State of Plorida, right?

13 A. She said that once again she was going to

14 leave and nat tell anyone where she was. going to go.

15 Q. Did she say that, based on your testimony;


-.
16 she already knew that her sister had given statements

17 to the police that implicated her in this case,

18 correct?
19 A. !n the prior 19 charges, yes.

20 Q. Yes?

21 Yes.

22 Q. Okay. Did she make it clear as to whether

23 she was referring to not telling family members or


24 whether she Wi:l.S talking about not telling the Court or

25 the bail bonds as to ~hare she was?


26 A. What she said was she's not going to tell

27 anyone. Not anyone.


28 Q. But that conversation came up in the conte.xt
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07/27/2010 13:18 8055205804 SANKEV 10428 P.OO2/005

IN THE ujNITED 8TATES DIS1RlCT COURT FOR THE EASTERN DISTRICT OF,
'I i
PENNSYLV AN1.A
!
!
LISA LIBERl, ~t al.• ) CIVIL ACTION
) NO. ()9 - 18989
)
)
v. ) DECLARATION BYNEIL SAN'KEY,
) PRIVATE INVESTIGATOR
ORLY TAl14let at. )
i
! )
~rendants. )
)
)
)

I, Neil ~eY7
I do hereby declare as follows: ,_

I. • am a Private Investigator~ California State Ucense number PI 10905. I abi


the
: ' N
! , w
Pmident of ¥ey Investigations, Inc. I have been so licensed fur twenty five years. I QW OVet'
I ::~

18 years old, ~ not suffer from any mental disease or impainnent and I have personal ~."
. ~, '

knowledge ofail! the facts set wIth in this Declaration, and ifcalled to testifY thereto, 1 CO~l and
i
wonld do so ~tly and truthfully.
!

2. In ~ay of20091 met with and interviewed John Mark Allen who informed me that
1
he had been the/ boyfriend ofLisa Liberi. also known as Lisa Richmdson, and that be was the
i
futher of their
,
sOD.
!

3. John!gave roo a photo-ropy ofa pbotograph which be told ~ was an accurate and
i

true reproducti~ ofa photograph ofLisa Libeti and her husband Brent. A copy of that
i
pb.otogmph is ~ and signed by me.
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!
·

4. llatejr showed that photograph to Sergeant Panl Morrison, a Rancho Cucamonga ,


!
Polkie Detecti~ who had been the Investigating Officer of a multiple Fmud case involving Lisa
i
Li~ a.k.a I4a Richardson, and he positively identified the lady in the photograph as being
1
I
Lisa Liberi~ su~uently convicted of the Offences. He oonfumed to me that, in acoordancc
!
i .
with the Court' ~ instmctions~ after conviction,. Liberi was allowed to IeSide in California or l'Iew
l
Mexico, where jshe has reiati\'eSt but not any other state until the end ofher probation in Mmich
i
of 201 1. Resi~ce in P A would be a clear violation of Liberi's probation and Sergeant Morrison
,
!
bad no evidencf ofLiberi residing in PA in 2009, at the time Liberi et v Taitz et at was filediOf

at any time ~ her conviction in 2008.


i
··
5. I Jaterjcaused the photograph to be ~ to Ed and Caren Hale in Texas, and.. in speaking
!
with them later!they both assured me that they recognized the lady in the photogtaph as beinE~
!
! ~ ..­

i~ca1 with ~e woman claiming to be Lisa Liberi in Your Honoris COurt on August 7, 20e9 in
t ~

Philadelphia. !j co

7. I dec~ onder penalty of perj\Jl'y mder the laws of the State of California that the~~
! c..:
foregoing is ~ and conect This Declaration was exectrted on July 27, 2010 at Simi Valle§!'
,I
.
I

CalifM\ia. l

,(:n/ ~("
Date I
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CALIFORNIA ALL-PURPOSE
CE,TIFICATE OF ACKNO'VLEDG:MENT
i

State of Califomia i
i

Comrtyof ~'"
;
!
On , '1:1\\0 1 heforemc, loretta J. Cabuyadao7 Notary Public
i (Ht:re-msert came lIIliI mle oHM 0f'Ii«:r)
i

pe1S01lallyappean'ld i ~ i l ~\9..y.,
I . ,

0*
who proved to me the basis of satis:fil.l;:tory ~dc:nce to Qe the ~(s) wiNse nam~s) Ware subscribed to

capacity(ies),.aild *
the witliin ~ and at:lmow]edged t6 me that hefsb~ey executed the·same in bis/berltheU; authorized
by hislhcrlthdr signature(s) on the instrnment the pel'SOn(s).:>or the entity upon. behalf Of
which the pet'SOn(s) ~ executed the instrument.
i
I certify under P~TY OF PERJURY under the laws ofthe Stme ofCa1ifbmia that the foregCJiQg paragnlpn
is true and CO!TCCl i
;
.
i
i

wtrNESS my hand ~d officialseaI.


