LIBERI V TAITZ (EDPA) - 121 - MOTION FOR RECONSIDERATION OF THE ORDER TO SEVER - Paed-15307802917

Case 2:09-cv-01898-ER Document 121 Filed 06/14/10 Page 1 of 46
Dr. Orly Taitz, Esq
Attorney Pro Se & Attorney
For Defend Our Freedoms Foundation
29839 Santa Margarita Parkway, Suite 100
Rancho Santa Margarita CA 92688
Tel: (949) 683-5411; Fax (949) 766-7603
E-Mail: dr_taitz@yahoo.com
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
LISA LmERI, et al., ) RESPONSE & MOTION FOR

) RECONSIDERATION
Plaintiffs )
) No. C 09 18.98 ECR
v. )
)
o
~ ~'.
~ ORL Y TAITZ, et al., )
) FILED
-~
~ ..ds;\ Defendants. ) JUN 1 42010
~\ ~
'C%, ~CHAEL E. KUNZ. Crerk
- - Oep. crerk
INTRODUCTION
Defendants, Dr. Orly Taitz and Defend Our Freedoms Foundation (DOFF),
hereafter styled "Defendants", fmd themselves ill the position of responding to
Plaintiffs' motion for reconsideration of the June 4,2010 order to sever and
transfer this case to Texas and California due to errors in the order caused by
misrepresentations and fraudulent assertions by the Plaintiffs to the Court. In as
Page lof 11
much as the situation has become confused owing to the multitude of pleadings,
Defendants also make this an alternative motion under FRCP Rule 60(b).
This situation is brought about by what could be described as a case of
confusion due to multiple pleadings by Plaintiffs and a campaign of ex parte
communications (letters and unftled pleadings) by Plaintiffs to the Court regarding
the events beginning roughly April 2009 to present. This in tum has caused the
confusion which resulted in the Court's order of June 4, 2010 ordering the case to
be severed and transferred to be defective for reasons outlined below. Defendants
do not seek a transfer to a district court in California and have made this clear
numerous times in writing to this Court as well as the Third Circuit Court of
Appeals but Defendants do request the case be dismissed for lack of federal
diversity jurisdiction. Defendants contend the Court has inexplicably overlooked
Defendants' contentions that plaintiffLiberi is a citizen of California and instead
relied on the Pennsylvania address used by Liberi when indeed she is not a citizen
of Pennsylvania despite documentary evidence to the contract - a felony
conviction and probation - Plaintiff incurred in California and is now
studiously trying to ignore.
I. mSTORY OF THE CASE
Multiple Plaintiffs sued many different defendants including Defendants on
various theories too numerous to dwell upon here but reflected in the record. The
Page 2 of 11
main and perhaps only viable Plaintiff suing Defendants is Lisa Liberi who
purports that she was defamed when in April 2009 defendant published her
criminal record from CA, as a warning to the public, since she had convictions of
forgery and grand theft, and was preparing court docwnents and sending them via
e-mail and mail to attorney Berg, who filed those docwnents with this very district.
Berg and Liberi were also doing donation drives. Taitz has posted this official
record with a proper intend to warn the public, particularly since one of the cases
dealt with vital records of the President of the United States Barack Obama. Taitz
wasned the public that there was a need to see the originals in light ofLiberi's
criminal convictions of forgery. While there is more than one Lisa Liberi in the
country, Taitz has done her due diligence and interviewed Liberi's arresting
officer, prosecuting attorney, probation officer, victims of her crimes and verified
that indeed Liberi, who was convicted in San Bernardino county CA in 2008 and
who currently is on probation, but fully under jurisdiction of CA is the assistant
preparing papers for Berg. Her probation allows her to stay with her relatives in
Santa Fe New Mexico, but she was not resident ofPA and was not allowed to
reside in PA or anywhere else per her supervised probation. Faced with an
embarrassing situation, possible revocation of probation and incarceration back in
the state prison in CA, Liberi and Berg have concucted their frivolous and
fraudulent legal action, they both provided perjured affidavits, where they claimed
Page 3 of 12
that Liberi is a citizen of PA and the only proof of that was Berg's submission of
his own business address as an address ofLiberi. Based on perjury and fraud they
claimed that Liberi is a resident of PA and that there is jurisdiction in PA based on
diversity. Taitz provided this court previously and providing again official
conviction records from CA, clearly showing her to be under the jurisdiction of the
state of CA and allowed only to NM, not PA. this clearly shows that the whole law
suit was a farce, a fraud perpetrated upon this court and upon the defendants. It was
filed with the only purpose to harass the defendents with the need to respond to
thousands of pages of pleadings unrelated to the dispute and the case being filed in
an out of state jurisdiction, where Taitz is not licensed, does not have access to
electronic filing and has difficulty following the case and responding. Due to the
fact that there was no diversity to begin with, Defendants motioned the court to
dismiss the case due to lack ofjurisdiction. Berg clearly knew that Liberi does not
reside in PA, he knowingly and maliciously concocted a case based on his own and
Liberi's perjury and with intend to harass. Due to that fact Defendants motioned
the court to dismiss with prejudice and to sanction Berg for violation of attorney's
code of ethics, abuse of process and fuing a frivolous action with intend to harass.
In the event this court is not willing to dismiss with prejudice, in the alternative
Defendants are seeking dismissal without prejudice. Since Plaintiffs are opposed to
transfer and Defendants are opposed to trsansfer, the case does not follow into the
Page 4 of 11
category of cases that can be transferred, it was fIled in improper jurisdiction and
the only proper available remedy will be a dismissal in PA.
As noted by the Court in the June 4, 2010 order, jurisdiction really did not
exist in this case owing to the presence of New Jersey parties. The removal of
these parties from the case was accomplished via judicial intervention which
Defendants believe was improper.
Defendants contended the lawsuit was frivolous. Plaintiffs then began a
campaign to "paper" Defendants into submission including the fIling of numerous
prejudicial and irrelevant materials about Defendants which remain in the case fIle.
Plaintiffs fIled an interlocutory appeal when thwarted by this Court in an attempt to
obtain an injunction but even this setback did not stop the blizzard of paper though
the Court suspended the case during part of the pendency of the now dismissed
appeal.
Plaintiffs continued to fIle materials with the Court even though the case was
suspended and Defendant in tum answered lest the Plaintiffs then contend, as they
have in the past, that these fIlings and their irrelevant and prejudicial contents were
characterized as "unopposed" by Defendants. Unfortunately, the record is confused
and many irrelevant and prejudicial materials have been permitted to propagate by
the Court and these materials should be stricken before any transfer.
The Court did not docket any of the Defendants' letters but did docket
Page 5 of 11
the January 21, 2010 letter by Plaintiff and attorney Berg which was
representative of much of the material offered. The letter contained nwnerous
attachments and served no purpose but to tar the Defendants. Defendants'
response to the Berg letter was not docketed. In the undocketed letters by
Defendants, including their most recent communication in regards to yet another
ex parte attempt by Plaintiffs to intluence the Court and mailed just a few days
before the Court's June 4, 2010 order, Defendants have repeatedly stated they
oppose any transfer while Plaintiffs in their letter have demanded a transfer to
California.
ll. REASONS THE JUNE 4 ORDER SHOULD NOT APPLY TO
DEFENDANTS
Application of the June 4, 20 I0 order to Defendants will result in injustice
for the following reasons. First, the Court has mischaracterized the order as
granting somehow Defendants' wishes. Defendants repeatedly tried to oppose any
transfer - the Court ignored Defendants' communications although they were
tendered only in response to Plaintiffs' attempts to ex parte communicate with the
Court. The Court must have been cognizant of the Defendants' communications
because it docketed one letter from Berg along with its so called exhibits.
Second, a transfer rather than a dismissal will work as an undue hardship on
Defendants. Plaintiffs have flIed thousands of pages of pleading and exhibits in
Page 6 of 11
this case which Defendants have replied to. There are multiple defendants and
plaintiffs of which only Defendants will be transferred to California.
The Court has also failed to take in consideration that Plaintiff Liberi is
not a resident or citizen of Pennsylvania and is a resident of citizen of
California due to her felony probation there, something she has not refuted
because it is true. If Liberi, the convicted document forger, is a citizen of
California, diversity jurisdiction does not exist and this case must be dismissed as
to Defendants. The only evidence of citizenship submitted by Liberi is the business
address of her attorney Philip Berg, used as her address on her pleadings,
Defendants have disputed this address. This is therefore a disputed fact, discovery
and an evidentiary hearing should be had upon this as Liberi and not the other
Plaintiffs is the main party complaining against Defendants. The whole essence of
the case revolves around Liberi's address, as over a year ago in the beginning of
April 2009 Taitz has disclosed on her web site the fact that assistant of attorney
Berg is a felon, convicted in the state of CA in 2008 in multiple counts of forgery
and grand theft, and therefore there is a need to investigate the documents
submitted by Berg and Liberi to court. Berg and Liberi were conducting a Nation
wide donations drive to support their legal work in exposing originally president
Bush and later Obama. Members of the public demanded answers from Berg, and
Berg has filed this frivolous law suit claiming that Liberi is a resident of PA,
Page 7 of 11
in order to defraud this court and in order to defraud the public and continue
with their donations drive, while simultaneously harassing the Defendants
with hundreds of thousands of pages of pleadings, full of slander, defamation,
perjury. Both Liberi and Berg knew that the court printout of Liberi's conviction
in CA is true and correct, that she is indeed Lisa Liberi, who was a convicted
forger and thief. This makes the case not only frivolous on it's face, but also
grounds for revocation of Liberi's probation and incarceration in CA. Berg's
actions were clearly sanction able, as he was defrauding the court and fuing a legal
action with the only purpose of harassment of the Defendants and aiding and
abetting perjury by his client. See attached exhibit Declaration made by Liberi in
CA. Liberi is subject to jurisdiction of the department of probations in CA,
therefore if she wants to file a legal action, her proper jurisdiction will be state
court in CA.
Defendants also contend the case will be so cluttered and confused that
a transfer will be unduly prejudicial as to Defendants and equally confusing to
the receiving court. A better result would be a dismissal with prejudice as
Plaintiffs have abused the court process or at the very least without prejudice.
Third, Defendants' respectfully disagree with the Court's analysis under 28
USC 1404. The transfer of this case in its present state will result in injustice and
undue inconvenience to Defendants. Plaintiff Liberi is a California citizen,
Page 8 of 11
citizenship is a factual dispute, which the Court has failed to address except to note
Liberi's alleged address on the pleadings, address that was provided by the
Plaintiffs without any verification.
ill. RELIEF SOUGHT
The Court's order of June 4,2010 should not apply as to Defendants and be
revised to reflect the following:
1. Plaintiff Lisa Liberi has not demonstrated she is a citizen of Pennsylvania and
has in fact along with her attorney Berg affmnatively misled the Court in this
respect.
2. If the Court is yet in doubt, discovery and an evidentiary hearing should be
afforded Defendants in regards to Liberi's citizenship.
3. The current contents of the Court file is overwhelmingly prejudicial to
Defendants and contains extraneous and irrelevant materials that would
impede justice if transferred "as is."
4. The so called voluntary dismissal of New Jersey defendants was not voluntary
in that the New Jersey defendants objected to dismissal without prejudice - the
case should have been dismissed at the point and may still be dismissed nunc pro
tunc.
6. Numerous ex parte communications of Plaintiffs with the Court were
inappropriate and give the appearance of having influenced the Court's June 4,
Page 9 of 11
2010 order in that the June 4 order mirrors the Plaintiffs most recent letter to the
Court.
7. The Court has made references to sanctions against Defendant Taitz in an out of
district court but has refused to take cognizance on the record of multiple sanctions
against Plaintiff Berg, at least one of those instances ordered in this very judicial
district. Sanctions against the defendant had nothing to do with this case or any of
the parties in this case. Sanctions had to do with political matter of the defendant
representing members of active military questioning legitimacy of the commander
in chief. On the other hand sanctions against Attorney Berg, that were presented to
this court showed similar modus operandi, as exhibited in this very case: namely
fuing a frivolous law suit with the purpose of harassing the defendants. Other
sanctions dealt with the fact that attorney Berg was not truthful with the court, also
represents the same modus operandi, as exhibited in this court. It is not clear why
this court has chosen to conspicuously address one instance of sanctions against
the defendant, where this order of sanctions is not fmal and is being currently
appealed, in a political matter involving the President and commander in chief,
which has absolutely nothing to do with the dispute in this case; while at the same
time this court has chosen to completely ignore multiple pleadings where the
deferidants have brought to the attention of this court multiple sanctions against the
Plaintiff and attorney in this case Philip Berg. Sanctions against Berg were relevant
Page 10 of 11
as they reflected the same modus of fuing frivolous action, harassment and fraud.
That is an additional reason, why the order is extremely prejudicial against the
Defendants.
8. The case against Defendants should be dismissed with prejudice for the reasons
briefed above.
Therefore the June 4, 2010 order should be held in abeyance until the above issues
are corrected and resolved.
Date: June 10,2010
lsi Orly Taitz, ESQ pro se and for Defend Our Freedoms Foundation
I, Orly Taitz, attest that true and correct copy of the above pleadings was sent to
Attorney Philip Berg by fIrst class mail, as well as other Defendants in this case.
lsi Orly Taitz

