Pacific Law Center et al v. Saadat-Nejad

Filing 80

BRIEF Addressing Issues This Court's Order Raised Directing Parties to Show Cause Why Summary Judgment Should Not Be Entered by Solomon Ward Seidenwurm and Smith LLP. (Attachments: # 1 Declaration of Edward J. McIntyre, # 2 Declaration of Michael M. Vasseghi, # 3 Exhibit Notice of Lodgment of Exhibits)(McIntyre, Edward) Modified on 7/28/2008 to term motion, correct event (mkz).

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EDWARD J. MCINTYRE [SBN 80402] emci ntyre@swss law.com MtcHAEL M. VASSECHI [SBN 210737] mvassegh i @swsslaw.com SOLOMON WARD SEIDENWURM & SMITH, 401 B Street, Suite 1200 San Diego, California 92101 Telephone: [phone] Facsimile: (6'lÐ 23147 55 Attorneys for SOLOMON WARD SEIDENWURM & SMITH, LLP

LLP

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CATIFORNIA

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PACIFIC LAW CENTER, A Professional Corporation and SOLOMON WARD SEIDENWURM & SMITH, LLP.,

CASE NO. O7-CV-OO46O JLS (POR)

Plaintiff,

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SHAHROKH SAADAT-NEJAD,
Defendant.

DECLARATION OF MICHAET M. VASSEGHI IN SUPPORT OF SOLOMON WARD SEIDENWURM AND SM¡TH'S BRIEF IN SUPPORT OF ORDER D]RECTING PART¡ES TO SHOW CAUSE AS TO WHY SUMMARY JUDCMENT SHOULD NOT BE ENTERED

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Date: Time:
Hon.
Jan

To Be Determined To Be Determined
is L. Sammartino

Courtroom:6

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ptoo432243tso1z6.o1s
BRIEF IN SUPPORT OF OSC RE

07-CV-00460 JLS (POR)

WHY MSJ SHOULD NOT BE ENTERED

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l, Michael M. Vasseghi, declare

as

follows:

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1.

I am an attorney licensed to practice before the Couds of the State of

california and before this court. I am an associate with the law firm of Solomon ward
seidenwurm & smith, the plaintiff in the above.entitled action. lf called to do so, I could
testify competently and of my own personal knowledge to the matters set foñh herein.

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2.

On July 1,2OOB,l contacted Mr. Saadat-Neiad to ask him to

agree to a

permanent injunction. I also invited him to come our office at Solomon Ward to discuss this
matter further. Mr. Saadat-Nejad declined the invitation'

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3.

During our phone conversation, Mr. Saadat'Nejad stated that he would enter

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into such a stipulation. He did not ask for compensation in exchange for signing the stipulation for the permanent injunction, but he wanted to be compensated for the harms

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that Solomon Ward had caused hlm during the pendency of this ligation, including causing
him to go to jail and for filing falsified documents.

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figure out."

I asked

Mr. Saadat-Nejad how much money he thought he was entitled

to.

He

declined to provide an amount, but he said that the amount was for "you [solomon ward] to

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5.

On .lune 27, 2OOB I conducted an online search using the Coogle search

engine. I found eight different web sites that appeared to be registered and maintained by Mr. Saadat-Nejad. True and correct copies of the relevant portions of those web sites are
lodged with the Court as Exhibits 1 though herewith.

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to the Notice of Lodgment filed concurrently

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P:0043 s499:90126.01 5

oz-cv-00460
\RATION OF |'4ICHAEL M. VASSECHI lN SUPPORT OF SOLO,I\¡q.N W, SRIÈT IN SUPPONT OF OSC RE WHY MSJ SHOULD NOT BE ENTERED

JLS (POR)

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A true, correct and complete copy of the transcript of the June 16, 2008

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pretrial hearing is lodged with the Court as Exhibit 9 to the Notice of Lodgment filed concurrently herewith.
I declare under penalty of perjury under the laws of the State of California that the

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foregoing is true and correct from my own personal knowledge and that I executed this
declaration on July 25, 2008, at San Diego, California.

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P:00435499:901 26.0'l 5

07-cv-00460 \RATION OF MICHAEL M. VASSECHI IN SUPPORT OF SOLOMON WARD'S BRIEF IN SUPPORT OF OSC RE WHY MSJ SHOULD NOT BE ENTERED

JLS (POR)

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CERTIFICATE OF SERVICE
I CAUSCd thc DECLARATION OF MICHAEL M. VASSEGHI IN SUPPORT OF

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SOTOMON WARD SEIDENWURM AND SMITH'S BRIEF IN SUPPORT OF ORDER
DIRECTING PARTIES TO SHOW CAUSE AS TO WHY SUMMARY JUDGMENT SHOULD

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NOT BE ENTERED 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

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Electronic Mail Notice List
Robert F. Clarke, Esq. (SBN 79881) Phillios & Associates 3030 N. Third Street, Suite 1100 Phoenix, M 850'12 Telephone: [phone] Facsimile: [phone] Attorneys for Pacific Law Center The following party is not on the list to receive e-mail notices from the Court. We are

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emailing copies to Mr. Saadat-Nejad at [e-mail].
ln addition, we are sending hard copies via Federal Express: Shahrokh SaadarNeiad 3713 Mt. Ashmun Place San Diego, CA921'l1

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VIA FEDERAL

EXPRESS

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Mclntvre
MCINTYRE

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P:00435499:901 26.01 5

o7-cv-00460
BRIEF IN SÙPPORT OF OSC RE WHY MsJ SHOULD

JLS (POR)

TION õF MrcFrAELvI/ASSECHt tN suPPoRT oF

NOT BE ENTERED

soLoMql\lwARD's