LIBERI V TAITZ (E.D. PA) - 1 - COMPLAINT - Gov - Uscourts.paed.302150.1.0

ER
Case 2:09-cv-01898-ER Document 1 Filed 05/04/09 Page 1 of 45
~'7.:;-O Law Offices of

PHILIP J. BERG, ESQUIRE
555 Andorra Glen Court, Suite 12
Lafayette Hill, P A 19444-2531 Attorney for: Plaintiffs
Identification No. 09867
(610) 825-3134
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
09 1898
LISA UBERI
and CIVIL ACTION NO.
PHILIP J. BERG, ESQUIRE

and
JURY TRIAL DEMANDED
THE LAW OFF1CES OF PHILIP J. BERG

and
EVELYN ADAMS a/k/a MOMMA E
and
LISA M. OSTELLA
and
GO EXCEL GLOBAL
Plaintiffs, :
vs.
ORL Y T AITZ, a/k/a DR. ORL Y TAITZ, a/k/a :

LAW OFFICES OF ORLY TAITZ; a/k/a
WWW.ORLYTAITZESQ.COM a/k/a
WWW.REPUBX.COM a/k/a ORLY TAITZ,
INC.
and
DEFEND OUR FREEDOMS
FOUNDAnONS, INC.
and
YOSEFTAITZ
and
THE SANKEY FIRM
and
SANKEY INVESTIGA TlONS, INC.
and
NElL SANKEY
and
JAMES SUNDQUIST
and
ROCK SALT PUBLISHING
1:\FOR1vlS\Liberi, Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages
and
LINDA SUE BELCHER a/k/a LINDA S.
BELCHER alk/a LINDA STARR; alkla
NEWWOMENSPARTYa/kia
STITCHENWITCH alk/a EVA BRAUN alk/a .
WEB SERGEANT alk/a KATY alk/a .
WWW.OBAMACITIZENSHIPDEBATE.ORG
and
EDGAR HALE alk/a JD SMITH;
and
CAREN HALE;
and
PLAINS RADIO NETWORK, a/ka PLAINS
RADIO NETWORK, INC. a/k/a PLAINS
RADIO;
and
BARH FARMS;
and
KPRN AM 1610;
and
DOES 1 through 200 Inclusive,
Defendants. :
PLAINTIFFS COMPLAINT
I. PRELIMINARY STATEMENT
NOW COMES, Lisa Liberi, Philip J. Berg, Esquire, the Law Offices of Philip 1. Berg,
Evelyn Adams alk/a MommaE, Lisa M. Ostella and Go Excel Global, Plaintiffs by and through
the undersigned counsel and brings this Complaint seeking injunctive relief and damages against
the Defendants, Orly Taitz alk/a Dr. Orly Taitz alkla Law Offices of Orly Taitz alk/a Orly Taitz,
Inc; Defend our Freedoms Foundation; Yosef Taitz; Neil Sankey; The Sankey Firm, Sankey,
Sankey Investigations, Inc., James Sundquist; Rock Salt Publishing; Linda Sue Belcher aIkIa
Linda S. Belcher a/k/a Linda Starr alk/a Newwomensparty alk/a Stitchenwitch alkla Eva Braun
alkJa Web Sergeant a/k/a Katy a.lkla www.ohamacttizenshiptiehate.m:g; Edgar (Ed) Hale alkla
JD Smith; Caren Hale; Bar H Farms; Plains Radio Network, Inc. alkJa Plains Radio; and KPRN
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2
AM 1610; individually and collectively, for their illegal acts against the Plaintiffs, their staff and
their businesses. This is a case that sets fC111h the facts that Defendants, Orly Taitz alk:/a Law
Offices of Orly Taitz alkla Orly Taitz, Inc., Defend our Freedoms Foundation, Inc., The Sankey
Finn, Sankey Investigations, Inc., and Neil Sankey, have sent Plaintiff Lisa Liberi's Social
Security number and personal data via e-mail in mass mailings, media groups, internationally
and to 1000's of undisclosed recipients, requesting the infonnation to be posted on websites
across the internet and have been harassing Plaintiff Lisa Liberi, Philip J. Berg, Esquire and the
Law Offices of Philip J. Berg. Defendants James Sundquist and Rock Salt Publishing have sent
mass e-mailing with Lisa Ostella's home address, phone number and maiden name through the
internet to an unknown number of undisclosed recipients slandering and harassing Lisa Ostella
and her family and have filed falsified police and law enforcement reports against Lisa Ostella
regarding supposed "hacking" of Defendant Orly Taitz, et al websites and PayPal accounts. Lisa
Liberi and her husband were also accused of "hacking" and tampering with Defendant Or1y
Taitz's website and PayPal accounts. Defendants' are well aware it is Orly Taitz, et al who has
placed JS Kit software which is a "tracking" and "hacking" software on her Defend our
Freedoms Foundation, Inc. websites and blogs in order to "track" and "hack" individuals and
their computers who have visited her websites. Defendant Yosef Taitz has a server in Orly Taitz,
et al and his home in order to complete their illegal activities. Defendants' have been slandering
Plaintiffs herein, their staff and their businesses; posting libel regarding the Plaintiffs, their staff
and their businesses on the internet and through mass maiJings on the internet; and harassing the
Plaintiffs, their staff and their businesses. Detendants DOES 1 through 200 are Defendants
internet providers, phone companies, e-mail providers, streamlines and unknown Defendants
who have allowed Defendants', Orly Taitz alk/a Dr. Orly Taitz a/k/a Law Offices of Orly Taitz
alk/a Orly Taitz, Inc., Defendant our Freedoms Foundation, Inc., The Sankey Finn, Sankey
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3
Investigations, Inc., Neil Sankey; Linda Sue Belcher alk/a Linda S. Belcher alkla Linda Starr
alk/a Newwomensparty a/k/a Stitchenwitch alk/a Eva Braun aIk/a Web Sergeant alkla Katy aIk/a
www.obamacitizenshipdebate.org, Plains Radio Network alk/a Plains Radio Network, Inc. aIkIa
Plains Radio and Mr. and Mrs. Hale, to continue their illegal and dangerous behaviors against
Plaintiffs, their staff and their businesses. As a result, Plaintiffs, their staff and their businesses
have been severely damaged as outlined herein.
II. JURISDICTION AND VENU:f~
1. This case involves diversity of citizenship and this Court has jurisdiction pursuant
to 28 U.S.c. § 1332(a).
2. This case further arises under the Constitution and laws of the United States and
presents a federal question within this Court's jurisdiction under Article III of the
Constitution and 28 U.S.C. § 1331.
3. Venue is proper in this Court under 28 U.S.c. § 139l(b).
III. PARTIES
4. Plaintiff, Lisa Liberi [hereinafter "Liberi"] is an adult individual with a business
address of 555 Andorra Glen COUli, Suite 12, Lafayette Hill, PA 19444-2531;
5. Plaintiff, Philip J. Berg, Esquire [hereinafter at times "Berg"] is an adult
individual with a business address of 555 Andorra Glen Court, Suite 12, Lafayette
Hill, P A 19444-2531;
6. Plaintiff, The Law Offices of Philip J. Berg is a law firm, with a staff, owned and
operated by Plaintiff PhiJip J. Berg, with a business address of 555 Andorra Glen
Court, Suite 12, Lafayette Hill, PA 19444-2531;
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4
7. Plaintiff: Evelyn Adams [hereinafter at times "Adams"] is an adult individual with
a residential address of Route 1, Box 106 BB, Wynnewood, Oklahoma 73098;
8. Plaintiff, Lisa M. Ostella [hereinafter "Ostella"] is an adult individual with a
residential address of2227 US Highway 1, #245, North Brunswick, NJ 08902-4402.
9. Plaintiff Go Excel Global is a Web Communications company owned and
operated by Lisa M. Ostella with a business address of 2227 US Highway], #245,
North Brunswick, NJ 08902-4402;
10. Defendant, Orly Taitz a/k/a Dr. Orly Taitz a/k/a Law Offices ofOrty Taitz, aIkIa
WWW.ORLYTAr(ZESQ.COM alk/a WWW.REPUBX.COM a/k/a orty Taitz, [nco
[hereinafter "Taitz"] is a licensed Attomey with a business addresses of 26302 La
Paz, Suite 211, Mission Viejo, CA 92691 and 29839 S. Margarita Pkwy, Rancho
Santa Margarita, CA 92688, and a home address of 31912 Monarch Crest, Laguna
Niguel, CA 92677;
11. Defendant, Defend our Freedoms Foundation, [nco is incorporated as a non-profit
organization owned and operated by Defendant Orly Taitz a/k/a Dr. Orly Taitz a/k/a
Law Offices of Orly Taitz with a business address of 26302 La Paz, Suite 211,
Mission Viejo, CA 92691;
12. Defendant Y osef Taitz [hereinafter "Yosef'] is an adult individual with a home
address of 31912 Monarch Crest, Laguna Niguel, CA 92677;
13. Defendant, The Sankey Film [hereinafter "Sankey Firm"] is owned and operated
by Neil Sankey. The Sankey Finn has a business address of 2470 Steams Street,
# 162, Simi Valley, Califomia, 93063 and Post Office Box 8298, Mission Hi11s,
Califomia 91346;
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14. Defendant Sankey Investigations, Inc. is incorporated in the State of California.
Sankey Investigations, Inc. is owned and operated by Neil Sankey and is a private
investigation Company. Sankey Investigations has a business address of Post Office
Box 8298, Mission Hills, California 91346 and 2470 Stearns Street, #162, Simi
Valley, California, 93063;
15. Defendant, Neil Sankey [hereinafter "Sankey"] is an adult individual and owner
of The Sankey Firm and with an business address of 2470 Stearns Street, #162, Simi
Valley, California, 93063 and Post Office Box 8298, Mission Hills, California 91346;
16. Defendant James Sundquist [hereinafter "Sundquist"]~ is an adult individual,
owner and operator as Director of Defendant Rock Salt Publishing, with a business
address of 55) Valley Road, Suite 123, Upper Montclair, New Jersey 07043;
17. Defendant Rock Salt Publishing [hereinafter "Rock Salt"] is a company owned
and operated by James Sundquist, as Director with a business address of 551 Valley
Road, Suite 123, Upper Montclair, New Jersey 07043;
18. Detendant, Linda Sue Belcher a/k/a Linda S. Belcher alk/a Linda Starr a/k/a
Newwomensparty alkla Stitchenwitch alk/a Eva Brau a/k/a Web Sergeant alk/a
www.obamacitzenshipdebate.org [hereinafter "Linda"] is an adult individual with a
home address of20 1 Paris Street, Castroville, Texas 78009-4516;
19. Defendant Edgar (Ed) Hale [hereinafter at times "Mr. Hale"] is an adult individual
with a residential and business address of 1401 Bowie Street, Wellington, Texas
79095;
20. Defendant Caren Hale [hereinafter at times "Mrs. Hale"] is an adult individual
with a residential and business address of 1401 Bowie Street, Wellington, Texas
79095;
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21. Defendant, Plains Radio Network a/k/a Plains Radio Network, Inc. a/k/a Plains
Radio,] hereinafter at times "Plains Radio"] is a business and owned and operated by
Defendants Edgar (Ed) and Caren Hale with a principal address of 1401 Bowie Street,
Wellington, Texas 79095;
22. Defendant, Bar H. Fanns [hereinafter at times "Bar H" is a business owned and
operated by Defendants Edgar (Ed) and Caren Hale with a principal address of 1401
Bowie Street Wellin!:,11:on, Texas 79095;
23. Defendant, KPRN AM 1610 [hereinafter "KPRN"] is a business owned and
operated by Defendants, Edgar (Ed) and Caren Hale with a principal address of 1401
Bowie Street, Wellington, Texas 79095; and
24. Defendants, DOES I through 200 are unknown Defendants who provide the
internet access, streaming, e-mail, broadcasting, etc., for Plains Radio, KPRN, Bar H
Fanns and Mr. and Mrs. Hale.
IV. FACTUAL ALLEGATIONS RELATING TO ORLY TAITZ alkla

