07-11-09 Samaan V Zernik (SC087400) Nivie Samaan: Sheppard Mullin's Motion To Appoint Pasternak Receiver S

Digitally signed
by Joseph
Zernik
DN: cn=Joseph
Zernik,
email=jz12345
@earthlink.net,
Joseph Zernik DMD PhD c=US
Date:
Fax: (801) 998-0917 Email: jz12345@earthlink.net 2009.03.05
13:57:27 -08'00'
07-11-09. Samaan’s Motion for Order Appointing Pasternak Receiver
The order is deemed fraud by the court on numerous counts:
a) Judge offering legal advice. On October 11, 2007, in open court, when Keshavarzi
brought a motion to compel, Judge Segal denied it, but instructed Keshavarzi to provide
him order appointing receiver. Keshavarzi hesitated for a bit, since on August 30, 2007,
Judge Connor reprimanded him in open court for making such suggestion in phone call
with ADR. I then protested askng what specific due process procesure was discussed.
Judge Segal then told him to produce a motion.
b) The motion was heard at 4-day notice, after an ex parte on November 5, 2007. But Judge
Segal “disposed” of the minute order for the ex parte hearing.
c) The motion falsely identifies the order granting summary judgment as the judgment.
d) In open court Keshavarzi explained that he did not recognize the judgment.
e) The order does not refer to any section of the code
f) The order does not incorporate the judgment
g) The order does not incorporate the contract
h) The order is arbitrary and abusive.
SHEPPARD MULLIN RICHTER & HAMPTON UP
A Limited Liability Partnership
2 Including Professional Corporations
PHILLIP A. DAVIS, Cal. Bar No. 110430
3 MOE KESHAVARZI, Cal. Bar No. 223759
333 South Hope Street, 48th Floor
4 Los Angeles., California 90071-1448
Telephone: 213-620-1780
5 Facsimile: 213-620-1398
. ,- ·i:::··.~- -. ~_ ~~._ .. " .:

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Attorneys for Plaintiff Nivie Samaan
8
9 SUPERIOR COURT OF THE STATE OF CAliFORNIA
10 FOR THE COUNTY OF LOS ANGELES -- WEST DISTRICT
II NIVIE SAMAAN, an individual; Case No. SC 087400
12 Plaintiff, Honorable John L. Segal
13 v. PLAINTIFF NIVIE SAMAAN'S

NOTICE OF MOTION AND
14 JOSEPH ZERNIK, an individual and MOTION FOR APPOINTMENT OF
DOES I through 10, inclusive, RECEIVER.
15
Defendants. rMemorandum of Points & Authorities,
16 Declarations of Sherry A1everson, Moe
Keshavarzi, Jared Harris, David J.
17 I Pasternak and Christina Pugh filed
, concurrently herewith]
18
rProposed Order lodged concurrently
19 herewith]
20 Date: November 20,2007
Time: 8:30 a.m.
21 Dept.: o
22
23
24
25
26
27
28
Exh p 1 EXHIBITS VOL V - RECEIVERSHIP
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\\'1I:·\\lST 1\1\IKI .+OO.+X()51
~ i
ZERNIK V CONNOR ET AL
PL\I~TIFF'S \10TIO:\ TO\PPOI:\T A RECEIVER
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
2
PLEASE TAKE NOTICE that on November 20, 2007, at 8:30 a.m., or
3
as soon thereafter as the matter may be heard, in Department 0 of the above-entitled
4
Court, located at 1725 Main Street, Santa Monica, California 90401, plaintiffNivie
5
Samaan ("plaintiff') will, pursuant to Sections 708.610,708.620 and 712.060 of the
6
California Code of Civil Procedure, bring on for hearing her motion for appointment
7
of a receiver to assist in enforcing the judgment against defendant Joseph Zemik
8
("Zemik" ).
9
10 Plaintiff makes this motion on the ground that Zernik refuses to comply
11 with the judgment against him and considering the interests of both the judgment
12 creditor and the judgment debtor, the appointment of a receiver is the only
13 reasonable method to obtain the fair and orderly satisfaction of the judgment.
14 Moreover, Samaan will be irreparably harmed if a receiver is not appointed.
15
This motion is based on this Notice of Motion, the attached
16
Memorandum of Points and Authorities and Declarations of Sherry Aleverson, Jared
17
Harris, Moe Keshavarzi, David J. Pasternak and Christina Pugh, including exhibits,
18
all pleadings, papers, and records filed in this action, those matters of which the
19
Court may take judicial notice, and any and all arguments made at the hearing on
20
this Motion.
21
22 Dated: October 25,2007
2 ':l
~'
SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
24
25 By
26 MOE KESHAV ARZI
Attorneys for PlaintitT Niv ie Samaan
28

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ZERNIK V CONNOR ET
\\lIc-\\ ES r I \lMKI -+0(,-+89517 I
AL
PLANTIFFS \10T10\; TO :\PPOI'\,T A RECEIVER
I. INTRODUCTION
2 On August 9,2007, Nivie Samaan ("Samaan") obtained a judgment
3 against Zernik requiring Zemik to sell the property located at 320 S. Peck Drive,
4 Beverly Hills, California ("Property"). Since that time Samaan has tried hard to
5 enforce the judgment but Zemik refuses to sell the Property. For example, after
6 judgment was entered, the Honorable Jacqueline A. Connor appointed a referee to
7 oversee close of escrow. Zernik refused to meet with the referee and repeatedly told
8 the referee that he does not accept the referee's authority. Eventually, because of
9 Zemik's repeated threats and harassment, the referee resigned.
10
11 Zernik also refuses to permit the lender to conduct its appraisal of the
12 Property. He has repeatedly called Judge Connor "corrupt" and has stated that he
13 does not intend to comply with the judgment.
14 The Code of Civil Procedure provides that the Court can appoint a
15 receiver if, considering the interests of both the judgment creditor and the judgment
16 debtor, the appointment of a receiver is a reasonable method to obtain the fair and
17 orderly satisfaction of the judgment. Here, Zemik's actions have confirmed that
18 appointment of a receiver is the only effective method of enforcing the judgment.
19
20
II. RELEVANT FACTS
2l A. The Court Enters Judgment in Favor of Samaan, Orders Zernik to Sell
22 the Property and Appoints a Referee Recommended by Zernik.
23 On August 8, 2007, the Court (the Honorable Jacqueline A. Connor,

