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EXHIBIT “5”

Z:\Liberi, et al, Taitz, et al, Plaintiffs’ Motion for Sanctions; Atty Fees; and Motion to Strike
Case 2:09-cv-01898-ER Document 146-7 Filed 10/07/10 Page 2 of 34

Law Offices of:


PHILIP J. BERG, ESQUIRE
555 Andorra Glen Court, Suite 12
Lafayette Hill, PA 19444-2531 Attorney for: Plaintiffs
Identification No. 09867
(610) 825-3134

UNITED STATES DISTRICT COURT


FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LISA LIBERI, et al, :


Plaintiffs, :
vs. :
: Case No.: 09-cv-01898-ECR
:
:
:
ORLY TAITZ, et al, : Assigned to Honorable Eduardo C. Robreno
Defendants. :
:

VERIFICATION OF LISA LIBERI

I, Lisa Liberi am over the age of eighteen (18); am a Plaintiff in the within action and

verify that the statements made in the foregoing are true and correct to the best of my knowledge,

information and belief. The undersigned understands that the statements therein are made subject

to the penalties of 18 Pa. C.S. Section 4904 and the laws of the United States relating to

unsworn falsification to authorities. I have personal knowledge of the facts herein and if called

to do so, I could and would competently testify under oath.

I, Lisa Liberi, declare as follows:

1. I am filing this verification in lieu of an Affidavit as for safety measures, I will

not place my address or have notarization on a document until there is some form of

protection for me, from the Defendants’ behaviors as Defendants will again publicize my

private data. Due to the fact Ms. Taitz, Linda Belcher and Neil Sankey, etc. have placed

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private personal information on the internet including but not limited to my name, date of

birth, social security number, mother’s maiden name, where I was born, etc

2. I do not reside in the States of Texas or California. And, contrary to the

statements of Orly Taitz, I have never disclosed to any of the Defendants what state issued

my driver’s license, my address or where I reside. Although, I did provide my vital records

to this Court to prove that I did not reside in California or Texas where any of the Defendants

reside.

3. I have been providing intern/donated paralegal services to Mr. Philip J. Berg and

his Law firm for the past few years. Mr. Berg does not pay my husband or me. In my role, I

research the laws and draft on behalf of Mr. Berg.

4. I did not and do not fundraise or have anything to do with any type of donations

taken in by Mr. Berg or his website, obamacrimes.com; I did not moderate or Administrate

Mr. Berg’s website. I did not and do not have access to or deal with any of Mr. Berg’s

personal or business financial accounts, including donations.

5. I have read Defendant Orly Taitz’s most recent frivolous filing, appearing on this

Court’s Docket as Entry number 145. Taitz again misquotes and misrepresents the

information in past court filed documents, and past Orders of this Court. I am truly shocked

and appalled that the Court does not take action against a licensed attorney that continually

files frivolous Court Documents, and many Court Documents that have been proven to be

altered and forged.

6. Geoff Staples statement is yet another “back scratching” document that Orly Taitz

has acquired by asking someone to lie. Staples gladly did so because he is still carrying the

grudge against Mr. Berg for firing him. The attachments to Geoff Staples faxed letter and

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attachments do not match the actual communication documents in Mr. Berg’s possession

regarding the setup of Linkpoint.

7. The actual documents prove that I did not set up the LinkPoint or PayPal

accounts. The actual documents prove that I did not handle and/or process credit cards. The

actual documents also prove that I never had passwords to Mr. Berg’s website and/or Geoff

Staples Private Servers.

8. I have never given anyone, including Geoff Staples, Defendants Linda Belcher,

Orly Taitz, Neil Sankey or Edgar or Caren Hale permission to utilize, forge, access or use my

email address at AOL.

9. I set up my AOL account approximately eight (8) years ago. At the time my AOL

account was set up, my email address was llisaliberi@aol.com, which was preset by AOL to

always appear on my outgoing emails. This is important because on the emails supplied by

Geoff Staples, it shows my email address as “Llisaliberi@aol.com”, which is not correct.

When I send an email, I cannot change the appearance of my email address from

“llisaliberi@aol.com”. As previously explained to this Court, in or about January 2010,

someone called AOL purporting to be me, gave all my confidential information and

cancelled my account. As a result, I lost eight (8) years of stored email.

