Mohammad Keshavarzi from Sheppard Mullin et al writing to me:
At 12:58 PM 2/6/2008, you wrote:
I learned today that you have been contacting the staff at the court of appeal. Such ex parte communication is improper. In the future plaintiff needs to be part of your communication with any court.
333 South Hope Street48th FloorLos Angeles, CA 90071-1448213.620.1780 office213.620.1398 faxhttp://www.sheppardmullin.com/ Moe Keshavarzi213.617.5544 direct 213.443.2910 direct faxMKeshavarzi@sheppardmullin.com Bio
And here is my response, definitely too long...
Moe:
You cannot be serious -
Do you mean you would like to accompany me anytime I go to the clerk's office to pay or copy file records?
Am I supposed to schedule any trip to the clerk's office with you in advance? How about when I call the courtroom assistant for scheduling? Would you expect it to be done by a conference call?
Would such rules apply only to me, or also to you and Countrywide?
Just so I do not dismiss this as ridiculous, please provide the details of the specific communications that you consider as improper and the subject of your email below, as well as the code section or rule of court that is the basis for your unfounded claim.
Needless to say, you have conducted numerous ex parte communications out of compliance and in violation of the law, with, for one example, Judge O'Brien as documented in transcript of Aug 30, 2007 and elsewhere. Similarly, it was just ridiculous watching Judge Goodman try to pretend he had no idea where the Proposed Order you "lodged" with him on September 14, 2007 came from. He should have taken some acting classes before trying to pull off something like that.
Also, I still am waiting to hear how the ex parte hearing of July 6, 2007 by Countrywide, to issue a gag order against me from talking with practically anybody and his brother about Countrywide and Sandor Samuels' corruption, was scheduled in a special court session, for a non-party listed on that day as Plaintiff (one of Judge Connor's innocent small random errors). The only plausible explanation I know of is through an ex parte communication with Judge Connor. Indeed, courtroom assistant told me that the unusual scheduling came directly from Judge Connor. And the only response from attorneys for Countrywide so far was that it involved "nothing improper". And of course, the ruling on July 6, 2007, to allow Countrywide to file moving papers after my deadline for the opposition was just standard due process of the law - the original intent of the framers of the constitution...
Otherwise, it is always a pleasant surprise to learn about the law and regulations from an attorney who appears specialized in providing services beyond the law. Your conduct in Samaan v Zernik, e.g. - the fabrication of fraudulent claims between Nov 3 and Nov 6, 2006, as documented in the 3-ways correspondence with Jae Arre (Samaan's husband - couldn't he pick up a name that reads less fabricated if he wanted to hide his previous identity?) and McLaurin (Countrywide's San Rafael Branch Manager - "the untouchable"), amounts to fraud and deceit - run of the mill criminal conduct.
Unfortunately, you cannot expect every court and every judge to be as cooperative in criminal conduct as Judge Connor. And in that case too, you completely misread the situation. Judge Connor had no interest and no intention of benefiting you or Samaan, only Countrywide. Her decision to award Samaan the right to purchase the property in a declining market, with no attorney fees, is just one indication of that. You were just a collateral beneficiary in a corrupt court action, where the only intent was to cater to any and all of Countrywide's wishes, for a fee, one must assume.
Recently I have been wondering what an attorney, who is versed in the law, like you, would put as the odds that Mozilo and Samuels would end up in jail...
Joseph Zernik
Defendant & Cross Complainant
in pro per
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