Liberi v Taitz Objections and Opp to Intelius Req for Judicial Notice Doc 389

8/4/2019 Liberi v Taitz Objections and Opp to Intelius Req for Judicial Notice Doc 389

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Liberi, et al, Plaintiffs Opposition and Objections to Defendant Intelius, Inc. Request for Judicial Notice 1

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Philip J. Berg, EsquirePennsylvania I.D. 9867

LAW OFFICES OF PHILIP J. BERG

555 Andorra Glen Court, Suite 12Lafayette Hill, PA 19444-2531

Telephone: (610) 825-3134E-mail:[email protected] Attorney in pro se and for Plaintiffs

UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA,

SOUTHERN DIVISION

LISA LIBERI, et al,

Plaintiffs,

vs.

ORLY TAITZ, et al,

Defendants.

:::::::::::::

::::

CIVIL ACTION NUMBER:

8:11-cv-00485-AG (AJW)

PLAINTIFFS OPPOSITION AND

OBJECTIONS TO DEFENDANT

INTELIUS, INC. REQUEST FOR

JUDICIAL NOTICE

Date of Hearing: October 17, 2011Time of Hearing: 10:00 a.m.Location: Courtroom 10D

Plaintiffs, by and through their undersigned counsel, Philip J. Berg, Esquire

files the within Objections to Defendant Intelius, Inc.s Request for Judicial Notice

as the Documents requested Judicial Notice of are notpublic record and are in full

dispute as they are not the documents portrayed by Defendant Intelius, Inc. and the

accuracy of the documents are under dispute as the documents Intelius, Inc. is

Case 8:11-cv-00485-AG -AJW Document 389 Filed 09/24/11 Page 1 of 6 Page ID#:9154


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requesting Judicial Notice of are not the documents Plaintiffs received as claimed

by Defendant Intelius.

1. It is heavily disputed that Intelius Exhibit 1 to the Declaration of

Benjamin Nelson [Nelson Decl] is in fact the report that Orly Taitz obtained and

received on April 12, 2009. Orly Taitz did not have an Intelius account or

accounts with any of the Reed Defendants. See the Declaration of Charles Edward

Lincoln, III filed July 25, 2011, Docket No. [DN] 313.

2. Exhibit 2 to Nelsons Decl is under dispute as it is not the report

Plaintiff Lisa Liberi received on herself on April 10, 2010 through

www.intelius.com. See the Declaration of Lisa Liberi with the report she obtained

directly from Intelius, Inc. and the receipt for said report.

3. Plaintiffs have not incorporated into their Complaint Intelius, Inc.s

Terms of Service as falsely claimed by Intelius, Inc. See Intelius, Inc.s Request for

Judicial Notice, pg. 1, 4.

4. Nelsons Decl. Exhibit 6, Letter from Lisa Ostella, is asking for

copies of all reports supplied to third parties on behalf of her and her spouse. See

Nelsons Decl., Exhibit 6. Lisa Ostellas letter is not simply asking for who

obtained her reports as stated by Benjamin Nelson on behalf of Intelius, Inc. and

their attorneys. See Intelius, Inc.s Request for Judicial Notice, pg. 2, 6.

Moreover, Plaintiff Lisa Ostella sent her letter with information that Intelius, Inc.



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demanded, which Mrs. Ostella believed would be kept in strict confidence

Therefore, Plaintiffs Object to Intelius, Inc.s and their attorneys

mischaracterization of Lisa Ostellas letter and the publication thereof.

5. Plaintiffs Object to Intelius, Inc.s supposed response referred to in

their Request for Judicial Notice on pg. 2, 7. Plaintiff Lisa Ostella never received

said letter. See the Declaration of Lisa Ostella.

6. Intelius, Inc.s Frequently Asked Questions are not incorporated

into Plaintiffs FAC referred to in Intelius, Inc.s Request for Judicial Notice on pg

2, 8.

7. Plaintiffs Object to Intelius, Inc.s statement to the Court on page 3

paragraph 2, These documents available from Intelius website are the proper

subject of judicial notice because they are incorporated into the First Amended

Complaint This is untrue and nowhere in Plaintiffs First Amended Complaint

will any party find reference to Intelius, Inc. Terms of Service and/or Frequently

Asked Questions.

8. Plaintiffs Object to Intelius, Inc.s statement to the Court on page 3

paragraph 2, Accordingly, the Court is authorized to take judicial notice of pages

made available to consumers performing searches through Intelius website,

including Intelius Terms and Conditions and Frequently Asked Questions

Defendant Intelius, Inc. is attempting to mislead this Court and confuse the issues.



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The within litigation has nothing to do with Plaintiffs conducting searches or

Plaintiffs specific accounts with Intelius, Inc. Other than the fact, Intelius, Inc

violated Californias Information Practices, Cal. Civ. Code 1798, et seq. and

therefore are liable for damages and statutory damages as Plaintiffs Lisa Liberi and

Lisa Ostella were customers of theirs at the time their private data was disclosed.

I. ARGUMENT:

9. Not only is Intelius, Inc. asking this Court to take Judicial Notice of

documents that are not incorporated into Plaintiffs FAC, they are attempting to

mislead this Court into believing documents they are providing are the genuine

documents, which they are not. Further, the documents are not of public record as

falsely claimed by Intelius, Inc.

10. The documents Defendant Intelius, Inc. is requesting Judicial Notice

of are not public records. In fact, several of them contain full Social Security

numbers, dates of birth, home addresses, etc.

11. It is well established, as a general rule, our Courts "may not consider

any material beyond the pleadings in ruling on a Federal Rules of Civil Procedure

[Fed. R. Civ. P.] 12(b)(6) Motion."Lee v. City of Los Angeles, 250 F.3d 668, 688

(9th Cir. 2001). (internal citation and quotation marks omitted). Our Courts may

consider materials that are submitted with and attached to the Complaint. Id. Our



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Courts may also consider unattached evidence on which the complaint

"necessarily relies" if: (1) the complaint refers to the document; (2) the document

is central to the plaintiff's claim; and (3) no party questions the authenticity of the

document. Marder v. Lopez, 450 F.3d 445, 448 (9th Cir. 2006);Lee, 250 F.3d at

688.

12. Our Courts may also take Judicial Notice of matters of public

record, Federal Rules of Evidence [Fed. R. Evid.] 201. See alsoLee 250 F.3d at

689. Our Courts cannot however, take Judicial Notice of facts that may be

subject to reasonable dispute.Id. at 689. To be more specific, our Courts may

not, on the basis of evidence outside of the Complaint, take Judicial Notice of facts

favorable to Defendants that could reasonably be disputed. See Id. at 689-90.

13. The documents Defendant Intelius, Inc. is requesting Judicial Notice

of are under full dispute; are notpublic records; are not incorporated in or attached

to Plaintiffs First Amended Complaint and are outside of the pleadings.

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II. CONCLUSION:

14. For the reasons outlined herein, Plaintiffs respectfully Request this

Court to Deny Defendant Intelius, Inc.s Request for Judicial Notice.

