Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

Embed Size (px)

Citation preview

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    1/25

    EXHIBIT "R"

    Case: 10-3000 Document: 003110370453 Page: 1 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    2/25

    Case No. 10-3000

    _______________________________________________________

    UNITED STATES COURT OF APPEALS

    FOR THE THIRD CIRCUIT_______________________________________________________

    LISA LIBERI, et al,

    Plaintiffs Appellees,

    v.

    ORLY TAITZ, et al,

    Respondents Appellants.

    ______________________________________________________

    On Appeal from the U.S. District Court, Eastern District of Pennsylvania,Case No. 09-cv-01898 ECR

    Judge Eduardo C. Robreno______________________________________________________

    VERIFICATION OF DEAN R. PICL, Esquire

    _______________________________________________________

    Philip J. Berg, EsquirePennsylvania I.D. 9867

    Law Offices of Philip J. Berg555 Andorra Glen Court, Suite 12

    Lafayette Hill, PA 19444-2531

    Phone: (610) 825-3134

    Facsimile: (610) 834-7659Email: [email protected]

    Attorney for Appellees

    Case: 10-3000 Document: 003110370453 Page: 2 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    3/25

    VERIFICATION OF DEAN R. PICL

    I, DEAN R. PICL, am over the age of eighteen (18) and am not a party to

    the within action. I verify that the statements made in the foregoing are true and

    correct to the best of my knowledge, information and belief. The undersigned

    understands that the statements therein are made subject to the penalties of 18 Pa.

    C.S. Section 4904 and the laws of the United States relating to unsworn

    falsification to authorities. 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 am a Lawyer, licensed to practice law in the State of California, the

    Supreme Court.

    2. I have known Lisa Liberi and her family for approximately five (5)

    years. I am also familiar with the underlying lawsuit which gives rise to the

    within Appeal.

    3. On Monday, November 22, 2010, I received an email from

    [email protected]. I believed the email came from Lisa Liberi,

    see EXHIBIT "1". I responded to this email on November 22, 2010 at

    12:24, see EXHIBIT "2". I received a second email from

    U.S. District Court for the Central District of California and the U.S.

    1

    Case: 10-3000 Document: 003110370453 Page: 3 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    4/25

    [email protected] on Tuesday, November 23, 2010 at 4:02:56

    which I also believed was from Lisa Liberi and was occasioned by my

    response to the first email, see EXHIBIT "3". I again responded, see

    EXHIBIT "4".

    4. On the evening of November 23, 2010, Lisa Liberi sent me a copy of

    the letter faxed to Judge Robreno in the U.S. District Court, Eastern District

    of Pennsylvania, Case No. 09-cv-01898 ECR, the underlying case.

    5. I received a third email from [email protected], that I did

    not respond to, see EXHIBIT "5".

    6. On November 24, 2010, I called Lisa Liberi regarding these emails I

    had received and learned that Lisa Liberi did not send me the emails from

    email address [email protected]. Shortly thereafter, I was

    furnished with information which demonstrated that the website had been

    set-up in Lisa Liberi's name by one or more other parties.

    7. I immediately forwarded the emails I had received from

    [email protected] and the responses thereto, attached hereto as

    EXHIBITS "1" through "5", to Lisa Liberi.

    2

    Case: 10-3000 Document: 003110370453 Page: 4 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    5/25

    and subject to the penalties of 18 Pa. C.S. Section 4904 that the foregoing is true

    __________________________

    Dean R. Picl

    and correct. Executed this 5th day of December 2010 at Covina, California.

    s/Dean R. Picl

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

    3

    (Signature received by fax - see attached)

    Case: 10-3000 Document: 003110370453 Page: 5 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    6/253

    Case: 10-3000 Document: 003110370453 Page: 6 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    7/25

    EXHIBIT "1"

    Case: 10-3000 Document: 003110370453 Page: 7 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    8/25

    > Date: Mon, 22 Nov 2010 11:09:31 +0000> From: [email protected]

    > To: [email protected]; [email protected];

    [email protected]; [email protected]; [email protected];

    [email protected]; [email protected]; [email protected]> Subject: lisaliberi.com

    >> Take a look at my new website:

    >

    > http://lisaliberi.com

    >> Let me know what you think.

