Professional Documents
Culture Documents
EXHIBIT “1”
Z:\Liberi, et al, Taitz, et al, Plaintiffs’ Motion for Sanctions; Atty Fees; and Motion to Strike
Case 2:09-cv-01898-ER Document 146-1 Filed 10/07/10 Page 2 of 12
Pennsylvania, and represent the Plaintiffs herein and am also a Plaintiff in the within action. I
am over the age of eighteen (18) and have personal knowledge of the facts herein. If called to do
I declare as follows:
approximately the end of 2006, early 2007. I do not pay any wages to Mrs. Liberi or her
2. I have reviewed the newest filing by Defendant Orly Taitz, which was filed on
September 28, 2010 and appears on this Court’s Docket as Entry Number 145, “Reply to
3. Defendant Orly Taitz’s filing contains nothing truthful. Instead, she has falsified,
manipulated, twisted, and maliciously misquoted all the events surrounding this case and
contains documents which were forged with Mrs. Liberi’s email address. Defendant Taitz’s
4. Taitz, Belcher and Geoff Staples falsely accuse Lisa Liberi of handling credit
cards, processing credit cards, setting up my Linkpoint account, having full control of my
Linkpoint and PayPal accounts and many other falsified accusations. None of this is true.
5. Lisa Liberi had nothing to do with the setup of my Linkpoint account. Dave
Williams, a third party contractor for Linkpoint, opened my account and Geoff Staples took
control of my Linkpoint account thereafter. Lisa Liberi did not have anything to do with my
Linkpoint or PayPal accounts. Lisa Liberi never handled any donations or credit cards,
never processed any credit cards, never stole from me, and never had access to my financial
accounts.
6. The attachments filed with Defendant Taitz’s Reply have been altered and Mrs.
Liberi’s email address was fraudulently added to the documents. This is not the first time
that my clients’ names and email addresses have been forged on documents filed with this
2010, appearing as Docket Entry No. 145, have been altered to reflect that Mrs. Liberi sent
the emails. The header information presented by Mr. Staples in his attachments to Taitz’s
filing, were presented as if Lisa Liberi was forwarding them to Geoff Staples. The header
information does not show routing from Mrs. Liberi’s email, instead it shows being routed
routing. The mail client Geoff Staples is using is Reflexion.net, which appears in the header
information supplied by Geoff Staples purportedly sent by Mrs. Liberi. According to Geoff
8. I pulled the header information from an email I received from Geoff Staples on
October 21, 2008, ironically, the header information reflects coming from Geoff Staples,
using Reflexion.net as the mail client with an assigned I.P. 205.237.99.176, see EXHIBIT
“B”. As you can see, Geoff Staples attachments show in the header information, that the
emails were actually sent from Geoff Staples and not Lisa Liberi.
9. I have pulled the header information from an email I received from Geoff Staples on
October 21, 2008, to show that Hostricity which is a local host of megawebservers, appears
as does his mail client Reflexion with IP 205.237.99.176 in his mail headers, which matches the
header, supplied by Geoff Staples in his attachments, filed by Taitz, of the email supposedly sent
by Mrs. Liberi. This proves that the email was sent from Geoff Staples and not Mrs. Liberi.
10. Mrs. Liberi’s husband, Brent has never had any credit card accounts setup on my
website and has never had his PayPal account accepting donations on my behalf, as falsely
accused by the Defendants. The only person who has ever stolen from me, as better
explained below, is Geoff Staples. And, as explained below, and substantiated with all the
email exchanges between Geoff Staples and myself and screen shots attached as Exhibits, it
was Geoff Staples who was illegally collecting all my supporters’ credit card details,
11. In or about August 2008, I received a call from Defendant Linda Belcher who was
using the name “Linda Starr”, asking me if I had heard the issues surrounding, then Senator
Barack H. Obama. Throughout the years, I had spoken to Linda Belcher on occasion. I did
not even know Linda Belcher’s legal name until I was forced to file the within action to
12. After researching the issues, Mrs. Liberi drafted a suit on my behalf, which I filed
against then Senator Obama. Said suit was filed on August 21, 2008. I filed two [2]
13. I was looking for someone to set-up and maintain a website on my behalf
regarding the recent litigation pertaining to Obama. Linda Belcher stated she had a long time
friend of twenty [20] years, Geoff Staples, who could set-up and maintain the website on my
14. Geoff Staples set-up my website at obamacrimes.com on August 21, 2008 and
handled everything pertaining to the website and my donation links. No one except Geoff
Staples had any log-in details or passwords to the website or my domains. I did not even
15. Geoff Staples asked me for my PayPal details, my log-in and password so he
would be able to set-up the donation button on my website. I gave Geoff Staples the
requested information and Mr. Staples set-up the donation button on my website.
