Case 8:11-cv-00485-AG-AJW Document 745 Filed 09/05/17 Page 1 of 19 Page ID #:18091

1 J.B. Lorenzo
2 Lorenzo Law Firm, P.A.
P.O. Box 11253
3 Tallahassee, FL 32302
4 admin@lorenzolawfirm.com
tele. No. 855.757.2757
5 Attorney for Plaintiff Lisa Ostella
6
7
UNITED STATES DISTRICT COURT
8 FOR THE CENTRAL DISTRICT OF CALIFORNIA,
SOUTHERN DIVISION
9
:
10 :
LISA LIBERI, et al, : Case No. 8:11-cv-00485-AG (AJW)
11 :
Plaintiff, :
12 : SECOND AMENDED COMPLAINT
:
13 vs. :
:
14
:
: Honorable Andrew J. Guilford
: Location: Courtroom 10D
15 ORLY TAITZ, et al, : Date filed: May 5, 2009
: Trail Date: None
16
Defendants. :: Request for Jury
17 :
:
18 :
:
19 :
20
21
The only remaining Plaintiff, Lisa Ostella (Plaintiff), by her counsel, submits

22 this amended complaint against the only Defendant, Orly Taitz.

23 PARTIES
24 1. The Plaintiff, is an individual residing in New Jersey.
25 2. The Defendant, Orly Taitz, is a resident of California.
26
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1 JURISDICTION AND VENUE

2
3. The amount in controversy, exclusive of interest and costs, exceeds
3
$75,000, for each individual asserted claim.
4
5 4. This Court has diversity of jurisdiction over this action pursuant to 28
6 U.S.C. 1332(a).
7
5. Venue is proper before this Court for this action, as the Defendant
8
resides in Santa Ana, California.
9
10 INTRODUCTION
11
6. On information and belief, the Defendant owns and administers the
12
www.orlytaitzesq.com web blog and owns and administers the following emails:
13
dr_taitz@yahoo.com, orly.taitz@gmail.com, and orly.taitz@hushmail.com. The
14
Defendants Internet publications demonstrate this. [Exhibit A]
15
7. The Defendants www.orlytaitzesq.com blog displays that it sells Ads,
16
seeks donations, and publishes authored postings including postings about the
17
Plaintiff. These statements on Defendants site are the reasons for this lawsuit.
18
19
These statements about the Plaintiff remain posted on the Internet from

20 Defendants site, as of May of 2017 (note the date stamp on each). [Exhibit A]

21 BACKGROUND
22 8. The Plaintiff provides web development services, owns a library of
23 domains to offer clients, and provides website hosting for clients.
24 9. The Defendant sought the Plaintiff, on or about September 2008,
25 to work on Defendants drorly.blogspot.com blog.
26
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1 10. The Plaintiff purchased on December 18, 2008, the domain

2 defendourfreedoms and suffixes .net, .info, .org, and .us. Plaintiff remains the
3 sole owner of this domain and suffixes. [Exhibit B Dkt. #722 - Ex. 2]
4
11. Plaintiff designed a spec blog platform using the domain
5
6
defendourfreedoms.org (doff.org) as a static site and a defendourfreedoms.us

7 (doff.us) as a blog for RSS feeds to generate search engine optimization (SEO) to
8 draw traffic to doff.org.
9 12. The doff.us site had a plugin PayPal donate button installed which was
10 controlled by the Defendants email orly.taitz@gmail.com.
11 13. Upon Plaintiffs May 4, 2010 issued subpoenas, it learned that Defendant
12
had a preexisting PayPal account using the dr_taitz@yahoo.com email account
13
which was receiving donations. [Exhibit C Dkt. #190 Ex. 5, p. 21]
14
14. The donations in both accounts through PayPal were to be deposited
15
only into the Defendants bank account. [Exhibit C Dkt. #190 Ex. 5, p. 8 and
16
at p. 22, ID #4709]
17
15. When a donor claimed that the donation was returned, the Defendant
18
claimed that the PayPal account to the defendourfreedoms.us blog was hacked by
19
outside sources, i.e., ObamaThugs.
20
21 16. The Plaintiff informed Defendant of the technical network
22 reasons, since the web blog was hosted on Plaintiffs server.
23
17. The Defendant disregarded Plaintiffs explanation and filed a cyber
24
crime report with the FBI seeking an investigation based on Defendants narrative.
25
26
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1 18. Plaintiff had email discussions with Defendant about needing to