Respectfully submitted,

Dated: September 23, 2011 /s/ Philip J. BergPhilip J. Berg, Esquire

Pennsylvania I.D. 9867LAW OFFICES OF PHILIP J. BERG


Telephone: (610) 825-3134E-mail:[email protected]

Attorney in Pro Se and Counsel foPlaintiffs



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Declaration of Philip J. Berg, Esquire 1

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Philip J. Berg, Esquire (PA I.D. 9867)E-mail:[email protected]



Telephone: (610) 825-3134 Fax: (610) 834-7659Attorney in pro se and for Plaintiffs



SOUTHERN DIVISION

LISA LIBERI, et al,

Plaintiffs,

vs.

ORLY TAITZ, et al,

Defendants.

:

::::::::::::::

CIVIL ACTION NUMBER:8:11-cv-00485-AG (AJW)

DECLARATION OF PHILIP J.

BERG, ESQUIRE


DECLARATION OF PHILIP J. BERG, ESQUIRE

I, Philip J. Berg, Esquire, am over the age of 18 and am a party to the within

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

and would competently testify. I am making this Declaration under the penalty of

perjury of the Laws of the United States pursuant to 28 U.S.C. 1746.

1. I am an Attorney in good standing, licensed to practice law in the

Commonwealth of Pennsylvania. I am licensed to practice in the U.S. District

Case 8:11-cv-00485-AG -AJW Document 389-1 Filed 09/24/11 Page 1 of 6 Page ID#:9160


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Courts, Middle and Eastern District of Pennsylvania; Third Circuit Court of

Appeals; the Pennsylvania Supreme Court; and the U.S. Supreme Court.

2. Intelius with their Motion to Dismiss [MTD] has filed a Declaration

from Benjamin Nelson [Nelson] who claims to be the Custodian of Records for

the past six [6] years.

3. Nelson states that I sent a letter on behalf of Plaintiff Lisa Liberi

[Liberi] and dealt with incorrect information they have on file for my client. My

letter, as demonstrated by Nelsons Exhibit 5 also pertained to Plaintiff Lisa

Ostella [Ostella] and dealt with incorrect information Intelius maintains on her.

4. Nelson also states they are not a Consumer Credit Reporting

Agency and they are not required to comply with the Fair Credit Reporting Act

[FCRA]. To the contrary, I located several locations on Intelius website, that

you can access by going to www.intelius.com that states they are a Consumer

Credit Reporting Agency and comply with the FCRA as well as other State and

Federal laws.

5. On file with the United States Security Exchange [SEC] is Intelius

October 19, 2009 Form S-1 Registration and located at

http://ipo.nasdaq.com/edgar_conv_html%5C2009%5C10%5C19%5C0000950123-

09-051082.html. Intelius states on pages 24 and 25 in their report to the SEC:

Because we use personal information in providing our information

services, we are subject to government regulation and vulnerable to



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adverse publicity. We provide many types of data and services thatalready are subject to regulation under the FCRA, Gramm-Leach-

Bliley Act, Drivers Privacy Protection Act and, to a lesser extent,various other federal, state and local laws and regulations. Violation

of these laws or regulations may result in substantial fines, judgmentsand other penalties.

These laws and regulations are designed to protect the privacy of the

public and to prevent the misuse of personal information in themarketplace.

6. Intelius repeats that they are a Consumer Reporting Agency and

follows the FCRA in their enterprise agreement located on their website at

http://www.intelius.com/enterpriseagreement.php. In this agreement, Intelius

states numerous times they are a consumer reporting agency governed by the

FCRA.

7. Intelius repeats they are a Consumer and Credit Reporting Agency in

their Security and compliance statements located on their website at

http://www.intelius.com/corp/security. In this publication by Intelius, they state:

Intelius recognizes the sensitivity surrounding many of its

applications and the data they rely on. As such, Intelius' informationsecurity policy addresses security at all levels: personnel, technology

and operations.

Intelius is a certified credit reporting agency.



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8. And, in Intelius TalentWise Agreement located at

https://www.talentwise.com/terms.html, Intelius again confirms they are governed

by the FCRA because they are a Consumer Reporting Agency:

DUE TO THE SENSITIVE AND HIGHLY REGULATEDNATURE OF THE DATA AND INFORMATION YOU AND

YOUR ORGANIZATION WILL GAIN ACCESS TOTHROUGH INTELIUS SCREENING SOLUTIONS LLC

(d/b/a "TALENTWISE") Intelius Screening Solutions LLC(d/b/a "TalentWise") is a consumer reporting agency and

provides consumer reports and investigative consumer reports("Screening Reports") as defined by the Fair Credit Reporting

Act ("FCRA")

9. The statements of Mr. Nelson are not accurate. I also have copies of

the background checks conducted on Plaintiff Lisa Liberi. Each background report

Mrs. Liberi obtained from Intelius and U.S. Search contained her full Social

Security number, date of birth, name, address, spouses name and other information

identified to her. The reports obtained by Mrs. Liberi were not generalized

searches of only a name.

10. Mr. Nelson states Defendant Orly Taitz obtained the same report as

Lisa Liberi. With this, Mr. Nelson has confirmed and substantiated Plaintiffs

allegations against Intelius. The reports Mrs. Liberi obtained were reports

governed by the FCRA as they were classified by Intelius as Consumer Reports

and that is the same Report obtained by Orly Taitz and Neil Sankey on Mrs. Liberi

as stated in Mr. Nelsons Declaration.



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11. The reports attached to Mr. Nelsons Declaration as Exhibit 1 and

2 are not the same reports obtained by Mrs. Liberi.

12. I am very concerned with the fact Intelius has spoiled evidence and

deleted evidence. This is very prejudicial to my clients. All evidence should have

been preserved by Intelius and their Attorneys as they were aware they were in

litigation.

13. Intelius has deleted Plaintiff Lisa Ostellas account; deleted al

searches performed by Mrs. Ostella; provided reports which do not match or

contain the same data as those purchased by Mrs. Liberi; and Intelius, although

they claim to maintain all searches performed, stated Mrs. Ostella never had an

account which had two [2], one of which was recently opened.

14. Intelius has also deleted all files they had available on both Mrs

Liberi and Mrs. Ostella. When attempting to search Mrs. Liberis name, the

reports provided by Mr. Nelson do not come up, nor do the reports Mrs. Liberi has

purchased.

15. Intelius is a Consumer Reporting Agency bound by the Fair Credit

Reporting Laws; California Laws; and Federal Trade Commission [FTC]

regulations.



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16. Intelius should have had safety precautions in place, had they of

Defendant Orly Taitz, Yosef Taitz, Neil Sankey and the other Sankey Defendants

would not have been able to obtain my clients private data from Intelius.

17. Intelius did not have a permissible or legal purpose in purchasing my

clients private data from the Reed Defendants and then selling it to third parties.

18. Mr. Nelson has also confirmed three [3] additional parties Mrs

Liberis private data was sold to, without any type of permissible purpose.

19. For the reasons outlined in Plaintiffs Opposition and Brief thereto

Defendant Intelius, Inc.s Motion to Dismiss must be Denied.

I declare under the penalty of perjury of the Laws of the United States and

California that the foregoing is true and correct.

Executed this 24th day of September, 2011 in the Commonwealth of

Pennsylvania, County of Montgomery.