16. In or about the end of September 2008, I began having problems with PayPal. I
had Mr. Staples set-up my fiancé’s PayPal account to use until I obtained my Linkpoint
account. I went ahead and purchased a Linkpoint account from David Williams on or about
17. On October 21, 2008 I received an email from Linkpoint welcoming me to their
services. In this email, it gave my store name, store number, my secure host name and my
user ID. This email did not give any password information. See EXHIBIT “C”. I
forwarded a copy of this email to Geoff Staples with instructions and a copy to Mrs. Liberi
18. On October 22, 2008, I made several calls to Geoff Staples to inquire whether my
Linkpoint account had been set-up on my website. Instead of receiving a return call from
Mr. Staples, I received an email from Linda Belcher stating she had called Mr. Staples and he
19. At this time, Geoff Staples was the only person with the password to my
Linkpoint account. I did not have access to my own account. To date, I still do not have my
Linkpoint Admin log-in details or password. I only have the user/store level access.
learned at that time that Geoff Staples had the donation information from my Linkpoint
forwarded email my supporter had received from Geoff Staples regarding his donation. Mr.
Staples was receiving all the donation information when a donation was made on Linkpoint
22. Since Mr. Staples had locked me out of my Linkpoint account, I contacted
Linkpoint and had my password reset. Geoff called me upset stating he needed to get into
my Linkpoint account due to issues with my website and gave excuses as to why he had
changed my password. Based on the fact he was my webmaster and had full control of my
website, I emailed him my password. See EXHIBIT “G”. Mrs. Liberi was not copied on
this email and never had the passwords to my PayPal or Linkpoint accounts. Mr. Staples
23. On November 2, 2008, after I had emailed my Linkpoint password to Mr. Staples,
Linkpoint account. See EXHIBIT “H”. The password was reset and again Mr. Staples and I
24. On November 3, 2008 I received another email from Mr. Staples. Mr. Staples
stated David Williams was “adding Linkpoint Connect to my Linkpoint account”. Mr.
Staples further explained how he was going to set-up the donation buttons on my website.
25. I received another email from Mr. Staples on November 3, 2008 informing me
that Dave Williams had placed the order for the Connect service and it would be available
this same date. Mr. Staples also informed me that he should have the server to my website
26. On November 4, 2008, Mr. Staples sent me an email stating Linkpoint was up on
my website. Mr. Staples had carbon copied Mrs. Liberi on his email requesting us to make a
small donation and to let him know if we encountered any problems. What was odd is that
Mr. Staples stated, “When it goes over to the Linkpoint site, their page doesn’t match the
website. This is due to a technical problem with Linkpoint, which they claim will be fixed in
the next 24 hours”. See EXHIBIT “K”. I have since learned that Geoff Staples never used
the secure link provided October 21, 2008 by Linkpoint. The problem referred to in Mr.
Staples statement above was not a Linkpoint problem, but instead, Mr. Staples had all the
Geoff Staples Hostricity server. See EXHIBIT “L”. With this, Mr. Staples was gathering
and storing all my supporters’ names, addresses, phone numbers, credit card numbers, etc.
Geoff Staples had to manually enter the credit card information as shown in these attached
reports of donations made by individuals, which were processed through Linkpoint by the
same private I.P. address (private IP addresses are not what the normal individual uses, but
webmasters and web host companies have access to private I.P. addresses). The private I.P.
had to have belonged to Geoff Staples, as he was the only one with access. See EXHIBIT
“M”. An unredacted copy of this report will be furnished to the Court “under Seal” upon
request.
27. On November 4, 2008 I received an email from Geoff Staples from his Hostricity
Help Desk helpdesk@hostricity.com email address. Mr. Staples had included numerous
email addresses in this email. This particular email was in response to the email I received
on November 2, 2008 from one of my supporters. Mr. Staples states in his email, “Oops.
That is my fault. It was supposed to be removed. I’ll fix it now. Interesting, no one else
seems to have noticed my mistake.” Mr. Staples was talking about the way he had his email
setup which were going to my supporters that he, Mr. Staples, had received donation
28. On November 4, 2008, I began receiving calls that my website was down. I put
several calls into Mr. Staples and did not receive a call back. In addition, I was attempting to
pay Mr. Staples web hosting bill and was having difficulties. I sent Mr. Staples an email
informing him that I was having difficulty paying my bill and I needed help from him if he
wanted to be paid by credit card. Otherwise I told him I would mail him a check. In this
same email I asked him if my website was back up. See EXHIBIT “O”.
website was not properly working. I had not heard back from Mr. Staples on my previous
emails, so I sent him another email again asking how long it was going to take to have my
30. During this time, I had been calling Geoff Staples asking for my passwords to my
domain names and website. Finally out of frustration, I emailed Mr. Staples on November 8,
31. On November 9, 2008 I finally received an email from Mr. Staples, which clearly
proves that Mrs. Liberi had nothing to do with my Linkpoint or PayPal accounts, any credit
cards or any of the donation information, it was Geoff Staples who did. Mr. Staples stated,
“First I reviewed the transactions in Linkpoint. For Nov. 7th and Nov. 8th you had less
than $100 declined – all in $20 transactions and 1 $100.00 transaction marked ‘fraud’”.
