LIBERI V TAITZ (APPEAL) - Appellants' Request For Judicial Notice - 23892610-Liberi-Et-Al-v-Taitz-Et-Al-Req-for-Judicial-Notice-3rd-Circut

Case: 09-3403 Document: 00319937503 Page: 1 Date Filed: 12/08/2009
U.S. District Court,

Eastern District of Pennsylvania Case Number: 09-cv-1898-ECR
Court of Appeals Case No. 09-3403
UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT
_____________ Ο _____________
LISA LIBERI, et al,
Petitioner – Appellant,
v.
ORLY TAITZ, et al,
Respondents – Appellee.
_____________ Ο _____________
APPELLANTS’ EMERGENCY REQUEST FOR JUDICIAL NOTICE OF APPELLEE

ORLY TAITZ, et al FALSIFIED LETTER FILED IN THE U.S. DISTRICT COURT,
CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION IN CASE NO. 09-cv-
00082-DOC; DOCKET of BARNETT, et al v. OBAMA, et al ; AND A PICTURE OF THE
POSTING OF THIS LETTER OF APPELLEE TAITZ, et al in SCRIBD PRIOR TO ITS
FILING IN THE UNITED STATES FEDERAL DOCKETING SYSTEM and PRIOR TO
THIS LETTER BECOMING PUBLIC RECORD
_____________________
Counsel: PHILIP J. BERG, ESQUIRE

LAW OFFICES OF PHILIP J. BERG
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531
(610) 825-3134
Identification No. 09867
Attorney for the Appellants’

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
Please Take Notice that Appellants, Lisa Liberi [hereinafter “Liberi”]; Philip J. Berg,
Esquire [hereinafter “Berg”], the Law Offices of Philip J. Berg; Evelyn Adams a/k/a Momma E
[hereinafter “Adams”]; Lisa Ostella [hereinafter “Ostella”]; and Go Excel Global by and through
their undersigned counsel, Philip J. Berg, Esquire, hereby submit this Emergency Request for
Judicial Notice of Appellee Orly Taitz, et al Filing of a letter dated December 2, 2009, with
falsified information, slander, libel, false accusations, amongst many other things about
Appellants Lisa Liberi and Philip J. Berg, Esquire filed in the United States District Court,
Central District of California, Southern Division in the case of Barnett, et al v. Obama, et al,
Case Number 09-cv-00082-DOC, attached hereto as EXHIBIT “1”; The Docket of Barnett, et
al v. Obama, et al, Case No. 09-cv-00082-DOC showing the letter filed as Docket entry number
100, attached hereto as EXHIBIT “2”; and a picture of Appellee Taitz, et al letter posted on the
internet at SCRIBD prior to its filing in the United States Federal Docketing System in the case
of Barnett, et al v. Obama, et al, Case No. 09-cv-00082, attached hereto as EXHIBIT “3”.
Appellee Orly Taitz, et al Filed her famous Dossier #6, which contains falsified
information about Appellant Liberi, her Social Security number, date of birth, and other private,
confidential and personal information in the case of Barnett, et al v. Obama, et al, Case No. 09-
cv-00082 filed in the United States District Court, Central District of California, Southern
Division before Judge Carter. Counsel herein sent a letter to Judge Carter and requested the
sealing of Appellee Taitz, et al Filing of Dossier #6 as it violated the Federal Rules of Civil
Procedure and the California local rules. Judge Carter in turn issued an Order Sealing the Court
Filing of Dossier #6 and Ordered Appellee Taitz, the attorney in the Barnett Case, to re-file her
documents with all Social Security numbers, date of birth’s and other personal information
redacted as he, Judge Carter, was concerned about the confidentiality of Liberi, her spouse and
other individuals private confidential information being made public. This September, 2009
Court Order of Judge Carter has been filed with this Court by Appellants’ with a Request for
Judicial Notice.
Here, two [2] months later, Apellee Orly Taitz, et al Filed the attached letter in the
Federal Docketing System and placed it on the World Wide Web at Scribd prior to its filing in
the Federal Docketing System. Neither Appellant Liberi nor Appellant Berg have anything to do
with the Barnett case filed in California and the only reason these documents have been Filed by
Appellee Orly Taitz, et al is to use the Federal Docketing System to further her illegal, harmful,
damaging behaviors towards Appellant Liberi, Appellant Berg and any party associated with
them. It is imperative that this Court take Judicial Notice of these documents as it shows the
continued deceptions, fabricated statements and stories and dishonesty of Appellee Orly Taitz, et
al as the statements made by Appellee Orly Taitz’s in this letter contradict her statements and
filings to Judge Robreno in the lower Court, U.S. District Court, Eastern District of
Pennsylvania. In addition, this letter of Appellee Orly Taitz’s also proves the allegations which
Appellants’ have pled against her and the other Appellees herein.
Moreover, Appellants’ requested Leave from Judge Robreno in the lower Court, U.S.
District Court, Eastern District of Pennsylvania on November 29, 2009 to file their Motion
requesting Transfer of the within Diversity Action to the United States District Court, Central
District of California, Southern Division located in South Orange County at 411 West Fourth
Street, Santa Ana, CA 92701-4516 with telephone number (714) 338-4750, see EXHIBIT “4”,
which is the very Court that Appellee Orly Taitz, et al filed this December 2, 2009 letter. Thus,
Appellants’ are concerned that Appellee Orly Taitz, et al may be attempting to conflict out the
Judges in the United States District Court, Central District of California, Southern Division. To
date, Judge Robreno has not granted or denied Appellants’ request for leave to file their Motion.
“A judicially noticed fact must be one not subject to reasonable dispute in that it is either
(1) generally known within the territorial jurisdiction of the trial court or (2) capable of accurate
and ready determination by resort to sources whose accuracy cannot reasonably be questioned.”
Fed. R. Evid. §201(b); Easy Sportswear, Inc. v. Am. Econ. Ins. Co., 2008 U.S. Dist. LEXIS
51402 (D. Pa. 2008); Nationwide Life Ins. Co. v. Commonwealth Land Title Ins. Com., 2005 U.S.
Dist. LEXIS 24479 (E.D. Pa. 2005); In re NAHC, Inc. Sec Litig, 306 F.3d 1315 (3d Cir. 2002)
“[a] court shall take judicial notice if requested by a party and supplied with the necessary
information.” Fed. R. Evid. 201(d) (emphasis added) Easy Sportswear, Inc., 2008 U.S. Dist.
LEXIS 514002 (D. Pa 2008) at *2.
It is firmly established that Requests for Judicial Notice are proper “only to the extent
that the noticed facts are relevant to an issue” that is before the Court. Each of the Exhibits that
Appellants are requesting Judicial Notice of are of the type that have previously been admitted
by Judicial Notice in the Third Circuit. This includes documents integral to or explicitly relied
upon in the Appellants’ Complaint and the reasons Appellants’ were forced to bring suit against
the Appellees. All Exhibits Appellants are requesting Judicial Notice of are directly related to
this within action and are relevant to the issues herein. In re Ravisent Techs., Inc. Sec. Litig.,
2004 U.S. Dist. LEXIS 132355 (D. Pa. 2004).
For the above aforementioned reasons, Appellants’ respectfully request this Honorable
Court to take Judicial Notice of Appellee Orly Taitz, et al letter of December 2, 2009 attached
hereto as EXHIBIT “1”; Barnett, et al v. Obama, et al Docket in Case No. 09-cv-00082-DOC
showing Appellee Taitz’s letter filed as Docket entry 100 attached hereto as EXHIBIT “2”; and
the picture of SCRIBD website showing Appellee Orly Taitz posted this letter on the world wide
web prior to its filing in the Federal Docketing System, attached hereto as EXHIBIT “3. ”.
Respectfully submitted,
s/ Philip J. Berg
Dated: December 8, 2009 ____________________________
Philip J. Berg, Esquire
(610) 825-3134
Attorney for the Appellants’

U.S. District Court,

Eastern District of Pennsylvania Case Number: 09-cv-1898-ECR
Court of Appeals Case No. 09-3403
UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT
_____________ Ο _____________
LISA LIBERI, et al,
Petitioner – Appellant,
v.
ORLY TAITZ, et al,
Respondents – Appellee.
_____________ Ο _____________
CERTIFICATE OF SERVICE
I, Philip J. Berg, Esquire, hereby certify that a copy of Appellants’ Request for Judicial
Notice was served this 8th day of December 2009 electronically upon the following:
Orly Taitz
Defend our Freedoms Foundation, Inc. (unrepresented)
26302 La Paz Ste 211
Mission Viejo, CA 92691
Email: dr_taitz@yahoo.com
Neil Sankey
The Sankey Firm, Inc. a/k/a The Sankey Firm (unrepresented)
Sankey Investigations, Inc.
2470 Stearns Street #162
Simi Valley, CA 93063
Email: nsankey@thesankeyfirm.com
Linda Sue Belcher

201 Paris
Castroville, Texas 78009
Email: Newwomensparty@aol.com and
Email: starrbuzz@sbcglobal.net
Ed Hale
Caren Hale
Plains Radio
KPRN
Bar H Farms
1401 Bowie Street
Wellington, Texas 79095
Email: plains.radio@yahoo.com; barhfarms@gmail.com;
ed@barhfarnet; and ed@plainsradio.com
s/ Philip J. Berg
________________________
PHILIP J. BERG, ESQUIRE
EXHIBIT “1 ” 5
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Dr. Orly Taitz ESQ
29839 Santa Margarita PKWY, ste 100
Rancho Santa Margarita CA 92688
12.02.09.
Request for investigation of misconduct in legal proceedings, submission of perjured

affidavits, submission of a letter to court by an attorney with improper purpose of covering up
criminal activity and obstruction of justice, withholding evidence by attorneys, and US
attorneys acting under conflict of interest
Attn. Honorable Judge David O Carter,
Your honor,
Under rule 83-3.1.12 you have the inherent power to investigate any misconduct perpetrated
upon this court during proceedings.
L.R. 83-3.1.12 Powers of an Individual Judge to Deal With Contempt or Other Misconduct Not
Affected . Disciplinary proceedings under Rule 83-3.1 shall not affect, or be affected by, any
proceedings for criminal contempt under the U.S. Criminal Code, nor shall anything contained in
this Rule 83-3.1 be construed to deny any judge of this Court said judge’s inherent power to
maintain control over the proceedings conducted before said judge, nor to deny the judge those
powers derived from any statute or rule of court. Misconduct of any attorney in the presence of
a court or in any manner in respect to any matter pending in a court may be dealt with directly
by the judge in charge of the matter or at said judge’s option, referred to the Committee, or
both.
There was a concerted and a well orchestrated effort by a number of individuals to assassinate
my character, endanger my law license and ultimately derail my case against Mr. Obama. A
number of criminal activities were perpetrated upon this court. I request urgent investigation of
the following activities:
1. Perjury committed by Lucas Smith in his letter to your honor, claiming that I have
suborned perjury, as I have never suborned perjury and only asked Mr. Smith to
authenticate the declaration that he has signed previously under the penalty of perjury
and later recorded on videotape by filmmaker Mr. William Waggener.
2. Perjury committed by Larry Sinclair in his letter claiming that I suborned perjury, as I
have never suborned perjury and simply asked Mr. Sinclair to authenticate an affidavit
submitted by him to the Chicago police and published in his book “Barack Obama &
Larry Sinclair Cocaine, Sex, Lies & Murder?” by Lawrence W. Sinclair .
3. A letter by attorney Philip Berg on behalf of his client Lisa Liberi submitted with
improper purpose to this court. Ms. Liberi is not only Mr. Berg’s client, but also his legal
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assistant, who according to Mr. Berg’s numerous radio interviews prepared a similar
case involving Mr. Obama. As Your Honor could see in dossier #6 submitted to this
court and Department of Justice, specifically Attorney General Eric Holder, as well as US
attorney’s office in this district, Ms. Liberi is a convicted felon, with 10 convictions of
forgery of documents, forgery of an official seal and grand theft. She was convicted in
January 2008 of all of the above felonies and received 8 year prison term. Miraculously
in spring of 2008 her 8 year prison term was reduced to probation only, which she was
allowed to serve in Santa Fe, NM, to be close to her father and step mother. Shortly
after her prison term was reduced from 8 years in prison to probation, she started
working with attorney Phillip Berg from PA on Obama eligibility case and in August of
2008 they submitted to US district court in the Eastern district of PA a case Berg v
Obama. This case contained some sworn affidavits from Kenya, testifying to Mr.
Obama’s Kenyan birth. As those were sworn affidavits submitted to federal court, I have
used this evidence by incorporation in a number of cases, including Lightfoot et al v
Bowen (vice presidential candidate Gail Lightfoot v secretary of state of CA Debra
Bowen ) submitted to the Supreme court of CA and the Supreme Court of the United
States and in this case Barnett et al v Obama, in the original pleadings submitted in
January 21, on the inauguration day and before Mr. Mr. Obama’s oath of office was
taken. ( the oath of office was actually taken the next day, as the first time it was
administrated improperly). Sometime in Spring of this year I received information that
Ms. Liberi has multiple convictions of forgery, used multiple social security numbers and
there is a real concern that the affidavits submitted to court by attorney Berg could have
been forged. I have written to Mr. Berg and asked him to either employ a forensic
document expert to check those documents for authenticity or give me an opportunity
to review those documents together with a forensic document expert in order to make
sure those documents are not forged, as I included them by reference in my pleadings in
this court. I thought Mr. Berg was not aware of Ms. Liberi’s past and would cooperate.
Instead Mr. Berg decided to keep me quiet by filing a totally frivolous legal action
against me, my investigator and a number of other parties. Mr. Berg was seeking a
restraining order on any information about Liberi and millions of dollars. US district
Judge Robreno promptly denied the TRO and issued an order to Berg to show cause,
why his case should not be dismissed due to lack of jurisdiction over the defendants in
the Eastern District of Pa. I am expecting this case to be dismissed shortly, as Mr. Berg
has never presented any evidence of jurisdictions over the defendants. I have also
removed from the first amended complaint in this case any mention of any evidence
coming from Berg and Liberi. I am greatly concerned that there was a concerted effort
to cloud the case against Mr. Obama by the evidence prepared by the convicted forger
Liberi. I believe someone has used this whole connection of Berg-Liberi as sort of an
insurance policy, in case this case goes to trial, it will be tainted. Additionally, I was
amazed by total paralysis of law enforcement to investigate any suspected criminal
activity by Berg and Liberi. According to San Bernardino District Attorney James Secord
Liberi is on disability and according to the terms of her probation she is not allowed to
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handle any credit cards of other individuals. According to the letter submitted to SSA by
former volunteer for Attorney Berg, Linda Belcher, Liberi has constantly handled credit
cards of individuals, who donated to Mr. Berg’s effort to expose Mr. Obama. Ms.
Belcher has also described routine practice of Mr. Berg paying Liberi’s earnings to her
husband Brent Liberi, which constituted fraud upon Social Security Administration and
IRS, perpetrated by Liberi and Berg, as Liberi was getting social security as a disabled
individual, and it was a violation of her probation. While all of this was reported, there
was no action by law enforcement yet.
4. From 11.11.09. to 11.22.09. I had the honor to be a delegate at the Continental
Congress 2009. One of the guest speakers for the Continental Congress was a former
Immigration officer and currently a private investigator in CO, Mr. John Samson. I have
stated to Mr. Samson that I need to tie some loose ends and I was wondering if as a
former immigration officer, Mr. Samson would be privy to the information, that other
investigators couldn’t obtain. In my presence Mr. Samson used his password and logged
into the Database “Intelligator’, and he printed out a document attached as an exhibit. It
shows that Mr. Obama’s immigration records show one more birthdate: 08.01.61 and
in the area of Ethnic origin it stated Equatorial Guinea. The rest of the information was
the usual, showing Michelle Obama as the spouse and the rest of the information that
we are used to see. This document provides significance in a number of areas: A. It
shows that with the minimal inquiry assistant US attorneys representing Mr. Obama in
this case knew or should have known, that not only there are 39 different social security
numbers that he used according to the databases, none of which were issued in Hawaii,
not only there are statements of forgery of his selective service certificate and
certification of life birth and his refusal to unseal the original birth certificate and
original birthing file from the Kapiolani hospital, there are additional doubts to his
citizenship, due to the presence of different date of birth and different origin. This
constitutes sufficient reason to doubt Mr. Obama’s citizenship status, where the US
attorney’s office and department of justice representing United states of America had
an obligation to withdraw from representation of Mr. Obama in this case and the fact
that it was not done, represents a clear violation of the professional ethics by the US
attorneys representing Mr. Obama in this case. B. This piece of information provided
another piece to the puzzle, as numerous articles have reported that some 500
Columbia university students from the same graduation year were questioned and
didn’t remember Mr. Obama as a student at Columbia, however at the same time there
was an article published in Seattle, Washington, regarding one, Roman Obama, an
exchange student from Equatorial Guinea (same origin listed in Mr. Obama’s
immigration records) studying in the university of Patrice Lumumba in Moscow. (this
university was known as a basis of heavy Communist indoctrination and rumored to be
the hunting ground of communist recruiting by the KGB). This university is very similar
to the university of Karl Marx, attended by Mr. Obama’s cousin, current prime minister
of Kenya Raela Odinga. C. It provided yet another connection between Mr. Obama and
the law clerk of this court Mr. Velamoor, as similarly there are conflicting accounts of
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Mr. Velamoor’s legal education in Martindale and WestLaw directories: one pointing to
Columbia university, while the other to the Comenis law school in Bratislava, Slovakia. It
appears that both might have been part of the same program with the Columbia
university. Additionally there is a geographical connection as both Mr. Obama and Mr.
Velamoor came from the same tiny community of Mercer Island WA. While Mr. Obama
in his memoirs writes that his mother was married to Mr. Obama Sr. and lived in Hawaii
in and around his birth, the registrar records show that she dropped out of the
university of Hawaii around December 1960 and reappeared some nine months later
enrolled in the university of Washington from August 1961, shortly after Mr. Obama’s
birth. This coupled with the fact that Mr. Velamoor is still listed as an employee of
Perkins Coie, the law firm, representing Mr. Obama in eligibility litigation, shows that
there had been some ethics violation and Mr. Velamoor had to disclose all of the
connections and conflict of interest and had to be recused from assisting your owner.
Lastly, after the order of 10.29.09 became public, it became a source of hounding and wilding of
me and my family. As an example, a teacher has approached one of my children, pointed to a
newspaper article and commented that the judge says “your mother tells witnesses to lie”.
There are daily death threats against me and my family, tampering with my car and my
husband’s car and there is no assistance from either police or FBI. I believe that the justice
department, Attorney General Eric Holder and Assistant US attorneys representing both United
States of America and Mr. Obama are guilty of obstruction of Justice, as they do not investigate
and simply burry any and all illegal activity by Mr. Obama, but they also stop and burry all the
investigation of death threats against me and my family as well as any and all acts along the
lines of those threats. The only way this illegal activity will ever be investigated and prosecuted,
is not from initiative of Mr. Holder, but rather pursuant to a court order from you Your Honor.
There is an urgent need for your honor to start the investigation of perjury, violation of ethics
and possibly other illegal actions committed by the parties listed above upon this court. Speedy
investigation and resolution is paramount not only for my family, but for the country as a whole.
Respectfully submitted
/s/Dr. Orly Taitz ESQ
I certify under penalty of perjury that the copies of the above letter were electronically served
upon all the parties in this case.
/s/ Dr. Orly Taitz, ESQ
Declaration of Orly Taitz
Under penalty of perjury I declare the following:

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1. I am over 18 years old, I am a resident of Orange County, California, I am of sound mind

and free of any mental disease and psychological impairment.
2. From 11.11.09. until 11.22.09. I was a delegate at the Continental congress 2009.
3. On 11.16.09. I met a guest speaker at the Congress Mr. John Samson, retired
Immigration officer and currently a private investigator in the state of Colorado.
4. In my presence Mr. Samson ran the background report for Mr. Barack Obama attached
as exhibit.
5. The report showed Mr. Obama’s date of birth to be 08.01.09. and not 08.04.09.
6. The report showed Equatorial Guinea as ethnicity.
I solemnly swear under penalty of perjury that all the facts stated and circumstances described
above are true and correct statements. Further declarant saith naught.
/s/ Orly Taitz
12.03.09.
Attachments:
An example of daily death threats. The IP addresses of most of the individuals making death
threats were traced to WA state.
Peter Submitted on 2009/12/02 at 3:09pm Can someone
Nantucket Oh, Your “pastor” friend wiley drake can WISH the president dead but I can’t wish
track this IP? It
ptn@aol.com YOU dead orly? YOU ARE SUCH A HYPOCRITE!!!! sounds like a
I WISH YOU NOTHING BUT DEATH AND MISERY. I WISH YOUR CAR WILL CRASH
71.112.191.144 death threat to
BECAUSE SOMEONE TAMPERED WITH IT, AND YOU WILL BURN AND BE IN THE
WORST AGONY OF YOUR LIFE. I WISH AND PRAY FOR THE MOST AWEFUL DISEASE me
TO INFLICT YOUR WHOLE FAMILY. I WISH FOR ALL RIGHT WINGERS TO DROP
6 #
DEAD NOW, FOR THE ARE THE SEEDS OF HUMANITIES DESTRUCTION. I WISH
SOMEONE WOULD TAKE YOU OUT BEHIND A SHED AND BEAT YOU TILL YOU START
MAKING SENSE. I WISH YOU WOULD STOP LYING AND TWISTING RUMORS INTO
SO-CALLED “FACTS” … I WISH A LOT OF THINGS EVIL TO COME YOUR WAY. I
LEARNED IT FROM RIGHT WINGERS LIKE WILEY DRAKE AND COMPANY.
Approve | Spam | Delete | Edit | Quick Edit | Reply

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NOBODY REMEMBERS OBAMA AT COLUMBIA
Looking for evidence of Obama's past, Fox News contacted 400

Columbia University students from the period when Obama claims
to have been there, but none remembered him.
Wayne Allyn Root was, like Obama, a political science major at
Columbia who also graduated in 1983. In 2008, Root says of
Obama, "I don't know a single person at Columbia that knew him,
and they all know me.
I don't have a classmate who ever knew Barack Obama at

Columbia . Ever! Nobody recalls him. I'm not exaggerating, I'm not
kidding."
Root adds that he was also, like Obama, "Class of '83 political
science, pre-law" and says, "You don't get more exact or closer
than that. Never met him in my life, don't know anyone who ever
met him.
At the class reunion, our 20th reunion five years ago, who was
asked to be the speaker of the class? Me.
No one ever heard of Barack! And five years ago, nobody even
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knew who he was. The guy who writes the class notes, who's kind
of the, as we say in New York, the macha who knows everybody,
has yet to find a person, a human who ever met him. Is that not
strange?
It's very strange." Obama's photograph does not appear in the

school's yearbook and Obama consistently declines requests to
talk about his years at Columbia, provide school records, or
provide the name of any former classmates or friends while at
Columbia.
http://en.wikipedia.org/wiki/Wayne_Allyn_Root#column-one
NOTE: Root graduated as Valedictorian from his high school, Thornton-Donovan School ,
then graduated from Columbia University in 1983 as a Political Science major (in the same
class as President Barack Obama WAS SUPPOSED TO HAVE BEEN IN)
Attachment: two different curriculum vitae for Mr. Velamoor. One shows JD from
Columbia University, another JD from Comenis University, Bratislava, Slovakia
An October 18th item focused on Siddharth Velamoor showing up in Judge Carter's court as his
new clerk. It turns out that Velamoor has multiple CVs.
From: West Legal Directory
Siddharth Velamoor
Perkins Coie
1201 Third Avenue
Suite 4800
Seattle, WA 98101-3099
Comenius University School of Law, Bratislava, Slovakia, 2008, J.D.
London School of Economics and Political Science, 2005, M.Sc., Major: International Relations
Dartmouth College, 2004, A.B., Honors: cum laude, Major: Government
But, lookie here!
From: Martindale.com
Siddharth Velamoor
Associate
Perkins Coie LLP
1201 Third Avenue, Suite 4800
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Seattle, Washington
Columbia University, J.D.
Dartmouth College, A.B.
11/17/2009 0532
#553 P.001!002
From:
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Background Report -11/16/2009 19:17
Print
Paqe I~ Search Criterion: Barack Obama STATE = IL Search Results: Name: BARACK H OBAMA
Address: 5046 S GREENWOOD AVE CHICAGO IL 60615 (Google maesl Verified address: No County: COOK
Phone: OOB: 08-01-1961 Age: 48 Gender: M Education: Graduate School Occupation Group:
Professionalffechnical Occupation: Unknown Ethnic Code: Equatorial Guinea Ethnic Group: F Language Code: E
1 Marital status: Unknown Business owner: Record 10 #: Possible nicknames:
None Found Possible Relatives and associates: MICHELLE OBAMA Age: 45 Neighbors;
Name: ,IMAMES B
Address: 4236 S GREENWOOD AVE CHICAGO IL60653

Phone:STE
WART
Name:
AREUA
Phone: 773-
624-7360
Address: 4326 S GREENWOOD AVE APT CHICAGO IL60653
BRADLEY Address Records: Address: 5046 S GREENWOOD AVE
Latitude:
41.803120 City: CHICAGO
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Longitude: -
87.599107 State: IL
Dwelling unit
size: N/R Zip: 60615
Homeowner/renter:
Unknown County: COOK
Length of residence: 1 years Area Data: City Data:

Chicago City
Housing Units: 1,152,868 land Square Miles:
FIPS: 17
227.13 FIPS Place: 1400
Longitude: -87.679365 Property Records: Home

purchase price: N/R
Latitude: 41.840675 Population: 2,896,016 Water Square Miles: 6.87
Loan
Type: N/R Purchase date: N/R
Estimated value:
$969,000 Mortgage Lender: N/R
Mortgage
term: N/R Date of refinance: 0000-00-00
Refinance amount: N/R
http://www-inteligator.com!advanced/xweb/index.php?xpath=premium _ usinfo&cisrestyp...
11/16/2009
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Attachment: Watertown article. Emphasis added; on

Origin-Equatorial Guinea, Last name Obama, Calculate the date of birth: publication 1992-age 31=Date of birth
1961 area of study Law
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Published on February 14, 1992, Page 8, Watertown Daily Times
SOVIET UNION'S DEMISE LEAVES LUMUMBA STUDENTS IN A BIND
For nearly a decade, Roman Obama's life at Patrice Lumumba University was almost paradise. He studied for free and got warm clothes
and cheap airline tickets that let him see the world.
"We had so many possibilities. Maybe it was not a luxurious life, but we could travel and do things," said Obama, a 31-year-old law
student from Equatorial Guinea.
The former Soviet Union spent huge sums of money over the past few decades to educate tens of thousands
Complete Article, 662 words: Purchase article
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Thursday, November 5, 2009 7:20 AM

From:
"Ben" <btc@nycap.rr.com>
Add sender to Contacts
To:
dr_taitz@yahoo.com
http://www.foxnews.com/story/0,2933,391882,00.html
Don't know how much of this is new to you, suggests that birth announcements in
Hawaii are fakes due to incorrect letter spacing not used by the era's linotype
Case
Case:
8:09-cv-00082-DOC-AN
09-3403 Document: 00319937504
Document 100 Page:
Filed
1312/03/2009
Date Filed:Page
12/08/2009
12 of 14
machines around paragraphs 32-34 1st sentence "On August 13, 1961, nine days after
his birth, an Obama birth" http://www.oilforimmigration.org/facts/?p=2187
Contains mention of brother, but not much more
It seems if you can connect Patrice Lumuba Friendship University, it may prove a
national security threat:
http://www.heritage.org/Research/RussiaandEurasia/bg660.cfm "Working through the

Mexican Communist Party and the Institute of Mexican-Russian Cultural Exchange, a
Soviet front in Mexico City, the KGB recruited Mexican students and radicals who were
alienated from the political system. They received scholarships for study along with
political indoctrination) at the Patrice Lumumba Friendship University in Moscow. As
graduates, they were infiltrated back into Mexico, where they were to recruit other
students to the revolutionary cause I. d Communist Shock Brigades. Clashes between
students and police broke out in Mexico City in July 19"
http://www.thefreelibrary.com/The+Soviet+roots+of+terrorism:+scratch+any+%22Islamic
%22+terrorist+group...-a0208218572
"The PLO/Fatah movement remains true to its communist roots today, with Moscow-
trained Mahmoud Abbas serving as chairman of the PLO. Abbas studied for a doctorate
from Patrice Lumumba University in Moscow, finishing in 1982. KGB defector Yuri
Bezmenov explained back in 1984 that Patrice Lumumba University was "under the
direct control of the KGB and [the] Central Committee, where future leaders of the so-
called 'National Liberation Movements' are being educated and selected carefully....
They were dispatched back to their countries to be leaders of the so-called 'National
Liberation Movements,' or, to be translated into normal human language, leaders of
international terrorist groups." Abbas then defended his thesis at the Oriental Studies of
the Soviet Academy of Sciences, which was then headed by former KGB General
Yevgeny Primakov."
Somewhere, deep within the site: www.Newzeal.blogspot.com you may be able to find
info that will lead you in a helpful direction. There are about 90 write-ups of Obama's
Socialist and Communist connections under the heading "The Obama Files" (right side,
a couple scrolls down.) I've been doing a little research for the author, he's in the states
right now, think he's heading to CA right now.
Case
Case:
8:09-cv-00082-DOC-AN
09-3403 Document: 00319937504
Document 100 Page:
Filed
1412/03/2009
Date Filed:Page
12/08/2009
13 of 14
and finally:
http://gunnyg.wordpress.com/2009/09/20/barack-obama-russian-plant-new-evidence/
links to:
http://www.wnd.com/index.php?pageId=88439
and
http://pub44.bravenet.com/forum/static/show.php?usernum=3764075825&frmid=6712&msgid=10
71062&cmd=show
Included for proof of its existence, original article here:
http://nl.newsbank.com/nl-
search/we/Archives?p_product=WA&p_theme=wa&p_action=search&p_maxdocs=200&
p_field_label-0=title&p_text_label-0=lumumba&p_field_label-1=Section&p_bool_label-
1=AND&p_field_label-2=Author&p_bool_label-
2=AND&s_dispstring=headline%28lumumba%29%20AND%20section%28*%29%20AN
D%20date%282/14/1992%20to%202/14/1992%29&p_field_date-
0=YMD_date&p_params_date-0=date:B,E&p_text_date-
0=2/14/1992%20to%202/14/1992%29&xcal_numdocs=20&p_perpage=10&p_sort=YMD
_date:D&xcal_useweights=no
Notice the publication date and age of "Roman":
"SOVIET UNION'S DEMISE LEAVES LUMUMBA STUDENTS IN A BIND
Watertown Daily Times (NY) - Friday, February 14, 1992

Author: Associated Press
For nearly a decade, Roman Obama's life at Patrice Lumumba University was almost
paradise. He studied for free and got warm clothes and cheap airline tickets that let him
see the world.
"We had so many possibilities. Maybe it was not a luxurious life, but we could travel and
do things," said Obama, a 31-year-old law student from Equatorial Guinea ."
Case
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09-3403 Document: 00319937504
Document 100 Page:
Filed
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Date Filed:Page
12/08/2009
14 of 14
EXHIBIT “2 ” 6
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(ANx), APPEAL, CLOSED, DISCOVERY, MANADR
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA

(Southern Division − Santa Ana)
CIVIL DOCKET FOR CASE #: 8:09−cv−00082−DOC−AN
Captain Pamela Barnett, et al v. Barack Hussein Obama, et al Date Filed: 01/20/2009

Assigned to: Judge David O. Carter Date Terminated: 10/29/2009
Referred to: Magistrate Judge Arthur Nakazato Jury Demand: None
Case in other court: 9th CCA, 09−56827 Nature of Suit: 440 Civil Rights: Other
Cause: 28:1331 Fed. Question Jurisdiction: Federal Question
Plaintiff
Ambassador Alan Keyes PhD represented by Orly Taitz
Orly Taitz Law Offices
26302 La Paz, Ste 211
Mission Viejo , CA 92691
949−683−5411
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Plaintiff
Wiley S Drake represented by Orly Taitz
(See above for address)
LEAD ATTORNEY
Gary G Kreep
United States Justice Foundation
932 D Street, Suite 2
Ramona , CA 92065
760−788−6624
Fax: 760−788−6414
Email: usjf@usjf.net
Plaintiff
Captain Pamela Barnett represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Lieutenant Colonel Richard Norton represented by Orly Taitz
Bauerbach (See above for address)
LEAD ATTORNEY
Plaintiff
Captain Robin D Biron represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Colonel John D Blair represented by Orly Taitz
LEAD ATTORNEY
Case:
Case:09-3403
8:09-cv-00082-DOC-AN
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Plaintiff
Mr David L Bosley represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Ms Loretta G Bosley represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Captain Harry G Butler represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Representative Glenn Casada represented by Orly Taitz
Tennessee (See above for address)
LEAD ATTORNEY
Plaintiff
Jennifer Leah Clark represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Representative Timothy Comerford represented by Orly Taitz
New Hampshire (See above for address)
LEAD ATTORNEY
Plaintiff
Charles Crusemire represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Representative Cynthia Davis represented by Orly Taitz
Missouri (See above for address)
LEAD ATTORNEY
Plaintiff
Chief Warrant Office Thomas S represented by Orly Taitz
Davidson (See above for address)
LEAD ATTORNEY
Plaintiff
Matthew Michael Edwards represented by Orly Taitz
LEAD ATTORNEY
Case:
Case:09-3403
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Plaintiff
Lieutenant Jason Freese represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Mr Kurt C Fuqua represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Officer Clint Grimes represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Julliett Ireland represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
D Andrew Johnson represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Israel D Jones represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
State Representative Timothy Jones represented by Orly Taitz
ESQ, MO (See above for address)
LEAD ATTORNEY
Plaintiff
Commander David Fullmer LaRoque represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Gail Lightfoot represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
MIL Officer Lita M Lott represented by Orly Taitz
US Army (See above for address)
Case:
Case:09-3403
8:09-cv-00082-DOC-AN
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LEAD ATTORNEY
Plaintiff
Major David Grant Mosby represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
MSGT Steven Kay Neuenschwander represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
State Representative Frank Niceley represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Retired Senator Jerry ONeil represented by Orly Taitz
Montana (See above for address)
LEAD ATTORNEY
Plaintiff
SFC E7 Robert Lee Perry represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Colonel Harry Riley represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Markham Robinson represented by Orly Taitz
LEAD ATTORNEY
Gary G Kreep
Plaintiff
Sergeant Jeffrey Wayne Rosner represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
MSGT Jeffrey Schwilk represented by Orly Taitz
LEAD ATTORNEY
Case:
Case:09-3403
8:09-cv-00082-DOC-AN
Document: 00319937505
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Page: 612:17
Date
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Plaintiff
Captain David Smithey represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Lieutenant Commander John Bruce represented by Orly Taitz
Steidel (See above for address)
LEAD ATTORNEY
Plaintiff
Commander Douglas Earl represented by Orly Taitz
Stoeppelwerth (See above for address)
LEAD ATTORNEY
Plaintiff
Thomas J Taylor represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Representative Eric Swafford represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Captain Neil B Turner represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Richard E Venable represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
LCDR Jeff Graham Winthrope represented by Orly Taitz
LEAD ATTORNEY
Plaintiff
Lieutenant Colonel Mark Wriggle represented by Orly Taitz
LEAD ATTORNEY
V.
Defendant
Case:
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Barack Hussein Obama represented by David A DeJute
SAUSA − Office of US Attorney
300 North Los Angeles Street Room 7516
Los Angeles , CA 90012
213−894−2574
Fax: 213−894−7819
Email: USACAC.Civil@usdoj.gov
LEAD ATTORNEY
Roger E West
AUSA − Office of US Attorney
Civil Division − Federal Building
300 North Los Angeles Street Suite 7516
Los Angeles , CA 90012
213−894−2461
Fax: 213−894−7819
Email: USACAC.Civil@usdoj.gov
LEAD ATTORNEY
Defendant
Condoleeza Rice
in her capacity as Secretary of State
TERMINATED: 07/15/2009
Defendant
Robert Mueller
in his capacity as Director of the Federal
Bureau of Investigation
Defendant
Michael W Hager
in his capacity as Acting Director, Office
of Personnel Management
Defendant
Michelle LR Obama represented by David A DeJute
LEAD ATTORNEY
Roger E West
LEAD ATTORNEY
Defendant
Hillary Rodham Clinton represented by David A DeJute
Secretary of State (See above for address)
LEAD ATTORNEY
Roger E West
LEAD ATTORNEY
Defendant
Case:
Case:09-3403
8:09-cv-00082-DOC-AN
Document: 00319937505
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Robert M Gates represented by David A DeJute
Secretary of Defense (See above for address)
LEAD ATTORNEY
Roger E West
LEAD ATTORNEY
Defendant
Joseph R Biden represented by David A DeJute
Vice−President and President of the (See above for address)
Senate LEAD ATTORNEY
Roger E West
LEAD ATTORNEY
Date Filed # Docket Text

