Liberi V Taitz - Exhibit 27 - Toi Show Cause - Affidavit Of Mommae

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EXHIBIT “27"

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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

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Attorney for Plaintiffs

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA LISA LIBERI, et al, Plaintiffs, vs. ORLY TAITZ, et al, Defendants.

: : : : : : Case No.: 09-cv-01898-ECR : : : :

AFFIDAVIT OF PLAINTIFF EVELYN ADAMS a/k/a MOMMA E I, Evelyn Adams a/k/a Momma E, am a Plaintiff in the within action. I have personal knowledge of the facts herein and if called to do so, I could and would competently testify under oath. I declare as follows: 1.

As outlined below, Orly Taitz threatened to take Philip J. Berg, Esq. and

his Law Practice down. Mrs. Taitz stated to do so; she would destroy Mr. Berg’s Paralegal, Lisa Liberi and get rid of her. The other Defendants’ have made similar threats. It is apparent that all of the Defendants’ in this case, teamed up together, worked together and targeted Attorney Philip J. Berg, his Law Practice, his Paralegal, Lisa Liberi and anyone assisting Mr. Berg in Pennsylvania, which includes me and Lisa Ostella.

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From June of 2008 until August 21, 2008, I Co-hosted the No Obama

Plains Radio Internet Talk Show with Edgar (Ed Hale). I left the show due to a disagreement with Mr. Hale due to his unethical tactics. I could not take Mr. Hale’s “breaking news”; lies and distortions of the truth, and I certainly could not lie for him as he had asked me to do. I had already informed several people that I would be leaving the show on Friday the 22nd of August 2008. 3.

After discovering that Mr. Hale had misrepresented facts to me, I notified

Mr. Hale that I was informed of a different set of facts. Mr. Hale became very upset and accused me of calling him a liar, which I had not done. We made an agreement that I would not appear as co-host on his show August 21, 2008, however, I would give a statement as to why I was leaving his show. I told Mr. Hale I would state my reason for departure was due to causes I had taken on during the Presidential Primary. 4.

As better explained below, Mr. Hale’s attacks on me are some of the

worse slander, defamation and harassment I have ever heard or seen. I have never had to endure this sort of thing in my entire life and it has gone on for almost a year. It has gotten steadily worse and is continuing as of this date. I state that for the first time in my life I am actually afraid of someone, for Mr. Hale is so volatile that I really don’t know what he will do, or is capable of doing. 5.

All of the Radio Shows Postings from the Plains Radio Forum and Chat

Room were recorded and copied and sent to me. I did not record any shows, but did go and check out the postings to make sure they were what was actually posted on Mr. Hale’s website about me.

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I started my own Internet Radio Show on Blog Talk titled “MommaE

Radio Rebels” on August 26, 2008. The first time I ever discussed Mr. Hale was on 8-28-08 on MommaE Radio Rebels Blog Talk Show at 2 PM CDT.

I simply

answered what was asked of me, or what was told to me in ways of news about the Election. I did not and have not ever trashed, slandered or defamed Mr. Hale in any way on any Radio Show that I have been on. 7.

Philip J. Berg, Esquire filed the first action challenging the constitutional

eligibility of our now, President Barack H. Obama on August 21, 2008. Mr. Hale began having Mr. Berg on his radio station at Plains Radio towards the end of August 2008. 8.

In or about September 2008, I joined forces with Mr. Berg and handled

fund raising for him. There was a major supporter who would hold challenges to raise funds for Mr. Berg to help with the expenses of the litigation which Mr. Berg had pending regarding our now President Obama. 9.

As explained in more detail below, Mr. Hale was raising funds on behalf

of Mr. Berg and therefore working for Mr. Berg who is located in Pennsylvania and subjected himself to the Pennsylvania jurisdiction. When Mr. Berg and Mr. Hale parted ways, Mr. Hale, by his own statements, filed complaints against Mr. Berg with the Pennsylvania Supreme Court in attempts to have Mr. Berg’s law license revoked, again subjecting him to the Pennsylvania jurisdiction. Linda Belcher, Orly Taitz, Ed Hale and Neil Sankey all joined forces and targeted Philip J. Berg, Esquire and his Law Practice. These Defendants’ were attempting to destroy Lisa Liberi, Mr. Berg’s paralegal and trying to get rid of her so Mr. Berg would be unable to keep up with the

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litigation, thus “shutting” Philip J. Berg and his law practice down, as threatened by Orly Taitz. 10.

On September 6, 2008 I received an email from Mr. Hale accusing me of

calling him a liar about his “stats” on his website and radio program. Mr. Hale then calls me a “bitch” and tells me to get ready for Monday night, which I took as a threat. See EXHIBIT “A”. 11.

On September 8, 2008 Plains Radio “No Obama” show, hosted by Ed

Hale and Cece Hickey. Ed Hale states that I am not a professional, that I am a telephone yaker. He further states that I am not a professional that I want to do my old crony thing. He states that I am a thief, he says that I have sat out there and told lie after lie and that the truth is not in me. He says that 2 weeks ago he was drawing 2-1/2 million listeners a night and now he is down to 1.4 million listeners and that he has lost a million listeners due to my lies in 2 weeks. He stated that he is tired of it, that I sit over there with 15 or 20 people listening to my show. That I can’t stand it because I lost out on the best thing that there was. I took the side of a liar called Larry Sinclair and it is back firing in my face and now I was trying to take him down, knowing these statements to be false. 12.

On September 23, 2009, during his radio show, Mr. Hale states that he

knows a man that was bank rolling the Chicago Ad and he had pledged $7,000.00 up to $10,000.00 for that Ad. Mr. Hale states that he will send him an e-mail and call him on the phone to see if he can get him to pump that money over to Mr. Berg. Then Mr. Hale states that there is a gentleman out there by the name of Robert Long that was going to bank roll that Chicago Ad. Mr. Hale then states that he will contact

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that man, that they were going to raise $17,000.00 for that Chicago Ad and they are better off putting that $17,000.00 in this man’s (Philip Berg) hands. Mr. Hale then states that Mr. Berg is not a wealthy man that he is in hard times financially. He asks everyone to donate to Phil Berg. Mr. Hale was clearly soliciting and accepting donations for Mr. Berg. 13.

On September 24, 2009 Mr. Hale then got a call from Donna in Ohio, and

she stated that she is sending Mr. Hale a check for $50.00 and that it will be dated for the first of the month. Mr. Hale says that is fine and appreciates it and says he has bills to pay. Mr. Hale states that he and Caren pledged a $1,000.00 of their personal money to Phil Berg last night. Donna from Ohio says ok, then you can keep $25.00 and send $25.00 to Mr. Berg and maybe that will help him out. 14.