“There was another transaction that was declined, but the person resubmitted it on
another credit card, which went through. I think this is likely due to the change I made
today which provides a message suggesting they try another card.” “On the website: I
have take [sic] a commenting system and made some programming changes to it so that it
will provide what is needed. I will install it in the morning.” See EXHIBIT “R”.
32. I wrote Mr. Staple’s back and stated, “you take me for a complete fool” and I
33. I decided to change webmasters based on the problems I had been having with
34. Also during this time, Defendant Taitz continued calling my office. She wanted
assistance from Mrs. Liberi with a Writ of Cert and other legal documents. Mrs. Liberi
refused to assist or have anything to do with Defendant Taitz. I filed a law suit with Mrs.
Liberi shortly thereafter and told Defendant Taitz to stop contacting my office, that she was
unethical and a liar. Next, Defendant Orly Taitz threatened to take me down and to do so she
was going to destroy my Paralegal, Lisa Liberi, and get rid of her. Since this time, Defendant
Taitz has continued illegal behaviors which have escalated to a point I am concerned for the
safety of my clients, Lisa Liberi, Lisa Ostella and their families. Defendant Taitz has
continually attempted to have my clients: Lisa Ostella and Lisa Liberi arrested on false
charges and has been cyber-stalking, harassing, inciting violence, among many other things
against my clients, Lisa Liberi and Lisa Ostella. Defendants Taitz, Belcher and Sankey have
also forged documents in the names of my clients, Lisa Liberi and Lisa Ostella, which is on
35. On December 1, 2008, I received an email from Geoff Staples stating, “We have
received your request and will respond as soon as possible: Passwords for Domain Names
96-M7-1B philjberg@gmail.com.” See EXHIBIT “U”. However, Mr. Staples failed to give
me the website and hosting passwords, which would allow my new webmaster to move my
websites.
36. On December 2, 2008, I received another email from Mr. Staples with additional
passwords. See EXHIBIT “V”. However, when my new webmaster, Gail Frye, attempted to
log-in, in order to transfer my websites, she discovered Mr. Staples had given the incorrect
passwords.
off of Geoff Staples server, hostricity.com, my office and new webmaster, Gail Frye were
forced to contact the Federal Bureau of Investigations (FBI) in Dallas, Texas and obtain their
assistance in obtaining my passwords. The FBI was successful and was able to obtain my
38. The problems with Mr. Staples did not stop there. On January 28, 2009, Geoff
Staples illegally billed my credit card in the amount of $67.20, even though I never allowed
my credit card to be utilized by Mr. Staples for anything other than the initial setup fees. Due
to my schedule, I asked Mrs. Liberi to please send an email to Mr. Staples regarding his
illegal activities and theft of monies from my credit card. Mrs. Liberi complied and carbon
copied me. See EXHIBIT “W”. This was not the first time this had occurred. Mr. Staples
also illegally charged my credit card in excess of Five Hundred [$500.00] Dollars on
39. Not only was Mr. Staples illegally storing all my supporters private information
and credit data, he released documents, with Mrs. Liberi’s email address forged onto them,
with my supporters credit card numbers, addresses, phone number, email addresses, etc. to
Defendant Orly Taitz illegally, without any type of subpoena or legal process. Defendant
Taitz also failed to notify me that she was seeking private records on my previous web
hosting account. Defendant Taitz took it upon herself and published this information all over
the Internet and sent it by mass emailing. Not only is this theft of my supporter’s data, it is a
serious data breach. For this reason, I need an immediate Court Order issued upon Geoff
Staples to turn over all of my supporters data, which he stole from me, immediately, so I can
I declare under penalty of perjury of the laws of the United States of America that the
foregoing is true and correct. Executed this 6th day of October, 2010.
Respectfully submitted,
Commonwealth of Pennsylvania )
§
County of Montgomery )
satisfactory evidence to be the person whose name is subscribed to this instrument, and
~TARY
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COMMONWEALTH OF peNN~YI. VANIA
Notarial Seal
Margaret Hagan, Notary Public
sIt')~marsh Twp" Montgomery County
i\ify'eommission Expires Dec. 3, 2010
Member, Pennsylvania Association of Notaries
My commission expires: j). ,--J '-II)