S"~
~~ . N!lie 1
;
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PESC[ffiF.ITON OF nmATl'ACHEO
I
OOCUM.'BNT
.

ned~q;h£~~n~
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•. Stale and COUI4y ~ IIIlISt be:: 1bc. saetc and. CoolJt1 ~.;OIe ~
NwnwofPages _1_ Document Date sigaer(J)par$OMll1~bdm:tbenotl:ry ~fm~~
! '------­ .. DID qf~ - " be l'hc dale tba( 1he ~$)~;ppMreCl whids.
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CAPAct1Y CLAIMED BY 'llJE SIGNER " Indi.aiie Ule ~ ~ 01: ~ ft:InM ~ ~ off~ f«= CUI.
~~ Iw;e) orcircliogheorrecl.ibr:DIL Fiikn to~~thi!s
CJ liI4ividuaJ. ($) ~maylali.lO-~of~~
O~~ • The ~ !IIIIIS ~ ifiIlIIr lie aJci:ar .m:ld phglqp~ ~
! l~ mil!it iIOt ~lm or IiDes.lfaaJ ~ ~~ ira
(1".) i sdciea·III'eiIl~~~.~~fOl'lJ.
.. ~ oflli. DI*I'Y public D:IIIISI ma!.di 1hc~.iIQ tiS ~ . . om. of
Ll Partner(s) i 'ibQ(lQWIIy ~ .
o Altomey--.m.fa.;t ~ A~ ~ is not m.'jllimd belt CCIIIIcI IfiIP to . . . tIii;j
o TIUStee(s) . ~i$Ji(ifJft~tr~toadift'trtDl~
o ~ __-+______________ ~_ ..
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IJ:IclIeItI: tl~ IN ~ of~ ~1JIIf1br;r at J.lIIgeS 8Dd dIlL
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corp<A&e~, iz:!dk:ate 1M ~ (i.e. m>. cro.~
• Secvrdr auxb tbi$~ to dlc sijJll'l(l cIommJcDf :
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Declaration of orty Taitz

1. My name is Orty Taitz

2.1 am over 18 years old

3. I am a resident of Orange County, CA

4. I don't suffer from any mental disease or impairment and have personal
knowledge of the following and certify under penalty of perjury and under the
laws of CA that foregoing is true and correct to the best of my knowledge.

5. Together with licensed investigator Neil Sankey I interviewed John Allen,


former boyfriend of Lisa liberi and the father of her only child.

6. Mr. Allen is a resident of Rancho Santa Margarita. CA and was interviewed in


my office at 29839 Santa Margarita PKWY, Rancho Santa Margarita, CA92688
...:.::> -:."1.
('
7. I asked Mr. Allen for a photograph of Lisa liberi and he gave me the:: ,
,..-.'";":

, .. ~
\
\
"

attached photograph of her with her second husband Brent Liberi and\~r.
,! .• ~ v

c:)
Allen's son.

8. The picture of Mr. Allen's and Ms. Uberi's son was removed for his priVacy. ; ....
(...o.'ii'

9. Mr. Allen has provided a description of Liberi's height and general buift°and
provided information regarding Liberi's criminal history and history of her
incarceration and probation.

10. Investigator Sankey met with Investigator Morison of Rancho Cucamonga


police department, who previously arrested Liberi and verified that indeed it is
the same person, who is depicted on the photograph and who was arrested
and convicted in 2008 and who is currently on probation with San Bernardino
CA probation department until March 2011.

11. I have forwarded attached photograph to Ed and Caren Hale, who were
present at the emergency court hearing on AUgU5t 7, 2009 in Liberi et al v Taitz
et al and I personally talked to caren Hale, who identified the woman on the
photograph as the same woman who was in court, testifying that she was Usa
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Uberi resident of PA, who was slandered and defamed by the plaintiffs 1 who
published the official criminal record of Lisa Liberi in CA.

