Liberi Taitz Request For Default 2009-06-02
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Law Offices of: Philip J. Berg, Esquire 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Identification No. 09867 (610) 825-3134
Attorney for Plaintiffs
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
PHILIP J. BERG, ESQUIRE, et al, Plaintiffs, vs. ORLY TAITZ, et al, Defendants.
: : : : : : Case No.: 09-cv-01898-ECR : : : :
REQUEST FOR ENTRY OF DEFAULT JUDGMENT Plaintiff, the Law Offices of Philip J. Berg, by and through its undersigned counsel, Philip J. Berg, Esquire, hereby request that Entry of Judgment by Default be entered for a sum certain, as outlined in Plaintiff’s Complaint and Counsel’s Declaration, against Defendant, collectively, jointly and severally, Defend our Freedoms Foundation, Inc. a/k/a Defend our Freedoms Foundation, pursuant to Federal Rule of Civil Procedure 55(b). In support of this request, Plaintiff relies upon the record in this case and the Declaration of Counsel submitted herein. Respectfully submitted,
Dated: June 2, 2009
s/ Philip J. Berg ____________________________ PHILIP J. BERG, ESQUIRE 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Attorney for Plaintiffs
Z:\Berg, Request for Entry of Judgment by Default against Defend our Freedoms Foundation, et al
1
Law Offices of: Philip J. Berg, Esquire 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Identification No. 09867 (610) 825-3134
Attorney for Plaintiffs
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
PHILIP J. BERG, ESQUIRE, et al, Plaintiffs, vs. ORLY TAITZ, et al, Defendants.
: : : : : : Case No.: 09-cv-01898-ECR : : : :
DECLARATION OF PHILIP J. BERG, ESQUIRE IN SUPPORT OF PLAINTIFF’S REQUEST FOR ENTRY OF JUDGMENT BY DEFAULT I, Philip J. Berg, Esquire being first duly sworn under oath, state the following: 1.
I, Philip J. Berg, Esquire, Counsel for Plaintiff, the Law Offices of Philip J. Berg, in the above-entitled action am familiar with the file, records and pleadings in this matter.
2.
The Complaint was filed and the Summonses were issued on May 4, 2009.
3.
Defendant, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms, was personally served with a copy of the Summons and Complaint on May 5, 2009, as reflected on the Dockets by the Proof of Service filed on May 7, 2009.
4.
Defendants, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms, Answer was due on the Complaint by May 26, 2009.
Z:\Berg, Declaration in support of Judgment by Default
1
5.
Defendant has failed to appear, plead or otherwise defend within the time allowed and therefore, is now in default.
6.
The Default of Defendant was entered on May 27, 2009.
7.
Plaintiff has sued for a sum certain as outlined in the Complaint.
8.
As required by the Servicemembers Civil Relief Act of 2003, I have confirmed that the Defendant is not currently in active military service.
9.
To the best of my knowledge, information and belief, Defendant is not an infant or incompetent person.
10.
Plaintiff requests that the Clerk of the Court enter Judgment by Default in favor of Plaintiff, the Law Offices of Philip J. Berg, and against the Defendant, collectively, jointly and severally, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms in the amount of Forty-Six Million [$46,000,000.00] Dollars pursuant to the Federal Rules of Civil Procedure, Rule 55(b)(1). Respectfully submitted,
Dated: June 2, 2009
Z:\Berg, Declaration in support of Judgment by Default
s/ Philip J. Berg _____________________________ Philip J. Berg, Esquire Attorney for Plaintiffs’
2
Law Offices of: Philip J. Berg, Esquire 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Identification No. 09867 (610) 825-3134
Attorney for Plaintiffs
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
PHILIP J. BERG, ESQUIRE, et al, Plaintiffs, vs. ORLY TAITZ, et al, Defendants.
