LINCOLN v DAYLIGHT CHEMICAL, et al. - 42 - NOTICE OF MOTION AND First MOTION for Sanctions - 031111761226.42.0

8/7/2019 LINCOLN v DAYLIGHT CHEMICAL, et al. - 42 - NOTICE OF MOTION AND First MOTION for Sanctions - 031111761226.4

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Gmail - Plaintiffls Alternative Rule 26(1) Report Page 1 of4

il*q *$ Orly Taitz Plaintiffs Alternative Rule 26{f} Report10 messagesCharles Lincoln Mon, Feb 14,2A11at12:26 AMTo: Jonathan Ross , orly. taitz@gmail. comCc: William Pallares , Bart Becker , "Mark l. Melo", Arnold Levine , [email protected], [email protected]

Dear Dr. Taitz & Messrs. Becker, Levine, Melo, Pallares, & Ross:Because cou.nsel Gary Kreep has appeared for me I have substantiallyaltered the Rule 26(f) Report and have prepared it to be submitted withmy counsel together as a "Plaintiffs Report" tomorrow.Charles E. Lincoln, IIInerrs l"iWtgTet: 5 72.968;2EOQDeo Vindiee"God be with gou,and with thg spirit!"

- -r 1 0-cv{ 1 573 -AG-LI NCO LN-Plai ntiff s-RU LE 26{f}-Re po rt-92-1 4'20fi .pdi214KOrly Taitz Mon' Feb 14,2011at 1:16 AMTo: Pamela Barnett , Ken and Betsey Allen

this was sent to me now by Creepy Kreep, Berg an LincolnJust a bunch of creeps[Qi"roteC text hidden]

Dr Crly Taiizf;SQ29839 Santa lvlergarita pkw5r, ste 100Rancho Santa l,4argarita, CA S2688ph 949-683-5411 fax949-766-7603orlvtattzesq.com

+ r I 0-cv-0 1 573-AG-L! NCOLN-P lai ntiff s-RU LE 26(f)-Report-02-1 4-20 { 1 - pdfi :214KOrly Taitz Mon, Feb 14,2011at {:51 AMTo:YosiTaltzA

https://mail.google.comlmalV?ui:2&ik:a325723cf&view:pt&search:inbox&th:12e234... 211512011

Case 8:10-cv-01573-AG -PLA Document 42 Filed 02/15/11 Page 1 of 16 Page ID#:1047


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Gary G. Kreep, Esq.United States Justice Foundation932D Street, Suite 2Ramona, CA 92A65Tel: 760-788-6624Fax: 760-788-6414Email: usj f(g,usj f.netPhilip J. Berg, Esq. (subject to applicatiorpro hac vice)Law Offices of Philip J. Berg555 Andora Glenn Court, Suite #12Lafayette Hill, PA 19444-2537Tel: (610) 825-3134Email: philjberg@ gmail. cornAttorneys for Plaintiff Charles Edward Lincoln, IIIUNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION

CHARLES EDWARD LINCOLN, III,Plaintiff,

V.DAYLIGHT CHEMICALINFORMATION SYSTEMS.INCORPORATED, YOSEF T AITZ,ORLY TALTZ" INC.. APPEALINGDENTISTRY, LAW OFFICE OF ORLYTAITZ(RICO Enterprise), DR. ORLYTAITZ, ESQ., D.D.S., J.D., DEFENDOUR FREEDOMS FOLiNDATION, andall JOHN & JANE DOES 1-10,

Defendants.

PLAINTIFF'S REPORT OF FEBRUARY 3,2011,26(' CONFERENCEPursuant to Federal Rules of Civil Procedure 26(0, as modified by Local

Rule 26-1 and this Court's Order Setting Rule 16(b) Scheduling Conference, theRULE 26(0 PLATNTTFF'SREPORT

CASE NO. 8: I 0-cv-01 573-AG-PLARULE 26(f) Plaintiffs Report onJoint Scheduling Conference held bytelephone on ThursdayFebruary 3,2AIl

CASE NO. CVl0-01573-AG (PLAx)



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Plaintiff hereby submits his report of the earLy meeting of counsel, conducted bytelephone on February 3,2011 at which point Plaintiff was not represented bycounsel. Plaintiff had repeatedly requested that opposing counsel agree to apostponement of the meeting until his counsel had appeared, but Defense counselsteadfastly refused. As a result, the conference conclusions cannot be called'Joint"or "agreed" in any meaningful sense.