Declarant furth~s not.

4~'
Signed
07 R 1 /0
Dated

(. .,'"

..
-'
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.' .'
'
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...
I:
i
I

DECLARATION OF LISA UBERJ


I

2
I, Lisa tiberi, do hereby declare that:

4 1 am the defendant in the within action and am making this Declaration in support of my
5 Motion to recuse the Office of the District for the County of San Bernardino.

6
1. 0Jl numerous occasions during the pendency of this action. DDA Secord bas made
7
8 reference to a criminal record which I purportedly had in the State of Texas. These references

9 were made during my atteJ:npts to obtain an OR release or bail reduction and appear to have been

lOan attempt to prejudice the Court against me. The attempt was apparently.success:fuI as the
11 Court wouldn't even grant electrOnic monitoring.
12
2. While it is true that in or about 1985, I was arrested in Ware, Texas, my ~qther.
,.:;::.::..::
13
Shirley Waddell posted bail for me, no charges were filed against me and, obviously::~ waS:~~;
14
. . ,

15 ""convicted·ofanything. I do not .recall what I was ar.resred for~ as itwas 21 years-agv:~~,

-c";
3. My attorney asked me what the District Attorney was talking about In an ~ to
16

17 establish the truth, I went to the Texas Department ofPublic Safety. Crime ~J:ds
-.. '

18
19
my name as Lisa R. Richardson and as Lisa R. Courville with my date of birth, May 28,
20
1965, no criminal records were fmmd. (A true and correct cOPy oithe search is attached
21
hereto and)noorporated in by reference as Exhibit 1.)
22
23 4. I then went to Instant Criminal Checks and paid to run my name with my social security

25 found. (A true and correct copy ofthe instant cri:tninal check is attached hereto and
26
incorporated in byreference as Exhibit 2.)
27
28
DECLARATIONOFUSALmEru
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on my case. ,
1

2
33., For the above afonmelitioued reasons, I respectfully request that D.D.A-James Secord ,

3
arid ,tJre San Bernardino CO\Dlty District Attomey's office be recused to insme me a

4
cha,nce at a fair trial.
5 . I declare under the penalty ofperjury of the .laws of the StateofCalifomia the foregoing is
6

1ni.e and correct


7

,DATED: September 21,2006


g

10

11

12

13

14

(', .

15 r<

-0
16

17
-.. ,
.
,

'

18

19

20
21

Z].

23

24

25

26

27

28

D~TIONOFUSALmIDU
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.,

/r:;x..,

I declare UDder the penalty of Perjury of the laws of the United States and' subject

to the penalties of 18 Pa C.S. Section 4904 that the foregoing is triie and correct.

Executed this lSlh dayofJuly, 2009.

LISAUBERI. Plaintiff

Vc:rifiQitionofLisa Libcri, Iuly 15,2009 12


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Document 136-1 Page:
Filed 36
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Date Page
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08/06/2010
of 48 P.007/019
#0494

CJPY FOR COUR~


1,;1
,

SUPERIOR COURT OF CALIFORNIA, COUNlY OF SAN BERNARDINO


SAN BERNARDINO DISTRICT

FSB04491
THE PEOPLE OF THE STATE OF CALIFORNIA, ) COURT CASE NO
)
. Plaintiff )
)
)
vs. )
) FELONY COMPLAINT
Lisa Liberi , )
aka Lisa R. Uberi, }
aka Lisa Renee Liberi, . )
) DA CASE NO 2004-00-0034761
aka Liaa C. Richardson, )
aka Lisa Courville-Rich, ')

aka Lisa Courville&Richardson. )

aka Lisa A Liberi . )

)
)
Defendant )
------------~----------~~~=---

The undersigned is informed and believes that: BY ~~ {). t2-­


Di:PUTY

...___ COUNT 1 _ {,":"=-'---=-:-­

On or about November 15, 2002, in the above named judicial district, ttj~ cri~~.pf
ATIEMPT TO FILE FALSE OR FORGED INSTRUMENT, in violation of PENAL COD~.sECT,ON
115{a), a felony, was committed by Usa Liberi, who did unlawfully and knowingly proc~ andO.ffer
a false and forged instrument to be filed, registered, and recorded in a public offi~' withi~··,this
(..!;
state, which instrument1 if genuine, might be filed, registered, and recorded under 'elaw of this
state orthe United States.

