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On Appeal Irom the United States District Court,
Central District oI CaliIornia, Southern Division
Case No. 8:11-cv-00485
Honorable Andrew GuilIord
Philip J. Berg, Esquire (PA Bar No. 09867)

555 Andorra Glen Court, Suite 12
LaIayette Hill, PA 19444-2531
Ph: (610) 825-3134
Fax: (610) 834-7659

I, Philip J. Berg, Esquire, am over the age oI 18 and am a party to the within
action. I have personal knowledge oI the Iacts herein, and iI called to do, I could
and would competently testiIy. I am making this Declaration under the penalty oI
perjury oI the Laws oI 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 oI Pennsylvania. I am licensed to practice in the U.S. District
Courts, Middle and Eastern District oI Pennsylvania; Third Circuit Court oI
Appeals; the Pennsylvania Supreme Court; and the U.S. Supreme Court. And, I am
the Attorney oI Record Ior all the Appellees/PlaintiIIs in this case.
2. On or about February 24, 2011, Orly Taitz contacted Marcee Sloan,
hearing Coordinator Ior the Disciplinary Board oI the Pennsylvania Supreme Court
and Ialsely led Ms. Sloan to believe that she (Orly Taitz) was calling on behalI oI
Federal Judge Andrew J. GuilIord and the U.S.D.C., Central District oI CaliIornia,
Southern Division, seeking conIidential records in a disciplinary hearing regarding
3. Based on Orly Taitzs Ialse assertions, Marcee Sloan, provided the
documents, including Mr. Bergs Answer which contained sensitive, private
inIormation pertaining to his client.

4. Orly Taitz Iiled all these documents in the District Court and
published them all over her website at:;
Petition-Ior-Discipline.pdI; /uploads/2011/03/img-224145617-
5. AIter Iinding Orly Taitzs website postings oI conIidential
documentation she obtained Irom Marcee Sloan, I contacted Marcee Sloan and
veriIied the above inIormation, including Orly Taitzs Iraudulent and deceptive
practices oI misrepresenting herselI claiming to represent the U.S. District Court
and Judge GuilIord.
6. Orly Taitz also Iiled these documents with the Santa Fe Probation
Department; San Bernardino County Probation Department; San Bernardino
County District Attorneys OIIice; Santa Fe Police Department; and in the San
Bernardino County Superior Court, Rancho Cucamonga Division, Case No. FWV-
028000 when Orly Taitz Iiled an Emergency Revocation oI Probation against

Appellee Lisa Liberi attempting to have Mrs. Liberi Ialsely arrested on Taitzs
Ialse allegations (malicious prosecution and abuse oI process).
7. On April 19, 2012 at approximately 11:18 p.m. PaciIic Standard
Time, Orly Taitz, Esquire Iiled a secondary 'Consolidated Reply BrieI, in case 11-
56164, knowing her attorney, JeIIrey Cunningham had Iiled their 'Consolidated
Reply BrieI in Case No. 11-56079, DNs 40-1 and 40-2, earlier that evening and in
violation oI Commissioner Shaws February 3, 2012 Order. Orly Taitz secondary
Consolidated Reply BrieI Iiled in Case No. 11-56164, DN 35-1, included three |3|
Exhibits, DNs 35-2; 35-3; and 35-4. Orly Taitz Exhibits on behalI oI DOFF
Exhibit '1, DN 35-2 A report Irom a 'supposed private investigator
who Taitz hired to attend my hearing
Exhibit '2, DN 35-3 - Petition Ior Discipline; and
Exhibit '3, DN 35-4 - My Response to the Petition Ior Discipline
containing conIidential inIormation as to my client
that is not oI public record.
8. These documents are all hearsay documents; have no relevance in
these Appeals; Orly Taitz has twisted and Iabricated what the documents state and
were only Iiled by Orly Taitz, abusing the Courts process, to attempt to lend
Taitz has hired Iour (4) diIIerent private investigation Iirms, that we are aware oI, to obtain the
Appellees private data, credit reports, Iinancial reports; to watch, surveil and Iollow the
Appellees, in Iurtherance oI her harassment and stalking oI the Appellees and their Iamilies.

