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EXHIBIT “4”

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Law Offices of:

PHILIP J. BERG, ESQUIRE
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531 Attorney for: Plaintiffs
Identification No. 09867
(610) 825-3134

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LISA LIBERI, et al, :

Plaintiffs, :
vs. : Assigned to Honorable Eduardo C. Robreno
:
ORLY TAITZ, et al, :
: Case No.: 09-cv-01898-ECR
Defendants.
:
:
:
:
:
:

AFFIDAVIT OF SHIRLEY WADDELL

I, Shirley Waddell am over the age of eighteen (18) and am not a party to the within

action. I have personal knowledge of the facts herein and if called to do so, I could and would

competently testify under oath.

I declare as follows:

1. I have read Orly Taitz’s Document 145 dated September 28, 2010.

2. If I fail to mention something it does not mean that Taitz is truthful, it is the mere

fact that the filing of documents with your Honor’s Court from May 2009 forward are

constantly, and deliberately being misquoted, and twisted. The frivolous filings are a

monumental pile of trash. Taitz is using your Honor’s Court to further harass the

Plaintiff’s and witnesses.

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3. Taitz is also being sued by Lisa Ostella. Taitz has never raised any questions as

to the State that Ostella lives in. WHY? Because all of this is just a ruse. Taitz’s actions

of filing frivolous Court Documents are intended to mislead or deceive Taitz’s followers

by constantly pounding lies into their heads about Liberi via court dockets downloaded

by SCRIBD. AGAIN, this is also wasting the Court’s time and putting the plaintiffs at a

great disadvantage. I thought the Courts had rules, and were supposed to be fair to both

sides.

4. Belcher’s letter, attached hereto as EXHIBIT “A” is presented to your Honor’s

Court by Taitz, a licensed attorney, as being a Sworn, Notarized Affidavit. Which it is

NOT. This is a forged Notary Seal, as Taitz knows. There is no state, no county,

no commission expires date, and no type of seal. The purpose is to deceive your

Honor, and Taitz supporters, while Taitz is preaching to the world about Berg, Ostella,

and Liberi defrauding the Court. Another ruse, and/or another red herring. The content

of the Belcher letter is as reliable and believable as the Notary Stamp and Orly

Taitz. Below is Texas Law regarding Notary Seal. I have personal knowledge as I

was a Texas Notary for years.

5. Texas Gov't. Code Ann. § 406.013 requires a Notary Public to use a seal of office

to authenticate the Notary Public’s official acts. Section 406.013 states:

a. A notary public shall provide a seal of office that clearly shows, when
embossed, stamped, or printed on a document, the words "Notary Public, State
of Texas" around a star of five points, the notary public's name, and the date
the notary public's commission expires. The notary public shall authenticate
all official acts with the seal of office.

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b. The seal may be a circular form not more than two inches in diameter or a
rectangular form not more than one inch in width and 2½ inches in length.
The seal must have a serrated or milled edge border.

c. The seal must be affixed by a seal press or stamp that embosses or prints a
seal that legibly reproduces the required elements of the seal under
photographic methods. An indelible inkpad must be used for affixing by a
stamp the impression of a seal on an instrument to authenticate the notary
public's official act.

d. Subsection (c) does not apply to an electronically transmitted authenticated

document, except that an electronically transmitted authenticated document
must legibly reproduce

6. According to Affidavits in another Federal Court, Yosef Taitz forged a document

for Orly Taitz, which was supposed to be President Obama’s birth certificate. Orly Taitz

also filed that in Federal Court as authentic. This took place in Federal Judge Carter’s

Court where she also tried to get several associates to lie. These affidavits have

previously been filed in your Honor’s Court. Taitz and Sankey have filed other

forged documents in your Honor’s Court. Evidence regarding forged documents was

filed in your Honor’s Court by Plaintiffs some months ago. Orly Taitz is running

around, pointing fingers and accusing innocent people of doing exactly what she

either has done or is presently doing.

7. Geoff Staples of Hostricity Web Hosting has Cerberus Helpdesk which is a

web based email management software created using PHP and My SQL which gives

Geoff Staples the ability to submit and update support tickets, create SLA plans for

supported clients, knowledge-base integration and more. Belcher and Staples have

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known each other (according to Belcher) about 20 years. Belcher talked Mr. Berg into

hiring Geoff Staples approximately August of 2008. Mr. Berg then fired Geoff Staples

on December 1, 2008 for dishonest acts.

8. Taitz, a licensed attorney, illegally barged into Mr. Berg’s private business affairs

again by recently contacting Geoff Staples to gain access to Mr. Berg’s private financial

records that Geoff Staples supposedly has saved on his (Geoff’s) server. Geoff Staples

illegally sent some pages of (supposedly) Mr. Berg’s financial documents to Taitz.

Some pages filed by Taitz have definitely been cut, pasted, and doctored up by someone.