2 correct report to FBI. [Exhibit D]
3
19. When Defendant refused to correct her FBI report, the Plaintiff told
4
Defendant to get another web worker.
5
20. Because Defendant posted on her web blog that an Orange County
6
Cybercrimes Unit agent was assigned to investigation, Plaintiff ended access to the
7
defendourfreedoms.us blog to transfer content to defendourfreedoms.net, and allow
8
for an investigation. [Exhibit D, p. 1]
9
21. Plaintiffs server has been available for an investigation since April 2,
10
11 2009. It has never taken place.
12 CHRONOLOGY OF EVENTS
13
22. On information and belief, the Plaintiff provides the following
14 chronology events leading up to the filing of this action.
15 a. On December 18, 2008, Plaintiff began to create a nonprofit
16 PayPal account for the Defendant.
17 b. On December 18, 2008, the Plaintiff provided the Defendant
18
via email the plugin script donation code for the Defendant to control.
19
[Exhibit E]
20
c. On December 23, 2008, Defendant registers DOFF Fictitious
21
Name Filing [Exhibit F - Dkt. #35, p. 22, pg. ID 408, also Dkt.
22
#722, Ex. 3]
23
d. On December 31, 2008, the Plaintiff stopped working on the set
24
up for the Defendants nonprofit PayPal account, because in lieu of
25
Defendant not having an acceptable FEI# designated to a recognized
26
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1 nonprofit organization, the Defendant had to use her own social

2 security number for the set up.
3
e. On and thereafter December 31, 2008, the Defendant proceeded to
4
finish the setup using her email orly.taitz@gmail.com and her own
5
social security number, to finally establish the PayPal account for
6
Defend Our Freedoms.
7
f. On and thereafter December 31, 2008, the Plaintiff no longer had
8
access to Defendants PayPal account named Defend Our Freedoms
9
10
Foundation.

11 g. On February 19, 2009, the Defendant registered Defend Our

12 Freedoms Foundation as a non-profit entity in the State of California.

13 [Exhibit G ].
14 h. On or about March 4 7, 2009, donors to doff.us using PayPal
15 button, experienced unsuccessful donor messages and Defendant was
16 made aware of the glitch. [Exhibit H Dkt. #722, Ex. 1, p. 3]
17 i. On March 16, 2009, Defendants private investigator sent an email
18
to Defendant and Plaintiff with subject line LISA LIBERI, informing
19
of Lisa Liberis criminal background record. [Exhibit I, Dkt. #190
20
Ex. 4, p. 7 ID #4665].
21
j. On April 2, 2009, the Plaintiff learned from Defendants web blog
22
post of Defendants FBI report and hacking claim of PayPal account.
23
[Exhibit H Dkt. #722, Ex. 1, p. 1 Dossier 5]
24
k. April 2 - 9, 2009, Plaintiff told Defendant that she needed to find
25
26
another webmaster because FBI report was false and explained how

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1 Defendant was wrong. [Exhibit D]

2
l. On or about April 9-12, 2009 Plaintiff coordinated with
3
Defendants new webmaster to transfer the doff.us blog data to
4
doff.net and for him to retrieve the data for the new site to be owned
5
by the Defendant and Plaintiff posted Understanding the Internet
6
101 confirming coordination and transfer of code to Defendant.
7
[Exhibit J Note pp. 6 - 8]
8
9 n. On April 13, 2009, Defendants private investigator sends an email
10 to Defendant about Lisa Liberis criminal background history.
11 [Exhibit I - Dkt. #190 Ex. 4, p. 7 ID #4665].
12
o. On April 17, 2009, the Defendant, files a report with the Orange
13
County Sheriffs Office stating (i) that Plaintiff, Lisa Ostella and Lisa
14
Liberi were one and the same, so as she claims she was told by the
15
private investigator, and (ii) that Lisa Ostella had taken $10,000 of
16
donations. [Exhibit I Dkt. #190 Ex. 4, p. 30-33]
17
18
ARGUMENT
19
23. From April 17, 2009, the Defendant went on an Internet defamation
20
21
campaign to maliciously malign and disparage the Plaintiffs character and