10. All emails contain header information, which Geoff Staples has provided in his

attachments, which show I did not send the emails he claims I did. The definition of an

“Email Header” is as follows:

“The Definition of Email Header is the text at the beginning of an Internet e-


mail message. It is generated by the client mail program that first sends it and by
all the mail servers en route to the destination. Each node adds more text,
including from/to addresses, subject, content type, time stamp and identification

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data. You can trace the path of the message from source to destination by
reviewing the e-mail header text.”1

11. My AOL email format since inception of my account. Geoff Staples attachments

to his letter do not match the format of my actual emails. See the email sent to Geoff Staples

attached as EXHIBIT “A”, which shows:

From: llisaliberi@aol.com
Date: Wed, Sep 3, 2008 at 11:56 PM
Subject: Fwd: Obama's Crimes on WBQC TV Link
To: philjberg@gmail.com, helpdesk@hostricity.com

12. I did not send the emails Geoff Staples has included in his attachments. Geoff

Staples attachments show that my email address was forged as broken down below.

13. Geoff Staples attachment, Exhibit “2”, page 29 of Orly Taitz’s September 28,

2010 filing (1st email), see EXHIBIT “B”, in the left upper part of the page shows the

following:

 Subject: Declined
From: Llisaliberi@aol.com
Date: Mon, 3 Nov 2008 02:25:29 EST
To: Llisaliberi@aol.com, helpdesk@hostricity.com

 Header information supplied by Geoff Staples, see EXHIBIT “B”, page 2

“[inbound] navstar@iolfree.ie
-address book_(javascript:;_
minimize_(javascript:;)
To: <geoffstaples@hostricity.com>
Date: Sun, 2 Nov 2008 18:12:45 –0500
X-Envelope-From:hostricity.com@megawebservers.com
Return-Path: hostricity.com@megawebservers.com
As you can see, the email was sent from
hostricity.com@megawebservers.com to geoffstaples@hostricity.com.

1
http://www.pcmag.com/encyclopedia_term/0,2542,t=e-mail+header&i=42243,00.asp

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I believe that this means a donation was made by navstar@iolfree.ie, on Mr.


Berg’s website. The donation information was sent to Geoff Staples.
Underneath, it shows Geoff Staples had an address book which appears was
illegally collecting and storing all of Mr. Berg’s donors private and credit card
data. Further, the email header shows the email was sent from Geoff Staples
server “Return–Path: hostricity.co@megawebservers.com to
<geoffstaples@hostricity.com>”. You will also note, my email address
llisaliberi@aol.com does not appear anywhere in the header information,
which is because I did not send this email, nor did this email come from my
AOL email account.

 Header information supplied by Geoff Staples, see EXHIBIT “B”, the top of
page 2

“Web197c0.megawebservers.com (8.13.6/8.12.6/SuSE Linux 0.6) with


ESMTP id mA2Ncjic017925 for geoffstaples@hostricity.com; Sun, 2 Nov
2008 18:12:45 –0500”

Linux is a different operating system. This header information shows that the
computer used to send the email, Geoff Staples claims I sent, was on a Linux
operating system. I do not use Linux and have always used Windows XP.

14. Geoff Staples attachment, Exhibit “2”, page 32 of Orly Taitz’s September 28,

2010 filing (2nd email), see EXHIBIT “C”, which shows:

 Subject: Fwd: Welcome to LinkPoint® API


From: Llisaliberi@aol.com
Date: Tue, 21 Oct 2008 22:26:14 EST
To: helpdesk@hostricity.com

This email was sent to Geoff Staples from Philip J. Berg, Esquire with the
email that Mr. Berg received from secure@securelinkpt.com as depicted by
the message to Geoff Staples from Mr. Berg, see EXHIBIT “D”. Mr. Berg’s
email address was removed and mine was fraudulently input.

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15. Geoff Staples attachment, Exhibit “2”, pages 33-36 of Orly Taitz’s September 28,

2010 filing (3rd email), towards the bottom of page 33. This is an email, which Geoff Staples

sent to me, which shows the correct format of my email address “llisaliberi@aol.com”, see

EXHIBIT “E”, which shows:

 Subject: Re: Fwd: Welcome to LinkPoint® API


From: Help Desk <helpdesk@hostricity.com>
Date: Tue, 21 Oct 2008 22:40:59 -0500
To: llisaliberi@aol.com

16. Geoff Staples attachment, Exhibit “2”, page 41 of Orly Taitz’s September 28,

2010 filing (4th email) see EXHIBIT “F”:

 Subject: Fwd: Donation: 0f6d3d2


From: Llisaliberi@aol.com
Date: Wed, 5 Nov 2008 14:45:01 EST
To: <helpdesk@hostricity.com?

 Holiday needs. Search Now.


(http://pr.atwola.com/promoclk/100000075x12127923820x1200798498/aol?r
edir=http://searchblog.aol.com/2008/11/04/happy-holidays-from –aol-
search/?ncid=emlentussear0000001” “Total Control Panel”
“https://asp-1.reflexion.net/userHome.jsp?uID=10008535”
This should be the last of them.”
“Geoff”

The email shows it came from the Control panel of one of Geoff Staples mail
servers, Reflexion. The message also shows it was from Geoff Staples, as he left
his message in the email “This should be the last of them” and then he signs his
name “Geoff”.