: : : : : : Case No.: 09-cv-01898-ECR : : : :
CERTIFICATE OF SERVICE
I, Philip J. Berg, Esquire, hereby certify that a copy of the Law Offices of Philip J. Berg’s Request for Entry of Judgment by Default; Declaration in Support of Request for Entry of Judgment by Default; and Proposed Default Judgment were served this 2nd day of June 2009 via United States Postal Service with postage fully prepaid upon the following: Defend our Freedoms Foundation, Inc. a/k/a Defend our Freedoms Foundation 26302 La Paz, Suite 211 Mission Viejo, CA 92691
s/ Philip J. Berg ________________________ PHILIP J. BERG, ESQUIRE Attorney for Plaintiffs
Z:\Berg, Certificate of Service re Request for Entry of Judgment by Default, DOFF, et al
1
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
PHILIP J. BERG, ESQUIRE, et al, Plaintiffs, vs. ORLY TAITZ, et al, Defendants.
: : : : : : Case No.: 09-cv-01898-ECR : : : :
DEFAULT JUDGMENT
The Defendant, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms, having failed to plead or otherwise defend in this action, and Default having heretofore been Entered; and counsel, for The Law Offices of Philip J. Berg, having Requested Judgment against the Defaulted Defendant, collectively, jointly and severally, and having filed a proper Request and Declaration in accordance with Federal Rule of Civil Procedure, Rules 55(a) and (b) and upon the Declaration of Philip J. Berg, Esquire, that Defendant, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms, is indebted to Plaintiff, The Law Offices of Philip J. Berg in the principal sum of Forty-Six Million [$46,000,000.00] Dollars plus interest thereon; that Defendant, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms, had been Defaulted for failure to appear pursuant to Rule 55(a) of the Federal Rules of Civil Procedure; and that the claim is for a sum certain or for a sum which can by computation be made certain; it is hereby
1
ORDERED, ADJUDGED and DECREED that Plaintiff, The Law Offices of Philip J. Berg, recover of the Defendant, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms, collectively, jointly and severally, the sum of Forty-Six Million [$46,000,000.00] Dollars, plus costs and interest according to law from the date of this Judgment until the entire amount is paid. This Judgment is entered by the Clerk of the Court at the request of The Law Offices of Philip J. Berg and upon Declaration of Philip J. Berg, Esquire, Counsel for the Plaintiff, that said amount, outlined in Plaintiff’s Complaint, is due, in accordance with Rule 55(b)(1) of the Federal Rules of Civil Procedure.
Dated this ______ day of June, 2009
MICHAEL E. KUNZ, CLERK
By: ___________________________ Deputy Clerk
2
Attorney for Plaintiffs
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
PHILIP J. BERG, ESQUIRE, et al, Plaintiffs, vs. ORLY TAITZ, et al, Defendants.
: : : : : : Case No.: 09-cv-01898-ECR : : : :
REQUEST FOR ENTRY OF DEFAULT JUDGMENT Plaintiff, the Law Offices of Philip J. Berg, by and through its undersigned counsel, Philip J. Berg, Esquire, hereby request that Entry of Judgment by Default be entered for a sum certain, as outlined in Plaintiff’s Complaint and Counsel’s Declaration, against Defendant, collectively, jointly and severally, Defend our Freedoms Foundation, Inc. a/k/a Defend our Freedoms Foundation, pursuant to Federal Rule of Civil Procedure 55(b). In support of this request, Plaintiff relies upon the record in this case and the Declaration of Counsel submitted herein. Respectfully submitted,
Dated: June 2, 2009
s/ Philip J. Berg ____________________________ PHILIP J. BERG, ESQUIRE 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Attorney for Plaintiffs
Z:\Berg, Request for Entry of Judgment by Default against Defend our Freedoms Foundation, et al
1
Law Offices of: Philip J. Berg, Esquire 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Identification No. 09867 (610) 825-3134
Attorney for Plaintiffs
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
PHILIP J. BERG, ESQUIRE, et al, Plaintiffs, vs. ORLY TAITZ, et al, Defendants.
: : : : : : Case No.: 09-cv-01898-ECR : : : :
DECLARATION OF PHILIP J. BERG, ESQUIRE IN SUPPORT OF PLAINTIFF’S REQUEST FOR ENTRY OF JUDGMENT BY DEFAULT I, Philip J. Berg, Esquire being first duly sworn under oath, state the following: 1.
I, Philip J. Berg, Esquire, Counsel for Plaintiff, the Law Offices of Philip J. Berg, in the above-entitled action am familiar with the file, records and pleadings in this matter.
2.
The Complaint was filed and the Summonses were issued on May 4, 2009.
3.
