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Philip J. Berg, Esquire Pennsylvania I.D. 9867 LAW OFFICES OF PHILIP J. BERG 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Telephone: (610) 825-3134 E-mail: philjberg@gmail.com
UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION LISA LIBERI, et al : : : Plaintiffs, : : : : : : : : : : Defendants. : : : : CIVIL ACTION NUMBER: 8:11-cv-00485-AG (AJW) DECLARATION OF LISA LIBERI Date of Hearing: May 14, 2012 Time of Hearing: 10:00 a.m. Location: Courtroom 10D
vs.
Declaration of Lisa Liberi I, Lisa Liberi am over the age of 18 and am a party to the within action. I have personal knowledge of the facts herein, and if called to do, I could and would competently testify. I am making this Declaration under the penalty of perjury of the Laws of the United States pursuant to 28 U.S.C. 1746. 1. I have read through Reed Elsevier, Inc.; LexisNexis; ChoicePoint,
Inc.; LexisNexis Risk Solutions FL, Inc.; LexisNexis Risk & Analytics Group, Inc.; LexisNexis Group; and Seisint, Inc. d/b/a Accurint [Accurint] collectively
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Reed Defendants] Motion for Summary Judgment, Declarations in support thereof; their Uncontroverted Facts; and all the Reed Defendants discovery responses to our requested Discovery. 2. I never met or talked with Neil Sankey, Todd Sankey, Sankey
Investigations, Inc. or the Sankey Firm, Inc., nor had I ever heard of them prior to the events leading up to the within lawsuit. 3. As we have always stated, and as now confirmed by the Reed
Defendants in their Motion for Summary Judgment [MSJ], Neil Sankey utilized his son, Todd Sankeys and the Sankey Firm, Inc.s accounts to obtain our consumer reports containing our private data. As a result of the unlawful
disclosures of our private data from the Reed Defendants and Accurint, my husband and I have been severely damaged and we cannot fix the damages caused by these Defendants. 4. Prior to the filing of this Declaration, Todd Sankey and the Sankey
Firm, Inc. filed what they called a Motion to Withdraw Admissions pursuant to Fed. R. Civ. P. 36(b). In their Memorandum, Todd Sankey and the Sankey Firm admit that Todd Sankey and the Sankey in fact had a Lexis password, see the Sankeys Memorandum of Points and Authorities, Docket No. 496-1, pages 8-9, paragraphs (c), (d), and (e). This statement by Todd Sankey and the Sankey Firm, Inc. shows Neil Sankeys Declaration was dishonest, as are the statements of the
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Reed Defendants in their Motion for Summary Judgment claiming none of the Sankeys had accounts with the Reed Defendants. 5. Shortly after Mr. Berg and I declined assistance to Orly Taitz, Orly
Taitz used the power of the Internet stating she was going to take Mr. Berg down and to do so she was going to destroy and get rid of me. Orly Taitz has admitted this in Court filings; see true and correct copies on file with this Court as DNs 190-3, p. 20 through 190-25, pp. 896-985 and DN 190-27, p. 1043. 6. Orly Taitz through Neil Sankey and the Sankey Firm, Inc. began
putting out a supposed criminal record which they stated was my rap sheet. I ignored this as I thought it was nothing more than a bullys school yard tactic. 7. On March 16, 2009, Neil Sankey through the Sankey Firm, Inc.
conducted searches of my name and address through Accurint. The search was conducted using my name and address and the result of the search only pertained to me and contained by name, addresses, date of birth, and both my old and new Social Security numbers, see a true and correct attached as EXHIBIT 1. The search was conducted directly through Accurint, see the bottom left of the page. EXHIBIT 1 was received unredacted from the Sankey Defendants. The search results also contained names that had never been mine nor had I ever used associated to my Social Security numbers, dates of birth and address. 8. On March 16, 2009, Neil Sankey through the Sankey Firm, Inc. also
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This comprehensive Report included my name, Social Security numbers, date of birth; my husbands name, Social Security number, date of birth; my employment; my cell phone number and carrier, which were unlisted and unpublished; my parents names, addresses, Social Security numbers, dates of birth; real estate I owned or had owned; bankruptcies; debts; criminal records; property value; income; education; sisters name, addresses, Social Security number, date of birth and friends of my sister also with names, addresses, dates of birth and Social Security numbers; my in-laws names, dates of births, Social Security numbers, addresses, including that of my sister and brother-in-law, Brandy and Jeremiah Heller, their relatives private data, etc., see a true and correct copy attached as EXHIBIT 2. EXHIBIT 2 was received from the Sankey Defendants in unredacted form. 9. On April 6, 2009, Neil Sankey obtained a comprehensive report on
my husband, Brent. This comprehensive report shows the same private data as mine; including bankruptcy and debts; and his sister and brother-in-law, Brandy and Jeremiah Heller see a true and correct copy attached as EXHIBIT 3. EXHIBIT 3 was received from the Sankey Defendants in unredacted form. My husbands report also contains names that were never his and that he never used associated with his date of birth and Social Security number.
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10.