Taitz filed fourteen (14) pages, and it is unknown who doctored the pages, see EXHIBIT

“B”. Pages 32 through 40 of Geoff Staples documents have triplicate information of

“Setting up LinkPoint”, and emails. This means the pages were copied and information

placed differently on each page, along with alteration marks. This makes it appear that

there are more documents than actually in reality are needed. Some documents have

headers on one page with the email message body on another page. Then this same email

will appear on another page positioned differently (at top instead of bottom, etc.), with

other information. I am certainly not an expert on forged documents; however lines

going horizontally across the page is very noticeable. The (=) equal signs are not

consistently the same size, some 0,s are different sizes. There is a line that goes from top

to bottom on all the pages that has to do with emails and training sheets of LinkPoint.

This vertical line is also on Staples, and Belcher’s Documents, but not on Taitz’s

Document 145.

9. The triplicate documents appear to be numbered pages #32, 33, 34; #35, 36, 37;

#38, 39, 40. Documents #32, 35, 38; #33, 36, 39; 34, 37, 40, do have pieces of same

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duplicate information placed at different areas on the paper with horizontal lines

indicating some type of alteration of document. Taitz has filed these so-called records

without documents of authenticity. All of these “dirty pages” were definitely meant

for the purpose of confusion and not clarity. Taitz is trying to prejudice her readers

with more garbage. Taitz, a licensed attorney, knows that what she did was illegal.

Legal authenticated records would have come from LinkPoint, with a subpoena.

Taitz did not need legal documents for evidence because Linda Belcher and Geoff

Staples documents would have absolutely no bearing on the case what so ever.

Again, their documents are as genuine, believable, and reliable as Linda Belcher’s

Notarized Affidavit.

10. On Taitz Document #145, page 42, Taitz, a licensed attorney, left the name of

Brian Malek, email address, home address, phone number, and credit card number

w/exp date sent to, geoffstaples@hostricity.com from navastar@iolfree.ie. This

information was not redacted. This is now circulating on the World Wide Web. Brian

Malek is going to be very unhappy with Taitz and Staples for stealing his records and

posting his sensitive material on the Internet. This page has also been altered. This page

also sits on the docket of your Honor’s Court.

11. There is a posting on the Internet by Ron Sturgeon and his attorney asking for

people to contact those regarding experiences with Geoff Staples. They are having

problems getting passwords, their websites and other negative issues with this man. The

same type of problems that Mr. Berg had with Staples in 2008. See:

http://www.hostricitysucks.com/attorney-letter and
http://www.hostricitysucks.com/index.php

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12. Taitz is running around like a chicken with it’s head cut off trying to do anything

and everything to confuse the issues of the reason that this lawsuit was filed. The first

part of September 2010, Taitz used an actor, David Acton, to act like a news reporter that

was reporting the news about this lawsuit, which of course was lies. She called this video

“Dr. Orly Taitz Sued by Birther Phil Berg in Apparent Birth Right Grudge Match”.

Of course she blamed Liberi. This video and the threads were removed from the Internet

shortly after Taitz posted it.

13. When this lawsuit was filed, Mr. Berg had met Taitz one time at a public

gathering. Orly Taitz came along late 2008 after Mr. Berg had filed a lawsuit regarding

the wording of the U.S. Constitution pertaining to the President of the U.S. being a

natural born citizen. Taitz came along, plagiarized Mr. Berg’s and Liberi’s work, and

filed the documents in Court with her name on it. People called Mr. Berg about this

plagiarizing, but Mr. Berg said that it did not matter as long as the issue of Obama was

cleared up. Taitz then started calling Berg’s office wanting Liberi to do her legal work.

Liberi and Berg had heard of Taitz’s reputation and did not want anything to do with her.

Mr. Berg finally told Taitz to stop calling his office in Pennsylvania, that she was

unethical, actions were illegal, she was a liar, and he wanted nothing to do with her.

That’s when Taitz said that she was taking Berg down and would destroy Liberi. At this

same time (end of 2008, or early 2009) Taitz demanded that Ostella lie to law

enforcement about her web site being hacked. Ostella refused, so Taitz posted and was

preaching that Ostella stole her donations among other things. We do not know what

Taitz was trying to hide or who she was trying to frame with saying that her website

was hacked. Taitz, a licensed attorney, then vindictively posted on the Internet Liberi’s

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social security number, birth date, place of birth, mother’s maiden name, father’s name,

and proceeded to email, and fax all of this information to millions. This is when and why

the lawsuit was filed. A jealous, vindictive, rejected attorney, Orly Taitz, was after

revenge. The issue of President Obama had nothing to do with this lawsuit.