24 Department ][) granted Samaan's Motion for Summary Judgment and ordered Zemik
25 to sell the Property to Samaan. (Keshavarzi Decl., ~ 2). On the same day the Court
26 entered judgment in favor of Samaan. (Id., Exh. 1). At a hearing on August 21,
27 2007, Judge Connor informed both parties that she had decided to appoint a referee
28 to oversee the escrow and sale of the Property and protect the interests of both
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ZERNIK V CONNOR ET
WU2-\\EST1\I\lKl·l(J1)4R')5171 AL
PLAI:\TIFF'S :VI0TIO~ TO .c\PPOINT A RECEIVER
parties. (ld.) Judge Connor then asked both parties to recommend three referees to
2 be appointed. (ML) Subsequently, both parties recommended three referees each.
3 (ld.) Both Samaan's and Zemik's list included the Honorable Gregory O'Brien, Jr.
4 (Ret.) of ADR Services, Inc. ("ADR Services") (ld., Exh. 2)
5
On August 30,2007, Jude Connor appointed Judge O'Brien as the
6
referee and ordered that the parties share his fee. (Keshavarzi Decl., Exh. 2).
7
8 B. Zernik Refuses to Participate in Escrow, Refuses to lVleet with the
9 Referee and Refuses to Pay His Share of the Referee's Fees.
10 Upon being appointed as a referee, Judge O'Brien's assistant Ms.
11 Christie Woo scheduled a hearing on September 10 for Judge O'Brien to meet with
12 the parties and discuss escrow. (Keshavarzi Decl., ,-r 3). On Friday, September 7,
13 Zemik spoke telephonically with Ms. Woo and asked for a conference call on that
14 day to discuss the case. (Keshavarzi Decl., Exh. 3). At 2: 17 p.m., Ms. Woo sent
15 both parties an email preliminary scheduling a conference call at 5: 15 p.m.
16 (Keshavarzi Decl. Exh. 4). The call never took place because Zemik refused to
17 participate. (~) Instead Zemik wrote emails to Ms. Woo challenging Judge
18 O'Brien's appointment and asking for copies of all orders that authorize Judge
19 O'Brien to act as a referee and hold conference calls. (Keshavarzi Decl., ,-r 3, Exh.
20 5 ).
2l
22 Zernik also did not appear at the September 10 conference with Judge
23 O'Brien. (ld~,,-r 4). Samaan and her counsel appeared and discussed escrow with
24 the Judge. Od.) That morning Zen1ik gave notice of his ex parte application to
'F recuse Judge O'Brien, even though he had recommended Judge O'Brien.
--,
26 (Keshavarzi Decl., Exh. 6).
27
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I WiJ2-WE:Sfl\1\lKl ZERNIK V CONNOR ET
.1O()-+~95171
AL
PLAINTIFF'S 'vIOTIO:\ TO APPOI1\T A RECEIVER
Subsequently Zernik refused to pay his share of Judge O'Brien's fee and
2 on September 20 wrote an email addressed to Judge O'Brien saying he would not
3 pay the bill because "as I explained in the past, I would not be able to participate in a
4 processes that is out of compliance with the law. Moreover, I find it a sad
5 commentary that you, Judge O'Brien, did." (Keshavarzi Decl., Exh. 7).
6
In the meantime, Zemik's repeated ex parte applications to recuse
7
Judge O'Brien were denied. (ld., ~~ 5-6) Undeterred, Zernik began a campaign of
8
harassing ADR's employees. Between September 20 to October 5, Zernik sent no
9
less than 35 emails and letters to ADR's employees demanding documents,
10
accusing Judge O'Brien of "dubious conduct," claiming "I do not recognize the
11
validity of the appointment of Judge O'Brien, and object to any action by ADR in
12
this regard." Zemik also threatened Judge O'Brien to stop working on the case
13
because "you are personally involved and liable." Cl1.:, Exh. 8).
l4
15 Eventually, on October 15, after Zemik's repeated threats and emails, in
l6 a letter to this Court resigned as the referee. (Keshavarzi Decl., Exh. 9). In that
17 letter Judge O'Brien wrote:
18
Unfortunately, since the case was first referred to me by
19 Judge Connor, certain circumstances have arisen that
maKe it imprudent for me to remain as the referee. After
20 further discussion with members of this firm, I must
reluctantly decline to participate further in this reference.
21
22 (Keshavarzi Dec!., Exh. 8).
23
c. Zerniks Tells The Title Company That He 'ViII Not Sell the Property and
24
Threatens the Lender's Appraiser.
25
Immediately after judgment was entered in Samaan's favor, Samaan
26
27 began the process of finalizing her loan and preparing for close of escrow. On
28 September 26, United Title Company was requested to open an account for the