COUNT 2
On or about November 15,2002, in the above named judicial distrtct, the crime of
FORGERY, !n violation of PENAL CODE SECT!ON 470(d). a felony, was committed by Lisa
Liberi, who did, with the intent to defraUd, falsely make, alter, forge and counterfeit, utter, publish,
pass and attempt to offer to pass, as true and genuine, a Department of Motor Vehicle form Lien
Satisfaied I Title Holder Releas containing the purported signature of Cheryl A. Olston, knowing
the same to be false, altered, forged and counterfeited.

Page 1
Complaint DA CASE NO: 200+00-0034761
09/17/2029 06:22 #0494
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110242722
Document 136-1 Page:
Filed 37
07/29/10
Date Page
Filed:37 of 48 P008/019
08/06/2010

..... .­ *****
COUNT 3
On or about November .15, 2002, in the above named judicial district, the crime of
FORGERY, in violation of PENAL CODE SECTION 470(d), a felony, was committed by lisa
Liberi, who did, with the intent to defraud, falsely make, alter, forge and counterfeit, utter, publish,
pass and attempt to offer to pass, as true and genuine, a Department of Motor Vehicle form Lien
Satisfaied I Title Holder Relsas containing the purported signature of Alicia P. Becerra, knowing'
the same to be false, altered, forged and counterfeited.

COUNT 4
On or about November 15, 2002, in the above named judicial district, the crime of
COUNTERFEIT SEAL, in violation of PENAL CODE SECTION 472, a felony, was committed by
Lisa Liberi, who did unlawfully and with intent to defraud, forge and counterfeit the seal.of AliCia P.
' . . ' , . \~. -:,.~

Becerra, a Notary Public, and did. falsely make forge and counterfeit an impression pu;t'!Orti~ ~to,
." ". ,.;­
be an impression of said seal, and did possess such counterfeited seal and impression, 'j(nowingit
" c;

to be counterfeited and did conceal said seal. -0

..• ,,) ,

* * " ... *

NOTICE TO DEFENDANT AND DEFENDANTS ATIORNEY


Pursuant to Penal Code Sections 1054.5.(b). the People are hereby informally requesting that
defense counsel provide discovery to the People as required by Penal Code Section 1054.3.
NOTICE TO ATTORNEY
The materials accompanying this notice may include information about witnesses. If so, these
materials a~e disclosed to you pursuant to Penal Code section ·1054.2 which provides: "No
attorney may disclose or permit to be disclosed to a defendant the address or telephone number
of a victim or witness whose name is disclosed to the attorney pursuant to subdivision (a) of
Section 1054.1 unless specifically permitted to do so by the court after a hearing and a. showing of
good cause."

Page 2
Complaint DA CASE NO: 2oo4..QO-0034761
09/17/2029 06:22 #0494
Case
Case: 2:09-cv-01898-ER
10-3000 Document 136-1 Page:
Document: 003110242722 Filed 38
07/29/10
Date Page
Filed:38 of 48P 009/019
08/06/2010

Fyrther, attached hereto and incorporated herein are official reports and documents of a law
"'J.'
enforcement agency which the undersigned believe.s establish probable cause for the arrest of
defendant(s) Lisa Liberi , for the above-listed crimes_ Wherefore, a warrant of arrest is requested
for Lisa Liberi .

, DECLARE UNDER PENALTV OF PERJURY THAT THE FOREGOING IS TRUE ANI)


CORRECT AND THAT THIS COMPLAINT CONSISTS OF 4 COUNT(S).

Executed at San Bemardlno, Califomia, on June 30. 2004.

ichaelLerbriC
DECLARANT AND COMPLAINANT

Agency: District Attorney B of 1- Hospitality . Prelim Est. 02:00

Defendant Birth Date Booking No. CII No. NCIC


- - Lisa i.Ji5ei1- . .. 'u5J28, ,.965

. ,
• r

..
......: '.