Distanced observance of unethical and illegal conduct and obvious true intent of Orly

Taitz as a person and as an attorney was the deciding factors that prompted Mr. Berg to

tell Taitz to stop calling and emailing his office in Pennsylvania.. Later, the Courts

witnessed the forged documents presented by Taitz, affidavits from her witnesses that

Taitz wanted them to lie and perjure themselves, unwillingness to follow Court rules and

regulations, bullying judges, intimidation of witnesses, obstruction of Justice, on and on.

So far, it has cost Taitz $20,000.00; hopefully soon it will cost her the license to practice

law. Evidence of the above has already been filed with your Honor’s Court.

14. Since the lawsuit has been filed, Taitz has told many, many lies, stalked, and

harassed Ostella, Liberi and their families, and still trying to manipulate the emotions and

prejudices of her followers with lies. Belcher, Taitz, Sankey, and John Allen have

harassed Liberi by contacting everyone that you can imagine with outrageous stories.

Liberi provides the proper documentation’s needed to clear up the lies, and the Agencies

place the names of Belcher, Taitz, Sankey, and John Allen in Liberi’s file as harassing

troublemakers to be ignored in the future. The next day brings more grief through

identity theft. Liberi & Ostella do know the hell caused by Taitz’s twisted evil mind.

The anxiety and stress is tremendous on Ostella and Liberi, and of course their families.

Evidence of the above has already been filed with your Honor’s Court.

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15. Taitz talks about Liberi’s ex-husband, and my grandson’s father. It is

unbelievable that Taitz is chasing around the country on her supporter’s money to talk to

Liberi’s ex-husband from approx. 21 years ago. I can only say that some people’s relationships

do not work out for many reasons, and they move on. Some couples prefer divorce to

years of tawdry affairs, and/or degradation of partner. However, Taitz must feel that it is

more profitable for her to stay married and continue to be an adulteress. Taitz feels no

shame, because evil has no shame. Taitz feels that she is having her cake and eating it

too, and/or there must be some kinky arrangement with her husband. Personally, I

among others do not care. However, she is allowed to continue to file frivolous garbage

that is being viewed by the world, and we are expected to give truthful answers or people

take her garbage to be the truth. Next she will be trying to find the diaper that Liberi

pooped in at age one. Why not? Her supporters are paying for it. Is there some type

of obsession here?

16. I am extremely uncomfortable regarding this woman talking about my grandson,

carrying a family picture around with her, and knowing my grandson’s age. I am also

concerned for the safety of my daughter and her husband.

17. Taitz is constantly twisting the truth regarding documents filed in your Honor’s

Court, so we provide to Federal and State Law Enforcement copies of filed documents.

This woman is totally and completely evil. I have never said that about a person before.

I did believe at one time that none of us are 100% EVIL. However, that was before

Taitz.

18. Taitz is now trying to say that Liberi was never placed in a safe at home program.

The California Secretary of State can prove her wrong, and so can your Honor. Taitz

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says she is a write-in candidate for California Secretary of State. I can just see her now

handing out safe at home addresses to all the abusive spouses. Taitz is much too self-

serving, and irresponsible to be a public servant of any kind. She does not follow the

rules of decency, rules of court, or rules of law. She wants to be a Dictator, and to be

noticed.

19. Taitz mentioned Ruben Nieto taking money out of Ostella’s Paypal Account.

Ruben Nieto was waiting for his pay off from Orly Taitz’s Paypal Account. Taitz had

to have communicated the information regarding her account to this dangerous criminal.

Taitz down plays her constant, intentional, irresponsible actions that deliberately put

Ostella, Liberi, and their families in danger.

20. Taitz complains that the Affidavits submitted to your Honor’s Court for Liberi are

similar. All of the Affidavits are legally notarized as to the truth of the matter. All

Affidavits would be similar due to testifying to the truth of the matter. The affidavits are

not word for word due to knowledge of subject matter being discussed. All witnesses can

testify to some things, some witnesses can testify to most things, Liberi, Ostella, and Berg

can testify to ALL things because it is about them and they lived it. I guess Taitz is

trying to infer that we are plagiarizing Affidavits like she plagiarized Mr. Berg’s and

Liberi’s work. Not True. Of Course we have to keep repeating things because Taitz

keeps constantly filing trash that is misrepresenting the facts from May 2009 forward.

Evidence has already been filed with the Court a couple of times.

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

4th day of October 2010.

is true and correct. Executed this ____

Sent by fax see next page

__________________________
Shirley Waddell, Declarant

State of California )

County of Sacramento )

On this ______ Melvin Mario

4th day of October, in the year 2010, before me _____________________
Notary Public Name

a notary public, personally appeared Shirley Waddell, and proved on the basis of satisfactory

evidence to be the person whose name is subscribed to this instrument, and acknowledged she

executed the same. Witness my hand and official seal.

Sent by fax see next page

___________________________
NOTARY PUBLIC

SEAL

July 6, 2013
My commission expires: _____________

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EXHIBIT “A”
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EXHIBIT “B”

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