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] [e-mail] MICHAEL M. VASSEGHI [SBN 210737] [e-mail] SOLOMON WARD SEIDENWURM & SMITH, LLP 401 B Street, Suite 1200 San Diego, California 92101 Telephone: [phone] Facsimile: [phone] Attorneys for Solomon Ward Seidenwurm & Smith, LLP

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

PACIFIC LAW CENTER, A Professional Corporation and SOLOMON WARD SEIDENWURM & SMITH, LLP., Plaintiff, v. SHAHROKH SAADAT-NEJAD, Defendant.

CASE NO. 07-CV-00460 JLS (POR) SOLOMON WARD SEIDENWURM AND SMITH'S NOTICE OF LODGMENT OF EXHIBITS ADDRESSING ISSUES RAISED BY THIS COURT'S ORDER DIRECTING PARTIES TO SHOW CAUSE AS TO WHY SUMMARY JUDGMENT SHOULD NOT BE ENTERED Date: To Be Determined Time: To Be Determined Courtroom: 6 Hon. Janis L. Sammartino

P:00435580:90126.015

07-CV-00460 JLS (POR) SOLOMON WARD SEIDENWURM AND SMITH'S NOTICE OF LODGMENT OF EXHIBITS

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Solomon Ward Seidenwurm & Smith, LLP respectfully lodges the following exhibits addressing issues raised by this Court's order directing parties to show cause as to why summary judgment should not be entered. Exhibit 1: Relevant portions of the web site: www.unitedstates.centcommil.com

/2008/03/17/attorneys_lobbying_dla_piper_rudnick_law_firm_offices_worldwide.aspx. Exhibit 2: Relevant portions of the web site: www.uscourtjudges.com/2007/11/20

/sandiego_city_district_attorney_police.aspx. Exhibit 3: Relevant portions of the web site: www.sandiego.fox6.com/General

Community/10news_com_fox6_com_cbs8_com_nbcsandiego_com_kusi_com_signonsandie go_com/classifieds/viewad?oid=2679949. Exhibit 4: Relevant portions of the web site: www.white-house-president.com/

2007/10/21/pentagon_attorney_sandiego_dui_bankruptcy.aspx. Exhibit 5: Relevant portions of the web site: www.unitedstatescentralcommand

.com/2007/11/26/pentagon_uscourts.aspx. Exhibit 6: Relevant portions of the web site: www.zionistterrorists.israelmfagovil.

com/2007/10/07/attorney_sandiego_centcom_pentagon_ntcom_pentagon_mi6_sis_cia_fbi_l aw_court_justice_defense_blackwater_usa_torture_murder_hire_bush_whitehouse.aspx. Exhibit 7: Relevant portions of the web site: www.white-house-president.com

/2007/05/24/israelmossadciablackwatermi6usa.aspx. Exhibit 8: Relevant portions of the web site: www.united-states-of-israel.mossad

govil.com/2007/05.aspx. Exhibit 9: Reporter's Transcript of June 12, 2008 Pretrial Conference.

DATED: July 25, 2008

SOLOMON WARD SEIDENWURM & SMITH, LLP

By:

/s/ Edward J. McIntyre EDWARD J. MCINTYRE MICHAEL M. VASSEGHI Attorneys for SOLOMON WARD SEIDENWURM & SMITH, LLP

P:00435580:90126.015

07-CV-00460 JLS (POR) 1 SOLOMON WARD SEIDENWURM AND SMITH'S NOTICE OF LODGMENT OF EXHIBITS

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P:00435580:90126.015

CERTIFICATE OF SERVICE I caused the SOLOMON WARD SEIDENWURM AND SMITH'S NOTICE OF LODGMENT OF EXHIBITS ADDRESSING ISSUES RAISED BY THIS COURT'S ORDER DIRECTING PARTIES TO SHOW CAUSE AS TO WHY SUMMARY JUDGMENT SHOULD 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 case. Electronic Mail Notice List Robert F. Clarke, Esq. (SBN 79881) Phillips & Associates 3030 N. Third Street, Suite 1100 Phoenix, AZ 85012 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 emailing copies to Mr. Saadat-Nejad at [e-mail]. In addition, we are sending hard copies via Federal Express: Shahrokh Saadat-Nejad 3713 Mt. Ashmun Place San Diego, CA 92111 VIA FEDERAL EXPRESS /s/ Edward J. McIntyre EDWARD J. MCINTYRE

07-CV-00460 JLS (POR) 2 SOLOMON WARD SEIDENWURM AND SMITH'S NOTICE OF LODGMENT OF EXHIBITS

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