On April 10, 2009, Neil Sankey through the Sankey Firm, Inc. sent an
Email to Bob Unruh, a Reporter with World Net Daily. This Email contained my name; a partial of my old Social Security number; my full new Social Security number issued to me in 2000; my date of birth; my husbands name, date of birth and Social Security number; friends and relatives of mine, their names, Social Security numbers and dates of birth and a note that Sankey stated There is also a Jerry HELLER and Douglas Cramer look interesting, but where do you stop?, see a true and correct copy of this Email attached as EXHIBIT 4. EXHIBIT 4 was sent out by Sankey and Taitz and is still available on the Internet in unredacted form. As can be seen all the information contained in this Email was obtained from the comprehensive reports attached hereto as EXHIBITS 2 and 3. 11. Neil Sankey through the Sankey Firm, Inc. forwarded the above Email
to Orly Taitz on April 13, 2009, see a true and correct copy attached as EXHIBIT 5. EXHIBIT 5 was sent out by Sankey and Taitz in unredacted form and is still available on the Internet. 12. On April 17, 2009 Orly Taitz began publishing on her websites at http://www.orlytaitzesq.com/blog1;
http://www.repubx.com;
http://www.orlytaitzesq.com; and all over the Internet on other websites; through her Social network sites, e.g. Facebook, beforeitsnews.com, etc.; through twitter; by mass emailing; postal mailing; hand delivery; sent to numerous Federal and
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State law enforcement agencies; and sent out repeatedly including Internationally. What Orly Taitz called Dossier No. 6. Taitzs Dossier No. 6 contained the unredacted Email she received from Neil Sankey on April 13, 2009 with mine and my husbands private data unredacted. True and correct copies of Taitzs Dossier No. 6 is on file with this Court; see DN 190-3, pp. 220-233; DN 190-4, pp. 234246; DN 190-10, pp. 473-488; and DN 190-24, pp. 938-942, which are true and correct copies of Orly Taitzs Dossier No. 6. This document also appears in the docket numerous times in previous filings going back to May 2009, which are also true and correct copies. Taitzs Dossier No. 6 with Neil Sankeys unredacted Emails are still available online at
http://www.oilforimmigration.org/facts/?p=1478. 13. Orly Taitzs Dossier No. 6 was filed in her different Court cases
through the ECF filing system, including the Honorable David O. Carters Court in Barnett, et, al. v. Obama, et, al., Case number 8:09-cv-00082-DOC-AN on September 21, 2009, Docket Number [DN] 69. documents on September 30, 2009, see DN 77. 14. Neil Sankey states in his Declaration filed in support of the Reed Judge Carter sealed the
Defendants MSJ, DNs 494, 494-1 and 494-2 that he obtained my Social Security number from a Declaration I filed in a criminal case; and from a bankruptcy filing and that he did not obtain it from any reports obtained from Accurint, this is
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untrue. These documents Neil Sankey is referring to were filed by Orly Taitz and her Attorney Jeffrey Cook on July 11, 2011, see DNs 280-4, 280-2, and 283-5, which we objected to. 15. Neil Sankeys Exhibit A, DN 494-1 and Exhibit B, DN 494-2
were obtained from this Courts Docket after they were filed by Orly Taitz and Peter Cook, Esq. on July 11, 2011, over 2 years after Neil Sankey through the Sankey Firm, Inc. purchased consumer reports on me and my husband and sent out his Email with mine and my husbands private data, see EXHIBITS 1, 2, 3, and 4 attached hereto. 16. Orly Taitzs filing, DN 283-2 filed July 11, 2011, is the document
Neil Sankey attaches to his Declaration as Exhibit A, DN 494-1. If you look at Neil Sankeys Exhibit A, you will see the PACER header from Orly Taitzs filing of DN 283-2 filed on July 11, 2011. Thus, Neil Sankey did not obtain this document until after July 11, 2011, which was over two years after he purchased comprehensive reports on me and my husband and over two years after he sent the Email with our private data to Bob Unruh and Orly Taitz. 17. Peter Cooks filing, DN 280-4 and Orly Taitzs filing, DN 283-5 filed
July 11, 2011 are the supposed bankruptcy pages, and at the top of each page it has PACER headers over-lapping each other, identically to Neil Sankeys Exhibit B, DN 494-2. This shows that Neil Sankey obtained these pages from the
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Courts Docket after they were filed by Peter Cook, Esq. and Orly Taitz on July 11, 2011, which again was two years after Neil Sankey purchased the comprehensive reports on me and my husband and over two years after he sent out his Email to Bob Unruh and Orly Taitz with our private data. 18. Neil Sankeys statements that he obtained my Social Security number
and husbands data from a bankruptcy filing or supposed Declaration filed by me in a criminal case are untruthful and falsified as explained above and as shown by Neil Sankeys Exhibits and the filings of Peter Cook, Esq. and Orly Taitz on July 11, 2011, DNs 280-4, 283-2, and 283-5. 19. The Reed Defendants admit that their company, Accurint, sold
reports on me and my husband to Neil Sankey and the Sankey Firm, Inc. on March 16, 2009; April 6, 2009; April 15, 2009; April 19, 2009; and May 7, 2009, see the Reed Defendants MSJ at p. 8, paragraph C (a). The Reed Defendants all have refused to turn over the reports in which they sold on me and my husband to Neil Sankey, The Sankey Firm, Inc. and IRBsearch, LLC. The Sankey Defendants furnished the reports in which they searched and purchased on March 16, 2009, see EXHIBITS 1 and 2 attached hereto; and the report they purchased on my husband on April 6, 2009, see EXHIBIT 3 attached hereto. Defendants have refused to turn over the other reports. The Sankey
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they are not a credit reporting agency and do not sell consumer reports governed by the Fair Credit Reporting Act. 21. On or about October 25, 2010, I went to the Reed Defendants website
at https://personalreports.lexisnexis.com/, see a true and correct copy of this webpage attached as EXHIBIT 6, to learn how to obtain my consumer report from them. As can be seen in EXHIBIT 6, the Reed Defendants state