DR. ORLY TAlTZ alkla LAW OFFICES OF ORLY TAITZ alkla
WWW.ORLYTAITZESQ.COM alkla WWW.REPlJBX.COM alkla
ORLY TAITZ, INC., DEFEND OUR FREEDOMS FOUNDATION,
INC. and YOSEF TAITZ
25. 1n or about November 2008, the name orty Taitz appeared as filing legal
complaints in Sacramento, California on behalf of Alan Keyes and other Plaintiffs
and against the Calitornia Secretary of State and other Defendants regarding the
Ban'y Soetoro a/k/a Barack H. Obama citizenship issues'. Ironically, Taitz
I Ambassador Dr. A/an K!!J!gs. el al. v. Calif(mlia SecrelaT}, o(Stale Debra Bowen, et ai. Superior Court of the State
of CaHfomia for the County of Sacramento, Case No. 34-2008-80000096-CU-WM-GDS, which was recently
dismissed.
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plagiarized the work of Philip J. Berg, his Assistant Lisa and his law practice, Law
Offices of Philip 1. Berg.
26. Orly Taitz set up the business name of Defend our Freedoms Foundation, Inc. as a
non-profit Organization with a Federal Tax Identification number of 26-4328440.
However, when you attempt to verify the Federal Tax Identification number it comes
back invali(f.
27. Taitz had a website at drorly.blogspot.com, which did have some nefarious
functions and Taitz authorized those functions. At this time, Ostella assumed it was
because Taitz did not understand the internet. There was a third [3 rd ] party program
added to drorly.blogspot.com. This program was collecting information from
everyone who was visiting and posting at Taitz website (drorly.blogspot.com) and
transferring the individuals' private data to an unknown server. Taitz was well aware
of these functions as she authorized them and had the head web master install the
software on December 24,2008.
28. The data transfer took place via a java sctipt program plus a put command that
enabled FTP transfer. The java program is what caused trouble with people using
Taitz's website located at drorly.blogspot.com. Most computers are set up with
security tirewalls that do not allow easy data collection.
29. Ostella purchased and owned the defendourfreedoms. us and
defendourfreedoms.org, web sites and she maintained them on the server that she
(OsteIla) paid for. Ostella allowed Taitz to use said websites. Ostella supported Taitz
and has always been involved with politics, campaigns and causes. So when Ostella
saw the antics with the java script program on the other blog (drorly.blogspot.com),
2 h\!P...:!1!y"'\£\'y~IDgIL~~~~t~!;,l,'<::91]!lQ.Q.~.IJQ~11Jl5J>.:2?jJ2~"2~:'..U_~8-=HCJ~~gIQmiJl=.S ubml~
I:\FORMS\Liberi, Berg, Law Offices of PJB. Adams and Ostella Complain! for Damages
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and it was never clear on how much Taitz realized was going on, Ostella took Taitz
over here to use Ostella's accounts. All of the DefendOurFreedoms domain names
were and are on Ostella's web accounts.
30. DefendOurFreedoms.org, owned by Lisa Ostella was and is hosted at Ostel1a's
server. It is a stand-alone server on rack rental at HE.Net. Ostella had and has full
access to this server and no other accounts are on this server but hers. Ostella verified
her IP lugs to ensure the website was not "hacked". The IP Address logs show every
IP address, which is a computer's identification that entered the website and/or server.
There has never been any other IP addresses that have appeared on the IP logs other
than Ostella's. Hence, the website and/or server have never been "hacked".
31. As for DetendOurFrecdoms.us, that was hosted at GoDaddy under Ostel1a's
reseller account. This domain did not point to a website, it pointed to a blog.
Specifically, it pointed to QuickBlogcast. This is very important to understand. A
blog is not a website. The domain points to a database label. If the blog had been
"hacked", someone would have had to break into GoDaddy's database files and know
what customer number the database files was under. This would have compromised a
number of other accounts with more damage other than a change in the e-mail
address. GoDaddy would have had to issue a notification to all customers. Of
course, GoDaddy never issued such a notification because the blog was never
"hacked".
32. None of the DefendOurFreedoms website were ever hacked or sabotaged, as Taitz
claimed. Being unable to access a website due to network latency does not equal
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"hacking". Traffic, congestion, line repairs affect network flow and all can always be
3
checked on the Internet Traffic RepOlt .
33. Another webmaster who goes by "creativeogre" and Ostella called Taitz and
explained to Taitz her websites had never been hacked.
34. On or about March 9, 2009, another issue arose with Taitz and her PayPal
account. Taitz had volunteers with access to the coding of her PayPal account on her
blogs. One of Taitz's volunteers or Taitz herself changed 1'aitz e-mail address
associated with her PayPal account oriy.taitz(lzJ,gmail.com to
[email protected].
35. Bob Stevens, Taitz's Head Webmaster created four [4] e-mail accounts for Taitz.
Taitz was supplied all her e-mail accounts which included, amongst others,
Qr.tall?c@grrmiL~om. Despite knowing this was her own e-mail address, Ta1tz sent a
mass e-mailing out with the below statement and posted the statement on her website,
knowing it to be false.
Breaking and entering into my Paypal account

:')LaT),:;":" H<!f.}~.~ ·x'.:!! (;;; !·i~!< ~~')UI/::-, /,..:~ ,"i.)1! ~,~p:~",.·, I t~::,','~j::-1
1,;.+1-:; ~nc ~" 1,,~·1. 'V.'l:<nf.i F,.;'j.fh<!:'nt ':.,r(\~!:~:~
"." (1:
, .,l
36. As a result, 1'aitz was not recelvmg her donations. Donations received were
rejected by PayPal as the e-mail address was incorrect and no such e-mail address
3 http://www.internettrafficreport.com
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existed. Since the e-mail address did not exist, PayPal rejected the donations and sent
them back to the contributors. Hence. the donations were not stolen or misdirected as
Taitz claimed, which Taitz was well aware.
37. Despite the fact Taitz was well aware her websites and PayPal accounts had
never been "hacked" or tampered with, 011 or about April 2. 2009, Taitz wrote to the
U.S. Supreme COUl1 Justices 4 seeking help in an investigation regarding a criminal
complaint she had tiled with the Federal Bureau of Investigations regarding hacking
into her websites and tampering of her PayPal accounts, and other things. Taitz sent
this same letter to the Secret Service and other Governmental Law Enforcement
Agencies. Taitz was aware the infornlation she gave to the Federal Bureau of
Investigations was tillse and she was wen aware she was filing a false report.
38. As a result of the false report made by Orly Taitz to the Federal Government,
Ostella informed Taitz that she must clear up the false reports or Ostella was
removing Taitz from her websites and server. Taitz refused to clear this matter up
and refused to retract her falsified police reports. When Taitz refused to clear up this
report, Ostella told Taitz she had to move her sites. Taitz asked Ostella to give her
thil1y [30] days so she would be able to find a new host.
39. Instead of Taitz locating a new server, she gave an interview to World Net Daili
on April 4 th , 2009 elaborating on her scheme to mislead the public and law
4 A copy of the letter Orly Taitz sent to the U.S. Supreme Court, which was posted by Orly Taitz on April 2. 2009 at
4:20 p.m. can be located at: h1trE(/defcndour.fi~~@,!!!;i.l1et!~J!09!04lQ'yJ;lJ?~J).:J!m"r~19-thc-w[eme-courtrequest-of
£.QQI1c rat iQ!l=-~j.ili~ th!:Clb i ~j!!'y_~.s I j gaJ it )D"i!~)(
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enforcement into believing her wcbsitcs and PayPal accounts were "hacked" and
"sabotaged". Again, Taitz was well aware none of these events took place.
40. Although Ostella continued infonning and explaining to Taitz her websites had
never been "hacked", Taitz continued to spread the falsified story. As a result,
Ostella told Taitz she had to immediately move her sites.
41. Taitz found a person by the name of Jesse Smith who was to be her new web host.
She authorized Ostella to transfer the domains to him. Jesse Smith first contacted
Ostella on April 9,2009. Ostella told him to initiate the transfer. Jesse Smith started
the initiation on April 10, 2009 through Network Solutions. Ostella accepted the
transfer request and the transfer process started.
42. Now, remember, the site was not a wehsite. It is a blog. The domain pointed to a
database label. Normally, when a domain is transfened from a website, the domain
just switches from the one site to the new site smoothly. It will leave the old site still
showing; but with the virtual host name. In order to move a blog site, which is a
database, the account would delete when the transfer activates. To protect al1 the
data, Ostella moved the account onto DefendOurFreedoms.Net, then unlocked the
domain and authorized the transfer. For whatever reason, this outraged Taitz and
Taitz accused Ostella of being defiant.
43. On April 12, 2009, Taitz went on the Evil Conservative Blogcast 6 and told the
audience that Ostella had threatened her and altered the focus of her story onto the
PayPalaccount.
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44. For protection purposes, Ostella locked the website access of all of her (Ostella's)
websites. Ostella changed the PayPal script in the donations button to reflect her own
account and removed Taitz's accounts from the site. Ostella placed notifications on
all her webpages that the sites were no longer 1'aitz's Defend our Freedom
Foundation, Inc. and Ostella posted the following links to ensure people understood
1'aitz's sites were never"hacked".
• Understanding the lnternet 101

hUn:!/clefcndollrfreeQor!l~J.et!20Q9I.Q1LL;;llwderstanding-the-intClllet-191.aspx
45. Once Ostella posted the above, she received the following Ceizc [sic] and Desist
from 1'aitz, which was untrue. Ostella at all times owned the domains and servers
that the domains were located.
"Ceize and Desist