22 reputation, using the Defendants own web blog www.orlytaitzesq.com for

23 thousands to read daily.

24 24. The Plaintiff asserts that Defendants filed false reports with the FBI
25
26
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1 and the Orange County Sheriffs Office and that they are not protected speech. (See
2 Lefebvre v. Lefebvre (2011) 199 Cal.App. 4th 696) [where the Defendants police
3 report was determined to be false . . . against the Plaintiff])
4 25. The Plaintiff asserts that the estimated daily unique visitors count for
5
Defendants www.orlytaitzesq.com site, is remarkable, based on Internet traffic
6
sources.
7
26. Based on information and belief, the Internet traffic sources scan
8
Alexa, Compete, Google Ad Planner etc. to depict the potential value of a site
9
based on unique user count. Unique user count is a common way of measuring the
10
popularity of a website and is often used by potential advertisers or investors. As
11
of February 2017, CuteStat.com estimated that the www.orlytaitzesq.com site
12
generates average daily visit of 1412 while StatShow.com estimates that the
13
www.orlytaitzesq.com site average daily visits of 2300. [Exhibit K].
14
15 27. Defendants libelous statements
16 April 17, 2009 - More explosive Information dossier #6 posted on
17 www.orlytaitzesq.com, using (dr_taitz@yahoo.com) email that was
sent to numerous recipients stating:
18
19 I started receiving statements and copies of pay pal receipts,
showing instead of my email address, an e-mail address of Lisa
20
Ostella. Originally, I thought that maybe her address showed on
21 the receipt, since she was a web master on the account, however,
when I checked the names and dates on the receipts, . . . I could
22
see that those were not received by the foundation, those
23 donations were missing. [ Exhibit I - Dkt. #190 - Ex. 4, p. 2-5,
24 pertinent at p. 3 and p. 4- [#4660- 4663]

25
26
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1 April 17, 2009 Defendant filed a police report with the Orange
2 County Sheriff Office stating that:
3
learned that some monetary donations intended
4 for Defend Our Freedoms was redirected to Lisas
personal email account; (2)in reality donations were
5
redirected to Lisa Ostellas (AKA: Lisa Liberi) personal
6 account; that the estimated loss was $10,000. -
[ Exhibit I - Dkt. #190 - Ex 4, p. 30 33, pertinent
7 p.32.) See also Exhibit 8 at p. 27 - 4) [#4886]
8
9
10
April 18, 2009 Follow up on Lisa Liberi, paralegal to Phil Berg,

11 posted on www.orlytaitzesq.com with caption and stated that:

12 I have closed the paypal account when I saw that Lisa Ostella
13 has redirected the Defend Our Freedoms blog and redirected
the paypal, - [Exhibit I - Dkt. #190- Ex. 4, P. 41-44 ID #4699]
14
15
April 18, 2009 Dont Be Fooled posted on
16
www.orlytaitzesq.com with caption stating the following about the
17
Plaintiff:
18
19 My former web master Lisa Ostella has created an
20 account that she called Defend Our Freedoms
Network and is soliciting donations, praying on
21 unsuspecting readers that would not notice the
difference between Defend Our Freedoms
22 Foundation and Defend Our Freedoms
Community. Please notice, your donations
23 there will not go to the foundation, they will go to her
24 personal bank account, connected to her personal
e-mail address GoExcellGlobal. She posted
25 underneath a PayPal logo with my e-mail address,
26
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1 however I have closed the pay-pal account. See

