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8/7/2019 LIBERI v TAITZ (C.D. CA) - 175.2 - Exhibit opposition to pro hac vice of Berg in case 10-1573 - gov.uscourts.cacd.49…
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Dr. ORLY TAITZ, ESQ S8#223433
29839 SA}ITA I{ARGARIIA PKWY
RAI{CHO SA}r{TA }IARGARIIA CA 92688, STE 100
PH 949-683-5411 EAx 949-766-7603E-r'IAfL orly. taitz Ggmail. com
Attorney FOR DEEEND OIIR EREEDOMS FOUIIDATION,
ORLY TAITZ INC, APPEATI}TG DEN?ISTRY
CIIARLES IINCOLN,
PI"AIIiITIFF,
vs.
DAYLTGHT CHEMTCA].,EI AI
)CASE NO. : 8 : 10-CV-01573-AG DEEEIIDAT.ITS' DEIEI{D
PI]R FREEDOMS FOI'NDATION. ORLY TAITZ INC A}ID
)APPSATING DENTTSTRY
)AMEI{DED OPPOSTTTON TO PRO trAC VrCE OF
)ATTORNEY PHILIP BERG
)
)
)
)
)EFENDANT
TO ALL PART]ES AND TO THEIR COUNSEL OF RECORD:
PLEASE TAKtr NOTICE that pursuant to federal rules of Civil Procedure RuIe 10 (
c, ) Defendants Defend Our Freedoms Eoundation, Orly TarLz, inc and Appealing Dentistry
(colfectively "Defendants") are filing this amended opposition to Pro Hac Vice and
adding a Table of Content to the pleading, exceedj-ng 10 pages.
TABLE OF CONTENT
1. Attorney Philip rT Berg is currently subject to a three judge disciplinary board
2. PhiJ-ip ,f . Berg was sanctioned twiee by Federal judgtes........... .......................'.p3
3. Philip il.Berg enpJ-oys as his paral.egaI a convicted docunent forger Lisa Liberi,
who is currently on probation with San Bernardino county, CA with 10 felony
4- Philip J. Berg filed a friwolousJ-aw
suitagainst Taitz..... ..--....'.............p9
5. Lincoln was sanctioned $150,000 in Federal court in TX--....'....-.. ...............p11
/s/orry Taitz
Notice of Joinder to Motion to Dismiss
Case 8:11-cv-00485-AG -AJW Document 175-2 Filed 04/18/11 Page 1 of 19 Page ID#:4071
8/7/2019 LIBERI v TAITZ (C.D. CA) - 175.2 - Exhibit opposition to pro hac vice of Berg in case 10-1573 - gov.uscourts.cacd.49…
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1752-exhibit-opposition-to-pro-hac-vice-of-berg 2/19
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t{iItl,,i:
UL.9LLy LdaLLa LJ\a
na a1 1^7a
EEDERAL COT'RT PROOF OF SERVrCE
certify under penalty of perjury and under the laws of CA that I served thi-s
Opposition to Pro Hac Vice on all the parties in this case on 02.21,.2011 via
and/or mail
/s/orly Tattz
Dr. Orly Tai-tz, ESQ
29839 Santa Margarita Pkwy
Rancho Santa Margarita CA 92688
amended
ECF
Notice of Joinder to Motion to Dismiss
Case 8:11-cv-00485-AG -AJW Document 175-2 Filed 04/18/11 Page 2 of 19 Page ID#:4072
8/7/2019 LIBERI v TAITZ (C.D. CA) - 175.2 - Exhibit opposition to pro hac vice of Berg in case 10-1573 - gov.uscourts.cacd.49…
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Case 8:10-cv-01573-AG -PLA Document 43 Filed 02115111 Page 1 of 17 Page lD#:1089
DR. ORLY TATTZ, ESQ S8.#223433
29839 SATiITA !4ARGARITA PKTfY
RAI{CFO SaNTA MARGARTTA CA 926gg, STE 100
pH 949-583-5411 FAr( 949-765-7603E-MAIL orly. taitz Ggnaj-l. com
Attorney FOR DEFEND OtlR FREEDOMS I'OUNDATION,
ORLY TAITZ INC, APPE,NTING DENTISTRY
CIIARLES LINCOLN , I CASE NO. : 8:10-CV-01573-AGPLAINTIFF, ) DEFET{DAIITS'DEFEND OttR
vs. ) aREEDOMS FOUNDATION, ORLY
DAYLTGBT CHEMTCAL, et a]- ) TArTz INC AI{D APPEALTNG
DE!'ENDAI{T ) DENTISTRY opposition to) appJ.j-cation to pro hac vice) fiJ.ed by Pennsylvania) attorney PhiJ-ip J. Berg)
)
TO ALL PARTIES AND TO THEIR COUNSEL OF RECORD:PLEASE TAKE NOTICE Defendants "Defend Our Freedoms
Foundation", Orly Taitz, inc and "Appealing Dentistry"(col-lectively "Defendants") are filing this opposlti-on
to Plaintiff's application for pro hac vice for out. ofstate attorney Philip J. Berg.