..
"I'
, . ,': ~
j.,

Page 3
Complaint DA CASE NO: 2004-00-0034761
09/17/2029 08:22 #0494
Case
Case: 2:09-cv-01898-ER
10-3000 Document 136-1 Page:
Document: 003110242722 Filed 39
07/29/10
Date Page
Filed:39 of 48P 010/019

08/06/2010

ORIG!NAL

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO

THE PEOPLE OF THE STATE OF CALIFORNIA, ) COURT CASE NO FWV028000


)
)
Plaintiff INFORMATION
}
)
VS. ) Arraignment Date: 04/07/2004
) Department: R2
Lisa Renee Richardson. }
aka Lisa R Liberi, )
aka Lisa Courville-Richardson, )
) DA CASE NO 2002-00-0008876
. aka Lisa A liber;, )

aka Lisa C Richardson, )

aka Lisa Courville-Rich, )

aka Usa Renee Uberi )

)
)
)
Defendant )

------~------------------------)
INFORMATION
SUMMARY
I',,:.
~

...---...
~~t
··-Ct. Charge .$petial
Range Defendant Allegation
No.
1
Charge
PC487(a) 16-2-3

16·2-3
Lisa Renee Richardson

Lisa Renee Richardson


-.. "

2 PC476a(a)

3 PC470(d) 16-2-3 lisa Renee Richardson

4 PC472 16-2-3 Lisa Renee Richardson

5 PC115(a) 16-2~3 Lisa Renee Richardson

6 PC487(a) 16-2-3 lisa Renee Richardson

7 PC476 16-2·3 Lisa Renee Richardson

8 PC470(d) 16-2-3 lisa Renee Richardson

9 PC472 16-2-3 lisa Renee Richardson

10 PC1"15(a) 16-2-3 Usa Renee Richardson

11 PC487(a) 16·2·3 Lisa Renee Rjchardson

Page 1
Information DA CASE NO; 2002-00-000&376
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Case:
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Document: 003110242722
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12 PC487{a) 16-2·3 Lisa Renee Richardson PC12022.6(a)(1 ) +1 YR

13 PC487(d)(1) 16-2-3 lisa Renee Richardson PC12022.6(a)(1) +1 YR

14 PC487(a) 16·2-3 Usa Renee Richardson PC12022.6(aX1 ) +1 YR

15 PC487(d)(1) 16-2-3 Lisa Renee Richardson PC12022.6(a)(1 ) +1 YR

16 PC487(a) 16-2-3 Lisa Renee Richardson PC12022.6(aX1) +1 YR

17 PC487(dX1) 16-2-3 Lisa Renee Richardson PC12022.6(a)(1 ) +1 YR

18 PC487(a) 16-2-3 Lisa Renee Richardson PC12022.6(a)(1) +1 YR

19 PC487{a) 16-2-3 Lisa Renee Richardson PC12022.6(a)(2) +2Yrs

c>

-'..

Page 2
Information OA CASE NO: 2002-00-0008876
09/17/2029 06:22 #0494
Case:
Case
10-3000
2:09-cv-01898-ER
Document: 003110242722
Document 136-1 Page:
Filed 41
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,,' ., Date Page
Filed:41 of 48P.012/019
08/06/2010

The District Attorney of the County of San Bernardino, by this Information alleges that: .

COUNT 1

On or about August 29. 2001, in the above named judicial district, the crime of GRAND
THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION 487(a), a felony, was
committed by Lisa Renee Richardson, who did unlawfully take money and personal property of a
value exceeding Four Hundred Dollars ($400). to wit, money in the sum of $38,000, the property of
Business Bank of California.

COUNT 2

On or about August 28, 2001, in the above named judicial district, the crime of NON~
SUFFICIENT FUND CHECK MULTIPLE CHECKS (FELONY), in violation of PENAL CO~
SECTION 476a(a}, a felony, was committed by Usa Renee Richardson, who did unlawfu(I~, an<i)
fraudulently make, draw, utter, and deliver checks and drafts for the payment of money t~ total
amoun(pf whiGh_~xceede" Two Hundr~d Dollars ($20Q), her:.t?inafier I~sted:
....... ~ . , '"

••
v.,
,[)

Date Payee Bank Amount

08/28/2001 Usa Libert Bank One $10,000:00

08/28/2001 Lisa Libert Bank One $27,000.00

knowing at the time of such making; drawing, uttering, and delivering, that he/she had not sufficient
funds in, and credit with, said bank to meet the said checks and drafts and all other checks, drafts,
and orders upon such funds then outstanding in full upon their presentation for payment; the said
defendant(s) at all of said times having the intent then and there to cheat and defraud said persons
and corporation(s).