2
[ Exhibit I - Dkt. #190 - Ex 4, p. 44]

3 April 19, 2009 Every day I get such Evidence of missing or

4
misdirected funds posted on www.orlytaitzesq.com, caption stating:
5
Every day I get such receipts, showing that my former web
6 master Lisa Ostella (posts under name Calpernia) has
7
redirected donations to herself, to her e-mail address.
Currently, as this was uncovered, she created new web sites
8 Defend our freedoms .org,net and continues the scheme by
9 making those sites similar to my old ones and using the
foundation name to steal more donations. She created a visa
10 donation site with her e-mail account Go Excell Global,
11 underneath she posted a paypal button showing my foundation
Defend Our Freedoms (without my consent) and my e-mail
12
address (without my consent) to look as if she is still connected
13 to me and my foundation, even though all ties with her were
severed a couple of weeks ago, when I found out about this
14
scheme and I closed the Pay Pal account completely. Any
15 person, whose donations were stolen by Lisa Ostella aka Lisa
16 Current aka Calpernia is asked to report this to his local police
or sheriffs department. As I found out, she appears to be
17 connected to Lisa Liberi, who is still working for attorney
18 Phillip Berg. Please see my dossier #6,-
[Exhibit C - Dkt. #190 Ex. 5, at p, 3]
19
20 April 20, 2009 (at 1:21 am) - About Lisa Ostella - dont patronage
21
diverting funds from a nonprofit, dont be part of slander posted on
22
www.orlytaitzesq.com an email sent via dr_taitz@yahoo.com to
23
numerous recipients and posted the same about the Plaintiff:
24
As I found a new web master, Ms. Ostella, who had the
25 access codes as a web master, instead of transferring
26 all the domains, has locked me and other volunteers out
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1 of the blog and transferred the account to herself, and is

2 using the name of my foundation fraudulently, without
my consent. She is using the pay-pal account that says
3 Defend Our Freedoms and my personal e-mail address
4 fraudulently and she posted numerous outrageous
slanderous statements about me while
5 pocketing the donations, [Exhibit C - Dkt. #190
6 Ex. 5, p. 57- 58, ID #4760]
7
April 21, 2009 Update on Lisa Plaintiff and Lisa Liberi, posted
8
on the blog www.orltytaitzesq.com in a letter to Mr. Al Barrs,
9
publishing a verification of the filed police report and states:
10
11 I have sent a Cease and Desist letter to Ms. Lisa
Ostella, demanding that she forward to me the
12 access codes for the domains and the e-mail
13
address list of the readers and stop fraudulently
operating under the name Defend Our
14 Freedoms and stop drawing financial profit
from the Defend Our Freedoms name. . . Ms.
15 Lisa Ostella is the one, who collected names
and e-mail addresses and she is currently
16 fraudulently sending e- mails to these readers
using Defend Our Freedoms name
17 [Exhibit C - Dkt. #190 - Ex 5, at p. 61-63]
18
May 5, 2009 Check public records for yourself, see that I am
19
providing truthful information posted on www.orlytaitzesq.com
20
blog stating:
21
Ms. Ostellas actions as a web master in locking
22 me out of my web site, allowing several days of
defamatory statements and later defrauding the donors
23 and my foundation, by sending e-mails and claiming to
represent foundation and soliciting donations for the
24 foundation are inexcusable and will have to be
prosecuted in due time.-
25 [Exhibit L - Dkt. #190 - Ex. 6, at p. 13-[14]]
26
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1 May 19, 2009 NJ Police posted on www.orlytaitzesq.com blog