04.13.09.
Ms. Ostella,
This is a Ceize and Desist Letter, advising you to stop immediately

operation of sites and shut down DefendOurFreedoms.net;
DefendOurFreedoms.US; DefendOurFreedoms.Org, and
DefendOurFreedoms.Com and any other relating sites that you have been
operating after I requested transfer. You have used those sites for
defamatory purpose of me and my foundation and you have used my
hkeness and my material without my permission. If you do not shut down
above sites immediately, fmiher actions wi11 be taken.
Sincerely,
Dr. Or1y 1'aitz Esq

26302 La Paz ste 211
Mission Viejo Ca 92691"
46. Moreover, 1'aitz, placed JS Kit software which is a "tracking" and "hacking"
software on her Defend our Freedoms Foundation, Inc. websites and blogs, this
softwith the exception of the DefendourFreedoms websites owned by Lisa Ostella, in
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order to "track" and "hack" individuals and their computers who have visited her
websites. Defendant Yosef has a server in Taitz, and his home in order to complete
their illegal activities.
47. Unfortunately, Liberi's computer was infected with Taitz's JS Kit Software and a
remote server was placed on Liberi's home computer by accessing Taitz website.
48. Taitz began changing her story to focus on "hacking" of her PayPal account, even
though it never happened. Taitz was literally telling people that her PayPal account
was "hacked", knowing this to be false. In fact, there is no way Taitz's PayPal
account could have been hacked. PayPal's servers that hold individuals' private data
are not connected directly to the internet. There are servers in between. So the server
an individual logs into in order to access their PayPal account, is not the same server
that houses the infomlation. If someone was able to break into that system, PayPal
would have had to notify all customers of a breach and shut all processes down to
investigate. Taitz literally had people thinking that her e-mail address was changed
from within the PayPal account, again knowing this information to be false.
49. Taitz never launched an investigation with PayPal in reference to her "hacking"
allegations. Instead, Taitz made blatant statements saying money was stolen out of
her account. Again, the entire time knowing this infonnation was false.
50. Because of Taitz false statements regarding her PayPal account being "hacked",
Ostella posted the following:
• Understanding the Internet 102 - PayPalGate
b.!.tQ)Idcfcndourireedoms.net/2009/04/ 14!understand ing-thc-intcrnet-I 02-

PayPalgale.asPK
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51. The change was in the e-mail address on the blogsite. Originally, the PayPal
donate code on the blogsite was in an encrypted script that PayPal makes available for
copying and pasting into blogs and websites. But GoOaddy made some updates in
the design in February 2009. The updates didn't function with the PayPal script
encryption. See the below e-mail received from GoOaddy.
Subject: Script Issue With Quick Blogcast
From: "Andrew" <[email protected]>
Date: Tue, April 21, 2009 6:40 am
To: info@goexcelglobaLcom
On February 11, 2009, Lisa, was advised that the PayPal button links do
not work on the sidebar within the Quick Blogcast.
Andrew S.
Team Sapphire
Customer Care Center
52. Taitz is no stranger to falsifying stories and falsely claiming to be the victim of
"hacking" of her websites. On December 12, 2009 Taitz and Bob Stevens, Taitz
Head Webmaster, began telling people that "Obama thugs" had her business/dental
site, dnaii/"com. shut down. They wanted this infonnation immediately posted on the
blogs. Ostella stopped the posting of this intonnation by looking up the domain and
finding Taitz's prior host data. In short what Taitz had done was switched her own
domain off the website. Taitz told Ostella she (Taitz) was signing up for a web tramc
program. Taitz told Ostella she (Taitz) was going to give Ostella access to get her
domain back and Ostella would be her new hired webmaster for Taitz's dental
websites. Ostella was never given access. Taitz's dental websites are up and running
and Ostella is unsure who Taitz's webmaster is.
53. On April 12, 2009, Ostella received the following e-mail containing false and
incomplete infonnation further slandering Ostella. This e-mail was sent to an
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unknown number of undisclosed recipients as well as carbon copied to Ostella and
the Chicago FBI:
----- Original Message ----
From: Orly Taitz
To: chuckolb
Cc: Li~a Ostell.S! ; Chicago FBI
Sent: Sunday, April 12, 20092:55 PM
Subject: Re: IMMEDIATE I Dr. Orly Taitz I Redirect

defendourfreedoms.net I Phil - therightsideoflife.com - the Conservative
Sanctuary
no, things are not right it is being investigate by the FBI. I cannot post
anything at the moment, Lisa Ostella, web master, has blocked me out
of my own blog and refuses to give me codes for my own
blog
Orly Taitz DDS Esq
Mission Viejo Ca 92691
29839 S. Margarita Pkwy
Rancho Santa Margarita Ca 92688
ph. w 949-586-8 I 10 c-949-683-5411
fax 949-586-2082
54. It was also discovered Taitz had authorized placement of JS Kit Software on all
her Defend our Freedoms Foundation, Inc. websites and blogs. Again, this does not
include the DefendourFrcedome websites owned and operated by Ostella. JS Kit
software is tracking software used in "hacking" websites and personal computers. In
the J S Kit software is a function that places remote servers on individual and
company computer systems in order to allow the person using JS Kit software, in this
case, Taitz, Yoself and other unknown individuals on their behalf to illegally enter the
individuals and company computers to steal and transfer data. This remote server
function was located on Liberi's computer.
55. Yosef, Taitz husband and Taitz have implemented their own server in their home
located in Laguna Niguel to utilize the "tracking" and "hacking" of individual and
company computers who have visited Taitz websites and blogs. Yosef is assisting his
I:\FORMS\Liberi, Berg, Law Offices of P18, Adams and Ostella Complaint for Damages
16
wife, and their companies, Orly Taitz. Inc., Defend our Freedoms Foundation, Inc.,
and Taitz, in her illegal activities. I-fence, it is not Plaintiffs Ostella or Liberi
"hacking" Taitz andlor Defend our Freedoms Foundation, Inc. websites, blogs andlor
PayPal accounts, it is Taitz, her husband Yosef and other unknown named individuals
on their behalf who are "hacking" the computers of the Plaintiffs and other
individuals and companies who have visited any oftheir websites andlor blogs.
56. On or about April 12,2009, Berg received an e-mail from Taitz stating he was to
"Ceize and Desist" [sic] from using Taitz's Quo Warranto, which Taitz claimed was
sent to Berg inadvertently. In this same e-mail, Taitz made false allegations claiming
his (Berg's) Paralegal, Lisa Liberi had an extensive criminal record involving
amongst other things identity theft. Taitz went on further in her e-mail to Berg that
Libert's husband was currently on parole and he had sct up two (2) accounts
accepting credit cards on Berg's "charitable toundation", again all of which was
falsified and fabricated by Taitz. Taitz in her e-mail stated as an officer of the Court
she was obligated to send the information to the "FBI", Attorney General of
California and San Bernardino County District Attorney since Lisa Liberi had an
eight [8] year conviction in San Bernardino County, California. Taitz in her e-mail
infonlled Berg that she believed that Berg, as an Officer of the Court, as well and a
fonner Assistant Attorney General of Pennsylvania, should join her in issuing a joint
Complaint and demand for investigation from the authorities. Taitz then forwarded
the e-mail addressed to Berg to an undisclosed number of recipients.
57. Liberi then received an e-mail from Mr. Hale claiming Lisa Liberi was stealing
money from Taitz's PayPal account. Mr. Hale's e-mail was forwarding an e-mail
sent out by mass mailing by Taitz stating, "/ also received information that her
I:\FORMS\Liberi, Berg. Law Offices of p.m, Adams and Ostella Complaint for Damages
17
husband. "1'/10 is cllrrent(v on parole. is an owner of 2 of'accolll1tS. accepting credit
cards on your charitable foundation web site." At all times, Taitz and Mr. Hale were
well aware this infonnation was false and untrue.
From: Ed Hale <ed(d)barhfarms.net>

~--~ .. ~-.-
Date: Mon. Apr 13, 2009 at 9:58 PM

Subject: Fwd: Ceizc and Desist demand to file a joint FBI complaint
To: Lisa Liberi <lisaliberiu~gmail.com>
"Well. I sure hope that you \\'ill enjoy your time in prison. We now have
you as \VC ahve undercover where you diverted funds from Dr Orly to
your website, We have had :2 people come t()rward witb Pay Pal rcciepts
proving you arc a their. Now me and Plains radio have been proven right
You and your whole bunch will wind up in jaih. "rhis is a great day for
Plains Radio and Ed Hale."'
----- Forwarded Message ----

From: "Orly Taitz" <dr taitz(iilyahqg.com>
To: "mark westmann" <!Il\vestJlwnn 13(c/Jgmail.com>, "Ed Hale
PlainsRadio" <parhfarms(a{gmail.com>
Sent: Monday, April13, 2009 11:01:25 PM (GMT -0600)
America/Chicago
Subject: Fw: Ceize and Desist, demand to file a joint FBI complaint
Orty Taitz DDS Esq
26302 La paz ste 211
ph. w Y49-586-SII 0 c-949-683-5411
fax 949-586-2082
--- On Sun, 4112/09, Orly Taitz <<lr lait{g~y{thoQ:~onl> wrote:
From: Orly Taitz <dr taitz(~vvahoo.eom>
Subject: Ceize and Desist, demand to file a joint FBI complaint
To: "Phil J Berg Esq (pvt)" <P)JiJ.!ll~Ig(alg!}1ail.coJn>
Cc: "Orly Taitz" <dr taitziii)yahoo.con}>
Date: Sunday, April 12,2009, 10:01 AM
1:\FORMS\Libcri, Berg, Law Offices ofPJB, Adal1h'l and Ostella Complaint for Damages
18
04.12.09.
Mr. Phillip Berg,
"this is to infOlID you that a few days ago I have forwarded my quo
warranto pleadings to Mr. John Hemenway, since he agreed to be my local
co-counsel in Washington DC. This was a confidential communication
and Mr. Hemenway stated, that mistakenly he has forwarded those
pleadings to you. Shortly thereafter you have sent a press release, stating
that you will be filing Quo Warranto action. This is a Ceize and Desist
letter, demanding that you do not use my pleadings and confidential
information in any way, shape or f()fJTI, as you received those in elTor
without my authorization.
Additionally, I received information from a licensed Private
investigator, with 20 years of experience with Scotland Yard and 12 years
of experience in US, that your paralegal Lisa Liberi has an extensive
criminal record, involving fraud, forgery of documents and identity theft.
See attached file. I also received infonnation that her husband, who is
currently on parole, is an owner of 2 of accounts, accepting credit cards on
your charitable foundation web site. As an officer of the court I am
obligated to forward this information to the authorities: FBI, Attorney
General of California and San Bernardino County Distict Attorney, since
Lisa Liberi had a 8 year conviction in San Bernardino County, California.
I believe that you, as an officer of the court, as well and a former Assitant
Attorney General of Pennsylvania, should join me in issuing a joint
complaint and demand for investigation from the above listed authorities.
Dr. Orly Taitz Esq"