LexisNexis Risk Solutions is in compliance with FACT Act provides you with one FREE report during each 12 month period. (Fair and Accurate Credit Transactions Act, which is part of the Fair Credit Reporting Act), with a link to obtain the information pertaining to the FACT Act. If you look to the right hand side of EXHIBIT 6, the Reed Defendants have links on how to dispute incorrect information; how to place a freeze on your consumer report; and the consumers bill of rights, all of which is required by the Fair Credit Reporting Act. 22. I downloaded the instructions to receive my full file disclosure and
the form you must fill out and send in from the Reed Defendants website at https://personalreports.lexisnexis.com/pdfs/CD107_CP-File-Disclosure-RequestForm_pg-1.pdf; https://personalreports.lexisnexis.com/pdfs/CD107_CP-Fileand
Disclosure-Request-Form_pg-2.pdf;
https://personalreports.lexisnexis.com/pdfs/CD107_CP-File-Disclosure-Request-
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Form_pg-3.pdf, see true and correct copies of these documents attached as EXHIBIT 7. As can be seen from EXHIBIT 7 LexisNexis Risk Solutions refers to the full file disclosures as consumer reports. 23. On October 26, 2010, I sent in the required forms to the Reed
Defendants along with a utility bill and my drivers license to obtain the full package of reports, including Accurint. I sent the request twice, one under my old Social Security number and one under my new. My husband also sent the same forms with a utility bill and his drivers license to obtain all of his reports. Neither of us ever received our full disclosure consumer reports from any of the Reed Defendants. 24. What I did receive however, was a letter from Accurint/LexisNexis
Risk Solutions, Inc. dated November 29, 2010 stating I did not have an Accurint file with them, see a true and correct redacted copy of this letter attached as EXHIBIT 8; and a secondary letter with the same date from LexisNexis with documents that contained very limited information, not my full report, that LexisNexis identified as my consumer report, see a true and correct redacted copy attached as EXHIBIT 9 along with my rights under the Fair Credit Reporting Act, see a true and correct copy attached as EXHIBIT 10, reconfirming that the reports sold by the Reed Defendants are governed by the Fair Credit Reporting Act, which is contrary to the Reed Defendants false
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assertions in their MSJ. Both letters received were sent from the same place in Georgia. As can be seen from EXHIBIT 9, this consumer report contains the same information as the Accurint Reports sold to Neil Sankey, IRBsearch, LLC and the Sankey Firm, Inc. attached hereto as EXHBITS 1, 2, and 3, with the exception of the relative, friends and associates information. 25. The Reed Defendants state in their responses for Accurint to our
Interrogatories that I ran Accurint searches on myself and Plaintiff Lisa Ostella. A true and correct copy of Accurints Responses to our Interrogatories is attached hereto as EXHIBIT 111 at pp. 167-171, paragraph 4. This is untrue. I have never had accounts with or access to Accurint products. I did have an account with LexisNexis that allowed, and I conducted, searches in their peoplefinder database on myself, husband, Lisa Ostella and her husband with their permission. True and correct copies of the reports I conducted were previously filed in this case, see DN 66, at pages 32-37 and DN 391-4 at pages 16, 29, 31-32, which are true and correct copies. 26. The Reed Defendants attempt to get crafty with their wording. They
state in their MSJ at p. 3, 3rd paragraph, that their Accurint reports do not contain mothers maiden names or places of birth. This too is inaccurate. The Reed Defendants admit in their MSJ that there are different levels of Accurint reports,
I have only attached the pertinent pages, but am in possession of the entire document. 11
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which explains why Neil Sankey and the Sankey Firm, Inc. had to run five (5) reports on my husband and I on March 16, 2009; April 6, 2009; April 15, 2009; April 19, 2009; and May 7, 2009, they would not continue paying the expenses for the same report, in such a short period of time. You can purchase Accurint reports with birth and death records, as advertised on their website at www.accurint.com and is how Neil Sankey, The Sankey Firm, Inc. who furnished the information to Orly Taitz, obtained my sisters death which was posted by Orly Taitz on June 27, 2009. Orly Taitzs post, I am back from PA. Very Important, a true and correct copy of which I obtained from Orly Taitzs website at and
http://www.orlytaitzesq.com/blog1/?p=2585
http://www.orlytaitzesq.com/?p=2585 is attached hereto as EXHIBIT 12. In this post, Taitz states that my sister died in Santa Fe, died of a drug over-dose, and the Santa Fe police department handled the investigation. Taitz also published my place of birth, and my mothers maiden name, a true and correct copy of which I obtained from Orly Taitz website at http://www.orlytaitzesq.com/blog1/?p=2522 and http://www.orlytaitzesq.com/?p=5822 is attached as EXHIBIT 13. 27. Orly Taitz in her post attached as EXHIBIT 12 also states I
planned a hit on my sister, a contract, and other statements completely untrue and then attaches a couple of pages from a supposed transcript, to imply and
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substantiate Taitzs false statements that I had something to do with my sisters death. 28. The Reed Defendants also raise the issue of Intelius and their Motion The
circumstances are far different with the Reed Defendants than they were with Intelius, there is no comparison. 29. The Reed Defendants claim in their MSJ at p. 2, paragraph A that
their Accurint Reports are primarily used for locating persons, verifying identity, and detecting fraud. This is not completely accurate. The Reed Defendants, Accurint, markets the Accurint Reports to Insurance companies and debt collection companies to assist in disability and other claims, collection of debts, fees, etc. I went directly to Accurints website at
http://www.lexisnexis.com/risk/solutions/contact-locate/skip-tracing-accurintcollections.aspx, took a screen shot (picture) and downloaded their brochure targeting debt collection companies, a true and correct copy of which is attached hereto as EXHIBIT 14. I also went directly to Accurints website that focus on Insurance at http://www.lexisnexis.com/risk/downloads/literature/accurint-
insurance.pdf and I downloaded their pamphlet targeting Insurance Company, a true and correct copy of which is attached hereto as EXHIBIT 15. Reports
intended for use by Insurance companies and Debt Collection companies are