 Header information supplied by Geoff Staples, see EXHIBIT “F”, page 1

[inbound] brianmalek1@yahoo.com
address book
minimize
To: <geoffstaples@hostricity.com>
Date: Mon, 3 Nov 2008 23:45:29 –0500
X-Envelope-From: hostricity.com@megawebservers.com
Return-Path: <hostricity.com@megawebservers.com

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I believe that this means a donation was made by brianmalek1@yahoo.com, on


Mr. Berg’s website. The donation information was sent to Geoff Staples.
Underneath, it shows Geoff Staples had an address book which appears was
illegally collecting and storing all of Mr. Berg’s donors private and credit card
data. Further, the email header shows the email was sent from Geoff Staples
server “Return–Path: hostricity.co@megawebservers.com to
<geoffstaples@hostricity.com>”. You will also note, my email address
llisaliberi@aol.com does not appear anywhere in the header information, which is
because I did not send this email, nor did this email come from my AOL email
account.

 Header information supplied by Geoff Staples, see EXHIBIT “F”, bottom of


page 1

“(8.13.6/8.12.6/SuSE Linux 0.6) with ESMTP id mA44jUcJ025401 for


<geoffstaples@hostricity.com>,; Mon, 3 Nov 2008 23:45:30 –0500”

Linux is a different operating system. This header information shows that the
computer used to send the email, Geoff Staples claims I sent, was on a Linux
operating system. I do not use Linux and have always used Windows XP.

17. Defendant Taitz has filed fourteen [14] pages of Mr. Berg’s stolen financial

information of his supporters and his Business. These fourteen [14] pages are altered, and

the information manipulated. Mr. Berg’s confidential setup information for Linkpoint has

been made public and supporters’ sensitive information has been breached.

18. I have read Linda Belcher’s letter. The conversations she has mentioned were not

with me, nor did I make the statements, which she claims. I did notice that she has forged

her Notary Stamp. Defendant Belcher has also forged a chat log and email inputting my

email address, which has been proven and is on file with this Court.

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19. I have never personally met Defendant Taitz, yet this monster has forever

negatively touched my life. She has almost a daily ritual of posting something about me on

her website. She posts my family picture, addresses and phone numbers that she believes to

be mine. She tells her supporters that I am trying to harm her, and that I am deliberately

trying to keep her from her work regarding President Obama. Taitz blames me and Mr. Berg

for having her Facebook accounts shut down, which is of course because she will not follow

the rules. Defendant Taitz tells her supporters that I am the reason that Mr. Berg and her do

not work together. She posts that I am a career criminal plus other outrageous remarks.

20. Defendant Taitz and her associates, including Defendant Belcher, have contacted

Social Security, IRS, State Tax, etc. and report false accusations against me. Defendant

Taitz has filed numerous false law enforcement reports against me. I do produce the

documents to all Agencies that prove Taitz and her associates are trouble making

harassers. The anxiety and stress is tremendous for both Plaintiff Ostella and me

21. Taitz has been stalking my son, as proven by her filings with this Court.

Someone calling the companies as me has canceled my AOL account and other accounts. My

computer has been hacked a few times. Taitz has been cyber-stalking me, and based on

evidence we have, I believe she attempted to or has hired a very dangerous felon to harm my

son, me and my husband, as well as many other crimes against me and my family.

Defendant Taitz has caused full identity theft of me and my husband by her repeated

postings, mass emailing, hand-outs of mine and my husband’s social security numbers, our

dates of birth, my mother’s maiden name, my place of birth and all my other private

confidential information. There is so much more that we have been forced to endure.

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22. My family and I live in fear every day as a result of Taitz’s threats and illegal

behaviors. No one should be forced to live in this terrorist type environment that Taitz and

her associates have surrounded us with. Taitz is obsessed with harming me and my family.

23. Defendant Taitz made flippant remarks that “Plaintiffs claim they reported

everything to the police but nothing has happened”. Removal of the videotape entitled “ Dr.

Orly Taitz Sued by Birther Phil Berg in Apparent Birth Right Grudge Match” was a

positive step, however Law enforcement investigations do take time, as does the California

Bar Association. Taitz crimes are very serious and involve crimes committed across State

lines.

I declare under the penalty of Perjury of the laws of the United States and subject to the

penalties of 18 Pa. C.S. Section 4904 that the foregoing is true and correct. Executed this

5th day of October 2010.

