Liberi V Taitz Objections and Opp To Intelius Req For Judicial Notice Doc 389

Case 8:11-cv-00485-AG -AJW Document 389 #:9154
Filed 09/24/11 Page 1 of 6 Page ID
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Philip J. Berg, Esquire Pennsylvania I.D. 9867 LAW OFFICES OF PHILIP J. BERG 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Telephone: (610) 825-3134 E-mail: philjberg@gmail.com
Attorney in pro se and for Plaintiffs
UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION : : : Plaintiffs, : : : : : : : : : : Defendants. : : : :
LISA LIBERI, et al,
CIVIL ACTION NUMBER: 8:11-cv-00485-AG (AJW) PLAINTIFFS OPPOSITION AND OBJECTIONS TO DEFENDANT INTELIUS, INC. REQUEST FOR JUDICIAL NOTICE Date of Hearing: October 17, 2011 Time of Hearing: 10:00 a.m. Location: Courtroom 10D
vs. ORLY TAITZ, et al,
Plaintiffs, by and through their undersigned counsel, Philip J. Berg, Esquire files the within Objections to Defendant Intelius, Inc.s Request for Judicial Notice as the Documents requested Judicial Notice of are not public record and are in full dispute as they are not the documents portrayed by Defendant Intelius, Inc. and the accuracy of the documents are under dispute as the documents Intelius, Inc. is
Liberi, et al, Plaintiffs Opposition and Objections to Defendant Intelius, Inc. Request for Judicial Notice
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requesting Judicial Notice of are not the documents Plaintiffs received as claimed by Defendant Intelius. 1. It is heavily disputed that Intelius Exhibit 1 to the Declaration of
Benjamin Nelson [Nelson Decl] is in fact the report that Orly Taitz obtained and received on April 12, 2009. Orly Taitz did not have an Intelius account or
accounts with any of the Reed Defendants. See the Declaration of Charles Edward Lincoln, III filed July 25, 2011, Docket No. [DN] 313. 2. Exhibit 2 to Nelsons Decl is under dispute as it is not the report
Plaintiff Lisa Liberi received on herself on April 10, 2010 through www.intelius.com. See the Declaration of Lisa Liberi with the report she obtained directly from Intelius, Inc. and the receipt for said report. 3. Plaintiffs have not incorporated into their Complaint Intelius, Inc.s
Terms of Service as falsely claimed by Intelius, Inc. See Intelius, Inc.s Request for Judicial Notice, pg. 1, 4. 4. Nelsons Decl. Exhibit 6, Letter from Lisa Ostella, is asking for
copies of all reports supplied to third parties on behalf of her and her spouse. See Nelsons Decl., Exhibit 6. Lisa Ostellas letter is not simply asking for who obtained her reports as stated by Benjamin Nelson on behalf of Intelius, Inc. and their attorneys. See Intelius, Inc.s Request for Judicial Notice, pg. 2, 6. Moreover, Plaintiff Lisa Ostella sent her letter with information that Intelius, Inc.
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demanded, which Mrs. Ostella believed would be kept in strict confidence. Therefore, Plaintiffs Object to Intelius, Inc.s and their attorneys
mischaracterization of Lisa Ostellas letter and the publication thereof. 5. Plaintiffs Object to Intelius, Inc.s supposed response referred to in
their Request for Judicial Notice on pg. 2, 7. Plaintiff Lisa Ostella never received said letter. See the Declaration of Lisa Ostella. 6. Intelius, Inc.s Frequently Asked Questions are not incorporated
into Plaintiffs FAC referred to in Intelius, Inc.s Request for Judicial Notice on pg. 2, 8. 7. Plaintiffs Object to Intelius, Inc.s statement to the Court on page 3,
paragraph 2, These documents available from Intelius website are the proper subject of judicial notice because they are incorporated into the First Amended Complaint This is untrue and nowhere in Plaintiffs First Amended Complaint will any party find reference to Intelius, Inc. Terms of Service and/or Frequently Asked Questions. 8. Plaintiffs Object to Intelius, Inc.s statement to the Court on page 3,
paragraph 2, Accordingly, the Court is authorized to take judicial notice of pages made available to consumers performing searches through Intelius website, including Intelius Terms and Conditions and Frequently Asked Questions. Defendant Intelius, Inc. is attempting to mislead this Court and confuse the issues.
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The within litigation has nothing to do with Plaintiffs conducting searches or Plaintiffs specific accounts with Intelius, Inc. Other than the fact, Intelius, Inc. violated Californias Information Practices, Cal. Civ. Code 1798, et seq. and therefore are liable for damages and statutory damages as Plaintiffs Lisa Liberi and Lisa Ostella were customers of theirs at the time their private data was disclosed.
I. 9.
ARGUMENT:
Not only is Intelius, Inc. asking this Court to take Judicial Notice of
documents that are not incorporated into Plaintiffs FAC, they are attempting to mislead this Court into believing documents they are providing are the genuine documents, which they are not. Further, the documents are not of public record as falsely claimed by Intelius, Inc. 10. The documents Defendant Intelius, Inc. is requesting Judicial Notice
of are not public records. In fact, several of them contain full Social Security numbers, dates of birth, home addresses, etc. 11. It is well established, as a general rule, our Courts "may not consider
any material beyond the pleadings in ruling on a Federal Rules of Civil Procedure, [Fed. R. Civ. P.] 12(b)(6) Motion." Lee v. City of Los Angeles, 250 F.3d 668, 688 (9th Cir. 2001). (internal citation and quotation marks omitted). Our Courts may, consider materials that are submitted with and attached to the Complaint. Id. Our
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Courts may also consider unattached evidence on which the complaint "necessarily relies" if: (1) the complaint refers to the document; (2) the document is central to the plaintiff's claim; and (3) no party questions the authenticity of the document. Marder v. Lopez, 450 F.3d 445, 448 (9th Cir. 2006); Lee, 250 F.3d at 688. 12. Our Courts may also take Judicial Notice of matters of public
record, Federal Rules of Evidence [Fed. R. Evid.] 201. See also Lee 250 F.3d at 689. Our Courts cannot however, take Judicial Notice of facts that may be subject to reasonable dispute. Id. at 689. To be more specific, our Courts may not, on the basis of evidence outside of the Complaint, take Judicial Notice of facts favorable to Defendants that could reasonably be disputed. See Id. at 689-90. 13. The documents Defendant Intelius, Inc. is requesting Judicial Notice
of are under full dispute; are not public records; are not incorporated in or attached to Plaintiffs First Amended Complaint and are outside of the pleadings. // // // // // // // // // // // //
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II. 14.
CONCLUSION:
For the reasons outlined herein, Plaintiffs respectfully Request this
Court to Deny Defendant Intelius, Inc.s Request for Judicial Notice. Respectfully submitted,
Dated: September 23, 2011
/s/ Philip J. Berg Philip J. Berg, Esquire Pennsylvania I.D. 9867