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consumer reports governed by the Fair Credit Reporting Act, 15 U.S.C. 1681a(d)(1)(A). 30. Orly Taitz filed a false law enforcement report against me on April
17, 2009 with the Orange County Sheriffs Department, a true and correct copy of the report obtained by subpoena is attached hereto as EXHIBIT 16", claiming I was the same person as Lisa Ostella and I had stolen approx. $10,000.00, which was completely untrue and falsified, from her and as a result thereto, she had Neil Sankey conduct background reports on me. 31. Neil Sankey went on the Plains Radio show with Edgar Hale on May
28, 2009 and told all the listeners that I owed a lot of people money in San Bernardino County and that was sufficient for him to run reports on me. This radio show transcript has been filed with this Court numerous times, and a copy of the entire radio show was provided to Judge Robreno in Pennsylvania, in this case on August 9, 2009 during a restraining order hearing. Sankey also discussed a loan I had taken out. 32. The Reed Defendants stated in their responses to our Interrogatories at
number 4, that the Sankey Firm, Inc.s purpose under the Gramm-Leach Bliley Act [GLBA], which Accurint is governed by, was For use by persons holding a legal or beneficial interest relating to the consumer and For use by persons acting in a fiduciary or representative capacity on behalf of the consumer.. See
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EXHIBIT 11, paragraph 4 at p. 169, for Mr. Sankeys purpose under the GLBA. 33. The Sankey Defendants used GLBA purpose claiming he was
collecting money from me, which is a report, governed by the Fair Credit Reporting Act. I have never given any of the Sankey Defendants permission or authorization to obtain any of my financial or consumer reports, I did not and do not owe Orly Taitz or any of the Sankey Defendants any money. I did not have knowledge at the time the Sankey Defendants obtained my financial and consumer reports, I did not know who any of the Sankey Defendants were prior to April 17, 2009, when Taitz sent out Dossier No. 6, nor had I ever heard of them. 34. The GLBA requires all financial institutions to notify its customers
when information is sought on them, giving their customer the opportunity to optout of the disclosure, except under a few exceptions, see 15 U.S.C. 6802(a) and 6802(b). One of the exceptions is disclosure to a Credit Reporting Agency, see 15 U.S.C. 6802(e)(6)(A). 35. The Reed Defendants admit to obtaining records from financial This is interesting
because neither I nor my husband have ever been notified by any of our financial institutions that any of the Reed Defendants were seeking our information. The
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only exception listed in the Gramm Leach Bliley Act that any of the Reed Defendants would qualify for is if they were credit reporting agencies. 36. Likewise, I and my husband are opted out with the three (3) National
Credit Reporting Agencies from selling our credit header data; and for all promotional purposes. Again, the only way any of the Reed Defendants could have obtained the credit header data from my credit reports or my credit reports, as they stated they obtain in their MSJ, from the National Credit Reporting Agencies is if they were another credit reporting agency. 37. The Reed Defendants also admitted in their MSJ that Neil Sankey
used the Sankey Firm, Inc.s log-in credentials to access and obtain the Accurint Reports purchased on me, my husband, Lisa Ostella and her husband as we plead in our Motion for Summary Judgment, pending before this Court, against Todd Sankey and the Sankey Firm, Inc. 38. As for the report that Accurint sold to IRBsearch, LLC, Neil Sankey
and the Sankey Firm, Inc. attached as EXHIBITS 1and 2, there are numerous names listed as AKAs with my date of birth and Social Security number that have never been my name or used by me as my name, these include but are not limited to: Lisa A. Liberi; Lisa R. Courville-Richardson; Lisa R. Courvillerichar; Lisa Reynolds;
Declaration of Lisa Liberi
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Lisa O. Courville; Lisa O. Courville Richardson; Lisa Courviller; Lisa Richardson Courville; L Richardson Courville; L Courville Richardso; L.R. Reynolds; Lisa Courricharcourri; Lisa R. Courvillerichar; Lisa R. CourvilleRichard; Lisa R. Courvillerichards; Lisa R. Courvillerichardso; Lisa R. Libert; L. Liberia; Lisa R. Liveri; Lisa R. Marshall; Lisa Rich; Lisa C. Richardson; Lisa R. Morris; Nicki Odem; Eloisa Morales; Lisa Renee Liberi; Lisa C. Richardson; Eloisa Becerra Morales; Nicki Odem; and Lisa Corvillericher. 39. The Reed Defendants through Accurint are also reporting
bankruptcies and judgments back from 1993, including but not limited to: Chapter 13 BK filed 11/30/2000 Case No. 0027288 Chapter 7 BK filed 12/12/2001 Case No. 0112042 Chapter 7 BK filed 06/02/1993 Case No. 9318163 Forcible Entry filed 05/17/2001 Case No. 134193 Small Claims Judgment filed 4/18/2001 Case No. 29409 Civil Judgment filed 9/01/2000 Case No. RCCI47798 Amt. $7,348 Civil Judgment filed 9/01/2000 Case No. RCCI47798 Amt. $8,430 Small Claims Judgment filed 5/08/2000 Case No. 00S00403 Civil Judgment filed 4/19/2000 Case No. RCCI45728
Declaration of Lisa Liberi
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Small Claims Judgment filed 9/01/1998 Case No. 17298 Small Claims Judgment filed 3/07/1994 Case No. 120009 Small Claims Judgment filed 8/10/1993 Case No. 116860 All of which are in violation of the Fair Credit Reporting Act, 15 U.S.C. 1681c(a)(1); 1681c(a)(2); and Sections 312 and 313 of the FACT Act. 40. The Reed Defendants through Accurint are also reporting me
convicted in incorrect criminal case information by my name, date of birth and Social Security number, in violation of the Fair Credit Reporting Act, 15 U.S.C. 1681c(a)(2), these include but are not limited to: San Bernardino County Case No. FSB044914 File Date: 06/30/2004 The above incorrect case information is listed repeatedly on the comprehensive background Report. I was not convicted in that case, that case was dismissed as it was a duplicate case. And, San Bernardino County Ticket Number 030202LL File Date: 03/21/2002 The above was a ticket I received, not a criminal case. 41. The Reed Defendants through Accurint also have many incorrect
addresses affixed with my name, Social Security number (old and new Social Security number) and date of birth, these include but are not limited to:
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9999 Willow Credk Rd, San Diego, CA 92131-1117 (Oct. 2006); 6022 Mira Vista Ln, Fontana, CA 92336-5806 (Dec. 2005); 920 S. Village Oaks Dr., Covina, CA 91724-3605 (Jul 2002 Feb. 2003); 11338 Kenyan B 119 WA, Rancho Cucamonga, CA 91701 (Sept. 1999 Dec. 2001); 26371 Paloma Apt 156, Foothill Ranch, CA 92610 (Nov 1991 Jan 1999); 1129 Headingly Ave. NW, Albuquerque, NM 87107 (Aug. 1991 Jan. 1999); 7200 Pazallo Pl, Alta Loma, CA 91701; 7150 Smiling Wood Ln Apt 705, Houston, TX 77086-3140; 7100 Smiling Wood LN Apt 507, Houston, Texas 77086-3140; 12777 Ahsford, Houston, Texas (Dec.1990); 7100 Smiling Wood Ln Apt 706, Houston, Texas 77086-3150; 11338 Kenyon Way Ste A, Rancho Cucamonga, CA 91701-9236 (Jan. 2004 - Dec 2006); 11338 Kenyon Way Ste B-119, Rancho Cucamonga, CA 91701-9236 (Oct 2001 Dec 2006); Pozallo Pl 7020, Alta Loma, CA 91701;
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11338 Kenyon Way Ste B, Rancho Cucamonga, CA 91701-9236 (Nov. 2001 Jan. 2002); 40 Bonito Court, Santa Fe, NM 87508-8311 (08/2006-01/2007); 1704 Llano St Ste B, Santa Fe, NM 87505-5415 (12/2003-12/2006); 7349 Milliken Ave., Bldg. 1 Rancho Cucamonga, CA 91730-7435 (Sept. 2001 March 2002); 1704 B LLA NO ST 159, Santa Fe, NM 87505 (7/2006-11/2006); 1704 Llano St Apt 159, Santa Fe, NM 87505-5415 (11/2004 10/2006); and 159 1704B Llano St, Santa Fe, NM 87505 (01/2005 05/2005).
42.
The Reed Defendants have all been put on notice and notified of all
the incorrect information in my file on October 26, 2010; February 28, 2010 when Mr. Berg wrote to them; and again in my responses to the Reed Defendants Interrogatories. To date, I have not received any correct reports or
communications in regards to my dispute. 43. These additional and incorrect names, addresses, expired bankruptcy
and judgments, and incorrect criminal information affixed to me by Accurint and the Reed Defendants, with my Social Security number and date of birth will stay
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with me forever. Accurint as well as the other Reed Defendants have resellers who sell their information and now have all this incorrect information associated with me in their databases, as well as other Data Brokers who purchase from Accurint and the other Reed Defendants and in turn resell the information to other third parties. I will never be able to correct this incorrect information. Not to mention the fact it was posted all over the Internet, sent by mass emailing, discussed on radio shows, sent through RSS feeds, sent to Millions of individuals and businesses including internationally, posted on Social network sites, e.g. Facebook, Beforeitsnews, etc., tweeted, etc. by Neil Sankey and Orly Taitz. 44. As a result of the disclosure of mine and my husbands private data,
both my husband and I have suffered full identity theft, which cannot be fixed. Many accounts were opened in our name with Mervyns, Target, Chase Bank, a timeshare was financed in our names, a mortgage was taken out in our name, a car was purchased from Bank of American in our name, and repossessed, and other credit accounts, all without our knowledge, permission and/or consent. It cant be fixed because our private data was shared with millions of people and businesses including internationally by the Sankey Defendants and Orly Taitz. Each time we spend attempting to clear up one account, three more are opened. 45. Even if my husband and I were provided new Social Security
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have my mothers maiden name, place of birth, date of birth, name, address, and other private data that the Social Security Administration asks to be verified before providing any information, and can call the Social Security Administration and obtain our new numbers. 46. My husband and I, as filed with this Court numerous times and
explained above, have also suffered other severe damages, including but not limited to medical expenses, medical complications, harassment, moving expenses, stalking, my husband had to take time of work, our utility services were scheduled shut-off by a person using my identity, death threats, non-stop phone calls, people showing up at our house, looking in our windows, false law enforcement reports (State and Federal), false reports to probation, abuse of process, malicious prosecution, severe emotional distress, paramedic expenses and procedures, medical procedures and expenses, hospitalizations, being shunned by neighbors, full identity theft, our credit was destroyed, etc. many of which are also permanent. I declare under the penalty of perjury of the Laws of the United States and the State of California that the foregoing is true and correct. Executed this 20 th day of April, 2012 in the State of New Mexico.
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EXHIBIT 1
Declaration of Lisa Liberi
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EXHIBIT 2
Declaration of Lisa Liberi
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EXHIBIT 3
Declaration of Lisa Liberi
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EXHIBIT 4
Declaration of Lisa Liberi
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From: Neil SANKEY [mailto:nsankey@thesankeyfirm.com] Sent: Friday, April 10, 2009 10:01 AM To: Bob Unruh Subject: LISA LIBERI etc Bob here are some bare facts about Bergs assistant. See below and attachments I dont know how much of the story you have already, but is essentially about WHO she really is and the questions that unfortunately brings up about Berg. Call, if you need to, at your convenience. Neil Sankey Investigator & Consultant. THE SANKEY FIRM Simi Valley, California 93063 nsankey@thesankeyfirm.com 805 520 3151 818 212 7615 cell
According to the Police she was born COURVILLE and married a Richardson (Possible Alan Douglas Richardson, currently residing in Las Vegas .) IF it was the other way around, then the Courville is Bill Marshall Courville 11/10/61 of Houston , Tx. 457-71-x I have several SS#'s for her and a LOT of AKA's. Her real SS# is probably 462-45-xxxx. Most prominent otherwise are 563-60-xxxx, 57217-x, 622-19-x She went BK in 2002 Her brother is probably Lawrence E Morris of Fontana and Rancho Cuc , CA . He was born 1/16/64 Her Husband, Brent J, a Parolee, I have not researched that. Is probably Brent J McCormack 563-77, also uses 331-02-x There is also a Jerry HELLER and Douglas Cramer look interesting, but where do you stop?.