Plaintiff (inpropiapersona, prior to the appearance of counsel) met andconferred by telephone with Jonathan Ross, William Pallares, and Orly Tattz whiletraveling through Texas in an effort to comply with the Court's order for the partiesto meet and confer prior to February 7 ,2011. Because the Plaintiff was notrepresented by counsel at that time, his statements and agreements to any jointstatement should not be binding on Plaintiff s now-appearing counsel Gary Kreepand Philip J. Berg and Plaintiff files his report separately.1. Statement Of The Casea. Plaintiffs Synopsis

Plaintiff holds a J.D. from the University of Chicagor and externed or clerkedfor two Federal Judges (Hon. Stephen Reinhardt, 9'h Circuit, Hon. Kenneth L.Ryskamp, S.D. Fla.). He is currently a disbarred attorney, formerly admitted andlicensed to practice in California (among other states). On or about May 30, 2009,Plaintiff was offered contract work as a litigation consultant,legal assistant, or law-clerk by Defendant Orly Taitz, who at all relevant times acted as de lfacto albeitunofficial servant andl or agent of and for Yosef T aitz and Daylight Chemical

1 Charles Edward Lincoln also received a B.A. from Tulane University (1980, where he graduated Phi BetaKappa, Magna cum laude), an M.A. from Harvard University 1rr1982, and a Ph.D. from HarvardUniversity in 1990. His Graduate Studies and Dissertation Research were supported by the NationalScience Foundation and National Geographic Sociefy as well as private funds including grants from thelate, Charles Pickering Bowditch Fund, the Harvard Peabody Museum, author James A. Michener andZemuniay Foundation of New Orleans.

RULE 26(t) Plaintifls Report26(1) REPORT on February 3 Phone Conference

Case #1 0-cv-01 573-AG-(PLAx)



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Information Systems, Inc.. Plaintiff frst met Dr. Orly Taitz on or about June 9,2009, and began work.

From the beginning, DefendantTaitz sought to defraud Plaintiff by seeking tohave him work for free for herself and her shell organizations including Defend ourFreedoms Foundation, Appealing Dentistry, Orly Taitz,Inc., and the Law Office ofOrly Tart4 all of which were actually shell-entities for Yosef Taitz and DaylightChemical Information Systems, Inc..

The scope of work which Dr.Tattz sought from Lincoln (and which Lincolnagreed to perform) rapidly expanded and the parties developed an altemative planfor compensation whereby in exchange for Lincoln's services as a litigationconsultant, quasi-political consultant, law clerk on numerous cases, and therelationship between Taitz & Lincoln became more complex on a personal andprofessional level, with Taitz agreeing and contracting to appear as attorney onbehalf of Lincoln as trustee for financially distressed estates and properties all overthe United States, and Orly Taitzbegan advertising her relationship with Lincolnand her involvement in Lincoln's mortgage redemption projects on her website andsoliciting new clients. Taitz induced Lincoln to agree to work based on extravagantpromises and deceptive statements, all involving large amounts of money and careand development of a personal and professional relationship, all relating toinformation derived from foreign (especially Israeli) sources and informationrelating to the constitutional illegitimacy of President Barack H. Obama to serveunder the U.S. Constitution of 1787.

Lincoln likewise advertised their relationship on his blog and both publicly,personally, and specifically endorsed Orly Taitz' campaign against Obama andannounced his Trust and Foundation's (Tiena Limpia/Deo Vindice) institutionalcommitment and support to Orly Taitz in July 2AA9. Defendant Orly Taitz agreedand offered and affempted to appear in cases in U.S. District Courts in California,Florida, and Idaho for Lincoln but only actually succeeded in appearing in a case inRULE 26(f) Plaintiff s Report26(f) REPORT on February 3 Phone Conference 3 Case #10-cv-01573-AG-(PLAx)



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Orange County, California regarding which Orly Tartz failed to take any meaningfulaction except withdrawing from representation in December 2009.