2 stating:
3
As you know my previous site, Defend Our Freedoms was
4 taken over by the web master Lisa Ostella. For over a
5
month now Lisa Ostella had no affiliation with Defend
Our Freedoms Foundation, however she has been
6 sending e-mails from Defend Our Freedoms and
collecting donations.
7 [Exhibit M - Dkt. #190- Ex. 7, p. 26 29]
8
9 May 20, 2009 posted a Following comment on
10 www.orlytaitzesq.com to her own May 19, 2009 NJ Police
11 post using dr_taitz@yahoo.com to state on May 20th, 2009 @ 7:36
12
am:
13 Defend our freedoms is a non profit registered under my
14 name. Lisa Ostella, the web master, was supposed to
register the domain under my name, instead she
15 entered her e-mail address Go Excell Global. She
16 keeps the domain and solicits donations by defrauding
the non-profit organization. When people donate, they
17 believe, that they donate to my effort, for me to travel to
18
different states, lobby officials, file legal actions,
instead she is diverting the donations to her own
19 pocket by fraud and she and her husband benefit from
defrauding me and my foundation.This is a criminal
20 matter [Exhibit M - Dkt. #190 - Ex. 7, p. 28]
21 March 3, 2011 Who are these people in Germany threatening
22 me? posted on www.orlytaitzesq.com blog stating:
23 I reported cyber crimes, I reported that my volunteer web
24 master Lisa Ostella locked me out of my prior web site for my
foundation, that donations to my foundation were diverted,
25
[Exhibit N - Dkt. #190 - Ex 22, at p. 33-34]
26
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1 28. Based on the listed libelous statements in 28, the Defendant

2 demonstrated a consistent repetitive pattern and practice of defaming the Plaintiff
3 done despite knowing the truth; hence, the Defendant used the Internet and her blog
4 to harass and defame the Plaintiff.
5 29. Defendants March 8, 2009 email posted in her
6
www.orlytaitzesq.com blog with a caption Dossier No. 5 shows
7
Defendant had knowledge of glitch and told a donor; the Defendant
8
states:
9
10
I finally figured, what happened. Somebody
tempered with my pay pal account, actually went into
11 account and changed it from
12 orly.taitz@gmail.com to orly.taitz@gmail.org - a non-existant
account for paypal. I guess it was done intermittently, so I got
13 some donations, but very little. Lisa Ostella, my web master will
14 report it to her carrier "go daddy", she will see if this e-mail is
not taken, we will add it. I will send an additional report to
15 Attorney General-Eric Holder, though he is Obama's
16 appointee... We are dealing with dirty mafia, running the
country. Please, see the letter to Attorney General, that I
17
posted,.. [Exhibit H Dkt. 722, Exhibit 1, p. 3]
18
19 30. Defendant continuously received donations though Defendant claims
20 she did not; both PayPal accounts show contributions contrary to claims.
21 [Exhibit C - Dkt. #190 Ex. 5]
22
23
31. Defendant knew of the separate identities of the previous party
24
(Lisa Liberi) and the remaining Plaintiff, Lisa Ostella.
25
26
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1 32. By Defendant, knowingly characterizing Lisa Ostella as Lisa Liberi,

2 and attributing to Lisa Ostella that she had a criminal background, what the
3 Defendant did was vindictively outrageous, willful, and professionally
4 reprehensible, for a member of the legal community and an officer of the court.
5
33. Though Defendant had filed numerous appeals and motions to
6
dismiss, it has NOT provided proof of all her claims.
7
8
9 CLAIM I
10 rd
(FAC 3 Claim - False Light Invasion of Privacy)
11
12
35. The Plaintiff realleges and incorporates by reference paragraphs 1
13
14 through 34, including sub-paragraphs as though fully set forth herein.

15 36. The Defendants web blog postings of the Plaintiff, Lisa Ostella, for
16
the last 8 years, depict the Plaintiff in a false light in that:
17
a. The Defendants web blog posting depiction of the Plaintiff are a
18
major misrepresentation of Lisa Ostellas character,
19
professionalism, responsibility, history, and reputation;
20
b. The Defendants depiction of the Plaintiff was and is highly
21 offensive to a reasonable person; and
22 c. Defendant acted in a reckless disregard as to the falsity of the
23 publicized posts about the Plaintiff.
24 37. That as a direct and proximate cause result of Defendants actions and
25 inactions, Plaintiff has been harmed.
26
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1 CLAIM II
2 (FAC 4th Claim Appropriation of name Invasion of Privacy)
3
4 38. The Plaintiff realleges and incorporates by reference paragraphs 1
5
through 37, including sub-paragraphs as though fully set forth herein.
6
7
39. The Defendants web blog postings, of the Plaintiff, Lisa Ostella, for