ph. w 949-586-8110 c-949-683-541I
fax 949-586-2082
58. It should be noted, Berg does -not have a charitable foundation website. He does
~
have a website with a donation button which allows people to donate one (1) of two
(2) ways, PayPal or by a separate credit card company, which Berg is the only party
with access.
I:\FORMS\Libcri. Berg, Law Offices ofPJB. Adams and Ostella Complaint for Damages
19
59. Moreover, Liberi has nothing to do with the web mastering of his (Berg's)
website, Taitz website or any other website. The coding for the donate buttons and
the accounts which donations go into are all done by a third party webmaster and is
all traceable.
60. Berg never received the "supposed" Quo WalTanto Taitz is refelTing to above, nor
has he seen it. However, what Liberi received from Allan Edward Buck, was a Writ
of Mandamus and a Writ of Quo Warranto that he himselfhad drafted and did all the
work on. If this is what Taitz is spreading around, it is not her work, but yet the work
of another party.
61. Plaintiffs then learned Orly Taitz had people go onto among others, Berg's
website at obamacrimes.com, download all the briefs investigated and prepared by
Berg and his assistant, copy the contents and Taitz then filed the briefs in Court
claiming the work to be hers, again whieh is plagiarism of Berg's and his assistant's
work, which is owned by the Law Offices of Philip J. Berg.
62. On or about April 14, 2009, Liberi received an e-mail from a third party that
contained a post on Plains Radio owned by Mr. and Mrs. Hale 7• The post was made
by Defendant Katy and states she received an e-mail from Taitz stating the following.
This same e-mail was also sent to an unknown number of undisclosed recipients:
Dr. Orly's site has been taken over by Obots!! E-mail from Orly
'This is an e-mail I recieved from her this afternoon:
Katy"
"This is a nightmare. I had hacking into my Pay Pal account. (see dossier #5 in
attachment), the e-mail address on my PayPaJ account was changed, sol would not be
able to get donations. It was reported by a number of donors and I have filed a complaint
with the FBI. My blog was set up by a volunteer Lisa Ostella. She is the web master and
I:\FORMS\Liberi. Berg. Law Offices ofPJB, Adams and OstelJa Complaint for Dflmages
20
:o;hc has the codes for the blog. She demanded that [ take back my complaint to FBI,
claiming that the change of e-mail address was done by a volunteer by name Fran, that
she banned Fran from the site, that it took care of the problem and [ need to take back my
complaint of hacking with FB\. as it gives her. as a web master a bad name. I refused
to do so, stating that it is a legitimate complainl, I want them to investigate. At that time
she stated that I will need to get my blog of her server, if [ don't take back the FBI
complaint.
r found somebody else to host the blog, however according to volunteers she never
forwarded the release and the codes to the platfonn company Go Daddy, she locked me
out of my own foundation site and refuses to give me the access codes. She has posted a
defamatory statement, claiming that r authorized hacking into my own account and that I
made bogus claims. This is totally ridiculous in light of the fact that I have statements
from the donors and I lost donations. The FBI agent in charge of this investigation is
Nathan Le, Orange county. CA, FBI, cyber crimes unit, phone 714-245-5328; 310-710
3459.
orty Taitz DDS Esq

I
2()302 La Paz ste 211
Mission Viejo Ca 92()91
ph. w 949-Sg6-811 0 c-949-683-5411
fax 949-586-2082 "
63. Again, Taitz was aware all this information was false. Ostella is a Webmaster by
trade, Taitz was maliciously slandering and posting libel about Ostella to punish and
harm Ostella for telling the truth, which has effected Ostella's company, Go Excel
Global.
64. On or about April 17, 2009 at approximately 9:31 a.m. Taitz sent out a mass e-
mailing of slander and libel pertaining to Liberi, Ostella, Berg and the Law Offices of
Philip .r. Berg. Liberi received an e-mail which contained Taitz Dossier No. Six (6)
which was nothing more than a vicious attack on Ostella and Liberi. Taitz fabricated
false allegations about both Ostella and Liberi. Taitz, gave personal identifying
information regarding Liberi including her entire Social Security. Taitz made many
false statements including but not limitt:d to the following: Ostella locked Taitz out of
her website instead of transferring the access codes and domains; Ostella posted
I:\FORMS\Liberi. Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages
21
bizarre defamatory statements that Taitz authorized hacking into her own account;
Taitz claimed she received reports that some defamatory comments were made under
alias usual1y used by Lisa Liberi, assistant for Attorney Philip J. Berg; Taitz
insinuated Ostella was taking monies donated to her; Liberi had an extensive criminal
record going back to 1990; Liberi, among other things. engaged in falsification of
police reports, manipulation of credit bureau reports; counterfeiting of court
documents; Liberi had Twenty-One Thousand [$21,000] Dollars per month in
restitution; several sources confinned that Liberi lives in N M; they confirmed her
date of birth and appearance as matching the ones on file with the San Bernardino,
CA district attorney; Libert launched vicious attacks against Taitz and then states
Liberi disagreed with her and this was the vicious attack. The list goes on. Dossier
No.6 by Taitz own admission was an open letter posted on the internet and forwarded
to 26,000 outlets of US and international media. In addition, Taitz sent this e-maiJ to
an unknown number of undisclosed recipients asking them to post the information on
their website. Again, included in this was Liberi's full Social Security number that
Taitz obtained without a permissible purpose from Defendants, Neil Sankey, The
Sankey Finn and Sankey Investigations, Inc. Moreover, Taitz sent this Dossier No.6
to Attnrney General Eric Holder; Solicitor General Elena Kagan; Director of FBI
Robelt Mueller; FBI Cyber Crime division, Orange County CA. Officer Nathan Le;
Director of Secret Service Mark Sullivan; Chief of Security of the Supreme Court,
Officer Christine Giaccio; Chief Justice of the Supreme Court John Roberts; and
Legal Counsel to the Chairman of Joint Chiefs of Staff Admiral Mullen, Captain
Crawford. Taitz was well aware this information was false, and it was illegal to
transmit a third (3fd) pa1ties personal identifying infOimation, including their Social
I:\FORMS\Liberi. Berg. Law Offices ofPJB. Adams and Ostella Complaint for Damages
22
Security number which Taitz had absolutely no permissible purpose to obtain;
distribute via the internet, bye-mail and posting a person's private confidential
information on wcbsites. A copy of Taitz Dossier No.6 will be provided to the
Court; with a request that it be placed "u"del' ~;eal". Taitz also posted this on her
website at Defend our Freedoms.s Below is only one of the many e-mails Taitz sent
on this date
-------OrigiI/{II Alessagc------
Dale: Fri. 17 Apr 2009 09: 10:41 -0700

Fra In: "'--'-'" -'-'~~L'!.CC'""""~:':'"
Suqject: More explosive information dossier #6
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tmn)!lvblog(£llya.b90 . canl;
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che?ler,G.9J!l; chuck,todd@nbclIl.!!.CO..m: info(iithillarydintoll.col1]; ciochheaq(iilskhronicle.com;
nacomprollli.?.f.'YhelJ'y9ureright~4gmai1f.9J:.tl; evil~vilconservativeonlil1e.com;
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Orly Taitz DDS

26302 La Paz ste 21 I
I:\FORMS\Liberi. Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
23
Rancho Santa Margarita Ca <!2688
ph. w 949-5116-8110 c-949-6l\3-541I
fax 949-586-20112
Dossier #6 new.doc
89601( \{ie',;_5t..'::JjJ~~IJ" 12.Q..'Y!1IQ£1.Q
65. April 13,2009, Taitz was on a blog talk radio station, The Dame Truth 9 , which is
an internet blog talk radio program. The entire time Taitz was on the air she did
nothing but slander Liberi with the above referenced information.

1o
66. Taitz then posted on her website Defend our Freedoms: "More on Lisa Liberi,
contact her probation officer in Santa Fe New Mexico 505-827-8627. She is not
allowed to be anywhere near other people's credit cards, By Orlytaitz April 17,2009"
67. On April 18,2009, Taitz posted further slander and libel about Ostel1a and Liberi,
on her website, Defend our Freedoms II:
Dr. Orly Taitz Esquire
Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA
92691. e-mail: [email protected]
Every day I get such evidence of missing or misdirected funds
"Every day I get such receipts, showing that my former web master Lisa Ostella
(posts under name Calpernia) has redirected donations to herself, to her e-mail
address. Currently, as this was uncovered, she created new web sites Defend
our freedoms .org, .net and continues the scheme by making those sites similar
to myoid ones and using the foundation name to steal more donations. She
created a visa donation site with her e-mail account Go Excell Global,
underneath she posted a PayPal button showing my foundation Defend Our
Freedoms (without my consent) and my e-mail address (without my consent) to
look as if she is still connected to me and my foundation. even though all ties with
!O http://ZI6.22l.JJ!2.26&logger/Q9stLMore-ol!:~.is<t:!dJ~!i.-cont'!c..L~.b£!:~J2.r:.obat ion-o !licer-i n-Santa-F e- N ew- Mex ieo
505 -82 7-8627-S.he- iS..:DDt -all9Yic.:l-to-l;!c-anywhcn:;:I1£ar-S!th.9J:J2<;Qru~s-(;Ied !J:.:f.<1!:.ds .asJ2~
I:\FORMS\Liberi, Berg, Law Ortices of PJB, Adams and Ostella Complaint for Damages
24
her were severed a couple of weeks ago, when I found out about this scheme
and I closed the Pay Pal account completely. Any person, whose donations were
stolen by Lisa Ostella aka Lisa Current aka Calpernia is asked to report this to
his local police or sheriff's department. As I found out, she appears to be
connected to Lisa Liberi, who is still working for attorney Phillip Berg. Please see
my dossier #6, Lisa Liberi aka Lisa Richardson aka Lisa Courvelle has a long
criminal record, that includes grand theft, forgery of documents, forgery of seal,
falsification of police reports and credit statements, where financial institutions
were defrauded out of thousands of dollars. She claims to be a different Lisa
Uberi, living in PA, however she lives in NM and her probation officers are
Joanne Martinez 505-827-8627 and Dawn Helling (not sure about spelling) 505
476-2359."
68. Taitz then set-up another blog l2 where she was slandering and posting libel about
Ostella. Taitz set up the blog, orlytaitz.com and posted the following:
Don't be fooled
"My former web master Lisa Ostella has created an account that she called Defend Our
Freedoms Network and is soliciting donations, praying on unsuspecting readers that
would not notice the difference between Defend Our Freedoms Foundation and Defend
Our Freedoms Community. Please notice, your donations there will not go to the
foundation, they will go to her personal bank account. connected to her personal e-mail
address GoExceliGlobal. She posted underneath a PayPal logo with my e-mail address,
however I have closed the pay-pal account. If you want to give donations to the Defend
Our Freedoms Foundations, please, mail them to Defend Our Freedoms Foundation
26302 La Paz ste 211, Mission Viejo CA 92691"
This entry was posted on Saturday, April 18th, 2009 at 5:27 pm and is filed under
• !' . You can follow any responses to this entry through the
?fl feed. You can , or '"-"C":.~=.""",,:- from your own site."
69. On April 20, 2009, Mr. Hale had a radio show on at 9:00 p.m. Mr. Hale's Guest
was Orly Taitz. Orly Taitz did nothing but slander Ostella and Liberi on Mr. Hale's
radio show with the false allegations outlined above. Mr. Hale then went on falsely
stating Lisa Ostclla and Lisa Liberi were one and the same person and she was a
criminal.
12 http://www.orlytaitzesq.com/blog1I?p=71
I:\FORMS\Liberi. Berg, Law Office8 of P.lR Adams and Ostella Complaint for Damages
25
70. On April 21, 2009, Taitz posted the tollowing slander and libel against Ostella,
Liberi, Berg, the Law Offices of Philip 1. Berg and Adams on her website 13 :
"Dear Mr. Barrs,