    >> Thanks!

    >=

    Case: 10-3000 Document: 003110370453 Page: 8 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    9/25

    EXHIBIT "2"

    Case: 10-3000 Document: 003110370453 Page: 9 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    10/25

    On Mon, 22 Nov 2010 12:24:08 -0800, DEAN PICL wrote:

    Unless you can suggest to me a good reason this, it does not please me.

    Case: 10-3000 Document: 003110370453 Page: 10 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    11/25

    EXHIBIT "3"

    Case: 10-3000 Document: 003110370453 Page: 11 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    12/25

    Date: Tue, 23 Nov 2010 04:02:56 +0000From: [email protected]

    To: [email protected]

    Subject: RE: lisaliberi.com

    I'm fabulous enough and I'm far to fabulous to care whether it pleases you or

    not.

    THE Fabulous Felon

    Case: 10-3000 Document: 003110370453 Page: 12 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    13/25

    EXHIBIT "4"

    Case: 10-3000 Document: 003110370453 Page: 13 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    14/25

    On Tue, 23 Nov 2010 12:03:40 -0800, DEAN PICL wrote:

    I(f) (sic) you are going to circulate the photo and felony tag, it certainlyjeopardizes your claim of damage done by Orlly. If you don't care, don't ask.

    Case: 10-3000 Document: 003110370453 Page: 14 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    15/25

    EXHIBIT "5"

    Case: 10-3000 Document: 003110370453 Page: 15 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    16/25

    Date: Tue, 23 Nov 2010 21:28:53 +0000From: [email protected]

    To: [email protected]

    Subject: RE: lisaliberi.com

    The Lisa Liberi who lives in Pennsylvania and works as a paralegal for Mr. Philip

    J. Berg, Esquire, is not the Lisa Liberi who lives in Santa Fe, New Mexico. I knowthis because Pennsylvania Lisa Liberi has submitted to federal court sworn

    affadavits under penalty of perjury that she is not New Mexico Lisa Liberi.

    Therefore, Pennsylvania Lisa Liberi and Mr. Philip J. Berg, Esquire have nointerest in this website and it has nothing to do with them or their law suit unless

    Pennsylvania Lisa Liberi and New Mexico Lisa Liberi are the same person. IF theyare the same person, then Mr. Philip J. Berg, Esquire and Pennsylvania / New

    Mexico Lisa Liberia have perpetrated a fraud upon a federal court, which cannotbode well for them.

    I have made no claim for damages to this point and am not represented by Orly

    Taitz. Nor, I am party to any lawsuit with Orly Taitz or anyone else at this time.

    My motivations for this action are my own and have nothing to do with Orly Taitzor anyone else.

    The Fabulous Felon

    Case: 10-3000 Document: 003110370453 Page: 16 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    17/25

    EXHIBIT "S"

    Case: 10-3000 Document: 003110370453 Page: 17 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    18/25

    Lisa Liberi, THE Fabulous FelonWelcome to my fabulous world of crime, swindles, perjury, fraud, nd sleaze

    read more

    Philadelphia Lisa is trying to steal my identity

    Lisa, Lisa, Lisa!I can hardly believe it. Philadelphia Lisa is trying really hard to be a criminal, but

    she's not smart like me. If someone's going to steal my identity, they're going to have to...

    Philadelphia Lisa is trying to steal my identity

    by Convicted Felon on DECEMBER 3, 2010 - 0 COMMENTS

    Lisa, Lisa, Lisa!

    I can hardly believe it. Philadelphia Lisa is trying really hard to be a criminal, but

    shes not smart like me. If someones going to steal my identity, theyre going to

    have to be smarter than Philadelphia Lisa. Anyway, Honey, if youre going to steal

    someones identity, make it someone with some money worth stealing!

    Get this!

    Philadelphia Lisa Liberis attorney, Mr. Philip J. Berg, Esquire wrote an URGENT

    URGENT URGENT letter to a judge in which Berg states, The domain name,

    lisaliberi.com was privately registered through Direct Internet Solutions The person

    who purchased lisaliberi.com and set-up the website http://lisaliberi.com and the

    email Direct Internet Solutions, they finally removed the private details and

    published the owner of the site.