Cn Fri-day evening after the end of the work day theplaintiff in this case filed a pro hac vice application
for Pennsylvania at.torney Philip J. Berg. As it was the
end of the day, bot.h attorneys for Law office of OrlyTaitz and for Daylight Chemical- already l-eft their
lrncofn v Dayliqht oppcsition to Pro Hac Vice 1
Case 8:11-cv-00485-AG -AJW Document 175-2 Filed 04/18/11 Page 3 of 19 Page ID#:4073
8/7/2019 LIBERI v TAITZ (C.D. CA) - 175.2 - Exhibit opposition to pro hac vice of Berg in case 10-1573 - gov.uscourts.cacd.49…
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Case 8:10-cv-01573-AG -PLA Document 43 Filed 02115111 Page 2 of 17 Page lD#:1 090
offices for the weekend and are unabl-e to responC
before Monday the 02.I4.207T motion hearing, even
though they intended to object Mr. Berg's application.Plaintiff stated previously t.hat Mr. Berg is intending
t.c appear, buL there was no application until Friday
evening. Additionally during Rul-e 26f conference therewas no attorney on the case and Lincol-n participatedpro se. Now, at 72:30 at night, on1-y a few trours before
the scheduled motion hearing Lincoln e-mailed Taltz a
new RuIe 26f statement, filed out by attorneys Berg and
Kreep, which states the case significantly di-fferentlyfrom the First Amended Complaint.
As the motion heari-ngr is in a few hours and both
counsel are not available, Taitz rs filing this
opposition without counsel on the case and opposes this
application to pro hac vice on the following grounds:
1. Pro hac vice application requires good standing and
good moral character of the attorney. Attorney Berg isnot in good standing with the PA bar, ds he is
currently subject to disciplinary proceedings. The
Disciplinary Board has already scheduled a three judge
panel hearing for Philip Berg for 02.23.20tt only nine
days from now. Exhibit 1
Berg was previously repeatedly sanctioned by the
Federal- court in PA for filing frivolous Iega1 actions.
Lincoln .r Daylight Opposltion tc Pro Hac Vice 2
Case 8:11-cv-00485-AG -AJW Document 175-2 Filed 04/18/11 Page 4 of 19 Page ID#:4074
8/7/2019 LIBERI v TAITZ (C.D. CA) - 175.2 - Exhibit opposition to pro hac vice of Berg in case 10-1573 - gov.uscourts.cacd.49…
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Case 8:10-cv-01573-AG -PLA Document 43 Filed AZ15l11 Page 3 of 17 Page lD
#:1091
In Re Berg, 2008 Bankr. LEXIS 322 (ED PA 2OOB); HoJ-swarth
v. Berg, 2005 U.S. Dist. LEXIS 15393 (ED PA 2005).
A July 25 , 2 005 articl-e f rom The Leqal Intel-ligiencer,
"Lawyer Slapped With $10K in Sanctj-ons for 'Laundry
List of Unethical Actions' sums the situation here up:
"Finding that a Pennsylvania lawyer had committed a
"laundry list of unethical actions, " a federal judge
has imposed more than $10,000 in sanctions and orderedthe lawyer to complete six hours of ethics training.