01/20/2009 1 COMPLAINT against Defendants Robert Mueller, Michael W Hager, Barack H
Obama and Condoleeza Rice.(Filing fee $ 350). Filed by Plaintiffs Alan Keyes PhD,
Wiley S Drake and Markham Robinson.(lwag) (lwag). (Entered: 01/23/2009)
01/20/2009 60 DAY Summons Issued re Complaint − (Discovery) 1 as to Defendants Robert
Mueller, Michael W Hager, Barack H Obama and Condoleeza Rice. (lwag) (Entered:
01/23/2009)
01/20/2009 2 CERTIFICATE of Interested Parties filed by Plaintiffs Alan Keyes PhD, Wiley S
Drake and Markham Robinson. (lwag) (lwag). (Entered: 01/23/2009)
01/20/2009 3 NOTICE TO PARTIES OF ADR PILOT PROGRAM filed.(lwag) (lwag). (Entered:
01/23/2009)
05/12/2009 4 ORDER TO SHOW CAUSE FOR LACK OF PROSECUTION by Judge David O.
Carter. Response to Order to Show Cause due by 5/29/2009. (smi) (Entered:
05/13/2009)
05/18/2009 5 PROOF OF SERVICE Executed by plaintiffs upon Barack H Obama served on
2/10/2009, answer due 3/2/2009. The Summons and Complaint were served by
substituted service, by not indicated statute, upon mail clerk at Department of Justice.
Due Dilligence declaration none. Original Summons not returned. (twdb) (Entered:
05/19/2009)
05/27/2009 6 MINUTES OF IN CHAMBERS ORDER TO SHOW CAUSE RE DISMISSAL FOR
LACK OF PROSECUTION held before Judge David O. Carter. The Court, on its
own motion, hereby ORDERS Plaintiff, to show cause in writing no later than June
12, 2009 why this action should not be dismissed for lack of prosecution. See order
for details. (smi) (Entered: 05/27/2009)
05/27/2009 7 First REQUEST for Clerk to Enter Default against defendant Barack H Obama filed
by filer−plaitiff Alan Keyes PhD. (Attachments: # 1 Affidavit Affidavit of process
server)(Taitz, Orly) (Entered: 05/27/2009)
06/01/2009 8 NOTICE OF DEFICIENCY Re: First REQUEST for Clerk to Enter Default against
defendant Barack H Obama 7 . The Clerk cannot enter the requested relief as statute
in which process was served not cited; name of deft does not exactly match name on
complaint. (rla) (Entered: 06/01/2009)
06/02/2009 9 Amendment to First REQUEST for Clerk to Enter Default against defendant Barack
H Obama 7 filed by Plaintiff Alan Keyes PhD. (Taitz, Orly) (Entered: 06/02/2009)
Case:
Case:09-3403
8:09-cv-00082-DOC-AN
Document: 00319937505
As of: 12/03/2009
Page: 912:17
Date
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06/02/2009 10 Amendment to First REQUEST for Clerk to Enter Default against defendant Barack
H Obama 7 filed by Plaintiff Alan Keyes PhD. (Attachments: # 1 Affidavit Amended
affidavit of the process server)(Taitz, Orly) (Entered: 06/02/2009)
06/10/2009 11 NOTICE OF CLERICAL ERROR: Due to clerical error the following docket entry
has been corrected as indicated below: The proof of service filed 5/18/09 answer due
deadline should be 4/11/09. Re: Service of Summons and Complaint Returned
Executed (60 days) 5 (twdb) (Entered: 06/10/2009)
06/10/2009 12 NOTICE OF DEFICIENCY Re: The Clerk cannot enter the requested relief as Proof
of Service is lacking required information. Please reivew Federal Rules regarding
service. (ade) (Entered: 06/10/2009)
06/11/2009 13 NOTICE OF MOTION AND Renewed MOTION for Reconsideration of Entry of
Default, Renewed MOTION to Correct Notice of Deficiency of Proof of Service,
Final Motion for Entry of Default against DefendantBarack H Obama filed by
Plaintiff Alan Keyes PhD. (Taitz, Orly) (Entered: 06/11/2009)
06/12/2009 14 MINUTES (IN CHAMBERS) ORDER Extending Order to Show Cause, and Finding
as Moot Plaintiffs' Motion for Clarification 13 by Judge David O. Carter. In light of
plaintiffs' efforts, the Order to Show Cause is extended until 07/13/2009 to permit
plaintiffs addirtional time to properly effect service pursuant to FRCivP4(i) as to all
defendants. In addition, Plaintiffs' motion is rendered MOOT due to the Court's
extension of the Order to Show Cause. (See order for further details) (db) (Entered:
06/12/2009)
06/14/2009 15 NOTICE OF MOTION AND MOTION for Reconsideration, MOTION for Entry of
Judgment pursuant to Rule 54(b) filed by plaintiff Alan Keyes PhD. (Taitz, Orly)
(Entered: 06/14/2009)
06/22/2009 16 MINUTES OF IN CHAMBERS ORDER by Judge David O. Carter: SETTING
HEARING ON MOTION: Before the Court is a Motion by Plaintiffs for
Reconsideration of Order to Show Cause or in the Alternative to Certify Question for
Appeal. Court sets this matter for hearing on July 13, 2009 at 8:30a.m. in Courtroom
9D. Plaintiffs are directed to make every effort possible to ensure that all remaining
defendants are aware of the hearing and provide documentation that the individual
receiving service is authorized to accept on defendants' behalf. (rla) (Entered:
06/22/2009)
07/05/2009 17 OF SERVICE filed by plaintiff Alan Keyes PhD, served on 06.28.09.. (Attachments:
# 1 Affidavit, # 2 Affidavit)(Taitz, Orly) (Entered: 07/05/2009)
07/07/2009 18 STATEMENT OF INTEREST (DeJute, David) (Entered: 07/07/2009)
07/08/2009 19 NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents. The
following error(s) was found: Title page is missing RE: Proof of Service (subsequent
documents) 17 . In response to this notice the court may order (1) an amended or
correct document to be filed (2) the document stricken or (3) take other action as the
court deems appropriate. (rrp) (Entered: 07/08/2009)
07/11/2009 20 OF SERVICE filed by plaintiff Alan Keyes PhD, Barack H. Obama, aka Barack
Hussein Obama, aka Barry Soetoro served on 06.29.09.. (Attachments: # 1
Affidavit)(Taitz, Orly) (Entered: 07/11/2009)
07/13/2009 21 NOTICE OF MOTION AND MOTION for Default Judgment against Defendant
Barack H. Obama, aka Barack Hussein Obama,II, a/k/a Barack H. Obama,II, a/k/a
Barry Obama, a/k/a Barry Soetoro filed by plaintiff Alan Keyes PhD. (Attachments: #
1 Exhibit Exhibit A, # 2 Exhibit Exhibit B, # 3 Appendix Appendix to Exhibit
B)(Taitz, Orly) (Entered: 07/13/2009)
07/13/2009 24 MINUTES OF Motion Hearing held before Judge David O. Carter: RE: MOTION for
Reconsideration of Order to Show Cause or in the Alternative to Certify Question for
Appeal 15 : Counsel are excused to meet and confer regarding service of Complaint.
Counsel return and advised the Court of their agreement to a means of proper service
upon President Barack Obama. Court directs plaintiffs to immediately effect service
of the Complaint upon a person authorized to accept service at the United States
Attorneys Office as to the remaining defendant. Court Reporter: Debbie Gale. (rla)
(Entered: 07/17/2009)
Case:
Case:
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8:09-cv-00082-DOC-AN
Document: 00319937505
As of: 12/03/2009
Page: 1012:17Date
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07/15/2009 22 FIRST AMENDED COMPLAINT filed by Plaintiff Alan Keyes PhD. (Taitz, Orly)
(Additional attachment(s) added on 8/24/2009: # 1 Summons Issued) (lwag).
(Entered: 07/15/2009)
07/15/2009 23 MINUTES (IN CHAMBERS): ORDER by Judge David O. Carter: FINDING
MOTION FOR RECONSIDERATION AS MOOT 15 : Counts Two and Three of the
Original Complaint, as well as all Defendants besides President Obama, are HEREBY
VOLUNTARILY DISMISSED. The Clerk shall serve this minute order on all parties
to the action. (rla) (Entered: 07/16/2009)
07/16/2009 25 MINUTES ( IN CHAMBERS) : ORDER held before Judge David O. Carter re: First
Amended Complaint 22 . Plaintiffs are ORDERED to properly serve the First
Amended Complaint on or before August 16, 2009 and file Proof of Service of such
on or before August 23, 2009. (dg) (Entered: 07/17/2009)
following error(s) was found: Hearing information is missing, incorrect, or not timely
RE: MOTION for Default Judgment 21 . In response to this notice the court may
order (1) an amended or correct document to be filed (2) the document stricken or (3)
take other action as the court deems appropriate. (twdb) (Entered: 07/17/2009)
07/30/2009 27 PROOF OF SERVICE Executed by Plaintiff Alan Keyes PhD, uponJoseph R Biden
served on 7/15/2009, answer due 9/13/2009. The Summons and Complaint were
served by registered California Process server, by Federal statute. Service accepted by
Flabia De La Rosa on behalf of Thomas O'Brien, US Atty. Original Summons not
returned. (Attachments: # 1 Appendix, # 2 Appendix)(Taitz, Orly) (Entered:
07/30/2009)
07/30/2009 28 PROOF OF SERVICE Executed by Plaintiff Alan Keyes PhD, uponUNITED
STATES OF AMERICA served on 7/15/2009, answer due 9/13/2009. The Summons
and Complaint were served by registered California process server, by Federal statute.
Service accepted by Flabia De La Rosa on behalf of Thomas O'Brien, US atty.
Original Summons not returned. (Taitz, Orly) (Entered: 07/30/2009)
07/30/2009 29 PROOF OF SERVICE Executed The Summons and Complaint were served by
registered California process server, by Federal statute. Service accepted by Flabia De
La Rosa on behalf of Thomas O'Brien US attorney. Original Summons not returned.
(Taitz, Orly) (Entered: 07/30/2009)
07/30/2009 30 PROOF OF SERVICE Executed by Plaintiff Alan Keyes PhD, uponMichelle LR
Obama served on 7/15/2009, answer due 9/13/2009. The Summons and Complaint
were served by registered California Process server, by Federal statute. Service
accepted by Flabia de la Rosa on behalf of Thomas O'Brien, US atty. Original
Summons not returned. (Taitz, Orly) (Entered: 07/30/2009)
07/30/2009 31 PROOF OF SERVICE Executed by Plaintiff Alan Keyes PhD, uponHillary Rodham
Clinton served on 7/15/2009, answer due 9/13/2009. The Summons and Complaint
were served by registered California process server, by Federal statute. Service
accepted by Flabia De La Rosa on behalf of Thomas O'Brien, US atty. Original
Summons not returned. (Taitz, Orly) (Entered: 07/30/2009)
07/30/2009 32 PROOF OF SERVICE Executed by Plaintiff Alan Keyes PhD, uponRobert M Gates
served on 7/15/2009, answer due 9/13/2009. The Summons and Complaint were
served by registered California process server, by Federal statute. Service accepted by
Flabia De La Rosa on behalf of Thomas O'Brien US atty. Original Summons not
returned. (Taitz, Orly) (Entered: 07/30/2009)
08/01/2009 33 NOTICE OF DISMISSAL filed by Plaintiff Markham Robinson, Wiley S Drake
pursuant to FRCP 41a(1) as to all defendants. (Taitz, Orly) (Entered: 08/01/2009)
08/01/2009 34 NOTICE OF MOTION AND MOTION to Expedite authentication, MOTION for
Issuance of Letters Rogatory for authenticity of Kenyan birth certificate filed by
Plaintiff Alan Keyes PhD. (Attachments: # 1 Appendix Photocopy of Obama's birth
certificate from Kenya)(Taitz, Orly) (Entered: 08/01/2009)
08/06/2009 35 ORDER by Magistrate Judge Arthur Nakazato: the documents listed below were
improperly filed for the following reasons: Lacks proper notice; improper form and
format; counsel failed to identify her Cal. State Bar No.; description of motion
Case:
Case:09-3403
8:09-cv-00082-DOC-AN
Document: 00319937505
As of: 12/03/2009
Page: 11
12:17Date
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Filed: 12/08/2009
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conflicts or differs from that which counsel entered on Court's e−docket; therefore,
the following document(s) shall be stricken from the record and shall not be
considered by the Court: MOTION to Expedite authentication MOTION for Issuance
of Letters Rogatory for authenticity of Kenyan birth certificate 34 . (rla) (Entered:
08/06/2009)
08/07/2009 36 NOTICE of Change of Attorney Information for attorney Roger E West counsel for
Defendants Michelle LR Obama, Hillary Rodham Clinton, Robert M Gates, Joseph R
Biden, Barack Hussein Obama, Interested Party UNITED STATES OF AMERICA.
Changing e−mail to roger.west4@usdoj.gov. Adding Roger E. West as attorney as
counsel of record for Defendants for the reason indicated in the G−06 Notice. Filed by
Defendants Barack H. Obama, et al. (West, Roger) (Entered: 08/07/2009)
08/18/2009 37 DECLINED STATEMENT OF CONSENT TO PROCEED before the assigned
Magistrate Judge filed by plaintiff Alan Keyes PhD. (Taitz, Orly) (Entered:
08/18/2009)
08/19/2009 38 NOTICE NOTICE OF MANUAL FILING filed by plaintiff Markham Robinson,
Wiley S Drake. (Kreep, Gary) (Entered: 08/19/2009)
following error(s) was found: Incorrect event selected, correct event is Review and
Incorrect category selected, correct category is Motion RE: Consent to Proceed
(CV−11C) DECLINED before US Magistrate Judge MJ Pilot 37 . In response to this
notice the court may order (1) an amended or correct document to be filed (2) the
document stricken or (3) take other action as the court deems appropriate. (rrp)
(Entered: 08/19/2009)
08/19/2009 40 NOTICE OF FAILURE BY PLAINTIFFS TO PROPERLY EFFECT SERVICE OF
PROCESS; DECLARATIONS OF DAVID A. DeJUTE AND FLABIA DE LA
ROSA filed by Defendants Michelle LR Obama, Hillary Rodham Clinton, Robert M
Gates, Joseph R Biden, Barack Hussein Obama, UNITED STATES OF AMERICA.
(Attachments: # 1 Exhibit 1−5)(West, Roger) (Entered: 08/19/2009)
08/20/2009 41 opposition to magistrate filed by Plaintiffs Clint Grimes, Julliett Ireland, D Andrew
Johnson, Israel D Jones, Timothy Jones, David Fullmer LaRoque, Gail Lightfoot, Lita
M Lott, David Grant Mosby, Steven Kay Neuenschwander, Frank Niceley, Jerry
ONeil, Robert Lee Perry, Harry Riley, Markham Robinson, Jeffrey Wayne Rosner,
Jeffrey Schwilk, David Smithey, John Bruce Steidel, Douglas Earl Stoeppelwerth,
Thomas J Taylor, Eric Swafford, Neil B Turner, Richard E Venable, Jeff Graham
Winthrope, Mark Wriggle, Alan Keyes PhD, Wiley S Drake, Pamela Barnett, Richard
Norton Bauerbach, Robin D Biron, John D Blair, David L Bosley, Loretta G Bosley,
Harry G Butler, Glenn Casada, Jennifer Leah Clark, Timothy Comerford, Charles
Crusemire, Cynthia Davis, Thomas S Davidson, Matthew Michael Edwards, Jason
Freese, Kurt C Fuqua (Taitz, Orly) (Entered: 08/20/2009)
08/20/2009 42 REFERRAL OF MOTION to Disqualify Magistrate Judge Arthur Nakazatohas been
filed. Pursuant to GO 08.05 and Local Rule 72−5 MOTION for Review 37 is referred
to Judge David O. Carter for determination. (jal) (Entered: 08/20/2009)
08/20/2009 43 Amendment to MOTION to Expedite authentication MOTION for Issuance of Letters
Rogatory for authenticity of Kenyan birth certificate 34 filed by Plaintiff Alan Keyes
PhD. (Taitz, Orly) (Entered: 08/20/2009)
08/21/2009 44 MINUTES OF IN CHAMBERS ORDER by Judge David O. Carter: ORDER
SETTING SEPTEMBER 8, 2009 HEARING ONMOTIONS: (See document for
details.) In summary, the Court sets for hearing at 8:00 a.m. on September 8, 2009, (1)
the Discovery Motion, (2) the Service Notice, and (3) the Ex Parte Application. All
parties are ordered to be present. The Clerk shall serve this minute order on all parties
to the action. (rla) (Entered: 08/21/2009)
08/24/2009 45 EX PARTE APPLICATION to Vacate Plaintiffs' Voluntary Dismsisal filed by
plaintiff Markham Robinson, Wiley S Drake. (Attachments: # 1 Supplement Memo of
Points and Authorities, # 2 Declaration Declaration of Markham Robinson, # 3
Declaration Declaration of Wiley S. Drake, # 4 Declaration Declaration of Elliot
Wilson, # 5 Exhibit Exhibit 1 − Wiley Substitution, # 6 Exhibit Exhibit 2 − Markham
Substitution, # 7 Exhibit Letter from Dr. Taitz, # 8 Exhibit Notice of Dismissal, # 9
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Proposed Order Proposed Order Granting Ex Parte Application)(Kreep, Gary)

