Pacific Law Center et al v. Saadat-Nejad

Filing 40

REPLY re 39 MOTION for Contempt re This Court's April 26, 2007 Preliminary Injunction filed by Pacific Law Center. (McIntyre, Edward)(mam).

Pacific Law Center et al v. Saadat-Nejad

Doc. 40

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EDWARD J. MCINTYRE [SBN 80402] [e-mail] SOLOMON WARD SEIDENWURM & SMITH, LLP 401 B Street, Suite 1200 San Diego, California 92101 Telephone: [phone] Facsimile: [phone] Attorneys for Pacific Law Center and Solomon Ward Seidenwurm & Smith, LLP

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

PACIFIC LAW CENTER, a Professional Law Corporation; and SOLOMON WARD SEIDENWURM & SMITH, LLP, Plaintiffs, v. SHAHROKH SAADAT-NEJAD, an individual, Defendant.

CASE NO. 07-CV-00460 LAB (POR) REPLY MEMORANDUM IN SUPPORT OF ORDER TO SHOW CAUSE RE SAADATNEJAD'S CONTEMPT OF THIS COURT'S APRIL 26, 2007 PRELIMINARY INJUNCTION ORDER Date: July 12, 2007 Time: 12:00 noon Courtroom: 9 Hon. Larry Alan Burns

P:310137.1:57122.003

07-CV-00460 LAB (POR) REPLY MEMORANDUM IN SUPPORT OF ORDER TO SHOW CAUSE CONCERNING SAADAT-NEJAD'S CONTEMPT OF THIS COURT'S APRIL 26, 2007 PRELIMINARY INJUNCTION ORDER Dockets.Justia.com

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THE ONLY ISSUE BEFORE THE COURT The issue is not Saadat-Nejad's complaint about Pacific Law Center's brief representation of him; nor Solomon Ward's representation of Pacific Law Center; not even Saadat-Nejad's racist, anti-Semitic rant. The only issue is whether Saadat-Nejad can flaunt his disobedience of this Court's orders. The Evidence Speaks for Itself. There is no need for a computer with Internet capacity in the courtroom at the hearing--as Saadat-Nejad demands. All this Court has to do is enter pacificlawyerscenter.com into its web browser. The result says it all. The Only Solution. A temporary restraining order did not work; neither did a preliminary injunction. Nor did the Court's two extended and patient colloquies that warned Saadat-Nejad not to "get chalk on his shoes." Saadat-Nejad's response to the order to show cause says it all--"...filing multiple cases against me (Criminal or Civil) will not keep me silent."1 While free, he will not obey. Regrettably, the only solution is for this Court to use its coercive powers to ensure obedience with its orders. Otherwise, we surrender to chaos.

DATED: July 9, 2007

Respectfully submitted, SOLOMON WARD SEIDENWURM & SMITH, LLP

By:

/s/ Edward J. McIntyre EDWARD J. MCINTYRE Attorneys for Pacific Law Center and Solomon Ward Seidenwurm & Smith, LLP

Saadat-Nejad's July 6, 2007 Response to Alleged Contempt, 5:18-19. [Emphasis added.]

P:310137.1:57122.003

-107-CV-00460 LAB (POR) REPLY MEMORANDUM IN SUPPORT OF ORDER TO SHOW CAUSE CONCERNING SAADAT-NEJAD'S CONTEMPT OF THIS COURT'S APRIL 26, 2007 PRELIMINARY INJUNCTION ORDER

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P:310137.1:57122.003

CERTIFICATE OF SERVICE I caused the REPLY MEMORANDUM IN SUPPORT OF ORDER TO SHOW CAUSE RE SAADAT-NEJAD'S CONTEMPT OF THIS COURT'S APRIL 26, 2007 PRELIMINARY INJUNCTION ORDER to be served in the following manner: Electronic Mail Notice List The following are those who are currently on the list to receive e-mail notices for this case. Electronic Mail Notice List NONE.

I manually served the following: Shahrokh Saadat-Nejad 3713 Mt. Ashmun Place San Diego, CA 92111 VIA FEDERAL EXPRESS /s/ Edward J. McIntyre__________ EDWARD J. MCINTYRE

-207-CV-00460 LAB (POR) REPLY MEMORANDUM IN SUPPORT OF ORDER TO SHOW CAUSE CONCERNING SAADAT-NEJAD'S CONTEMPT OF THIS COURT'S APRIL 26, 2007 PRELIMINARY INJUNCTION ORDER