liberi v tatiz (c.d. ca) - 283.2 - # 2 exhibit request for juicial notice of eclaration of liberi...

8/6/2019 LIBERI v TATIZ (C.D. CA) - 283.2 - # 2 Exhibit Request for juicial notice of eclaration of Liberi with full SSN - cacd-031012664326.283.2

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1 llDr. Orly Taitz, ESQ21129839 Santa Margarita pkwy, ste 1003 lln*"no Santa Margarita CA 92688

Attorney for "Defend our Freedoms" Foundation

UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIA * SOUTHERI\ DIVISION

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LISA LIBERI and PHILIP J. BEG,ESQTIIRE and THE LAW OFFICES OFPHILIP J. BERG and EVELYN ADAMSa/k/a MOMMA E and LISA M. OSTELLAand GO EXCEL GLOBAL,Plaintiffs,

VS.ORLY TAITZ, a/k/a DR. ORLY TAITZ,alWaLAW OFFICES OF ORLY TAITZ;a/k/a ORLY TAITZ,INC. and DEFENDOUR FREEDOMS FOTINDATIONS,INC. and YOSEF TAITZ and THESANKEY FIRM aNd SANKEYINVE,STIGATIONS, INC. and NEILSANKEY and JAMES SIINQUIST andROCK SALT PUBLISHING and LINDASUE BELCHER a/k/a LINDA S.BELCHER a/k/a LINDA STARR; alWaNEWWOMENSPARTY alWaSTITCHENWITCH a/k/ a EY A BRALTNa/k/a WEB SERGEANT alk/a KATY a/klaWWW. OBAMAC ITIZENSHIPDEBATE.ORG and EDGAR HALE a/WaJDSMITH; and CAREN F{ALE; and PLAINSRADIO NETWORK, alHa PLAINSRADIO NETWORK, INC. a/k/a PLAINSRADIO; and BAR H FARMS; and KPRNAM 1610; and DOES I through 200Inclusive,

CASE NO. 8:1 1-cv-00485-AG (AJW)Request for judicial notice ofDeclaration by Lisa Liberi in criminalcaseFWV 028000, where Liberivoluntarily entered in public recordher full unredacted social securitynumberBankruptcy petitions by Lisa Liberi,filed in 2000 and2002 with full,unredacted social security numbersCriminal record of Lisa Liberi fromSan Bernardino superior courtshowing 10 felonyconvictions ofgrand theft, forgery of an official sealand offer to file forged/altereddocumentsDate: August 8,2011Time: 10:00 a.m.Dept.: Crtrm 10D

Judge:Magistrate Judge:Trial Date:Complaint Filed:

Andrew J. GuilfordRobert N. BlockJune 5,2012May 4, 20A9

Defendants.

Case 8:11-cv-00485-AG -AJW Document 283-2 Filed 07/11/11 Page 1 of 10 Page ID#:6872


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/s/ Orly TaitzProof of service

I attest, that atrue and correct copy of the above pleadings was served on all the parties tothis action by ECF and/or e-mail on 07.11.201I

lsl Orly TaitzDECLA,RATION BY ORLY TAITZ, ESQ

I Declare under penalty of perjury, that Attached declaration of Lisa Liberi is a trueand correct copy of the declaration filed by Lisa Liberi in San Bernardino, CASuperior Court on September 21,2006 and signed under penalty of perjury by LisaLiberi. On the first page of the declaration, which is contained in public recordsLisa Liberi entered her full unredacted social security number. For the purpose othis filing I redacted the last four digits of Liberi's Social Security number.lsl OrIy Taitz



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}ECLARATI$N OF LISA LIBERI

I, Lisa Liberi, do hereby- declare thal:I am the deftsdant in the witiria a*ti** aad avu making this Declaration in supFort of my

Motian ta rccuse the Office i:fthe Distriet for the Cou.tfy af,San Bernardinc.

L On numerous accasi*ns during the pendency af this action, DDA Se*crd has maderelbrence to a criminai recrlrd which I purpartediy had in the State *i Texas. Tnese referen*eswere made during my anempts to obtain an OR release or bail reducti+n and appear to have beerrao attempt to prejudice the Ccurt against rne" The atterapt r*'as apparently successful as theCourt wouldn't even grant electranic monitoring.

2. While it is true that in or about 1985,I was arrested in Waco, -lexas, my mother,Shirley Waddelt posted bail for me, no charges were filed against me and, obviously, I was nctco*'icie'j ofanything. I do not recali *hat i was ariesied for. as it r"as 21 ie;"- ago.