(Entered: 08/24/2009)
08/24/2009 60 DAY Summons Issued re First Amended Complaint − (Discovery) 22 as to
Biden and Barack Hussein Obama. (lwag) (Entered: 08/24/2009)
08/26/2009 46 PROOF OF SERVICE Executed 08.25.09. The Summons and Complaint were served
by process server, by Federal statute. Service accepted by Patricia Myles, civil process
clerk for US attorneys on behalf of all defendants. Original Summons was returned.
(Taitz, Orly) (Entered: 08/26/2009)
08/26/2009 47 DECLARATION of Gary G. Kreep in support of EX PARTE APPLICATION to
Vacate Plaintiffs' Voluntary Dismsisal 45 filed by Plaintiffs Markham Robinson,
following error(s) was found: Local Rule 7−19.1 Notice to other parties of ex parte
application lacking RE: EX PARTE APPLICATION to Vacate 45 . In response to this
notice the court may order (1) an amended or correct document to be filed (2) the
document stricken or (3) take other action as the court deems appropriate. (twdb)
(Entered: 08/27/2009)
08/27/2009 49 CERTIFICATE OF SERVICE filed by plaintiff Markham Robinson, Wiley S Drake,
re EX PARTE APPLICATION to Vacate Plaintiffs' Voluntary Dismsisal 45 served on
August 27, 2009. (Kreep, Gary) (Entered: 08/27/2009)
following error(s) was found: Title page is missing RE: Declaration (Motion related)
47 . In response to this notice the court may order (1) an amended or correct document
to be filed (2) the document stricken or (3) take other action as the court deems
appropriate. (rrp) (Entered: 08/27/2009)
08/28/2009 51 DECLARATION of Gary G. Kreep in support of EX PARTE APPLICATION to
Vacate Plaintiffs' Voluntary Dismsisal 45 filed by Plaintiffs Markham Robinson,
following error(s) was found: Title page is missing RE: Proof of Service (subsequent
documents) 49 . In response to this notice the court may order (1) an amended or
correct document to be filed (2) the document stricken or (3) take other action as the
court deems appropriate. (twdb) (Entered: 09/01/2009)
09/01/2009 53 OF SERVICE filed by plaintiff Markham Robinson, Wiley S Drake, re EX PARTE
APPLICATION to Vacate Plaintiffs' Voluntary Dismsisal 45 served on 8/27/2009.
(Kreep, Gary) (Entered: 09/01/2009)
09/02/2009 54 CERTIFICATE OF SERVICE filed by plaintiff Markham Robinson, Wiley S Drake,
re EX PARTE APPLICATION to Vacate Plaintiffs' Voluntary Dismsisal 45 served on
September 2, 2009. (Kreep, Gary) (Entered: 09/02/2009)
09/04/2009 55 NOTICE Declaration regarding Kenian Hospital Birth Certificate of Barack Obama
filed by plaintiff Alan Keyes PhD. (Attachments: # 1 Declaration Declaration
regarding Kenian Hospital Birth Certificate, # 2 Appendix Kenian Hospital Birth
Certificate for Barack Obama)(Taitz, Orly) (Entered: 09/04/2009)
09/04/2009 56 NOTICE OF MOTION AND MOTION to Dismiss Case ; AND MEMORANDUM OF
POINTS AND AUTHORITIES IN SUPPORT OF MOTION filed by Defendants
Michelle LR Obama, Hillary Rodham Clinton, Robert M Gates, Joseph R Biden,
Barack Hussein Obama, UNITED STATES OF AMERICA. Motion set for hearing
on 10/5/2009 at 08:30 AM before Judge David O. Carter. (Attachments: # 1 Exhibit 1
and 2)(West, Roger) (Entered: 09/04/2009)
09/08/2009 57 ORDER SETTING SCHEDULING CONFERENCE FOR 10/5/2009 at 8:30 AM
before Judge David O. Carter. (rrp) (Entered: 09/08/2009)
09/08/2009 58 ORDER by Judge David O. Carter DENYING PLAINTIFFS MOTION FOR
MODIFICATION OF MAGISTRATE JUDGE NAKAZATOS AUGUST 6, 2009
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ORDER AND DENYING PLAINTIFFS MOTION TO RECUSE MAGISTRATE

JUDGE NAKAZATO; GRANTING EX PARTE APPLICATION FOR ORDER
VACATING VOLUNTARY DISMISSAL. Plaintiffs Motion to Modify the
Magistrate Judges August 6, 2009 Order and Motion to Recuse the Magistrate Judge
37 is DENIED. Plaintiffs Robinson and Drakes Ex Parte Application for Order
Vacating Voluntary Dismissal 45 is hereby GRANTED. (kh) (Entered: 09/08/2009)
09/08/2009 74 MINUTES OF Hearing re: Discovery; Service Notice and ex Parte Application held
before Judge David O. Carter: Court and counsel confer re service of Defendants.
Defense counsel states that service has been effectuated. Court and counsel confer
regarding Ex Parte Application to Vacate Dismissal filed by Markham Robinson and
Wiley S. Drake. Court grants Ex Parte Application. Attorney Gary Kreep added to the
case. Court sets Scheduling Conference for October 5, 2009, at 8:30 a.m. Court and
counsel confer and set tentative case management dates. Court and counsel confer
regarding recusal of Magistrate Judge Arthur Nakazato. Court denies, without
prejudice, Plaintiffs Motion to Recuse the Magistrate Judge. The Court also denies
Plaintiffs Motion for Modification of Magistrate Judge Nakazatos August 6, 2009
Order. Court Reporter: Maria Dellaneve. (kh) (Entered: 09/25/2009)
09/10/2009 59 MINUTES OF IN CHAMBERS ORDER Referring Motion to Magistrate Judge held
before Judge David O. Carter. Court orders First Amended Motion for Issuance of
Letters Rogatory and Initiation of Discovery,filed by plaintiffs on August 20, 2009
referred to assigned Magistrate Judge Arthur Nakazato. Accordingly, the noticed
hearing date of September 14, 2009 at 8:30 a.m. before this Court is vacated. (db)
(Entered: 09/10/2009)
09/10/2009 60 EX PARTE APPLICATION for Order for LIMITED STAY OF DISCOVERY ;
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF filed
by Defendants Michelle LR Obama, Hillary Rodham Clinton, Robert M Gates, Joseph
R Biden, Barack Hussein Obama, UNITED STATES OF AMERICA. (Attachments:
# 1 Proposed Order)(West, Roger) (Entered: 09/10/2009)
09/11/2009 61 MEMORANDUM in Opposition TO PLAINTIFFS' FIRST AMENDED MOTION
FOR ISSUANCE OF LETTERS ROGATORY AND INITIATION OF DISCOVERY
filed by Defendants Michelle LR Obama, Hillary Rodham Clinton, Robert M Gates,
Joseph R Biden, Barack Hussein Obama, Interested Party UNITED STATES OF
AMERICA. (West, Roger) (Entered: 09/11/2009)
09/11/2009 62 NOTICE of Appearance filed by attorney Gary G Kreep on behalf of Plaintiffs
Markham Robinson, Wiley S Drake (Kreep, Gary) (Entered: 09/11/2009)
09/13/2009 63 NOTICE filed by plaintiff Pamela Barnett. (Attachments: # 1 Letter proposed
schedule of depositions, notice of motion to disqualify Gary Kreep as a co−counsel
due to conflict of interest)(Taitz, Orly) (Entered: 09/13/2009)
09/14/2009 64 OPPOSITION TO APPLICATION FOR LIMITED STAY OF DISCOVERY re: EX
PARTE APPLICATION for Order for LIMITED STAY OF DISCOVERY ;
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF 60
filed by Plaintiffs Markham Robinson, Wiley S Drake. (Attachments: # 1 Declaration
Declaration in Support of Plaintiff's Opposition to Defendants' Ex Parte Application
For Limited Stay of Discovery, # 2 Appendix Plaintiffs' Compendium of Authorities
in Support of Plaintiffs' Opposition to Defendants' Ex Parte Application For Limited
Stay of Discovery, # 3 Exhibit Exhibits to Plaintiffs' Compendium of Authorities in
Support of Plaintiffs' Opposition to Defendants' Ex Parte Application For Limited
Stay of Discovery)(Kreep, Gary) (Entered: 09/14/2009)
09/15/2009 65 REVISED OPPOSITION to Ex Parte Application for Limited Stay of Discovery re:
EX PARTE APPLICATION for Order for LIMITED STAY OF DISCOVERY ;
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF 60
filed by Plaintiffs Markham Robinson, Wiley S Drake. (Attachments: # 1 Declaration
Declaration of Gary G. Kreep in Support of Filing Plaintiffs' Revised Opposition to
Defendants' Ex Parte Application For Limited Stay of Discovery, # 2 Declaration
Declaration of Gary G. Kreep in Support of Filing Plaintiffs' Revised Opposition to
Defendants' Ex Parte Application For Limited Stay of Discovery, # 3 Appendix
Plaintiffs' Compendium of Authorities in Support of Plaintiffs' Opposition to
Defendants' Ex Parte Application For Limited Stay of Discovery, # 4 Exhibit Exhibits
to Plaintiffs' Compendium of Authorities in Support of Plaintiffs' Revised Opposition
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to Defendants' Ex Parte Application For Limited Stay of Discovery)(Kreep, Gary)

(Entered: 09/15/2009)
09/16/2009 66 MINUTES (IN CHAMBERS): ORDER by Judge David O. Carter granting 60 Ex
Parte Application for Order for Limited Stay of Discovery. All discovery herein shall
be stayed pending resolution of Defendants Motion to Dismiss, except for any
discovery as to which Plaintiffs can demonstrate, to the satisfaction of Magistrate
Judge Nakazato, is necessary for the purpose of opposing the Motion to Dismiss.
(ade) (Entered: 09/17/2009)
09/18/2009 67 OPPOSITION to MOTION to Dismiss Case ; AND MEMORANDUM OF POINTS
AND AUTHORITIES IN SUPPORT OF MOTION 56 filed by Plaintiffs Markham
Robinson, Wiley S Drake. (Attachments: # 1 Appendix Plaintiffs' Compendium of
Authorities in support of Plaintiffs' Opposition to Defendants' Motion to Dismiss, # 2
Exhibit Exhibits to Plaintiffs' Compendium of Authorities in support of Plaintiffs'
Opposition to Defendants' Motion to Dismiss)(Kreep, Gary) (Entered: 09/18/2009)
09/21/2009 68 JOINT REPORT Rule 26(f) Discovery Plan filed by Defendants Michelle LR Obama,
Hillary Rodham Clinton, Robert M Gates, Joseph R Biden, Barack Hussein Obama,
Interested Party UNITED STATES OF AMERICA.. (West, Roger) (Entered:
09/21/2009)
09/23/2009 70 MINUTES OF IN CHAMBERS ORDER by Judge David O. Carter: DENYING
REQUEST TO FILE SECOND AMENDED COMPLAINT WITHOUT LEAVE OF
COURT 69 : The Clerk shall serve this minute order on all parties to the action. (rla)
(Entered: 09/23/2009)
09/23/2009 71 OF SERVICE filed by plaintiff Pamela Barnett, served on 09,23.09.. (Taitz, Orly)
(Entered: 09/23/2009)
09/25/2009 72 REPLY MEMORANDUM TO OPPOSITION TO DEFENDANTS' MOTION TO
DISMISS FILED BY ALL PALINTIFFS EXCEPT DRAKE AND ROBINSON filed by
Biden, Barack Hussein Obama, Interested Party UNITED STATES OF AMERICA.
(Attachments: # 1 Attachment)(West, Roger) (Entered: 09/25/2009)
09/25/2009 73 REPLY MEMORANDUM TO OPPOSITION FILED BY PLAINTIFFS DRAKE AND
ROBINSON filed by Defendants Michelle LR Obama, Hillary Rodham Clinton,
Robert M Gates, Joseph R Biden, Barack Hussein Obama, Interested Party UNITED
STATES OF AMERICA. (West, Roger) (Entered: 09/25/2009)
09/26/2009 75 NOTICE OF MOTION AND MOTION for Leave to file Surreply filed by plaintiff
Clint Grimes, Julliett Ireland, D Andrew Johnson, Israel D Jones, Timothy Jones,
David Fullmer LaRoque, Gail Lightfoot, Lita M Lott, David Grant Mosby, Steven
Kay Neuenschwander, Frank Niceley, Jerry ONeil, Robert Lee Perry, Harry Riley,
Jeffrey Wayne Rosner, Jeffrey Schwilk, David Smithey, John Bruce Steidel, Douglas
Earl Stoeppelwerth, Eric Swafford, Neil B Turner, Richard E Venable, Jeff Graham
Winthrope, Mark Wriggle, Alan Keyes PhD, Pamela Barnett, Richard Norton
Bauerbach, Robin D Biron, John D Blair, David L Bosley, Loretta G Bosley, Harry G
Butler, Glenn Casada, Jennifer Leah Clark, Timothy Comerford, Charles Crusemire,
Cynthia Davis, Thomas S Davidson, Matthew Michael Edwards, Jason Freese, Kurt C
Fuqua. Motion set for hearing on 10/1/2009 at 08:30 AM before Judge David O.
Carter. (Taitz, Orly) (Entered: 09/26/2009)
09/28/2009 76 MINUTES (IN CHAMBERS): ORDER by Judge David O. Carter: REQUEST FOR
LEAVE OF COURT TO FILE SUR−REPLY 75 : The Court GRANTS Plaintiffs'
Motion and will give Plaintiffs leave of court to file a surreply not to exceed ten (10)
pages to be filed by 5 p.m. on October 1, 2009. Plaintiffs' courtesy copy of the
sur−reply shall be delivered to the Court's dropbox on the ninth floor of the Santa Ana
courthouse by no later than noon on October 2, 2009. The Clerk shall serve this
minute order on all parties to the action. (rla) (Entered: 09/28/2009)
09/30/2009 77 MINUTES OF IN CHAMBERS ORDER held before Judge David O. Carter: On
09/28/09, Court received letter from attorney Philip J Berg requesting Exhibit 7 to
Response in Opposition to Motion 69 be sealed as it contains personal identifying
information(see Order for specifics). Court orders Plaintiffs Opposition to Motion to
Dismiss Case (Doc 69) sealed. Plaintiffs shall refile redacted copy of entire
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Opposition to Motion to Dismiss, including all exhibits by Friday, October 2, 5 p.m.