LAW OFFICES OF PHILIP J. BERG
555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Telephone: (610) 825-3134 E-mail: philjberg@gmail.com Attorney in Pro Se and Counsel for Plaintiffs
Case 8:11-cv-00485-AG -AJW Document 389-1 #:9160
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Philip J. Berg, Esquire (PA I.D. 9867) E-mail: philjberg@gmail.com LAW OFFICES OF PHILIP J. BERG 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Telephone: (610) 825-3134 Fax: (610) 834-7659 Attorney in pro se and for Plaintiffs UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION LISA LIBERI, et al, : : : : Plaintiffs, : : : : : : : : Defendants. : : :
CIVIL ACTION NUMBER: 8:11-cv-00485-AG (AJW) DECLARATION OF PHILIP J. BERG, ESQUIRE Date of Hearing: October 17, 2011 Time of Hearing: 10:00 a.m. Location: Courtroom 10D
DECLARATION OF PHILIP J. BERG, ESQUIRE I, Philip J. Berg, Esquire, am over the age of 18 and am a party to the within action. I have personal knowledge of the facts herein, and if called to do, I could and would competently testify. I am making this Declaration under the penalty of perjury of the Laws of the United States pursuant to 28 U.S.C. 1746. 1. I am an Attorney in good standing, licensed to practice law in the
Commonwealth of Pennsylvania. I am licensed to practice in the U.S. District
Declaration of Philip J. Berg, Esquire
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Courts, Middle and Eastern District of Pennsylvania; Third Circuit Court of Appeals; the Pennsylvania Supreme Court; and the U.S. Supreme Court. 2. Intelius with their Motion to Dismiss [MTD] has filed a Declaration
from Benjamin Nelson [Nelson] who claims to be the Custodian of Records for the past six [6] years. 3. Nelson states that I sent a letter on behalf of Plaintiff Lisa Liberi
[Liberi] and dealt with incorrect information they have on file for my client. My letter, as demonstrated by Nelsons Exhibit 5 also pertained to Plaintiff Lisa Ostella [Ostella] and dealt with incorrect information Intelius maintains on her. 4. Nelson also states they are not a Consumer Credit Reporting
Agency and they are not required to comply with the Fair Credit Reporting Act [FCRA]. To the contrary, I located several locations on Intelius website, that you can access by going to www.intelius.com that states they are a Consumer Credit Reporting Agency and comply with the FCRA as well as other State and Federal laws. 5. October On file with the United States Security Exchange [SEC] is Intelius 19, 2009 Form S-1 Registration and located at
http://ipo.nasdaq.com/edgar_conv_html%5C2009%5C10%5C19%5C000095012309-051082.html. Intelius states on pages 24 and 25 in their report to the SEC: Because we use personal information in providing our information services, we are subject to government regulation and vulnerable to
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adverse publicity. We provide many types of data and services that already are subject to regulation under the FCRA, Gramm-LeachBliley Act, Drivers Privacy Protection Act and, to a lesser extent, various other federal, state and local laws and regulations. Violation of these laws or regulations may result in substantial fines, judgments and other penalties. These laws and regulations are designed to protect the privacy of the public and to prevent the misuse of personal information in the marketplace. 6. Intelius repeats that they are a Consumer Reporting Agency and
follows the FCRA in their enterprise agreement located on their website at http://www.intelius.com/enterpriseagreement.php. In this agreement, Intelius
states numerous times they are a consumer reporting agency governed by the FCRA. 7. Intelius repeats they are a Consumer and Credit Reporting Agency in
their Security and compliance statements located on their website at http://www.intelius.com/corp/security. In this publication by Intelius, they state: Intelius recognizes the sensitivity surrounding many of its applications and the data they rely on. As such, Intelius' information security policy addresses security at all levels: personnel, technology and operations. Intelius is a certified credit reporting agency.
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8.
And,
in
Intelius
TalentWise
Agreement
located
at
https://www.talentwise.com/terms.html, Intelius again confirms they are governed by the FCRA because they are a Consumer Reporting Agency: DUE TO THE SENSITIVE AND HIGHLY REGULATED NATURE OF THE DATA AND INFORMATION YOU AND YOUR ORGANIZATION WILL GAIN ACCESS TO THROUGH INTELIUS SCREENING SOLUTIONS LLC (d/b/a "TALENTWISE") Intelius Screening Solutions LLC (d/b/a "TalentWise") is a consumer reporting agency and provides consumer reports and investigative consumer reports ("Screening Reports") as defined by the Fair Credit Reporting Act ("FCRA") 9. The statements of Mr. Nelson are not accurate. I also have copies of
the background checks conducted on Plaintiff Lisa Liberi. Each background report Mrs. Liberi obtained from Intelius and U.S. Search contained her full Social Security number, date of birth, name, address, spouses name and other information identified to her. The reports obtained by Mrs. Liberi were not generalized
searches of only a name. 10. Mr. Nelson states Defendant Orly Taitz obtained the same report as
Lisa Liberi. With this, Mr. Nelson has confirmed and substantiated Plaintiffs allegations against Intelius. The reports Mrs. Liberi obtained were reports
governed by the FCRA as they were classified by Intelius as Consumer Reports and that is the same Report obtained by Orly Taitz and Neil Sankey on Mrs. Liberi, as stated in Mr. Nelsons Declaration.
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11.
The reports attached to Mr. Nelsons Declaration as Exhibit 1 and
2 are not the same reports obtained by Mrs. Liberi. 12. I am very concerned with the fact Intelius has spoiled evidence and
deleted evidence. This is very prejudicial to my clients. All evidence should have been preserved by Intelius and their Attorneys as they were aware they were in litigation. 13. Intelius has deleted Plaintiff Lisa Ostellas account; deleted all
searches performed by Mrs. Ostella; provided reports which do not match or contain the same data as those purchased by Mrs. Liberi; and Intelius, although they claim to maintain all searches performed, stated Mrs. Ostella never had an account which had two [2], one of which was recently opened. 14. Intelius has also deleted all files they had available on both Mrs.
Liberi and Mrs. Ostella. When attempting to search Mrs. Liberis name, the reports provided by Mr. Nelson do not come up, nor do the reports Mrs. Liberi has purchased. 15. Intelius is a Consumer Reporting Agency bound by the Fair Credit
Reporting Laws; California Laws; and Federal Trade Commission [FTC] regulations.
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16.
Intelius should have had safety precautions in place, had they of,
Defendant Orly Taitz, Yosef Taitz, Neil Sankey and the other Sankey Defendants would not have been able to obtain my clients private data from Intelius. 17. Intelius did not have a permissible or legal purpose in purchasing my
clients private data from the Reed Defendants and then selling it to third parties. 18. Mr. Nelson has also confirmed three [3] additional parties Mrs.
Liberis private data was sold to, without any type of permissible purpose. 19. For the reasons outlined in Plaintiffs Opposition and Brief thereto,
Defendant Intelius, Inc.s Motion to Dismiss must be Denied. I declare under the penalty of perjury of the Laws of the United States and California that the foregoing is true and correct.
Executed this 24th day of September, 2011 in the Commonwealth of Pennsylvania, County of Montgomery. /s/ Philip J. Berg Philip J. Berg, Esquire, Declarant
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Attorney for Plaintiffs
UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION LISA LIBERI, et al, : : : Plaintiffs, : : : : : : : : : : Defendants. : : : :
CIVIL ACTION NUMBER: 8:11-cv-00485-AG (AJW) DECLARATION OF LISA LIBERI Date of Hearing: October 17, 2011 Time of Hearing: 10:00 a.m. Location: Courtroom 10D