I have reported the matter to the Sheriff's department and FBI. See below the receipt for
the police report with the name and phone number of the detective. The name of the FBI
agent is John Haas- supervisor of the cyber crimes unit 714-542-8825. Please spread the
word and give everybody the new web address for the Defend Our Freedoms
Foundation, which is
Please post this web address in as many blogs and sites as you can, so it will be picked
up quickly by different search engines and can be seen by all my readers. I have closed
my pay pal account and did not receive any pay pal or visa donation since 04.11.09. If
you or anybody else has given any donations after this date, using pay-pal, visa,
MasterCard, American Express and so on, believing that these donations were received
by the Defend Our Freedoms foundation, please demand a refund and report it to the
Sheriffs department, FBI and IRS as funds stolen from the non profit organization. I have
sent a Cease and Desist letter to Ms. Lisa Ostella, demanding that she forward to me the
access codes for the domains and the e-mail address list of the readers and stop
fraudulently operating under the name DefendOurFreedoms and stop drawing financial
profit from the Defend Our Freedoms name. I have also sent a Cease and Desist letter to
Evelyn Adams aka Momma E, talk show host David Levin and other parties who are
fraudulently advertising on the foundation website and drawing profit from it or from
reader lists given or sold to them by Ms. Ostella. Ironically Ms. Ostella has accused me of
collecting information on the readers. In reality I did not have any such information and
could not reach most of the readers, aside from ones whose names were in my
9LJi:.it:;;(c!{.l.3.tI99:..Qprne-mail account. Ms. Lisa Ostella is the one, who collected names
and e-mail addresses and she is currently fraudulently sending e-mails to these readers
using DefendOurFreedoms name. If you get such e-mail. please demand that she
immediately stop this practice and forward the list to me. as the president of the
foundation.
My primary goal is to expose all the fraud committed by Obama and removing him out of
office as an usurper, litigation against Ms. Ostella is secondary. I also need to get full
information in regards to full damage to the foundation and me, stemming from actions of
Ms. Ostella and parties that patronage her site and are aiding and abetting her.
I, also, sent an e-mail withdossier#6toMr.Phil Berg, advising him of lengthy criminal
record of grand theft, forgery, forgery of seal and other related crimes, committed by Ms.
Lisa Liberi, his paralegal and assistant, who reportedly was managing his fund raising
efforts. I believe Mr. Berg should not be using a person with such past in his fund raising
efforts and legal practice and should issue a statement advising the donors and
supporters, that Ms. Lisa Liberi is no longer employed by him or his foundation and that
he is reviewing all donations and all legal records handled by Ms. Lisa Liberi. I believe the
donors to Mr. Berg foundation should get assurances that their donations were used for
litigation and the cause and not to reimburse victims of Ms. Liberi's prior
schemes, reported to add to $21,000 per month.
Sincerely,
Dr. Orly Taitz, ESQ"
04.21.09.
- -......- . - -
l:\FORMS\Liberi, Berg, Law Offices ofPJB, Adams and OsleUa Complaint for Damages
26
71. Unfortunately, Taitz continued sending out the above false statements and her
falsified Dossier No.6, every day since to websites and undisclosed recipients
requesting the posting of the infonnation along with her requests for everyone out
there to contact the FBI, the Orange County Sheriff's Department, a probation officer
in Santa Fe, New Mexico and report this infom1ation. It was nothing more than
harassment of Liberi, Ostella, Berg and the Law Oftlces of Philip J. Berg.
72. Taitz distributed this information including Liberi's full Social Security number,
date of birth, residcncy, ctc. to in excess of Two Hundred and Fifty Thousand
[250,000] individuals and businesses.
V.FACTUAL ALLEGATIONS RELATING TO DEFENDANTS' NEIL

SANKEY, THE SANKEY FIRM AND SANKEY INVESTIGATIONS
73. Plaintiffs incorporate by reference all of the foregoing allegations as if set forth
herein at length.
74. Defendant Neil Sankey is a licensed private investigator and owns and operates
the Sankey Firm and Sankey Investigations, Inc. Sankey is aware aware of the State
and Federal laws peliaining to disclosure of third party information: the posting of
Social Security numbers; the disclosure of Social Security numbers and personal
identifying information; the permissible purpose requirement before disclosing any
J:\FORMS\Uberi. Berg. Law Offices ofPJB. Adams and OSlella Complaint for Damages
27
paliies Social Security number, date of birth, where they reside or any personal
information at all; the transmittal of Social Security numbers; State and Federal laws
against endangering, harassing, threatening and attempting to destroy any person's
life and/or reputation.
75. Despite knowing these very laws, Sankey through his investigation finns, the
Sankey Finn and Sankey Investigations, Inc. conspired with Taitz to destroy Liberi
and violated every privacy protection law; State and Federal laws for the disclosure,
posting, and transmitting a person's Social Security number and personal identifying
infonnation; and violated the permissible purpose rule. In so doing, Sankey through
his investigation finns, the Sankey Firm and Sankey Investigations, Inc. just to
mention a few, violated Liberi's First Amendment Rights to Privacy, First and
Fourteenth Amendment pertaining to invasion of privacy, a right to be safe, etc. See
below which is a copy of Neil Sankey's e-mails from the Sankey Film and Sankey
Investigations, Inc.
76. Neil Sankey, by his own admission received from Defendant Linda statements
that Liberi had a long criminal record going back to the 90's and Liberi had been
convicted of among other things, real estate fraud, falsification of police reports,
manipulation of credit burcau reports, and counterfeiting of documents, which is
completely false. Without bothering to investigate thc information sent by Linda,
Neil Sankey through his finns, the Sankey Finn and Sankey Investigations, Inc. sent
an e-mail out with the false information as if it were true. Since this e-mail was sent
Neil Sankey admitted to two [2] separate individuals that he did not investigation the
infonnation and could not verify it was in fact Liberi. See below.
I:\FORMS\Liberi. Berg. Law Offices of P.JB, Adams and Os(ella Complaint for Damages
28
From: =~=~c=~~~~~~.==~·~
To: [email protected]; ~ir taitz(d)yahoo.com

Subject: FW: »»»»»Urgent IMPORTANT INFO SAME
SUBJECT««<Date: Mon, 16 Mar 2009 14:57:13 -0700
PLEASE NOTE THE LAST LINE!
Thursday, April 10, 2008
New Mexico Woman Sentenced in Identity Theft: and Real Estate Fraud
Lisa Liberi, aka Lisa Richardson, 42, New Mexico, was sentenced in connection
with felony charges involving identity theft and forged > documents. Liberi
appeared in San Bernardino County. Rancho Cucamonga, Superior Court, on
March 21,2008. She was sentenced to a state prison term of 8 years, imposed but
stayed, and placed on supervised probation tor 3 years as part of a plea agreement.
Liberi was sentenced on ten felony counts ranging from Grand Theft, Forgery,
and Filing False Documents.
From 2000 to 2004, Liberi engaged in a complex fraud involving falsification of

police reports, manipUlation of credit bureau reports, loan fraud, and
counterfeiting of c0U11 documents resulting in hundreds of thousands of dollars in
losses to banks and credit unions.
In 2002, San Bernardino County Sheriffs Department personnel arrested> Liberi

on theft by false pretense charges. In July 2004. Investigators from the San
Bernardino County District Attorney's Real Estate Fraud Unit arrested Liberi at
the Ontario International Airport f()r additional felony charges while she was out
on bail.
She has an extensive criminal record going back to the 90's.
77. Instead of truly investigating the information, Sankey through his investigation
firms "The Sankey Film" and "Sankey Investigations" sent the information to Taitz
and a repmier with World Net Daily via e-mail along with Liberi's full social security
number, date of birth and where she resided. Also included, was Liberi's private
confidential information.
78. Sankey sent false and incorrect intormation claiming it to be associated with
Liberi. See below, Liberi's full Social Security has been replaced with X's in order to
protect the confidentiality of her Social Security number, however, in the original e-
mail her full Social Security number is disclosed:
I:\FORMS\Liberi. Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
29
From: Neil SANKEY