DefendantTailz did not initially disclose the degree of her abject dependenceupon both the financial support and direction of Yosef Taitz and the relationshipbetween her activities and his, but this gradually became apparent until Orly Taitzterminated all her activities with Lincoln as a direct and proximate result of YosefTaitz' directions and orders.

Lincoln's association with Orly Tartz has severely injured his ownprofessional prospects for professional recovery and his own political aspirations,his personai reputation and even his personal and professionai relationships withothers. Lincoln has been ridiculed and vilified in the on-line media and press, byOrly Taitz herself and by entities which may be related to or controlled by YosefTaitz, whose operation appears to be designed deceptively to defeat its own expresspurposes by incompetence and clownish misrepresentation.b. Synopsis by Defendanti. Law Office of Orly Taitz and Dr. Orly Taitz, Etq., D.D.S.'

J.D.The core of the apparent employment and attorney-client relationship and the

central places or institutions around which all personal andprofessional interactiontook place. Dr. OrIy Tartz initiated a malicious prosecution of Lincoln for forgeryin relationship to one case in which she attempted and failed to appear in Florida,and she initiated this prosecution at the direction of and with the support of YosefTaitz & Daylight Chemical Information Systems, Inc.

ii. Daylight Chemical Information Systems,Inc. and Dr.Yosef TaitzThe actual interested parties who controlled and directed all operations and

made the actual decisions of the Law Office of Orly Taitz and Dr. Orly Taitz, Esq.,D.D.S., J.D., including but not limited to the decision to breach all contracts andRULE 26(t) Plaintifls Repcrt26(fl REPORT on February 3 Phone Conference 4 Case # l0-cv-01573-AC-(PLAx)



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agreements with Lincoln and the decision to maliciously prosecute him.Throughout their relationship, Dr. Orly Taitz was constantly receiving phone callsfrom Yosef Taitz in which she said very little but listened and spoke exclusively inHebrew or Russian, neither of which Plaintiff understands beyond a handful ofwords. iii. Defend Our Freedom Foundation, Orly Taitzr lnc. and

Appealing DentistryCollateral entities and institutions organized at the same central place as the

Law Office of Orly Taitz and Orly Taitz, D.D.S., J.D.; Defend our FreedomFoundation and Appealing Dentistry in particular were used as vehicles to makeextravagantpromises to Lincoin, seeking to induce his cooperation in a tangled webof possibly or potentially fraudulent activities, all of which promises were false andmost of which activities were either questionable or downright illegal, while Taitz &DOFD refused to honor their commitments to support Lincoln's mortgage work.Many of the long-term staff employees of Appealing Dentistry speak Hebrew orRussian.2. Subject Matter JurisdictionThe parties dispute whether this Court has federal subject matter jurisdiction.Plaintiff contends there is federal subject matter jurisdiction pursuant to 28 U.S.C.$$ 1331,1332 & 1367. Plaintiff was born in Texas and his maintained a residencein Texas for most of his adult life. A1l his latest (past ten years') driver's license and(exercised) voter's registration and voting were in Travis County, Texas.

All the Defendants are California residents or corporations. DiversityJurisdiction exists without any question whatsoever. Other states in which Lincolnhas recently resided would include Massachusetts and Florida. Lincoln's longestrecent presence in California was directly related to his work with and for Orly Taitzand her associated organizations.

Plaintiffs RICO allegations will be amended within such time as allowed byRULE 26(q Plaintifls Report26(f) REPORT on February 3 Phone Conference Case #1 0-cv-01 573-AG-(PLAx)



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the Court to provide full substantiation for the interstate and internationalracketeering andthreat of continuous criminal conduct which Defendants Yosef &Orly Taitzhave engaged and continue to pose. With the basis of a federal claim forsubject matter jurisdiction, there is also a basis for supplemental jurisdiction under28 U.S.C. $ 1367, as ail claims arise from the same common nucleus of operativelaw and fact and the same time frame and focus (May 2009-July 2010).