/s/ Philip J. Berg

Philip J. Berg, Esquire, Declarant



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Declaration of Lisa Liberi 1

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Telephone: (610) 825-3134E-mail:[email protected] Attorney for Plaintiffs



SOUTHERN DIVISION

LISA LIBERI, et al,

Plaintiffs,

vs.

ORLY TAITZ, et al,

Defendants.

:

::::::::::::::

::


DECLARATION OF LISA LIBERI


Declaration of Lisa Liberi

I, Lisa Liberi, am over the age of 18 and am a party to the within action. I

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

competently testify. I am making this Declaration under the penalty of perjury of

the Laws of the United States pursuant to 28 U.S.C. 1746.

1. I ran reports on myself through Intelius in April 2010. I purchased

two [2] separate reports at that time. The first report I purchased was a full



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5. Intelius continues stating they are not a credit reporting agency and

they do not have to adhere to the FCRA. This is contrary to Intelius statements on

their website at http://www.intelius.com/enterpriseagreement.php

http://www.intelius.com/corp/security; https://www.talentwise.com/terms.html or

what they filed in October 2009 with the U. S. Securities and Exchange

Commission (SEC) located on the SEC website a


09-051082.html, and, the terms and conditions I was required to accept to purchase

my reports. In all these locations, Intelius openly admits they are a Consumer

Reporting Agency and they adhere to the FCRA, and other State and Federal

laws, as required.

6. The terms and conditions I had to agree to for my TalentWise report

are attached hereto as EXHIBIT C and do not match the terms and conditions

attached to Mr. Nelsons Declaration as his Exhibit 4.

7. On November 1, 2010, I sent a very detailed letter to Intelius

regarding the incorrect information they maintained on me in their files. See

EXHIBIT D. I sent my letter to them with delivery confirmation by way of

priority mail through the post office. I never received my reports from Intelius, nor

did I receive any type of response.



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8. I also discovered that Intelius pulled my private data from reports they

purchased from LexisNexis and ChoicePoint, [the Reed Defendants]. I wa

never notified Intelius was purchasing reports or my private data from the Reed

Defendants; I never gave my permission, nor would I have, and I am disgusted

they resold my private data for a profit. More disgusting is the fact they sold my

private data to Orly Taitz to carry out her threats towards me; to Neil Sankey to

supply to Taitz; to K. Lawson, T. Loggia and Ms. Choy. I was never notified by

Intelius of these searches, of these reports provided on me, or any legal permissible

purpose for which Intelius provided my reports. Instead, Intelius provided my

private information without any verification, for a profit. These were not genera

searches of a name that Intelius sold to these individuals.

9. I conducted another search at www.intelius.com after receiving Mr

Nelsons Declaration. Everything pertaining to me had been deleted. There were

not any Lisa Liberis appearing with addresses in San Francisco, Virginia, or any

Liberis with the first names appearing in Mr. Nelsons report attached as his

Exhibit 2 to his Declaration. The names and addresses appearing in Mr

Nelsons report, Exhibit 2 to his Declaration were non-existent. See the screen

shots attached hereto as EXHIBIT E.

10. I always believed my identifying information, including my Social

Security number, date of birth, place of birth, maiden name, relatives names, etc



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would remain confidential and I would have full control over who my information

was supplied to, not a data broker for a profit.

11. My family and I have been severely damaged as a result of the Reed

Defendants and Intelius, freely providing my confidential information for a fee

which profits them. Although there are laws to protect my information, the Reed

and Intelius Defendants refuse to adhere to the laws and protect individuals

including my family members privacy and mine.

12. In fact these Defendants sold my information for threats to be carried

out against me, which they were. As a result, I have been severely harassed, cyber-

stalked, stalked, ridiculed, my privacy invaded, and my full identity stolen over

and over again, along with my husbands. My son has been stalked by Defendant

Taitz. As a result of the stress induced by the Defendants, I have had paramedics

at my home numerous times due to my health complications from the severe stress

I have been hospitalized for heart complications due to the stress; I have had to pay

for cardiac treatments, including but not limited to Enhanced Externa

Counterpulsation [EECP] on two (2) occasions; Echo Cardiograms; and other

cardiac testing which is very expensive.

13. Intelius simply ignored the letters from my attorney and from me

Intelius did not report the misuse of the information they provided on me and my

family to law enforcement or any other data brokers. Intelius did not report to law



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enforcement Defendants Orly Taitz, Neil Sankey, Yosef Taitzs, etc. misuse of the

information maintained with Intelius. Intelius, like the Reed Defendants, just

ignored it.


the State of California that the foregoing is true and correct.

Executed this 23rd day of September, 2011 in the State of New Mexico.

Lisa Liberi, Declarant



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28EXHIBIT A



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From: Intelius

Date: Sat, Apr 10, 2010 at 10:25 PM

Subject: Intelius Purchase Receipt - Order #30897400To: [email protected]

Hello Lisa,

Your order number30897400 was placed on April 10th, 2010, 9:20 PM (PST).

Thank you for placing your order with Intelius.com

Your credit card statement will reflect a $44.96 charge from Intelius.com.

To access your reports purchased in the last 45 days, visit View My Reports.

Order Details

1 Background ReportClub Intelius Discount. You saved $4.99.

$44.96

Total Charge $44.96

Your Savings: $4.99

Customer Service Contact Information:

Contact Us via Email.

Club Intelius Phone Number: (866) 974-6187

Service Hours: Mon - Fri, 4:30AM - 10:00PM PST

This is an automated notification. Please do NOT reply to this e-mail.

Please print this page or note the order number for future reference.

Thank you for your business and making Intelius your trusted information source.

Best Regards,

Intelius

If you would like to unsubscribe, please contact Customer Service

Exb. "A", pg



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VerificationServices

BackgroundCheck

ReversePhoneLookup

Property&Neighborhood

InformationServices

PeopleSearch

EmailSearch

SocialNetSearch

ProtectionServices

ReverseCellPhoneDirectory

IdentityProtect

Criminal&SexOffender

Busin

essServices

Em

ployeeScreening

Te

nantScreening

AllProducts&Services

Wh

atisaBackgroundReport?

ABackgroundReportcontains

informationcollectedfrompublic

reco

rdsandpubliclyavailabledata.

The

reportisdesignedasaservice

toassistyouinlocatingorverifying

anindividual'sbackground

information.Thedatawithinthe

reportiscompiledfromthousandsof

diffe

rentsourcesthatinclude

government,property,andother

publicrecordrepositories.The

Inteliusserviceorganizesand

integratesinformationtogetherasa

convenientserviceforyou.

YourReportSummary

Order#30897400

PersonSelection

AddressHistory

SingleStateCriminalCheck

PeopleSearchReport

PersonalPublicRecordsData

PropertyHistorySummary

SingleStateCivilJudgments

Name:

LisaLiberi

ReportContents

Itisimportanttounderstandthatpublicrecordsareonlyasaccurateas

theagenciesthatinputthem.

Pleasebesuretocloselyrevie

wthepublicinformationlistedaboutthein

dividualthatyoumaybe

researchinginthereport.

YourTransactionWas

Successful.

YourCreditCardWillReflectA$44.96ChargeFromIntelius.

YourOrder#is30897400.