Subject: FW: LISA LIBERI etc
To: dr taitz:Cl!yal19.9-,-gm:J
Date: Monday. April 13. 2009, 7:04 PM
Here is the Liberi stuff you requested. This is also what r sent to Bob Unruh
From: Neil SANKEY [mailto:[email protected]] Sent: Friday, April
10, 2009 10:0 I AM To: Bob Unruh Subject: LISA LIBERI etc Bob here are some
bare facts about Berg's assistant. See below and attachments I don't know how
much of the story you have already, but is essentially about WHO she really is
and the questions that unfortunately brings up about Berg. Call, if you need to, at
your convenience. Neil Sankey Investigator & Consultant. THE SANKEY FIRM
Simi Valley, California 93063 [email protected] 805 520 3151 8] 8
2127615cel1
(Addendum)
LlSA RENEE UBERI. Bn 5/28/1965. 462-45-xxxx, XXX-XX-XXXX (& others)
According to the Police she was born COURVILLE and married a Richardson
(Possible Alan Douglas Richardson, currently residing in Las Vegas .) IF it was
the other way around, then the Courville is Bill Marshall Courville 11110/61 of
Houston, Tx. 457-7\-x I have several SS#'s for her and a LOT of AKA's. Her
rca] SS# is probably 462-45-xxxx. Most prominent otherwise are 563-60-xxxx,
572-17-x, 622-19-x She went BK in 2002 Her brother is probably Lawrence E
Morris of Fontana and Rancho Cuc, CA. He was born 1116/64 Her Husband,
Brent J, a Parolee, I have not researched that. Is probably Brent J McConnack
563-77, also uses 331-02-x There is also a Jerry HELLER and Douglas Cramer
look interesting, but where do you stop?
From: Neil SANKEY Subject: Bergs PayPal To: dl' [email protected] Date:
Monday, April 13,2009, 7: 15 PMIt comes as no surprise to learn that the link to a
Visa donation to Berg, (as opposed to PayPal) has been removed. Neil
79. Sankey through his investigation finns, the Sankey Finn and Sankey
Investigations, Inc., did not have a pennissible purpose to obtain Liberi's Social
Security number or any other personal identifying infonnation of tiberi.
80. Moreover, Taitz did not have a pe1l11issible purpose to obtain or receive Liberi's
Social Security number and personal identifying infonnation. This was nothing more
than a complete l1bellslander and invasion of privacy not to mention it violated state
and federal laws.
I:\FORMS\Liberi, Berg, Law Offices of PJB, Adams and Ostella Complaint for Damages
30
81. Furthelmore, Sankey through his investigation finns, the Sankey Finn and Sankey
Investigations, lnc., did not have any permissible purpose to disclose Liberi's Social
Security number to any third parties including a Reporter with World Net Daily.
82. In so doing, Sankey through his investigation fimls, the Sankey Finn and Sankey
Investigations, Inc., have severely endangered Liberi, her son and husband. Liberi
was given a confidential address as a result of her and her son be.ing victims of
domestic violence. Sankey, through his investigation finns, the Sankey Finn and
Sankey Investigations, Inc., have now disclosed Liberi's private personal information,
full Social Security number, date of hirth and where she lives and has allowed said
infonnation to be posted all over the internet hy Taitz and sent across the United
States and Internationally, by Taitz own admission.
83. Sankey through his investigation finns, the Sankey Finn and Sankey
Investigations, Inc., conspired with Taitz to ensure Liberi's Hfe was endangered and
ruined. Sankey was well aware ofTaitz threat to destroy Liberi to get to Berg and his
law practice.
84. Sankey through his investigations finns, the Sankey Firm and Sankey
Investigations, Inc., had a duty to abide by the California privacy Jaws. Because
Sankey through his investigation finns, the Sankey Finn and Sankey Investigations,
Inc., failed to ensure Taitz had a permissible purpose, which she did not, the fact
Sankey himself distributed Liberi's Social Security number and private personal
identifying infonnation through e-mail to a Reporter and Taitz, since Sankey and his
investigation firms failed to ensure and sign a contract with Taitz and the Reporter
with World Net Daily to ensure the confidentiality of Liberi's Social Security
I:\FORMS\Liberi, Berg, Law Offices ofPJB. Adams and Ostella Complaint for Damages
31
number, date of birth, and other private personal identifying infonnation, he is liable
for all the mass e-mailing Taitz did as ifhe sent the e-mails personally.
VI. FACTUAL ALLEGATIONS RELATING TO DEFENDANTS'
JAMES SUNDQUIST and ROCK SALT PUBLISHING
herein at length.
86. James Sundquist through his company, Rock Salt Publishing, accessed Ostella's
home address and began sending mass e-mailing with her private confidential
intonnation to an unknown number of undisclosed recipients. In so doing, Sundquist
through Rock Salt listed Ostella's phone number as his personal phone number in
order to entice people to call and harass Ostella. The original e-mail from James
Sundquist at Rock Salt Publishing is below, however, the X's placed were done so to
protect Ostella and are replacements from the actual address and phone number. The
X's were not part of the original e-mail and only added as this complaint will be
pubIi c record.
From: ".r ames S undquist" <H!~IS,sJIJ.t!illy_t.:I:iZJ)J1.11t;t>

Subject: re Lisa Ostella
Date: Tue. April 21. 2009 6:40 am
To: ~Q!lt!S;l@rtQriL!J~.!llfQ@h!~~~t~IY.il~&Ql:D
Dear Tom O'Neill & North Brunswick Republican Organization and
Breederville Director.
I need to alert you to the fact that Lisa Ostella has defrauded Dr.
Orly Taitz and has hijacked her website. I have just spoken at length
to Dr. Taitz.
You can call her to verify this. Dr. Taitz tel number is 949-683-5411.
I live in New Jersey and have written two books and have a massive
database in which I am able to expose what Lisa Ostella did to Dr.
Orly Taitz. including approximately a thousand radio stations whicll r
ti'equent as a guest.
Ms. Ostella's address and tel # are:
I:\FORMS\Liberi. Berg, Law Offices of pm, Adams and Ostella Complaint for Damages
32
Ostella, Lisa
brecdervi ILc-,-colJl
xxxxxxxxxxxxxxxxx
North Brunswick. New Jersey OR902
United State~
***
Sincerely,
James Sundquist
Director
Rock Salt Publishing
(732) xxx-xxxx
87. Sundquist through his company Rock Salt tiled false police reports with the
Brunswick, New Jersey FBI and local authorities falsely accusing Ostella of hijacking
Taitz's websites and diverting funds from Taitz's PayPal accounts.
88. Sundquist. through his company Rock Salt, posted on Taitz's website,
orlytaitz.com, that Ostella had hijacked Taitz's website and was diverting Taitz's
PayPal funds and that he had reported to the Brunswick, New Jersey FBI and local
authorities. In addition, Sundquist, through his company Rock Salt, also posted
Ostella's home address and telephone numbers. 14
Dr. Orly Taitz Esquire

Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691 Copyright
2009
Official Blog of Dr. Orl}' Taitz Esquire

April 22nd, 2009
Welcome to the OFnCIAL Dr. Orly Taitz Esquire blog.
Please Note: I am NOT using PayPal anymore at this time for donations,
Please mail your donations to:
Defend Our Freedoms Foundation
26302 La Paz stc 211
Mission Viejo CA 92691.
e-mail: 9''..Jil!tz@Y.<lhoo&Q!1l
From .James Sandquist, director of Rock Sail Puhlising

April 23rd. 2009
I:\FORMS\Liberi. Berg, Law Offices of P JB, Adams and O~tclla Complaint for Damages
33
Fwd: Lisa Oste-Jla Inte-md .'raud in North Brunswick, N.J
Thursday, April 23, 2009 6:44 AM
From:
"James Sundquist" <[email protected]>
V ie\~'_~gl1jacl JjgJJliJ~
To:
"Orly Taitz" <Qx..Jillg@ym:1gO.<;QIl]>
Begin forwarded message:
From: James Sundquist <mck.§jl1!@yerizon.:I!~.t>
Date-: April 23, 2009 9:39:46 AM EDT
To: il;;kconsum~[ilffaL~((lllps.li1ate-,nj .tlS
Subject: Lisa Ostella Internet Fraud in North Brunswick, NJ
Dear Director of Consumer Affairs and the FBI for New Jersey.
You should be alerted to the following report regarding North Brunswick resident Lisa Oslella.
Because this also involves interstate commerce. the FBI needs to know about this too!
I need to alert you to the fact thai Lisa Ostella has defrauded Dr. Orly Taitz and has hijacked her
website. r have just spoken at length to Dr. Taitz.
You can call her to verify this. Dr. Taitz tel number is 949-6R3-54 I 1.
WORLONETDAILY has just run a national story on this:
~JlJ2;l~'"-:':.,:!,~"\UJ.Qsorrr{jJ1d~~J2hn'?j}1~e.t\,i; E,jli.~_~~(~Jmg~q=2,~:2~2
I live in New Jersey and have written two books and h(lve a massive database in which) am able
to expose what Lisa Ostella did to Dr. Or1y Taitz. induding approximately a thousand radio
stations which r frequent as a guest.
Ms. Ostella 's addres~ and lel # are:
Ostella, Lisa
12r""~Jj,,-[yjJkSOr!l
xxxxxxxxxxxxxx
North Brunswick. New Jersey 08902
United States
***
I hope that you will do what you can do to wam your community about Lisa Ostella!
Sincerely,
James Sundquist
Director
Rock Salt Publishing
http://rockAO-salt.s..!,'phasministry.cQJni
89. Sundquist, through Rock Salt is known to make terrorist threats through the
intemet against individuals in order to intimidate them and scare them on behalf of
others when the individuals do not a!:,J'fce in their cause and/or stand up for
themselves.
90. Sundquist, through his Company Rock Salt, Taitz and Defend our Freedoms
Foundation, Inc., have placed Ostella in fear for her children and family. Moreover,
Sundquist, through his company Rock Salt, Taitz and Defend our Freedoms
I:\FORMS\Liberi. Berg, Law Offices ofPJB, Adams and Ostclla Complaint for Damages
34
Foundation. Inc., have caused OstcUa and her family to be harassed and have placed
their lives in danger. Ostella and her family have heen repeatedly harassed by
individuals on behalfofTaitz, Defendant our Freedoms, Sundquist and Rock Salt.
91. Sundquiest, Rock Salt, Taitz and Defend our Freedoms Foundation, Inc. are well
aware Ostella has never "hacked" anything and their reports are all falsified. They
are well aware Taitz and Defend our Freedoms Foundation, Inc. have never been
hacked. Instead, it is Taitz and her associations on her behalf who have installed JS
Kit software which is a "hacking" and "tracking" software on Taitz's Defend our
Freedoms Foundation, Inc. in order to "track" and "hack" individuals and their
computers who have visited Taitz and Defend our Freedoms, Tnc. websites and blogs.
VII. FACTUAL ALLEGATIONS RELATING TO LINDA SUE