Declaration of Lisa Liberi I, Lisa Liberi, am over the age of 18 and am a party to the within action. I have personal knowledge of the facts herein, and if called to do, I could and would competently testify. I am making this Declaration under the penalty of perjury of the Laws of the United States pursuant to 28 U.S.C. 1746. 1. I ran reports on myself through Intelius in April 2010. I purchased
two [2] separate reports at that time. The first report I purchased was a full
Declaration of Lisa Liberi
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background report on myself. Intelius assigned my report, Intelius Report No. 30897400. See my Intelius report and receipt attached hereto and incorporated in by reference as EXHIBIT A. As shown by the report I purchased, the
information contained within the file only pertains to me, not the general name Lisa Liberi. 2. I have never seen an Intelius report or purchased an Intelius report that
appears as the one filed by Benjamin Nelson as his Exhibit 2 to his Declaration. EXHIBIT A attached hereto is the only background report I have purchased from Intelius, the two [2] reports do not match. Mr. Nelsons report is far different than the report I actually received. 3. At the time I conducted my search, when I ran the name Lisa Liberi
there were only two [2] files which came up, both of which belonged to me. 4. I also ran a report on myself through Intelius and purchased the
TalentWise Report. The TalentWise report, like my background report, is very specific to me only, not just a name of Lisa Liberi. As can be seen on my TalentWise report, attached hereto as EXHIBIT B, it contains my date of birth, address, Social Security number and other private data, which has been properly redacted for this filing. At the time I purchased my TalentWise report, it was all done online. There was absolutely no verification by Intelius to ensure I was entitled to the report, as required by the FCRA. My Intelius TalentWise Report Number is 30897630.
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5.
Intelius continues stating they are not a credit reporting agency and
they do not have to adhere to the FCRA. This is contrary to Intelius statements on their website at http://www.intelius.com/enterpriseagreement.php;
http://www.intelius.com/corp/security; https://www.talentwise.com/terms.html or what they filed in October 2009 with the U. S. Securities and Exchange Commission (SEC) located on the SEC website at
http://ipo.nasdaq.com/edgar_conv_html%5C2009%5C10%5C19%5C000095012309-051082.html, and, the terms and conditions I was required to accept to purchase my reports. In all these locations, Intelius openly admits they are a Consumer Reporting Agency and they adhere to the FCRA, and other State and Federal laws, as required. 6. The terms and conditions I had to agree to for my TalentWise report
are attached hereto as EXHIBIT C and do not match the terms and conditions attached to Mr. Nelsons Declaration as his Exhibit 4. 7. On November 1, 2010, I sent a very detailed letter to Intelius
regarding the incorrect information they maintained on me in their files. See EXHIBIT D. I sent my letter to them with delivery confirmation by way of priority mail through the post office. I never received my reports from Intelius, nor did I receive any type of response.
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8.
I also discovered that Intelius pulled my private data from reports they
purchased from LexisNexis and ChoicePoint, [the Reed Defendants]. I was never notified Intelius was purchasing reports or my private data from the Reed Defendants; I never gave my permission, nor would I have, and I am disgusted they resold my private data for a profit. More disgusting is the fact they sold my private data to Orly Taitz to carry out her threats towards me; to Neil Sankey to supply to Taitz; to K. Lawson, T. Loggia and Ms. Choy. I was never notified by Intelius of these searches, of these reports provided on me, or any legal permissible purpose for which Intelius provided my reports. Instead, Intelius provided my private information without any verification, for a profit. These were not general searches of a name that Intelius sold to these individuals. 9. I conducted another search at www.intelius.com after receiving Mr.
Nelsons Declaration. Everything pertaining to me had been deleted. There were not any Lisa Liberis appearing with addresses in San Francisco, Virginia, or any Liberis with the first names appearing in Mr. Nelsons report attached as his Exhibit 2 to his Declaration. The names and addresses appearing in Mr.
Nelsons report, Exhibit 2 to his Declaration were non-existent. See the screen shots attached hereto as EXHIBIT E. 10. I always believed my identifying information, including my Social
Security number, date of birth, place of birth, maiden name, relatives names, etc.
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would remain confidential and I would have full control over who my information was supplied to, not a data broker for a profit. 11. My family and I have been severely damaged as a result of the Reed
Defendants and Intelius, freely providing my confidential information for a fee which profits them. Although there are laws to protect my information, the Reed and Intelius Defendants refuse to adhere to the laws and protect individuals, including my family members privacy and mine. 12. In fact these Defendants sold my information for threats to be carried
out against me, which they were. As a result, I have been severely harassed, cyberstalked, stalked, ridiculed, my privacy invaded, and my full identity stolen over and over again, along with my husbands. My son has been stalked by Defendant Taitz. As a result of the stress induced by the Defendants, I have had paramedics at my home numerous times due to my health complications from the severe stress; I have been hospitalized for heart complications due to the stress; I have had to pay for cardiac treatments, including but not limited to Enhanced External Counterpulsation [EECP] on two (2) occasions; Echo Cardiograms; and other cardiac testing which is very expensive. 13. Intelius simply ignored the letters from my attorney and from me.
Intelius did not report the misuse of the information they provided on me and my family to law enforcement or any other data brokers. Intelius did not report to law
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enforcement Defendants Orly Taitz, Neil Sankey, Yosef Taitzs, etc. misuse of the information maintained with Intelius. Intelius, like the Reed Defendants, just ignored it.
I declare under the penalty of perjury of the Laws of the United States and the State of California that the foregoing is true and correct. Executed this 23rd day of September, 2011 in the State of New Mexico.
Lisa Liberi, Declarant
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EXHIBIT A
From: Intelius <donotreply@intelius.com> Date: Sat, Apr 10, 2010 at 10:25 PM Subject: Intelius Purchase Receipt - Order #30897400 To: lisaliberi@gmail.com
Hello Lisa, Your order number 30897400 was placed on April 10th, 2010, 9:20 PM (PST). Thank you for placing your order with Intelius.com Your credit card statement will reflect a $44.96 charge from Intelius.com. To access your reports purchased in the last 45 days, visit View My Reports. Order Details 1 Background Report Club Intelius Discount. You saved $4.99. Total Charge Your Savings: $4.99 Customer Service Contact Information: Contact Us via Email. Club Intelius Phone Number: (866) 974-6187 Service Hours: Mon - Fri, 4:30AM - 10:00PM PST This is an automated notification. Please do NOT reply to this e-mail. Please print this page or note the order number for future reference. Thank you for your business and making Intelius your trusted information source. Best Regards, $44.96 $44.96
Intelius
If you would like to unsubscribe, please contact Customer Service
Exb. "A", pg. 8
Thank You for Your Order - Intelius.com
https://www.intelius.com/search-detail-out.php?Select=1&ReportType=8&Selection=0
Club Member lisaliberi@gmail.com [Sign Out] | My Intelius Help: (888) 445-2727 | View My Reports
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Background Report - April 10, 2010