U.S. District Judge J- Curtis Joyner's 10-page opinion
in lloLsworth v. Berg is packed with criticism of the
conduct of attorney Philip Berg of Lafayette Hill'
Pa."Other attorneys should look to Mr. Berg's actions
as a blueprint for what not to do when attemptj-ng to
effectively and honorably perform the duties of the
legal profession, " Joyner wrote. "This court has grown
weary of Mr. Bergi's continuous and brazen disrespect
toward this court and his own clients. Mr. Berg's
actions are an enormous waste of iudicial time and
resources that this court cannot, in qood conscience/
allow to go unpunished, " Joyner wrote. In the suit,
l,incoln v Daylight Opposition to Pro Hac Vice 3
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Case B:10-cv-01573-AG -PLA Document 43 Filed 02115111 Page 4 ot 17 Page lD#.1092
Berg is accused of 1ega1 malpract.ice by former clients
who claim his faj-l-ure to respond to an ERISA cl-aim
against them led to a default judgment. But the
sanctions against Berg stem from his decision to file a
third-party counterclaim of fraud against a pension
fund that had sued his former clients, according to
court papers. Joyner bl-asted Berg for filing the fraud
cIaim, calling it an "irresponsible decision" because
the c.l-aim was "utterly barren of any scinti-l-la of lega1
principles." Berg's motion was rejected and a default
judgment of more than $5,300 was entered against his
clients. The judgment swel.Ied to more than $10,000 when
Carpenters Heal-th later successfully moved for a
supplemental judgmenl to recover more than $4r 700 in
attorney fees for its efforts in responding to Berg's
untimely motions. Holsworth and his wife later filed a
1egal malpractice suit against Berg in the Philadelphia
County Court of Common Pleas, alleging that Berg
negligently failed to represent them in the Carpenters
Health case. A year later, in February 2005. Bergr moved
Lincoln v Daylight opposition to Pro Hac Vice 1
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Case B:10-cv-01573-AG -PLA Document 43 Filed 02115111 Page 5 of 17 Page lD
#:1093
to join Carpenters Health as a third-party defendant i-n
the malpractiee suit, demanding more than $20,000 in
damages. fn his counterclaim, Berg alleged that the
ERISA suit filed by Carpenters Health in 200L, which
led to the malpracti-ce claim against him, was "a fraud
upon the court and a fraudul-ent taking from the
Holsworths."Carpenter Health's lawyers removed the case
to federal court and filed a motion to di-smiss thecl-aim. Joyner agreed, findinq that Berg's fraud clai-m
was "frivolous" and was motivated by an intent "to
harass Carpenters Heal-t.h and the Holsworths, as well as
to delay and disrupt the administration of justice."
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. "
Grant.ing surnmary judgment in favor of Carpenters
Heal-th, Joyner said he found it "wholly unnecessary"
even to consider the facts of the ERISA case because it
was "abundantly clear" that Carpenters Health was
Lincoln v Daylight' Opposition to Pro Hac Vice 5
Case 8:11-cv-00485-AG -AJW Document 175-2 Filed 04/18/11 Page 7 of 19 Page ID#:4077
8/7/2019 LIBERI v TAITZ (C.D. CA) - 175.2 - Exhibit opposition to pro hac vice of Berg in case 10-1573 - gov.uscourts.cacd.49…
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Case B.10-cv-01573-AG -PLA Document 43 Filed 02115111 Page 6 of 17 Page lD#:1094
enlitled to a judgment as a matter of law. Joyner
invj-ted Carpenters Heafth to fiLe a motion for Rule 11
sanctions. When it did, Joyner found that Berg
"continued his trend of unprofessional conduct ". . .
"Bergr's fraud claim, Joyner said, was "inadequately
pled, not grounded in fact, time-barred, and utterly
irrelevant to the pending malpractice action against
him. ". . . "fn his sanctions order, Joyner ordered Berg torej-mburse Carpenters Health the $10,668 in attorney
fees and costs it incurred in defending t.he claim. He
al-so ordereci Berg to complete six credits of ethics
courses certified by the Pennsylvania Board of
Continuing Legal Education, and recommended t.hat Berg
be investigated by the Pennsylvania Bar Association's
Committee on Legal Ethics and Professional
Responsibility. "
Similarly Berg demanded drsbarment of the Supreme
court Justi-ces Sandra Day O'Connor, Antonin Scalia and
Clarence Thomas. http : / /en.wikipedia.orq/wLkilPhilip J. Berg
http: / /en.wikipedia.org/wikilPhitip J. Berg
Lincoln v Daylight Opposition lo Pro Hac Vice 6
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8/7/2019 LIBERI v TAITZ (C.D. CA) - 175.2 - Exhibit opposition to pro hac vice of Berg in case 10-1573 - gov.uscourts.cacd.49…
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Case 8;10-cv-01573-AG -PLA Document 43 Filed 02115111 Page 7 of 17 Page lD#:1 095
In October 2004, Berg filed Rodriguez v. Bush 04-4952 Eastern District of PA,
accusing the President of the United States and 155 other parties of complicify in
the 9ll1 attacks.