BELCHER alkJa LINDA S. BELCHER alkla LINDA STARR a/kJa
NEWWOMENSPARTYa/kJa STITCHENWITCH a/kJa EVA
BRAUN a/k/a WEB SERGEANT a/kJa KATY a/kJa
WWW.OBAMACITIZENSHIPDI'3BATE.
herein at length.
93. Defendant, Linda contacted Berg in or about August 2008 regarding the questions
into Barack H. Obama's citizenship status. Berg and his staff investigated the Mr.
Obama's citizenship and found there were genuine questions as to his Constitutional
qualifications to run for and serve as President of the United States.
94. Due to some unauthorized credit card charges by Geoff Staples, double billing
and failure to maintain Berg's website, in or about November 2008, Berg fired Gcoff
Staples as webmaster and hired another third party, Gail Fry, to take over the website.
Due to the expense involved, Linda was allowed to be a moderator.
T:\FORMS\Libcri. Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
35
95. In or about the end of January 2009, Linda began causing the webmasters and
administrators problems with Berg's website. Linda was warned to calm down
numerous times, however failed to comply. Linda felt she was in charge of Berg's
website and sent e-mails to the website moderators deten'ing anyone from contacting
Berg, Berg's assistant or the webmaster. Linda even stated she was in charge. As a
result. Linda's moderator status was removed. However, she was stil1 capable of
posting on the blogs at obamacrimes.com.
96. In or about early February 2009, Berg on behalf of Adams had all the Defendants
herein served with a cease and desist in attempts to stop the Defendants from their
illegal and dangerous behaviors against and towards Adams.
97. Linda began posting on Berg's blog that individuals who were assisting with
Berg's website were hacking Berg's website. Linda even posted on the blog a third
p31iy blog called Politijab had hacked Berg's site. All of this was unfounded and
untrue.
98. In or about the end of February 2009, Linda called Berg's assistant and asked her
to attend a conference call. Berg's assistant, Lisa, told Linda she was not available to
call Berg. Linda called Berg and called Lisa back excited that Berg had agreed.
During the conference call, Berg gave out his e-mail address and told folks with
questions they could e-mail him. Berg hung up the call. One individual mentioned
he had some important material to send to Berg, Linda immediately stated "send the
e-mail to me at ncwwomensparty@;ml.com and I will make sure Berg gets it. Linda
told the caller not to send it to Berg's e-mail address." Berg never received the e
mail.
I:\FORMS\Liheri. Berg. Law Offices ofPJB. Adams and Oslella Complaint for Damages
36
99. On or about March 4, 2009, Linda began calling all the webmasters, moderators
and past volunteers of Berg's website telling thcm that Lisa, Berg's assistant was a
liar, she was deleting Berg's e-mails and phone messages, no one could reach Berg
and slandering Berg's assistant, she was hostile with some and harassing others. Berg
and his staff received numerous complaints regarding Linda's unacceptable
behaviors. Berg's assistant statcd she would quit, as the false rumors of Linda's were
not helping thc cause. Berg cut all ties with Linda at that time.
100. On or about March 6, 2009, Linda continued her unacceptable behaviors,
badmouthing Lisa, Berg's Assistant, badmouthing and slandering Berg, harassing
people from Berg's blog, etc. Linda made derogatory remarks about Berg and Berg's
assistant, Lisa, on Berg's website blog. Linda's last post was:
Re.~t{~J;lL.DisQ)SS ioo.J.Q12i.~..Lrm11VJ22..:_Q3.LOj'j.Q_~
. by Linda Starr on Today, 23:23

I am done with all the lies, false accusations, trashing and
vicious crap that has been done to me since January by
certain people around here. They tell me my services are no
longer needed and I am not welcome here. I spent all these
months doing nothing but working my butt off for Phil and this
cause and I'm out. No explanations except for more lies told
about me...and Phil won't even talk to me after over a 10
year friendship!! How's that one? Lisa wants the trolls to take
over and everyone knows Phil jumps to her tune, or so she tells
it.
101. As a result, Linda was completely banned. Before being banned, Linda took
Berg's blog database of e-mail addresses. After being banned, Linda sent the
following c-mail out via her nc\v\vomcnS12artY(llli!.Q].com e-mail address as a mass
mailing on several different datcs to hundreds of people including Berg's Expert
Witncsses, Berg's supporters, attomey's Berg works with on other cases, Berg's
l:\FORMS\Liberi. Berg. Law Offices ofPJB, Adams and Ostella Complaint for Damages
37
contributors. Defendants Orly Taitz, Mr. & Mrs. Hale, etc. only a few are attached for
this Honorable Court's review:
Original Message ----

From: [email protected]
To: [email protected]
Sent: Saturday. March 07,2009 1:26 AM
Subject: I am sorry to tell you aiL ..
but my affiliation with Obamacrimes.com and Phil J Berg has

come to a unhappy parting of the ways. I cannot abide the
lies, false accusations and trashing of me when I discovered
some less than honest dealings were going on. One lie after
another has been told to me and about me! I have given
this cause and Phil everything in my being since last July,
when my research really began in June.
Maybe in a few days I will be able to talk about if,

but my stomach is churning tonight and I am heartbroken at
the betrayal of me after a 10 + year friendship was ended
tonight, where Phil was not even willing to listen to me or even
tell me what it is I am supposed to have done, this time. I will
try to make a more complete statement in a day or two.
I am certain that Barry Soetoro is not a US citizen, but we

need people with more integrity to pursue this cause.
Jlda __Starr
JowuL'" new Wonwn& Parlg
Feminism: (noun) the radical notion that women are people.
Well behaved women seldom make history!
On Sat, 3/7/09. [email protected]
<[email protected]> wrote:
From: [email protected]
<~ ewworne-'1sparty@aol.~orn>
Subject: Re: Fw: I om sorry to tell you all ...
I:\FORMS\Liberi, Berg, Law Offices of PJB, Adams and Ostella Complainl for Damages
38
She didn't like it that I could reach Phil and she wanted to
shut off that line of communication. I got him on your call
and she didn't like that at all. And the fact that I defied her
and did it anyway ticked her off a lot. She wants all the
attention I am guessing. I found out things about her that
were just awful from Kat who quit 3 days ago.
She wouldn't say what she found, she told me to do a search

for "Lisa Liberi" maiden name of Richardson out of
NM formerly of San Bernadino, CA
An honest person doesn't stand a chance against a lying charlatan.
JJndaStarr
:JoumL,., new WomeIU Pari1l

--- On Sat, 317109, [email protected]

<Newwomensparty@ao/.com> wrote:
From: [email protected] <[email protected]>

Subject: Re: Fw: I am sorry to tell you all ...
No one can reach him. she controls all his e-mail and all his
phone messages. she deletes what she doesn't want him to
see or hear.
J!inlo. __~arr
:JoumL'" new WonwIU pari,!

[email protected] <Newwomensparty@ao/.com>
wrote:

Subject Re: Fw: I am sorry to tell you all...
I shouldn't tell you what Kat found out about her and told me
to search for today, It is shocking, but there is a problem with
MY credibility? This explains why she doesn't become
l:\FORMS\Liberi. Berg, Law Offices ofP.TB, Adams and Ostella Complaint for Damages
39
a licensed attorney in her own right. Convicted felons can't.

Do NOT let either Phil or Lisa know I told you about this. No
telling what that nut would do to me or my family.
Mortgage Fraud Blog - New Mexico Woman Sentenced in

Identity Theft and_Real El>tate Frqud
Thursday, April 10, 2008

New Mexico Woman Sentenced in Identity Theft and Real
Estate Fraud
lisa Uberi aka lisa Richardson, 42, New Mexico, was
t
sentenced in connection with felony charges involving

identity theft and forged documents. Liberi appeared in San
Bernardino County, Rancho Cucamonga, Superior Court, on
March 21, 2008. She was sentenced to a state prison term of
8 years, imposed but stayed, and placed on supervised
probation for 3 years as part of a plea agreement. Uberi was
sentenced on ten felony counts ranging from Grand Theft,
Forgery, and Filing False Documents.
From 2000 to 2004, liberi engaged in a complex fraud
involving falsification of police reports, manipulation of credit
bureau reports, loan fraud, and counterfeiting of court
documents resulting in hundreds of thousands of dollars in
losses to banks and credit unions.
In 2002, San Bernardino County Sheriffs Department
personnel arrested Uberi on theft by false pretense charges.
In July 2004, Investigators from the San Bernardino County
District Attorney's Real Estate Fraud Unit arrested Uberi at the
Ontario International Airport for additional felony charges
while she was out on bail.
l
; ;; i
JJnla _){arr
.?. ounde,., new WomeM pari,!
Feminism: (noun) the radical notion that women are people,

I:\FORMS\Liheri, Berg, Law Oftices of PJB, Adams and Ostella Complaint for Damages
40
Subject: New site www.ObamaCitizenshipDebate.com
To: [email protected]
Date: Wednesday, March 18,2009,6:45 PM
As you've probably noticed, there have been changes to the OC Board
discussions lately. Everything from additional Agents, to subtraction of
Agents and members, to Obots being allowed back to the board and to
be placed into positions of trust as Moderators/Agents. A lot has been
going on behind the scenes, as well as on the OC board itself.
I'm sure you're not happy with what's going on. We aren't, either. It's
counter productive to having discussions, when you're busy rehashing 6
month-old arguments with people who are purposely derailing every
discussion. So a group of us got together, including former
Moderators/ Agents, and decided it was time to do our own thing.
We've decided to create our own board. It will be an atmosphere that is
Obot-FREE. Our core group want nothing more than Justice for the
usurper in our Office. We can have flowing discussion, like we had
before the changes at OC. Also, there may be some pleasant surprises in
store, on the new board. Surprises that will definitely be a HUGE benefit
for this cause. We aren't limiting ourselves to discussions of anyone
attorney or effort. We want to raise public awareness of all the efforts
to expose the truth and remove the Usurper from office.
We'd like to have you join us at our new site, if you are interested in
truth and justice. Please invite others to join, but only invite those who
you're SURE are with US, not THEM. This will ensure progress in our daily
discussions. We are implementing a screening process to insure only like
minded individuals are accepted into our ranks. Welcome to our friends.
Thanks.
The Administration Team at ObamaCitizenshipDebate
oflnda Starr
:JQunler, new Womeru pari"
Lisa
to
Liberi
date Mar 20,20099:48 PM
subject
mailed-by
Lisa, below is the e-mail Linda sent to Amboy Duke, the guy she thinks is
I:\FORMS\Uberi, Berg, Law Offices ofPJB, Adams and Ostella Complaint for Damages
41
Ted Nudgent. Amboy Duke is not Ted Nugent but someone from another
blog.
Thank you for responding. I am glad to hear from you again. I was
beginning to think you got frustrated and quit. I have a new effort
and site that is very exciting to a lot of people who are following me,
having gotten disgusted with Phil.
We just got the new site up and plan to raise public awareness for
all the cases. This way I have not publicly gone against Phil, whose
efforts I truly do not want to harm, or diminish his chances to win
any of his cases. He deserves credit for all his hard work when he
was the only one willing to take action and the first to file suit. He
has worked tirelessly, but unfortunately, he won't win because there
is a serious problem with Lisa and Barry's people are going to hurl it
out in the court and that'll be it for all the cases.
Berg supporters know something very bad happened to make me