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EXHIBIT 5
Declaration of Lisa Liberi
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From: Neil SANKEY nsankey@thesankeyfirm.com Subject: FW: LISA LIBERI etc To: dr_taitz@yahoo.com Date: Monday, April 13, 2009, 7:04 PM Here is the Liberi stuff you requested. This is also what I sent to Bob Unruh . From: Neil SANKEY [mailto:nsankey@thesankeyfirm.com] Sent: Friday, April 10, 2009 10:01 AM To: Bob Unruh Subject: LISA LIBERI etc Bob here are some bare facts about Bergs assistant. See below and attachments I dont know how much of the story you have already, but is essentially about WHO she really is and the questions that unfortunately brings up about Berg. Call, if you need to, at your convenience. Neil Sankey Investigator & Consultant. THE SANKEY FIRM Simi Valley, California 93063 nsankey@thesankeyfirm.com 805 520 3151 818 212 7615 cell
According to the Police she was born COURVILLE and married a Richardson (Possible Alan Douglas Richardson, currently residing in Las Vegas .) IF it was the other way around, then the Courville is Bill Marshall Courville 11/10/61 of Houston , Tx. 457-71-x I have several SS#'s for her and a LOT of AKA's. Her real SS# is probably 462-45-xxxx. Most prominent otherwise are 563-60-xxxx, 57217-x, 622-19-x She went BK in 2002 Her brother is probably Lawrence E Morris
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of Fontana and Rancho Cuc , CA . He was born 1/16/64 Her Husband, Brent J, a Parolee, I have not researched that. Is probably Brent J McCormack 563-77, also uses 331-02-x There is also a Jerry HELLER and Douglas Cramer look interesting, but where do you stop?.
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EXHIBIT 6
Declaration of Lisa Liberi
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EXHIBIT 7
Declaration of Lisa Liberi
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Declaration of Lisa Liberi
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Declaration of Lisa Liberi
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Declaration of Lisa Liberi
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Declaration of Lisa Liberi
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EXHIBIT 12
Declaration of Lisa Liberi
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http://www.orlytaitzesq.com/?p=2585
Home .Latest polling: Dr. Orly Taitz is ranked #1 among CA GOP voters. Candidate Statement on CA ballots for U.S. Senator Complaint in GA GA Judge Denies Obamas Motion to Dismiss GA Proposed Summary of Law and Fact Election challenge Secretary of State Indiana.pdf Farrar et al v Obama et al First amended complaint.doc Farrar corrected proposed summary of law and fact.pdf Transcript Farrar.pdf Farrar v Obama Exhibits in case file.pdf Farrar Exhibits entered in the record by Judge Malihi.docx Criminal Complaint sent to the AG of MS. Orly Pleadings before NH Video: Orly before NH Election Committee Police Concerns Sample Letter Videos
Mail donations to: Defend Our Freedoms Foundation, c/o Dr. Orly Taitz 29839 Santa Margarita Pkwy, Ste 100 Rancho Santa Margarita, CA 92688. Contact Dr. Taitz at orly.taitz@gmail.com or dr_taitz@yahoo.com. In case of emergency, call 949-683-5411. "It is not the critic who counts; not the man who points out how the strong man stumbles, or where the doer of deeds could have done them better. The credit belongs to the man who is actually in the arena, whose face is
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marred by dust and sweat and blood; who strives valiantly; who errs, who comes short again and again, because there is no effort without error and shortcoming; but who does actually strive to do the deeds; who knows great enthusiasms, the great devotions; who spends himself in a worthy cause; who at the best knows in the end the triumph of high achievement, and who at the worst, if he fails, at least fails while daring greatly, so that his place shall never be with those cold and timid souls who neither know victory nor defeat." -- Theodore Roosevelt, April 23, 1910 When the people fear their government, there is tyranny. When the government fears the people, there is liberty. -- Thomas Jefferson During times of universal deceit, telling the truth becomes a revolutionary act. -George Orwell First they ignore you, then they ridicule you, then they fight you, then you win. -- Mahatma Gandhi
The articles posted represent only the opinion of the writers, do not necessarily represent the opinion of Dr. Taitz, Esq. Dr. Taitz, Esq. has no means of checking the veracity of all the claims and allegations in the articles.