credibility to her Ialse statements against me and the other Appellees to her
supporters and Iollowers; to harass me and the other Appellees; to cause me harm;
to Ialsely accuse Appellee Lisa Liberi oI Ialse crimes; and to prejudice this Court
against me and the other Appellees. Just like in February 2011, on April 20, 2012,
Orly Taitz published her April 19, 2012 Iiling in this Court all over the Internet,
sent it through thousands oI RSS Ieeds; posted them on Social Networks, including
but limited to:;;;;;;;
Court-oI-PA;; and
9. The above website and Internet postings by Orly Taitz were easy to
locate with a simple search in Google. I went to each web link above and
downloaded the documents, along with taking screen shots (computer pictures).
Attached hereto as is a true and correct copy oI Orly Taitzs
website showing all documents listed and available Ior download: Taitz Reply
BrieI on behalI oI DOFF Iiled in Case NO. 11-56164, Exhibits '1, '2 and '3;
and Taitz Consolidated Reply BrieI Iiled by her attorney JeIIrey Cunningham in
Case No. 11-56079, under the heading 'Filed Yesterday, with links to all Iour sets
oI documents. Attached as is a true and correct copy and a screen
shot oI JeIIrey Cunninghams Consolidated Reply BrieI Iiled in Case No. 11-
56079 DN 40-1; Attached as is a true and correct copy, along with
a screen shot, oI Orly Taitz on behalI oI DOFFs Consolidated Reply BrieI Iiled in
Case No. 11-56164, DN 35-1; attached as is a true and correct copy

oI the report Taitz obtained Irom a 'supposed private investigator Iiled in this
case as DN 35-2; attached as is a true and correct copy and a
screen shot oI the Petition Ior Discipline Iiled in this case as DN 35-3. I also
downloaded and took a screen shot oI my answer to the Disciplinary Petition
obtained by Orly Taitz by Iraudulent means and deceptive practices, and that
contains private inIormation as to my client, Iiled in this case as DN 35-4. All oI
which Orly Taitz posted on her website; I have put the link to Orly Taitzs website
and social networks sites above, but due to the conIidentiality oI these documents,
I have attached them as an Exhibit.
10. Orly Taitz, Esquire has a history oI Iiling Iraudulently obtained
documents; Iorged and altered documents; perjured statements, etc. in our Courts.
Taitz, counsel Ior DOFF, has a history oI obtaining documents by Iraudulent
means and Iiling manuIactured, altered and Iorged documents as genuine, in our
Federal Courts, see , 670 F. Supp. 2d 1363 (M.D. Ga. 2009)
(imposing $20,000 sanctions on counsel Orly Taitz Ior use oI the legal process Ior
an improper purpose), aIId , 2010 U.S. App. LEXIS 5340
Cir. Mar. 15, 2010); , U.S.D.C., Central District oI
CaliIornia, Southern Division, Case No. 8:11-cv-00485 AJG ($250.00 Sanctions
Ior Iailing to abide by the Courts June 14, 2011 Order, DN 227);
, U.S.D.C., Central District oI CA, Southern Div., Case No. 09-cv-

00082 DOC (ManuIactured/Iorged Kenya Birth CertiIicate, Docket No. 55-3 Iiled
Sept. 4, 2009 and CertiIied copy oI Kenya Registration oI Birth, Docket No. 34-2
Iiled August 1, 2009 bearing President Barack Obamas name);
, U.S.D.C., Southern District oI Florida, Case No. 9:09-cv-81255-WPD,
Docket No. 55-1 Iiled January 26, 2010 (ManuIactured, altered and Iorged website
pages; subpoenas and emails Iiled as genuine by Taitz); and
, U.S.D.C., District oI Columbia, Case No. 11-402, Docket No. 39, October
17, 2011, Opinion oI Judge Lamberth, page 3, In 2 and Docket No. 33 Iiled August
30, 2011 Opinion oI Judge Lamberth, pages 7-8, In 4 (Iraudulently obtained
Selective Service Record oI President Obama and a veriIication oI President
Obamas Social Security number obtained in violation oI our Federal Laws,
through the Social Security E-VeriIy).
11. These Exhibits Iiled by Orly Taitz are irrelevant and as stated above,
only Iiled in this Court to harass me and the other Appellees who I represent; to
harm my clientele that have nothing to do with this case; cause harm to me and my
practice; to bully Appellee Lisa Liberi and accuse her oI additional Ialse crimes; to
arouse the emotions oI her supporters and Iollowers against the Appellees; and to
prejudice this Court against the Appellees.

I declare under the penalty oI perjury oI the Laws oI the United States and
CaliIornia that the Ioregoing is true and correct.
Executed this 24
day oI April, 2012 in the Commonwealth oI Pennsylvania,
County oI Montgomery.
/s/ Philip J. Berg
Philip J. Berg, Esquire, Declarant