This 237-page civil law-suit included allegations pursuant to the RICO (Racketeer
Influenced and Corrupt Organizztions Act) against The United States Of
America, the Federal Emergency Management Agency, the Department of
Homeland Security, George Herbert Walker Bush, George Walker Busho
Richard Cheney, Donald H. Rumsfeld,and numerous others, totaling 156
defendants in the U.S. District Court for the Eastern District of Pennsylvania.
This lawsuit made hundreds of allegations "...; that phone calls made by some of
the victims, as reported by their family members, were not actually made but were
"faked" by the government using "voice morphing" technology;that a missile, not
American Airlines Flight 77, struck the Pentagon; that United Airlines Flight 93
was shot down by the U.S. military; that the defendants had foreknowledge of the
attacks and actively conspired to bring them about; that the defendants engaged in
kidnapping, arson, murder, treason, conspiracy, trafficking in narcotics,
embezzlement, securities fraud, insider trading identity and credit card theft.
blackmail. trafficking in humans, and the abduction and sale of women and
Lincoln v Dayl-ight Opposilion to Pro Hac Vice 'i
Case 8:11-cv-00485-AG -AJW Document 175-2 Filed 04/18/11 Page 9 of 19 Page ID#:4079
8/7/2019 LIBERI v TAITZ (C.D. CA) - 175.2 - Exhibit opposition to pro hac vice of Berg in case 10-1573 - gov.uscourts.cacd.49…
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Case B:10-cv-01573-AG -PLA Document 43 Filed 02115111 Page 8 of 17 Page lD#:1096
children for sex. rt
http : / /en.wi-kipedia-org/wiki/Philip J. Berg
Rodriquez v Bush was dismissed on all counts against
all plaintiffs.
3. By Berg's own admission he employs as a paralegal
one Llsa Llberj-, who has been charged of 23 counts of
forgery of documents anci theft and in plea bargain
convicted in 10 counts of forgery in theft in 2008 inSan Bernardino CA Exhibit 2. She is currently on
probation under supervislon of San Bernardino CA
Probati-on department Exhibit 3. Having a convicted
forger as a paralegal unCermlnes integrity of the
court. In 2004-2006, when Liheri was incarceraled, she
filed multiple frivolous 1egal actions. Her first
Iegal action Liberi v Sheriff's department et. al
5:04-cv-OL524-vAp was a 30 mil-lion dollar case agai-nst
tnslliple rndividuals, including District attorneys'
office, her prior attorneys, judges, sheriffs'department, policemen and detectives and many others.
rt was a frivol-ous 1egal action, which caused an
enormous emotional distress and financial hardships tomany/ it was dismissed after her attorney was
sanctioned mult.iple times and after her attorneydropped Liberi as a client. Not satisfied, Liberi filed
pro se yet anot.her frivolous RICO law suit for $280
miJ.J-ion against the San Bernardino County/ CA/ West
Lincoln v Daylight Opposition to Pro Hac Vice B
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Case 8:10-cv-0'1573-AG -PLA Document43 Frled02115111 Page I of 17 Page lD#.1097
Valley Correctional facility, district attorneys,police officers, police detect.ives, numerous 1aw
enforcement officials Lisa Liberi v West Valley Centeret al 2:05-cv-0301S-VAP-SGL. In a simil-ar modus
operandi she accused mult.iple innocent individuals of
committing crimes. Her legal action was dismissed. As
shown in these examples, Both Liberi and Berg have a
history and modus operandi of filing mul-timillion
dollar faw suits for the sole purpose of harassment.