Thankyouforplacingyourorderwith

Intelius

BackgroundReport-April10,2010

[email protected][SignOut]|MyIntelius

Help:(888)445-2727|ViewMyReports

1

of10

4/11/201012:26AM

Exb. "A", pg. 9



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RunAnotherBackgroundReport

PersonSelection

1

LisaLiberi

(909)466-9532

KnownAddress:

7349Milliken#140

RanchoCucamonga,

CA91730

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4/11/201012:26AM

Exb. "A", pg. 10



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Thisr

eportsectionlistshistorical

addre

ssesassociatedwithan

individualfrompublicrecords.An

Addre

ssHistorycanassistinflagging

addre

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public

records.Theaddressesand

phone

numbersarenotlistedindate

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andshouldbeindividually

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7349Milliken#140

RanchoCucamonga,CA

91730

1537Grandview

Upland,CA91784

4Bonito

SantaFe,NM8

7508

1

LisaLiberi

(909)466-9532

PropertyReport

2

LisaLiberi

PropertyReport

3

LisaLiberi

(505)466-2505

PropertyReport

PropertyHistorySummary

WhatisaPropertyHistory

Summary?

Thiss

ectionlistssummary,

neighbors,relativesandareadata

assoc

iatedwiththepropertywhen

availa

ble.TheRelativesand

Assoc

iatessectionlistspotential

relativ

esorpreviousoccupants

assoc

iatedwithanindividualand/or

theira

ddressfrompublicrecords.

TheN

eighborsAroundtheProperty

sectio

nliststheimmediateneighbors

aroun

dtheproperty.Thesesections

canhelpconfirmt

hepeoplelinkedto

yours

ubjectandprovideadditional

peoplethatmayhavecurrentor

forwardinginformationonthe

where

aboutsofyoursubject.

of10

4/11/201012:26AM

Exb. "A", pg. 11



24/63

Get

ACompletePropertyReport

Get

ACompletePropertyReport

ADDRESS&CONTAC

TINFO:

7349Milliken#140

RanchoCucamonga,

CA91730

(909)466-9532

CompletePropertyRe

ports

Include:

Listofall65neighborh

ood

sexoffenders

SalesHistory

MortgageInformation

SatelliteImage

AndMore

GetaComplete

PropertyReport

PROPERTYDETAILS

OwnerName

PropertyInfo

LdcCentralParkPlaza

Taxes:$11,0

01(2008)

NEIGHBORSAROUNDTHEPROPERT

Y

Name

RogerCSparks

7723MillikenAve

RanchoCucamonga,

CA91730

(909)466-7989

BackgroundCheck

ArturoPalato

7868MillikenAve

RanchoCucamonga,

CA91730

(909)945-0591

BackgroundCheck

JefferyMiller

7868MillikenAve

RanchoCucamonga,

CA91730

(909)758-0795

BackgroundCheck

GinaDuncan

7868MillikenAve

RanchoCucamonga,

CA91730

(909)244-0668

BackgroundCheck

JrG

Black

7868MillikenAve

RanchoCucamonga,

CA91730

(909)483-1349

BackgroundCheck

AREADATA

Total

Population

Avg.House

Price

A

vg.Household

Income

AreaSex

Offenders

51,9

69

$145,5

00

$50,0

47

65

ADDRESS&CONTAC

TINFO:

1537Grandview

U

land,CA91784

of10

4/11/201012:26AM

Exb. "A", pg. 12



25/63

SingleStateCr

iminalCheck

WhatisaSingleStateCriminal

Chec

k?

Thiss

ectionlistscriminalrecords

fromc

ountycourts,

departmentof

corrections,administrationofthe

courts

,andotherlegalagenciesfor

these

lectedstate.

Thetypesof

offens

esincludefelonies,

misde

meanors,sexualoffenses,and

more.

Pleasecloselyrevieweach

recordassubjectswithacommon

name

mayreturnmultiplecriminal

recordresults.

CriminalCheckDisclaimer

Custo

mersarechargedasearchfee

forexecutingaCriminalCheck.

The

CriminalCheckreportreturnsresults

which

mayincludeallcriminal

recordsornoresultsfoundonthe

individual.

Inthe

eventofusingthisservicefor

crimin

albackgroundchecks,you

shouldnotassumethatthisdata

provid

esacompleteoraccurate

historyofanyperson'scriminal

history.

Yous

houlduseextremecaution

when

interpretingtheresultsofa

crimin

albackgroundsearchforany

typeo

fpersonalverification.

Positiveorfalsematchesincriminal

searchesmaynotprovide

confirmationofanindividual's

crimin

albackground.

Pleas

ereferencetheupdatedIntelius

UserAgreementforadditional

restric

tionsregardingtheusageof

NATIONWIDECRIMINALCH

ECKOFFER

"30%

ofpeoplechangetheiraddressesnationwideeachyear...especiallycriminals"

Get$10offonaNationwideCriminalCheckforLisaLiberinow.

of10

4/11/201012:26AM

Exb. "A",pg. 13



26/63

thisda

ta.

IDENTIFICATION

LisaLiberi

CA

SOURCE:

CA

IDENTIFICATION

LisaALiberi

CA

SOURCE:

CA

IDENTIFICATION

LisaRLiberi

CA

SOURCE:

CA

DOB:

May

28

,1965

CRIMINALCHECKFORALL

LISALIBERIINTHESTATEOFCA

Record1of4

OFFENSEDETAILS

CASENUMBER:

FS

B044914-ConfirmCaseattheCourthouse

COUNTY

CHARGED:

Sa

nBerna

dino

DISTRICT:

SAN

BERNARDINO

SUPERIOR

OFFENSEDATE:

06

/30/2004

OFFENSE

COUNTY:

San

Berna

dino

Record2of4

OFFENSEDETAILS

CASENUMBER:

FS

B044914-ConfirmCaseattheCourthouse

COUNTY

CHARGED:

Sa

nBerna

dino

DISTRICT:

SAN

BERNARDINO

SUPERIOR

OFFENSEDATE:

06

/30/2004

OFFENSE

COUNTY:

San

Berna

dino

Record3of4

OFFENSEDETAILS

CASENUMBER:

03

0202LL-ConfirmCaseattheCourthouse

COUNTY

Sa

nBerna

dino

DISTRICT:

SAN

BERNARDINO

SUPERIOR

of10

4/11/201012:26AM

Exb. "A", pg. 14



27/63

CivilJu

dgment

Report

Whatare

Tax

Lien,

Bank

rup

tcy,

&Ju

dgmen

ts?

Thiss

ectionlistscivilrecordsfrom

countycourtsfortheselected

addre

ss.

Thetypesofrecords

includ

epropertytaxliens,generaltax

liens,

bankruptcies,smallclaims,

judgm

ents,andmoreassociatedwith

these

lectedaddress.