October 13, 2008 Clip #1 Plains Radio “No Obama” Talk Show. Hosts

are Ed and Caren Hale. Mr. Hale is accusing me and Lucy Orgain of making threatening phone calls about 4:00 AM to Phil Berg and to him saying that they were going to be killed, including Ed and Caren’s daughter, husband and children. Mr. Hale states that this is all a rigged deal by MommaE and her conspirators, he has proof, because the Obama Campaign went to work and they called him this afternoon and told him, who in the hell did it. Mr. Hale stated that he was going to use a word that Caren was going to cuss him for and Caren tells him not to use it, so he says “MommaE will crawl in bed with anybody that will give her a buck and that is what I have done.” Mr. Hale also stated that Cece and Patrick Hickey also got threatening phone calls and they didn’t want to come back on the show and they don’t know how people got their phone number. Mr. Hale stated “I have never attacked MommaE

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except that one time and that was in retaliation to what she said about me”. Again, knowing this information to be false. 15.

October 14, 2008 Plains Radio Clip #2 Plains Radio “No Obama” Talk

Show. Hosts Ed and Caren Hale. Mr. Hale then stated “I understood that Lucy, MommaE and this Phil Berg’s Assistant were going everywhere yesterday telling everything that they could, there’s a bunch of damn idiots over there.” Mr. Hale then states “I guess that MommaE is jealous because I have the bigger show.” 16.

October 20, 2008 I received an email from Ed Hale at 12:36:09 AM. Mr.

Hale calls me a moron, threatens to sue me (again) if I say one more word about him. Says I am nothing but a stupid jackass with the IQ of a moron. He says that all I do is tell lies and to stop it, or he will stop my ass. He says that I am nothing but an old woman that loves to gossip. He says that I am not worth a tinder dam and just as stupid.

He says that I think I can do a radio show, that I am uneducated,

unprofessional and above all else I lie. He states that I have no idea what dead air and all them dam uh make me sound like Obama. He says now stop or I will stop you in the courthouse. See EXHIBIT “B”. 17.

October 20, 2008 Clip #1 Plains Radio “No Obama/Lions Den” Talk

Show. Hosts Ed and Caren Hale. Mr. Hale states “Phil’s (Berg) case is so weak it’s not funny and what he’s doing is milking this damn thing for all the money he can get. He is in it for the money just like Larry Sinclair is in it for the money.” Mr. Hale goes on further stating “I would not trust Phil Berg any further than I can throw Larry Sinclair after what he did to me. Now I will tell you this much, there is another person out there that is probably the sorriest, low life bitch that I have ever had the

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un-pleasure of knowing and that’s MommaE. She is the worst pathetic person that ever walked on 2 feet, she sits over there and the only thing she’s got to talk about on her radio show is me…you know something I am going to trash you up one side and down the other, because I tell you something you and your cohorts over there have the intelligence of a moron or less and you know what I’m tired of it… I sent you that e-mail Saturday night that made me so damn mad where you were talking about me. You’re an idiot MommaE, you’re the most stupid ignorinest [sic] person that ever walked on 2 feet. You know something you’re a 70 year old woman that all you know how to do is just like all old women gossip… Your intelligence, lord a mercy don’t even bring me there…I tell you something you know, I can not believe that I helped you get this start and now you think you’re the goddess of the airways, but your not you’re the ass of the airways MommaE. I tell you something all you got is a bunch of lack minded idiots that listen to you that don’t have the intelligence to figure out that your nothing but full of bull… You’ll know how she got money, she claimed she got hurt out in California and she got a bunch of Workman’s Comp money and there wasn’t a damn thing wrong with her and she even told me that. She said she was fine, but she got several hundreds of thousands of dollars for a Workman’s Comp Case in California. She come back here to Texas to hide from California, I hope the State of California comes after her for Workman’s Comp Fraud.

Yeah I knew that to

MommaE… you’re about as low life as there ever was…” 18.

October 20, 2008 Plains Radio Clip #4 “No Obama/Lions Den” Talk

Show. Hosts Ed and Caren Hale. Randy calls into Ed’s show and tells Ed Hale that he is going to be the topic on MommaE’s show at 11 PM tonight. Randy says he

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thinks they need to go over there and give them some grief and see how they like it for a change talking about my show. Ed says “I tell you what why don’t you just call in and make her hang up on you. Caren states that we have caller ID and Ed states that Randy knows how to get rid of that Caller ID don’t you Randy”. Then Ed says “all you guys go and call in to MommaE’s show and tell her what a lying hussy she is and hit star 67 on the phone and she can’t tell who it is and Randy says that’s right it blocks your ID”. Lee in the chat “says to tell me the way and I’m going to make her remember my name”. Ed says “I don’t know the way to her show” and Randy says she is on My Two Cents”… Ed states “MommaE has got to be the ungodliness, stupidest, ignorantest [sic] woman that ever walked.” Ed says “I’m gonna tell you one thing, you know something MommaE, I’m warning you damn you, you say one word bad about me and I guarantee your gonna wish to hell you hadn’t”…Ed continues “Phil Berg I tell you what I knew you were in the tank with MommaE and I knew you were the one that started all this trouble and buddy I’m gonna get your damn Law License. I tell you another thing folks when Phil Berg says he does not have that Birth Certificate, he’s a lying SOB, because I can prove he got it”. 19.

October 20, 2008 Plains Radio Clip #5 “No Obama/Lions Den” Talk

Show. Hosts Ed and Caren Hale. Ed states that he is broke, that if it cost a nickel to use the bathroom, he’d have to throw up. While Ed in on the radio, Jewels in the Chat room, says she is gonna call into MommaE’s show and Ed says “ok Jewels I appreciate that, just let it rip, you’ll probably get hung up on pretty quick, you better have it down pat what your gonna say in a hurry, cause I guarantee they’ll hit that button so fast it’ll make your nose bleed.” Caren says “there may be a whole bunch

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of us calling in” referring to my show. Ed says “well I’ll tell you what guys I’ll appreciate it.” Ed then states “I know that one of the big reasons that I probably lost this tape if the tape exists is because of MommaE and Phil Berg. Im’ gonna do everything I can to see that Phil Berg loses his license. I have been told by a couple of Attorneys today that what he did was not only unethical but also border lines on illegality. Phil Berg you got it coming buddy, I tell you what I don’t care, your court case ain’t worth the paper it’s written on. I’ve had 3 different Attorneys tell me that and they have studied it, so you go on out there and sucker the people out of more money.” 20.

October 20, 2008 My-Two-Cents Blog Talk Radio Show. Host Matthew

Harris, Co-hosts MommaE and Philip. Ed Hale called into my show. He said he called in to apologize, that he was tired of the fighting, etc., and wanted to call a truce. I did not say anything the host and other co-host talked to him. I did make one remark, I said I have been called a bitch, a whore, a low life piece of shit and I can’t talk about this right now. When the show ended at 1 AM EDT, I found an e-mail in my Inbox from Mr. Hale that wiped out any “good” intentions he tried to convey earlier. See EXHIBIT “C”. 21.