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\\'02- \\ r:"r ]\1 \1 K 1-100489517 1 ZERNIK V CONNOR ET AL
PLAf\iTIFF'S \tIOTIO)! TO APPOI0iT A RECTI\ FR
Property and prepare a preliminary title report. (Declaration of Sherry Alverson
2 ("Alverson Decl.") ~ 2). The next day, United Title sent a letter to the Property
3 addressed to Zemik to notify him of the process. (Id.) Upon receiving the letter, on
4 October 3, Zemik contacted United Title's office and spoke to the office manger Ms.
5 Sherry Alverson. (Id., ~ 3). Zemik told Ms. Alverson that "the transaction was
6 fraudulent, that he would not permit the sale ofthe Property to go forward and
7 demanded that we [United Title] cancel the order." (~)
In the ensuing weeks, just as he had done with ADR, Zemik started a
9
campaign of harassment directed at United Title's employees. (Alverson Decl.,~ 3,
10
Exh. A). He repeatedly called their office and sent no less than II emails. (ld.)
I1
Eventually, United Title asked Zemik to deal only with its counsel. (Id.)l
12
\3 Zemik has also prevented Saaman's lender from appraising the
14 Property for Samaan's loan. After judgment in her favor was entered, Samaan
15 retained the services of Pacific Mortgage Consultants ("Pacific Mortgage") to
16 procure her loan for purchase ofthe Property. (Pugh Dec!" ~ 2). Pacific Mortgage
17 asked Prefened Appraisals, Inc. to conduct the appraisal. (Declaration of Jared
18 Harris ("Han'is Decl."), ~ 2). On October 5, 2007, at 10:00 a.m. Jared Harris and
19 Kris Wallace of Preferred Appraisals appeared at the Property to begin the appraisal.
20 (Harris Decl., ~ 2). Messrs. Harris and Wallace began measuring and inspecting the
21 Property. (leU Upon noticing them, Zemik came outside and asked what they were
22 doing. (1d.) After Mr. Harris explained their purpose, Zemik said that Pacific
?
__I
l'
24
25 Harassment and threats are Zemik's modus operandi. During the litigation,
while Samaan's motion for summary judgment was pending, Zemik contacted
26 Countrywide, a third-party witness and asked that they sign false declarations.
(Keshavarzi Dec!., ~ 9). Because Countrywide would not do so, Zemik began
27 harassing its employees, including its president and General Counsel. Od.)
Eventuany Countrywide obtained a protective order against Zemik. oct.)
28
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ZERNIK V CONNOR ET
1\lMK1-lOO-l89:'171
AL
PLAI~TIFF'S \10T10\7 TO APPOINT A R f( F:JVER
Mortgage is "a fraud", and that he would not permit the appraisal of his Property.
2 Od.)
In the ensuing days, as he had done with ADR and United Title, Zernik
4
began a campaign of harassment and threats directed against Preferred Appraisals.
5
Between October 5 and October 13 Zemik sent Preferred Appraisals no less than
6
five emails stating that Preferred Appraisal should stay away from the transaction
7
involving his Property and that he had "filed a report with the Beverly Hills Police
8
Department." (Harris Decl., Exh. B).
'9
10 Zemik has also been harassing Paci fic Mortgage. On October 8 and
11 then again on October 19, he wrote emails to Pacific Mortgage claiming that the
12 transaction t~or purchase of the Property involved "fraud" and threatened them with a
13 complaint to the California Department of Real Estate if they did not immediately
14 cease participating in the transaction. (Pugh Decl., ~ 3, Exh. C).
15
D. Betw€'en August 8 to October 22, Zernik Noticed No Less Than 36 Ex
16
Parte Applications.
17
18 Perhaps the best example of Zernik's failure to accept the consequence
19 of his actions and the judgment against him is the fact that since August 9, 2007,
20 when Judge Connor granted Samaan's Motion for Summary Judgment, Zemik has
21 noticed no less than 37 ex parte applications. (Keshavarzi Decl., ~ 7).
Among these ex parte applications are Zemik's repeated requests for

23 reconsideration of the order granting Samaan's motion for summary judgment. (Id.,
24 ~ 7). In these ex parte applications Zemik also has repeatedly challenged the Court's
")"
... ~' authority over him, called Judge Connor a "corrupt judge," calling Judge Segal "a
26 rogue judge" and asked Judge Segal "to cease and refrain from acting as the
27 presiding judge in Samaan v. Zemik". (Keshavarzi Decl., Exh. 10). Through his
28
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ZERNIK V CONNOR ET
\\ U2-WEST.l \1\IK 1~·()().l:N51' I AL
PLAI"<TIFF'S \l10TION TO APPOf\iT A RECEIVER
filings and actions Zernik had confirmed that he does not intend to comply with the
2 judgment and does not intend to sell the Property to Samaan.
3
III. DISCUSSION
4
A. THE COURT SHOULD APPOINT A RECEIVER TO ENFORCE THE
5
JUDGl\IENT AGAINST ZERNIK
6
7
"The court may appoint a receiver pursuant to Article 7 (commencing
8 with Section 708.610) of Chapter 6 of Division 2 to enforce a judgment for
9 possession or sale of property." Cal. Code Civ. Proc. § 712.060. Under Section
10 708.620 the Court may appoint a receiver to enforce the judgment "where the
II judgment creditor shows that, considering the interests of both the judgment creditor
12 and the judgment debtor, the appointment of a receiver is a reasonable method to
13 obtain the fair and orderly satisfaction of the judgment." Cal. Code (,iv. Proc.
14 9 708.620.
15 A receiver appointed under Section 708.620 is subject to the general
16 provisions of receivership law regarding appointments, qualifications, powers, rights
17 and duties. Cal. Code Civ. Proc. § 708.610. Accordingly, receivers appointed after
18 judgment may (1) carry the judgment into effect or (2) dispose of property pursuant
19 to the judgment. Cal. Code Civ. Proc. § 564(b)(3),(4); Gold v. Gold Realty Co., 114
20 Cal. App. 4th 791, 804 (2003) (holding that the court had authority to appoint
21 receiver to enforce judgment requiring dissolution of real estate corporations).
22
Given Zernik's conduct since judgment was entered against him in this
23
24 case the appointment of a receiver is the only method to "obtain the fair and orderly
25 satisfaction of the judgment." Cal. Code Civ. Proc. § 708.620.
26 Zernik has shown that he does not believe the judgment against him is
27 valid or that the judge issuing the judgment had the authority to do so. Aside from
28
-8
I ZERNIK V CONNOR ET
WO:-WES 11 \l\IKI .HJO-\8LJ.' I 7 , AL
PLAINTIFFS \IOTI01\ TO APPOIN r A RECEIVER
1 actually telling a non-party that he does not intend to comply with the judgment
2 (Alverson Decl., ~ 2), Zemik's actions confirm that he will not comply with the
3 judgment: Zemik has filed several ex parte applications and motions asking the
4 Court to vacate the judgment or reconsider the order granting the motion for
5 summary judgment. All such requests have been denied. The judgment has not
6 been stayed. but Zernik is refusing to accept its legal consequences.
7
'Nithout a receiver Samaan will be unable to enforce her judgment.
8
There is no adequate remedy at law. The referee appointed to this case resigned
9
because of Zernik's harassment and Samaan has no other remedy.
10
11 If the Court does not appoint a receiver Samaan will suffer irreparable
12 harm. Any delay in possession by Samaan will significantly cause harm to Samaan.
13 The judgment against Zemik requires him to transfer the Property to Samaan at the
14 contract price of$I,718,000. The Property is currently worth more than that
15 amount. (Keshavarzi Decl., Exh. II). As the Court is likely aware, the real estate
16 market in Southern California is in decline right now. (Keshavarzi Dec\., Exh. 12).
17 Any delay will deny Samaan the use of the equity in the Property.
18
B. THE COURT SHOULD SELECT DAVID J. PASTERt~AK AS THE
19
RECEIVER.
20
21 Samaan respectfully requests that the Court choose Mr. David J.
22 Pasternak as the receiver to enforce her judgment against Zernik. The declaration of
23 Mr. Pasternak and his receivership resume confirm that he is quali fied to act as a
24 receiver in til is matter. (Declaration of David J. Pasternak, ,-r~ 2-7, Exh. A).
25
26
27
28
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ZERNIK V CONNOR ET
W02-WEST l\l\IK! -fII1)4X'J517! AL
PLAI?\ITIFF'S \IOTIO\i TO APPO[1\"T A RECEIVER
IV. CONCLUSION
2
For the foregoing reasons Samaan respectfully requests that the Court
3 appoint David J. Pasternak as the receiver.
4
5 Dated: October 26, 2007
6 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
7
8 By ------
MOE KESHA V ARZI
9 Attorneys for Plaintiff
NIVIE SAMAAN
10
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13
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ZERNIK V CONNOR PLAf1\;TIFF'S
WIJ2-WESI I \l~tK I -11J1i-lX95' -; 1 ET AL 'vlOTIO\; TO APPOINT A RECEIVER
\ (', ?,'.-- ...
.. I), 'y . ) )
1 DECLARATION OF SHERI ALVERSON
2 I, Sheri Alverson, state and declare as follows:
3 1. I am the office manager of Westlake Village office of United Title