Respectfully submitted,

____________________________
LISA LIBERI, Plaintiff

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EXBHIBIT “A”

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From: <llisaliberi@aol.com>
Date: Wed, Sep 3, 2008 at 11:56 PM
Subject: Fwd: Obama's Crimes on WBQC TV Link
To: philjberg@gmail.com, helpdesk@hostricity.com

Geoff,

Sorry I accidently sent this with nothing in it. Can you please post this on
obamacrimes.com.

Thanks,
Lisa

ps: I hope your computer is working better.


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EXHIBIT “B”

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EXHIBIT “C”

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EXHIBIT “D”

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From: Philip Berg <philjberg@gmail.com>


Date: Tue, Oct 21, 2008 at 9:14 PM
Subject: Fwd: Welcome to LinkPoint(R) API
To: geoffstaples@geoffstaples.com, "llisaliberi@aol.com" <llisaliberi@aol.com>

Geoff:
LinkPoint sent me two [2] sets of e-mails to set up regarding
replacement of PayPal.
They appear to be very simillar.
This is the first which is forLinkPoint (R) API and the other is
LinkPoint Central.

Please do ASAP.

My Store Name Should change as it is "LAW OFFICES OF PHILIP"

Perhaps to;

"Support Federal Lawsuit to Remove Obama from Ballot" which is


what you had on PayPal.

Thanks,

Phil

---------- Forwarded message ----------


From: secure@secure.linkpt.net <secure@secure.linkpt.net>
Date: Tue, Oct 21, 2008 at 10:17 AM
Subject: Welcome to LinkPoint(R) API
To: "philjberg@gmail.com" <philjberg@gmail.com>

Welcome to LinkPoint(R) API

Cardservice International(R) welcomes you to Internet payment processing and the


LinkPoint(R) Secure Payment Gateway. We are pleased that you have chosen our
LinkPoint Select API for your e-commerce Web site, and we offer the following
information to ensure effective setup of this application. Please read this e-mail carefully.
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This e-mail contains confidential information about your LinkPoint account. Please
protect this information to prevent unauthorized access to your account.

Your DBA store name is: "LAW OFFICES OF PHILIP"


Your store number (store name) is between the quotation marks ("): "1202841"
Your user ID is between the quotation marks ("): "1202841"
Your secure host name is: "secure.linkpt.net" (port 1129)

Your Temporary Password


Please call our 24-hour Internet Support Department at (888) 477-3611,to obtain your
activation password. To expedite this process, please have your store number ready and
available. You will need your password to access reports and administrative tools.

Forget your password?


If you should forget your private password at anytime, call our 24-hour Internet Support
Department at (888) 477-3611, to obtain a new temporary password. After you receive a
new password, it will take approximately 30 minutes for the system to update. We
suggest that you change your new temporary password the next time you log on to
LinkPoint Central.

Technical Questions?
Please contact LinkPoint Select API support at (888) 477-3611 Monday through Friday
9am to 6pm Eastern Standard Time.

General Questions?
Please contact your Cardservice International sales agent at DOMINICK@FDIS-
MWS.COM.

Getting Started
See the LinkPoint API Integration Guide for full instructions on using the LinkPoint API.

To access LinkPoint reports and administrative tools, please use LinkPoint Central. Log
on using the URL below.

LinkPoint reports and administration URL (LinkPoint Central) =>


https://www.linkpointcentral.com

After you log on to the LinkPoint Central secure Web site, you should change your
temporary password to a new secret or private password. To change your password, click
on Admin in the Main Menu Bar, then on Change Password. Choose a password that is
familiar to you, and commit it to memory. Once you establish your new password,
Linkpoint will have no record of your private password. Note: For your own security,
please do not share this password with anyone.

Your Digital Certificate


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In order for you to begin accepting credit card payments, your ISP may require a digital
certificate to complete the setup of your store. This certificate should be saved as a file on
your Web server with a .pem extension.
To download your digital certificate, please use LinkPoint Central.
Access LinkPoint download Center in the LinkPoint Central Support section:
- Log in at https://www.linkpointcentral.com.
- Click on "Support" in the Main Menu Bar.
- Click on the word "Download Center" under Downloads in the Side Menu Box.
- Click on the word "download" Store PEM File section on main page.
- Key in necessary information to start download.

Merchant Services
If you have questions about your merchant account, statement, etc., contact Card Service
International Merchant Services Department at (877) 274-7915.

Thank you for processing with Cardservice International and the Linkpoint Secure
Gateway. We appreciate your business!

-----------------------------------------
The information in this message may be proprietary and/or
confidential, and protected from disclosure. If the reader of this
message is not the intended recipient, or an employee or agent
responsible for delivering this message to the intended recipient,
you are hereby notified that any dissemination, distribution or
copying of this communication is strictly prohibited. If you have
received this communication in error, please notify First Data
immediately by replying to this message and deleting it from your
computer.
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EXHIBIT “E”

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EXHIBIT “F

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