Page 3
Information OA CASE NO: 2002-00-0008876
09/17/2029 06 22 #0494
Case:
Case
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2:09-cv-01898-ER
Document: 003110242722
Document 136-1 Page:
Filed 42
07/29/10
Date Page
Filed:42 of 48P.013/019
08/06/2010

*****

COUNT 3

On or about July 16, 2002, in the above named judicial district, the crime of FORGERY, in
violation of PENAL CODE SECTION 470(d}, a felony, was committed by Lisa Renee Richardson,
who did, with the intent to defraud, falsery ma.ke, alter, forge and counterfeit, utter, publish, pass and
attempt to offer to pass, as true and genuine, Release of Lien, knowing the same to be false, altered.
forged and counterfeited ..

*****

COUNT 4

On or about July 18, 2002, in the above named judicial district, the crime of COUNTERFEIT .
SEAL, in violation of PENAL CODE SECTION 472, a felony, was committed by Lisa Renee
Richardson, who did unlawfully and with intent to defraud, forge and counterfeit a. Superior Court of
California for the County of San Bernardino and did falsely make forge and counterfeit anjmpression
'-' -"1
purpQrting to be an impre~ion of~aid sea.!l and djd pOS§jess su~h co~!1t~rfeited seal. a.:ndimpr~q'n,
"_.- : '~. -~

knowing it to be counterfeited and did conceal said s e a l . " ~~.

"''''***
..
..... 4

COUNT 5

On or about July 18, 2002, in the above named judicial district, the crime of ATTEMPT TO
FILE FALSE OR FORGED INSTRUMENT, in violation of PENAL CODE SECTION 115(a), a felony,
was committed by Lisa Renee Richardson, who did unlawfully arid knowingly procure and offer a
false and forged instrument to be filed, registered, and recorded in a public office within this state,
which instrument, if genuine, might be filed, registered, and recorded under a law of this state or the
United States.

Page 4
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10494 P 014/019
Case:
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2:09-cv-01898-ER
Document: 003110242722
Document 136-1 Page:
Filed 43
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*****

COUNT 6

On or about October 24, 2000, in the above named judicial district, the crime of GRAND
THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION 487(a), a felony, was
committed by Lisa.Renee Richardson, who did unlawfully take money and personal property of a
value exceeding Four Hundred Dollars ($400). to wit, money in the amount of $8,459, the property of
-Pomona First Federal. the property of Pomona First Federal.

*****

COUNT 7

On or about October 24, 2000, in the above named judicial district, the crime of FORGERY, in
violation of PENAL CODE SECTION 476, a felony, was committed by Lisa Renee Richardson, who
made, passed, uttered, and published, and attempted to do so, with intent to defraud a p~n,
- ...and
.,
possessed 1 with like intent, to utter, pass and publish, a fictitious and altered bill, note, a~d2cheQ~;'~::
puroorting to .be the bill, no~e. and_check, S1lnd other instrum~nt in writing fQr the pqyment ftmoney .
and property of a real and fictitious financial institution.

***** -'..
COUNT 8

On or about July 16, 2002, in the above named judicial district, the crime of FORGERY, in
violation of PENAL CODE SECTION 470{d), a felony, was committed by Lisa Renee Richardson,
who did, with the intent to defraud, falsely make, alter, forge and counterteit, utter, publish, pass and
attempt to offer to pass, as true and genUine, Release of Lien, knowing the same to be false, altered,
forged and counterteited.

Page 5
Information DA CASE NO; 2002-00-0008876
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Case:
Case
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Document: 003110242722
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48

*****

COUNT 9 '

On or about July 18, 2001, in the above named judicial district, the crime of COUNTERFEIT
SEAL, in violation of PENAL CODE SECTION 472, a felony, was c;:ommitted by Lisa Renee
Richardson, who did unlawfully' and with intent to defraud, forge and counterfeit a Superior Court of
California for the County of San Bernardino and did falsely make forge and, counterfeit an impression
purporting to be an impression of said seal, and did possess such counterfeited seal and impression,
- '

knowing it to be counterfeited and did conceal said seal.