January 5, 2009 Plains Radio “The Lions Den” Talk Show. Hosts Ed and

Caren Hale. Ed Hale begins his show stating “tell you what; I guess it is now time to move on and talk about the thief. I think all of you are aware that MommaE stole the divorce documents. I talked to Steve Pidgeon today and if they are not removed and she doesn’t go on the air and say those are Plains Radio documents that he would be willing to come to Amarillo, Texas. and file a million dollar Law Suit against her,

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Monks Media, Blog Talk Radio and Mark McGrew.” Mr. Hale is talking about the Obama v. Obama divorce papers from Hawaii which I received from Lisa with Philip J. Berg, Esquire’s Office. Caren Hale asks why Mark McGrew. Ed Hale states “because Mark McGrew was on her show and he was trying to tell everyone out there that Plains Radio Network had those documents, not MommaE.” Caren Hale states “Mr. McGrew states that those documents originally came from Plains Radio and MommaE said uh uh”. Ed Hale states “this woman is nothing but a thief, I have proved many times that she lies on her show and she has a bunch of idiots that sit over there and listens to her, she is the most pathetic, sorry person, low life that ever walked on 2 feet.” Ed Hale states “here’s where she is lying out her ass, I put those numbers on those pages and nobody else, I did not, was not stupid, each one of those numbers and you wanna know something there’s 4 other pages in the damn documents and I numbered them 1 through 12 and there were no missing pages, you lying heifer, you know something you just lied through your butt on that. Here’s where she is lying through her ass again, the Court in Hawaii you have to go and apply for these documents, you do not go and get those documents in a matter of hours, it takes 3 days, our PI applied for these documents on the 26th and he didn’t get them until the 29th, she’s lying through her damn teeth, this is the most worthless human being that ever walked on 2 feet.

Well I’m gonna tell you something

MommaE, I’m coming after you, I’m gonna land on you like a ton of bricks, unless those are removed and when you go back on the air and admit they were stolen from Plains Radio Network. You wanna know how I can get you, because those were not released for public viewing until 8:05 Central time and you admit that you had them

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on your damn web site at 2:30, at 2:30 they were not available for public view, so therefore they were not, I repeat they were not public news, you screwed up. I am so damn mad at that stupid ass. I proved that she is a dumb ass liar. Number one I proved that those numbers at the bottom of the pages are mine. That’s how I know this woman is lying out her ass, this is how I know she is nothing but a low life thief and all you stupid idiots that sit over there and listen to this lying heifer, you ought to be ashamed of yourself. There was a spy in here for MommaE, his name is Mountain Goat and I booted his ass last night and he was banned from this place. You know what he was one of the people that I gave a sneak preview to. You didn’t get it liar, you stole it, you’re a thief, I’m angry Caren I am angry , what she did to these people is unforgivable. She did it and claiming the fame for herself and she did nothing, and I’m gonna tell you something, if that bitch doesn’t go on the air and I’m not retracting that word and I got other words I’d love to say. If she does not go on the air and publicly say she stole those documents from Plains Radio Network, I can assure you she won’t have a pot to piss in or a window to throw it out of when Steve Pidgeon gets through with her and Monks Media if you don’t fire her, you gonna go down to, Blog Talk Radio you don’t remove her, your going down to, I know you people got money and Steve Pidgeon is gonna love to get it. Now we’re coming after you, you got a choice, do what’s right, get rid of this lying thief or will take you down. I can prove beyond a doubt that she stole those documents from us.” 22.

On October 22, 2008, I received an email from a friend. This email was

from Ed Hale falsely accusing Philip J. Berg, Esq. of stealing the “Michelle Obama”

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tapes. Mr. Hale states in this email that he has reported Mr. Berg to the State Bar of Pennsylvania. See EXHIBIT “D”. 23.

On November 3, 2008, Mr. Hale put a post out about Mr. Berg on his

website located at www.plainsradio.com. Mr. Hale stated in his post that Mr. Berg was a crook, his cases were not going anywhere, that Berg had the Kenyan Birth Certificate and refused to file it and that Berg was broke and only in this for the money. See EXHIBIT “E”. 24.

On January 1, 2009, I received an email from Mr. Hale. In this email Mr.

Hale accuses me of stealing his “hosts” and telling lies about him. Mr. Hale then states “I am about to come down on your like stink on shit”. Ed Hale rants on and then calls Mr. Berg a “crook”. See EXHIBIT “F”. 25.

On January 4, 2009, I received another email from Mr. Hale. In this Email

Mr. Hale is accusing me of again taking his Obama v. Obama divorce decree. Mr. Hale goes on calling me a “fucking bitch”; a “fucking whore”; a “fucking good for nothing bitch”; a “fucking crook”, etc. Mr. Hale then threatens to again “trash” me and Mr. Berg. See EXHIBIT “G”. 26.

January 6, 2009 Plains Radio “The Lions Den” Talk Show. Hosts Ed and

Caren Hale. Ed states “My temper is flaring as usual, I hate to be taken out by somebody that lies, I don’t lie and I don’t go around stealing things. It is sad and pathetic when somebody will go out and steal something that somebody else has worked so hard for. I am upset and I am angry, I just confronted a lying thief, you know what she is going to have a Blog Talk Show, I would love for about 100 of you people to line up over there and tell her she’s a liar and a thief. Do a Blog Talk

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search under MommaE Radio Rebels and you will find her. She’s 72 years old, that picture she’s got up there makes her look like a beautiful young chick, I got news for you, she’s fat, ugly, grey headed and she has to use a walker to get around and she’s gonna be meeting her maker very soon I’m telling you that and for her to lie and to steal knowing that’s gonna send her to hell, I don’t know what the heck to tell you to do.” 27.

On January 10, 2009, I invited Pastor Wiley Drake onto my radio show.

Shortly after Mr. Drake agreed to appear, I received an email from him stating “I do a lot of shows, but based upon the reputation of MammaE and your deception I can not do your show”. See EXHIBIT “H”. I immediately called Mr. Drake and was told that Ed Hale had told him that I was a liar and could not be trusted. 28.

January 23, 2009 Plains Radio “The Lions Den” Talk Show. Hosts are Ed

and Caren Hale. Ed Hale says to Cort Wrowinsky “I am going to tell you something about Steve Pidgeon, he knew the day I found out that ole MommaE stole those Divorce Documents from Plains, I called Steve and talked to him, Steve was very much aware that this woman was a liar and a thief, now he went on her program knowing that that was nothing but a bunch of liars and a bunch of thieves, he degraded himself, I for one can no longer trust that man. That is exactly why I said I wouldn’t have Steve back on no more. We raised $10.000.00 for Steve and Steve knew and for him to go over there and associate him self with those known liars and known thieves and they’ve been proved beyond a doubt, that’s a slap in the face of everybody that donated to him and that’s the way I look at it…” Ed Hale says “ok, ok, alright I understand now, that lying damn bitch, Steve Pidgeon just sent me an e-mail

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or called Caren. She told him that her name was Evelyn Adams; he did not know it was MommaE until he was already on the air. So that’s the way the lying bitch did it, ok Caren see if you can get a hold of Steve. I tell you what that is sad and pathetic when she stoops down to that damn low to lie. You know that’s the kind of woman this piece of shit is and I don’t care if I get fined by the FCC and everybody else.” 29.