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Case 8:11-cv-00485-AG-AJW Document 503-12 Filed 04/19/12 Page 5 of 7 Page ID #:13107 On the plane to Philly I read hundreds of pages of transcripts in criminal case hearings of Liberi. Keep in mind that recently I had threats to shoot me and burn my body for the world to see. Later a clamp was missing and fumes emissions hose was disconnected in my car, that lead to the fumes accumulating around the engine, which is extremely dangerous. As I read August 4, 2004 transcript, I found a testimony of detective Liebreich. He testified in regards to recording of phone calls Lisa Liberi made from jail to her husband Brent Liberi. She was telling him that she was upset with her sister Cheryl Richardson. Cheryl cooperated with the police and told them about 19 prior criminal investigations of Liberi. Liberi told Brent (see copies of the transcripts attached) that she will get her sister in jail and will spread the word that she is a rat. She was telling Brent do you know what they do in prison to rats? At that time DA James Secord asked the detective to explain. The detective stated that a contract will be issued on such person, a green light and such person will be attacked and/ or killed. He mentioned that 5 people were killed last year alone. I got concerned, if this woman could plan a hit, a contract on her own sister, it would not be inconceivable that she would plan a hit on an attorney and her family, if this attorney outed her. I kept reading and found out that indeed less then a year later her sister was dead. Official cause of death, from what I understand, is drug overdose. However, drug overdose can be self inflicted or inflicted by others. At this time I would like to know if there are any pathologists among the readers of this blog? Can someone go to the police department and probation department in Santa Fe NM and show them all this info. According to detective Teresa Standiford from Orange County economic crimes unit, my report and the whole file was transferred to Santa Fe, as Lisa Liberi lives there. I tried to find out the status, but it is very hard to reach anybody in the police department there. The phone number of detective Teresa Standford in CA 714-647-7486, 714-647-7038. Case # 09-068339. Liberis prosecuting DA in Ca is James Secord 909-387-8309 In Santa Fe I was given a number for detective Martin Lopez 505-955-5010, General number for the Santa Fe police is 505-955-5038. Investigations unit- 505-955-5038 The supervisor of her probation department is Joan Martinez 505-476-2359 Regional probation officer is Rose Bobchack 505-476-2363. After the hearing on Thursday I talked to Phil Berg and I have shown him the transcripts of Liberis prior hearings. I put him on notice in regards to her dangerous propensities and let him know that if he continues with this law suits and continues denying, what is clearly a public record, he endangers me and my whole family. If something happens and Liberi is involved, he will be held accountable as an accomplice.
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Comments
5 Responses to I am back from PA. Very Important. 1. sillyhaha June 27th, 2009 @ 5:57 pm I am thrilled that all went well for you and the other defendants on Thur! Seems like the Judge feels that this case is a complete waste of time and unfair to all the defendants. It is a frivolous case. Interesting info on Lisa Liberi. Sounds like she may be looking at more legal problems as a result of going after you and Linda Starr. Serves her rightand I hope Berg gets sanctioned for this nonsense. Well done, Dr. Taitz!!! 2. sillyhaha June 27th, 2009 @ 6:22 pm Dr. Taitz, Please be careful. This Lisa Liberi woman is dangerous. Thank God she doesnt live near you. Somewhere someone talked about escorting you to the courthouse on the 13thhe would be carrying a gun. This concerns me. He wont be allowed in with the gun. And, I wouldnt want anything to damage your reputation. I personally would leave all guns at home. Peaceful protesters can assist you to and from the building. After the von Brunn incident, I would hate to see further linking of guns/violence and the citizenship issue. 3. Bill Angles June 27th, 2009 @ 6:52 pm Searched web for Chuck Crismayer with no luck, so I called phone number you posted and talked with Mr. CRISMIER. He was kind enough to give me instructions to be able to hear your interview with him. Thought I would pass it on: http://www.saveus.org Click on Viewpoint broadcast button on left side of page, click on ARCHIVES. Interview is posted there. Of all the interviews Ive listened to (and that is most of them) this is the best. Mr. Crismier did a great job with his supporting commentary. He is a first-class broadcaster, talented enough to have a show on a major network in my opinion. 4. tainler June 27th, 2009 @ 8:20 pm I am VERY concerned for Orly and her family. Lisa liberi doesnt have to live close to Orly to attempt anything. If she has connections to get rid of someone then all she needs is a phone or computer. Is there a way to investigate her computer or tap her phone lines that would be legal? A very frightening situation. I am starting to wonder if Lisa L. has any deep ties with obama and his clan. Im sure she does. Anyway, remember AirFrance flight 447 that just crashed in the ocean? I read there there were people of status that maybe were or could expose anything government wise and suspiciously enough the plane went down. Orly should not announce any travel plans, flight information and should not
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Case 8:11-cv-00485-AG-AJW Document 503-12 Filed 04/19/12 Page 7 of 7 Page ID #:13109 leave her car at the airport. Is there any way that police could be notified ahead of time and have the area checked out at the location of the hearing on the 13th. looking for snipers, a so-called drunk driver that could run up on a sidewalk and kill anyone with their car and make it look like an accident? I personally feel every act of protection should be high priority for Orly and her familys safety. They know she will be gone on this tripwill her house, family, personal property be safe? Is it possible to have a neighborhood watch while she is gone or have the police do frequent checks at her house while not there? I know Orly is smart but she probably is the most hated person by Obama and his corrupt thugs. I just want Orly and her family to be safe. The electrical wires to her house should be checked too as well as air conditioning units. Anything can be done to those things to make them malfunction and overheat. Not sure if this should be posted as long as Orly reads it. 5. live oak June 27th, 2009 @ 10:03 pm Its really good to have you back Orly! Im so sorry that youve had to spend time away from your family with this mess that Berg has caused you, and I hope the good people that did donate to Berg can get their money back. Mr. Berg should have to pay all your court costs and expenses as well. What he has done to you and to the profession is beyond despicable! Please be careful Orly. We all love you and have you in our prayers. Have a peaceful and relaxing weekend with your family. No worries. Monday is a big day. I pray that this will be over soon while America is still recognizable.
DVD of the historic trial in GA and DVD of a historic testimony in NH, where evidence was provided showing Obama using a forged birth certificate and a stolen social security number. The DVDs are in a beautiful commemorative case with personal autographs from attorney Dr. Orly Taitz $22.50 each +$2.50 for shipping and handling. Pay by credit card on the website RunOrlyRun.com or by check to: Orly Taitz for US Senate 2012, 29839 Santa Margarita ste 100, RSM, CA 92688. -----------------------------------Attention Users of Internet Explorer: Internet Explorer users may be infected with viruses that can crash their computers when browsing or commenting in this website.