4~
06.10.10
Exhibit 1
Public Record of Lisa Liberi's Bankrupcy filing with address 11952 Huntley Dr.
Rancho Cucamonga, CA 91739 , San Bernardino County with Liberi's sworn
declaration given under penalty of perjury.
Page 11 of 12
Exhibit 2
Public Record of Lisa Liberi's declaration made under penalty of perjury and
under laws of CA in San Bernardino County of CA, seeking recusal of San
Bernardino District Attorney James Seord from prosecuting a nUtuber of her
criminal cases.
Exhibit 3
Public record from San Bernardino CA Superior Court of Lisa Liberi's multiple
criminal convictions for forgery and grand theft, as well as conditions of Lisa
Liberi's formal probation granted on 03.21.2008 in San Bernardino County,
CA to last until 03.21.2011
Page 12 of 12
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bi&i
2
5. A few months after the arrest in Texas, I secured a job, got married to William Courvi11e
3
and we bought a home together in Texas.

4
6. I was divorced in or about the end of 1989 and I accepted a transfer to Newport Beach,
5
California with the company I was working for. I relocated from Texas to California in
6
7
or about December 1989.
9
7. On January IS, 2002 a Search Warrant was served on my property located at 11952
10
Huntley Avenue, Etiwanda" California 91739. At this same time, I was arrested on
It
allegations ofP.C. 470 and P.C. 487. based on San Bernardino County Sheriff's
12
Department Case #1 10200477.

13
14
8. My bail was set at $20,000 which was posted on January 15. 2002 and I was released
IS
from West Valley Detention Center.
16
9. February 25,2002 my Arraignment came on for hearing in San Bernardino County
17
Superior Court, Rancho Cucamonga District, Case #0201341972. No one from the San
18
Bernardino County District Attorney's Office appeared, no charges were filed, my bail
19
bond was exonerated and I was released.

20
21
10. In or about September 200~ I filed a motion in my Paternity Action, San Bernardino
22
County Superior Co~ Rancho Cucamonga District, Case #RFL-034080, requesting
23
permission to relocate with my minor son to New Mexico. On or about October 18,
24
2002, my motion was granted along with a new visitation order pennitting my child's
25
biological father, John Allen to visit with our son in Albuquerque, New Mexico the third
26
weekend of every month at Neutral Comer, a County facility.

27
11. In or about early November 2002, my husband, child and I relocated to New Mexico.
28
t<.t:. moox 131100! Mall rage I Vi I

27) THE DEFENDANT IS NOT TO FILE AHY LAWSUrTllEGAL ACTION WITHOUT PRIOR CONTACT WITH PROBATION OFFICER.
28) 00 NOT APPlY FOR CREDIT OR A LOAN WITHOUT PRIOR CONTACT WITH PROBATION OFFICER.
29) COMPLY WITH AHY COURT-ORDERED PAYMENT SCHEOULE,
30) MAKE RESTITUTION TO VICTIM (SEE PROBATION REPORT) IN AN AMOUNT TO BE DETERMINED BY PROBATION,
31) MAKE RESTITUTION TO VICTIM (SEE PROBATION REPORT) IN AN AMOUNT TO BE DETERMINED BY PROBATION,
PROBATION MAY BE SERVED THROUGH INTER STATE COMPACT AGREEMENT IN THE STATE OF NEW MEXICO UPON
32) APPROVAL FROM PROBATION,
0r1y Tailz ODS Esq
26302 La Paz ste 211

Mission Viejo Ca 92691
29839 S, Margarita Pkwy

Rancho Santa Mwgarita Ca 92688
ph. w 949-586-8110 0-949-683-5411

fax 949-586-2082
CoIlfidei rtiafity Notice: This &-mail, induding all aIfaItlInen!II is for the sole use of !he intsnded rec:iplent(s) and may contain confidential and privileged
information, My IJI'IIiIIJ1hori review, use, disc:It:l6uflI (J( di$tJiIlu!iOn is prohibited unIe8Il specfficaily proyided U1CIer!he New Mexico Inspection of ~
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information. My IJI'IIiIIJ1hori review,use,discfosure or dilsIribuIioo is prohibited unless specilk:atly provided 1J!1der!he New Mexico Inspedion of Public
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The reason for the relocation was due to my health complications, harassment I was
2
enduring from my child's biological father, my father's poor health and to be closer to
3
my family and assist my sister with her medical and psychiatric conditions. The District
4
Attorney has alleged that I fled California to avoid prosecution without a single shred of
5
evidence to support such an allegation, once again attempting to prejudice the Court
6
against me.
7
12. Upon arrival in New Mexico, my husband, Brent Liberi, immediately obtained ajobwitb
8
9
Seeds of Change located in Santa Fe. My husband is still ""ith this company and was
10 recently promoted.
11
13. January 14, 2003, Michelle D. Strickland, Esq. filed a civil lawsuit on my behalf: in San
12
Bernardino County Superior Court, Central District, Case #SCVSS-98957 against among
I3
others, Paul Monison, the investigating officer in the matter herein.
14
14. April 01,2003 Michelle D. Strickland filed a motion re Writ of Possession. D.D.A.
15
James Secord made an appearance as a Special Party of Interest I was not present for
16
17
this hearing, however, I was infonned by Ms. Strickland that D.D.A. Secord stated I was
18
under investigation and was required to bring the motion for writ of possession before the
19
Judge who issued the search warrant. This was the first time I heard I was under
20
investigation. Based on the statements ofD.D.A. Secord my motion was denied without
21
prejudice.
22
15. April 10, 2003, Ms. Strickland filed a motion for reconsideration as she detennined the
23
24
Statements given by D.D.A. Secord were not accurate. A hearing was set for May 13,
25 2003.
26
16. May 09,2003 the San Bernardino County District Attorney's Office filed the first set of
27
charges against me, Case #FWV 028000, based on the same San Bernardino County
28
Sheriff s Deparunent Case # 11 0200477.