8 the last 8 years, have been for the purposes of deriving donations and have been for

9 the defendants commercial or trade interest, without having any redeeming public
10 interest, news, or historical importance.
11 40. As a result of Defendants misappropriation of Plaintiffs name, the
12 Defendant had financially benefited at the expense of the Plaintiff and the Plaintiff
13 has been directly and proximately hurt.
14
CLAIM III
15
16 (FAC 7th Claim Cyber Harassment/Bullying)

17
18 41 The Plaintiff realleges and incorporates by reference paragraphs 1
19 through 40, including sub-paragraphs as though fully set forth herein.
20 42. The Defendants web blog postings for the last 8 years, have had a
21 harassing and bullying effect. The Defendant used the Internet crossing stateliness
22 vilifying and criminality on the Plaintiff.
23 43. The Defendant continuously posted about the Plaintiff, harassing the
24 Plaintiff by characterizing her as a criminal and reading that Defendant is coaxing
25 donors and followers to garner bad sentiments toward the Plaintiff. To see the
26
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1 claims on the Defendants web blog still into 2017 is harassing to the Plaintiff, i.e.,
2 Pursuant to Calif. C. Civ. Proc. 527.6; Calif. C. Civ. Proc. 1708.7
3
Calif. C. Civ. Proc. 527.6: (3) Harassment is . . . a knowing and
4 willful course of conduct directed at a specific person that seriously alarms,
annoys, or harasses the person, and that serves no legitimate purpose. The
5 course of conduct must be that which would cause a reasonable person to
6 suffer substantial emotional distress, and must actually cause substantial
emotional distress to the petitioner.
7
8 Calif. C. Civ. Proc. 1708.7: (a) A person is liable for the tort of
9 stalking when the plaintiff proves . . . (1) The defendant engaged in a
pattern of conduct the intent of which was to, . . . or harass the plaintiff. . .
10
. . (2) As a result of that pattern of conduct, either of the following
11 occurred: . . . (B) The plaintiff suffered substantial emotional distress, and
12 the pattern of conduct would cause a reasonable person to suffer
13 substantial emotional distress.
14
15 44. The Defendants web blog postings maliciously tarnishing the
16 Plaintiffs reputation and persona through the last eight (8) years has had a
17
harassing and bullying effect tormenting the Plaintiff, whose livelihood depends on
18
her work on the Internet and utilizing the Internet, for marketing, delivery of
19
services, and communicating with clients.
20
21
CLAIM IV
22
th
23 (FAC 8 Claim Defamation Per Se - Libel Per Se)

24
25 45. The Plaintiff realleges and incorporates by reference paragraphs 1

26
through 44, including sub-paragraphs as though fully set forth herein.

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1 46. All the Defendants blog posting at www.orlytaitzesq.com about

2
the Plaintiff, are false and malicious, rising to the level of libel, libel Per Se and the
3
Defendant, professionally, should have been aware. Calif. C. Civ. Proc. 45.
4
47. The Defendant has directly and proximately caused the Plaintiff 8
5
years of suffering from Orly Taitzs actions and pattern of libelous conduct; which,
6
any reasonable person, would appreciate the gravamen.
7
8
9
10 CONCLUSION
11
48. Based on the foregoing, the Plaintiff argues that Defendants
12
statements were done (i) with total disregard for the truth, (ii) with malice, (iii)
13
calculated for commercial interest, (iv) without no First Amendment protection or
14
privilege applies, (v) without public import or public interest value, (vi) without
15
basis in truth, (v) by invading privacy, and (vi) by misappropriating name for
16
17
commercial gain.