leave (which it did), but I do not intend to make it a public issue.
Many of them did and a lot of people left and convinced me to do
my own campaign and are following me now. It's because I was
accused of terrible things by Lisa that are simply not true and I
defended myself, but only with a handful of people. Phil believed
her and I was forced out. Then he wrote me another nasty e-mail
basically trying to intimidate me into silence about Lisa, which
wasn't necessary because I wasn't the one who exposed her issues
as I was accused of doing. I didn't even know it, but she has some
major credibility problems that I don't want to get into.
We believe our time is better spent raising public awareness for the
efforts of everyone. Phil shouldn't be slamming Orly Taitz just
because she's making a lot of noise and getting a lot of attention. I
told him not to be slamming her, but now that I'm forced out, he is
listening to Lisa. It looks like sour grapes. My role was both
cheerleader and attack dog since I could do that as a volunteer.
Lisa has allowed trolls to take over and even become moderators. I
don't know if she's getting blackmailed by them or what, but it's a
very toxic environment and people just don't want to be there, and
that includes financial supporters who wonder now how their
donations have been spent. It got so bad that you saw the results
when you kept asking questions. And it's was never that way
before. Posters welcomed the chance to answer questions. My site
will be like that and we will have a section that isn't up yet, to list the
facts and answer most of the pertinent questions. You will be able
to go to one place and get answers without having to sort through
1000's of blogger posts.
I:\FORMS\LiberL Berg, Law Offices oHm, Adams and OsteUa Complaint for Damages
42
I used to be a guest on a lot of radio shows talking about my

findings exposing various scandals and crimes. I am going to start
doing that again to reach a larger audience. Me and the others who
came with me to start this new effort feel that if we can raise the
public awareness to a level that 100 million people are demanding
Barry produce the proof, or that the DOJ arrest and remove him to
prosecute for all his many crimes in illegally usurping office as
POTUS.
My efforts will not conflict with Phil's, but I feel compelled to say,
please don't get involved with him. I no longer trust Phil or his
Judgment after he was willing to listen to outright lies about me
made by Lisa. You don't throw someone under the bus after being
friends for more than 10 years, especially not your main
cheerleader who fires people up to support the cause. Like I said
before, this is no catfight. It's a major integrity issue. Lisa is a
pathological liar and it really pains me to say that, but it's true. I
can't, in good conscience, possibly recommend you get involved
with Phil after what I learned. I don't want to say more in writing.
In answer to your second e-mail, no one contacted me on your

behalf. And if someone does, I will answer their questions in detail.
I have enough knowledge to do that and speak coherently on the
subject. In fact, I have been dOing that all along except for a few
legal questions. Now I know the answers so we don't necessarily
need anyone else to answer. I am raising funds to wage a media
campaign to raise public awareness, buying media ads and such.
And if you decide to help us, you will know exactly what we are
doing. My site is moving to another server today that is a better
place for our bloggers and security. My site is going to be bigger
than Phil's because a lot of the supporters who had another favorite
and scattered when their efforts failed, will join me and we'll support
them ALL
I look forward to speaking to you or someone on your behalf soon.
J:inda .slarr
Jountk,., new Women& ParlV
1:\FORMS\Liheri. Berg, Law Offices of PJB, Adams and Ostc11a Complaint for Damages
43
t02. On March 7, 2009, Linda caned the otlice and left a message for Berg stating
"Lisa is sending vial things out about me, she is bad mouthing me, she is deleting my
e-mail to you and she sent me e-mails admitting it." Knowing the entire time these
were alllics and fabricated stories.
103. Linda called Berg and told him his Liberi had a criminal record and was stealing
Twelve Thousand [$12,000.00] Dollars per month from Berg's PayPal account and
was sending "vial" things around the internet about Linda. Linda went on further
stating Liberi had a criminal record going all the way back to the 1990's, all of which
Linda knew was false. Berg told Linda to send him an e-mail with all these e-mails
attached. Berg thcn called Liberi and asked for the same thing. Liberi sent Berg
thirty-seven [37] pages. Linda sent nothing.
104. As time went on, Berg sent e-mails to Linda asking for her list. Berg finally
received another nasty e-mail about Lisa stating Lisa didn't like what Linda had sent
on Thursday so Lisa deleted it. Berg asked Linda numerous times to resend the
"supposed" e-mail, Berg never received anything. Instead, Linda blocked Berg's e
mail address.
105. Linda sent the same accusations outlined above via e-mail to a private
investigator named Neil Sankey with The Sankey Finn and Sankey Investigations,
Inc. Instead of investigating the information Sankey e-mailed the infonnation along
with Liberi's Social Security number, date of birth and where she lived to a Reporter
at World Net Daily and to Orty Taitz. [see above under "Factual Allegations
pertaining to Orly Taitz, et al" and Factual Allegations pertaining to Sankey, et a1."]
106. Linda's behaviors continued and she then began contacting moderators on Berg's
website blog. Linda was attempting to lure all of Berg's moderators over to her new
I:\FORMS\Libcrl, Berg, Law Offices of PJB, Adams and Ostella Complaint for Damage~
44
website. Linda was also attempting to steal Berg's supporters. It was later
discovered Linda was in fact the individual with an extensive criminal record dating
back to ] 992 through 2007 for Theft, Fraud, and Fraud by Check, etc., according to
the Texas Depmiment of Public Safety and according to a criminal background check
run on her by her Social Security number.
VIII. FACTUAL ALLEGATIONS RELATING TO EDGAR (ED) HALE,

CAREN HALE, PLAINS RADIO NETWORK a/ka/ PLAINS RADIO
NETWORK, INC. a/kla PLAINS RADIO, a/kla BAR H FARMS and
KPRN AM 1610
herein at length.
108. Defendants, Mr. and Mrs. Hale began operating a radio pro !:,Tfam, Plains Radio,
through a tower, which they own, KPRN. The Radio show is an internet radio show
that is broadcast through different stations. Plains Radio also has a website and chat
room located at plainsradio.com. that Mr. and Mrs. Hale worked.
109. In or about June 2008. Mr. and Mrs. Hale contacted Evelyn Adams and requested
she co-host their radio shows on Plains Radio Network, an internet radio show. Mrs.
Adams quit and left Plaintiffs radio show on or about August 21, 2008. Defendants
Hale banned Mrs. Adams computer IP address from his website located at
http://vv'w\v.plainsradio.com, thus Adams could not access his website at all as she
was permanently banned.
110. Shortly thereafter, Adams began hosting another show, Momma E Radio Rebels
and co-hosted shows on Monks Media. Once Adams began with her own show,
Defendants Mr. & Mrs. Hale began slandering Adams name on their radio show,
I:\FORMS\Liberi, Berg. Law Offices ofPJB, Adams and Ostella Complaint for Damages
45

LIBERI V TAITZ (E.D. PA) - 1 - COMPLAINT - Gov - Uscourts.paed.302150.1.0

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LIBERI V TAITZ (E.D. PA) - 1 - COMPLAINT - Gov - Uscourts.paed.302150.1.0

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ER

Case 2:09-cv-01898-ER Document 1 Filed 05/04/09 Page 1 of 45

~'7.:;-O Law Offices of

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

PHILIP J. BERG, ESQUIRE

THE LAW OFF1CES OF PHILIP J. BERG

ORL Y T AITZ, a/k/a DR. ORL Y TAITZ, a/k/a :

and to 1000's of undisclosed recipients, requesting the infonnation to be posted on websites

have been severely damaged as outlined herein.

II. JURISDICTION AND VENU:f~

Constitution and 28 U.S.C. § 1331.

3. Venue is proper in this Court under 28 U.S.c. § 139l(b).

4. Plaintiff, Lisa Liberi [hereinafter "Liberi"] is an adult individual with a business

5. Plaintiff, Philip J. Berg, Esquire [hereinafter at times "Berg"] is an adult

Court, Suite 12, Lafayette Hill, PA 19444-2531;

7. Plaintiff: Evelyn Adams [hereinafter at times "Adams"] is an adult individual with

a residential address of Route 1, Box 106 BB, Wynnewood, Oklahoma 73098;

8. Plaintiff, Lisa M. Ostella [hereinafter "Ostella"] is an adult individual with a

residential address of2227 US Highway 1, #245, North Brunswick, NJ 08902-4402.

9. Plaintiff Go Excel Global is a Web Communications company owned and

operated by Lisa M. Ostella with a business address of 2227 US Highway], #245,

North Brunswick, NJ 08902-4402;

WWW.ORLYTAr(ZESQ.COM alk/a WWW.REPUBX.COM a/k/a orty Taitz, [nco

[hereinafter "Taitz"] is a licensed Attomey with a business addresses of 26302 La

11. Defendant, Defend our Freedoms Foundation, [nco is incorporated as a non-profit

Mission Viejo, CA 92691;

address of 31912 Monarch Crest, Laguna Niguel, CA 92677;

14. Defendant Sankey Investigations, Inc. is incorporated in the State of California.

investigation Company. Sankey Investigations has a business address of Post Office

Valley, California, 93063;

16. Defendant James Sundquist [hereinafter "Sundquist"]~ is an adult individual,

Road, Suite 123, Upper Montclair, New Jersey 07043;

www.obamacitzenshipdebate.org [hereinafter "Linda"] is an adult individual with a

home address of20 1 Paris Street, Castroville, Texas 78009-4516;

Wellington, Texas 79095;

Bowie Street Wellin!:,11:on, Texas 79095;

23. Defendant, KPRN AM 1610 [hereinafter "KPRN"] is a business owned and

Bowie Street, Wellington, Texas 79095; and

Fanns and Mr. and Mrs. Hale.

IV. FACTUAL ALLEGATIONS RELATING TO ORLY TAITZ alkla

complaints in Sacramento, California on behalf of Alan Keyes and other Plaintiffs

Ban'y Soetoro a/k/a Barack H. Obama citizenship issues'. Ironically, Taitz

Offices of Philip 1. Berg.

non-profit Organization with a Federal Tax Identification number of 26-4328440.

added to drorly.blogspot.com. This program was collecting information from

software on December 24,2008.

Taitz's website located at drorly.blogspot.com. Most computers are set up with

security tirewalls that do not allow easy data collection.

29. Ostella purchased and owned the defendourfreedoms. us and

were and are on Ostella's web accounts.

30. DefendOurFreedoms.org, owned by Lisa Ostella was and is hosted at Ostel1a's

31. As for DetendOurFrecdoms.us, that was hosted at GoDaddy under Ostel1a's

Specifically, it pointed to QuickBlogcast. This is very important to understand. A

address. GoDaddy would have had to issue a notification to all customers. Of

explained to Taitz her websites had never been hacked.

associated with her PayPal account oriy.taitz(lzJ,gmail.com to

Breaking and entering into my Paypal account

Taitz claimed, which Taitz was well aware.

U.S. Supreme COUl1 Justices 4 seeking help in an investigation regarding a criminal

thil1y [30] days so she would be able to find a new host.

Ostella told Taitz she had to immediately move her sites.

transfer request and the transfer process started.

b.!.tQ)Idcfcndourireedoms.net/2009/04/ 14!understand ing-thc-intcrnet-I 02-

----- Original Message ----

Subject: Re: IMMEDIATE I Dr. Orly Taitz I Redirect

----- Forwarded Message ----

To: "mark westmann" <!Il\vestJlwnn 13(c/Jgmail.com>, "Ed Hale