They caused immeasurable financial and emotional clamage
to t.he defendants.
4. Berg and Kreep (local- attorney contact) have a long
standing vendetta against Ta:-Lz, whereby an effort was
made by Berg and Kreep to defame Tatt-z and undermine
her cases. Four convicted felons: Charles Lincoln, Lisa
Liberi, Lucas Smit.h and Larry Sinclair were used i-n a
concerted effort to provi-de perjured affidavits in aneffort. to destroy her liti-gation efforts dealing withlegitimacy of Barack Hussein Obama.
In a nut shel-l Berg and Kreep are known as
establ-ishment or controlled opposition attorneys. Berg
is a l-iberal Democrat and Clinton supporter, Kreep issupposedly a conservative, Al1 three: Berg, Kreep and
Taitz, along with many other attorneys filed legal
actj-ons seeking ascertainment of legitimacy of Barack
Husse j-n Obama (hereinafter "Obama" ) to U. S. presidency.
Both Berg and Kreep used in their pleadings a
Lincoln v Daylight Opposition to Pro Hac Vice 9
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definition of natura"l- Born citizen, which is actuallymost beneficial to the defense and concentrated on one
issue: birth certj-ficate. Taitzr oh the other hand,folfowed a theory most beneficial to the plaintiffs.
She has been working with top investigators and a
retired senior deportation officer from the
department of Homeland Security and uncovered that
Obama is using a Connecticut Social Security number,
which he could not legal1y obtain while residing j-n HI.
Taitz made nearly 40 trips all over the nation,
lobbying for this issue and assembled a group of 200
top members of the U.S. military, Slate Representatives
and others and brought her actions to court. Media has
named Tait.z the l-eader of the movement. Instead of
supporting her Berg and Kreep attacked her, defamed and
slandered her in the eyes of the clients, in the media
and in the eyes of judges, including judge Carter in
this district. Berg instituted a $800 million dollarsfrivolous lega1 action aqainst. her for the sole
purpose of harassment. He claimed that hj-s paralegal
and he were defamed by Taitz' publication of an
investigator's report. of Liberi's crj-minal record. He
claimed t.hat she was a different Lisa Liberi from PA
not Lisa Liberi, a convicted felon from CA.
When Taitz demanded to see Liberi- | s PA drivers license,Berg refused to present it, making a baseless
accusation that attorney Ta:-tz tried to hi-re a hit man
to kilI Liberi and kidnap children of his web master
Linco.Ln v Daylight Opposition to Pro Hac Vice 10
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Case 8:10-cv-01573-AG -PLA Document43 FiledA2l15l11 Page 11 of 17 Page lD#:1 099
Lisa Ostell-a. Judge Robreno in Eastern District of PA
rul-ed that there was no basis for the allegations and
found Berg, Liberi and Ostella not beli-evabl-e aswitnesses. Exhibit 5 Order by Judge Robreno, Exhibit 6
59 E motion by Taitz.
fp this time Tait z Ls being attacked by both the
Pl-aintiff, Charles Lincol-n, and his proposed attorneyPhilip Berg, both of whom have a lengthy history offiling frivolous 1ega1 actions for purpose of
harassment and lengthy history of sanctions.
Pl-aintiff Charles Lincoln has a long history of filingfrivolous law suits and filing documents, t.hat
according to his crlminal indictment and motions by the
government, forged. Exhibit J, Criminaf number A-99-
CR-275-WS United States v Lincoln
Governments' Response describe multiple arrests ofCharles Lincoln for theft, ds well as a scheme, where
Li-ncol-n de facto stole from his own clients when hetendered his l-aw cli-ents a bogrus court receipt and
instead deposited funds in his personal bank account
unCer a bogus Social Security number. After lincoln was
convicted and resigned from the Texas bar in a plea
bargain aqreement, he contj-nued filinq frivolous law
suits.Lincoln fil-ed so many frivolous law suits in federaland st.ate courts in TX, that he was sanctioned $60,500
in the state court and later $150,000 by Chief Judge ofthe Western District of TX Hon. Walter Smith. A motion
Lincoln v Daylight Opposition to Pro Hac Vice 11
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Case 8:10-cv-01573-AG -PLA Document 43 Frled 02115111 Page 12 of 17 Page lD
#:1 1 00
for sanctions against Lincoln was filed by the attorney
General of TX Greg Abbott on behalf of multiple judges,
who were continuously harassed by Lincoln and otherparties, who were his de facto cl-ients. Lincolnrs
sanctions incl-uded not only aggregate $210,500, but an
order from Chief District Judge Wal-ter Smith, whereby
Lincoln is forbidden to file any legal actions in any
federal courts in the stat.e of TX and forbidden to
remove from State courts any cases to Federal courts
unt.il Lincoln pays i-n full $150,000 of sanctions
assessed by Chief Judge Walter Smith.