COUNT 10

On or about July 18,2002, in the above named judicial district, the crime of ATTEMPT TO
FILE FALSE OR FORGED INSTRUMENT, in violation of PENAL CODE SECTION 115(a). a felony,
was committed by Lisa Renee Richardson, who did uniawfully and knowingly procure and offer a
Hfalse and fQrged jn!;itrument to b~Jiled, r~g.ister~<t andJ9C9.rQf;'!d ina Dut>.lie offic~w:ithin this ,state,
which instrument, if genuine, might be filed, registered, and recorded under a law of this ~te or the

United States. "\uu,:

*****

COUNT 11
-..
c.,'
V')
On or about May 3, 2001, in the above named judicial district, the crime of GRANDiHEFT OF
PERSONAL PROPERTY, in violation of PENAL CODE SECTION 487(a), a felony, was committed by
Lisa Renee Richardson, who did unlawfully take money and personal property of a value exceeding
Four Hundred Dollars ($400), to wit, money in the amount of $35,000 the property of Community
Bank.

Page 6
Information DA CASE NO: 2002'()O·OOO8876
09/17/2029 08:23
Case:
Case
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2:09-cv-01898-ER
Document: 003110242722
Document 136-1 Page:
Filed 45
07/29/10
Date Page #0494
Filed:45 of 48P.018/019
08/06/2010
."

*****

COUNT 12

On or about July 3,2001, in the above named judicial district, the crime of GRAND THEFT OF
PERSONAL PROPERTY, inviolation of PENAL CODE SECTION 487(a), a felony. was committed by
Lisa Renee Richardson, who did unlawfully take money and personal property of a value exceeding
Four Hundred Dollars.($400)". to wit, money in the amount of $31 ,457 the property of USA Federal
Credit Union.

***1<*

COUNT 13
. ..
On or about July 3, 2001, in the above named judicial district, the crime of GRAND THEFT

AUTO, in violation of PENAL CODE SECTION 487(d)(1), a felony, was committed by Lisa Renee

Richardson, who did unlawfully take an automobile, 1998 Lincoln Versailles, vehicle identification

~-,-'

number 5LMRU27L4WLJ46490- ,=-.; -~< ,

, ' ­
. i "

COUNT 14
. -..
On or about July 3, 2001, in the above named judicial district. the crime of GRAND ~EFT OF
PERSONAL PROPERTY, in violation of PENAL CODE SECTION 487(a), a felony, was committed by
Lisa
.
Renee
.
Richardson, who did unlawfully take money and personal
. property of a value exceeding
Four Hundred Dollars ($400), to wit, money in the amount of $23,494 the property of USA Federal

Credit Union.

*****

COUNT 15

On or about July 3, 2001,. in the above named judicial district, the crime of GRAND THEFT

AUTO, in violation of PENAL CODE SECTION 487(d)(1), a felony. was committed by Lisa Renee

Page 7
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Richardson, who did unlawfully take an automobile, 2001 Chevrolet Camaro Z28, vehicle
identification number 2G1 FP22GX12120621.

*****

. COUNT 16
, .
On or about September 12, 2001, in the above named judicial district, the crime of GRAND
THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION 487(a), a felony, was
committed by Usa ReneeRichardson, who did unlawfully take money and personal property of a
value exceeding Four Hundred Dol/ars ($400), to wit, money in the amount of $21 ,305 the property of
USA Federal Credit Union.

COUNT 17

On or about August 30,2001, in the above named judicial distriCt. the crime of GRAND
THEFT AUTO. in violation of PENAL CODE SECTION 487(d)(1), a felony, was committed 91 Lisa
Renee Richardson, who did unlawfully take an automobile, 1'999 DOdge Grand Caravan 81; ve~!~
identification number 284GP44RXR455666'. 1"-: .:,1

**"'**
..
.......,r

COUNT 18

On or about September 12,2001, in the above named judicial district, the crime of GRAND
THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION 487(a), a felony, was
committed by Lisa Renee Richardson, who did unlawfully take money and personal property of a
value exceeding Four Hundred Dollars ($400), to wit, money in the amount of $15.242, the property
of USA Federal Credit Union.

pageS
Information DA CASE NO: 2002--00·0008876
09/17/2029 0823 #0494 P018/019
Case:
Case
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2:09-cv-01898-ER
Document: 003110242722
Document 136-1 Page:
Filed 47
07/29/10
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of 48

*****

COUNT 19

On or about August 30, 2001, in the above named judicial district, the crime of GRAND
THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION 487(a), a felony, was
committed by Lisa Renee Richardson, who did unlawfu"y take money and personal property of a
value exceeding Four Hundred Dollars ($400), to wit, money in the amount of $228,600 the property
. of M.D.C. Holdings, Inc., dba Home America.