Pleaseclosely

review

eachrecordascommon

addre

ssesmayreturnmultiplecivil

recordresults.

of10

4/11/201012:26AM

Exb. "A", pg. 15



28/63

CIVILJUDGMENTRECORD

SFORLISALIBERIINTHESTATEOFCA-6RECORDSFOUND

RECORD1

CIVILRECORDVERIFICATION:CONFIRMC

ASE#2002193850ATTH

ECOURTHOUSE

Defendant:

Liberi,Lisa

CaseNumber:

2002193850

FilingType:

CivilJudgment

EntityType:

IndividualRecord

FilingDate:

20

020400

AmountLiability:

$20,944.00

Address:

10

567GreenAcreDr

City:

RanchoCucamonga

State:

Ca

Zip:

91730

Plaintiff:

RedlandsCentennial

CourtCode:

Ca254

CourtName:

SanBernardinoCounty,San

BernardinoSuperiorCourt

UnlawfulDetainer:

N

RECORD2


ASE#0222845ATTHECOURTHOUSE

Defendant:

Liberi,Lisa

CaseNumber:

0222845

FilingType:

Chapter7Filing(New)

EntityType:

IndividualRecord

FilingDate:

20

020807

Address:

11952HuntleyDr

City:

RanchoCucamonga

State:

Ca

Zip:

91

739

Attorney:

CurtisRAijala

AttorneyPhone:

90

99830877

AttorneyAddress

:

123WB

St#C

AttorneyCity:

Ontario

AttorneyState:

Ca

AttorneyZip:

91

762

AssetsAvailable:

N

CourtCode:

Casbrf1

CourtName:

CaliforniaFedCourt-riverside

JudgeInitials:

Pc

ActionType:

Bankruptcy

RECORD3


ASE#0222845ATTHECOURTHOUSE

Defendant:

Liberi,Lisa

CaseNumber:

0222845

FilingType:

Chapter7Dismissal

EntityType:

IndividualRecord

FilingDate:

20

020807

Address:

11952HuntleyDr

City:

RanchoCucamonga

State:

Ca

Zip:

91

739

Attorney:

CurtisRAijala

Attorne

Phone:

90

99830877

Attorne

Address

:

123WB

St#C

of10

4/11/201012:26AM

Exb. "A", pg. 16



29/63

CustomersarechargedasearchfeeforexecutingaCivilJudgmentcheck.

TheCivilJudgmentreportreturnsresults

whichmayincludeallciviljudgmentrecordsornoresultsfoundontheindividu

al.

Intheeventofusingthisse

rviceforcivilbackgroundchecks,youshouldnotassumethatthisdataprovidesa

completeoraccuratehistoryofanyperson'sciviljudgmenthistory.

Youshoulduseextremecautionwheninterpretingtheresultsofaciviljudgmentbackgroundsearchforanytypeof

personalverification.

Positiveorfalsematchesin

civilsearchesmaynotprovideconfirmationofanindividual'sciviljudgmentbackground.

PleasereferencetheupdatedInteliusUseragreementforadditionalrestriction

sregardingtheusageofdata.

Current&HistoricalPeopleSearchReport

WhatisaCurrent&Historical

Peop

leSearchReport?

Thiss

ectionlistscurrentand

historicalpeoplesearchrecordsthat

share

thesamenameandstateas

yours

earchsubject.ThePeople

Searc

hSummarycanbehelpfulin

provid

ingaconsolidatedviewof

match

ingcurrentandhistorical

recordsforyoursubjectsname

acrossmultiplepublicsources.

Incom

e&HomeValuearecompiled

fromp

roperty,

demographic,census,

&otherpublicrecordsources.

Incom

e&HomeValuemaycontain

specifichouseholdandareastatistics

assoc

iatedwithanindividualor

addre

ss.

Name

AddressHistory

PreviousCities

Avg.Income/Home

Value

1

LisaLiberi

RELATIVES:

BLiberi

Address

1:

7349MILLIKEN140

RANCHOCUCAMONGA,

CA

91730

(909)46

6-9532

Address

2:

1537GR

ANDVIEW

UPLAND

,CA91784

(909)46

6-9532

Address

3:

4BONIT

O

SANTA

FE,

NM87508

(505)46

6-2505

RanchoCucamonga,

CAUpland,CA

SantaFe,

NM

Avg.Income:

$50,0

47

Avg.HomeValue:

$149,3

00

Property

Report

2

LisaLiberi

Address

1:

11952H

UNTLEYDR

RANCHOCUCAMONGA,

CA

91739

RanchoCucamonga,

CA

Avg.Income:

$70,4

61

Avg.HomeValue:

$180,2

00

Property

Report

of10

4/11/201012:26AM

Exb. "A", pg. 17



30/63

BackgroundInfo

rmation

BookmarkIntelius|Help|About|Careers|Privacy|ContactUs|FAQ|

Terms&Conditions|SiteMap|Affiliates|Directory|VolumeDiscounts

2003-2010

Intelius,

Inc.

FirstName

MI

LastName

S

tate

S

electaS

tate

Current/PreviousAddress[optional]

City[optional]

Seac

Whatdoe

saBackgroundCheck

include?

Backgroun

dreportsinclude,when

available,acriminalandsexoffender

check,

lawsuits,

judgments,

liens,

bankruptcies,

homevalue&property

ownership,addresshistory,phone

numbers,r

elatives&associates,

neighbors,

marriage/divorcerecordsand

more.

NannyEmploymentCheck&OtherHires

10of10

4/11/201012:26AM

Exb. "A", pg. 18



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EXHIBIT B

19



32/63

From: TalentWise

Date: Sat, Apr 10, 2010 at 10:40 PMSubject: TalentWise Purchase Receipt - Order #30897630To: [email protected]

Lisa, thank you for placing your order with TalentWise.

We received your order April 10, 2010 at 9:36 PM Pacific time.

Order Summary for Order #30897630

1 Nationwide Employment Background Check $59.95

Order Total: $59.95

Your credit card statement will show a charge for$59.95 from INTELIUS SCREENING.

Questions about your order?

Our Customer Service team is available from 5:00 AM to 4:30 PM Pacific time, Mondaythrough Friday.

Phone: 1.866.338.6739

Fax: 1.877.974.6150

Email: [email protected]

Please do not attempt to reply to this email message, as your reply will not be received.

For information about volume discounts and custom screening packages, please call ourSales team at (877) 893-1665 or email [email protected].

To view your reports, visit your TalentWise Dashboard Portal.

TalentWise TalentWise

2003-2010 Intelius, Inc.

Exb. "B", pg. 20



33/63

InteliusScreeningCustomerService

P.O.Box1048

|Bothell,WA98041-1048

(866)338-6739

|c

[email protected]

PerCaliforniaCivilCode1786,InteliusScreeningSolutionsdoesnotguaranteetheaccuracyortruthfuln

essoftheinformationin

thisreportastothepersonwh

oisthesubjectoftheinvestigation,o

nlythattheinformationisaccurately

copiedfrompublicrecords.

Informationgeneratedasares

ultofidentitytheft,includingevidenc

eofcriminalactivity,maybeinaccuratelyassociatedwiththe

personwhoisthesubjectofth

ereport.