1
2 17. In or about October 2003, during the ongoing preliminary hearing in this matter, D.D.A.
3 James Secord obtained an ex parte order from the Orange County Superior Co\ll't
4 Lamoreaux Justice Center in order to obtain access to my confidential Paternity Action,
5
Case #AD-60301. D.D.A. Secord failed to give notice to my attorney's or any parties
6
associated with the Paternity Action so they wou1d have an opportunity to protect the
7
confidentiality of that fi1e. I learned of this during my preliminary hearing in Case
8
9 #FWV-028000 when D.D.A. Secord had my Paternity file brought up to the court room
10 and requested judicial notice of certain documents.
11 18. In or about February 2004, I learned that Randolph C. Houts. Attorney for USA Federal
12
Credit Union and a witness in this case obtained copies ofdocuments which were located
13
within my Paternity Action.
14
19. On March 31 J 2004, I underwent Open Heart Surgery at the Heart HO!q)ital located in
15
16 Albuquerque, New Mexico.
17 20. As a result of the complications I suffered from my Open Heart Surgery, my court
18 appearances were continued. My then attorney, David Goldstein and D.D.A. James
19
Secord stipulated to have my court hearings continued to July 13. 2004.
20
21. On or about June 14,2004, the San Bernardino County District Attorney's Office signed
21
for Government Claims filed on my behalf by Michelle D. Strickland for the illegal
22
access and dissemination of confidential documents taken from my Paternity Action to
23
24 Randolph C. Houts.
25 22. In or about mid June 2004, John Allen, D.D.A. Secord's witness contacted Officer Rudy
--..
26 Gallegos with the Santa Fe Police Department and attempted to have me arrested on a
27
warrant prior to its issuance. The only way Mr. Allen would have had knowledge a
28
warrant was being sought was from D.DA. Secord and/or the San Bernardino County
2
District Attorney's Office. D.D.A. Secord was well aware that my child and I are the
3
victims of John Allen's crimes, for which Mr. Allen was convicted. Further, Mr. Allen
4
was aware I was being arrested when I flew to California as he also sent the chi1d support
5
for July 2004 by restricted delivery knowing I would be unable to pick up the check. (A
6
true and correct copy of Officer Rudy Gallegos declaration is attached hereto and
7
incorporated in by reference as Exhibit 3.)

8
9
23. On June 30, 2004, D.DA. James Secord obtained another warrant for my arrest from the
to
San Bernardino County Superior Court, Central District, Case #FSB 044914 under my
11
married name of LIBERI involving the same vehicle and Credit Union relative to which I
12
was litigating in the first case, Case #FWV028000. D.D.A. Secord was aware I was
13
litigating the first case under my maiden name of RICHARDSON in San Bernardino
14
County Superior Court, Rancho Cucamonga District, as he was the deputy district
15
16
attorney who filed the first case, Case #FWV 028000.
17
24. July 12, 2004, I was arrested at the Ontario Airport by Michael Leiberich with the San
18
Bernardino County District Attorney's Office on behalf of D.D.A. Secord when I flew in
19
for my July 13,2004 court date. As previously stated, D.D.A. Secord knew I would be
20
appearing as he had stipulated to the hearing date of July 13,2004.

21
25. I was taken to West Valley Detention Center, booked and placed in isolation in the men's
22
,.
... J
unit. I suffered another heart attack, which shut down the bypassed area ofmy heart and
24
Ketoacidosis.
25
26. I appeared in Court July t 4, 2004 in-custody for my Arraignment for Case #FSB 044914
'-.
26
and bail hearing on both cases. I entered a plea ofNot Guilty to all counts. My bail on
27
this arrest, Case #FSB 044914 was set at $100,000.00 with a 1275.1 hold. My
28
~
Preliminary hearing was set for July 26, 2004.
I
.,.... 27. August 04,2004 at 8:30 a.m. I was present for a bail hearing on both cases and to have
3 the 1275.1 hold removed on Case FSB-044914. D.D.A. Secord had Mr. Thomas Rice
4 from the Department of Insurance appear in attempts to have my bail bond agent, Scott
5
Mehr's license revoked. D.D.A. Secord stated to the court that Scott Mehr was kicking
6
me back money paid for the bail premium. and that he had a tape of our conversation.
7
This simply was not the case; Scott Mehr was reducing my bail premium to 8% based on
8
9 a new law which had just passed. .Judge Pacheco removed the 1275.1 hold and asked
10 Mr. Mehr ifhe was posting my bail. D.D.A. Secord then made an oral motion and
11 attempted to have my bail raised to $750,000.00. Judge Pacheco denied D.D.A. Secord's
12
request. Steve & Scon Mehr bail bonds posted my baH totaling $350,000.00. I was
13
released:from West Valley Detention Center on August 05, 2004.
14
28. On or about August 09, 2004, I had a court appearance in my Paternity Action. I arrived
15
16 at Department R-17 of this court at approximately 8:30 a.m. I was sitting in the
17 courtroom waiting for my attorney, P. Timothy Pittullo, when D.D.A Secord appeared. I
]8 got up and left the courtroom with a friend of mine, and D.D.A. Secord chased me down
19 the hall. It frightened me and I went into the women's bathroom and waited for awhile.
20
D.D.A. Secord was well aware that I was represented by counsel in the criminal matter.
21
And shouldn't talk to me without my lawyer. D.D.A. Secord came into Department R-17
22
., ..
-.)
two more times and my family attorney had to intervene.
24 29. On or about December 10,2004, my civil attorney. Michelle D. Strickland flIed a lawsuit
25 against D.D.A. Secord, D.A. Michael Ramos, San Bernardino County, San Bernardino
26 County District Attorney's Office, San Bernardino County District Attorney's Office
27
Investigator Robert Schreiber, and other defendants on my behalf and on behalf of my
28
'""'"
\
minor son, Clifford, for the illegal access and dissemination of confidential documents
1
.., from my Paternity Action. United Stales District Court, Central District of Californi~
3
Case #04-1524-VAP (SGLx).
4
30. In or about May 2005, San Bernardino County Counsel, representing D.D.A. James
5
Secord, D.A. Michael Ramos, San Bernardino County, San Bernardino County District
6
Attorney's Office, SSCDA Investigator Robert Schreiber and other county employees
7
filed a motion to dismiss pursuant to F.RC.P. 12(B)(6).

8
9
31. County Counsel's motion to dismiss was heard on August 01, 2005. Honorable Virginia
10 Phillips dismissed Michael A. Ramos, SBCDA Investigator Robert Schreiber and the
11
District Attorney's Office, however found that there was sufficient allegations asserted
12
and held D.D.A. James Secord to answer nine (9) causes of action. The causes of actions
13
D.D.A. James Secord was held to answer for include Abuse of Process, Invasion of
14
Privacy, violation ofequal protection of the laws. violations of non-discriminatory
15
16
policing services, civil conspiracies~ 42 U.S.C. 1983, 1985 and 1986 claims,
17
negligence and violations of due process rights. Judge Phillips fwther ruled that the
18
alleged conduct ofD.D.A. Secord is not protected from prosecutorial immunity because
19
it falls outside the scope of his prosecutorial functions. (A true and correct copy of the
20
Federal Ruling on the County's motion to dismiss is attached hereto and incorporated in
21
by reference as Exhibit 4.)
22
32. I have not been treated fairly by D.D.A. Secord or as all other defendants are treated. It is
23
24
apparent that there is a conflict which prohibits D.D.A. Secord and the San Bernardino
25 County District Attorney's Office from making professional, unbiased decisions

26
pertaining to me and my case. I fear I have no chance at a fair trial as long as D.D.A.
27
Secord and the San Bernardino County District Attorney's Office are allowed to remain
28
on my case.
..
") 33. For the above aforementioned reasons, I respectfully request that D.D.A. James Secord
3
and the San Bernardino County District Attorney's office be recused to insure me a
4
chance at a fair trial.
5
I declare under the penalty of perjury of the laws of the State of California the foregoing is
6
true and correct.