Order #30897400 What is a Background Report?
Your Report Summary
Name:
Lisa Liberi
Report Contents
Personal Public Records Data Property History Summary Single State Civil Judgments
Person Selection
Address History
Single State Criminal Check
People Search Report
A Background Report contains information collected from public records and publicly available data. The report is designed as a service to assist you in locating or verifying an individual's background information. The data within the report is compiled from thousands of different sources that include government, property, and other public record repositories. The Intelius service organizes and integrates information together as a convenient service for you.
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Exb. "A", pg. 9
It is important to understand that public records are only as accurate as the agencies that input them. Please be sure to closely review the public information listed about the individual that you may be researching in the report.
4/11/2010 12:26 A
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We found 2 records that match your search. Click "View Report" to view background report on each individual.
1 Lisa Liberi (909) 466-9532 View all Addresses Currently Viewing
Known Address: 7349 Milliken #140 Rancho Cucamonga, CA 91730
2 Lisa Liberi
Known Address: 11952 Huntley Dr Rch Cucamonga, CA 91739 View all Addresses
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Personal Public Records Data

What is a Personal Public Records Data?
Subject Name: Lisa Liberi
Listed Aliases: Lisa Liberi
Personal public record data can be inaccurate, so it's important to understand what is in the public records for Lisa Liberi.
Personal public records data refers to information such as aliases, birth dates, age and other data found to be connected to Lisa Liberi in the public record. This information can further help you by identifying alternate and/or maiden names, age variations, and any other information that may be associated with Lisa Liberi.
Case 8:11-cv-00485-AG -AJW Document 389-2 Filed 09/24/11 Page 10 of 35 Page ID #:9175
Address History For Lisa Liberi

What is an Address History?
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Exb. "A", pg. 10
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1 91730
Lisa Liberi Rancho Cucamonga, CA
7349 Milliken #140
(909) 466-9532
Property Report
2 Upland, CA 91784
Lisa Liberi
1537 Grandview
Property Report
This report section lists historical addresses associated with an individual from public records. An Address History can assist in flagging address exceptions that may exist in public records. The addresses and phone numbers are not listed in date order and should be individually reviewed.
3 Santa Fe, NM 87508
Lisa Liberi
4 Bonito
(505) 466-2505
Property Report
Property History Summary

What is a Property History Summary?
This section lists summary, neighbors, relatives and area data associated with the property when available. The Relatives and Associates section lists potential relatives or previous occupants associated with an individual and / or their address from public records. The Neighbors Around the Property section lists the immediate neighbors around the property. These sections can help confirm the people linked to your subject and provide additional people that may have current or forwarding information on the whereabouts of your subject.
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Exb. "A", pg. 11
4/11/2010 12:26 A
ADDRESS & CONTACT INFO: 7349 Milliken #140 Rancho Cucamonga, CA 91730 (909) 466-9532
Get A Complete Property Report
PROPERTY DETAILS
Owner Name Ldc Central Park Plaza

NEIGHBORS AROUND THE PROPERTY
Property Info Taxes: $11,001 (2008)
Name
Complete Property Reports Include: Arturo Palato 7868 Milliken Ave Rancho Cucamonga, CA 91730 (909) 945-0591 Background Check
Roger C Sparks 7723 Milliken Ave Rancho Cucamonga, CA 91730 (909) 466-7989 Background Check
List of all 65 neighborhood sex offenders Sales History Mortgage Information Satellite Image And More Jeffery Miller 7868 Milliken Ave Rancho Cucamonga, CA 91730 (909) 758-0795 Background Check
Get a Complete Property Report Gina Duncan 7868 Milliken Ave Rancho Cucamonga, CA 91730 (909) 244-0668
Background Check
Jr G Black 7868 Milliken Ave Rancho Cucamonga, CA 91730 (909) 483-1349

AREA DATA
Background Check
Total Population 51,969
Avg. House Price $145,500
Avg. Household Income $50,047
Area Sex Offenders 65
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Exb. "A", pg. 12
ADDRESS & CONTACT INFO: 1537 Grandview Upland, CA 91784
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4/11/2010 12:26 A
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Customers are charged a search fee for executing a Criminal Check. The Criminal Check report returns results which may include all criminal records or no results found on the individual. In the event of using this service for criminal background checks, you should not assume that this data provides a complete or accurate history of any person's criminal history. You should use extreme caution when interpreting the results of a criminal background search for any type of personal verification. Positive or false matches in criminal searches may not provide confirmation of an individual's criminal background. Please reference the updated Intelius User Agreement for additional restrictions regarding the usage of
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Exb. "A", pg. 13
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this data.
CRIMINAL CHECK FOR ALL LISA LIBERI IN THE STATE OF CA
Record 1 of 4
IDENTIFICATION
Lisa Liberi
CA
SOURCE: CA
OFFENSE DETAILS FSB044914 - Confirm Case at the Courthouse San Bernadino 06/30/2004 OFFENSE COUNTY: San Bernadino DISTRICT: SAN BERNARDINO SUPERIOR
CASE NUMBER:
COUNTY CHARGED:
OFFENSE DATE:
Record 2 of 4
IDENTIFICATION
Lisa A Liberi
CA
SOURCE: CA
OFFENSE DETAILS FSB044914 - Confirm Case at the Courthouse San Bernadino 06/30/2004 OFFENSE COUNTY: DISTRICT: SAN BERNARDINO SUPERIOR San Bernadino
CASE NUMBER:
COUNTY CHARGED:
OFFENSE DATE:
Record 3 of 4
IDENTIFICATION
Lisa R Liberi
CA
SOURCE: CA
DOB: May 28, 1965
OFFENSE DETAILS 030202LL - Confirm Case at the Courthouse San Bernadino DISTRICT: SAN BERNARDINO SUPERIOR
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Exb. "A", pg. 14
CASE NUMBER:
COUNTY CHARGED:
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This section lists civil records from county courts for the selected address. The types of records include property tax liens, general tax liens, bankruptcies, small claims, judgments, and more associated with the selected address. Please closely review each record as common addresses may return multiple civil record results.
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Exb. "A", pg. 15
4/11/2010 12:26 A
CIVIL JUDGMENT RECORDS FOR LISA LIBERI IN THE STATE OF CA - 6 RECORDS FOUND
RECORD 1 Liberi, Lisa Civil Judgment 20020400 10567 Green Acre Dr Ca Redlands Centennial San Bernardino County, San Bernardino Superior Court Unlawful Detainer: N Court Code: Ca254 Zip: 91730 City: Rancho Cucamonga Amount Liability: $20,944.00 Entity Type: Individual Record Case Number: 2002 193850
CIVIL RECORD VERIFICATION: CONFIRM CASE # 2002 193850 AT THE COURT HOUSE
Defendant:
Filing Type:
Filing Date:
Address:
State:
Plaintiff:
Court Name:
RECORD 2 Liberi, Lisa Chapter 7 Filing (New) 20020807 Rancho Cucamonga 91739 9099830877 Ontario 91762 Casbrf1 Pc Action Type: Court Name: Assets Available: Attorney State: Ca N California Fed Court-riverside Bankruptcy Attorney Address: Attorney: State: Ca Curtis R Aijala 123 W B St # C Address: 11952 Huntley Dr Entity Type: Individual Record Case Number: 0222845
CIVIL RECORD VERIFICATION: CONFIRM CASE # 0222845 AT THE COURT HOUSE
Defendant:
Filing Type:
Filing Date:
City:
Zip:
Attorney Phone:
Attorney City:
Attorney Zip:
Court Code:
Judge Initials:
RECORD 3 Liberi, Lisa Chapter 7 Dismissal 20020807 Rancho Cucamonga 91739 9099830877 Case Number: Entity Type: Address: State: Attorney: Attorney Address: 0222845 Individual Record 11952 Huntley Dr Ca Curtis R Aijala 123 W B St # C
CIVIL RECORD VERIFICATION: CONFIRM CASE # 0222845 AT THE COURT HOUSE
Defendant:
Filing Type:
Filing Date:
City:
8 of 10
Exb. "A", pg. 16
Zip:
Attorney Phone:
4/11/2010 12:26 A
Customers are charged a search fee for executing a Civil Judgment check. The Civil Judgment report returns results which may include all civil judgment records or no results found on the individual.
In the event of using this service for civil background checks, you should not assume that this data provides a complete or accurate history of any person's civil judgment history.
You should use extreme caution when interpreting the results of a civil judgment background search for any type of personal verification.
Positive or false matches in civil searches may not provide confirmation of an individual's civil judgment background.
Please reference the updated Intelius User agreement for additional restrictions regarding the usage of data.
Current & Historical People Search Report