Also on January 23, 2009, someone posted a letter from Orly Taitz on Ed

Hale’s website at plainsradio.com regarding comments made by a radio show host, Michael Medved, that Orly Taitz felt were degrading and slandering. I find this post very interesting, since the Plaintiffs’ Lisa Liberi, Philip J. Berg, Esq, The Law Offices of Philip J. Berg, Esq, Lisa Ostella and Evelyn Adams aka MommaE have filed a Law Suit against Dr. Orly Taitz, Esq, et al for Slander, Invasion of Privacy; violations of Plaintiffs’ Right to Privacy; Libel; Cyber-Harassment; Harassment; Defamation, Placing the Plaintiffs’ in a false light before the public, etc.. It appears that when it happens to Mrs. Taitz, she wants the protection of the Law, but when she does it to someone else; she says that it is frivolous. She thinks the Law should protect her from this sort of treatment, but when we filed to protect our rights and families, she feels that the Law doesn’t apply to us and that the Courts should dismiss the Case. Mrs. Taitz and Edgar Hale whose web site this was posted on, with his full approval have done the same thing to all of the Plaintiffs’. The Defendants’ in this case have called the Plaintiffs’ liars, crooks, thieves, con-artists, criminals, every nasty profane name in the book on the radio, on their blogs/forums/we sites and even put out the personal identifying information of the Plaintiffs’, including Lisa Liberi’s social security number and date of birth. Mrs. Taitz has had false Police and FBI reports

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filed against Lisa Liberi and Lisa Ostella. Plaintiffs’ families and husbands have been threatened; all of them investigated for no good reason what so ever, without any permissible reason, or the permission of the Plaintiffs’. See EXHIBIT “I”. 30.

On January 24, 2009, Mr. Hale posted on his website at plainsradio.com a

criminal record which he claimed belong to me. Mr. Hale also sent this criminal record of another Evelyn Adams out via email to an unknown undisclosed amount of people. See EXHIBIT “J”. This by no means is a criminal record of mine, nor do I have any type of criminal record. 31.

January 26, 2009 Plains Radio “The Lions Den” Talk Show. Hosts Ed

and Caren Hale. Ed Hale states “Arlen Williams is part of the crowd that MommaE, Phil Berg and Linda Starr all hang out with.” Caren Hale asks who Linda Starr is and Ed replied “she is Phil Berg’s secretary that keeps trashing me over there on his (Phil Berg’s) site. I got news for you’ll if you donate a dime to that man you are the biggest fools that ever walked on 2 feet.” Ed Hale asks Caren if she remembers when Phil Berg was first on here how he was asking if we knew anybody that he could borrow $18,000.00 from cause he was losing his house. Caren says “no, I must have been doing something else.” Ed says “this man has never been into this, except for one thing and it is called money.” Ed Hale states “I have a pending litigation to have Mr. Berg’s license revoked and Caren you are aware of that” Caren replied “yes”. Ed Hale states “how in the hell can you make peace with people when they are out there trashing you.” Caren says “well you quit trashing and maybe they will stop trashing.” Caren says “Do unto others”. Ed says “I have never trashed Arlen Williams one bit and that he (Arlen) was out there telling lies how I was taking

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money, stealing money and get the law involved and that I should be in jail and this is a direct result of MommaE, Phil Berg and Linda Starr.” Ed says “these people have got the egos and they lie like dogs”. Ed Hale says “I am going to start to fight back, because if he doesn’t then it makes him look guilty. I wanna tell people why, I think they have a right to know what is going on with MommaE, Phil Berg and Linda Starr. In September we had private contacts with API these people over in Norway that had this tape of Michelle Obama, that tape was real, the guy wanted some kind of legal document relieving him of the responsibility and I called Phil Berg and told Phil what I needed, Phil said let me talk to the guy. I gave Phil the phone number and the next day it was plastered every where that Phil Berg was his Attorney and MommaE was on the radio on 4 different occasions saying that she had talked to, I don’t even remember his name now, Sammy whatever, that she talked to him 3 times on Sunday and 4 times on Monday. Then this guy came after me trashing, that woman and Phil Berg tried to steal those tapes from me, I created so much ruckus which I guess I shouldn’t have, that he refused to release the tapes. I got all of this evidence together I filed it with the State Supreme Court of Philadelphia, asking them to remove Phil Berg’s license. It will come up soon and they will remove that man’s license.” Ed Hale then states, “Hey I wanna fight with them. I am to the point and I thinks it is time to go on the attack”. Ed Hale states to caller Ralph “I put out last night that we had the Indonesian Passport in our possession and Linda Starr came out this morning on her blog site that Phil Berg has had it for months.” Ed Hale was actually talking about Philip J. Berg’s blog site located at www.obamacrimes.com.

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On January 31, 2009, I received an email with a post Ed Hale made on his

forum at plains radio.com. Mr. Hale was stating he did not cuss Steve Pidgeon he called me (MommaE) a bitch. See EXHIBIT “K”. 33.

February 3, 2009, I received an email with a post from Ed Hale’s site at

plainsradio.com. Ed Hale posted his post further calling me a liar, a thief and stating I stole his Obama v. Obama 1964 Divorce papers. See EXHIBIT “L”. 34.

On February 4, 2009 Plains Radio “Patriotic Music Show”. Host Ed Hale

and Phil. Ed Hale reads the Demand to Cease and Desist and Retract Libel. Mr. Hale states “I filed a Law Suit against MommaE and I set the Judge to have MommaE bring a certified copy of the 1964 Divorce Degree with the Court Seal embedded in it to the Court like I will provide.” Ed Hale states “Phil Berg is in Pennsylvania, and representing a client that is in Oklahoma and that means he (Mr. Berg) is practicing Law in Oklahoma without a License, wonder who needs to go to jail there.” 35.

March 13, 2009 Plains Radio Network (Mr. Edgar (Ed) Hale) files a Law

Suit against me claiming I had stolen the Obama v. Obama divorce papers from him and his website. See EXHIBIT “M”. Mr. Hale failed to properly serve me, so Mr. Berg’s office had to contact the Court to find out what the lawsuit was about. Mr. Berg filed a response in opposition to Mr. Hale’s lawsuit and the case was dismissed with prejudice. See EXHIBIT “N”. 36.

March 29, 2009 I received an email from Lisa Liberi, Paralegal and

Assistant to Philip J. Berg. The email was from Ed Hale filing a State Bar Complaint against Philip J. Berg for practicing law without a license. See EXHIBIT “O”.

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March 29 , 2009, I received an email from Lisa Liberi, Paralegal and

Assistant to Philip J. Berg. The email was from Ed Hale calling Lisa Liberi a liar. Attached to the email was a letter supposedly sent to the Judge in the Collingsworth County Court, however, the letter was never actually sent by Mr. Hale. Instead, Mr. Hale posted it on his website. See EXHIBIT “P”. 38.