7
DATED: September 21, 2006

8
10
LISA LIBERI
11
12
"'\
.. 13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2 5. A few months after the arrest in Texas, I secured a job, got married to William Courville
3
and we bought a home together in Texas.
4
6. I was divorced in or about the end of 1989 and I accepted a transfer to Newport Beach,
5
California with the company I was working for. I relocated from Texas to California in
6
7 or about December 1989.
8
9 7. On January 15,2002 a Search Warrant was served on my property located at 11952
10
Huntley Avenue, Etiwanda, California 91739. At this same time, I was arrested on
11
allegations ofP.C. 470 and P.C. 487, based on San Bernardino County Sheriff's
12
Department Case # 110200477.
13
14 8. My bail was set at $20,000 which was posted on January 15, 2002 and I was released
15 from West Valley Detention Center.
16 9. February 25, 2002 my Arraignment came on for hearing in San Bernardino County
17
Superior Court, Rancho Cucamonga District Case #0201341972. No one from the San
18
Bernardino County District Attorney's Office appeared, no charges were filed, my bail
19
bond was exonerated and I was released.
20
21 10. In or about September 2002~ I filed a motion in my Paternity Action, San Bernardino
22 County Superior Co~ Rancho Cucamonga District, Case #RFL-034080, requesting
23 pennission to relocate with my minor son to New Mexico. On or about October 18,
24 2002, my motion was granted along with a new visitation order permitting my child's
25
biological father, John Allen to visit with our son in Albuquerque, New Mexico the third
26
weekend of every month at Neutral Comer, a County facility.
27
11. In or about early November 2002, my husband, child and I relocated to New Mexico.
28
DECLARA nON OF LISA tiBERI
The reason for the relocation was due to my health complications, harassment I was
1
2 enduring from my child's biological father, my father's poor health and to be closer to
3 my family and assist my sister with her medical and psychiatric conditions. The District
4 Attorney has alleged that I fled California to avoid prosecution without a single shred of
5
evidence to support such an allegation, once again attempting to prejudice the Court
6
against me.
7
12. Upon arrival in New Mexico, my husband, Brent Liberi, immediately obtained ajob with
8
9 Seeds of Change located in Santa Fe. My husband is still with this company and was
10 recently promoted.
11 13. January 14,2003, Michelle D. Strickland, Esq. filed a civil lawsuit on my behalf, in San
12
Bernardino County Superior Court, Central District, Case #SCVSS-98957 against among
13
others, Paul Morrison, the investigating officer in the matter herein.
14
14. April 01,2003 Michelle D. Strickland filed a motion re Writ of Possession. D.D.A.
15
16 James Secord made an appearance as a Special Party of Interest. I was not present for
17 this hearing, however, I was informed by Ms. Strickland that D.D.A. Secord stated I was
18 under investigation and was required to bring the motion for writ of possession before the
19
Judge who issued the search warrant. This was the first time I heard I was under
20
investigation. Based on the statements of D.D.A. Secord my motion was denied without
21
prejudice.
22
15. April 10, 2003, Ms. Strickland filed a motion for reconsideration as she determined the
23
24 statements given by D.D.A. Secord were not accurate. A hearing was set for May 13,
25 2003.
26 16. May 09, 2003 the San Bernardino County District Attorney's Office filed the first set of
27
charges against me, Case #FWV 028000, based on the same San Bernardino County
28
DECLARATION OF LISA LIBERI
Sheriff's Department Case # 110200477.

1
2 17. In or about October 2003, during the ongoing preliminary hearing in this matter, D.D.A
3 James Secord obtained an ex parte order from the Orange COWlty Superior Court,
4 Lamoreaux Justice Center in order to obtain access to my confidential Paternity Action,
5
Case #AD-60301. D.D.A. Secord failed to give notice to my attorney's or any parties
6
associated with the Paternity Action so they would have an opportunity to protect the
7
confidentiality of that file. I learned of this during my preliminary hearing in Case
8
9 #FWV-028000 when D.D.A. Secord had my Paternity file brought up to the court room
10 and requested judicial notice of certain documents.
11 18. In or about February 2004, I learned that Randolph C. Houts, Attorney for USA Federal
12
Credit Union and a witness in this case obtained copies ofdocuments which were located
13
within my Paternity Action.
14
19. On March 31, 2004, I underwent Open Heart Surgery at the Heart Hospital located in
15
16 Albuquerque, New Mexico.
17 20. As a result of the complications I suffered from my Open Heart Surgery, my court
18 appearances were continued. My then attorney, David Goldstein and D.D.A. James
19
Secord stipulated to have my court hearings continued to July. 13, 2004.
20
21. On or about June] 4,2004, the San Bernardino County District Attorney's Office signed
21
for Government Claims filed on my behalfby Michelle D. Strickland for the illegal
22
access and dissemination of confidential documents taken from my Paternity Action to
23
24 Randolph C. Houts.
25 22. In or about mid June 2004, John Allen, D.D.A. Secord's witness contacted Officer Rudy
26 Gallegos with the Santa Fe Police Department and attempted to have me arrested on a
27
warrant prior to its issuance. The only way Mr. Allen would have had knowledge a
28
DECLARATION OF LISA LIBERl
warrant was being sought was from D.D.A. Secord and/or the San Bernardino County
1
2 District Attorney's Office. D.D.A. Secord was well aware that my child and I are the
3 victims of John Allen's crimes, for which Mr. Allen was convicted. Further, Mr. Allen
4 was aware I was being arrested when I flew to California as he also sent the child support
5
for July 2004 by restricted delivery knowing I would be unable to pick up the check. (A
6
true and correct copy ofOfficer Rudy Gallegos declaration is attached hereto and
7
incorporated in by reference as Exhibit 3.)
8
9 23. On June 30, 2004, D.D.A. James Secord obtained another warrant for my arrest from the
10 San Bernardino County Superior Court, Central District, Case #FSB 044914 tmder my
11 married name of LIBERI involving the same vehicle and Credit Union relative to which I
12
was litigating in the:first case, Case #FWV-028000. D.D.A. Secord was aware I was
13
litigating the flISt case under my maiden name of RICHARDSON in San Bernardino
14
County Superior Court, Rancho Cucamonga District, as he was the deputy district
15
16 attorney who filed the first case, Case #FWV 028000.
17 24. July 12,2004, I was arrested at the Ontario Airport by Michael Leiberich with the San
18 Bernardino County District Attorney's Office on behalf ofD.n.A. Secord when I flew in
19 for my July 13,2004 court date. As previously stated, D.D.A. Secord knew I would be
20
appearing as he bad stipulated to the hearing date of July 13,2004.
21
25. I was taken to West Valley Detention Center, booked and placed in isolation in the men's
22
unit. I suffered another heart attack, which shut down the bypassed area of my heart and
23
24 Ketoacidosis.
25 26. I appeared in Court July 14,2004 in-custody for my Arraignment for Case #FSB 044914
26 and bail hearing on both cases. I entered a plea ofNot Guilty to all counts. My bail on
27
this arrest, Case #FSB 044914 was set at $100,000.00 with a 1275.1 hold. My
28
DECLARAnON OF LISA LIBERl
Preliminary bearing was set for July 26, 2004.

1
2 27. August 04, 2004 at 8:30 am. I was present for a bail hearing on both cases and to have
3 the 1275.1 hold removed on Case FSB-044914. D.D.A. Secord had Mr. Thomas Rice
4 from the Department of Insurance appear in attempts to have my bail bond agent, Scott
5
Mehr's license revoked. D.D.A. Secord stated to the court that Scott Mehr was kicking
6
me back money paid for the bail premium, and that be had a tape of our conversation.
7
This simply was not the case; Scott Mehr was reducing my bail premium to 8% based on
8
9 a new law which had just passed. .Judge Pacheco removed the 1275.1 hold and asked
10 Mr. Mehr ifhe was posting my bail. D.D.A. Secord then made an oral motion and
11 attempted to have my bail raised to $750,000.00. Judge Pacheco denied D.D.A. Secord's
12
request. Steve & Scott Mehr bail bonds posted my bail totaling $350,000.00. I was
13
released from West Valley Detention Center on August 05, 2004.
14
28. On or about August 09, 2004, I had a court appearance in my Paternity Action. I arrived
15
16 at Department R-17 0 f this court at approximately 8:30 a.m. I was sitting in the
17 courtroom waiting for my attorney, P. Timothy Pittullo, when D.D.A. Secord appeared. I
18 got up and left the courtroom with a friend ofmine, and D.D .A. Secord chased me down
19
the hall. It frightened me and I went into the women's bathroom and waited for awhile.
20
D.D.A. Secord was well aware that I was represented by counsel in the criminal matter.
21
And shouldn't talk. to me without my lawyer. D.D.A. Secord came into Department R-17
22
two more times and my family attorney had to intervene.
23
24 29. On or about December 10,2004, my civil attorney, Michelle D. Strickland filed a lawsuit
25 against D.D.A. Secord, D.A. Michael Ramos, San Bernardino County, San Bernardino
26 County District Attorney's Office, San Bernardino County District Attorney's Office
27
Investigator Robert Schreiber, and other defendants on my behalf and on behalf of my
28
DECLARAnON OF LISA LIBERI
minor son, Clifford, for the illegal access and dissemination of confidential documents
2
from my Paternity Action. United States District Court, Central District of California,
3
Case #04-1 524-V AP (SGLx).
4
30. In or about May 2005, San Bernardino County Counsel, representing D.D.A. James
5
Secor~ D.A. Michael Ramos, San Bernardino County, San Bernardino County District
6
Attorney's Office, SaCDA Investigator Robert Schreiber and other county employees
7
filed a motion to dismiss pursuant to F.R.C.P. 12(B)(6).