SPECIAL ALLEGATIONS

It is further alleged as to counts 12,13,14,15,16,17, 18thatin the commission o6f.:.e ap6¥6


offenses the said defendants Usa Renee Richardson, with the intent to do so, took, dama~~d a~d :.,~,
destroyed property of a value exceeding $50,000, within the meaning of Penal Code sectio'rr
< -r',
12022.6(a). ­
----:c:-----,.-. .. _. _.. ... _.-_ ....._
..
-'
.. ..... -'-"'1:-•....
It is further alleged as to count 19 that in the commission of the above offense the saHt
defendant lisa Renee Richardson, with the intent to do so, took, damaged and destroyed property of
a value exceeding $150,000, within the meaning of Penal Gode Section 12022.6(b).

*****

'* '" '1r '* *

NOTICE TO DEFENDANT AND DEFENDANT'S ATTORNEY


Pursuant to Penal Code Sections 1054,5.(b). the People are hereby informally requesting that defense
counsel provide discovery to the People as required by Penal Code Section 1054.3.
NOTICE TO ADORNEY
"rhe materials accompanying this notice may include information about witnesses. If so, these
materials are disclosed to yoa pursuant to Penal Code section 1054.2 which provides: "No attomey

Page 9
Information OA CASE NO: 2002-00-0008876'
09/17/2029 08:23 #0494 P019/019
Case
Case: 2:09-cv-01898-ER
10-3000 Document 136-1 Page:
Document: 003110242722 Filed 48
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08/06/2010

may disclose or permit to be disclosed to a defendant the address or telephone number of a victim or
witness whose name is disclosed to the attorney pursuant to subdivision (a) of Section 1054.1 unless
specifically permitted to do so by the court after a hearing and a showing of good cause,"

THIS INFORMATION CONSISTS OF 19 COUNT(S).

MICHAEL A. RAMOS
DISTRICT ATTORNEY
County of San Bernardino'
State of California

By:

Filed in Superior Court,


County of,san Bemardino

Dated: _ _ _ _ _ __

..
-~
v',
\0

Page 10
Information DA CASE NO: 2002..oQ-0008876
Case: 10-3000 Document: 003110242723 Page: 1 Date Filed: 08/06/2010
Case: 10-3000 Document: 003110242724 Page: 1 Date Filed: 08/06/2010
Case: 10-3000 Document: 003110242725 Page: 1 Date Filed: 08/06/2010

Law offices of Dr. Orly Taitz, ESQ

29839 Santa Margarita Pkwy, ste 100

Rancho Santa Margarita CA 92688

Declaration of Orly Taitz


1. My name is Orly Taitz, I am a resident of the state of CA, I am over 18 years old, don’t suffer of
any mental impairment and declare under penalty of perjury:
2. I have personal knowledge of the following
3. Exhibits #2 Affidavit of Caren Hale and #3 Affidavit of Edgar Hale were received in a computer
file form, that exceeded allowed memory space and I am not able to upload them to the ECF
system
4. Yesterday, on 08.05.10. I sent with the messenger service Rapid Delivery/one day delivery
above exhibits together with the whole document of “Response to Appellee’s Motion to Dismiss
the Appeal “
5. I personally talked to the owner of the delivery service, Brett Wool, as well as his employee Pat
and confirmed that the whole file and exhibits 1-6 were delivered to the Third Circuit Court of
Appeals on 08.05.10 and I was charged $90 via my credit card
6. On the same day Linda Sue Belcher , one of the parties in Liberi v Taitz 09-1898 USDC Eastern
District of PA , underlying case for the current appea, contacted me via e-mail and phone and
expressed her willingness to join me as an appellant. She expressed that in her statement in
exhibit 5 and was advised by me to fax her consent to the same delivery service, to be delivered
to the Third Circuit Court of Appeals on the same day, 08.05.10. I stated to Ms. Belcher that I
will cover additional $90 for additional delivery.
7. All of the above information is true and correct to the best of my knowledge .
8. Declarant further says not.

Dr. Orly Taitz, ESQ

08.06.10

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