(ln) (Entered: 09/30/2009)
10/01/2009 78 opposition surreply opposition to motion to dismiss re: MOTION to Dismiss Case ;
AND MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
MOTION 56 filed by Plaintiffs Clint Grimes, Julliett Ireland, D Andrew Johnson,
Israel D Jones, Timothy Jones, David Fullmer LaRoque, Gail Lightfoot, Lita M Lott,
David Grant Mosby, Steven Kay Neuenschwander, Frank Niceley, Jerry ONeil,
Robert Lee Perry, Harry Riley, Jeffrey Wayne Rosner, Jeffrey Schwilk, David
Smithey, John Bruce Steidel, Douglas Earl Stoeppelwerth, Eric Swafford, Neil B
Turner, Richard E Venable, Jeff Graham Winthrope, Mark Wriggle, Alan Keyes PhD,
Pamela Barnett, Richard Norton Bauerbach, Robin D Biron, John D Blair, David L
Bosley, Loretta G Bosley, Harry G Butler, Glenn Casada, Jennifer Leah Clark,
Timothy Comerford, Charles Crusemire, Cynthia Davis, Thomas S Davidson,
Matthew Michael Edwards, Jason Freese, Kurt C Fuqua, Defendant Robert Mueller.
(Attachments: # 1 Exhibit Letter from snator Sessions, # 2 Exhibit Quo Warranto
request submitted to Atty Gen Eric Holder, # 3 Exhibit Request for investigations of
Obama's background from the office of the Sec of State of KY, # 4 Exhibit Affidavit
PI Susan Daniels−Obama's use of SS number of the deceased)(Taitz, Orly) (Entered:
10/01/2009)
10/01/2009 79 NOTICE OF MOTION AND MOTION to Sever PLAINTIFFS filed by PLAINTIFFS
Markham Robinson, Wiley S Drake. (Attachments: # 1 Declaration Declaration of
Wiley Drake in Support of Motion for Severance, # 2 Exhibit Exhibit 10 in Support of
Motion for Severance, # 3 Exhibit Exhibits 1−9 in Support of Motion for Severance, #
4 Declaration Declaration of Gary Kreep in Support of Motion for Severance, # 5
Exhibit Proposed Second Amended Complaint)(Kreep, Gary) (Entered: 10/01/2009)
10/02/2009 80 OPPOSITION filed by Plaintiffs Clint Grimes, Julliett Ireland, D Andrew Johnson,
Turner, Richard E Venable, Jeff Graham Winthrope, Alan Keyes PhD, Pamela
Barnett, Richard Norton Bauerbach, Robin D Biron, John D Blair, David L Bosley,
Loretta G Bosley, Harry G Butler, Glenn Casada, Jennifer Leah Clark, Timothy
Comerford, Charles Crusemire, Cynthia Davis, Thomas S Davidson, Matthew
Michael Edwards, Jason Freese, Kurt C Fuqua, Defendant Michael W Hager.
(Attachments: # 1 Exhibit Dossier # 3, # 2 Exhibit Dossier #4, # 3 Exhibit Dossier #5,
# 4 Exhibit FOIA from Pamela Barnett, # 5 Exhibit Letter from legal counsel to
Chairman of Joint Ch. of Staff, # 6 Exhibit Quo Warranto, # 7 Exhibit Easterling et al
motion to file under original jurisdiction, # 8 Exhibit Certified mail receipt US Atty
District of Columbia Jeffrey Taylor, # 9 Exhibit Dossier #1 no Social Security
Numbers)(Taitz, Orly) (Entered: 10/02/2009)
10/05/2009 81 MINUTES OF taking under advisement 56 Motion to Dismiss Case ; Motion Hearing
held before Judge David O. Carter:; Scheduling Conference held before Judge David
O. Carter. Case Management dates are as follows: Motion for Summary Judgment
Hearing December 7, 2009, at 8:30 a.m. File Motion for Summary Judgment
November 16, 2009 Opposition to Motion for Summary Judgment November 26,
2009 Reply to Motion for Summary Judgment November 30, 2009 Final Pretrial
Conference January 11, 2010, at 8:30 a.m. Jury Trial January 26, 2010, at 8:30 a.m.
Court Reporter: Debbie Gale. (ade) (Entered: 10/07/2009)
10/07/2009 82 EX PARTE APPLICATION to Accelerate motion for relief from stay of discovery
Order on Motion to Dismiss Case, Motion Hearing, Scheduling Conference,,,,,, 81
filed by plaintiffs Clint Grimes, Julliett Ireland, D Andrew Johnson, Israel D Jones,
Timothy Jones, David Fullmer LaRoque, Gail Lightfoot, Lita M Lott, David Grant
Mosby, Steven Kay Neuenschwander, Frank Niceley, Jerry ONeil, Robert Lee Perry,
Harry Riley, Jeffrey Wayne Rosner, Jeffrey Schwilk, David Smithey, John Bruce
Steidel, Douglas Earl Stoeppelwerth, Eric Swafford, Neil B Turner, Richard E
Venable, Jeff Graham Winthrope, Mark Wriggle, Alan Keyes PhD, Pamela Barnett,
Richard Norton Bauerbach, Robin D Biron, John D Blair, David L Bosley, Loretta G
Bosley, Harry G Butler, Glenn Casada, Jennifer Leah Clark, Timothy Comerford,
Charles Crusemire, Cynthia Davis, Thomas S Davidson, Matthew Michael Edwards,
Jason Freese, Kurt C Fuqua. (Attachments: # 1 Exhibit 1st response from US attorney
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Roger West, # 2 Exhibit 2nd response from the US attorney Roger West)(Taitz, Orly)
(Entered: 10/07/2009)
10/08/2009 83 MINUTES (IN CHAMBERS): ORDER by Judge David O. Carter: DENYING EX
PARTE MOTION FOR RELIEF FROM STAY OF DISCOVERY 82 : The Ex Parte
Motion is hereby DENIED. The Clerk shall serve this minute order on all parties to
the action. (rla) (Entered: 10/08/2009)
10/11/2009 84 Request for judicial notice filed by Plaintiffs Clint Grimes, Julliett Ireland, D Andrew
Johnson, Israel D Jones, Timothy Jones, David Fullmer LaRoque, Gail Lightfoot, Lita
M Lott, David Grant Mosby, Steven Kay Neuenschwander, Frank Niceley, Jerry
ONeil, Robert Lee Perry, Harry Riley, Jeffrey Wayne Rosner, Jeffrey Schwilk, David
Matthew Michael Edwards, Jason Freese, Kurt C Fuqua (Attachments: # 1 Affidavit
Expanded affidavit by Susan Daniels)(Taitz, Orly) (Entered: 10/11/2009)
following error(s) was found: Incorrect event selected RE: Miscellaneous Document
84 . In response to this notice the court may order (1) an amended or correct document
to be filed (2) the document stricken or (3) take other action as the court deems
appropriate. (twdb) (Entered: 10/14/2009)
10/16/2009 86 REQUEST FOR JUDICIAL NOTICE filed by plaintiffs Clint Grimes, Julliett Ireland,
D Andrew Johnson, Israel D Jones, Timothy Jones, David Fullmer LaRoque, Gail
Lightfoot, Lita M Lott, David Grant Mosby, Steven Kay Neuenschwander, Frank
Niceley, Jerry ONeil, Robert Lee Perry, Harry Riley, Jeffrey Wayne Rosner, Jeffrey
Schwilk, David Smithey, John Bruce Steidel, Douglas Earl Stoeppelwerth, Eric
Swafford, Neil B Turner, Richard E Venable, Jeff Graham Winthrope, Mark Wriggle,
Alan Keyes PhD, Pamela Barnett, Richard Norton Bauerbach, Robin D Biron, John D
Blair, David L Bosley, Loretta G Bosley, Harry G Butler, Glenn Casada, Jennifer
Leah Clark, Timothy Comerford, Charles Crusemire, Cynthia Davis, Thomas S
Davidson, Matthew Michael Edwards, Jason Freese, Kurt C Fuqua. (Attachments: # 1
Affidavit Expanded affidavit by Susan Daniels− use of ss number of the deceased by
Barack Obama)(Taitz, Orly) (Entered: 10/16/2009)
10/22/2009 87 REQUEST FOR JUDICIAL NOTICE filed by Defendants Michelle LR Obama,
Hillary Rodham Clinton, Robert M Gates, Joseph R Biden, Barack Hussein Obama,
United States of America. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(West, Roger)
(Entered: 10/22/2009)
10/25/2009 88 REQUEST FOR JUDICIAL NOTICE filed by plaintiffs Clint Grimes, Julliett Ireland,
D Andrew Johnson, Israel D Jones, Timothy Jones, David Fullmer LaRoque, Gail
Lightfoot, Lita M Lott, David Grant Mosby, Steven Kay Neuenschwander, Frank
Niceley, Jerry ONeil, Robert Lee Perry, Harry Riley, Jeffrey Wayne Rosner, Jeffrey
Schwilk, David Smithey, John Bruce Steidel, Douglas Earl Stoeppelwerth, Eric
Exhibit 2004 AP article "Kenyan born Obama...")(Taitz, Orly) (Entered: 10/25/2009)
10/29/2009 89 ORDER by Judge David O. Carter: REGARDING DEFENDANTS' MOTION TO
DISMISS 56 : (See document for details.) Defendants' Motion to Dismiss is
GRANTED. IT IS SO ORDERED. (MD JS−6. Case Terminated) (rla) (Entered:
10/29/2009)
11/09/2009 90 NOTICE OF MOTION AND MOTION for Reconsideration re Order on Motion to
Dismiss Case 89 filed by plaintiffs Clint Grimes, Julliett Ireland, D Andrew Johnson,
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Turner, Richard E Venable, Jeff Graham Winthrope, Mark Wriggle, Pamela Barnett,
Richard Norton Bauerbach, Robin D Biron, David L Bosley, Loretta G Bosley, Harry
G Butler, Glenn Casada, Jennifer Leah Clark, Timothy Comerford, Charles
Crusemire, Cynthia Davis, Thomas S Davidson, Matthew Michael Edwards, Jason
Freese, Kurt C Fuqua. Motion set for hearing on 11/20/2009 at 09:00 AM before
Judge David O. Carter. (Attachments: # 1 Exhibit Declaration of Orly Taitz, # 2
Exhibit Coroners report of Donald Young, Affidavit of Larry Sinclair)(Taitz, Orly)
(Entered: 11/09/2009)
11/13/2009 91 REQUEST FOR JUDICIAL NOTICE re MOTION for Reconsideration re Order on
Motion to Dismiss Case 89 MOTION for Reconsideration re Order on Motion to
Dismiss Case 89 MOTION for Reconsideration re Order on Motion to Dismiss Case
89 MOTION for Reconsideration re Order on Motion to Dismiss Case 89 MOTION
for Reconsideration re Order on Motion to Dismiss Case 89 90 filed by plaintiffs Clint
Grimes, Julliett Ireland, D Andrew Johnson, Israel D Jones, Timothy Jones, David
Fullmer LaRoque, Gail Lightfoot, Lita M Lott, David Grant Mosby, Steven Kay
Neuenschwander, Frank Niceley, Jerry ONeil, Robert Lee Perry, Harry Riley, Jeffrey
Wayne Rosner, Jeffrey Schwilk, David Smithey, John Bruce Steidel, Douglas Earl
Stoeppelwerth, Eric Swafford, Neil B Turner, Richard E Venable, Jeff Graham
Winthrope, Mark Wriggle, Alan Keyes PhD, Pamela Barnett, Richard Norton
Bauerbach, Robin D Biron, John D Blair, David L Bosley, Loretta G Bosley, Harry G
Butler, Glenn Casada, Jennifer Leah Clark, Timothy Comerford, Charles Crusemire,
Cynthia Davis, Thomas S Davidson, Matthew Michael Edwards, Jason Freese, Kurt C
Fuqua. (Attachments: # 1 Appendix Third circuit court of appeals decision)(Taitz,
Orly) (Entered: 11/13/2009)
11/13/2009 92 OPPOSITION re: MOTION for Reconsideration re Order on Motion to Dismiss Case
89 MOTION for Reconsideration re Order on Motion to Dismiss Case 89 MOTION
for Reconsideration re Order on Motion to Dismiss Case 89 MOTION for
Reconsideration re Order on Motion to Dismiss Case 89 MOTION for
Reconsideration re Order on Motion to Dismiss Case 89 90 filed by Defendants
Barack Hussein Obama, Interested Party United States of America. (West, Roger)
(Entered: 11/13/2009)
11/16/2009 93 NOTICE OF MOTION AND MOTION for Reconsideration re Order on Motion to
Dismiss Case 89 filed by plaintiffs Clint Grimes, Julliett Ireland, D Andrew Johnson,
Matthew Michael Edwards, Jason Freese, Kurt C Fuqua. Motion set for hearing on
12/7/2009 at 10:00 AM before Judge David O. Carter. (Attachments: # 1 Declaration
Declaration of Orly Taitz re basis for the motion for reconsideration, # 2 Declaration
Declaration of Orly Taitz, # 3 Declaration Declaration of Orly Taitz re attempt for
meet and confer, # 4 Declaration Coroners report and declaration of Donald
Young)(Taitz, Orly) (Entered: 11/16/2009)
11/16/2009 94 NOTICE OF APPEAL to the 9th CCA filed by Plaintiffs Markham Robinson, Wiley
S Drake. Appeal of Order on Motion to Dismiss Case 89 . (Filing fee $455, receipt
number 09730000000006158038.) (Attachments: # 1 Supplement Representation
Statement and Service List, # 2 Supplement 9th Circuit Court of Appeals Docking
Statement, # 3 Exhibit District Court Order Being Appealed)(Kreep, Gary) (Entered:
11/16/2009)
11/17/2009 95 NOTIFICATION by Circuit Court of Appellate Docket Number 09−56827, 9th CCA
regarding Notice of Appeal to 9th Circuit Court of Appeals, 94 as to Plaintiff
Markham Robinson, Wiley S Drake. (dmap) (Entered: 11/17/2009)
following error(s) was found: Incorrect event selected RE: MOTION for
Reconsideration 89 93 . In response to this notice the court may order (1) an amended
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or correct document to be filed (2) the document stricken or (3) take other action as
the court deems appropriate. (twdb) (Entered: 11/18/2009)
11/18/2009 97 Amendment to MOTION for Reconsideration re Order on Motion to Dismiss Case 89
MOTION for Reconsideration re Order on Motion to Dismiss Case 89 MOTION for
Reconsideration re Order on Motion to Dismiss Case 89 93 filed by Plaintiffs Clint
Grimes, Julliett Ireland, D Andrew Johnson, Israel D Jones, Timothy Jones, David
Fullmer LaRoque, Gail Lightfoot, Lita M Lott, David Grant Mosby, Steven Kay
Neuenschwander, Frank Niceley, Jerry ONeil, Robert Lee Perry, Harry Riley, Jeffrey
Wayne Rosner, David Smithey, John Bruce Steidel, Douglas Earl Stoeppelwerth, Eric
Declaration Declaration of Orly Taitz re basis for reconsideration, # 2 Declaration
Declaration of Orly Taitz re meet and confer, # 3 Declaration Declaration re Larry
Sinclair, his affidavit and book, # 4 Affidavit Coroners death cert. Donald Young;
Affidavit of Larry Sinclair)(Taitz, Orly) (Entered: 11/18/2009)
11/19/2009 98 OPPOSITION TO AMENDED MOTION FOR RECONSIDERATION re: MOTION
for Reconsideration re Order on Motion to Dismiss Case 89 MOTION for
Reconsideration re Order on Motion to Dismiss Case 89 93 filed by Defendants
Barack Hussein Obama, Interested Party United States of America. (West, Roger)
(Entered: 11/19/2009)
11/30/2009 99 MINUTES (IN CHAMBERS): ORDER by Judge David O. Carter: taking under
advisement 90 Motion for Reconsideration. The Court finds matter appropriate for
decision without oral argument. Fed. R. Civ. P. 78; Local Rule 7−15. Accordingly, the
hearing set December 7, 2009 at 8:30 a.m. is removed from the calendar. Parties will
be served with the Courts ruling. (ade) (Entered: 11/30/2009)
12/03/2009 100 letter to judge Carter filed by Plaintiff Pamela Barnett (Attachments: # 1 Exhibit
Barack Obama background report)(Taitz, Orly) (Entered: 12/03/2009)
EXHIBIT “3 ” 7
http://www.scribd.com/doc/23612301/KEYES-BARNETT-v-OBAMA-100-letter-to-judge-Carter-filed-by-
Plaintiff-Pamela-Barnett-gov-uscourts-cacd-435591-100-0?autodown=pdf
Note, the above copy of Taitz 12/2/09 letter above is missing the PACER header assigned when a
document is filed on PACER. This can only mean that Defendant Orly Taitz, et al posted this letter
on the world wide web through SCRIBD prior to her filing it with the U.S. District Court, Central District
of California, Southern Division through PACER to ensure it spread like wildfire, which it did, across
the world wide web to ensure further damages to the Plaintiffs herein.
EXHIBIT “4 ”
LAW OFFICES OF
PHILIP J. BERG
PHILIP J. BERG
CATHERINE R. BARONE
BARBARA MAY
(610) 825-3134
FAX (610) 834-7659
NORMAN B. BERG, Paralegal [Deceased] E-Mail: philjberg@gmail.com
November 29, 2009
Honorable Eduardo C. Robreno