4 Company ("United Title"). I have personal knowledge of all facts set forth in this
5 declaration, and if called as a witness could and would testify competently thereto.
6 2. On or about September 26, 2007, United Title was requested to open

7 an account for the property located at 320 S. Peck Drive, Beverly Hills, California 90212
8 (the "Property"). The order required us to prepare a preliminary title report for the
9 Property. It is our practice to send a letter to the property owner upon opening an order to
10 inform them of the process. This letter is called an NT19 letter. On or about September
11 27, we sent an NT 19 letter to the Property addressed to its owner Mr. Joseph Zernik
12 3. On October 3,2007, Mr. Zemik contacted our office and was
13 transferred to me. He told me that he was not going to sell the Property, that the
14 transaction was fraudulent, that he would not pennit the sale of the Property to go forward
15 and demanded that we cancel the order. I responded that I needed to look into his claims
16 and that I would follow up with IDm. Mr. Zernik demanded that we cancel the order
17 within 15 minutes of our call. In the ensuing days Mr. Zernik continued to contact our
18 office, spoke to various employees and demanded that we cancel the order. ivlr, Zernik
19 also sent us 11 different emails. Attached hereto as Exhibit A are true and correct copies
20 of emails we received from Mr. Zernik. Eventually, I refened the matter to our general
21 counsel and asked .Mr, Zernik to deal directly with our attorneys.
22 I declare under penalty of perjury under the laws of the State of California
23 that the foregoing is true and correct.
24 Executed on October J.1.., 2007 at Westlake Village, Cahfomia
25
2 6 i { '
~ /J/
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eri verson
27
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~]-
W02·WEST: 1MMKJ \4D04S5534.1 DECLARJ\TION OF ALFRED C.ANrNO
ORDER #80701422-77 Page 1 of 1
Moe Keshavarzi
From: joseph zernik IJz12345@earthlink.net]

Sent: Wednesday, October 03, 2007 1146 AM
To: Alverson, Sheri; kdzien@unitedtitle.coml
Subject: ORDER #80701422-77
SENT BY EMAIL AND BY FAX
October 3, 2007
Mr Dzien
Ms Alverson:
[ received a letter (attached) dated September 27,2007, signed by
Cindy MarkOVich, Title Officer, United Title Company. That letter
falsely stated that I selected your otlice to provide title insurance
for my "current real estate sale or refinance transaction".
None of that is true.
When I called and talked with Terry, Title Officer, and Ms Alverson,
the Manager of the company, around II :OOam, [ was told that such
action was initiated based on a phone call from Victor Parks, Paci fic
Mortgage Consultants. They were surprised to hear that I had never
approached V ictor Parks in th is regard.
Ms Alverson and Terry both promised me that the letter wasjust a
safety instrument required by law for that purpose, moreover, Ms
Alverson promised me that she was closing that order #80701422-77, as
we were speaking on the phone.
Both promised me fax to contirm such understanding within 15-30 minutes.
When 1 called back more than 30 minutes later, Ms Alverson brought Mr
Dzien on the line, and he claimed that United Title was only
investigating the case, and it was not closed yet. Both demanded a
written demand from me to close order ;,80701422-77 , which is hereby served.
The fact that you initiated such fraudulent action by Victor Parks
based on a phone calL but demanded extra work and effon on my pan
to stop such fraudulent action is astonishing' Your conduct raises
concern that you are operating out of compliance with the law and in
violation of the terms of you Lcense.
Please contirm no later than 2 OOpm today, Wed, Oct 3, 2007,
that order #80701422-77 was irreversibly and permanently
closed. Please send copies by email, for expediency, and by fax, so
that [ have the hand signature image on it.
Joseph Zernik
320 South Peck Drive
Bfl, CA 90212
Fax: 8019900917

10/1812007
hvd: ORDER #80701422-77 Page 1 of 3
Moe Keshavarzi
From: Joseph zernik Uz 12345@earthlink.net]
Sent: Wednesday, October 03,2007 12:53 PM
To: Alverson, Sheri
Subject: Fwd ORDER #80701422-77
October 3. 2007
Ms Alverson:
Pkasc take notice.
This is to confirm that you acknowledged by phone receit of the email

below. I understand that your counsel did not receive his copy_ His
email address is corrupt. He refused to several requests to clearly
spe II it out by phone,
Regardless. you acknowledged receipt, and a fax was also sent and
succussfully transmitted (see below).
[ expect your immediate attention to this matter to mitigate harm.
Joseph 7ernik
Date: Wed. 3 Oct 2007 12:00:22 -0700
-From: send:{/~mail.efax.com
To: JlI234."i//:earthlink.net
'Subjtct: Successful transmi~,sion to 18009318888. Re:
X-J2ld: 79533."272
. X-.12Bld: 795335269
·X-J2C Date: 2007-10-03 11:53 :26
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Dear Joseph Zernik,

:>
Re:
-The I page fax you sent through eFax.com to 18009318888
was successfully transmitted at 2007 -10-03 19:00:22 (GMT),
. The length of transm iss ion \vas 54 seconds.
·The receivlI1g machine's fax] D: 18054961870.