3. My attomey asked me ra.hat fhe District Altorney u.as taiking abaut. In an effort toestablish tire {r::th" } went t* th* Texas Department of Public Safety, Crirne RecordsServiceo and Cornputerized Criminal Hist*qy atlny narr: as l.isa R. fur..hardscs and a-q Lisa R- C**::ville wirh my d*re cf birth. May 28,1965, no crirninal records were found. {A true and carrect copy olthe search is attachedberet* and iac*qp*rsted in by re{ieren** ;is Exhibit f .i

4. I then Frent rrl Insant Criminal Checks and paid to nrn lny narue with my sociai securjt-vnumb*:r 462-45#af , again, n* records "+eref,+*r:d" iA iru* *:d correct ci:p_:_' nith* icstarr:t errninal cl'reck is attaebed hereto andir:corp*rated in b;o- r*fereficc as Sxhibit 1-)

DSCI-ARATTON OF' L} SA LIBERI



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6.

A few months after ihe arrest in Texas, I secured a job, got crarried ta William Courvilieand r*'e baught a home tsgeiher in T*xas.I was div*reed in er about the end af 1989 asd I accepted a transt'er to Neuport Beach,Caiifomia r+.ith the csmpany I was rvorking [:r. I reiocated from Texas to C*lifomia in*r abcut December 1989.

7 , On January i 5, 2002 a Search Warrant u,as sen ed on my Froperfy lacated at 1 I 952Huatley Alnue, Etiwandq Catifornia 91?19. At this s&me time, I was arrested onallegations of P.C. 4?0 and P"C. 48?, based on San Bernardino C*unty Sheriff=sBeparfment Case #1 I 0?0047?.

8. My baii was set at $?$,00S w-hieh was posted on January 15, ?002 and I $*-as releasedfrom WeslYailey Detention Center.

L February 25, ?002 my Arraignment carne on far hearing in San Bernardino Coun{vSuperi*r Court" Ranch* C.ucam+nga District, Case #{}?013 41972. No one from &e SailBernardino Caunty llistrict Attorney's Otfice appeare4 no charges were flle{ my bailbond -*as exo:rerated ead I was released.

1*" ln or ab*ut $eptember 2002. I fited a mstion in rny Paterniff Ac{ioa, San BemardinoCounty Sapericr Courf Rancho Cucar**nga Districl, Case #RFL-CI34S8fi, ffiquesiingpernrisslnn to reloeate with my minor s$n lo t'Jew Mexica. CIn or aboui Ositrobcr i 8,2002. my motion was gr:rnied along u.ith a new visitaticn *:der permitti[g my chiid'sbi*logical father, J*hn Alla* tc visit v;ith *ur sc* in Albuquerque, ld*w lriexico *e thirdrreekend af every month at Neutrai Ccrner. a Count-l faciliry"

I i. ia or abcut early November 2S0?" my husband, child and I relocated to hlew l'{exico.DECLARANON OF LISA L]BER]



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'fhe reason for the relocaticn rvas due to my bealth complications, harassment I w.asenduring lrom my child's biological father, my father's poor health and to be closer tomy family anC assist mv sister *'ith her medical and ps.r*chiatric conditions. The DistrictAttornel" has alleged that I fled Califomia to avoid prosec*tion without a single shred ofevidence tc support such an allegation, once again attempting to prejudice rhe Ccunagainst me.

12. Upon arrival in New fulexico, my husband, Brent Libcri, immediatel.v obtained a job withSeeds of Change located in Santa Fe. My husband is stitl witb this company and rn'asrecently promoted.

13. January 14, ?003, Michelle D" Strickiand, Esq. filed a civil la*'suit on my behalf, in SanBernardino Count-v Superior Court-. Central District" Case #SCVSS-98957 against amongothers, Paul Morrison, the investigating officer in the matter herein.

14. April 01, 2OO3 l\tlichells D. Strickland filed a mofion re \f,rrit *f Possession. ll.!l.AJames Secord made an appearance as a Special Party'of Interest. I was not present forthis hearing, however, I was informed by Ms. Strickland that D.D.A. Secord statcd I rvasunder investigation and was required to bring the motion for writ of possession before theJudge *ho issued the search warant. This *'as the first time I heard i was underinvestigation. Based on the statements of D-D.A. Secord my motion was denied withourpre.iudice.

15. April 10, 2003, Ms. Strickland filed a motion for reconsideration as she determined thestaxements given by D.D.A. Secord r+'ere not accurate. A hearing was set for lv{a,v 13,?00?

16. lv{ay 09, l00l the San Bernardino Countv District Attomey's Office iiled the first set ofcharges against rne. Case #F$,n 028*0C, based on the same San Bernardin* Ccuntl'

DECLARATION OF LISA I-IBERI



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Sheriffs Deparfment Case #1 1 02S04??,17. In or alro*t Oetober 2S*3, during the ongoing preliminary hearing in this matter, D.DA.