March 31, 2009, a post appeared on Plains Radio Forum by a JD Smith at

2:58 AM. JD Smith is an alias used by Ed Hale. The post was nothing more than degrading, posting libel, falsely accusing Mr. Berg and me of crimes and that we were under investigation and were going to be arrested. See EXHIBIT “Q”. 39.

In or about the month of February 2009, Orly Taitz began putting

statements out about Philip J. Berg, Esquire and his paralegal Lisa Liberi. Orly Taitz stated that Berg’s cases against Obama were really Lisa Liberi’s cases and Lisa Liberi was the brains behind Berg. 40.

Towards the end of February 2009, Orly Taitz made the threat that she

was going to take Phil Berg down and to do so she was going to destroy Lisa Liberi; Berg’s Paralegal and get rid of her. 41.

On March 29, 2009, Mr. Hale placed on the right side of Plains Radio

website under the PayPal Button a remark about the Law Suit, a Button for Berg’s Motion and a Button for PRN response to Berg. The response to Berg is the letter that he never filed with the Court, but sent viral all over the Internet. 42.

March 31, 2009, I received an email from my attorney which he received

from Ed Hale titled “Response to your lies to the judge” Attached to this email was

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another letter Mr. Hale wrote to the Collingsworth Judge and sent to us as if he had filed it with the Court. Mr. Hale’s letter was not filed by him with the Court but instead posted on his website at plainsradio.com. See EXHIBIT “R”. 43.

April 13, 2009 The Dame Truth Blog Talk Radio Show.

Marnie and DrKate and their Guest is Dr. Orly Taitz, Esq.

Hosts are

Mrs. Taitz starts by

saying “a lot of things are happening. When I reported this to the FBI, I got an anonymous phone call telling me that there is a lady by the name of Lisa Liberi is a Paralegal working for Phil Berg, an Attorney that is pursuing the same issue. She has an extensive Criminal record and she was convicted of Identify Fraud, Forgery and Mortgage Fraud. I asked a Licensed Investigator and he came back with a report that things seem to be checking our. Indeed this woman by the name of Lisa Richardson Liberi that lives in the State of New Mexico, where she actually lives that has a Criminal record going back to 1990…I forwarded this information to Attorney Phil Berg and told him that she had access to his PayPal and that as an Officer of the Court I need to report this and you need to join me in reporting this and I have not heard back from him yet. transparencies.

When people are donating money there needs to be

You have to tell somebody, this needs to be checked.

I got

information from Mr. Neil Sankey, who is a Licensed Private Investigator, when you have people that have access to public funds to donations and a lot of donations you don’t want people with Criminal records any where near that.” When Orly Taitz was asked if it was possible that there were 2 different Lisa Liberi’s. Mrs. Taitz’s states “I was checking that, but as far as we could find, Liberi is her real name, but the information I got was that her name is Lisa, former name Richardson and I saw

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another former name of Courvell and from what he sent there is only one person with all of those names Lisa Courvell Richardson Liberi, resident of New Mexico. Her conviction was in San Bernardino, CA, we also saw that her husband, somebody by the name of Brent Liberi according to what they are saying is on Parole. This Private Investigator, Mr. Sankey has talked to the FBI Agent Nathan Le that was suppose to investigate my PayPal tampering and he has reported this as well and he also reported this to the San Bernardino Police Department and I believe DA as well and let them investigate this as well.” 44.

On April 13, 2009, Ed Hale posted on his website at www.plainsradio.com

a message titled “Dr. Orly has been scammed by Lisa Liberia (Phil Berg Assistant)” In this post, Ed Hale states Lisa Liberi has been stealing from Orly Taitz and other slanderous, libel information about Lisa Liberi, me, Philip J. Berg, Esq. and Lisa Ostella.. See EXHIBIT “S”. 45.

On April 17, 2009, I received several forwarded emails from individuals

which were originally from Orly Taitz. In these emails Orly Taitz had Dossier #6, again which contained Lisa Liberi’s full social security number, date of birth and other personal identifying information. Neil Sankey sent Orly Taitz and a Reporter with World Net Daily several emails, which are included in Mrs. Taitz Dossier #6. One email from Mr. Sankey contained Ms. Liberi’s full social security number, date of birth, and other personal identifying information. In another email Mr. Sankey put a copy of an unverified and untruthful article from mortgagefraudblog.com pertaining to “a” Lisa Liberi; however, Mr. Sankey altered this article and added “She has a criminal history going back to the 90’s”. See EXHIBIT “T”. In Mrs. Taitz Dossier

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#6, Mrs. Taitz added at the end supposed “Terms and Conditions of Probation” which has also been altered, number 8 was replaced with a smiley face, which was meant to entice Mrs. Taitz followers to act upon number 8, in attempts to have Mrs. Liberi further harassed. Neither Orly Taitz nor Neil Sankey had absolutely NO permissible purpose to access Ms. Liberi’s social security number or other personal identifying information; had absolutely NO permissible purpose to investigate Ms. Liberi; and had absolutely NO permissible purpose for sending Ms. Liberi’s social security number, date of birth and other personal identifying information out to over 140,000 people and businesses, including internationally.

Lisa Liberi has never

worked for Orly Taitz; Lisa Liberi refused to have anything to do with Orly Taitz. Lisa Liberi has provided paralegal services to Mr. Berg since 2007.

Orly Taitz

Dossier #6 is attached as EXHIBIT “U”. 46.

On April 22, 2009 I received an email from Orly Taitz entitled “New Blog

Address”. You will notice that attached to that heading was Dossier #6 about Lisa Liberi, which contains Lisa Liberi’s full social security number, date of birth and other personal identifying information. This Dossier was being sent out under all kinds of headings to thousands upon thousands of people over and over again. It was also being forwarded to me by other Blog owners and even the Co-host of my show, as will be proven in this Exhibit. See EXHIBIT “V”. 47.

On April 22, 2009, I received an email titled “Linda Starr Connection”

this was sent by some one whose name will be filed UNDER SEAL DUE TO FEAR OF RETAILATION! See EXHIBIT “W”.

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48.

On

April

Document 106-8

28,

2009,

Orly

Filed 08/26/2009

Taitz

posted

on

Page 23 of 37

her

website

at

http://www.orlytaitzesq.com/blog1/?m=200904 seeking Plaintiffs’ to have Arlen Specter, U.S. Senator of Pennsylvania, recalled. Mrs. Taitz was successful and was able to secure Plaintiffs’. See EXHIBIT “X”. 49.

At the end of April 2009, I contacted Neil Sankey. I asked Neil Sankey

why he obtained Lisa Liberi’s social security number. I also asked Mr. Sankey why he would put this information out without first verifying the accuracy. Mr. Sankey stated “I told Orly Taitz not to put the information out, that it was unverified”. I asked Mr. Sankey why he sent the information to the Reporter at World Net Daily. Neil Sankey denied this. I then read his own email to him, and Mr. Sankey asked where I had obtained the email. I told him Orly Taitz had it posted on her website. Mr. Sankey stated he would be happy to speak to Mr. Berg and clear this up, and “debunk” it. However, to date, I do not believe Mr. Sankey has ever followed through with his word. 50.