Previous Cities Avg. Income / Home Value
Name
Address History
What is a Current & Historical People Search Report?
Lisa Liberi Avg. Income: $50,047
Address 1: 7349 MILLIKEN 140 RANCHO CUCAMONGA, CA 91730 (909) 466-9532
Address 2: 1537 GRANDVIEW UPLAND, CA 91784 (909) 466-9532
Rancho Cucamonga, CA Upland, CA Santa Fe, NM
Property Report Avg. Home Value: $149,300
RELATIVES: Address 3: B Liberi 4 BONITO SANTA FE, NM 87508 (505) 466-2505
This section lists current and historical people search records that share the same name and state as your search subject. The People Search Summary can be helpful in providing a consolidated view of matching current and historical records for your subjects name across multiple public sources. Income & Home Value are compiled from property, demographic, census, & other public record sources. Income & Home Value may contain specific household and area statistics associated with an individual or address. Avg. Income: $70,461
Lisa Liberi
Address 1: 11952 HUNTLEY DR RANCHO CUCAMONGA, CA 91739
Rancho Cucamonga, CA Avg. Home Value: $180,200
9 of 10
Exb. "A", pg. 17
Property Report
4/11/2010 12:26 A
Background Information
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Background reports include, when available, a criminal and sex offender check, lawsuits, judgments, liens, bankruptcies, home value & property ownership, address history, phone numbers, relatives & associates, neighbors, marriage/divorce records and more.
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10 of 10
Exb. "A", pg. 18
4/11/2010 12:26 A
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19
EXHIBIT B
From: TalentWise <DoNotReply@intelius.com> Date: Sat, Apr 10, 2010 at 10:40 PM Subject: TalentWise Purchase Receipt - Order #30897630 To: lisaliberi@gmail.com
Lisa, thank you for placing your order with TalentWise. We received your order April 10, 2010 at 9:36 PM Pacific time. Order Summary for Order #30897630 1 Nationwide Employment Background Check Order Total: $59.95 $59.95
Your credit card statement will show a charge for $59.95 from INTELIUS SCREENING. Questions about your order? Our Customer Service team is available from 5:00 AM to 4:30 PM Pacific time, Monday through Friday. Phone: 1.866.338.6739 Fax: 1.877.974.6150 Email: customerservicesolutions@intelius.com Please do not attempt to reply to this email message, as your reply will not be received. For information about volume discounts and custom screening packages, please call our Sales team at (877) 893-1665 or email sales@intelius.com. To view your reports, visit your TalentWise Dashboard Portal.
TalentWise
TalentWise
2003-2010 Intelius, Inc.
Exb. "B", pg. 20
Applicant Report: Lisa Liberi - TalentWise
https://www.intelius.com/screening/report.php?ApplicantID=45747986&dist=1&printer=1
Intelius Screening Customer Service P.O. Box 1048
| Bothell, WA 98041-1048 (866) 338-6739 | customerservicesolutions@intelius.com
Per California Civil Code 1786, Intelius Screening Solutions does not guarantee the accuracy or truthfulness of the information in this report as to the person who is the subject of the investigation, only that the information is accurately copied from public records. Information generated as a result of identity theft, including evidence of criminal activity, may be inaccurately associated with the person who is the subject of the report.
APPLICANT REPORT: Lisa Liberi

Report Status: Request Submitted: Pending Apr 10, 2010 9:36 pm
Requested by:
Lisa Liberi
LisaLIberi
(505) 424-9055
Package Title:
Nationwide Employment Background Check
Applicant ID:
45747986
Applicant Name:
Lisa Liberi
Date of Birth:
5/28/1965
Address:
1704b Llano Street #159 Santa Fe, NM 87505
Memo:
APPLICANT REPORT CONTENTS
Liberi
COMPLETE STATUS
SSN Verification
Success Review Below Pending Clear
Address History
Criminal Database Search
Nationwide Sex Offender Registry Check
1
xxx-xx-4312 California 2000
SSN VERIFICATION
SSN
State of Issue
1 of 3
Exb. "B", pg. 21
Date of Issue
4/11/2010 12:40 A
Name Searched Success: Full name matches SSN. No AKAs were found for this applicant.
Lisa Liberi
AKA Results
ADDRESS HISTORY
This report shows addresses associated with the SSN searched. Addresses are usually, but not always, listed from most to least recent. 2983 PLAZA BLANCA SANTA FE, NM 87507 11952 HUNTLEY DR RANCHO CUCAMONGA, CA 91739 4 BONITO SANTA FE, NM 87508 PO BOX 548 RIBERA, NM 87560 1537 GRANDVIEW UPLAND, CA 91784 7349 MILLIKEN #140 RANCHO CUCAMONGA, CA 91730
Address 1
Address 2
Address 3
Address 4
Address 5
Address 6
Intelius obtains address history information from public records and other third-party sources. Intelius cannot guarantee that this information is accurate or current.
CRIMINAL DATABASE SEARCH
This component of the Applicant Report is still pending.
NATIONWIDE SEX OFFENDER REGISTRY CHECK

We have searched for the applicant in the sex offender registries of all 50 states, the District of Columbia, and Puerto Rico. Clear No records were found. Positive or false matches within a criminal search may not provide confirmation of a criminal background.
Search Description
Result
END OF REPORT
USERS OF THIS REPORT MUST COMPLY WITH THEIR OBLIGATIONS UNDER THE FAIR CREDIT REPORTING ACT:
http://www.ftc.gov/os/2004/11/041119factaapph.pdf
APPLICANTS MAY VIEW THEIR RIGHTS UNDER THE FAIR CREDIT REPORTING ACT:
2 of 3
Exb. "B", pg. 22
http://www.ftc.gov/bcp/edu/pubs/consumer/credit/cre35.pdf
4/11/2010 12:40 A
2003 - 2010 Intelius Screening Solutions DBA TalentWise
3 of 3
Exb. "B", pg. 23
4/11/2010 12:40 A
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24
EXHIBIT C
https://www.talentwise.com/screening/agreement.php?newaccount=1 Case 8:11-cv-00485-AG -AJW Document 389-2 Filed 09/24/11 Page 25 of 35 Page ID #:9190
Exb. "C", pg. 25
Terms and Conditions - TalentWise
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DUE TO THE SENSITIVE AND HIGHLY REGULATED NATURE OF THE DATA AND INFORMATION YOU AND YOUR ORGANIZATION WILL GAIN ACCESS TO THROUGH INTELIUS SCREENING SOLUTIONS LLC (d/b/a "TALENTWISE"), TALENTWISE WANTS TO ENSURE THAT YOU AND YOUR ORGANIZATION UNDERSTAND THEIR OBLIGATIONS REGARDING THEIR ACCESS TO AND USE OF TALENTWISE SERVICES AND AGREE TO COMPLY WITH THOSE OBLIGATIONS. BY CLICKING AND ACCEPTING, YOU AGREE THAT: 1. YOU ARE EMPLOYED BY YOUR ORGANIZATION AND ARE AUTHORIZED TO ENTER INTO THIS AGREEMENT WITH TALENTWISE, AND YOU UNDERSTAND THAT TALENTWISE IS RELYING ON THIS AUTHORIZATION; 2. YOU HAVE READ, UNDERSTOOD AND APPROVED THIS AGREEMENT AND YOUR ORGANIZATION'S OBLIGATIONS DESCRIBED HEREIN; YOU HAVE HAD AN OPPORTUNITY TO CONSULT WITH LEGAL COUNSEL AND OTHER EXPERTS OR ADVISORS AS DEEMED NECESSARY; AND, YOU HAVE HAD AMPLE OPPORTUNITY TO ASK QUESTIONS ABOUT THESE TERMS AND CONDITIONS; AND, 3. YOU WILL NOT ALLOW ANY PERSON TO ACCESS THE TALENTWISE SITE UNLESS THAT PERSON IS A BONA FIDE EMPLOYEE AND HAS REVIEWED, UNDERSTOOD AND AGREED IN WRITING TO BE BOUND BY THESE TERMS AND CONDITIONS. I accept the TalentWise Terms and Conditions
TalentWise FCRA Subscriber Agreement