APPLICANTREPORT:LisaLibe

ri

Requestedby:

LisaLibe

ri

LisaLIberi

(505)424-9055

PackageTitle:

NationwideEmploymentBackgroundCheck

ReportStatus:

Pending

RequestSubmitted:

Apr10,20109:36pm

ApplicantID:

45747986

ApplicantName:

LisaLibe

ri

DateofBirth:

5/28/1965

Address:

1704bLlanoStreet#159

SantaFe

,NM87505

Memo:

Liberi

#

APPLICANTREPORTCONTENT

S

COM

PLETE

STATUS

1

SSNVerification

Success

2

AddressHistory

ReviewBelow

3

CriminalDatabaseSearch

Pending

4

NationwideSexOffenderRegistryCheck

Clear

1

SSNVERIFICATION

SSN

xxx-xx-4312

StateofIssue

California

DateofIssue

2000

1

of3

4/11/201012:40AM

Exb. "B", pg. 21



34/63

NameSearched

LisaLiberi

Success:FullnamematchesSSN.

AKAResults

NoAKAswerefoundforthisapplicant.

2

ADDRESSHISTORY

Thisreportshowsaddressesassociated

withtheSSNsearched.Addressesareusually,b

utnotalways,listedfrommosttoleastrecent.

Address1

2983PLAZABLANCA

SANTAFE,NM87507

Address2

11952HUNTLEYDR

RANCHOCUCAMONGA,CA91739

Address3

4BONITO

SANTAFE,NM87508

Address4

POBOX548

RIBERA,NM87560

Address5

1537GRANDVIEW

UPLAND,CA91784

Address6

7349MILLIKEN#140

RANCHOCUCAMONGA,CA91730

Inteliusobtainsaddresshistoryinformationfrompublicrecordsandotherthird-partysources.Inteliuscannotguaranteethatthisinformationisaccurateorcurrent.

3

CRIMINALDATABASESEAR

CH

ThiscomponentoftheApplicantReportisstillpending.

4

NATIONWIDESEXOFFEND

ERREGISTRYCHECK

SearchDescription

Wehavesearchedfortheapplicantinthesexoffenderregistriesofall50states,theDistricto

fColumbia,andPuertoRico.

Result

Clear

Norecordswerefound.Positiveorfalsema

tcheswithinacriminalsearchmaynotprovideconfirmationofacriminalbackground.

ENDOFR

EPORT

USERSOFTHISREPORTMUSTCOM

PLYWITHTHEIROBLIGATIONSUNDERTHEF

AIRCREDITREPORTINGACT:

http://www.ftc.gov/os/2004/11/041119fac

taapph.pdf

APPLICANTSMAYVIEWT

HEIRRIGHT

SUNDERTHEFAIRCREDITREPORTINGACT:

http://www.ftc.gov/bcp/edu/pubs/consum

er/credit/cre35.pdf

of3

4/11/201012:40AM

Exb. "B", pg. 22



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2003-2010InteliusScreeningSolutionsDBATalentWise

of3

4/11/201012:40AM

Exb. "B", pg. 23



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EXHIBIT C

24



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ttps://www.talentwise.com/screening/agreement.php?newaccount=1

Exb. "C", pg. 25



38/63

Sign In | New Account

Customer Support: 1.866.338.6739

Name Email Address

Company Title

Please state your permissible purpose for access ing TalentWise services (examples: pre-employment

screening, tenant screening, employee screening, etc.)

TalentWise Terms and Conditions

DUE TO THE SENSITIVE AND HIGHLY REGULATED NATURE OF THE DATA AND INFORMATION YOU AND YOUR ORGANIZATION WILL GAIN ACCESS TO THROUGH

INTELIUS SCREENING SOLUTIONS LLC (d/b/a "TALENTWISE"), TALENTWISE WANTS TO ENSURE THAT YOU AND YOUR ORGANIZATION UNDERSTAND THEIR

OBLIGATIONS REGARDING THEIR ACCESS TO AND USE OF TALENTWISE SERVICES AND AGREE TO COMPLY WITH THOSE OBLIGATIONS. BY CLICKING ANDACCEPTING, YOU AGREE THAT:

YOU ARE EMPLOYED BY YOUR ORGANIZATION AND ARE AUTHORIZED TO ENTER INTO THIS AGREEMENT WITH TALENTWISE, AND YOU UNDERSTAND THAT

TALENTWISE IS RELYING ON THIS AUTHORIZATION;

1.

YOU HAVE READ, UNDERSTOOD AND APPROVED THIS AGREEMENT AND YOUR ORGANIZATION'S OBLIGATIONS DESCRIBED HEREIN; YOU HAVE HAD AN

OPPORTUNITY TO CONSULT WITH LEGAL COUNSEL AND OTHER EXPERTS OR ADVISORS AS DEEMED NECESSARY; AND, YOU HAVE HAD AMPLE OPPORTUNITY

TO ASK QUESTIONS ABOUT THESE TERMS AND CONDITIONS; AND,

2.

YOU WILL NOT ALLOW ANY PERSON TO ACCESS THE TALENTWISE SITE UNLESS THAT PERSON IS A BONA FIDE EMPLOYEE AND HAS REVIEWED, UNDERSTOOD

AND AGREED IN WRITING TO BE BOUND BY THESE T ERMS AND CONDITIONS.

3.

I accept the TalentWise Terms and Conditions

TalentWise FCRA Subscriber Agreement

PLEASE CAREFULLY READ THESE TERMS AND CONDITIONS BEFORE CLICKING THE "ACCEPT" BUTTON FOR THIS AGREEMENT. CLICKING ANDACCEPTING INDICATES THAT YOU HAVE THE AUTHORITY TO ENTER INTO THIS AGREEMENT ON BEHALF OF YOUR EMPLOYER ("YOU" OR "YOUR"),

AND YOU AND YOUR EMPLOYER HAVE READ THIS AGREEMENT, UNDERSTAND IT, AND AGREE TO BE BOUND BY ITS TERMS AND CONDITIONS. For

purposes of this Agreement only, you understand that Intelius Screening Solutions LLC (d/b/a "TalentWise") is a consumer reporting agency and provides

consumer reports and investigative consumer reports ("Screening Reports") as defined by the Fair Credit Reporting Act ("FCRA"). TalentWise will furnish you with

Screening Reports for employment background screening of applicants ("Applicant"), conditioned upon your compliance with this Agreement and fulfillment of all

your obligations (including payment) under this Agreement (and any other agreements you and TalentWise may have).

YOU UNDERSTAND THAT THE PROVISIONS IN THIS AGREEMENT (INCLUDING WARRANTY DISCLAIMERS AND LIMITATIONS ON LIABILITY)

REPRESENT AN AGREED UPON PRICE-RISK ALLOCATION. TALENTWISE WOULD NOT BE ABLE TO OFFER YOU ITS CURRENT PRICING STRUCTURE

BUT FOR THIS ALLOCATION.

1. You and your company shall:

I accept the terms and conditions of the TalentWise FCRA Subscriber Agreement

As an authorized representative of my Company, I accept the terms and conditions detailed above.

I Accept I Decline

Privacy Policy | 2003 - 2011 TalentWise Solutions LLC

s and Conditions - TalentWise https://www.talentwise.com/screening/agreement.php?newa

9/20/2011

Exb. "C", pg. 26



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EXHIBIT D

27



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Exb. "D", pg. 28



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1

November 01, 2010

InteliusConsumer AffairsP.O. Box 808

Bothel, Washington 98041-0808

Sent via Priority Mail Delivery Confirmation required 0309 3220 0001 9214 5504Three (3) pages total

Re: My Intelius Report

To whom it may concern,

I have purchased a copy of my report from your agency, which was run by mySocial Security number. There is a lot of incorrect information you have on meunder my Social Security number. Ironically, the incorrect and wronginformation you maintain on me is the same as the incorrect informationmaintained by LexisNexis. Obviously, you pull my private information fromLexisNexis for re-sale, which I have never authorized.

