Pacific Law Center et al v. Saadat-Nejad

Filing 55

MOTION for Permanent Injunction by Pacific Law Center. (Attachments: # 1 Memo of Points and Authorities in Support of Permanent Injunction# 2 Declaration of Edward J. McIntyre in Support of Permanent Injunction)(McIntyre, Edward)

Pacific Law Center et al v. Saadat-Nejad

Doc. 55

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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 JLS (POR) PACIFIC LAW CENTER AND SOLOMON WARD'S NOTICE OF MOTION AND MOTION FOR PERMANENT INJUNCTION Date: Time: Ctrm: March 28, 2008 10:30 a.m. 6, Third Floor

Hon. Janis L. Sammartino

P:317960.1:57122.003

07-CV-00460 JLS (POR) PACIFIC LAW CENTER AND SOLOMON WARD'S NOTICE OF MOTION AND MOTION FOR PERMANENT INJUNCTION Dockets.Justia.com

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PLEASE TAKE NOTICE that on March 28, 2008 at 10:30 a.m., or as soon thereafter as the matter may be heard, in Court PLEASE TAKE NOTICE that on November 2, 2007 at 1:30 p.m., or as soon thereafter as the matter may be heard, in Courtroom 6 of the U.S. District Court, Southern District of California, 880 Front Street, San Diego, California, Pacific Law Center and Solomon Ward will move this Court to enter a permanent injunction as follows: Saadat-Nejad, and anyone acting in concert with him, is hereby permanently enjoined and restrained from: 1. Registering, and trafficking in, any internet website or domain name that contains the words Pacific, Law and Center, with or without other words or symbols, in any respect whatsoever; 2. Registering, and trafficking in, any internet website or domain name that contains the words Solomon and Ward, with or without other words or symbols, in any respect whatsoever; 3. Registering and trafficking in the service mark or trade name Pacific Law Center in any respect whatsoever; and 4. Registering and trafficking in the service mark or trade name Solomon Ward or Solomon Ward Seidenwurm & Smith in any respect whatsoever. The motion will be based upon this notice of motion and motion, the accompanying memorandum of points and authorities, the declaration of Edward McIntyre and the Court's files in this case, including , McIntyre Declaration, with Exhibits (Docket No. 3); Slattery Declaration, with Exhibits (Docket No. 3); Phillips Declaration, with Exhibits (Docket No. 18); Supplemental Memorandum, with Exhibits (Docket No. 18); McIntyre Declaration (Docket No. 36); McIntyre Declaration (Docket No. 39); Exhibits in Notice of Lodgment, and specifically Exhibits 5 through 11 (Docket No. 39); McIntyre Declaration (Docket No. 48), the transcripts of the March 29, 2007 /// /// /// /// /// /// ///
P:317960.1:57122.003

-107-CV-00460 JLS (POR) PACIFIC LAW CENTER AND SOLOMON WARD'S NOTICE OF MOTION AND MOTION FOR PERMANENT INJUNCTION

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and April 26, 2007 hearings (Docket No. 39, Exhibits 2 and 4); oral argument, and on such other and further evidence as may be presented at the time of the hearing.

DATED: November 15, 2007

Respectfully submitted, SOLOMON WARD SEIDENWURM & SMITH, LLP

By:

/s/ Edward J. McIntyre EDWARD J. MCINTYRE Attorneys for Pacific Law Center and Solomon Ward

P:317960.1:57122.003

-207-CV-00460 JLS (POR) PACIFIC LAW CENTER AND SOLOMON WARD'S NOTICE OF MOTION AND MOTION FOR PERMANENT INJUNCTION

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P:317960.1:57122.003

CERTIFICATE OF SERVICE I caused the PACIFIC LAW CENTER AND SOLOMON WARD'S NOTICE OF MOTION AND MOTION FOR PERMANENT INJUNCTION 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. The following party who is not on the list to receive e-mail notices for this case. He therefore requires manual noticing, via Federal Express: Shahrokh Saadat-Nejad 3713 Mt. Ashmun Place San Diego, CA 92111 VIA FEDERAL EXPRESS /s/ Edward J. McIntyre EDWARD J. MCINTYRE

-307-CV-00460 JLS (POR) PACIFIC LAW CENTER AND SOLOMON WARD'S NOTICE OF MOTION AND MOTION FOR PERMANENT INJUNCTION