James Secord obreined er sx psrte srd*r fr+rn the Ora.rge C+unfy* S*peri*r Conrt,Lamoreaux Justice Ce*ler in order to *btain access to rny confidential Paternity Actior,C*se #A*-60:fi1- Ii.D.A- Seu:rd faiied to give notice t* my attoiaey's 'f,r any partiesassociated *'ith the Patemity Actior: so they would have an oppo*unity to protect theconfidentiaiity af thar fiie. i ieamed oi&is drning *ry preiiminary hearing in Case#FWV-0280SS rvhen D.D.A. Secord had rny Parsmity file braught up to the courr rsomand requesed judiciai notice of certain docunefits.

18. In or aboul February 20$4, I learned that Randolph C. Houts, Attrrney for USA FederalCredit Union and a witness in this ease cbtained copies cfdocume*fs which were locakdwithin my Patemiry* Action.

I9" On Mar*h J 1, :0S4. I *nder*er:t Op*.n Heart Srrg*ry at the Hesrt Hcspital l*cated inAlbuquerque, }iew Mexico.

20. As a result of the complications I suft?red from my Cpen Heart Srugery, my csurtappearances rvere eontinued. My then attorney, David Galdstein and D.D.A. JarnesSecord stipulated to have rny c$Ert hearings continued to July 13, ?004.

21. On or abaut June 14, 20*4, the San Bsursrdino County Disfict Attorney's Office signedfor Government Claims filed on my betralf b-v Michelle D. Strickland for the iiiegalaccess and dissemination of eonfidential doexrnents teken frarn rny Paternity Action toR"andolph C. Hatrts.

32. ln or abaut mid J*ne 20S4, J+hn Allerl, D.D-A. $ec*rd's wiiness contacted Officer RudyGailegos with ttre Santa Fe Folice Deparhnelit and attempted t* have n*e arrested qn aw'arranl pricr ta iis issr*inee. 'lhc t:nly way fufr. hllen q'cuid }:ar.* had kn**'ledge a

DECLARATION SF LISA I-IBSRI



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li"alTant rvas treing sought was frcm D.D.A, Sec*rd and,or the San Bemardino CounfyDistriet Attcrney's Office. D.D.A. Secord was rvell a\4,are that my child and i are thevictims af John Allen's crirnes, fcr ra.hich Mr. Allen.,vas convicted. Further, Mr. Allenwas arl'iue I u'as being arrested r+&en I flew to California as he also sent the ehild supportlor July 2004 by restrised deiiver,v know'ing I would be urable to pick up the cheok. (Atrue and correct copy of Officer Rudy Gallegos declaration is attached hereto andincorporated in by reference as Exhibit 3.)

?3. On June 30, 2004, D.D.A. Jarnes Secord obtained anotlerwarrant for my arrest from theSan Bernardino County Superior Court, Central District, Case #FSB 044914 under mymarried name of LIBERI involving the same vehicle and Credit Union relative to which Iwas litigating in the first case, Case #FWV-028000. D.D.A. Secord was aware I waslitigating the first case undermy maidenname of RICFIARDSON in San BernardinoCar.rng Supen+r Cor-rt, RanchcoCucanonga Distnct, ss he rvas the depu{' distdctaftomey who filed the first case, Case #FWV 02*000.

24. July 12,2004,I was arresteri at the Ontario Airpart by Michael Leiberich raith the SanBernardino Counfy District Attorney's Office on behalf of D.D.A. Secord when I flew infor my JuJy 13,2004 court date. As previously stated, D.D.A. Secord knew I would beappearing as he had stipulated to the hearing date of July 13, 2004.

25- I r*'as taken to West V-alley Detention Center, booked and placed in isolation in the men-'surrit. I sutfered another heart attar.k, r.r'hich shut dorrr the trypassed area of my' heart andKetoacidosis-

?6. I appeareC in Courl July 14, ?004 in-custady for my* Arraignrnent for Case #FSB 044914and baii hearing on both cases. I entered a plea cf Not Guiiry to all counts. My bail onthis arresl Case #FSB S44914 was set at S100,000.00 with a 1775.1hulrt. M1'

DECI,ARATION OF LISA LIBERI



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Preliminary bearing $'as set for Jul,v ?6, l0fJ4.?7. August 04,20A1at {l:30 a.m. I was present for a bail hearing on both cases and to have

the 1175.1 hold rernu,ed on Case FSB-044914. D.D.A. Secord had Mr. Thomas Ricefrom the Department of Insurance appear in anempts to have m3' traii bond agent, Sconh4ehr's iicerrse revoked. D.D.A. Securd stated tc the court that Scott l"{ehr r'.'as kickingme back monev paid for the bail premium, and that he had etape of our conversation-This simply ltias not the case; Scott S4eir *'as reducing m-v bait premium to 87o based ona nel\,'law which had just passed. .Judge Pacheco removed the 1275.1 hold and askedMr. Mehr if he rvas posting my bail. D.D.A. Secord then made an oral motion andattempted to have my bail raised to $750,000.00" Judge Pacheco denied D.D.A. Secord'srequest. Steve & Scott Mehr baii bonds posted my bail totaling $350,000.00. I r+asreleased from West Valley Detention Center on August 05, 2004.