10/18/2007
fwd: ORDER #80701422-77 Page 2 of 3
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>1'0: salverson:ii!unitedtitle.com, kdzien((tunitcdtitle.com I
. ·From: jost:ph zernik ·.jzI23451~!earthlink.net>
. Subject: ORDER #80701422-77
. SENT BY EMAIL AND BY FAX
. 'October 3, 2007
·Mr Dzien
·Ms Alverson:
·-1 received a letter (attached) dated September 27.2007, signed by

Cindy Markovich, Title Off;cer, United Title Company. That letter
-falsely stated that I selected your offict: to provide titk
insurance for my "current real estate sale or refinance transaction".
>None of that is true.
"When [called and talked with Terry, Title Officer. and Ms Alverson,
.the Manager of the company, around II :OOam, I was told that such
-'action was initiated based on a phone call from Victor Parks,
>Pacific Mortgage Consultants. They were surprised to hear that I
>had never approached Victor Parks in this regard.
>
> Ms A Iverson and Terry both promised me that the letter was just a
>safety instrument required by law for that purpose, moreover, Ms
>Alverson promised me that she was closing that order #80701422-77,
>as we were speaking on the phone.
>Both promised me fax to confirm such undt:rstanding within 15-30 minutes.
>Wht:n I called back more than 30 minutes later. Ms Alverson brought

'Mr Dzien on the line, and he claimed that United Title was only
>investigating the case, and it was not closed yet. Both demanded a
>written demand from me to c lose order ;;80701422-77 , which is hereby served.
-The fact that you initiated such fraudulent action by Victor Parks
>based on a phone call. but demanded extra work and effort on my part
to stop such fraudulent action is astonishing' Your conduct raises
concern that lOU are operating out of compliance with the law and in
>violation of the tenns of you license.
>Please confirm no later than .~:OOpm today. Wed. Oct 3, .2007,

>that order '18070 \42.2-77 was irreversibly and pennanently

10118:2007
Fwd: ORDER #80701422-77 Page 3 of 3
·closed. Please send copies by email. for expediency, and by fax,

'so that 1 have the hand signature image on it.
>Joseph Zemik
·BH. CA 90212
Fax: 80 I 990 091 7

10/18/2007
Page 1 of '-1
Moe Keshavarzi
From: Joseph zernik UZ 12345@earthlinknet]

Sent: Saturday, October 06, 2007 616 PM
To: Alverson, Sheri
Subject: URGENT TIME IS OF THE ESSENCE. DEMAND FOR DOCUMENTS. ORDER #80701422
77
Attachments: 07-09-10 MOTION ON 1703 to disqulify judge[2] w sig.pdf; 07-10-02 DOCUMENTS FOR
AITAChMENTpdf; 07-10-02 LEITER TO ADR+O'BRIEN+KESHAVARZI[slg] pdf
October 5,2007
Ms Salverson:
Copy of this Notice was also emailed to your attorney.
Please notice the Legal Notice below, addressed among others to United Title. It specifically requests that you
provide copies of documents that you hold authorize you to take any action.
Documents provided to me (attached: 07·09·10 Motion to Disq!Jalify Judge 170·3) as the basis for Samaan's
action:
These documents are insufficient, and accordingly, to the best of my knowledge, Judge O'Brien never issued any
order in this regard.
1) Email note from Christie Woo (ADR) dated Sept 7, 2007, providing me with the documents that Art Keshavarzi
provided her as the foundation for his authority (attached: 07·10·02 DOCUMENTS FOR ATTACHMENT):
a) Minute Order by Judge Connor, dated August 30,.2007.
b) Order Granting Summary Judgment by Judge Connor, dated August 9, 2007.
Neither documents is coming close to establishing any authority for any action by your company or anybody else.
2) Letter/Email sent to ADR/Judge O'Brien (attached: 07·10·02 LETTER TO ADR+O'BRIEN+KESHAVARZI
[sig]);regarding your letter dated Sept 27,2007.
This letter lists the deficiencies in documents produced to me as the foundation of authority.
No response was received from Judge O'Brien to date.
No notice of any action by Judge O'Brien was ever noticed to me.
Follow up questions and demand for docllments:
1) Referring the order was recorded on September 7, 2007 as document 20072080731.
Could you please explain wl1ich specific order you are referring to, and where you obtained that document
#20072080731?
I would be grateful if you could attach a PDF image of the order that you are referring to.
2) Is there any explicit authorization for your company to proceed with any action in that order?
3) Is there any other document beyond that Order that is the foundation for your actions in this case')
4) Are you implying that escrow was opened and your actions were part of an open escrow'> If so. what is he name of the
escrow company and the escrow officer?

10/1812007
Page:2 af4
:;) Did you get any document signed by Judge O'Brien to allow you to proceed with any actions') If so, please forward to me
a copy of that document.
6) I I' not, whose signature do you have and what document is the basis for the specific actions taken by your company: If so,
please forward to me a copy of that document.
7) It appears from conversation with rv1s Alverson and also with the appraisal company, that in both cases they received
instruction from Pacfic Mortgage Consultants and/or Victor Parks, employed with that company. Victor Parks is not an
uninvolved party, he is both a marriage relative ofSamaan, and currently there is pending motion to add him as cross
defendant in this legal action, on claims of Fraud, Negligence, and Conspiracy.
Did Parks provide any foundatIOn for his authority to contact you in this case?
ADDITIONAL INFORMATION REGARDING JUDGES:

I) On Sepetember 10,2007, I dirnqualified Judge Connor, by serving her in open court filing pursuant to Section CCP 170.3.
(attached) My claims amounted to: Willful Misconduct, Subversion of Justice, Fraud, Deceit. Corruption (no typo here) and
more. Judge Connor took ov~r an hour to read my tiling, then came back and stated that she was not admitting any of the
claims, but decided to recuse herself. Of note, she chose NOT to tile a veritied statement to justify her actions, which would
then be reviewed and adjudicated by another judge of the same court.
2) After that Judge Goodman was claiming assignment - he recused himself a few days ago, per CCP 170 I
3) After that Judge Biderman \\as claiming assignment - he recused himself today, CCP sectIOn unknown
4) Today I was told that Judge Segal is assigned, but [ cannot tind any document in compliance with the law to substantiate
that. Similarly, I could not find such documents for Judge Biderman and Goodman.
5) Together with Judge Neirdorf who recused himself per CCP 170.6 in :Z005, this case is now on its fifth judge' II
6) Judge O'BRIEN was supposed to be appointed as Escrow Referee, but his appointment was never completed.
PENDING COURT ACTION:
I) Ex Parte Hearing noticed fix Wed, Oct 10,2007, under Judge SegaL \\hich would include a proposed order to vacate
Judge Connor's Summary Judgement and Order Granting Summary Judgment.
2) Motion for Sanctions against Att Keshavarzi tor Samaan per CCP 128.7 is on the Court's schedule .
.3) Motion for Leave to Amend Claims, including claims against Parks and Samaan for Fraud, on the COLIrt's schedule
4) Notice of Appeal filed todJy
ATT DZIEN:
PLEASE TAKE NOTICE,
I) I hold that the facts listed aC)ove, on their own, require that as a Counsel who takes reasonable caution in his practice as an
attorney, you advise for your title company and Ms Alverson, to immediately halt any action.
2) I hold that the facts listed above, on their own, require that as a Counsel who take reasonable caution in his practice as an
attorney, you caution Ms A Iverson that she must take extra caution in review of documents, verification of signatures and
authenticity, and that you too lake extra caution in verification of the legal foundation of any authority tor any action taken by
you or by United Title .
.3) I sincerely hope that you do not get inadvertantlyl involved in conduct that is out of compliance with the law and the
terms of United Title license and your license as an attomey.
I demand that you immediatelv, and no later than Monday, October 8, 2007, 5:00pm, provide me copies of any and all
documents th~t are the found~tion for actions by United Title. Abent clear, unequivocal authority, I demand that
you immediately close this fijle.
Thank you for your cooperation,
Joseph Zernik
From: joseph zernik [ mailto:jzl2345@earthlink.netJ

10/18/2007
Page 3 01'4
Sent: Friday, October 05, 2007 11: 12 AM

To: pghChristian@sbcglobal.com; bruce@pmloans. com; jbakshandeh@hotmail.com; request@prefapp.com;
preferred@dc.rr.com; salverson@untitedtitle.com; Moe Keshavarzi; Mara@ADRservices.org
Subject: LEGAL NOTICE
October 5. 2007
Pacific Mortgage Consutants

.
Victor Parks. Keren Landucchi, Michael James O'Reillv, Bruce Kocen. Christina Pu~h ~
Ty
Preferred Appraisals
Ms Alverson
United Title Company
Mara Seales. Retired Judge O'Brien

CIO Mara Seales
ADR Services
RE: LEGAL NOTICE
To All Listed Above, Jointly andlor Severally:
Employees of Preferred Appriasal were found today on my property. listed below. they were requested
to leave immediately. and they left with me a paper showing that they were instructed to do so by
Christina Pugh of Pacific Mortgage Consultants.
I also received a ldter from United Title that they were requested to search title for the property by
Victor Parks of Pacifici j~ortgage Consultants.
Please take notice:
I am tiling a report with the Beverly Hills Police.
You are instructed to cease and refrain from any action relative to my property that is out of compliance
with the law and without my authorization.
If you have any lawful authorization for any of these actions, please forward proof of such authorization
to me no later than 5:00pm today, Friday, October 5, 2007. to this email address or by fax to: (801) 998
0917.
Absent proof of such legal authority. you may be listed in legal action.
Joseph Zernik. Owner

Beverly Hills. CA 90212

] 0/18/2007
Page 4 01'4
CC:
K~ren Landucchi
\1icha~1James O'Reilly
700 Larkspur Landing Circle #275
Larkspur. CA 94939
888A68.9502
Bruce Kocen
415-259-6380
bruce((l'pmloans.com
Christina Pugh
<pghChristianf(Lsbcglobal.com>
Victor Parks
CO Att Bakhshandeh
.c-Jbakshandeh((ohotmail.com>
(866 )-5.:28-2729
< preferred@dc.rr.com>
<request(wpre1'app.com>
l fniled Title
Ms Alverson
<sal wrsonl (vuntitedti tie. com>
Judge O'Brien
Mara Scales
ADR Services
<Maraf(!}ADRservices.org>
Nivie Samaan
c/o Att Keshavarzi
At 03:22 PM 10/3/2007. you wrote:
Both the property whidl is the subject mailer of our title file 80701422-77 and you are subject to the
Jurisdiction of the Los Angeles County Superior Court in case number SC 087400. It is noted that the court
grant~d a summary judgment in favor of plaintiff, Nivie Samaan, and against you in the lawsuit. The order
was recorded on September 7. 2007 as document 20072080731. No one at United Title Company has or will
make promises to you. Please do not communicate with our Westlake Village office in any fashion. You are
\\dcome to write or email me. Please note that the "corruption" in the email address you use was a typo on
your end.

1O! 18/2007
Page 1 of ')
Moe Keshavarzi
From: Joseph zernik [jz12345@earthlink.net]