Mrs.

Taitz

then

posts

on

her

website

at

http://www.orlytaitzesq.com/blog1/?p=8 Dossier #6, which contains the full social security number of Lisa Liberi, her date of birth and other personal identifying information. Mrs. Taitz sent her Dossier #6 to over 140,000 people on April 17, 2009 and is continuing to send and have others send to this date. She sent it out under 2 headings, “More Explosive Information Dossier #6” and “New Blog/Site”.

Mrs.

Taitz, Edgar (Ed) Hale and Neil Sankey are not only sending this kind of information out about Lisa Liberi, but about Lisa Ostella and me. Mrs. Taitz calls on people that live in the States we live in to investigate and get all of the information they can about

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not only Lisa Liberi, Lisa Ostella, me, but our husbands, where we have lived, who our associates are, and especially whether my husband JD Adams and I had contact with Lisa Liberi when we lived in California. She tells people that she has to have this before they go to Court. In all of the Defendants’ posts, emails, etc. you will see where Mrs. Taitz is asking people to send these libel, degrading and falsified writings out, asking people to call and harass other people including Probation Officers, Police Departments, Sheriff’s Office, FBI, etc and asking for information on us and our husbands. 51.

Orly Taitz did not stop there. Orly Taitz was writing, posting and sending

emails with her articles about Lisa Ostella and Lisa Liberi, which were nothing more than falsified allegations, degrading Lisa Ostella, Lisa Liberi, me, and Philip J. Berg, libel, and done by Mrs. Taitz maliciously and with malice to humiliate all of us. The list includes the following and the actual documents to each post are attached hereto as EXHIBITS. EXHIBIT “U” “Dossier #6” Posted by Orly Taitz on April 17, 2009 Dossier contains the full social security number, date of birth and other personal identifying information of Lisa Liberi and other statements classifying the Plaintiffs’ in this case as “Obots” and President Obama’s “clique”. http://www.orlytaitzesq.com/blog1/?p=8 EXHIBIT “Y” “Follow up on Lisa Liberi, paralegal to Phil Berg” Posted by Orly Taitz on April 18, 2009 This post calls for the “purging” of President Obama and his “clique”, who Plaintiffs’ herein have been labeled. http://www.orlytaitzesq.com/blog1/?p=36

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EXHIBIT “Z” “Every day I get such evidence of missing or misdirected funds” Posted by Orly Taitz on April 19, 2009 http://www.orlytaitzesq.com/blog1/?p=119 EXHIBIT “AA” “Update on Lisa Ostella and Lisa Liberi” Posted by Orly Taitz on April 21, 2009 http://www.orlytaitzesq.com/blog1/?p=195 EXHIBIT “BB” “More attacks on me. More indepth research is done in spite of attacks” Posted by Orly Taitz on May 1, 2009 http://www.orlytaitzesq.com/blog1/?p=513 EXHIBIT “CC” “Check public records for yourselves, see that I am providing truthful information” Posted by Orly Taitz on May 5, 2009 http://www.orlytaitzesq.com/blog1/?p=759 EXHIBIT “DD” “I need two articles and update on Lisa Liberi” Posted by Orly Taitz on May 8, 2009 http://www.orlytaitzesq.com/blog1/?p=807 EXHIBIT “EE” “Information update on both Liberi and Obama” Posted by Orly Taitz on May 9, 2009 http://www.orlytaitzesq.com/blog1/?p=834 EXHIBIT “FF” “Update on Obama investigation and Liberi investigation” Posted by Orly Taitz on May 11, 2009 http://www.orlytaitzesq.com/blog1/?p=945 EXHIBIT “GG” “Comment from Lynda Starr about a 10 million dollar lawsuit filed against her by Phil Berg, Lisa Liberi and others” Posted by Orly Taitz on May 11, 2009 on both Orly Taitz, Esq’s blog and Linda Starr’s blog http://www.orlytaitzesq.com/blog1/?p=950 and http://obamacitizenshipdebate.org/2009/05/

Affidavit of Plaintiff, Evelyn Adams

24

Case 2:09-cv-01898-ER Document 106-8 Filed 08/26/2009 Page 26 of 37 EXHIBIT “HH” “I need to get more answers” Posted by Orly Taitz on May 13, 2009 (This is where she asks for people to find out if my husband and I had any connection to Lisa Liberi when we lived in California, if we lived in PA or NJ, if we had a record. It is the last paragraph in her post) http://www.orlytaitzesq.com/blog1/?p=978 EXHIBIT “II” Please write to your congressmen and senators” Posted by Orly Taitz on May 16, 2009 http://www.orlytaitzesq.com/blog1/?p=1055 EXHIBIT “JJ” “Voter verification” Posted by Orly Taitz on May 20, 2009 http://www.orlytaitzesq.com/blog1/?p=1249 EXHIBIT “KK” “Overview” Posted by Orly Taitz on May 22, 2009 See items number 3, 4, 5, 12, 13 and all paragraphs under item #15. http://www.orlytaitzesq.com/blog1/?p=1346 EXHIBIT “LL” “I am trying to stay away Liberi-Berg issue, but I got more questions and here is more info” Posted by Orly Taitz on May 31, 2009 http://www.orlytaitzesq.com/blog1/?p=1843 EXHIBIT “MM” “Update on Berg” Posted by Orly Taitz on June 15, 2009 Another slandering post about Philip J. Berg and Lisa Liberi. Orly Taitz also discloses information on a sealed case Mr. Berg had pending before the U.S. District Court, District of Columbia. The case was sealed pursuant to statute. http://www.orlytaitzesq.com/blog1/?p=2259#comments EXHIBIT “NN” “Ties to Everett, need help with research” Posted by Orly Taitz on June 22, 2009 This is where Orly Taitz gives Lisa Liberi’s place of birth; Mother’s maiden name; and other personal identifying information. http://www.orlytaitzesq.com/blog1/?p=2522

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“Unfortunately I have to spend more time on Berg’s latest motion, I have to provide a response” Posted by Orly Taitz on June 24, 2009 http://www.orlytaitzesq.com/blog1/?p=2579 EXHIBIT “OO” “I am back from PA. Very Important.” Posted by Orly Taitz on June 27, 2009 This is the vicious, vile posting of Orly Taitz accusing Lisa Liberi of placing a “hit” or “contract” on her sister who happened to pass away from a self inflicted drug over-dose. Orly Taitz called for a pathologist and asked her followers to contact the police department, probation department, the detective, Orly Taitz gave the phone numbers of said law enforcement, and give this information to them that since Lisa Liberi put a “hit” out on her own sister who ended up dead a year later, then she would have no thought about placing a “hit” on an attorney and her family who “outed” her. Orly Taitz also inferred that Lisa Liberi disconnected hoses on her (Orly Taitz) car, etc. http://www.orlytaitzesq.com/blog1/?p=2585 EXHIBIT “PP” “Smoking Gun” Posted by Orly Taitz on July 3, 2009 Response of Orly Taitz again telling people to send out Dossier #6 which contains Lisa Liberi’s full social security number, date of birth and other personal identifying information. http://www.orlytaitzesq.com/blog1/?p=2716 EXHIBIT “QQ” “Response to Patriot“ Posted by Linda Starr on May 20, 2009 This is another post degrading Philip J. Berg and Lisa Liberi and falsely accusing Philip J. Berg and Lisa Liberi of defaming her, harming her family, placing her and her family in danger, etc. http://obamacitizenshipdebate.org/2009/05/ EXHIBIT “RR” “Today is Lisa Liberi's 44th birthday!” Posted by Linda Starr on May 28, 2009 This post is again falsely accusing Lisa Liberi of banning people from Mr. Berg’s website because they are questioning her “criminal” record. Linda degrades both Lisa Liberi and Philip J. Berg. http://obamacitizenshipdebate.org/2009/05/may-28th-happy-birthday.html