United States District Court
for the Eastern District of Pennsylvania
11614 U.S. Courthouse
601 Market Street
Philadelphia, PA 19106-1797
Sent via Fax to (267) 299-7428...................................................................................................45 Pages
Re: Liberi, et al. v. Orly Taitz, et al, Case No. 09-cv-01898 ECR
Leave to file Plaintiffs’ Emergency Motion to Transfer Venue of the within Case to the
United States District Court, Central District of California, Southern Division________
Dear Judge Robreno:
Pursuant to this Court’s Order of June 25, 2009 Plaintiffs’ are seeking Leave of this Court to
file the attached Emergency Motion to Transfer Venue of the within action to the United States District
Court, Central District of California, Southern Division located in South Orange County at 411 West
Fourth Street, Santa Ana, CA 92701-4516 with telephone number (714) 338-4750.
Plaintiffs’ bring to this Courts attention that all Defendants have prior hereto requested this
Court to transfer this case to California or Texas, although Plaintiffs’ are unaware of the Defendants
position to Plaintiffs’ request herein.
Thank you.
Respectfully,
Philip J. Berg
PJB:jb
Enclosures
Z:\Liberi Ltr to Judge Robreno Nov. 29, 2009 1

Honorable Eduardo C. Robreno November 29, 2009

United States District Court
for the Eastern District of Pennsylvania
Page Two of Two
cc: Orly Taitz, et al and

Defend our Freedoms Foundation, Inc.
Ph: (949) 683-5411
Fax: (949) 586-2082
By Email: dr_taitz@yahoo.com
Counsel in pro se
Defend our Freedoms Foundations, Inc. is unrepresented
Neil Sankey
The Sankey Firm, Inc. a/k/a The Sankey Firm
Phone: (805) 520-3151and (818) 366-0919
Cell Phone: (818) 212-7615
FAX: (805) 520-5804 and (818) 366-1491
Linda Sue Belcher

201 Paris
Home Phone: (830) 538-6395
Cell Phone: (830) 931-1781
Ed Hale
Caren Hale
Plains Radio
KPRN
Bar H Farms
1401 Bowie Street
Phone: (806) 447-0010 and (806) 447-0270
Email: plains.radio@yahoo.com and
Email: barhfarms@gmail.com and ed@barhfarms.net
Z:\Liberi Ltr to Judge Robreno Nov. 29, 2009 2

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA
LISA LIBERI, et al, :

Plaintiffs, :
: Assigned to Honorable Eduardo C. Robreno
:
vs. :
: Case No.: 09-cv-01898-ECR
:
:
ORLY TAITZ, et al, :
Defendants. :
ORDER
AND NOW, this _____ day of ___________________, 2009, upon Plaintiffs’
Emergency Motion to Transfer Venue; any responses thereto; and for good cause shown,
it is hereby
ORDERED and DECREED that Plaintiffs’ Emergency Motion to Transfer
Venue to the United States District Court, Central District of California, Southern
Division pursuant to 28 U.S.C. §1404(a) is hereby GRANTED.
IT IS FURTHER ORDERED that the Clerk of the Court shall transfer the
within Case to the United States District Court, Central District of California, Southern
Division located in South Orange County at 411 West Fourth Street, Santa Ana, CA
92701-4516 with telephone number (714) 338-4750.
IT IS SO ORDERED:
Date: November _____, 2009 ______________________________

Eduardo C. Robreno, Judge
U.S. District Court for the Eastern
District of Pennsylvania
Z:\Liberi Motion to Transfer Venue to South Orange County, CA 11 28 09 1

Law Offices of:

Lafayette Hill, PA 19444-2531 Attorney for: Plaintiffs
(610) 825-3134


Plaintiffs, :
vs. :
:
:
:
ORLY TAITZ, et al, : Assigned to Honorable Eduardo C. Robreno
Defendants. :
:
PLAINTIFFS’ EMERGENCY MOTION REQUESTING TRANSFER OF VENUE

PURSUANT TO 28 U.S.C. § 1404(a) FROM THE U.S. DISTRICT COURT,
EASTERN DISTRICT OF PENNSYLVANIA TO THE U.S. DISTRICT COURT,
CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION
NOW COMES the Plaintiffs’, Lisa Liberi [hereinafter “Liberi”], Philip J. Berg,
Esquire [hereinafter “Berg”], the Law Offices of Philip J. Berg, Evelyn Adams a/k/a
Momma E [hereinafter “Adams”], Lisa Ostella [hereinafter “Ostella”] and Go Excel
Global by and through their undersigned counsel and respectfully requests this Honorable
Court to grant their Emergency Motion to Transfer Venue of the within case from this
Court, the United States District Court for the Eastern District of Pennsylvania to the
United States District Court, Central District of California, Southern Division located in

South Orange County at 411 West Fourth Street, Santa Ana, CA 92701-4516 with
telephone number (714) 338-4750. In support hereof, Plaintiffs’ aver as follows:
• Although this is a Diversity Case and venue is proper in both

locations, the vast majority of the Defendants are located in Southern
California;
• Defendants Orly Taitz, Esquire a/k/a Orly Taitz a/k/a Dr. Orly Taitz
a/k/a Law Offices of Orly Taitz a/k/a Orly Taitz, Inc [hereinafter
“Taitz”], Defend our Freedoms Foundations, Inc. [hereinafter
“DOFF”], Neil Sankey [hereinafter “Sankey”], Sankey Investigations,
Inc. and the Sankey Firm, Inc. a/k/a The Sankey Firm own and
operate their businesses and own property within the United States
District Court, Central District of California, Southern Division;
• The Statute relied on by the Plaintiffs’ and the Statute the Plaintiffs’
are asking to be utilized and upheld is a California Statute, California
Civil Code 1798, et sequitur;
• There is a concern that Defendant Taitz and DOFF are attempting to

liquidate their assets and sign away their rights to the assets owned
and operated by Taitz, DOFF and Taitz’s husband, Yosef Taitz.
• California is a Community Property State, any judgment obtained

against Taitz is also collectable from any assets owned by her
husband, Yosef Taitz;
• Transfer of venue is appropriate pursuant to 28 U.S.C. § 1404(a) as a

result of California being able to enforce the Judgment, practical
considerations that would expedite and simplify the trial; California’s
local interest in deciding the local controversies at home, in particular
upholding California’s Civil Code 1798, et sequitur; and this is a
Diversity Case and the United States District Court, Central District
of California, Southern Division is very familiar with this State Law.
• All Defendants have asked this Court to transfer the within Case to
California and the Case must be tried together as there was a common
scheme in the actions of the Defendants which have severely harmed
and damaged the Plaintiffs.

WHEREFORE, Plaintiffs’ respectfully prays that this Honorable Court Grant
their Motion and Transfer Venue of the within Case to the United States District Court,
Central District of California, Southern Division located in South Orange County at 411
West Fourth Street, Santa Ana, CA 92701-4516 with telephone number (714) 338-4750.
Respectfully submitted,
Dated: November 29, 2009 _____________________________

Attorney for the Plaintiffs’
(610) 825-3134

Law Offices of:

Lafayette Hill, PA 19444-2531 Attorney for: Plaintiffs
(610) 825-3134


Plaintiffs, :
vs. :
:
:
:
ORLY TAITZ, et al, : Assigned to Honorable Eduardo C. Robreno
Defendants. :
:
PLAINTIFFS’ MEMORANDUM OF LAW IN SUPPORT OF

THEIR EMERGENCY MOTION REQUESTING TRANSFER OF VENUE
PURSUANT TO 28 U.S.C. § 1404(a) FROM THE U.S. DISTRICT COURT,
EASTERN DISTRICT OF PENNSYLVANIA TO THE U.S. DISTRICT COURT,
CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION
I. STATEMENT OF FACTS:
Defendant Taitz through DOFF and Defendant Sankey through Sankey
Investigations and the Sankey Firm have invaded the privacy of Liberi, Ostella, and
Adams by publicizing Liberi’s full Social Security number, date of birth, mother’s
maiden name, place of birth and other personal information of Liberi’s, including
information about Liberi’s medical conditions, child, husband, etc. and has targeted all
the work Liberi has performed for Berg in Pennsylvania. Taitz through DOFF has also

publicized Ostella’s name, address, maiden name, where her family resides, parents
names and where they reside, etc. and Taitz has also published Adams name, address,
husband’s information, etc. Taitz filed false law enforcement reports with the Federal
Bureau of Investigations (FBI); police departments; called for people where the
Plaintiffs’ reside; falsely accused Liberi and Ostella of “hacking” her paypal account and
website or forum; falsely accused Adams and Berg of diverting funds and making money
off of her company name; falsely accused Liberi of “murdering” her sister; falsely
accused Liberi’s husband of diverting funds from Berg; falsely accused Liberi of being
convicted of crimes including but not limited to identity theft, manipulation of police
reports, manipulation of credit reports, real estate crimes, etc., which has placed the
Plaintiffs’ in the false light before the publics eye; slandering the Plaintiffs’; harassed the
Plaintiffs; invaded the Plaintiffs’ seclusion; publicly disclosed private facts about the
Plaintiffs’; destroyed the Plaintiffs’ reputation; and interfered with the Plaintiffs’ business
associates, etc.
Shortly thereafter, the Hales had Taitz through DOFF and Sankey through Sankey
Investigations and the Sankey Firm on their radio show. Taitz continued her malicious
lies about Plaintiffs’ and Sankey continued his distribution of Liberi’s private
confidential information as well as Adams and Ostella’s. In fact, Sankey and Hale
announced on the radio show on May 28, 2009 that Liberi had recently taken out a loan,
which she had. The only way they would have known this is if they had illegally
accessed Liberi’s credit report or applied for and taken out credit in Liberi’s name.
Sankey, Taitz and Hale then altered and forged Ostella’s emails and published them on
the internet. Edgar Hale admitted in an email to Liberi that Taitz used him to assault

Liberi to get to Berg. The Hales also have viciously attacked, slandered, harassed and
threatened Adams. The Hales have admitted in writing that is on file with this Court,
Taitz, DOFF and the other Defendants used them to “assault” Liberi to take down Berg.
Belcher joined forces with Taitz in or about January 2009 in their attempts to
destroy Berg and Liberi. Belcher sent out mass emails with all kinds of false statements
about Liberi and Berg. Belcher filed false reports with the Social Security
Administration, manufactured emails and “chat logs” which she had filed with this Court;
and further published Liberi’s private confidential information.
As a result, Plaintiffs’ filed suit on May 4, 2009 of which all Defendants were
served. The Defendants’ Answers to the Plaintiffs’ Complaint were due May 26, 2009.
Taitz and DOFF failed to timely Answer Plaintiffs’ Complaint and therefore, default was
entered against them, and they waived their rights to raise any type of affirmative
defenses. Despite this, Taitz and DOFF untimely filed a one sentence denial as their
Answer and a “Motion to Dismiss” without any type of supporting law.
Since the time Plaintiffs’ filed suit, the Defendants actions and behaviors have
continued. Taitz, DOFF, Sankey, Sankey Investigations, Inc, and the Sankey Firm, Inc.
a/k/a the Sankey Firm are located in California. The majority of their Assets are located
in California. In addition, Taitz’s owns two [2] Dental Practices in the jurisdiction of the
United States District Court, Central District of California, Southern Division and she and
her husband own a Software Engineering company with their headquarters located in the
jurisdiction of the United States District Court, Central District of California, Southern
Division with offices over seas, in New Jersey and Santa Fe, New Mexico.

Furthermore, according to Affidavits on file in the United States District Court,
Southern District of Florida, Taitz was having a “love affair” with her law Clerk,
disbarred Attorney Charles Lincoln. Mr. Lincoln has filed his Affidavits claiming Yosef
Taitz has demanded that Orly Taitz sign all her rights to the Assets over to him (Yosef
Taitz), see EXHIBITS “A” and “B”. California is a community property state. Any
judgment obtained against the Defendants is also collectible against the Defendants
spouse and their assets, even if not in the other party’s name. Also in California, as well
as many other states today, it is illegal to transfer ownership of property or assets when
the party knows there is pending litigation against them. See the Uniform Fraudulent
Transfer Act, Cal Civ Code § 3439, et sequitur.
Because there has been a threat of Taitz signing away her rights to the family
assets, which are valued at approximately Twenty-Five Million [$25,000,000.00] Dollars
and based on the award of statutory penalties pursuant to California Civil Code 1798, et
sequitur, Plaintiff Liberi’s award pursuant to statute alone against Taitz and DOFF is in
excess of Eight Hundred and Seventy Million [$870,000,000.00] Dollars for just one
count. Thus, Plaintiffs’ are relying on the assets owned by Taitz, DOFF and her spouse,
Yosef Taitz, in order to collect against any judgment granted by the Court. For these
reasons, it may be imperative for Plaintiffs’ to move the United States District Court,
Central District of California, Southern Division for an Ex Parte Order freezing all of
Taitz, DOFF and Taitz’s portion of her spouses Assets.
Sankey, Sankey Investigations, Inc., and the Sankey Firm, Inc. a/k/a the Sankey
Firm are licensed in California, conduct business in and are located in Southern
California. In addition, Plaintiff Liberi has been speaking with and learned the California

licensing bureau of Private Investigators, the actions of Sankey through his corporations
are criminal in nature and therefore, Liberi was instructed to report Sankey’s illegal
actions to the County District Attorney where Sankey and his Corporations are located
and demand prosecution.
In addition, all the Defendants requested the within case be transferred to
California or Texas. Texas is an improper venue, however, venue is proper in both
Pennsylvania and the United States District Court, Central District of California,
Southern Division, located at 411 West Fourth Street, Santa Ana, CA 92701-4516 with
telephone number (714) 338-4750.
For the above aforementioned reasons, Plaintiffs’ respectfully request this
Honorable Court to Grant their Emergency Motion and Transfer the within action to the
United States District Court, Central District of California, Southern Division located
within South Orange County at 411 West Fourth Street, Santa Ana, CA 92701-4516 with
II. TRANSFER OF VENUE TO THE UNITED STATES DISTRICT

COURT, CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN
DIVISION IS PROPER IN THIS CASE:
In considering whether to grant venue transfer under 28 USCS § 1404(a), courts
engage in a two-part test: (1) whether action might have been brought in proposed
transferee forum; and (2) whether transfer promotes convenience and justice. Excelsior
Designs, Inc. v Sheres, 291 F Supp 2d 181 (E.D. NY 2003).
In a diversity action like this one, venue is proper "only in (1) a judicial district
where any Defendant resides, if all defendants reside in the same State, (2) a judicial

district in which a substantial part of the events or omissions giving rise to the claim
occurred, or a substantial part of property that is the subject of the action is situated, or
(3) a judicial district in which any Defendant is subject to personal jurisdiction at the time
the action is commenced, if there is no district in which the action may otherwise be
brought." 28 U.S.C. §1391(a).
It is in the public and private interests that the Federal Laws be upheld pertaining
to venue and transfer of cases within the Federal Court systems. 28 U.S.C. §1404(a) only
provides for the transfer of a case where both the original and the requested venue are
proper. Jumara v. State Farm Ins. Co., 55 F.3d 873, 878.
Section 1404(a) transfers are discretionary determinations made for the
convenience of the parties and presuppose that the Court has jurisdiction and that the case
has been brought in the correct forum. Lafferty v. Gito St. Riel, 495 F.3d 72, 77 (3d Cir.
Pa. 2007) citing Jumara v. State Farm Ins. Co., 55 F.3d 873, 878 (3d Cir. 1995).
However, the moving party is not required to show truly compelling
circumstances for change of venue, but rather that all relevant things considered, the case
would be better off transferred to another district. Dominy v. CSX Transp., Inc., 2006
U.S. Dist. LEXIS 9422 (E.D. Pa. Mar. 9, 2006), supra., citing In re United States, 273
F.3d 380, 388 (3d Cir. 2001).
In determining whether to transfer a case, the court must first determine whether
the action "might have been brought" in the proposed transferee district. Banket v. GC
Am., Inc., 2005 U.S. Dist. LEXIS 23550 at *10 (E.D. Pa. Oct. 11, 2005), citing Van
Dusen, 376 U.S. at 616, 84 S. Ct. at 809. Assuming that this requirement has been
satisfied, which it has been herein, the court must then assess a number of private and

public interest factors in addition to those enumerated in § 1404(a) (convenience of the
parties and witnesses and the interests of justice). Jumara v. State Farm Insurance
Company, 55 F.3d 873, 879 (3d Cir. 1995). Specifically, the private interests have
included: (1) the plaintiff's forum preference as manifested in the original choice; (2) the
defendant's choice of forum; (3) where the claim arose; (4) the convenience of the parties
as indicated by their relative physical and financial conditions; (5) the convenience of the
witnesses--but only to the extent that the witnesses may actually be unavailable for trial
in one of the fora; and (6) the location of books and records. In re Amendt, 169 Fed.
Appx. 93 at *8 (3d Cir. 2006), citing Jumara, at 879-80. The public interests have
included: (1) the enforceability of the judgment; (2) practical considerations that could
expedite or simplify trial; (3) the relative administrative difficulty in the two fora
resulting from court congestion; (4) the local interest in deciding local controversies at
home; (5) the public policies of the fora; and (6) in a diversity case, the familiarity of the
two courts with state law. Id. Rogal v. Skilstaf, Inc., 446 F. Supp. 2d 334, 336 (E.D. Pa.
2006).
It would be far easier for the United States District Court, Central District of
California; Southern Division to enforce any judgment’s obtained, as the bulk of the
Defendants assets are located in that Court’s jurisdiction. This particular Court that the
Plaintiffs’ are seeking the case to be transferred to is readily familiar with their own State
statutes, California Civil Code 1798, et sequitur, which the Plaintiffs’ rely upon. It is in
the public interest to see that California upholds its statutes when wrongs have been
committed; and the United States District Court, Central District of California, Southern
Division has the ability to expedite and/or simplify the trial.