,)R f\n .rr +h.-,.'+ A.:,.:rcr nO .)nn.4 I t'-"-.l ^ ^^,ir an6aar^--- i-. -.=, D-*=-i*., .4.-+i,\- T -*;.'^,{ f ) Lwv1, r rrgu ! vww! 4l,l/vr4i!v frl rrr.' I 4rert!:J r-rvrruir. | &r.!!uat Depattment R-l? of this court at approrimatei"v 8:30 a.m, I was sitting in thecourtroom u'aiting for my attomey, P. Timothy Pittullo, *hen D.D.A. Secord appeared. Igot up and left the courrroom voith a friend of mine, and D.D.A. Secord chased me downthe hail. It frightened me and I rvEnt into the women's bathroom and *'aited for an'hile.D.D.A- Secord was well aware that I was represented by counsel in the crimirnl matter.And shouidn't talk to me without my lauyer. D.D.A- Secord came intc Department R-17tn.o more times and mv famih. attornev had to intervene.

39. On or about December I0, 2004, my cir.il attome)'. Michelie D. Strickland filed a larvsuitagainst D.D.A. Secord, D.A. Michael Ramos, San Rernardino County', San BemardinoCounty District Attorney's C)ffice, San Bernardino County District Attorne]"'s Offic.eInve;tigatrr Roberi Schreiber, and other defendants $n ffi) behalf and cn behalf of m,v

DECLARATION OF LISA LIBERI



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minor.ron, Cliffcirct. lor the illcgal access ancl disseminatioll c'f coniidential docuntent,rfrr:m m-v Paremiry'Action. Unired Srates llistrict Court, Central District of Califrrrnia,Case #04- I 524-l'AP tSGI-x).

30. In or about lr{ay'2005. San Bemardino Caunf-u- Courisel, reprssenting D.D.A. JarnesSec*rd. D.A. Michael Ramos, San Bernardinc Co**t-v, Sm Bcntardin* LlountS'DisirictAttorne-v'5 Otlce, SECDA Inv*stigator Robert Schreiber and other count)' emplol'ees{iieii a n:otion to clismiss pursuant to F.R.C.P. 1:{B}i6}.

il" Llounry Ccunsel's motion to dismiss was heard on Augusl01,2005. Honorable VirginiaPhiiiips d.ismissed ivlichael A. Ramos, SBCIIA lnvestigator Robert Schreiber and theDistrict Aftorney's Offiee, horvever found that there was sufficient allegations asseriedand held D.D"A. James Secnrd to ans*.er nine {9} c&uses of acticn. The causes of actionsD.D.A. James Secord ii.as heid to answer for inelude Abuse of Process, lnvasion ofPrivecv- vi6latricn olequal croteciion *f the laws- violaticns af n*n-discrirninatoqypolicing services, civil conspiracies, 42 1,1.S.C. $$ i983, 1985 and 1986 ciaims'negligence ald violations of due process rights" Judge Phillips further ruled that thealleged ccnduct of D.D.A. Secord is not pr*t*cted from prosecutorial immunify becauseit lblls outside rhe scgpe of his prosecutorjai Jirnctions. {A true and correct copy of theFederal Ruiing on the County's motion to dismiss is attached hereio and incorporated inby ref'erence as Exhihit 4.i

3f. I have nnf been treated iairll.. b1, D-D.A. sec|rd *r as al! other defendants al"e treated' It isapparent that rhere is a conllict rvhich prahibit.s l).D'A- Secord and rhe San BernardinoCounl-v Disn'ici Attorne-u*'s Office lrorn making prof*ssional' unbiased decisionsperraining to me and my case. I fear I lruu* nojunce at a fair trial as long as D'D'A'Scct:rd a,tC thc San BcmarrJin* Ccunq,' Districl Allcmel"s OiJjcr are rll*rved to r*main

DECLARATION OF LISA LIBERI



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liberi v tatiz (c.d. ca) - 283.2 - # 2 exhibit request for juicial notice of eclaration of liberi...

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