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On May 06, 2009, Mr. Hale had a radio show which he called a “Special

Broadcast”. During this radio show, Ed Hale said that Phil Berg “is wanting to shut Plains radio and Orly Taitz down.” Ed Hale further states “I can destroy every one of those plaintiffs in that lawsuit. And the ones I cannot, Orly can, we are going to take Berg down. We are going to take all of his people down too”. Mr. Hale then makes threats to the other people in the case. 53.

On May 28, 2009, Mr. Hale had Neil Sankey on his radio program at

Plainsradio.com. Mr. Sankey stated Lisa Liberi had 200 criminal counts against her; that Lisa Liberi was re-arrested in 2004 for buying and selling houses; that Lisa Liberi manipulated credit reports and police reports to fake her own identity theft; that Lisa Liberi had defrauded banks and financial institutions out of hundreds of thousands of dollars; that people in San Bernardino were looking for Lisa Liberi and he (Neil Sankey) knew where she was and he would disclose where she is when it suits him; none of which was true. Mr. Hale then stated, “Lisa Liberi just took out another loan”. Neil Sankey then stated “Evelyn Adams made me say the information was unverified” and then Neil Sankey stated I was very bad and he was still investigating me. There is no way Neil Sankey or Ed Hale would have known if Lisa Liberi had taken out a loan or not unless they illegally accessed her credit reports (they had her social security number, date of birth, address and mother’s maiden name) or applied for credit in Lisa Liberi’s name without her knowledge or authorization. 54.

On June 12, 2009 I received an e-mail that Mr. Edgar (Ed) Hale sent to his

Attorney Ted Hoppe, titled “Adams destroies evidence – letter to Judge” See EXHIBIT “SS”.

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June 25, 2009 this Court had a hearing regarding our case. It is my

understanding from my attorney that your Honor warned Mrs. Taitz not to further distribute Mrs. Liberi’s social security number or it would weigh heavy in favor of the Plaintiffs’ and there were discussions in Court on how the Defendants’ were to conduct themselves. None of the Defendants’ listened to your Honor. June 27, 2009, upon Mrs. Taitz return home, she immediately posted on her blog “I’m Back from PA. Very Important” Mrs. Taitz did nothing except inferred Ms. Liberi put a “hit” or “contract” out on her sister and then “murdered” her sister, called for a pathologist, gave law enforcement phone numbers, probation department numbers, and asked for people to go into the police departments or call the law enforcement agencies and give this information to them about Lisa Liberi. Mrs. Taitz continued on claiming it is not inconceivable to believe that Lisa Liberi would put a “hit” or “contract” on her and her family. I am aware, Lisa Liberi’s did have a sister who passed away from a self inflicted drug over-dose. Ms. Liberi’s sister’s death was very hard on her family. Since your Honor denied our Injunction without Prejudice, this was just another way for Orly Taitz to put out malicious false statements about Lisa Liberi to degrade, violate the privacy of, harass and harm Lisa Liberi and her family. See EXHIBIT “OO”. 56.

The evening of June 25, 2009, Ed and Caren Hale and Linda Belcher a/k/a

Linda Starr had a radio show on Plains Radio. Linda Belcher and Ed Hale began threatening any witness for the Plaintiffs’ and any witness planning on giving an Affidavit for the Plaintiffs’. Linda Belcher stated that they will know who all the witnesses are who do affidavits because the witnesses have to give their real names

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and addresses. Ed Hale states “we will have their names”; “we will have their addresses”; “we will know who they are”; “we will go after them with a vengeance”; “and prove them a liar also”. 57. falsified

Dr. Orly Taitz is the one who has gone on Radio Shows and put out information

regarding

Lisa

Liberi,

filed

falsified,

unfound

and

unsubstantiated FBI, Police and Sheriff Department criminal reports against Lisa Liberi and Lisa Ostella and talked to DA’s and told others to do the same thing as well as contact and harass Probation Officers. Orly Taitz statements for doing these heinous things, especially to Lisa Liberi were that she, “as an Officer of the Court” had a duty to put these statements about Lisa Liberi out there.

“That anyone

associated with the Obama cases; fundraising and dealings with donations, as Lisa Liberi has, the public had a right to know.” Lisa Liberi has never done fundraising for Philip J. Berg, Esquire or anyone else for that matter. Lisa Liberi does not handle any of the donations which go to Mr. Berg, and Mr. Berg has announced publicly that no one has stolen from him and he is the only person who has anything to do with the money which comes in. 58.

It should be noted, sometime between May and June of 2009, Dr, Taitz

hired a “Law Clerk” by the name of Dr, Charles Edward Lincoln III. Mr. Lincoln has written her pleadings, Cook v. Good, et al , which Mr. Lincoln filed on Orly Taitz behalf in Georgia and was present at the hearing on the 16th of July as Orly Taitz Law Clerk. Mr. Lincoln has written and Orly Taitz pleadings Keyes v. Obama, et al that had a hearing on the 13th of July and again Mr. Lincoln was present as Orly Taitz’s Law Clerk. Mr. Lincoln was also present at the June 25, 2009 hearing before your

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Honor in our case, again as Orly Taitz Law Clerk. Now Dr. Taitz has made an issue out of the fact that Mr. Berg supposedly has a convicted Criminal working for him, Orly Taitz also put out Lisa Liberi’s social security number, mother’s maiden name, where Ms. Liberi was born, date of birth and other personal identifying information; has falsified law enforcement reports against Lisa Liberi; has had all her supporters and followers calling police departments, FBI, probation departments, district attorney’s, etc. about Lisa Liberi again with numerous falsified accusations against Lisa Liberi. Orly Taitz has even stated she is afraid for her life because of Lisa Liberi; inferred Lisa Liberi “murdered” her own sister; falsely accused Lisa Liberi of disconnecting a house from her car; and stated that the public needs to know because she is an Officer of the Court. Orly Taitz is having all of us investigated, without a permissible purpose, because we are all Criminal in her mind, as well as in the Hale’s, Belcher/Starr’s and Sankey’s minds. 59.