8
9
31. County Counsel's motion to dismiss was heard on August 0I, 2005. Honorable Virginia
10 Phillips dismissed Michael A. Ramos, SBCDA Investigator Robert Schreiber and the
11
District Attorney's Office, however found that there was sufficient allegations asserted
12
and held D.D.A. James Secord to answer nine (9) causes of action. The causes of actions
13
D.D.A. James Secord was held to answer for include Abuse of Process, Invasion of
14
Privacy, violation of equal protection of the laws, violations of non-discriminatory
15
16
policing services, civil conspiracies~ 42 U.S.C. 1983, 1985 and 1986 claims,
17
negligence and violations of due process rights. Judge Phillips further ruled that the
18
alleged conduct of D.D.A. Secord is not protected from prosecutorial immunity because
19
it falls outside the scope of his prosecutorial functions. (A true and correct copy of the
20
Federal Ruling on the County's motion to dismiss is attached hereto and incorporated in
21
by reference as Exhibit 4.)
22
32. I have not been treated fairly by D.D.A. Secord or as all other defendants are treated. It is
23
24
apparent that there is a conflict which prohibits D.D.A. Secord and the San Bernardino
25 County District Attorney's Office from making professional, unbiased decisions

26
pertaining to me and my case. I fear I have no chance at a fair trial as long as D.D.A.
27
Secord and the San Bernardino County District Attorney's Office are allowed to remain
28
DECLARATION OF LISA LffiERI

Wherefore, defendants demand judgment that the complaint be dismissed, together with the
costs and disbursements of this action.
DM~:V
Dr. Orly Taitz ESQ
26302 La Paz, ste 211
Mission VieJo, CA 92691
Pro Se and on behalf of Defend our Freedoms Foundation and as a president of Defend Our
Freedoms Foundation
Addendum 1 Case FWV028000 - Defendants
Next Court Date Status Agency I Arrest Date Count 1 Chatge Violation Date
DR Number
1 LIBERI, LISA R RA 0511812001 PC 115(A) 05/1812001

110013759
ALIAS: UBERt, LISA R
ALIAS: COURVlllERICHARDSON, LISA
AliAS: LlSERI, LISA A
ALIAS: RICHARDSON, LISA C
ALIAS: COURVILLERICH, LISA
ALIAS: LIBERt, LISA RENEE
AlIAS: LIBERI. LISA
ALIAS: RICHARDSON, LISA RENEE

.. " i
WamInt Type 'SiBtw :lasued Affldavit
iNONe :NlA NlA
PmbatIon ;Type
'Gl8nted .ExpiI800n
Formal 0312112008 .0312112011
Senf8nce ,ConvictedDate County Jail CTS
:State Prison Max Sentence
;NlA 'NIA
.Fine and Penalty !Restitution Fine "Restitution to Victim

..
'0 NlA
Case FWV028000 Defendant 1608112 LlBERI, LISA RENEE Charges
Arnst Claargea
Count iChaIJ18 'Severity :Description VIoIBtion ,P#eaStatus

Date
1 iBURGlARY 05I18flOO1
Filed Cha.,.
Count ChalJ18 !Severity :~ VIOlation Plea .Status

Date
1 PC487(A) ~F 'GRAND THEFT: PROPERTYJETC 05I18fl001 HTA

OVER $400
7
Case 2:09-cv-O 1898-ER Document 35 Filed 05/28/09 Page 8 of 23
2 PC47O(0)F FORGERY 0511812001 HTA
3 PC 472 'F 'FORGE OFFICIAl SEAL 0511812001 HTA
4 'PC115(A) :F OFFERIETC FALSEIFORGEO 0511812001 HTA

INSTRUMENT TO FILE
, .,
5 PC 487(A) 'F GRAND THEFT: PROPERlYlETC 0511812001 HTA
OVER $400
"'
6 PC 47O(D) F ,FORGERY 0511812001 HTA
1 'PC4n F .FORGE OFFICIAL SEAL ,0511812001 HTA
8 PC 115(A) ,F 'OFFERIETC FALSEIFORGEO ;0511812001 HTA

INSTRUMENT TO FILE
9 'Pc 487(A) F GRAND THEFT: PROPERlYlETC 0511812001 HTA

:OVERS400
10, PC487(A) ~F GRAND THEFT: PROPERlYlETC '0511812001 HTA

OVERS4QO
11 ,pc ;F GRAND THEFT: '0511812001 ;HTA

487(0)(1) AUTOMOBILElANIMALlETC
..
12 ;pc 487(A) 'F ,GRAND THEFT: PROPERTYIETC 0511812001 HTA
OVER $400
13 'PC .F :GRANO THEFT: 0511812001 HTA

487(0)(1) AUTOMOBILElANIMALlETC
14 PC487(A) 'F :GRANO THEFT: PROPERlYlETC :0511812001 ;HTA

:OVER$400
15 PC 'F GRAND THEFT: '0511812001 HTA

487(0)(1) ,AUTOMOBILElANIMAUETC
, , .. ..
16 PC 487(A) :F 'GRAND THEFT: PROPERTYIETC 0511812001 ,HTA
OVER $400
11 PC 487(A) F 'GRAND THEFT: PROPERTYIETC 0511812001 HTA

OVER $400
Infor' Chargee
8
- ...
Count Chatge .SeV9lfty :Desctiption Violation Plea Status
Date
1 pc 487(A) F GRAND THEFT: PROPERTYIETC 05I18f2001 GUILTY :CONVICTED

,OVER $400
2 PC F 'NONSUFFICIENT FUNDS: CHECKS 05I18f2001 GUilTY ,CONVICTED

476A(A)
3 ,PC470(D)F FORGERY 0511812001 DISMISSED
4 PC 472 'F 'FORGE OFFICIAL SEAL 05I18f2001 DISMISSED
5 :Pc 115(A) F OFFE~CFALSEFORGED 05I18f2001 :GUILTY CONVICTED

,INSTRUMENT TO FILE
6 :PC487(A) F GRANO THEFT: PROPERTYJETC 05l18f2001 GUILTY .CONVICTED

OVER $400
~. - . .
7 'PC 476 F :MAKlNG, POSSESSING, UTIERING 05l18f2001 DISMISSED
:FICTIOUS INSTRS
8 .PC470(D) F FORGERY ,0511812001 DISMISSED
9 PC 472 F FORGE OFFICIAl SEAL 05l18f2001 GUILTY CONVICTED
10 PC 115(A)F OFFERIETC FALSE/FORGED 05I18f2001 DISMISSED

INSTRUMENT TO FilE
11 PC 487(A) F GRANDTHEFT:PROPERTYIETC 0511812001 'GUllTY CONVICTED

OVER $400
12 PC 487(A) F GRAND THEFT: PROPERTYIETC 05l18f2001 GUilTY CONVICTED

OVER $400
13 PC F GRANO THEFT: 05I18f2001 DISMISSED

487(0)(1) AUTOMOBILElANIMAUETC
14 PC 487(A) F GRANO THEFT: PROPERTYIETC 0511812001 DISMISSED

OVER $400
15 PC F GRAND THEFT: 05I18f2001 DISMISSED

9
16 PC 487(A) F GRANDTHEFT:PROPERTV~C 0511812001 DISMISSED

OVER $400
17 PC F GRAND THEFT: 0511812001 DISMISSED

487(0)(1) AUTOMOBILEIANIMAUETC
18 PC 487(A) F GRAND THEFT: PROPERTVIETC 0511812001 GUlLTV CONVICTED

OVER $400
19 PC 487(A) F GRAND THEFT: PROPERTYIETC 0511812001 GUlLTV CONVICTED

OVER $400
20 PC 115(A) F OFFE~CFALS~ORGED 0511812001 GUlLTV CONVICTED

INSTRUMENT TO FILE
21 PC 470(0) F FORGERY 0511812001 DISMISSED
23 PC 472 F FORGE OFFICIAL SEAL 05/1812001 DISMISSED
Case FWV028000 Defendant 1608112 UBERI. USA RENEE - Probation
Probation Type: FORMAL Granted: 0312112008 Expire: 0312112011
SUPERVISED PROBATION GRANTED FOR A PERIOD OF 36 MONTHS ON FOLLOWING TERMS

AND CONDI110NS:
1) SERVE 26 DAYS IN A SAN BERNARDINO COUNTY JAIL FACILITY, WITH CREDIT FOR
TIME SERVED, A MATTER OF 26 DAYS, PLUS CONDUCT CREDIT PURSUANT TO 1
PC4019 NO ABIDE BY ALL RULES AND REGULATIONS OF THE FACILITY WITHOUT THE
POSSIBILITY OF COUNTY PAROLE.
2) VIOLATE NO LAW.
3) REPORT TO THE PROB OFFICER IN PERSON IMMEDIATELY 0- NO THEREAFTER

ONCE EVERY FOURTEEN (14) DAYS OR AS DIRECTED. REPORT TO THE PROB
OFFICER IN PERSON IMMEDIATELY 0- NO THEREAFTER ONCE EVERY FOURTEEN
(14) DAYS OR AS DIRECTED.
10
Case 2;09-cv-01898-ER Document 35 Filed 05/28/09 Page 11 of 23
4) COOPERATE WITH THE PROBATION OFFICER IN A PLAN OF REHABILITATION AND