18 49. Also, the Plaintiff underscores the Defendant has demonstrated a

19
pattern and practice of untruthful, malicious, and sensational misconduct, devised to
20
hurt the Plaintiff.
21
22
PRAYER FOR RELIEF
23
24
NEXT PAGE
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1
2
PRAYER FOR RELIEF
3
WHEREFORE, Plaintiff prays for the Court to consider the amount of
4
5 years that it will take for the Defendants Internet postings about the Plaintiff to not
6 be propagated nor indexed by Yandex, Bing and Google and data aggregators.
7 MOREOVER, Plaintiff further prays that the Court render a judgment in
8 Plaintiffs favor as follows:
9
10 1. For general damages, to be awarded of $10,000,000;
11 2. For special damages arising from loss of business and business
12 opportunities, according to proof at trial;
13 3. For presumed damages;
14 4. For exemplary (punitive) damages;
15 5. For equitable relief including but not limited to the relief requested
16 above that would address Defendants egregious, sensational and
17 malicious conduct;
18
6. For costs of suit incurred in this action, along with attorney fees; and
19
7. For each and other further relief as the Court deems just and proper.
20
21
22 Respectfully submitted: September 5, 2017
23 /s/ J.B. Lorenzo
24 LORENZO LAW FIRM, P.A.
25 Counsel for Plaintiff
26
27 Page 17 of 19

28 PLAINTIFFS SECOND AMENDED COMPLAINT

LORENZO LAW FIRM, P.A.

Case 8:11-cv-00485-AG-AJW Document 745 Filed 09/05/17 Page 18 of 19 Page ID
#:18108

1 CERTIFICATE OF SERVICE
2
3
I hereby certify that a true and correct copy of the foregoing has been
4
5
furnished to the following via electronic mail and by regular U.S. mail first class

6 on this 5th day of September, 2017 to:

7
8 Jeff Cunningham, Esq.
9 Schumann Rosenberg
3100 Bristol Street, Suite 100
10 Costa Mesa, CA 92602
11 jcunningham@schumannrosenberg.com
Tel: (714) 850-0210, Ext. 268
12
Fax: (714) 850-0551
13 Counsel for Defendant Orly Taitz
14 /s/JB Lorenzo
15 Jose B. Lorenzo
LORENZO LAW FIRM, P.A.
16 2040 Delta Way
17 P.O. Box 11253
Tallahassee, FL 32302
18
admin@lorenzolawfirm.com
19 Counsel for Plaintiff
20
21 EXHIBIT INDEX NEXT PAGE
22
23
24
25
26
27 Page 18 of 19

28 PLAINTIFFS SECOND AMENDED COMPLAINT

LORENZO LAW FIRM, P.A.

Case 8:11-cv-00485-AG-AJW Document 745 Filed 09/05/17 Page 19 of 19 Page ID
#:18109

1 EXHIBIT INDEX
2
3
A. May 9, 2017 screen shots of Defendants defamatory posts from
4 her www.orlytaitzesq.com web blog about Plaintiff
5 B. WHOIS record of Plaintiffs ownership of the domains Defend
6 Our Freedoms and suffixes
7 C. Docket # 190 Exhibit 5
8 D. Email correspondence between parties about Defendants claims
9 and report to FBI
10 E. Email Plaintiff to Defendant sending the donate button code for
Defendants operation 12/18/2008
11
12 F. Fictitious name filing by Defendant of Defend our Freedoms
12/23/2008
13
G. Non Profit registry in California by Defendant of Defend Our
14
Freedoms 2/19/2009
15
H. Docket #722, Exhibit #1, Defendants published Dossier 5
16
I. Docket # 190 Exhibit 4
17
J. Email correspondence between Plaintiff and Defendants new
18
webmaster coordinating to transfer content between old and new
19 site
20 K. Internet screen shot of website traffic stats for Defendants blog
21 site where defamatory statements are published
22 L. Docket # 190 Exhibit 6
23 M. Docket # 190 Exhibit 7
24 N. Docket # 190 Exhibit 22
25
26
27 Page 19 of 19

28 PLAINTIFFS SECOND AMENDED COMPLAINT

LORENZO LAW FIRM, P.A.