III. IT IS IMPERATIVE TO KEEP THIS CASE TOGETHER IN A

SINGLE LAWSUIT AS THE DEFENDANTS HAVE ALL SHARED
A COMMON SCHEME AND THEREFORE, THE ENTIRE
LAWSUIT SHOULD BE TRANSFERRED TO THE U.S. DISTRICT
COURT, CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN
DIVISION PURSUANT TO 28 U.S.C. SECTION 1404(a):
Determination of whether the claims or parties should be severed is more
appropriately made when the Court can determine which issues will go to trial, Miller v.
Hygrade Food Prods. Corp., 202 F.R.D. 142, 145 (E.D. Pa. 2001). To address this issue
now is simply premature because this action has not proceeded beyond the pleading
stage, and the Court has yet to sort out the intricacies of the relationships among the
Defendants’, United States v. Private Sanitation Indus. Ass’n of Nassau/Suffolk, Inc., 793
F. Supp. 1114, 1154 (E.D. N.Y. 1992). Indeed, although Plaintiffs strongly disagree, this
case could possibly develop so that Plaintiffs cannot prove that Defendants acted in a
common way; however, because the record is not fully developed, it is premature to
foreclose Plaintiffs from pursuing that opportunity. Foreman Indus., Inc. v. Gen. Motors
Corp., 34 B.R. 712, 715 (S.D. Ohio 1983).
The purpose of Rule 20(a) is to "promote trial convenience and expedite the final
determination of disputes, thereby preventing multiple law suits." 7 Charles Alan Wright,
et al., Federal Practice and Procedure § 1652 at 395 (3d ed. 2001); see also Formosa

Plastics Corp., U.S.A. v. ACE Am. Ins. Co., 2009 U.S. Dist. LEXIS 71712 (D.N.J. Aug.
14, 2009) citing Mosley v. General Motors Corp., 497 F.2d 1330, 1332 (8th Cir. 1974)
(all 'logically related' events entitling a person to institute a legal action against another
generally are regarded as comprising a transaction or occurrence).
Courts generally apply a case-by-case approach in determining whether a
particular factual situation meets the same transaction or occurrence test. See 7 Charles
Alan Wright, et al., Federal Practice and Procedure § 1653 at 409 (3d ed. 2001); Blood v.
Fed. Bureau of Prisons, 2009 U.S. Dist. LEXIS 21529 (M.D. Pa. Mar. 17, 2009) citing
Mosley, 497 F.2d at 1333. The test mirrors the one applied under Federal Rule of Civil
Procedure 13(a), under which "'Transaction' is a word of flexible meaning. It may
comprehend a series of many occurrences, depending not so much upon the
immediateness of their connection as upon their logical relationship.'" Mosley, 497 F.2d
at 1333 (emphasis added) (quoting Moore v. New York Cotton Exchange, 270 U.S. 593,
610, 46 S. Ct. 367, 371, 70 L. Ed. 750 (1926)); see also In re University Med. Ctr., 973
F.2d 1065, 1086 (3d Cir. 1992) (recognizing logical relationship test under Rule 13(a)).
Identifying each event is not demanded. See Mosley, 497 F.2d at 1333; King v. Pepsi
Cola Metro. Bottling Co., 86 F.R.D. 4, at *6 (E.D. Pa. 1979).
Here, the Defendants’ all joined forces with Taitz to destroy Berg and destroy his
paralegal, Liberi and get rid of her and any other parties associated with Berg and Liberi.
All of the Defendants’ went after the Plaintiffs, due to their association with Berg and his
lawsuits and caused the Plaintiffs’ to suffer injuries.
Furthermore, none of the Defendants have raised the issue, cited or established
any legally cognizable prejudice as a result of hearing together all of the Plaintiffs’ claims

against all of them responsibly for Plaintiffs’ injuries; however, there would be great
prejudice to the Plaintiffs. First, severance would be a tactical boon to all Defendants. If
the case is separated and tried in different locations, the Defendants’ would then point to
the other Defendants’ not named in those particular actions if these claims were not tried
together, leaving the jury wondering why a claim had not been brought against the other
Defendants. e.g., The case against Taitz and Sankey is separated and moved to California
while the case against the Hale Defendants is moved to Texas. First problem with this is
all the Plaintiffs’ would have to travel to three (3) different locations and Hale would
blame Taitz for the actions, which would cause the jury to wonder why the Plaintiff failed
to name Taitz. The permutations of this prejudice are boundless. The jury might give a
compromise verdict, in which case Plaintiffs would not get the full value of their
damages. Next, there are many parties who are willing to be witnesses against the
Defendants named herein. Severance of these claims would cause each of the witnesses
to have to be brought to Court three (3) or more times in different States to testify to a
pattern of facts and opinions, where experts are concerned, which are common to all
Defendants. Not to mention the fact, Plaintiffs’ witnesses would have to be deposed
three (3) times if the case is severed. This would triple all costs associated with
Plaintiffs’ witnesses.
Severance would cause inconvenience and prejudice to the parties, especially the
Plaintiffs’ and their witnesses. In addition, it would undermine Plaintiffs’ ability to
contest the Defense case, in light of the fact that this triplication would burden all the
witnesses and jurors as well as waste judicial resources.

These are important reasons to try the case as a single, coherent whole, and
Plaintiffs’ urge the Court not to undermine that. Severance is an extraordinary procedure
and cannot be justified unless it will substantially further the ends of judicial economy,
prevention of delay and prejudice, and otherwise serve the ends of justice. This standard
has not been met in this case and therefore, the case should not be severed.
IV. CONCLUSION:
For the reasons stated herein, Plaintiffs’ respectfully request this Honorable Court
to grant their Emergency Motion and Transfer the entire case to the United States District
Court, Central District of California, Southern Division located in South Orange County
at 411 West Fourth Street, Santa Ana, CA 92701-4516 with telephone number (714) 338-
4750.
. Respectfully submitted,
Dated: November 29, 2009 _____________________________

Attorney for the Plaintiffs’
(610) 825-3134

EXHIBIT “A”
Case 9:09-cv-81255-WPD
Case: 09-3403 Document:
Document00319937507
20 Entered on
Page:
FLSD20Docket
Date11/13/2009
Filed: 12/08/2009
Page 19 of 37
Document00319937507
20 Entered on
Page:
FLSD21Docket
Date11/13/2009
Filed: 12/08/2009
Page 20 of 37
Document00319937507
20 Entered on
Page:
FLSD22Docket
Date11/13/2009
Filed: 12/08/2009
Page 21 of 37
Document00319937507
20 Entered on
Page:
FLSD23Docket
Date11/13/2009
Filed: 12/08/2009
Page 22 of 37
Document00319937507
20 Entered on
Page:
FLSD24Docket
Date11/13/2009
Filed: 12/08/2009
Page 23 of 37
EXHIBIT “B”
Document
00319937507
22 Entered on
Page:
FLSD26Docket
Date11/17/2009
Filed: 12/08/2009
Page 6 of 30

SOUTHERN DISTRICT OF FLORIDA---PALM BEACH
MARSHA G. RIVERNIDER, §
ROBERT H. RIVERNIDER, §
CHARLES EDWARD LINCOLN, III, §
Plaintiffs, §
§
v. § Case No. 09-91255-CIV
§ HON. W.P. DIMITROULEAS
U.S. BANK NATIONAL ASSOCIATION, §
AS TRUSTEE FOR THE C-BASS §
MORTGAGE LOAN ASSET-BACKED §
CERTIFICATES, SERIES 2006-CBS, §
And all JOHN & JANE DOES 1-50 § AFFIDAVIT REGARDING
Defendants. § ALLEGATIONS OF FRAUD
§
§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§
AFFIDAVIT AND DECLARATION OF CHARLES EDWARD LINCOLN, III
1. My name is Charles Edward Lincoln, III. I am over the age of 18, of sound mind,
and have never been convicted of any crime of moral turpitude within the meaning of
Beltran-Tirado v. INS, 213 F.3d 1179, 1183 (9th Cir. 2000) and Quintero-Salazar v.
Keisler, 506 F.3d 688 (9th Cir. 2007); I write this affidavit from personal knowledge.
2. I have a J.D. from the University of Chicago in addition to a Ph.D. from Harvard
University and am a former judicial law clerk to the Honorable Kenneth L. Ryskamp in
this United States District Court for the Southern District of Florida, having applied for
my clerkship in March 1991 and completed my term in September 1993.
3. I was later disbarred due to a December 1999 indictment, which I can only call
politically motivated and unjust, although I take full responsibility for my own errors. I
also apologize to this United States District Court, and in particular to the Honorable
Kenneth L. Ryskamp, for the dishonor my misfortunes may have brought to this court, in
the past and at the present time, by my failures and indiscretions, especially in light of the
honor which Judge Ryskamp bestowed upon me by hiring me as his law clerk.
4. Dr. OrIy Taitz was aware of all details of my background, and in May 2009, hired
me to work with her as a consultant and law clerk on a series of cases relating to the
Affidavit of Charles Edward Lincoln, III, in Response to Order to Show Cause, 1

Document 21, Dated November 13,2009, regarding promised legal representation
in this Case by Dr. Orly Taitz, Esquire
Document
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Article II Constitutional eligibility of the current President of the United States, Barack
H. Obama. I continued to work with her through November 4,2009.
5. I prepared all the documents, which Dr. Taitz signed in this case, as I have been
preparing almost all (approximately 95-98%) the documents she has signed in all of her
recent cases pending in Federal court in any and every state where she has appeared. I
never caused any papers to be filed, in this or any other case, which she had not approved
and signed or authorized to be electronically signed or submitted.
6. I was responsible for delivering all papers in this case to Robert H. Rivernider for
filing. I certainly never gave him any documents, which I knew or suspected to be
fraudulent in any way, shape or form.
7. I never knowingly submitted any false documents to this Court nor did I submit
any documents I had any imaginable reason to believe were false. I submitted every
document signed by Orly Taitz or any other person only in the belief that these were
legitimate documents.
8. Our agreement was a mixture of pay plus exchange of services. Since I am no
longer a licensed attorney I have been involved in real estate management and mortgage
finance. Dr. Orly Taitz agreed to represent me as legal counsel
9. What has happened here is that, much to our mutual discomfort I am sure, Orly
Taitz and I had an intense but adulterous love affair, which continued until November 4,
2009. I can say nothing in our defense except that I fell in love with Dr. Taitz and she
repeated on dozens of occasions that she loved me, but could not leave her husband
because she did not want to lose "her children and her life."
10. I am not proud of these facts, but put together they constitute the simple if
unremarkably tawdry background against which Dr. Taitz' behavior and accusations
against me/all the Plaintiffs in this case must be judged and evaluated.
Affidavit ofCharles Edward Lincoln, III, in Response to Order to Show Cause, 2

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11. Dr. Taitz terminated our relationship in the aftermath of the October 12, 2009,
disclosures made by one Lucas Daniel Smith on the internet which in rather grotesquely
vulgar and sensationalistic manner revealed my love affair with Dr. Taitz to the world,
and not coincidentally, to arly's husband Yosef Taitz, whom arly has consistently
described to me as viciously controlling, verbally, and emotionally abusive, he is the kind

of husband who will not allow his wife to speak freely at the dinner table or in front of
her children or guests, and who becomes violently angry if his wife is not at home by
sunset on the Sabbath for family/home prayer.
12. I provided copies of my affidavit to both Dr. Taitz and her attorney Dr. Jonathan
H. Levy of Hilton Head, South Carolina and Washington.
13. Dr. Levy warned me that I could expect "strong and vengeful" action from Dr.
Taitz' when I spoke to him last on Thursday, November 12, 2009, although he did not
condone such acts, and specifically qualified that he had absolutely nothing to do with
Dr. Taitz' prior letter to this Court Noted "Received" at Docket Entry 1 in this case.
14. I have no other explanation for what Dr. Taitz is doing in this case, but I will give
the following opinions:
15. Dr. Taitz' letters to the court and her Sunday November 15, 2009, communication
to me bye-mail (a true and correct copy of which is attached as Exhibit A), are the acts of
an extremely unhappy woman who got caught having an adulterous love affair by her
husband and the entire world at the moment of maximum political and public exposure in
her entire life.
16. Dr. Kathy Garcia-Lawson's separate affidavit submitted alongside this one
addresses the concerns raised in Dr. Taitz' E-mail.
17. Neither my affair with Dr. arly Taitz nor anything else which I have done
constitutes a fraud on this court, nor any other court, nor any reason for the Court to
dismiss my Complaint jointly filed with Robert H. and Marsha G. Rivernider.

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18. It is terribly embarrassing and a professional disgrace when personal lives intrude
themselves upon Court Judicial Proceedings.
19. If this Court feels that the events have in any way colored this Court's perception
of the parties or ability to judge the facts of the case between the Plaintiffs and the
Defendants impartially, or if the Court feels that it will be prejudiced against the
Plaintiffs because of my and Dr. Taitz' love affair, which had NOTHING whatsoever to
do with the validity of a mortgage or assignments between US BANK, Robert H. and
Marsha G. Rivernider, and Charles Lincoln, this Court should consider recusal rather
than dismissing the case.
20. As undignified, unprofessional, and unseemly as this Plaintiffs exchange with
Dr. Taitz may seem, it is merely reflective (at the absolute worst) of this Plaintiffs and
Dr. Taitz' emotional immaturity in the handling of their personal lives, and do not reflect
on ANY of the other matters raised in Plaintiffs' Response to the Court's Second Order
to Show Cause and the Defendant's Motion to Dismiss in any way, shape or form.
Further affiant sayeth naught.
Signed, declared under penalty of perj , and executed in Palm Beach Gardens,
Florida, on this Monday the 16th day of No ember,
By:~o----::,.JF---""--=~,.qq...~,-+-:£'-4-~~~---"oC=---
arIes Ed ara co n, III
c/o Peyton Yates Freiman
603 Elmwood Place, Suite #6
Austin, Texas 78705
Telephone: 512-968-2500
E-mail: charles.lincoln@rocketmail.com
Alternative Address:
c/o Kathy Ann Garcia-Lawson
2620 Nature's Way
Palm Beach Gardens, Florida 33410
Telephone: 512-968-2500/512-923-1889
Facsimile: 561-691-1423

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Page 10 of 30
NOTARY'S JURAT
Charles Edward Lincoln, III, appeared in person before me on this Monday the
16th day of November, 2009, in Palm Beach Gardens, Florida, and having been by me
duly sworn upon his oath he did verify the truth of all the statements of fact set forth
above, and did declare and acknowledge the statements of opinion made above and the
sincerity of their submission to the Court.
I am an officer authorized to administer oaths and take testimony under the laws
of the State of Florida, my principle place of bus' eing in Palm Beac County,
Florida.
ALEJANDRO VERA
Notary Public, State 01 Florida
Commisslon# 00812909
My comm. expires Aug. 7, 2012
Printed Name ofNotary:_---'-/)-'-'~'__=BJ,"____'_4~AJ_j_a

o_ __={)._(£_-f)p_'__ _
Business AddresscQ)'"dS ~ RL-IJ.u fBC Ft,. S34/(J
My Commission Expires: l):..-()=->::C-"------_?-~Gd:>'-O=....c...I;;=+-----

)

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Exhibit A:
Sunday, November 15,2009
E-Mail from
Dr. Orly Taitz, Esquire

Drucken Case: 09-3403 Document:
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30 1 of 1
Von: Dr. Orly Taitz ESQ (dr_taitz@yahoo.com)

An: Charles Lincoln
Datum: Sonntag, den 15. November 2009,9:45:01 Uhr
Betreff: Charles, you need to see a doctor and your case needs to be stayed pending tr-nt
Charles,
I received your two phone messages. In the first message your speech was extremely blurry, unclear, second message
sounded like you were a different person.
I believe that you need urgent evaluation and treatment by a psychiatrist. All of your behavior as of late, all of the e-
mails to me, my husband and my attorney suggest the same. You are hurting me, my husband, my children, your wife,
your son, Rverniders and yourself
I am sending a declaration to judge Dimitrious in FL, letting him know, that I believe you are in need of urgent
psychiatric evaluation and possibly treatment, and I believe that case needs to be stayed pending your evaluation and
treatment.
Dr. Orly Taitz ESQ
29839 Santa Margarita Pkwy ste 100
Rancho Santa Margarita Ca 92688
ph. 949-683-5411
fax 949-766-7603
orlytaitzesq.com
drtaitz.com
taitzofficesuites.com
http://de.mg41.mai1.yahoo.com/dc/launch?.gx=1 &.rand=17q8i4v26j71 i 11/15/2009

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AFFIDAVIT NUMBER 2:
Dr. Kathy Ann Garcia-Lawson, Ph.D.
Marsha G. Rivernider, Robert H. Rivernider, Charles Edward Lincoln, III v.