PLEASE CAREFULLY READ THESE TERMS AND CONDITIONS BEFORE CLICKING THE "ACCEPT" BUTTON FOR THIS AGREEMENT. CLICKING AND ACCEPTING INDICATES THAT YOU HAVE THE AUTHORITY TO ENTER INTO THIS AGREEMENT ON BEHALF OF YOUR EMPLOYER ("YOU" OR "YOUR"), AND YOU AND YOUR EMPLOYER HAVE READ THIS AGREEMENT, UNDERSTAND IT, AND AGREE TO BE BOUND BY ITS TERMS AND CONDITIONS. For purposes of this Agreement only, you understand that Intelius Screening Solutions LLC (d/b/a "TalentWise") is a consumer reporting agency and provides consumer reports and investigative consumer reports ("Screening Reports") as defined by the Fair Credit Reporting Act ("FCRA"). TalentWise will furnish you with Screening Reports for employment background screening of applicants ("Applicant"), conditioned upon your compliance with this Agreement and fulfillment of all your obligations (including payment) under this Agreement (and any other agreements you and TalentWise may have). YOU UNDERSTAND THAT THE PROVISIONS IN THIS AGREEMENT (INCLUDING WARRANTY DISCLAIMERS AND LIMITATIONS ON LIABILITY) REPRESENT AN AGREED UPON PRICE-RISK ALLOCATION. TALENTWISE WOULD NOT BE ABLE TO OFFER YOU ITS CURRENT PRICING STRUCTURE BUT FOR THIS ALLOCATION. 1. You and your company shall:
I accept the terms and conditions of the TalentWise FCRA Subscriber Agreement
As an authorized representative of my Company, I accept the terms and conditions detailed above. Name Email Address
Company
Title
Please state your permissible purpose for accessing TalentWise services (examples: pre-employment screening, tenant screening, employee screening, etc.)
I Accept
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| 2003 - 2011 TalentWise Solutions LLC
Exb. "C", pg. 26

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9/20/2011 5:35 PM
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27
EXHIBIT D
Exb. "D", pg. 28
November 01, 2010 Intelius Consumer Affairs P.O. Box 808 Bothel, Washington 98041-0808
Sent via Priority Mail Delivery Confirmation required 0309 3220 0001 9214 5504 Three (3) pages total
Re:
My Intelius Report
To whom it may concern, I have purchased a copy of my report from your agency, which was run by my Social Security number. There is a lot of incorrect information you have on me under my Social Security number. Ironically, the incorrect and wrong information you maintain on me is the same as the incorrect information maintained by LexisNexis. Obviously, you pull my private information from LexisNexis for re-sale, which I have never authorized. The wrong information you maintain on me, that must be deleted immediately, includes but is not limited to: NAMES: - The following names have never been mine and have never been used by me: Liberi, Lisa A Courville-Richardson Lisa R Courvillerichar, Lisa R Courville, Lisa O. Corvillerichardson, Lisa Courviller, Lisa Courville, Richardson L Courville, Richardso L YEAR OF BIRTH: The following date of birth is not mine and has never been used by me: 1967 SOCIAL SECURITY NUMBERS The following Social Security numbers have never been mine and have never been used by me: 563-42-xxxx (CA: 1936-1951); 563-72-xxxx (CA: 1964) 1
Exb. "D", pg. 29
ADDRESSES: The following addresses are not mine and have never been used by me: 40 Bonito Ct Santa Fe, NM 87508-8311, 1704 Llano St Apt 159 Santa Fe, NM 87505-5415 1704 Llano St Ste B Santa Fe, NM 87505-5415 990 Cypress Station Dr Apt 303 Houston, Texas 77090-1546 6018 Spring Creek LN Spring, TX 77379-8805 8902 Arcadian Houston, Texas 77088 375 Bladwin PY Katy, TX 77449 13800 Ella Blvd. Apt A201 Houston, Texas 77014-3318 I am in need of a copy of my Intelius report from your company, which shows the information you maintain on me has been corrected and all person(s) or entities who have obtained my report in the last three (3) years. My correct information is as follows: Address for last five (5) years: Lisa Rene Liberi 2983 Plaza Blanca Santa Fe, NM 87507 (505) 473-9185 xxx-xx-4312 05/28/1965
Last 4 of SSN: Date of Birth
Exb. "D", pg. 30
Exb. "D", pg. 31
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32
EXHIBIT E
http://www.intelius.com/results.php?ReportType=8&qf=Lisa&qmi=&qn=Liberi&qa=&qtickler= Case 8:11-cv-00485-AG -AJW Document 389-2 Filed 09/24/11 Page 33 of 35 Page ID 1&qcs=NM&searchform=background&focusfirst=1#:9198
Exb. "E", pg. 33
Background Check & People Search Powered by Intelius
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Search results for Lisa Liberi in New Mexico

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We We We We We We We We searched Lisa Liberi and found 0 records in NM searched Alisa Liberi and found 0 records in NM searched Alissa Liberi and found 0 records in NM searched Elesa Liberi and found 0 records in NM searched Elisa Liberi and found 0 records in NM searched Elysa Liberi and found 0 records in NM searched Liza Liberi and found 0 records in NM searched Lisa Liberi and found 2 records nationwide
We found 2 people that match Lisa Liberi in New Mexico.
1.
Name/Aliases
Lisa M Liberi, age 53

Has lived in DOB Phone Address
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Related to
Lisa M Liberi L M Liberi Lisa M Mangan
Prospect Park, PA King Of Prussia, PA Norristown, PA Glenolden, PA
Mary E Mangan Gerald D Mangan
2.
Name/Aliases
Lisa Marie Liberi, age 33

Has lived in DOB Phone Address
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Related to
Lisa Marie Liberi Lisa Liberi Laws
Miami, FL Raleigh, NC Charlotte, NC Pittsburgh, PA
Grace Mary Laws Fred R Laws Diane Marie Laws Christina L Joseph Jennifer Grace Barker
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Exb. "E", pg. 34

1 of 2
9/20/2011 5:24 PM
Background Check & People Search Powered by Intelius
http://www.intelius.com/results.php?ReportType=8&qf=Lisa&qmi=&qn=...
Exb. "E", pg. 35

2 of 2
9/20/2011 5:24 PM
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Attorney for Plaintiffs
UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION : : : Plaintiffs, : : : : : : : : : : Defendants. : : : :
LISA LIBERI, et al,
CIVIL ACTION NUMBER: 8:11-cv-00485-AG (AJW) DECLARATION OF LISA OSTELLA Date of Hearing: October 17, 2011 Time of Hearing: 10:00 a.m. Location: Courtroom 10D
vs.
ORLY TAITZ, et al,
Declaration of Lisa Ostella I, Lisa Ostella, am over the age of 18 and am a party to the within action. I have personal knowledge of the facts herein, and if called to do, I could and would competently testify. I am making this Declaration under the penalty of perjury of the Laws of the United States pursuant to 28 U.S.C. 1746. 1. I am shocked, appalled and mortified with the unprofessional actions
of Intelius and their law firm, Jones Day.