FOllOW ALL REASONABLE DIRECTIVES OF THE PROBATION OFFICER.
5) SEEK AND MAINTAIN GAINFUL EMPLOYMENT. OR ATTEND SCHOOL. AND KEEP THE
PROBATION OFFICER INFORMED OF STATUS OF EMPLOYMENT. OR SCHOOL.
6) KEEP THE PROBATION OFFICER INFORMED OF PLACE OF RESIDENCE AND

COHABITANTS AND GIVE WRmEN NOTICE TO THE PROBATION OFFICER TWENTY
FOUR (24) HOURS PRIOR TO ANY CHANGES. PRIOR TO ANY MOVE PROVIDE
WRITTEN AUTHORIZATION TO THE POST OFFICE TO FORWARD MAlL TO THE NEW
ADDRESS. PERMIT VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGENTS
OF THE PROBATION DEPT. ANDiOR LAW ENFORCEMENT FOR THE PURPOSE OF
ENSURING COMPUANCE WITH PERMIT VISITS AND SEARCHES OF PLACES OF
RESIDENCE BY AGENTS OF THE PROBATION DEPT. ANDiOR LAW ENFORCEMENT
FOR THE PURPOSE OF ENSURING COMPLIANCE WITH PERMIT VISITS AND
SEARCHES OF PLACES OF ReSIDENCE BY AGENTS OF THE PROBATION DEPT.
ANDIOR LAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCE WITH
THE TERMS AND CONDITIONS OF PROBATION; NOT 00 ANYTHING TO INTERFERE
WITH THIS REQUIREMENT. OR DETER OFFICERS FROM FULFilliNG THIS
REQUIREMENT. SUCH AS THE TERMS AND CONDITIONS OF PROBATION; NOT DO
ANYTHING TO INTERFERE WITH THIS REQUIREMENT. OR DETER OFFICERS FROM
FULFilliNG THIS REQUIREMENT. SUCH AS ERECTING ANY LOCKED FENCES/GATES
THAT WOULD DENY ACCESS TO PROBATION OFFICERS. OR HAVE ANY ANIMALS ON
THE PREMISES THAT WOULD REASONABLY DETER. ERECTING ANY LOCKED
FENCESIGATES THAT WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE
ANY ANIMALS ON THE PREMISES THAT WOULD REASONABlY DETER, THREAT
THREATEN THE SAFETY OF. OR INTERFERE WITH, OFFICERS ENFORCING THIS
TERM. EN THE SAFETY OF, OR INTERFERE WITH, OFFICERS ENFORCING THIS TERM.
1) NEITHER POSSESS NOR HAVE UNDER YOUR CONTROL ANY DANGEROUS OR

DEADLY WEAPONS OR EXPLOSIVE DEVICES OR MATERIALS TO MAKE EXPLOSIVE
DEVIces.
8) SUBMIT TO A SEARCH AND SEIZURE OF YOUR PERSON. RESIDENCE ANDiOR

PROPERTY UNDER YOUR CONTROL AT ANY TIME OF THE DAY OR NIGHT BY ANY
LAW-ENFORCEMENT OFFICER, WITH OR WITHOUT A SEARCH WARRANT. AND WITH
OR WITHOUT CAUSE (PEOPLE -V- BRAVO).
9) NEITHER USE NOR POSSESS ANY CONTROLLED SUBSTANCE WITHOUT MEDICAL

PRESCRIPTION. A PHYSICIANS'S WRmEN NOTIce IS TO BE GIVEN TO THE
PROBATION OFACER.
10) SUBMIT TO A CONTROLLED SUBSTANCE TEST AT DIRECTION OF PROBATION

OFFICER. EACH TEST IS SUBJECT TO AN $11.00 FEE, TO BE COllECTED BY
CENTRAL COLLECTIONS
11) NOT POSSESS ANY TYPE OF DRUG PARAPHERNALIA. AS DEFINeD IN H&S11364.5(D)
11

12) PARTICIPATE IN A COUNSELING PROGRAM AS DIRECTED BY THE PROBATION

OFACER, SUBMIT MONTHLY PROOF OF ATTENDANCE ANDIOR SUCCESSFUL
COMPlETION TO THE PROBATION OFFICER AS DIRECTED AND BE RESPONSIBLE
FOR PAYMENT OF ALL PROGRAM FEE(S).
13) NOT ASSOCIATE WITH KNOWN CONVICTED FELONS OR ANYONE ACTIVELY

ENGAGED IN CRIMINAL ACTMTY B-OR CODEFENDANT(S) OR VlCTIM(S).
14) NOT ASSOCIATE WITH KNOWN ILLEGAL USERS OR SELLERS OF CONTROLLED

SUBSTANCES,
15) NOT MAINTAIN A CHECKING ACCOUNT OR COMPLETE OR ENDORSE ANY CHECKS

UNLESS MADE PAYABLE TO YOU AND NOT HAVE ANY BLANK CHECKS IN YOUR
POSSESSION WITHOUT PERMISSION OF THE PROBATION OFFICER.
16) SUBMIT A RECORD OF INCOME AND EXPENDITURES TO THE PROBATION OFFICER

QUARTERLY.
17) NEITHER POSSESS NOR USE ANY CREDIT CARD WITHOUT PERMISSION OF THE
PROBATION OFFICER.
18) NOT DRIVE OR POSSESS KEYS OR DOCUMENTATION TO ANY MOTOR VEHICLE

UNLESS LEGALLY REGISTERED TO YOU OR AN IMMEDIATE FAMILY MEMBER,
EXCEPT IN THE COURSE OF EMPLOYMENT.
19) REPORT ALL MOTOR VEHiClES REGISTERED TO YOU TO THE PROBATION OFFICER
WITHIN SevEN (7) DAYS OF ACQUISITION.
20) SUBMIT TO AND COOPERATE IN A FIELD INTERROGATION BY ANY PEACE OFFICER

AT ANY TIME OF THE DAY OR NIGHT.
21) CARRY AT ALL TIMES A VALID DRIVERS LICENSE OR DEPARTMENT OF MOTOR

VEHiClES IDENTIFICATION CARD AND DISPLAY SUCH IDENTIFICATION UPON
REQUEST BY ANY PURPOSE WITHOUT FIRST NOTIFYING THE PO. CONTAINING
YOUR TRUE NAME AGE AND CURRENT ADDRESS
22) ENROLL IN THE DRUG TREATMENT PROGRAM AT THE DIRECTION OF THE

PROBATION OFFICER, AND SHOW PROOF OF ENROLLMENT TO THE PROBATION
OFFICER WITHIN SEVEN (7) DAYS.
23) MAKE RESTITUTION TO THE VlCTlM(S) (SEE PROBATION REPORT) IN THE AMOUNT
OF 59223.n PLUS A 10% ADMINISTRATIVE FEE. TO BE PAID THROUGH CENTRAL
COLLECTIONS
24) MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORT) IN THE AM OUNT OF
$35000.00 PLUS A 10% ADMINISTRATIVE FEE, TO BEPAID THROUGH CENTRAL
COLLECTIONS
12
Case
Case2:09-cv-01898-ER
2:09-cv-01898-ER Document
Document121 Filed05/28/09
35 Filed 06/14/10 Page
Page13
38ofof23
46
25) MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORT) IN THE AMO UNT OF
$68951.08 PLUS A 10% ADMINISTRATIVE FEE, TO BE PAID THROUGH CENTRAl
COLLECTIONS
26) PAY A RESllTUTION FINE IN THE AMOUNT OF $200.00, PLUS A TEN PERCENT (10%)
ADMINISTRATIVE FEE THROUGH CENTRAL COLLECTIONS.
27) THE DEFENDANT IS NOT TO FILE ANY LAWSUITIlEGAL ACTION WITHOUT PRIOR
CONTACT WITH PROBATION OFF1CER.
28) 00 NOT APPLY FOR CREDIT OR A LOAN WITHOUT PRIOR CONTACT WITH
PROBATION OFFICER.
29) COMPLY WITH ANY COURT-ORDERED PAYMENT SCHEDULE.
30) MAKE RESTITUTION TO VICTIM (SEE PROBATION REPORT) IN AN AMOUNT TO BE

DETERMINED BY PROBATION.
31) MAKE RESTITUTION TO VICTIM {SEE PROBATION REPORT} IN AN AMOUNT TO BE

32) PROBATION MAY BE SERVED THROUGH INTER STATE COMPACT AGREEMENT IN

THE STATE OF NEW MEXICO UPON APPROVAL FROM PROBATION.
Case FWV028000 - Defendants
Seq Defendant Next Court Date StatuB Agency I .A1T88t Date Count 1 Charge VIOlation Date
DR Number
1 USERI USA R
! RA 0511812001 PC 115(A) 05/1812001
110013759
ALIAS: LlBERI, LISA R
ALIAS: COURVILLERICHAROSON, USA
ALIAS: UBER', LISA A
ALIAS: RICHARDSON, LISA C
ALIAS: COURVILLERICH, LISA
ALIAS: lIBERI, USA RENEE
ALIAS: LlBERI. LISA
13
ALIAS: RICHARDSON. LISA RENEE
Case FWV028000 Defendant 1608112 UBERI, USA RENEE - Status
CUstody HlA
Filing Type Held to Answer Filing Date 0SI09I2OO3
On:tered Bail SO.oo Posted Bail $0.00
D.A James R. Secord Defense Dean Pilei (Court AppoInted,
Next Action: Deputy Repotftl: RA-RC 110013759
Wamlnt Type Status Issued Affidavit
NONE NlA MIA
ProbIIfIon Type Granted Expiration
Formal 0312112008 0312112011
Santance Convicted Date County Jail CTS
0112512G08 26 Days 26 Days
State Prison Max Sentence
NlA MIA
Fine and Penally Restitution Fine Restitution to Victim
o HlA
Case FWV028000 Defendant 1608112 UBERI, USA RENEE - Charges
14
Case
Page15
40ofof23
46
Arrest Charges
Count Charge Severity Description Violation Plea Status