Now, Orly Taitz Law Clerk, Charles Edward Lincoln III has been in

Federal Prison has been Disbarred in Florida and California and would have been in Texas, but the Supreme Court accepted his resignation instead of State Bar Disciplinary.

The reasons for Mr. Lincoln’s disbarment is due to the fact he was

convicted of Federal Crimes of using a false social security number to open a bank account; for falsifying and forging the Federal Court Clerk’s receipts, then paying off his clients not to produce the forged receipts or appear in Court; has been jailed by the Federal Courts several times for “Contempt of Court”. See EXHIBITS “TT”. 60.

Obviously, Mrs. Taitz statements that the public had a right to know and

she, being an Officer of the Court had the duty to disclose all this information on Lisa

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Liberi, was a false statement. Instead, it is clear to me that Mrs. Taitz did this to Lisa Liberi to carry out her threats that she would take Mr. Berg down and would do it by destroying his Paralegal, Lisa Liberi and get rid of her, all of Philip J. Berg’s associates and anyone associated with Philip J. Berg, Esquire. The Defendants’ teamed up together, targeted Philip J. Berg, his Law Practice and his Paralegal, Lisa Liberi in Pennsylvania in attempts to take Philip J. Berg, his Law Practice and Lisa Liberi, his very able Paralegal down, again as Orly Taitz threatened. All of the Defendants’ actions were done maliciously, with malice, to harm and destroy the Plaintiffs herein. 61.

While this is not all of the evidence I have on all of the Defendants I am

going to stop here with the exhibits, but can and will produce not only all of this in Discovery and Court, including complete Radio Show Recordings, as well as the clips that were retracted from those shows.

These slanderous, harassing, defamatory

remarks were made on just about every show that Orly Taitz could get on, including Plains Radio. Even after the Law Suit was filed Dr. Taitz, Linda Belcher aka Linda Starr, Neil Sankey, Caren Hale and Edgar (Ed) Hale continued with their behavior on the Plains Radio Network “The Lions Den” and other shows on that Network with other Hosts. They have not only continued with the behavior that brought the Law Suit about, but the attacks and threats by them have gotten a lot worse and I have a complete recording of Radio Shows after the Law Suit was filed and Served the first week of May to date.

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Several other people have recorded all of the shows to date also, for fear

of Mr. Hale editing them, since he has the equipment to do that. The posts on their forums and chat rooms have also gotten a lot worse. 63.

On July 23, 2009, Orly Taitz set up a new website. In her new website,

located at www.orlytaitzesq.com. In reviewing her website she has links to her court cases; frequently asked questions; a link to her blog; and “supporting documentation”. When

clicking

on

supporting

documentation

it

takes

you

to

http://orlytaitzesq.com/supporting_documentation.htm where amongst other things, she has re-published Dossier #6. Please note, no other dossiers are located on this page, only Dossier #6 with Ms. Liberi’s full social security number. Mrs. Taitz new Dossier #6 has been changed only in the font size, Lisa Liberi’s full social security number is still present with Lisa Liberi’s other personal identifying information. See EXHIBIT “UU”. It should also be noted that Mrs. Taitz now has placed her Dossier #6 on this new website and also still has it published on her blog located at http://www.orlytaitzesq.com/blog1/?p=8. 64.

We filed for an Injunction in order to stop them from mentioning any of us

in any way on any Radio Show or their Blogs and Forums, but it has not been granted at this time. Mr. Hale told his listeners to donate to pay for their Attorney to fight our Law Suit because we had filed for an Injunction to shut him down and take him off the air, which your Honor knows is not true. 65.

Your Honor, you wanted to know why you would have jurisdiction and

not Texas or California. Only one of the Defendants lives in the Western District of Texas, Mr. and Mrs. Hale, Plains Radio Network, Inc., Bar H Farms, Inc. and KPRN

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1610 AM are in the Northern District of Texas and Dr. Orly Taitz, Defend our Freedoms Foundations, Inc.; The Sankey Firm, Inc. a/k/a The Sankey Firm; Sankey Investigations and Neil Sankey are located in the Central District of California. In addition, the only Defendant in Western Texas is Linda Belcher a/k/a Linda Starr and no other Defendants. 66.

I have not in any way, attacked these people and I do fundraising for

Philip J. Berg, Esq and have now for almost a year. Since Mr. Berg, the Law Offices of Mr. Berg, his paralegal and I have been attacked and targeted and I do work for him in a volunteer status then I believe that this Court has jurisdiction. If it was transferred I would have to be in 3 different jurisdictions in order to get the Justice that I am entitled to and deserve. I believe that Mr. and Mrs. Hale, Plains Radio Network, Inc., Bar H Farms, Inc., and KPRN 1610 AM have subjected their selves to this Courts jurisdiction by the fact they were fundraising for Mr. Berg, their statements about fundraising for Mr. Berg on September 23rd and 24th on their radio show and accepting a donation from Donna in Ohio for Mr. Berg. Mr. Hale has targeted Mr. Berg in Pennsylvania; targeted me for working for Mr. Berg in Pennsylvania; targeted Lisa Ostella in Pennsylvania and targeted Lisa Liberi in Pennsylvania. Mr. Hale also solicits and receives donations from all over the USA, including Pennsylvania. 67.

I also believe that Linda Belcher aka Linda Starr has subjected her self to

the jurisdiction of this Court by the volunteer work she did for Mr. Berg and by the statements she made telling people that she was the Administrator of his Blog. I believe that Dr. Orly Taitz, Esq., has subjected her self to the jurisdiction of this

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Court not only by targeting all of us, who are associated with Philip J. Berg in Pennsylvania; but soliciting and receiving donations from all over the USA, including Pennsylvania; by soliciting clients in Pennsylvania to recall Senator Arlen Specter; soliciting and signing up Plaintiffs’ in Pennsylvania for her military cases; and by her meetings in Pennsylvania meeting all of your elected officials. I also believe that Neil Sankey has subjected his self to this Court’s jurisdiction by his targeting Mr. Berg’s paralegal Lisa Liberi, which also targets Mr. Berg personally and his Law Offices. 68.

I pray that the Court and Honorable Eduardo C. Robreno agrees with me,

for at disabled 70 years old I would be hard pressed to be in 3 different jurisdictions for Justice and it would create an extreme hardship as my only income is social security and disability. I suffer from disabilities which make it difficult for me to walk or stand for periods of time. Also, the Defendants’ should all be tried together as they teamed up together to harm each and every Plaintiff. 69.

My attorney has explained to me what your Honor’s rules mean. I have

told my attorney I am not opposed to transferring our case to the U.S. District Court, Central District of California, Western Division located at 312 N. Spring Street, Los Angeles, California 90012. I lived in California for many years and still have friends I would be able to stay with while there for Court, in addition, it is far cheaper to fly into Los Angeles, California. Plus, the Defendants’ have all agreed to have the case transferred to California.

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I declare under the Penalty of Perjury of the Laws of the United States that the foregoing is true and correct. Executed this _____ day of July 2009.

_____________________________ EVELYN ADAMS, Plaintiff

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