1
Declaration of Lisa Ostella
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2.
As per the advice of a law firm, I submitted a professional request for
data I was entitled to about searches that had been conducted on me. My reports were important as they contained incorrect information about me and I wanted to properly dispute it. 3. I took the required actions of making law enforcement reports,
because of the Reed Defendants and Defendant Intelius breach of my private information to the Defendants in this suit. I wrote to Intelius and provided the necessary data per the FCRA [Fair Credit Reporting Act] requirements of receiving my Intelius Reports and who had conducted searches on me. 4. My letter stated in a professional fashion why the data was requested.
I supplied further confidential information, including the Federal Bureau of Investigation (FBI) Agents name of who I was working with, law enforcement report numbers, my new home address, and other private data demanded by Intelius in order for me to obtain my reports. 5. Yet, with no other reason I can fathom but for malicious reasons,
Intelius and Jones Day filed my letters unredacted. Jones Day comes to the table of this case with a high reputation of professionalism. performed with a school yard bully mentality. 6. Intelius was brought into this suit by actions and statements of the Yet, they have just
Defendants Taitz and Sankey. Taitz and Sankey have published every bit of
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private identifying information about me, that they obtained from the Reed Defendants and Intelius. 7. And, Intelius and their Attorneys with Jones Day do not have the
required, procedural decency to redact personal identifying information in a correspondence I was required procedurally to make. Intelius and their Attorneys with Jones Day's unprofessional, nonprocedural actions have left me overwhelmed with disbelief. 8. Contrary to the statements made in Intelius's Motion to Dismiss
(MTD), I was a customer since December 2008. See my account details attached hereto as EXHIBIT 1. 9. After Intelius was put on notice that their databases and terms and
conditions of use were being violated by their clients, they deleted my account. I attempted to access my account in September 2011, but my account had been deleted by Intelius. With the deletion of my account, Intelius also erased all searches I had conducted. 10. Contrary to Intelius's statements, searches were run on me, my
husband and my children. Neil Sankey stated multiple times he ran searches on me using Intelius as outlined in our First Amended Complaint (FAC).
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11.
Orly Taitz gave sworn testimony to the Orange County Sheriffs
Department she had searches run on me. See Exhibit 16 filed May 20, 2011, Docket No. (DN) 190-4, and in Court filings located in the dockets in this case. 12. I, myself, ran searches on me under my maiden name and my married
name. See EXHIBIT 2. 13. According to Intelius own Terms and Conditions filed as Exhibit
4 of Benjamin Nelsons Declaration, Intelius was required to notify authorities of the misuse by Orly Taitz and Neil Sankey. See Intelius's MTD Docket #380-7 Exhibit 4 paragraph 5 user agreement about contacting authorities for notification of abuse. However, Intelius chose to delete account data instead. 14. Mr. Nelson states in his Declaration that only public information is
provided. As shown by my EXHIBIT 2, my Social Security number appears on my report and my report is specific to me, contrary to Mr. Nelson and Intelius statements that searches are only generic. 15. Mr. Nelson and Intelius also stated they are not consumer reporting
agencies bound by the Fair Credit Reporting Act (FCRA). I was conducting searches with the United States Security Exchange (SEC) and located Intelius Form S-1 dated October 19, 2009 at the SECs website at
http://ipo.nasdaq.com/edgar_conv_html%5C2009%5C10%5C19%5C000095012309-051082.html. Intelius states on pages 24 and 25 in their report to the SEC:
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Because we use personal information in providing our information services, we are subject to government regulation and vulnerable to adverse publicity. We provide many types of data and services that already are subject to regulation under the FCRA, Gramm-LeachBliley Act, Drivers Privacy Protection Act and, to a lesser extent, various other federal, state and local laws and regulations. Violation of these laws or regulations may result in substantial fines, judgments and other penalties. These laws and regulations are designed to protect the privacy of the public and to prevent the misuse of personal information in the marketplace.
16.
Also during my searches, I came across Intelius enterprise agreement
at http://www.intelius.com/enterpriseagreement.php. In this agreement, Intelius states numerous times they are a consumer reporting agency government by the FCRA. 17. Intelius also has that they are a consumer reporting agency in their
Security and compliance located at http://www.intelius.com/corp/security which states: Intelius recognizes the sensitivity surrounding many of its applications and the data they rely on. As such, Intelius' information security policy addresses security at all levels: personnel, technology and operations. Intelius is a certified credit reporting agency. 18. In Intelius TalentWise Agreement located at:
https://www.talentwise.com/terms.html, Intelius states:
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DUE TO THE SENSITIVE AND HIGHLY REGULATED NATURE OF THE DATA AND INFORMATION YOU AND YOUR ORGANIZATION WILL GAIN ACCESS TO THROUGH INTELIUS SCREENING SOLUTIONS LLC (d/b/a "TALENTWISE") Intelius Screening Solutions LLC (d/b/a "TalentWise") is a consumer reporting agency and provides consumer reports and investigative consumer reports ("Screening Reports") as defined by the Fair Credit Reporting Act ("FCRA") 19. As can be seen by my attached report, my report contains my Social
Security number and Social Security numbers are not public information or general information for those who share the same name. 20. Mr. Nelson states I was sent a letter in December 2010 informing me
that I would need a Subpoena or Court Order to obtain the individuals who performed searches on me. To date, I have never received a letter from Intelius. And, if a Subpoena or Court Order is required, why did Intelius and Mr. Nelson offer account details pertaining to me and Lisa Liberi ?
I declare under the penalty of perjury of the Laws of the United States and the State of California that the foregoing is true and correct.
Executed this 23rd day of September, 2011 in the State of New Jersey.
Lisa Ostella, Declarant
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EXHIBIT 1
Member Status: Basic lisaostella@hotmail.com [ Sign Out] | My Intelius Help: (888) 445-2727 | View My Reports
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My Intelius
Reports Purchases Account Club Intelius Alerts Help Review your Intelius customer account profile on this secure page. Update payment info, change your pasword, edit your billing address and more below.
Account
Personal Profile
Email Address: lisaostella@hotmail.com Name: Lisa Ostella Company: Member Since: 12-29-2008 Address: 622 Remsen Avenue North Brunswick, NJ 08902
Exb. "1", pg. 8
08902 Phone: (732) 846-2875
Personal Profile
Email Address lisaostella@hotmail.comFirst Name Last Name Phone Number Optional
Company Optional
Address City State Country Zip Code
Edit Personal Profile
Payment Info
Pay By: Credit Card Cardholder Name: Lisa Ostella CC Number: XXXXXXXXXXXX5031 CC Expiration: 08-2009 Billing Address: 622 Remsen Avenue North Brunswick, NJ 08902 United States
Payment Info
Exb. "1", pg. 9
Pay By Cardholder Name First and last name as shown on card
Billing Address Billing City Billing State Billing Zip/Postal Code Billing Country Credit Card Number No spaces or punctuation Credit Card Expiration We accept Visa, MasterCard, Card Security Code (CVV) Discover and American Express What is this? Edit Payment Info
User Preferences
Subscribe to newsletter: Yes | No
Please send me exclusive discounts, coupons, and updates via the e-newsletter.
User Preferences
Change Password
Change Password
Old / Temporary Password
Exb. "1", pg. 10
New Password
Must be at least 8 characters and contain a letter and a number
Re-type New Password Type password again to verify
Change Password Bookmark Intelius | Help | About | Careers | Privacy | Contact Us | FAQ | Terms & Conditions | Site Map | Affiliates | Directory | Volume Discounts 2003-2010 Intelius, Inc.
Exb. "1", pg. 11
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EXHIBIT 2
12
Sign In My Intelius View My Reports
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Background Report
Learn more about SSN XXX-XX-2308 & Last Name Ostella with a comprehensive Background Report.
LOCATIONS FOR OSTELLA: RELATIVES OF 2 Addresses in North Brunswick, NJOSTELLA: 1 Address in Belleville, NJ 3 Relatives found 1 Address in Elizabeth City, NC Report includes: (when available) Statewide Criminal Check Sex Offender Check Bankruptcies & Liens Small Claims & Judgments Address History Relatives & Roommates Neighbors Home Value & Details Neighborhood Info Satellite & Map Images Alias Names Much more... View Sample Regular Price
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Exb. "2", pg. 13
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Philip J. Berg, Esquire (PA I.D. 9867) E-mail: philjberg@gmail.com LAW OFFICES OF PHILIP J. BERG 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Telephone: (610) 825-3134 Fax: (610) 834-7659 Attorney in pro se and for Plaintiffs UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION LISA LIBERI, et al, vs. ORLY TAITZ, et al, : : : Plaintiffs, : : : : : : Defendants. : :
CIVIL ACTION NUMBER: 8:11-cv-00485-AG (AJW) PLAINTIFFS CERTIFICATE OF SERVICE
I, Philip J. Berg, Esquire, hereby certify a true and correct copy of Plaintiffs
Objections/Opposition; Declarations of Philip J. Berg, Esquire; Lisa Ostella; Lisa Liberi; and Certificate of Service to Defendant Intelius, Inc.s Request for Judicial Notice were served through the ECF filing system this 24th day of September 2011 upon the following:
Orly Taitz 29839 Santa Margarita Parkway, Suite 100 Rancho Santa Margarita, CA 92688 Email: orly.taitz@gmail.com and Email: dr_taitz@yahoo.com Served via the ECF Filing System Attorney for Defendant Defend our Freedoms Foundation, Inc.
Liberi, et al Plaintiffs Cert of Svc re Objections/Opposition to Intelius Req. For Judicial Notice
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Kim Schumann, Esquire Jeffrey P. Cunningham, Esquire Peter Cook, Esquire SCHUMANN, RALLO & ROSENBERG, LLP 3100 Bristol Street, Suite 400 Costa Mesa, CA 92626 Email: pcookA@srrlawfirm.com Served via the ECF Filing System Attorney for Defendants Orly Taitz; Orly Taitz, Inc.; and Law Offices of Orly Taitz James F McCabe Morrison & Foerster 425 Market St San Francisco, CA 94105-2482 Email: jmccabe@mofo.com Served via the ECF Filing System Attorney for Defendants: Reed Elsevier, Inc. LexisNexis Group, Inc LexisNexis, Inc. LexisNexis Risk and Information Analytics Group, Inc. LexisNexis Risk Solutions, Inc. LexisNexis Seisint, Inc. LexisNexis Choicepoint, Inc. John A Vogt, Jr., Esquire Edward San Chang, Esquire Jones Day 3161 Michelson Drive Suite 800 Irvine, CA 92612 Email: javogt@jonesday.com Email: echang@jonesday.com Served via the ECF Filing System Attorney for Defendant Intelius, Inc.
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Marc Steven Colen, Esq. Law Offices of Marc Steven Colen 5737 Kanan Road, Ste. 347 Agoura Hills, CA 91301 Email: mcolen@colenlaw.com Served via the ECF Filing System Attorney for Defendants: Neil Sankey; Todd Sankey; Sankey Investigations, Inc. and The Sankey Firm, Inc. Michael J Niborski, Esquire Pryor Cashman LLP 1801 Century Park East 24th Floor Los Angeles, CA 90067 Email: mniborski@pryorcashman.com Attorney for Daylight Chemical Information Systems, Inc.
/s/ Philip J. Berg Philip J. Berg, Esquire