    The only problem is that this statement isnt true. Heres the subpoena sent by Mr.

    Philip J. Berg, Esquire on November 15th, 2010, demanding that the information be

    provided. This subpoena is signed only by Mr. Philip J. Berg, Esquire and is from the

    U. S. District Court in Oregon. Im not a lawyer, Im only the Fabulous Felon, but I

    sure do wonder why nothing was said about the subpoena in the letter to the judge

    unless theres something fishy about it. Perhaps, this subpoena is not a legally drawn

    document, which means that Mr. Philip J. Berg, Esquire used it fraudulently to get

    the information he desired.

    As Ive said before, Im New Mexico Lisa Liberi, the Fabulous Felon, not Philadelphia

    Lisa Liberi, so I just dont understand why that stupid woman keeps telling people

    that shes me unless shes just jealous because Im fabulous and shes not.

    Im psychic and Ive been having long conversations with Norman. Hes not pleased

    and hes been rolling over in his grave because hes so upset, he cant sleep.

    P. S. I guess Philadelphia Lisa Liberi and Mr. Philip J. Berg, Esquire didnt know what

    they were talking about when they accused someone else of creating my website.

    Dumb, just dumb. Id call those two Dumb and Dumber, but it would be a waste of

    time figuring out which one is which.

    CATEGORIES

    Crime Pays Very Well,

    Thank You!Me! Me! All About Me!

    My Fans

    RECENT POSTS

    Philadelphia Lisa is trying

    to steal my identity

    My Future!

    Some people cant take a

    joke

    Let me teach you the tools

    of my tradeI just received a fabulous

    gift

    RECENT COMMENTS

    Convicted Felon on Some

    people cant take a joke

    ITDph on Some people cant

    take a joke

    Convicted Felon on Some

    people cant take a joke

    lilachers on Some peoplecant take a joke

    ITDph on Some people cant

    take a joke

    Home About Me! Me! Me! Im So Glamorous My Fabulous Resume!

    Search for:

    ARCHIVES

    December 2010

    November 2010

    META

    Register

    Log in

    Entries RSS

    Comments RSS

    WordPress.org

    delphia Lisa is trying to steal my identity | Lisa Liberi, THE Fabulou... http://lisaliberi.com/crime-pays-very-well-thank-you/philadelphia-

    12/3/2010 1

    http://lisaliberi.com/crime-pays-very-well-thank-you/philadelphia-lisa-is-trying-to-steal-my-identity/Case: 10-3000 Document: 003110370453 Page: 18 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    19/25

    My Future!

    This entry was posted in Crime Pays Very Well, Thank You!. Bookmark the permalink.

    2010 Lisa Liberi, THE Fabulous Felon

    This is a parody website. The actual criminal records are correct. The rest is not true. What do you expect from a fabulous felon and liar?

    Leave a Reply

    You must be logged in to post a comment.

    delphia Lisa is trying to steal my identity | Lisa Liberi, THE Fabulou... http://lisaliberi.com/crime-pays-very-well-thank-you/philadelphia-

    12/3/2010 1

    Case: 10-3000 Document: 003110370453 Page: 19 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    20/25

    http://lisaliberi.com/wp-content/uploads/2010/12/Liberi_ltr_to_Robreno_Defcopies_D11_23_2010.pdf

    Case: 10-3000 Document: 003110370453 Page: 20 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    21/25

    http://lisaliberi.com/wp-content/uploads/2010/12/public_domain_registry-.pdf

    Case: 10-3000 Document: 003110370453 Page: 21 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    22/25

    EXHIBIT "T"

    Case: 10-3000 Document: 003110370453 Page: 22 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    23/25

    http://lisaliberi.com/wp-content/uploads/2010/12/public-domain-registry-.pdf

    Case: 10-3000 Document: 003110370453 Page: 23 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    24/25

    Case: 10-3000 Document: 003110370453 Page: 24 Date Filed: 12/06/2010

  • 8/8/2019 Liberi v Taitz Appellees Exbs R Thru T to Their Emergency Motion for a TRO

    25/25

    Case: 10-3000 Document: 003110370453 Page: 25 Date Filed: 12/06/2010