Defendant, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms, was personally served with a copy of the Summons and Complaint on May 5, 2009, as reflected on the Dockets by the Proof of Service filed on May 7, 2009.
4.
Defendants, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms, Answer was due on the Complaint by May 26, 2009.
Z:\Berg, Declaration in support of Judgment by Default
1
5.
Defendant has failed to appear, plead or otherwise defend within the time allowed and therefore, is now in default.
6.
The Default of Defendant was entered on May 27, 2009.
7.
Plaintiff has sued for a sum certain as outlined in the Complaint.
8.
As required by the Servicemembers Civil Relief Act of 2003, I have confirmed that the Defendant is not currently in active military service.
9.
To the best of my knowledge, information and belief, Defendant is not an infant or incompetent person.
10.
Plaintiff requests that the Clerk of the Court enter Judgment by Default in favor of Plaintiff, the Law Offices of Philip J. Berg, and against the Defendant, collectively, jointly and severally, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms in the amount of Forty-Six Million [$46,000,000.00] Dollars pursuant to the Federal Rules of Civil Procedure, Rule 55(b)(1). Respectfully submitted,
Dated: June 2, 2009
Z:\Berg, Declaration in support of Judgment by Default
s/ Philip J. Berg _____________________________ Philip J. Berg, Esquire Attorney for Plaintiffs’
2
Law Offices of: Philip J. Berg, Esquire 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Identification No. 09867 (610) 825-3134
Attorney for Plaintiffs
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
PHILIP J. BERG, ESQUIRE, et al, Plaintiffs, vs. ORLY TAITZ, et al, Defendants.
: : : : : : Case No.: 09-cv-01898-ECR : : : :
CERTIFICATE OF SERVICE
I, Philip J. Berg, Esquire, hereby certify that a copy of the Law Offices of Philip J. Berg’s Request for Entry of Judgment by Default; Declaration in Support of Request for Entry of Judgment by Default; and Proposed Default Judgment were served this 2nd day of June 2009 via United States Postal Service with postage fully prepaid upon the following: Defend our Freedoms Foundation, Inc. a/k/a Defend our Freedoms Foundation 26302 La Paz, Suite 211 Mission Viejo, CA 92691
s/ Philip J. Berg ________________________ PHILIP J. BERG, ESQUIRE Attorney for Plaintiffs
Z:\Berg, Certificate of Service re Request for Entry of Judgment by Default, DOFF, et al
1
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
PHILIP J. BERG, ESQUIRE, et al, Plaintiffs, vs. ORLY TAITZ, et al, Defendants.
: : : : : : Case No.: 09-cv-01898-ECR : : : :
DEFAULT JUDGMENT
The Defendant, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms, having failed to plead or otherwise defend in this action, and Default having heretofore been Entered; and counsel, for The Law Offices of Philip J. Berg, having Requested Judgment against the Defaulted Defendant, collectively, jointly and severally, and having filed a proper Request and Declaration in accordance with Federal Rule of Civil Procedure, Rules 55(a) and (b) and upon the Declaration of Philip J. Berg, Esquire, that Defendant, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms, is indebted to Plaintiff, The Law Offices of Philip J. Berg in the principal sum of Forty-Six Million [$46,000,000.00] Dollars plus interest thereon; that Defendant, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms, had been Defaulted for failure to appear pursuant to Rule 55(a) of the Federal Rules of Civil Procedure; and that the claim is for a sum certain or for a sum which can by computation be made certain; it is hereby
1
ORDERED, ADJUDGED and DECREED that Plaintiff, The Law Offices of Philip J. Berg, recover of the Defendant, Defend our Freedoms Foundation Inc. a/k/a Defend our Freedoms, collectively, jointly and severally, the sum of Forty-Six Million [$46,000,000.00] Dollars, plus costs and interest according to law from the date of this Judgment until the entire amount is paid. This Judgment is entered by the Clerk of the Court at the request of The Law Offices of Philip J. Berg and upon Declaration of Philip J. Berg, Esquire, Counsel for the Plaintiff, that said amount, outlined in Plaintiff’s Complaint, is due, in accordance with Rule 55(b)(1) of the Federal Rules of Civil Procedure.
Dated this ______ day of June, 2009
MICHAEL E. KUNZ, CLERK
By: ___________________________ Deputy Clerk
2
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