The wrong information you maintain on me, that must be deleted immediately,includes but is not limited to:

NAMES: - The following names have never been mine and have never beenused by me:

Liberi, Lisa ACourville-Richardson Lisa RCourvillerichar, Lisa RCourville, Lisa O.Corvillerichardson, LisaCourviller, LisaCourville, Richardson LCourville, Richardso L

YEAR OF BIRTH: The following date of birth is not mine and has never beenused by me:

1967

SOCIAL SECURITY NUMBERS The following Social Security numbers havenever been mine and have never been used by me:

563-42-xxxx (CA: 1936-1951);563-72-xxxx (CA: 1964)

Exb. "D", pg. 29



42/63

2

ADDRESSES: The following addresses are not mine and have never been usedby me:

40 Bonito CtSanta Fe, NM 87508-8311,

1704 Llano St Apt 159Santa Fe, NM 87505-5415

1704 Llano St Ste BSanta Fe, NM 87505-5415

990 Cypress Station Dr Apt 303Houston, Texas 77090-1546

6018 Spring Creek LNSpring, TX 77379-8805

8902 ArcadianHouston, Texas 77088

375 Bladwin PYKaty, TX 77449

13800 Ella Blvd. Apt A201Houston, Texas 77014-3318

I am in need of a copy of my Intelius report from your company, which shows theinformation you maintain on me has been corrected and all person(s) or entitieswho have obtained my report in the last three (3) years.

My correct information is as follows:

Address for last five (5) years: Lisa Rene Liberi2983 Plaza BlancaSanta Fe, NM 87507(505) 473-9185

Last 4 of SSN: xxx-xx-4312

Date of Birth 05/28/1965

Exb. "D", pg. 30



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Exb. "D", pg. 31



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EXHIBIT E

32



45/63

http://www.intelius.com/results.php?ReportType=8&qf=Lisa&qmi=&qn=Liberi&qa=&qtickler=

&qcs=NM&searchform=background&focusfirst=1

Exb. "E", pg. 33



46/63

Sign In | Register

Background Check Background Check by SSN Employee Screening

We found 2 people that match Lisa Liberi in New Mexico.

First Name required

Lisa

M.I. Last Name required

Liberi

Current/Previous Address City/State state required

NM Search

People Search Background Check Criminal Records Reverse Lookup

Search results forLisa Liberi in New Mexico

Expanded Search Results:

We searched Lisa Liberi and found 0 records in NM

We searched Alisa Liberi and found 0 records in NM

We searched Alissa Liberi and found 0 records in NM

We searched Elesa Liberi and found 0 records in NM

We searched Elisa Liberi and found 0 records in NM

We searched Elysa Liberi and found 0 records in NM

We searched Liza Liberi and found 0 records in NM

We searched Lisa Liberi and found 2 records nationwide

Get more details

Name/Aliases Has lived in DOB Phone Address Related to

Lisa M Liberi

L M Liberi

Lisa M Mangan

Prospect Park, PA

King Of Prussia, PA

Norristown, PA

Glenolden, PA

Mary E Mangan

Gerald D Mangan

Get more details

Name/Aliases Has lived in DOB Phone Address Related to

Lisa Marie LiberiLisa Liberi Laws

Miami, FLRaleigh, NC

Charlotte, NC

Pittsburgh, PA

Grace Mary LawsFred R Laws

Diane Marie Laws

Christina L Joseph

Jennifer Grace Barker

Not the right person? Search again:

All Products & Services | Help | About | Careers | Contact Us | FAQ | Site Map | Directory | Affiliates | Volume Discounts | Intelius Blog

2003-2011 Intelius, Inc. All Rights Reserved. Privacy Policy | Terms & Conditions

1. Lisa M Liberi, age 53

2. Lisa Marie Liberi, age 33

ground Check & People Search Powered by Intelius http://www.intelius.com/results.php?ReportType=8&qf=Lisa&qm

9/20/2011

Exb. "E", pg. 34



47/63

ground Check & People Search Powered by Intelius http://www.intelius.com/results.php?ReportType=8&qf=Lisa&qm

9/20/2011

Exb. "E", pg. 35



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Declaration of Lisa Ostella 1

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555 Andorra Glen Court, Suite 12

Lafayette Hill, PA 19444-2531

Telephone: (610) 825-3134

E-mail: [email protected] Attorney for Plaintiffs



SOUTHERN DIVISION

LISA LIBERI, et al,

Plaintiffs,

vs.

ORLY TAITZ, et al,

Defendants.

:

::::::::::::::

::


DECLARATION OF LISA

OSTELLA


Declaration of Lisa Ostella

I, Lisa Ostella, am over the age of 18 and am a party to the within action. I

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

competently testify. I am making this Declaration under the penalty of perjury of

the Laws of the United States pursuant to 28 U.S.C. 1746.

1. I am shocked, appalled and mortified with the unprofessional actions

of Intelius and their law firm, Jones Day.



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2. As per the advice of a law firm, I submitted a professional request for

data I was entitled to about searches that had been conducted on me. My reports

were important as they contained incorrect information about me and I wanted to

properly dispute it.

3. I took the required actions of making law enforcement reports

because of the Reed Defendants and Defendant Intelius breach of my private

information to the Defendants in this suit. I wrote to Intelius and provided the

necessary data per the FCRA [Fair Credit Reporting Act] requirements of

receiving my Intelius Reports and who had conducted searches on me.

4. My letter stated in a professional fashion why the data was requested

I supplied further confidential information, including the Federal Bureau of

Investigation (FBI) Agents name of who I was working with, law enforcement

report numbers, my new home address, and other private data demanded by

Intelius in order for me to obtain my reports.

5. Yet, with no other reason I can fathom but for malicious reasons

Intelius and Jones Day filed my letters unredacted. Jones Day comes to the table

of this case with a high reputation of professionalism. Yet, they have jus

performed with a school yard bully mentality.

6. Intelius was brought into this suit by actions and statements of the

Defendants Taitz and Sankey. Taitz and Sankey have published every bit of



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private identifying information about me, that they obtained from the Reed

Defendants and Intelius.

7. And, Intelius and their Attorneys with Jones Day do not have the

required, procedural decency to redact personal identifying information in a

correspondence I was required procedurally to make. Intelius and their Attorneys

with Jones Day's unprofessional, nonprocedural actions have left me overwhelmed

with disbelief.

8. Contrary to the statements made in Intelius's Motion to Dismiss

(MTD), I was a customer since December 2008. See my account details attached

hereto as EXHIBIT 1.

9. After Intelius was put on notice that their databases and terms and

conditions of use were being violated by their clients, they deleted my account. I

attempted to access my account in September 2011, but my account had been

deleted by Intelius. With the deletion of my account, Intelius also erased all

searches I had conducted.

10. Contrary to Intelius's statements, searches were run on me, my

husband and my children. Neil Sankey stated multiple times he ran searches on me

using Intelius as outlined in our First Amended Complaint (FAC).