Sent: Tuesday, October 09, 2007 1:29 AM
To: Dzien, Kenneth
Cc: Bruce Kocen- PMC; Alverson, Sheri; Christina Pugh- PMC; Ty - Preferred Appraisals
Subject: LEGAL NOTICE TIME IS OF THE ESSENCE. DEMAND FOR DOCUMENTS ORDER
#80701422-77
October 8. 2007
Mr Dzien. Ms Alverson - United Title
Mr Kocen. Ms Pugh - PMC
Ty - Preferred Appraisals
Sir/Madam:
Your name came up recently relative to an initiative by Mr Victor Parks to get you involved in a real
estate transaction. I called your respective offices and requested that you produce evidence that Victor
Parks was authorized by law to do so. None of you provided any evidence like that.
I again repeat my demand that you produce to me any and all documents used by Mr Parks to establish
his legal authority to initiate this action.
PLEASE TAKE NOTICE:
Did you obtain any paper with Mr Parks signature?
Mr Parks \\ias involved in multiple instances of fraud relative to a previous attempt by his relative
Samaan to purchase my property in 2004.
For example:
In the various subpoena production materials I found two types of hand signatures for Victor Parks.
One I identify as the Northern California type, and the other is the Southern California type. But none
bears any semblance to Victor Parks' signature on declarations in court.
Therefore. the signature used on a Prequalification Letter, dated Sept 7, 2004. presented by his relative
by marriage- Samaan - on his behalf - was the Southern California type. The content of that letter had
no base in reality. and constituted Fraudulent Inducement. In court, Victor Parks and Samaan, failed to
include that document in subpoena production, in fact disowning it. When I introduced it. as an
example of fraud perpetrated jointly by Samaan and Parks. they tried to raise evidentiary objection to the
document on the grounds of "improper fIuthentis:ation". With that, in fact. they admitted that it was a
case of forgery.
On the other hand. Samaan's 1003. which too - had no base in reality, was signed by the Northern
California type of signature. In court. they tried to introduce a copy with no signature at all. In that
document the signature indicates that Parks interviewed Samaan and entered that loan application. In
deposition, Samaan stated that Parks had nothing to do with that loan application. and that she and her
husband completed it \vithout even talking with Parks. In that document Parks and Samaan evidenced
Bank Fralld qgainst a Government Backed Lender.

1011812007
Page 2 of2
Also. in our transaction, Samaan (in LA) routinely sent and received fax communications impersonating
Parks (in Washington State at that time), That scheme that amount to Wire Fraud against an
Individual. and also Wire Fraud against a Financial Institution. Parks' fax line automatically
fornarded to Samaan's fax line. And when sending documents under his personality. she vvould set her
machine to show no header [D.
In short. you are provided more than sufficient warning. I demand to see any documents that were
presented to you as the Inundation for Parks' authority to initiate the title and appraisal action. These are
no fraud amateurs.
Here are link to some basic documents in this regard.

a) WIRE FRAUD AGAINST AN INDIVIDUAL AND AGAINST A FINANCIAL INSTITUTION:
http://home.earthlink.nctl-jzl.2345/COUNTR YWIDE/04-1 O-18-gemailsomvirefraud.pdf
EmailsfromrealtorLibowtoParksandback.Libowisrequestingexplanation.Su·ch requests were
repeated 3 days in a row.
Parks failed to respond. in fact tacitly admitting that his fax communications were automatically
diverted to Samaan all along without our knowledge.
Same scheme was used in communications with Countrywide re: loan documents.
b) BANK FRAUD AGAINST A GOVERNMENT BACKED LENDER:

http://homc.carthlink.ne~:I-jz 12345/COUNTRYWI DE/04-09-27-1 003p 1-4.pdf
Note double Receipt Da:te stamps page I
Note Parks signature on page 4. compare to c) below.
C)FRAUDlILENTINDllCEIVIENT
http://home .carthlink.nct/-j z 12345/COU~TR YWI D E/04-09-0 7prcqualificationletter. pdf
Note the hand signature on page 2. compare to b) above.
d) FRAlJD
http://homc.earthlink.net!-jz 1.2345!COUNTRYWIDE/06-1 0-27parkssignatureincourtdcclaration. pdf
Parks signature on court declaration bears no semblance to the previous two signatures.
I would be glad to provide additional information.
Prudence suggest that you stay away from involvement in such dealings, The statements above are not
the kind that are made lightly. and detinitely not the type that would be taken lightly by any body with a
license in the financial fi,~ld. You are more than welcome to share this communication with Mr Parks,
and try to get his response in \'vTiting. I would be grateful if you share such response with me. I believe
that is your minimal duty under such circumstances.
Joseph Zernik

110/18/2007
Page I of 3
Moe Keshavarzi
From: joseph zernik Uz12345@earthlink.net]

Sent: Wednesday, October 10,20074:54 AM
To: Dzien, Kenneth; Alverson, Shen
Subject: RE LEGAL NOTICE: TIME IS OF THE ESSENCE. DEMAND FOR DOCUMEI'HS. ORDER
#80701422-77
Att Dzien:
Could you please be \'l~ry specific regarding "certain court proceedings" referred below.
What documents were provided to you to initiate this process'?
Ms Alverson indicated that it was opened based on a phone calL and a phone call alone.
I repeat my demand that you immediately produce such documents to me.
Refusing to do so. and convincing Ms Alberson to reopen the tile, after she promised me in our tirst
phone call that she closed it as we were speaking, would raise questions regarding your conduct as a
counsel.
Joseph Zernik
At 10:49 AM 10/9/2007. you wrote:
I am not tr:v ing to be (C)J]frontational with you. but lneed to ask what is your kgal authority to make any
demand upon L nitcd litk') You are aware that lot 252 tract 7710 is the subject of certain court pmceeding to
which you are a party I understand that you have concerns, but I would appreciate your understanding that
United Title has obligations with regard to the privacy rights of others.
From: joseph zernik [ mailto:jz12345@earthlink.net]

sent: Tuesday, October 09, 2007 1:29 AM
To: Dzien, Kenneth
Cc: Bruce Kocen- Ptt1C; Alverson, Sheri; Christina Pugh- PMC; Ty - Preferred Appraisals
Subject: LEGAL NOTICE: TIME IS OF THE ESSENCE. DEMAND FOR DOCUMENTS. ORDER
#80701422-77
October 8. 2007
Mr Dzien. \1s Alvason - United Title

Sir/Madam:
Your name came up recently relative to an initiative by Mr Victor Parks to get you involved
in a real estate transaction. I called your respective offices and requested that you produce
evidence that Victor Parks was authorized by law to do so. None of you provided any
evidence Ii ke that.
I again repeat my demand that you produce to me any and all documents used by Mr Parks
to establish his legal authority to initiate this action.