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EXHIBIT 13
Declaration of Lisa Liberi
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Dr. Orly Taitz Esquire Defend Our Freedoms Foundation 26302 La Paz ste 211, Mission Viejo CA 92691 Copyright 2009 Previous Post Ties to Everett, need help with research ,
You mentioned Everett, Wash. connection with Barack Obamas mothers family. Just wondering if you knew that connection went back for over a century
http://www.heraldnet.com/apps/pbcs.dll/article?AID=/20081026/NEWS01/710269867
Plus a bit more about the Wolfleys: http://www.santacruzsentinel.com/world/ci_12517525 So with a POTUS with a Muslim father and German roots mother, why shouldnt Israelis be worried? If you do post this info, please dont mention my name or email. Cheers Response I am really concerned about several coincidences 1. a man who threatened to shoot me and burn my body for the world to see was tracked to a computer server in Everett WA. Another person that threatened me was traced to Chauhelis WA and yet another one to Canada (from what I understand not far from the border with WA state). A few days after the threat there was a clamp missing and a disconnected fumes emissions hose in my car and my husbands car died, suddenly a fuse was missing. 2. Obama does not talk about it, but his mother wasnt in HI when he was a baby, she was enrolled in the U of Seattle WA from August 1961-till June 1962, which means that as a baby he lived in WA. 3. Lisa Liberi, assistant for Berg, who has a lengthy criminal record of grand theft, forgery of documents and forgery of official seal doesnt talk about it, but according to records she was born in WA state. From what I recall Bellview WA. (her name at birth was Lisa Richardson. From what I recall father -Jack Richardson, mother Shirley Wadell)
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4. Obama, Liberi and Obamas mother Stanley Ann Dunham- all have multiple social security numbers according to databases. 5. Liberi was convicted of forgery of documents and according to experts, there are multiple signs of forgery in Obamas documents. 6. Stanley Ann Dunham also went by the name Shirley Ann Dunham. We found a Dunham organization, owned by Shirley Ann Dunham; one location was in Seattle another in Bellview WA. They dealt with insurances, lawyers, mortgages- you can get ss numbers from all of these records. 7. From what I recall, there was a discrepancy between Intellius records and Secretary of state records. According to the sec. of state a man owned that co. One of our volunteers pulled court records in Bellview for the Dunham organization. This man, Mr. Dunham (dont remember first name) kept changing his middle initial in several court cases, which was suspicious by itself. 8. There was a very strange newspaper article in WA (I believe Seattle), from what I recall, when Obama supposedly was in Columbia. It stated that one, Roman Obama studied at the university of Patrice Lumumba in Moscow, Russia, and had some financial difficulties. 9. When grandma Dunham got sick, a reporter from WA (I believe Seattle) has writen an interview with Charles Payne, saying the grandma got a broken hip. She was dead of cancer a few days later. I was wondering, why did it come out in WA, and not HI or IL? 10. Based on all of the above, I have a nagging feeling, that there is somebody there in WA, some relative of Obama, somebody who we might think is no longer with us.
This entry was posted on Monday, June 22nd, 2009 at 3:35 pm and is filed under Uncategorized. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.
[emphasis added]
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EXHIBIT 14
Declaration of Lisa Liberi
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http://www.lexisnexis.com/risk/solutions/contact-locate/skip-tracing-accurint-collections.aspx ID Case 8:11-cv-00485-AG-AJW Document 503-14 Filed 04/19/12 Page 2 of 4 Page #:13115
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EXHIBIT 15
Declaration of Lisa Liberi
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http://www.lexisnexis.com/risk/downloads/literature/accurint-insurance.pdf Case 8:11-cv-00485-AG-AJW Document 503-15 Filed 04/19/12 Page 2 of 2 Page ID #:13119
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EXHIBIT 16
Declaration of Lisa Liberi
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Philip J. Berg, Esquire (PA I.D. 9867) E-mail: philjberg@gmail.com LAW OFFICES OF PHILIP J. BERG 555 Andorra Glen Court, Suite 12 Lafayette Hill, PA 19444-2531 Telephone: (610) 825-3134 Fax: (610) 834-7659 Attorney in pro se and for Plaintiffs UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION : : : Plaintiffs, : : : : : : Defendants. : :
I, Philip J. Berg, Esquire, hereby certify a true and correct copy of the Declaration
of Lisa Liberi in support of Plaintiffs Opposition to the Reed Defendants Motion for Summary Judgment was served through the ECF filing system this 20th day of April 2012 upon the following:
James F McCabe Morrison & Foerster 425 Market St San Francisco, CA 94105-2482 Email: jmccabe@mofo.com Attorney for Defendants: Reed Elsevier, Inc.; LexisNexis Group; LexisNexis; LexisNexis Risk and Information Analytics Group, Inc.; LexisNexis Risk Solutions, Inc.; LexisNexis Seisint, Inc. d/b/a Accurint; Choicepoint, Inc.
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Marc Steven Colen, Esq. Law Offices of Marc Steven Colen 5737 Kanan Road, Ste. 347 Agoura Hills, CA 91301 Email: mcolen@colenlaw.com Attorney for Defendants: Todd Sankey; and The Sankey Firm, Inc. Orly Taitz 29839 Santa Margarita Parkway, Suite 100 Rancho Santa Margarita, CA 92688 Email: orly.taitz@gmail.com and Email: dr_taitz@yahoo.com Attorney for Defendant Defend our Freedoms Foundation, Inc.
Kim Schumann, Esquire Jeffrey P. Cunningham, Esquire SCHUMANN, RALLO & ROSENBERG, LLP 3100 Bristol Street, Suite 400 Costa Mesa, CA 92626 Email: pcookA@srrlawfirm.com Attorney for Defendants Orly Taitz; Orly Taitz, Inc.; and Law Offices of Orly Taitz /s/ Philip J. Berg Philip J. Berg, Esquire