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11. Orly Taitz gave sworn testimony to the Orange County Sheriffs

Department she had searches run on me. See Exhibit 16 filed May 20, 2011

Docket No. (DN) 190-4, and in Court filings located in the dockets in this case.

12. I, myself, ran searches on me under my maiden name and my married

name. See EXHIBIT 2.

13. According to Intelius own Terms and Conditions filed as Exhibit

4 of Benjamin Nelsons Declaration, Intelius was required to notify authorities

of the misuse by Orly Taitz and Neil Sankey. See Intelius's MTD Docket #380-7

Exhibit 4 paragraph 5 user agreement about contacting authorities for notification

of abuse. However, Intelius chose to delete account data instead.

14. Mr. Nelson states in his Declaration that only public information is

provided. As shown by my EXHIBIT 2, my Social Security number appears on

my report and my report is specific to me, contrary to Mr. Nelson and Intelius

statements that searches are only generic.

15. Mr. Nelson and Intelius also stated they are not consumer reporting

agencies bound by the Fair Credit Reporting Act (FCRA). I was conducting

searches with the United States Security Exchange (SEC) and located Intelius

Form S-1 dated October 19, 2009 at the SECs website a


09-051082.html. Intelius states on pages 24 and 25 in their report to the SEC:



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Because we use personal information in providing our information

services, we are subject to government regulation and vulnerable to

adverse publicity. We provide many types of data and services that

already are subject to regulation under the FCRA, Gramm-Leach-

Bliley Act, Drivers Privacy Protection Act and, to a lesser extent,

various other federal, state and local laws and regulations. Violation

of these laws or regulations may result in substantial fines, judgments

and other penalties.

These laws and regulations are designed to protect the privacy of the

public and to prevent the misuse of personal information in the

marketplace.

16. Also during my searches, I came across Intelius enterprise agreement

at http://www.intelius.com/enterpriseagreement.php. In this agreement, Intelius

states numerous times they are a consumer reporting agency government by the

FCRA.

17. Intelius also has that they are a consumer reporting agency in their

Security and compliance located at http://www.intelius.com/corp/security which

states:

Intelius recognizes the sensitivity surrounding many of its

applications and the data they rely on. As such, Intelius' information

security policy addresses security at all levels: personnel, technology

and operations.

Intelius is a certified credit reporting agency.

18. In Intelius TalentWise Agreement located at:

https://www.talentwise.com/terms.html, Intelius states:



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DUE TO THE SENSITIVE AND HIGHLY REGULATED

NATURE OF THE DATA AND INFORMATION YOU AND

YOUR ORGANIZATION WILL GAIN ACCESS TO THROUGH

INTELIUS SCREENING SOLUTIONS LLC (d/b/a

"TALENTWISE") Intelius Screening Solutions LLC (d/b/a

"TalentWise") is a consumer reporting agency and provides consumer

reports and investigative consumer reports ("Screening Reports") as

defined by the Fair Credit Reporting Act ("FCRA")

19. As can be seen by my attached report, my report contains my Socia

Security number and Social Security numbers are not public information or

general information for those who share the same name.

20. Mr. Nelson states I was sent a letter in December 2010 informing me

that I would need a Subpoena or Court Order to obtain the individuals who

performed searches on me. To date, I have never received a letter from Intelius

And, if a Subpoena or Court Order is required, why did Intelius and Mr. Nelson

offer account details pertaining to me and Lisa Liberi ?


the State of California that the foregoing is true and correct.

Executed this 23rd day of September, 2011 in the State of New Jersey.

Lisa Ostella, Declarant



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28EXHIBIT 1



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We accept Visa, MasterCard,

Discover and American

ExpressWhat is this?

Pay By

Cardholder Name

First and last name as shown on card

Billing Address

Billing City

Billing State

Billing Zip/Postal Code

Billing Country

Credit Card Number

No spaces or punctuation

Credit Card Expiration

Card Security Code (CVV)

Edit Payment Info

User Preferences

Subscribe to newsletter: Yes | No Please send me exclusive discounts, coupons, and updates via the e-newsletter.

User Preferences

Change Password

Change Password

Old / Temporary Password

Exb. "1", pg.



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Declaration of Lisa Ostella

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EXHIBIT 2

12



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Sign In My Intelius

View My Reports


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Liberi, et al Plaintiffs Cert of Svc re Objections/Opposition to Intelius Req. For Judicial Notice 1

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Philip J. Berg, Esquire (PA I.D. 9867)E-mail:[email protected]



Telephone: (610) 825-3134 Fax: (610) 834-7659Attorney in pro se and for Plaintiffs



SOUTHERN DIVISION

LISA LIBERI, et al,

Plaintiffs,

vs.

ORLY TAITZ, et al,Defendants.

:

::::::::::


PLAINTIFFS CERTIFICATE OF

SERVICE

I, Philip J. Berg, Esquire, hereby certify a true and correct copy of Plaintiffs

Objections/Opposition; Declarations of Philip J. Berg, Esquire; Lisa Ostella; Lisa Liberi;

and Certificate of Service to Defendant Intelius, Inc.s Request for Judicial Notice were

served through the ECF filing system this 24th

day of September 2011 upon the

following:

Orly Taitz

29839 Santa Margarita Parkway, Suite 100

Rancho Santa Margarita, CA 92688Email: [email protected] and


Served via the ECF Filing System

Attorney for Defendant Defend our Freedoms Foundation, Inc.



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Liberi, et al Plaintiffs Cert of Svc re Objections/Opposition to Intelius Req. For Judicial Notice 2

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Kim Schumann, EsquireJeffrey P. Cunningham, Esquire

Peter Cook, Esquire

SCHUMANN, RALLO & ROSENBERG, LLP

3100 Bristol Street, Suite 400Costa Mesa, CA 92626

Email: [email protected] via the ECF Filing System

Attorney for Defendants Orly Taitz; Orly Taitz, Inc.; and

Law Offices of Orly Taitz

James F McCabe

Morrison & Foerster425 Market St

San Francisco, CA 94105-2482

Email:[email protected]

Served via the ECF Filing System

Attorney for Defendants:Reed Elsevier, Inc.

LexisNexis Group, IncLexisNexis, Inc.

LexisNexis Risk and Information Analytics Group, Inc.

LexisNexis Risk Solutions, Inc.LexisNexis Seisint, Inc.

LexisNexis Choicepoint, Inc.

John A Vogt, Jr., Esquire

Edward San Chang, Esquire

Jones Day

3161 Michelson Drive Suite 800

Irvine, CA 92612Email:[email protected]


Attorney for Defendant Intelius, Inc.



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Marc Steven Colen, Esq.Law Offices of Marc Steven Colen

5737 Kanan Road, Ste. 347Agoura Hills, CA 91301


Attorney for Defendants:

Neil Sankey; Todd Sankey; Sankey Investigations, Inc. and

The Sankey Firm, Inc.

Michael J Niborski, Esquire

Pryor Cashman LLP

1801 Century Park East 24th FloorLos Angeles, CA 90067


Attorney for Daylight Chemical Information Systems, Inc.

/s/ Philip J. Berg

Philip J. Berg, Esquire