Date
1 PC459 F BURGLARY 0511812001
Filed Charges
Count Charge Sewdty Description VIOlation Plea Status

Date
1 PC 487(A) F GRAND THEFT: PROPERTYIETC 0511812001 HTA

OVERS400
2 PC 470(0) F FORGERY 0511812001 HTA
3 PC 472 F FORGE OFFICIAL SEAl 05/1812001 HTA
4 PC 115(A) F OFFERIETC FALSEIFORGED 0511812001 HTA

INSTRUMENT TO FilE

OVERS400
6 PC 470(0) F FORGERY 0511812001 HTA
7 PC 472 F FORGE OFFICiAl SEAl 0511812001 HTA
8 PC 115(A) F OFFERlETCFALSEIFORGED 0511812001 HTA

INSTRUMENT TO FilE

OVER $400
10 'PC 487(A) F GRAND THEFT: PROPERTYIETC 0511812001 HTA

OVER $400
11 PC F GRAND THEFT: 0511812001 HTA

487(0)(1) AUTOMOBllElANIMAUETC
15
Case 2:09-cv-01898-ER Document 35 Filed 05128/09 Page 16 of 23
12 PC 487(A) F GRAND THEFT: PROPERTY/ETC 0511812001 HTA

OVER $400

14 PC 487(A) F GRAND THEFT: PROPERTYIETC 05/1812001 HTA

OVER $400

487(D)(1) AUTOMOBllEIANIMALJETC
16 PC 487{A) F GRAND THEFT: PROPERTYIETC 0511812001 HTA

OVER $400
17 PC 487{A) F GRAND THEFT: PROPERTYIETC 0511812001 HTA

OVER $400
Infor Charges
Count Charge Severity Description VIOlation PIes Status

Date
1 PC 487{A) F GRAND THEFT: PROPERTYIETC 0511812001 GUlLTV CONVICTED

OVER $400
2 PC F NONSUFFICIENT FUNDS: CHECKS 0511812001 GUILTY CONVICTED

476A(A)
4 PC 472 F FORGE OFFICIAL SEAl 0511812001 DISMISSED
5 PC 115(A) F OFFE~CFALS~ORGED 0511812001 GUlLTV CONVICTED

INSTRUMENT TO FILE

OVER $400
7 PC 476 F MAKING, POSSESSING, UTIERING 0511812001 DISMISSED

FtCTIOUS INSTRS
16
Case
Page17
42ofof23
46
9 PC 472 F FORGE OFFICIAL SEAL 0511812001 GUlLTV CONVICTED
10 PC 115(A) F OFFERIETC FALSE/FORGED 0511812001 DISMISSED

INSTRUMENT TO FILE
11 PC 487(A) F GRAND THEFT: PROPERTVIETC 0511812001 GUllTV CONVICTED

OVER $400

OVER $400

487(D}(1) AUTOMOBILEIANIMAUETC
14 PC 487(A) F GRAND THEFT: PROPERTYIETC 0511812001 DISMISSED

OVER $400

487(0)(1) AUTOMOBllEIANIMAUETC
16 PC 487(A) F GRAND THEFT: PROPERTVIETC 0511812001 DISMISSED

OVER $400

487(0)(1) AUTOMOBllElANIMAUETC

OVERS400
19 PC 487(A) F GRAND THEFT: PROPERTVIETC 0511812001 GUllTV CONVICTED

OVER $400
20 PC 115(A) F OFFERlETCFALS~ORGED 0511812001 GUllTV CONVICTED

INSTRUMENT TO FilE
23 PC 472 F FORGE OFFICiAl SEAL 0511812001 DISMISSED
case FWY028000 Defendant 1608112 LlSERI, LISA RENEE Probation

17
Probation Type: FORMAL Granted: 0312112008 Expil'fl: 0312112011
SUPERVISED PROBATION GRANTED FOR A PERIOD OF 36 MONTHS ON FOLLOWING TERMS

AND CONDmONS:
1) SERVE 26 DAYS IN A SAN BERNARDINO COUNTY JAIL FACIUTY, WITH CREDIT FOR
TIME SERVED, A MATTER OF 26 DAYS. PLUS CONDUCT CREDIT PURSUANT TO 1
PC4019 NO ABIDE BY ALL RULES AND REGULATIONS OF THE FACILITY WITHOUT THE
POSSIBILITY OF COUNlY PAROLE.
2) VIOLATE NO LAW.
3) REPORT TO THE PROB OFFICER IN PERSON IMMEDIATELY 0- NO THEREAFTER ONCE

EVERY FOURTEEN (14) DAYS OR AS DIRECTED. REPORT TO THE PROB OFFICER IN
PERSON IMMEDIATELY 0- NO THEREAFTER ONCE EVERY FOURTEEN (14) DAYS OR
AS DIRECTED.
4) COOPERATE WITH THE PROBATION OFFICER IN A PLAN OF REHABIUTATION AND

FOUOW AU REASONABLE DIRECTIVES OF THE PROBATION OFFICER.
5) SEEK AND MAINTAIN GAINFUL EMPLOYMENT. OR AliENO SCHOOL. AND KEEP THE
PROBATION OFFICER INFORMED OF STATUS OF EMPLOYMENT. OR SCHOOL.
6) KEEP THE PROBATION OFFICER INFORMED OF PLACE OF RESIDENCE AND

COHABITANTS AND GIVE WRITTEN NOTICE TO THE PROBATION OFFICER TWENTY
FOUR (24) HOURS PRIOR TO ANY CHANGES. PRIOR TO ANY MOVE PROVIDE
WRITTEN AUTHORIZATION TO THE POST OFFICE TO FORWARD MAIL TO THE NEW
ADDRESS. PERMIT VISITS AND SEARCHES OF PLACES OF RESIDENCE BY AGENTS
OF THE PROBATION DEPT. ANDiOR LAW ENFORCEMENT FOR THE PURPOSE OF
ENSURING COMPLIANCE WITH PERMIT VISITS AND SEARCHES OF PLACES OF
RESIDENCE BY AGENTS OF THE PROBATION DEPT. AND/OR LAW ENFORCEMENT
FOR THE PURPOSE OF ENSURING COMPLIANCE WITH PERMIT VISITS AND
SEARCHES OF PLACES OF RESIDENCE BY AGENTS OF THE PROBATION DEPT.
ANOIOR LAW ENFORCEMENT FOR THE PURPOSE OF ENSURING COMPLIANCE WITH
THE TERMS AND CONDITIONS OF PROBATION; NOT DO ANYTHING TO INTERFERE
WITH THIS REQUIREMENT. OR DETER OFFICERS FROM FULFILLING THIS
REQUIREMENT. SUCH AS THE TERMS AND CONDITIONS OF PROBATION; NOT DO
ANYTHING TO INTERFERE WITH THIS REQUIREMENT, OR DETER OFFICERS FROM
FULFILLING THIS REQUIREMENT. SUCH AS ERECTING ANY LOCKED FENCESfGATES
THAT WOULD DENY ACCESS TO PROBATION OFFICERS. OR HAVE ANY ANIMALS ON
THE PREMISES THAT WOULD REASONABLY DETER, ERECTING ANY LOCKED
FENCESIGATES THAT WOULD DENY ACCESS TO PROBATION OFFICERS, OR HAVE
ANY ANIMALS ON THE PREMISES THAT WOULD REASONABLY DETER, THREAT
THREATEN THE SAFETY OF, OR INTERFERE WITH, OFFICERS ENFORCING THIS
TERM. EN THE SAFETY OF, OR INTERFERE WITH. OFFICERS ENFORCING THIS TERM.
18
Case
Document 121 Filed05/28/09
Page1944ofof2346
7} NEITHER POSSESS NOR HAVE UNDER YOUR CONTROL ANY DANGEROUS OR

DEADLY WEAPONS OR EXPLOSIVE DEVICES OR MATERIALS TO MAKE EXPLOSIVE
DEVICES.
8) SUBMIT TO A SEARCH AND SEIZURE OF YOUR PERSON, RESIDENCE ANDIOR

PROPERTY UNDER YOUR CONTROL AT ANY TIME OF THE DAY OR NIGHT BY ANY
LAW-ENFORCEMENT OFACER, WITH OR WITHOUT A SEARCH WARRANT, AND WITH
OR WITHOUT CAUSE (PEOPLE -V- BRAVO).
9) NEITHER USE NOR POSSESS ANY CONTROLLED SUBSTANCE WITHOUT MEDICAl

PRESCRIPTION. A PHYSICIANS'S WRITTEN NOTICE IS TO BE GIVEN TO THE
PROBATION OFFICER.
10) SUBMIT TO A CONTROLLED SUBSTANCE TEST AT DIRECTION OF PROBATION