U.S. Bank, N A., Combined Response to Second Order to Show Cause Filed 11-02-09 and Motion to 6
Dismissedfiled 9-24-09, with reservation ofPlaintiffs' Rights to File Motion to Convert 12(b)(6) to
Rule 56MSJ
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SOUTHERN DISTRICT OF FLORIDA---PALM BEACH
MARSHA G. RIVERNIDER, §
ROBERT H. RIVERNIDER, §
CHARLES EDWARD LINCOLN, III, §
Plaintiffs, §
§
v. § Case No. 09-91255-CIV
§ HON. W.P. DIMITROULEAS
U.S. BANK NATIONAL ASSOCIATION, §
AS TRUSTEE FOR THE C-BASS §
MORTGAGE LOAN ASSET-BACKED §
CERTIFICATES, SERIES 2006-CBS, §
And all JOHN & JANE DOES 1-50 § Affidavit of Psychologist
Defendants. § Regarding Charles E. Lincoln
§
§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§§
AFFIDAVIT OF DR. KATHY GARCIA-LAWSON
1. My name is Kathy Ann Garcia-Lawson. I am over the age of 18 and
otherwise competent to make this affidavit.
2. I received a Ph.D. from Nova Southeastern University in Clinical Psychology
where I also completed a one year postdoctoral specialty in psychoanalytic psychology
and technique followed by a two year postdoctoral residency at 45 th Street Mental Health
Center in West Palm Beach, Florida (now called "Oakwood").
3. A true and correct (if slightly out of date) copy of my vita is attached as
Exhibit B to this Affidavit.
4. Since 1995 I have engaged in the private practice of clinical psychology with
my current office location at 2401 PGA Boulevard, Suite 128, Palm Beach Gardens,
Florida 33410.
5. I have known Charles Edward Lincoln, III, since Saturday, May 11,2008,
when he called me to discuss my concerns regarding rampant abuses in the Family Law
Courts and in Family Law/Divorce/Child Custody systems generally.
6. I consider him to be a good-hearted, honorable, and trustworthy man, as well
as a competent and well-read student of the law and constitutional history and theory.
Affidavit ofDr. Kathy Ann Garcia-Lawson, Ph.D. in Support ofCharles Lincoln's 1

Response to Order to Show Cause, Document 21, Dated November 13,2009,
regarding promised legal representation in this Case by Dr. Orly Taitz, Esquire
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7. I am perfectly aware of his background and status as a disbarred attorney, but
in some ways, I think his background makes him more useful and trustworthy than many
licensed attorneys who cannot criticize the system because they depend upon it and are
part of it.
8. One of my past attorneys, Montgomery Blair Sibley, was suspended in both
the District of Columbia and Florida, as well as threatened with disbarment, because of
his criticism of the judiciary and the unconstitutional operation of the Family Courts
which routinely deny due process of law in an arbitrary and capricious manner, to the
great injury of spouses and children all over the United States.
9. In January-May of2009, I became interested in the work of Dr. Orly Taitz
against the constitutional eligibility of President Barack H. Obama. I made contact with
Dr. Taitz who indicated that she lacked competent assistance in her litigation, whose end
goal of removing the President I supported on moral, philosophical, and political
grounds, and I suggested to her that she contact Charles Lincoln and see whether they
could work together, which they quickly began to do.
10. Sometime in early-mid July 2009, Charles Lincoln confided to me in a late-
night telephone call that he was involved in a very intense love affair with Orly Taitz as
well as working for her constantly to the exclusion of everything else in his life. Charles
said that he had been very lonesome since he separated from his wife Elena in late July
2002, and that Orly had made him "feel alive" and he believed that they could work
together and accomplish things he could never do on his own.
11. Although he was calling me and updating me as a friend, that night Charles
Lincoln at that time said that he was very disturbed by the events, which had transpired
with Orly, a married woman, and requested that I advise him as a psychologist. I spoke
to Charles about Orly about 3-4 times a week after that, sometimes more.
Affidavit ofDr. Kathy Ann Garcia-Lawson, Ph.D. in Support of Charles Lincoln's 2

Response to Order to Show Cause, Document 21, Dated November 13, 2009,
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12. Charles has also come to visit me in Palm Beach Gardens on three separate
occasions since this started, and Orly is always on his mind, as are his concerns with their
relationship.
13. I should make it clear that Charles was never a formal patient of mine, never
paid me for services, and I consider our relationship still to be that of friends rather than
doctor-patient. I counseled him professionally as ifhe were a patient of mine, but more
informally than formally, as I would do to any friend in need.
14. I did my best to advise Charles to terminate his relationship with Orly, after
all I am an advocate for Christian marriage and monogamy.
15. I had the opportunity to travel to Orange County, California, on the weekend
of October 2-6 in Orange County, California, and did spend some time meeting with Orly
and Charles as they worked together on the Obama litigation.
16. Charles had asked for my professional observations concerning the
authenticity of Orly' s feelings towards him.
17. I, like others close to Charles, were gravely concerned about the sincerity of
Orly's involvement with Charles or whether she was taking advantage of a lonely man in
exchange, quid pro quo, of his drafting of her pleadings.
18. I have no personal knowledge of any of the papers passing between Charles
and Orly in this case or any other case, but I cannot imagine any reason why Charles
would have needed to falsify documents from Orly because they worked together, very
intensely, for five months and I know he wrote more documents which she signed than
she ever wrote on her own, by a very dramatic factor.
19. Charles copied me on almost everything he wrote for Orly, including his legal
research for her, and his output was nothing less than prodigious. I was concerned for his
well-being and his general health because Orly's demands on him sometimes seemed
excessive.

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20. I have read arly's Sunday Novmeber 15,2009, e-mail attached as Exhibit A
to this affidavit and in my professional opinion, this tum of events seems to be rooted in
vindictiveness and hostility, and I find it suspect thatfher conduct and actions have so
radically changed in the immediate aftermath of the October 29,2009, dismissal of the
Obama case before Judge Carter's case.
21. I have wondered whether arly's involvment with Charles was strictly a result
of her interest in using him on the Obama case, and I think that arly may have been
"leading Charles" on and that she never really intended to follow through on her
commitments to the mortgage litigation.
22. In my time of knowing Charles I have found him always to be forthright and
honest in a genuine and caring individual.
23. I would be happy to testify on his behalf or elaborate upon this affidavit in
response to any questions which the Court might have in the future.
24. I find it quite unfortunate that this inappropriate and personal relationship has
found its way to contaminate a significant case such as the present one, but I agree that
Charles had the need to be forthcoming and truthful regarding all the circumstances
bearing on his defense against arly's charges.
25. It is my professional opinion that Charles Edward Lincoln suffers from no
psychological disorders, excluding possible occasional mild depression brought on by
loneliness, and I see no cause to recommend him for psychiatric evaluation of any kind.
26. I have also met Bob Rivemider and nothing in my observation of either
Lincoln or Rivemider suggests to me that they were likely to have been attempting to
falsify Orly's involvement in this case in any way. I am aware that Orly did appear or
attempt to appear in several other cases for Charles E. Lincoln involving mortgages and
real-estate around the United States.
Further affiant sayeth naught.

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Signed, declared under penalty of perjury, and executed in Palm Beach Gardens,
Florida, on this Monday the 16th day of November, 2009.
"
() -r-.';,-'..:::o.._'1,-"U=,,--v / ,} /1P .
BY:--:;-;:----,-;-=~,__-'-t::::-"-.'----;-' --:;:(,:;:-t:.(.&_'.:....t-.:..../'--
l..-;:::', . . - __
Kathy Ann Gar . -Lawson, Ph.D.
2401 PGA Boulevard, Suite 128
Palm Beach Gardens, Florida 33410
Office Telephone: 561-694-2772
Facsimile: 561-691-1423
NOTARY'S JURAT
Kathy Ann Garcia-Lawson appeared in person before me on this Monday the 16th
day of November, 2009, in Palm Beach Gardens, Florida, and having been by me duly
sworn upon her oath she did verify the truth of all the statements of fact set forth above,
and did declare and acknowledge the statements of her professional opinion made above
and the sincerity of their submission to the Court.
I am an officer authorized to administer oaths and take testimony under the laws
of the State of Florida, my principle place of business being in Palm Beach /ounty,
Florida.
ALEJANDRO VERA
Notary Public, State of Florida
Commission, 00812909
My oomm. ellplres Aug. 7, 2012
Printed Name of Notary: I/If3,Y19/J JOd tZJ2A
Business Address: d50S fG-4. Wi) 'Pes:;. Pc- 33£//0
My Commission Expires:_--,-.t1.....;O<:::........:=G-,,-'-<l-7+-'.....c9--..D..L...:-42=~ _

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Page 19 of 30
Exhibit A:
Sunday, November 15, 2009
E-Mail from
Dr. Orly Taitz, Esquire

Drucken
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Page 20 of 30 1 of 1
Page
Von: Dr. Orly Taitz ESQ (dr_taitz@yahoo.com)

An: Charles Lincoln
Datum: Sonntag, den 15. November 2009,9:45:01 Uhr
Betreff: Charles, you need to see a doctor and your case needs to be stayed pending tr-nt
Charles,
I received your two phone messages. In the first message your speech was extremely blurry, unclear, second message
sounded like you were a different person.
I believe that you need urgent evaluation and treatment by a psychiatrist. All of your behavior as of late, all of the e-
mails to me, my husband and my attorney suggest the same. You are hurting me, my husband, my children, your wife,
your son, Rverniders and yourself
I am sending a declaration to judge Dimitrious in FL, letting him know, that I believe you are in need of urgent
psychiatric evaluation and possibly treatment, and I believe that case needs to be stayed pending your evaluation and
treatment.
Dr. Orly Taitz ESQ
29839 Santa Margarita Pkwy ste 100
Rancho Santa Margarita Ca 92688
ph. 949-683-5411
fax 949-766-7603
orlytaitzesq.com
drtaitz.com
taitzofficesuites.com
http://de.mg41.mail.yahoo.com/dc/launch?.gx=1&.rand=17q8i4v26j7li 11/15/2009
Document00319937507
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Page 21 of 30
Exhibit B:
Professional Vita
Kathy Ann Garcia-Lawson, Ph.D.,
In Psychology with specialty
In Psychoanalytic Technique

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VITA
Kathy Ann Garcia-Lawson, Ph.D.
A. Personal Data
Address: 2620 Natures Way, Palm Beach Gardens, Florida 33410

Telephone: 561.624.8725
DOB: February 4, 1958
B. Educational Background
1. Montclair State College, Upper Montclair, NJ 07043

Major: Psychology B.A. 1982
Minor: Counseling, Human Services and Guidance
2. Nova Southeastern University, Ft. Lauderdale, FL 33314

Major: Counseling Psychology M.S. 1990
Major: School Guidance and Counseling M.S. 1990
Nova Southeastern University, Ft. Lauderdale, FL 33314
3. Ph.D. - Clinical Psychology
Ph.D. 1995
Advanced Training: Psychoanalytic Psychotherapy Program
4. Nova Southeastern University, Ft. Lauderdale, FL 33314 1996
Family and County Court Mediation Training 10-12-04

5. Broward County Bar Association, Ft. Lauderdale, FL 33314
C. Professional Membership
American Psychological Association 1992-Present
D. Current Position
Private Practice in Clinical Psychology

2401 PGA Boulevard, Ste.128, Palm Beach Gardens, FL 33410
1995- Present
E. Clinical Experience
1. Essex Rehabilitation Center, Verona, NJ Group

Therapy with dually diagnosed patients. 1981-1982
2. Glenbeigh Hospital of the Palm Beaches, West Palm Beach, FL 1988-1989

Group psychotherapy with adolescents with eating disorders and
substance abuse problems.
1
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Clinical Experience (continued).
3. Humana Hospital West Palm Beach, FL 1989-1990
Group psychotherapy with adolescents in a long-term residential

psychiatric program. Group and individual psychotherapy with
geriatric patients in short-term facility. Provided crisis intervention to
adults.
4. Nova University Comm. Mental Health Clinic, Coral Springs, FL 1992-1993
Dual Diagnosis Program: Provided individual short-term and long-

term psychotherapy. Intake interviewing, treatment planning,
testing, and evaluation of patients.
5. 45 th Street Mental Health Center, West Palm Beach, FL 1993-1996
Provided individual and group psychotherapy to adolescents and

adults in both out-patient and in-patient facilities. Treatment
planning, testing, and evaluation was conducted. Provided
individual and family therapy to school-age children through
contract with Palm Beach Board of Education.
F. Teaching Experience
1. Palm Beach School Board, West Palm Beach, FL (ESE) 1988-1990

2. Embry Riddle Aeronautical University (Psychology Classes) 1992
3. Palm Beach Community College (Psychology Classes) Barry 1990-1994
4. University (Psychology Classes) 1994
G. Administration
1. Developed the psycho-educational program at Glenbeigh Hospital.

2. Editor for Books and Article Reviews for Southeast Florida Association
for Psychoanalytic Psychotherapy (SEFAPP) Newsletter.
3. Grant proposal for prevention ofjuvenile delinquency.
4. Consultant to Florida's Commission on Marriage and Family Initiatives-Cited
as a consultant in the Commission's Report, Is No-Fault at Fault?, released
March, 2008.
H. Dissertation
The Effects ofthe Sudden Death ofa Psychotherapist on Patients
I. Publications
Garcia-Lawson, Kathy (1997). Thoughts on Termination - Practical Considerations:

Journal of Psychoanalytic Psvchology, 14(2),239-257.
Garcia-Lawson, Kathy (2000), Sudden Death ofthe Therapist: Effects on the Patient:
Journal of Contemporary Psychotherapy, 30(1) 85-103.
Non-published: Family Law
Garcia-Lawson, Kathy, Baker, Josiah, and Posthumus, Stanley, (2006) Protecting

Florida Families- Ending the Divorce Epidemic: A Social Disease. Presented to the
Childrens Rights Council, November, 2006 in Washington DC and at the State of
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Florida South Legislative Meeting.
J. Areas of Research/Interest: Activist in Safeguarding Marriage and Family.
K References
Available Upon Request.
2
Law Offices of:

(610) 825-3134 Attorney for Plaintiffs


Plaintiffs, :
vs. :
:
ORLY TAITZ, et al, :
Defendants.
:
:
:
:
CERTIFICATE OF SERVICE
I, Philip J. Berg, Esquire, hereby certify that a copy of Plaintiffs’ Emergency
Motion to Transfer Venue to the U.S. District Court, Central District of California,
Southern Division was served this 29th day of November 2009 electronically upon the
following:
Orly Taitz
Defend our Freedoms Foundation, Inc. (unrepresented)
Neil Sankey
The Sankey Firm, Inc. a/k/a The Sankey Firm (unrepresented)

Linda Sue Belcher

201 Paris
Ed Hale
Caren Hale
Plains Radio
KPRN
Bar H Farms
1401 Bowie Street
Email: plains.radio@yahoo.com; barhfarms@gmail.com;
ed@barhfarms.net; and ed@plainsradio.com
________________________

LIBERI V TAITZ (APPEAL) - Appellants' Request For Judicial Notice - 23892610-Liberi-Et-Al-v-Taitz-Et-Al-Req-for-Judicial-Notice-3rd-Circut

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Case: 09-3403 Document: 00319937503 Page: 1 Date Filed: 12/08/2009

U.S. District Court,

UNITED STATES COURT OF APPEALS

LISA LIBERI, et al,

ORLY TAITZ, et al,

APPELLANTS’ EMERGENCY REQUEST FOR JUDICIAL NOTICE OF APPELLEE

Counsel: PHILIP J. BERG, ESQUIRE

Attorney for the Appellants’

TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

LEXIS 514002 (D. Pa 2008) at *2.

2004 U.S. Dist. LEXIS 132355 (D. Pa. 2004).

hereto as EXHIBIT “1”; Barnett, et al v. Obama, et al Docket in Case No. 09-cv-00082-DOC

Attorney for the Appellants’

U.S. District Court,

UNITED STATES COURT OF APPEALS

LISA LIBERI, et al,

ORLY TAITZ, et al,

Linda Sue Belcher

Dr. Orly Taitz ESQ

29839 Santa Margarita PKWY, ste 100

Rancho Santa Margarita CA 92688

Request for investigation of misconduct in legal proceedings, submission of perjured

Attn. Honorable Judge David O Carter,

/s/Dr. Orly Taitz ESQ

/s/ Dr. Orly Taitz, ESQ

Declaration of Orly Taitz

Under penalty of perjury I declare the following:

1. I am over 18 years old, I am a resident of Orange County, California, I am of sound mind

/s/ Orly Taitz

Peter Submitted on 2009/12/02 at 3:09pm Can someone

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NOBODY REMEMBERS OBAMA AT COLUMBIA

Looking for evidence of Obama's past, Fox News contacted 400

I don't have a classmate who ever knew Barack Obama at

It's very strange." Obama's photograph does not appear in the

From: West Legal Directory

Comenius University School of Law, Bratislava, Slovakia, 2008, J.D.

Dartmouth College, 2004, A.B., Honors: cum laude, Major: Government

But, lookie here!

Columbia University, J.D.

Dartmouth College, A.B.

Background Report -11/16/2009 19:17

Address: 4236 S GREENWOOD AVE CHICAGO IL60653

BRADLEY Address Records: Address: 5046 S GREENWOOD AVE

Length of residence: 1 years Area Data: City Data:

Housing Units: 1,152,868 land Square Miles:

Longitude: -87.679365 Property Records: Home

Refinance amount: N/R

Attachment: Watertown article. Emphasis added; on

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Published on February 14, 1992, Page 8, Watertown Daily Times

SOVIET UNION'S DEMISE LEAVES LUMUMBA STUDENTS IN A BIND

Complete Article, 662 words: Purchase article

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Thursday, November 5, 2009 7:20 AM

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Contains mention of brother, but not much more

http://www.heritage.org/Research/RussiaandEurasia/bg660.cfm "Working through the

Included for proof of its existence, original article here:

Notice the publication date and age of "Roman":

"SOVIET UNION'S DEMISE LEAVES LUMUMBA STUDENTS IN A BIND

AND NOW, this _ day of _______________, 2009, upon Plaintiffs’

Date: November _, 2009 __________________________