Pacific Law Center et al v. Saadat-Nejad

Filing 48

DECLARATION of Edward J. McIntyre by Plaintiff Pacific Law Center. (McIntyre, Edward)

Pacific Law Center et al v. Saadat-Nejad

Doc. 48

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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) DECLARATION OF EDWARD J. MCINTYRE Date: July 25, 2007 Time: 12:15 p.m. Courtroom: 9 Hon. Larry Alan Burns

P:311229.1:57122.003

07-CV-00460 LAB (POR) DECLARATION OF EDWARD J. MCINTYRE
Dockets.Justia.com

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I, Edward J. McIntyre, declare: 1. I am a member of the Bar of this Court, and a partner at Solomon Ward

Seidenwurm & Smith, LLP, counsel for Pacific Law Center and Solomon Ward. I personally know the facts in my declaration. Saadat-Nejad's Self-Representation. 2. Shahrokh Saadat-Nejad has, both in the superior court and this Court, insisted

on representing himself. 3. Indeed, this whole matter began when Saadat-Nejad fired his appointed--

public defender--counsel in a superior court criminal action and then hired, and subsequently fired, Pacific Law Center. Thereafter, Saadat-Nejad fired his reappointed public defender and represented himself in the criminal proceeding. In that respect, he has bragged about the result he achieved for himself. 4. At both the March 28 temporary restraining order hearing and the April 26

preliminary injunction hearing, Saadat-Nejad represented himself. In each proceeding, he has filed papers on his own behalf. Harm to Solomon Ward and Pacific Law Center. 5. As the chairman of Solomon Ward's litigation department, one of my

responsibilities is recruiting new litigators. 6. During a recent--within the last two weeks--interview of a prospective new

associate, I asked him what he would like me to tell him about the firm. He immediately mentioned all of the Saadat-Nejad anti-Semitic and other postings that he found when he "Googled" Solomon Ward. 7. As a consequence, I spent the next 20 minutes of the interview explaining

Saadat-Nejad, his antipathy toward the firm merely because we represent Pacific Law Center, and the proceedings in this Court. 8. In our recruiting effort, we constantly run advertisements in, among others,

legal publications. We have no way of knowing how many potential fine young lawyers have not responded to us because they found the same materials--all of which infringe
P:311229.1:57122.003

DECLARATION OF EDWARD J. MCINTYRE

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07-CV-00460 LAB (POR)

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Solomon Ward's registered domain names and violate this Court's orders. 9. In tandem, there is no way to determine how many potential clients have

avoided Pacific Law Center for the very same reason. 10. Accordingly, Solomon Ward and Pacific Law Center respectfully request this

Court to enter an order directing the hosts of Saadat-Nejad's websites previously identified to this Court, and adjudged to violate this Court's orders, immediately to remove his offending websites. I declare on penalty of perjury under the laws of the State of California and United States of America that the facts in this declaration are true and correct, based on my own personal knowledge, and that I executed this declaration in San Diego, California on July 24, 2007 at San Diego, California. /s/ Edward J. McIntyre EDWARD J. MCINTYRE

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DECLARATION OF EDWARD J. MCINTYRE

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07-CV-00460 LAB (POR)

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CERTIFICATE OF SERVICE I caused the DECLARATION OF EDWARD J. MCINTYRE 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 David Blaire-Loy, Esq. ACLU Foundation of San Diego & Imperial Counties P.O. Box 87131 San Diego, CA 92101 Telephone: [phone] 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

DECLARATION OF EDWARD J. MCINTYRE

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07-CV-00460 LAB (POR)