Your Honor has reviewed the First Amended Complaint in
this case and issued a tentalive ruling to dismiss t2
out of 13 causes of action and the defendants move this
court not to give the Plaintiff leave to amend due to
his extensive history of filing frivolous l-aw suits for
purpose of harassment. While defendants vehemently deny
the allegations brought by the Plaintiff and assertthat not only the defendants do not owe anylhing to t.he
Plaintiff, but the Pfaintiff actually owes refund of
moneys paid and damages, even if the court were to
Lreat arguendo the remaining cause of action as true,
this remaining cause of action cannot be sustained in
FeCeral court due to lack of subject matterjurisdiction and therefore the whole case needs to be
di-smissed.
If arguendo this court does not dismiss the remaining
cause of action, Defendants, also move this court to
Linco.ln v Daylight Opposition tc Pro Hac Vice ':2
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Case 8.10-cv-01 573-AG -PLA Document 43 Ftled 0215111 Page 13 af 17 Page lD#"1141
extend the order by Chief Judge Walter Smith from the
Western District of TX and preclude Lincoln from
proceeding with this remaining cause of action and anyand all other causes of actions or other l-aw suits inthis federal- court until he pays $150,000 of sanctions
assessed agrainst hiim by the Chief District Judge Hon
walter smith in TX.
Defendants are greatly concerned that Lheir 4, 5th and
9 th Amendment Due Process rights will be detrimentallyaffected if pro hac vice is granted to Berg and if thisduo of legal terrorists is allowed a l-eave to amend a
complaint that was already amended.
ST'MIMRY
L. Due to aJ.J. of the above Defendants velrementJ-y oppose
pro hac wice appJ-ication for PhiJ-ip Bergr and
respectfully move this court to deny AppJ.ication for
Pro Hac Vice submitted by Philip J. Berg
2. Defendants move this court not to grant thePJ.aintiff a leave to anend Lris First Amended CompJ.aint.
3. Defendants respectfuJ-J-y move this court to extend to
the Central District of CA a sanctions order issued on
March 25, 2008 by the Chief District ,Judge Wa.lter Smith
in AX in case W-08C4-010 , whereby Lincoln is precJ-uded
from proceeding in this jurisdiction with this case or
any other case untiJ- he pays $150 r 000 assessed against
him in U.S. Distriet Court for the lfestern Districts ofTX, whictr was extended to Eastern, Southern and
Northern District of TX.