In response to Defendant Daylight Chemical Information Systems, Inc.'s andDr. Yosef Taitz' motion to dismiss, pursuant to Rule 12(bX1), Plaintiff contendsthere is diversity jurisdiction pursuantto 28 U.S.C. $ 1332. However, Defendantscontend that Plaintiff cannot establish complete diversity because he recentlyasserted in public documents that he was a citizen of the State of California.3. Key Legal Issues

Whether arly Taitz was at all times legally as well as de ifaclo agent for oremployee/servant of Yosef Taitz & Daylight Chemical lnformation Systems suchthat allthe actions of Orly Taitz as agent or servant should be imputed to YosefTaitz as principal.

Whether the muttiple shell organizations operated by Yosef and Orly TatIzwere enterprises engaged in a pattern of racketeering activity within the meaning of18 U.S.C. $1961 et seq..

Whether Dr. Orly Taitz'partial performance and long-term announcementsand advertising of her contractual promises and professional relationship withLincoln validates or constitutes evidence of the existence and validity of hercontractual agreement with Lincoln sufficient to support judicial enforcement ofsaid contracts betweenTaitz and Lincoln.4. Parties, Evidence, etc.L. Parfies

Plaintiff Charles E. Lincoln, III;Defendant Law Office of Orly Taitz;

RULE 26(0 Plaintifls Report26(fl REPORT on February 3 Phone Conference Case #1 0-cv-0 1 573 -AG-(PLAx)



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Defendant Dr. Orly Taitz, Erq., D.D.S., J.D.;Defendant Daylight Chemical Information Systems, Inc.;Defendant Dr. Yosef Taitz;Defendant Defend Our Freedom Foundation;Defendant Orly TaiIz,Inc.; andDefendant Appealing Dentistryb. Percipient WitnessesCharles E. Lincoln, III;Dr. Orly Taitz;Dr. Yosef Tattz;John & Jane Doe Employees/Independent Contrators/Consultants of

Appealing Dentistry, Defend Our Freedoms Foundation, Orly Taitz,Inc.,Daylight Chemical Information Systems,Inc., and Orly Taitz,Inc.c. Key Documents(1) All e-mail communications between Orly Taitz and Charles Lincoln,including all versions of contractual negotiations and all legal documents preparedand edited, and all legal research.(2) All professional or political e-mail communications between OrlyTaitz, Appealing Dentistry, Defend Our Freedoms Foundation, Orly Taitz. Inc., theLaw Office of Orly Taitz, and Yosef TattzlDaylight Chemical lnformation Systems,concerning Obama eligibility litigation, birth certificates, Lucas Daniel Smith,mortgage litigation, and Charles Edward Lincoln, III, reiating to thosecommunications which were non-privileged because they were discussed by OrlyTaitz with Charles Edward Lincoln, disclosed physically to Charles Edward Lincolnor to the three children of Orly & Yosef Taitz, ot to other parties.(3) A11 communications between Orly & Yosef Taitz and anyone in theIsraeli or Chinese govemment or Secret Services (e.g. MOSSAD) or anyoneinvolved in the Obama elegibility litigation, mortgage litigation, birth certificates,RULE 26(0 Plaintiff s Report26(f) REPORT on February 3 Phone Conference

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Lucas Daniel Smith, or Charles Edward Lincoln III.5. DamagesLincoln alleges actual breach of employment contract damages in an

amount in excess of $100,000.00, actual breach of attorney-client contractdamages in excess of $500,000.00, libel and defamation and IIBD damages in anamount in excess of $50010000, and racketeering damages in an amount inexcess of $1,000,000.00.6. Insurance

Defendants Law Office of Orly Taitz and Dr. Orly Taitz, Esq., D.D.S., J.D.are ctnrently being defended by ZurichNorth America.7. Likelihood of Motionsa. Plaintiff