Liberi V Taitz Objections and Opp To Intelius Req For Judicial Notice Doc 389

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Case 8:11-cv-00485-AG -AJW Document 389 #:9154

Filed 09/24/11 Page 1 of 6 Page ID

Attorney in pro se and for Plaintiffs

LISA LIBERI, et al,

vs. ORLY TAITZ, et al,

Case 8:11-cv-00485-AG -AJW Document 389 #:9155

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Case 8:11-cv-00485-AG -AJW Document 389 #:9156

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Case 8:11-cv-00485-AG -AJW Document 389 #:9157

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Case 8:11-cv-00485-AG -AJW Document 389 #:9158

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Case 8:11-cv-00485-AG -AJW Document 389 #:9159

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For the reasons outlined herein, Plaintiffs respectfully Request this

Dated: September 23, 2011

/s/ Philip J. Berg Philip J. Berg, Esquire Pennsylvania I.D. 9867

Case 8:11-cv-00485-AG -AJW Document 389-1 #:9160

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vs. ORLY TAITZ, et al,

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

Declaration of Philip J. Berg, Esquire

Case 8:11-cv-00485-AG -AJW Document 389-1 #:9161

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Case 8:11-cv-00485-AG -AJW Document 389-1 #:9162

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Declaration of Philip J. Berg, Esquire

Case 8:11-cv-00485-AG -AJW Document 389-1 #:9163

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Declaration of Philip J. Berg, Esquire

Case 8:11-cv-00485-AG -AJW Document 389-1 #:9164

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

Declaration of Philip J. Berg, Esquire

Case 8:11-cv-00485-AG -AJW Document 389-1 #:9165

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Declaration of Philip J. Berg, Esquire

Case 8:11-cv-00485-AG -AJW Document 389-2 #:9166

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Attorney for Plaintiffs

vs. ORLY TAITZ, et al,

Case 8:11-cv-00485-AG -AJW Document 389-2 #:9167

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Case 8:11-cv-00485-AG -AJW Document 389-2 #:9168

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Declaration of Lisa Liberi

Case 8:11-cv-00485-AG -AJW Document 389-2 #:9169

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Declaration of Lisa Liberi

Case 8:11-cv-00485-AG -AJW Document 389-2 #:9170

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Declaration of Lisa Liberi

Case 8:11-cv-00485-AG -AJW Document 389-2 #:9171

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Lisa Liberi, Declarant

Declaration of Lisa Liberi

Case 8:11-cv-00485-AG -AJW Document 389-2 #:9172

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Case 8:11-cv-00485-AG -AJW Document 389-2 #:9173

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