OFFICER. EACH TEST IS SUBJECT TO AN $11.00 FEE, TO BE COLLECTED BY
CENTRAL COLLECTIONS
11) NOT POSSESS ANY TYPE OF DRUG PARAPHERNAliA, AS DEFINED IN H&S11364.5(D)
12) PARTICIPATE IN A COUNSELING PROGRAM AS DIRECTED BY THE PROBATION

OFFICER, SUBMIT MONTHLY PROOF OF ATTENDANCE ANDIOR SUCCESSFUL
COMPlETION TO THE PROBATION OFFICER AS DIRECTED AND BE RESPONSIBLE
FOR PAYMENT OF AlL PROGRAM FEE(S).
13) NOT ASSOCIATE WITH KNOWN CONVICTED FELONS OR ANYONE ACTIVELY

ENGAGED IN CRIMINAL ACTIVITY B-OR CODEFENDANT(S) OR VlCTIM(S).
14) NOT ASSOCIATE WITH KNOWN IlleGAl USERS OR SEUERS OF CONTROllED

SUBSTANCES,
15) NOT MAINTAIN A CHECKING ACCOUNT OR COMPLETE OR ENDORSE ANY CHECKS

UNLESS MADE PAYABLE TO YOU AND NOT HAVE ANY BLANK CHECKS IN YOUR
POSSESSION WITHOUT PERMISSION OF THE PROBATION OFFICER.
16) SUBMIT A RECORD OF INCOME AND EXPENDITURES TO THE PROBATION OFFICER

QUARTERlY.
17) NEITHER POSSESS NOR USE ANY CREDIT CARD WITHOUT PERMISSION OF THE
PROBATION OFFICER.
18) NOT DRIVE OR POSSESS KEYS OR DOCUMENTATION TO ANY MOTOR VEHICLE

UNLESS LEGAlLY REGISTERED TO YOU OR AN IMMEDIATE FAMILY MEMBER,
EXCEPT IN THE COURSE OF EMPLOYMENT.
19) REPORT AU MOTOR VEHICLES REGISTERED TO YOU TO THE PROBATION OFFICER

WITHIN SEVEN (7) DAYS OF ACQUISITION.
19
Case 2:09-cv-01898-ER Document 35 Filed 05/28109 Page 20 of 23
20) SUBMIT TO AND COOPERATE IN A FIELD INTERROGATION BY ANY PEACE OFFICER

AT ANY TIME OF THE DAY OR NIGHT.
21) CARRY AT ALL TIMES A VALID DRIVERS LICENSE OR DEPARTMENT OF MOTOR

VEHICLES IDENTIFICATION CARD AND DISPLAY SUCH IDENTIFICATION UPON
REQUEST BY ANY PURPOSE WITHOUT FIRST NOTIFYING THE PO. CONTAINING
YOUR TRUE NAME AGE AND CURRENT ADDRESS
22) ENROLL IN THE DRUG TREATMENT PROGRAM AT THE DIRECTION OF THE

PROBATION OFFICER, AND SHOW PROOF OF ENROLLMENT TO THE PROBATION
OFFICER WITHIN SEVEN (7) DAYS.
23) MAKE RESTITUTION TO THE VlCTIM(S) (SEE PROBATION REPORn IN THE AMOUNT
OF $9223.n PLUS A 10% ADMINISTRATIVE FEE, TO BE PAID THROUGH CENTRAL
COLLECTIONS
24) MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORn IN THE AM OUNT OF
$35000.00 PLUS A 10% ADMINISTRATIVE FEE. TO BEPAID THROUGH CENTRAL
COLLECTIONS
25) MAKE RESTITUTION TO THE VICTIM (SEE PROBATION REPORn IN THE AMO UNT OF
$66951.08 PLUS A 10% ADMINISTRATIVE FEE. TO BE PAID THROUGH CENTRAL
COLLECTIONS
26) PAY A RESTITUTION FINE IN THE AMOUNT OF $200.00, PLUS A TEN PERCENT (10%)
ADMINISTRATIVE FEE THROUGH CENTRAl COLLECTIONS.
27) THE DEFENDANT IS NOT TO FILE ANY LAWSUITIlEGAl ACTION WITHOUT PRIOR
CONTACT WITH PROBATION OFFICER.
28) DO NOT APPLY FOR CREDIT OR A LOAN WITHOUT PRIOR CONTACT WITH
PROBATION OFFICER.
29) COMPLY WITH ANY COURT-ORDERED PAYMENT SCHEDULE.
30) MAKE RESTITUTION TO VICTIM (SEE PROBATION REPORn IN AN AMOUNT TO BE

31) MAKE RESTITUTION TO VICTIM (SEE PROBATION REPORT) IN AN AMOUNT TO BE

32) PROBATION MAY BE SERVED THROUGH INTER STATE COMPACT AGREEMENT IN

THE STATE OF NEW MEXICO UPON APPROVAL FROM PROBATION.
20

21

LIBERI V TAITZ (EDPA) - 121 - MOTION FOR RECONSIDERATION OF THE ORDER TO SEVER - Paed-15307802917

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LIBERI V TAITZ (EDPA) - 121 - MOTION FOR RECONSIDERATION OF THE ORDER TO SEVER - Paed-15307802917

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Case 2:09-cv-01898-ER Document 121 Filed 06/14/10 Page 1 of 46

Dr. Orly Taitz, Esq

Attorney Pro Se & Attorney

For Defend Our Freedoms Foundation

29839 Santa Margarita Parkway, Suite 100

Rancho Santa Margarita CA 92688

Tel: (949) 683-5411; Fax (949) 766-7603

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LISA LmERI, et al., ) RESPONSE & MOTION FOR

hereafter styled "Defendants", fmd themselves ill the position of responding to

misrepresentations and fraudulent assertions by the Plaintiffs to the Court. In as

This situation is brought about by what could be described as a case of

confusion due to multiple pleadings by Plaintiffs and a campaign of ex parte

communications (letters and unftled pleadings) by Plaintiffs to the Court regarding

be severed and transferred to be defective for reasons outlined below. Defendants

diversity jurisdiction. Defendants contend the Court has inexplicably overlooked

Defendants' contentions that plaintiffLiberi is a citizen of California and instead

of Pennsylvania despite documentary evidence to the contract - a felony

conviction and probation - Plaintiff incurred in California and is now

studiously trying to ignore.

I. mSTORY OF THE CASE

Multiple Plaintiffs sued many different defendants including Defendants on

who currently is on probation, but fully under jurisdiction of CA is the assistant

reside in PA or anywhere else per her supervised probation. Faced with an

embarrassing situation, possible revocation of probation and incarceration back in

Case 2:09-cv-01898-ER Document 121 Filed 06/14/10 Page 4 of 46

claimed that Liberi is a resident of PA and that there is jurisdiction in PA based on

Case 2:09-cv-01898-ER Document 121 Filed 06/14/10 Page 5 of 46

the only proper available remedy will be a dismissal in PA.

Defendants believe was improper.

Defendants contended the lawsuit was frivolous. Plaintiffs then began a

campaign to "paper" Defendants into submission including the fIling of numerous

Plaintiffs fIled an interlocutory appeal when thwarted by this Court in an attempt to

characterized as "unopposed" by Defendants. Unfortunately, the record is confused

Case 2:09-cv-01898-ER Document 121 Filed 06/14/10 Page 6 of 46

representative of much of the material offered. The letter contained nwnerous

attachments and served no purpose but to tar the Defendants. Defendants'

Defendants, including their most recent communication in regards to yet another

ll. REASONS THE JUNE 4 ORDER SHOULD NOT APPLY TO

Application of the June 4, 20 I0 order to Defendants will result in injustice

granting somehow Defendants' wishes. Defendants repeatedly tried to oppose any

transfer - the Court ignored Defendants' communications although they were

tendered only in response to Plaintiffs' attempts to ex parte communicate with the

Second, a transfer rather than a dismissal will work as an undue hardship on

Defendants. Plaintiffs have flIed thousands of pages of pleading and exhibits in

Case 2:09-cv-01898-ER Document 121 Filed 06/14/10 Page 7 of 46

plaintiffs of which only Defendants will be transferred to California.

not a resident or citizen of Pennsylvania and is a resident of citizen of

because it is true. If Liberi, the convicted document forger, is a citizen of

to Defendants. The only evidence of citizenship submitted by Liberi is the business

Berg is a felon, convicted in the state of CA in 2008 in multiple counts of forgery

with their donations drive, while simultaneously harassing the Defendants

with hundreds of thousands of pages of pleadings, full of slander, defamation,

grounds for revocation of Liberi's probation and incarceration in CA. Berg's

CA. Liberi is subject to jurisdiction of the department of probations in CA,

a transfer will be unduly prejudicial as to Defendants and equally confusing to

the receiving court. A better result would be a dismissal with prejudice as

Third, Defendants' respectfully disagree with the Court's analysis under 28

undue inconvenience to Defendants. Plaintiff Liberi is a California citizen,

Case 2:09-cv-01898-ER Document 121 Filed 06/14/10 Page 9 of 46

Plaintiffs without any verification.

ill. RELIEF SOUGHT