Plaintiff anticipates filing motions to compel discovery of electronic and otherdocuments from all Defendants, but especially from Yosef Taitz, Daylight ChemicalInformation Systems, Inc., Appeaiing Dentistry, Defend Our Freedoms Fotrndation,OrIy Taitz, Inc.; Plaintiff contends that given Defendants' massive computersophistication, it will be necessary to examine all computer harddrives and storagesystems directly and physically due to possible "accidental loss" or "spoilage" ofevidence, including regularly timed destruction of documents which at the presenttime the Court should order to cease.b. Defendants

Defendants Law Office of Orly Taitz and Dr. Orly Taitz, Esg., D.D.S., J.D.state that they do not anticipate bringing arry motions other than a motions forsummary judgment or partial summary judgment pursuant to Fed. R. Civ. Proc. 56and motions in limine. But based on the February 3,2011, discovery conference,Plaintiff expects that Defendants will file multiple and massive Motions forProtective Orders and to prevent electronic discovery.RULE 26(0 Plaintifls Report26(0 REPORT on February 3 Phone Conference 8 Case #10-cv-01573-AG-(PLAx)



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8. Manual for Complex LitigationIt is unclear whether this case could evolve into a complex litigation situation

if further evidence of international goveflrmental (or corporate) connections orespionage is discovered. Accordingly, the Plaintiff cannot be certain at the presenttime whether it wouldbe helpfulto utilize the Manual of Complex Litigation in thiscase or not.9. Status of Discovery

The Plaintiff agreed (without counsel) on February 3,2011, to serve his initialdisclosures on or before March 21,2011. Plaintiff s recently appearing counselcannot agree to such a foreshortened time fuame and would ask until May 1, 2011,or that the Court dispense with the requirement of initial disclosures all together.The parties acknowledge their duties to supplement disclosures and discoverypursuant to Federal Rules of Civil Procedure 26(e).10. Discovery Plana. Numbering

The parties agree to use a single, unified numbering system, numbering eachdeposition exhibit in consecutive numerical order. Plaintiffs proposes that hisdocuments shall be numbered 1 through 999. Defendant Orly Taitz' documentsshall be numbered 1001-1999; Defendant Yosef Taitz' documents should benumbered 200 I -2999; Defendant Daylight Chemical Information Systems'documents should be numbered 3001-3999; Defendant Defend Our Freedoms'Documents Should be nurnbered 4001-4999; Defendant Orly Taitz' Inc's documentsshould be numbered 5001-5999; Appealing Dentistry's documents 6001-6999;LawOffice of Orly Taitz' documents 7001-7999, etc.b. Written Discovery

The parties anticipate propounding interrogatories, requests for production ofdocuments, and requests for admissions.c. DepositionsRULE 26(0 Plaintiffs Report26ifl REPORT on February 3 Phone Conference Case #1 0-cv-01 573-AG-(PLAx)



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The parties anticipate taking the following depositions: Charles E. Lincoln,III; Dr. Otly Taitz; and Dr. Yosef Taitz; Plaintiff anticipates taking depositions ofemployees and agents of each of the individual and corporate Defendants; during theFebruary 3,2011, conference, Dr. OrIy Tartz indicated that she wished to either sueor take evidence from Plaintiff s associates (1) Peyton Yates Freiman, (2) KathyAnn Garcia-Lawson, (3) Elena K. Lincoln, and (4) Charles Edward Lincoln, IV, aswell as (5) Lucas Daniel Smith, and (6) Lany Sinclair.