L:ncoln v Daylight Cpposilion io Pro Hac Vice 13
Case 8:11-cv-00485-AG -AJW Document 175-2 Filed 04/18/11 Page 15 of 19 Page ID#:4085
8/7/2019 LIBERI v TAITZ (C.D. CA) - 175.2 - Exhibit opposition to pro hac vice of Berg in case 10-1573 - gov.uscourts.cacd.49…
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1752-exhibit-opposition-to-pro-hac-vice-of-berg 16/19
Case B:1 0-cv-01 573-AG -PLA Document 43 Filed 02115111 Page 14 of 17 Page lD
#:1102
02.14.20rL
l s / orty Tai-tz, EsQ
Counsel for Orly Taitz, inc, "Defend Our FreedomsFoundatioll" and "Appealing Dentistry"
PROOF OF SERVICE
f certify ttrat abowe plea*ingswere served by ECF arrd/
or mai]- ot] A2 . t4 " ?ALL on
Gary Kreep
932 D- str. ste 2
Lincoln v Daylight opposition io Pro Hac Vice 74
Case 8:11-cv-00485-AG -AJW Document 175-2 Filed 04/18/11 Page 16 of 19 Page ID#:4086
8/7/2019 LIBERI v TAITZ (C.D. CA) - 175.2 - Exhibit opposition to pro hac vice of Berg in case 10-1573 - gov.uscourts.cacd.49…
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1752-exhibit-opposition-to-pro-hac-vice-of-berg 17/19
Case 8:10-cv-01573-AG -PLA AU$111 Page 16 of 17 Page lD
drsciplinary heari-ng f iled on the web site of t.he
Disciplinary Board of PA
2.A sulnmary of criminal convictions of Lisa Liberi is a
true and correct copy of such sumlnary posted on the web
cite for the San BernarCino CA Superior Court
3. A letter from the San Bernardino District Attorney
is a true and correct letter recerved by Taitz via e-
mail and mail
4. A L2.23.2010 order by JuCge Eduardo F.obreno is a
true and correct copy of such order issue in Liberi v
Taitz 09-1898 Eastern District of PA
5. Rule 59E motion 1s a true and Correct copy of such
motion filed by Taitz j-n 09-1898 Eastern distri-ct of PA
Liberi v TatLz
6. Criminal number A-99-CR-275-WS United States v
Lincoln Governments I Response is a true and cgrrect
copy of such response filed in the case
7 , Third party defencants Jr-idges Higqinbotham and Mac
Master motion for sanction against Charles Lincoln and
Daniel Simon is a true and correct copy of such motion
filed in Greg Abbott v Daniel si-mon 06:08-cv-10 wss.
8. March 25, 2008 order by Judge walt.er smith in w-
08CA-010 granting $150,000 sanctions agiainst Lincoln
and preclusion from filingin federal courts in TX, is
a true and correct order filed in this case '
Affiant furt.her saYS not
Docunrent 43 Filed#.1144
Lincoln v Baylight Cpposition to Pro Hac Vice 1-5
Case 8:11-cv-00485-AG -AJW Document 175-2 Filed 04/18/11 Page 17 of 19 Page ID#:4087
8/7/2019 LIBERI v TAITZ (C.D. CA) - 175.2 - Exhibit opposition to pro hac vice of Berg in case 10-1573 - gov.uscourts.cacd.49…
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1752-exhibit-opposition-to-pro-hac-vice-of-berg 18/19
Case 8:10-cv-01573-AG -PLA Document 43 Filed AZ15l11 Page 17 of 17 Page lD
#.1105
/s/ Dr. orly Taitz, ESQ
02.14.20rr
Lancoln v Davlight Opposition to Pro Hac Vice L]
Case 8:11-cv-00485-AG -AJW Document 175-2 Filed 04/18/11 Page 18 of 19 Page ID#:4088
8/7/2019 LIBERI v TAITZ (C.D. CA) - 175.2 - Exhibit opposition to pro hac vice of Berg in case 10-1573 - gov.uscourts.cacd.49…
http://slidepdf.com/reader/full/liberi-v-taitz-cd-ca-1752-exhibit-opposition-to-pro-hac-vice-of-berg 19/19
case 8:10-cv-01 573-AG -PLA Document 43 Filed az15l11 Page 15 of 17 Page lD
#:1103
F.amona CA 92065
Attorney for Plaintiff
Jonathan Ross
Arnold Levine
Mark Melo
Bradley and Gmelich
700 North Brand Boulevard, 1Oth Floor
Glendale, CA 9L203-L422
Attorneys for DaYlight Chemical
and Yosef Tal_Lz
Willi-am Pallares
Bart Becker
Lewis Brisbois
North Figueroa str L2Lh floor
Los Angeles, CA 90012-264Lattorneys for Dr. orly Taitz and Law offices of orly
ICTLLL
Affidawit of OrJ.Y Taitz
I certify under penalty of perjury anc under the laws
of CA, that' I' Orly Taitz' over 18 years old, do not
suffer fromany mental impairment and have personal
knowledge of the following:
l.ACopyoftheDisciplinaryhearingforAttorneyPhilip J. berg is a true and correct copy of such
L.incoln v Daylight Oppcs.ltlon to Pro Hac Vice 15
Case 8:11-cv-00485-AG -AJW Document 175-2 Filed 04/18/11 Page 19 of 19 Page ID#:4089
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