The Parties anticipate the identity of third-pafiy witnesses will be disclosedduring ongoing discovery and reserve the right to depose them.

d. Discovery Subject MatterPlaintiff does not recall that the parties discussed whether to conductdiscovery in phases on February 3,2011, or not. There are severai reasons why thismight be a desirable strategy, but these will be discussed by counsel.e. Existing Or Issues To Arise

Electronic discovery wiil be a seriously disputed discovery issue; spousalprivilege may be an issue for discovery concerning Orly & Yosef Taitz; nationalsecurity may be an issue relating to discovery relating to Orly & Yosef Taitz &Daylight Chemical Information Systems, Inc.; Attorney-Client privilege betweenTaitz and Lincoin no longer exists (for obvious reasons) but Attorney-Clientprivilege between Taitz and Dr. Jonathan Levy may exist and yet Levy may be awitness to certain relevant facts; Lincoln is willing to waive any claim of privilegewith Dr. Kathy Ann Garcia-Lawson although he sometimes rather informallyconsuited with her in her capacity as a psychologist regarding his relationship(s)with Dr. Orly Tattz and Orly Taitz' deeply troubled marriage to her husband Yosef.f. Electronically Stored Information (Identification, Maintenance

And Production Agreements/Discussions)The parties have not entered into any agreements about electronically stored

information. Currentiy, the Plaintiff is anticipating extensive electronic discovery,RULE 26(q Plaintiff s Report26(f) REPORT on February 3 Phone Conference 10 Case #10-cv-01573-AG-(PLAx)



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however, Defendants do not agree. However, should electronic discovery becomenecessary, the Parties agree to cooperate as to time and cost saving protocols toimplemen t any foreseeab le electronic di scovery.g. Limitations

The parties do not propose any changes to the limitations on discoveryimposed under the Federal Rules of Civil Procedure, and instead reserve the right tostipulate or seek an order from the Court altering the limitations imposed by theFederal Rules should the need arise.11. Discovery Cut-Off

On February 3,2All, the parties tentatively discussed December 9,2011.t2. Expert DiscoveryThe Parties on February 3,2011 proposed the following tentative schedule forexpert discovery:

Initial Expert Disclosure:Rebuttal Expert Disclosure :13. Dispositive MotionsDefendants Law Office of Orly Taitz and Dr. Orly Taitz, Ese., D.D.S., J.D.

anticipate filing a motion for summary judgment as to the statue of limitation andcausation. Defendants Law Offrce of Orly Taitz and Dr. Orly Taitz, Esq., D.D.S.,J.D. reserve the right to fi1e on other grounds depending upon the disclosure of factsduring discovery.14. Settlement

Plaintiff proposes mediation and/or moctrdmoot "trial-by-jnry" as settlementtecniques.15. Trial Estimatea. Jury Trial

The parties demand a jury trialb. WitnessesRULE 26(f) Plaintiff s Report26(fl REPORT on February 3 Phone Conference

November lI,2011; andNovember25,20ll

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The number of Witnesses has not yet been established for any party.c. Time Estimate For TrialThe parties estimate a 5 to 6 day jury trial.16. Trial CounselPlaintiffs trial counsel: Gary Kreep, Erq., & Philip J. Berg, Esq.Defendants Law Office of Orly Taitz'and Dr. Orly Taitz, Esq., D.D.S., J.D.'s

trial counsel: Bartley L. Becker and William E. Pallares.Defendants Chemical Information Systems, Inc.'s and Dr. Yosef Taitz' trial

counsel: Jonathan A. Ross;Defendants Defend Our Freedom Foundation's, Orly Taitz. Inc.'s andAppealing Dentistry's trial counsel: Dr. Orly Taitz.Plaintiff s trial counsel, once approved for Pro Hac Vice will be: Philip J.

Berg, Erq., sponsored by local counsel, Gary G. Kreep, Esq.17. Independent Expert Or MasterThe parties do not anticipate the need for the Court to appoint a master

pursuant to Rule 53 or an independent scientific expert; the Plaintiff suggests that anindependent expert regarding issues of national security and/or computer/electronicdata storage and retrieval MAY be necessary.18. Timetable

The Parties on February 3,2011, tentatively proposed the following datesbefore the appearance of Plaintiff s counsel:

Discovery cut-off: December 9,2017;Motion cut-off: Ianuary 30,2012;Final Pretrial Conference: February 27,2012; andTrial: March 12,2012.19. Other Issues

At this time, the Parties do not anticipate any other issues.RULE 26(0 Plaintiff s Report26(0 REPORT on February 3 Phone Conference 12 Case #10-cv-01573-AG-(PLAx)



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