10/18/2007
Page 2 01'3
PLEASE TAKE NOTICE:

Mr Parks \vas involved in multiple instances of fraud relative to a previous attempt by his
relative Samaan to purchase my property in 2004.
For example:
[n the various subpoena production materials I found two types of hand signatures for
Victor Parks. One I identify as the Northern California type, and the other is the Southern
California type. But none bears any semblance to Victor Parks' signature on declarations in
court.
Therefore, the signature used on a Prequalijication Letter, dated Sept 7, 2004. presented by
his relative by marriage- Samaan - on his behalf - was the Southern California type. The
content of that letter had no base in reality. and constituted Fraudulent Inducement. In
court, Victor Parks and Samaan, failed to include that document in subpoena production, in
fact disowning it. When I introduced it. as an example of fraud perpetrated jointly by
Samaan and Parks, they tried to raise evidentiary objection to the document on the grounds
of "improper authentication". With that. in fact. they admitted that it was a case of
forgery.
On the other hand.. Samaan ~\' 1003, which too - had no base in reality, was signed by the
Northern California type of signature. In court, they tried to introduce a copy with no
signature at all. In that document the signature indicates that Parks interviewed Samaan and
entered that loan application. In deposition. Samaan stated that Parks had nothing to do
with that loan application, and that she and her husband completed it without even talking
with Parks. In that document Parks and Samaan evidenced Bank Fraud against a
Government Backed Lender.
Also. in our transaction, Samaan (in LA) routinely sent and received fax communications
impersonating Parks (in Washington State at that time). That scheme that amount to Wire
Fraud against an Tndividual, and also Wire Fraud against a Financial Institution. Parks'
fax line automatically forwarded to Samaan's fax line. And when sending documents under
his personality. she would set her machine to show no header 10.
In short you are provided more than sufficient warning. I demand to see any documents
that were presented to you as the foundation for Parks' authority to initiate the title and
appraisal action. These are no fraud amateurs.

a) WIRE FRAUD AGAINST AN INDIVIDUAL AND AGAINST A FINANCIAL
INSTITUTION:
http://home.earthlink.netJ~jz I :.345/COUNTR Y'vVIDEI04-1 0-18-gemailsonwirefraud.pdf
Emails from realtor Libow to Parks and back. Libow is requesting explanation. Such
requests were repeated 3 days in a row.
Parks failed to respond, in fact tacitly admitting that his fax communications were
automatically diver1ed to Samaan all along without our knowledge.
Same scheme \lias used in communications \liith Countrywide re: loan documents.
b) BANK FRAUD AGAINST AGQVERNMENT BACKED_LENDER:

10/18/2007
Page 3 of 3
http> !home.earthlink.net/~jz 1.2345/COUNTRYWIDE/04-09-27-l 003p 1-4.pdf

Note double Receipt Date stamps page I
\iote Parks signature on page 4, compare to c) below.
C) FRAUDULE'IT INDUCEMENT
http:/; home.carth,!ink.m::t/~j 1.12345/COUNTRYWI 0 E/04-09-07prequalificationletter. pdf
d) FRAUD
http://home.earthlink.nctl~.i712345/COUl\TR YWI DE,:U6-1 0-
.2 7parkssignatureincourtdeclaration. pdf
Prudence suggest that you stay away from involvement in such dealings. The statements
above are not the kind that are made lightly, and detini tely not the type that vv·ould be taken
lightly by any body with a license in the financial field. You are more than welcome to
share this communication with Mr Parks, and try to get his response in wTiting. I would be
grateful if you share such response with me. I believe that is your minimal duty under such
circumstances.
Joseph Zcrnik

I0/1 ~V2007
Page I of4
Moe Keshavarzi
From: joseph zernik UZ 12345@earthlink.net]

Sent: Wednesday, October 10, 2007 1054 AM
To: Dzien, Kenneth; Alverson. Sheri
Subject: RE LEGAL NOTICE: TIME IS OF THE ESSENCE. DEMAND FOR DOCUMENTS ORDER
#80701422-77'
October 10. 2007
Mr Dzien:
Let me dilTer:
1) !'v1s Alverson indicated on the phone that she closed the order as we were speaking on the phone:
:2) Ms Alverson indicated by phone that because of the concern that actions be initiated that are not in
compliance with the law. title companies are mandated by law to send notices such as the one you sent
to me. which is how I knew of your actions in the first place.
3) You are an attorney and should know better, than tell me about "certain proceedings" ..
This is a repeat demand that you provide legal documentation for any action that United Title took
relative to my property.
I hope that this is not the way you establish the legal foundation of titles at United Title. Rut then again.
if Mr Parks chose you to work \vith. there may be a reason ....
Joseph Zcrnik
At 09:33 AM 10/1 0/2007, you wrote:
I hope that you will appreciate the fact that I want to be patient and show you respect. [n my opinion veiled
threats. demands made without basis. and a non businesslike approach only degrade one's position. Allow me
please to respond then to the essential points of your email You.ofcourse. are aware of the legal proceeding.s
..to which you are a party". You are participating actively in that litigation. Please cite any legal authority fix
JOu to request (you cal call it a demand if you insist) infolTllation from United Title. [n order to clear up one
of your assertions [ want to state that United Title personnel have made no promises to you nor will they ma"e
any promises to you in the future. You have no right to ask us to make promises to you.

Sent: Wednesday, October 10, 20074:54 AM
To: Dzien, Kenneth; Alverson, Sheri
Subject: RE: LEGAL NOTICE: TIME IS OF THE ESSENCE. DEMAND FOR DOCUMENTS. ORDER
#80701422-77
Att Dzien:
Could you please be very specific regarding "certain court proceedings" referred below.
What documents \vere pro\ ided to you to initiate this process'?
1\ls Alverson indicated that it was opened based on a phone calL and a phone call alone.

I 0; 18/~007
Page 2 of 4
Refusing to do so. and convincing Ms Alberson to reopen the file. after she promised me in
our first phone call that she closed it as we were speaking, \vould raise questions regarding
your conduct as a counsel.
Joseph Zernik
At 10:-1-9 AM 10/9/2007, you \vrote:
I am nut tryin~ to be ~onfrontational with vou . but I need to ask what is vour legal authoritv to make any
demand upon lin ited Title" You are awar~ that lot ~5~ tract 7710 is the s'ubject ;r certain CZHlrt proceedi"ng to
which you are a party. I understand that you have concerns. but I would appreciate your understanding that
United Title has obligations with regard to the privacy rights of others. ~
From: joseph zernik [ mailto:iz1234S@earthlink,net]

To: Dzien, Kenneth
Subject: LEGAL NOTICE: TIME IS OF THE ESSENCE, DEMAND FOR DOCUMENTS. ORDER
#80701422-77
October 8, 2007

\-1r Kocen. Ms Pugh - PMC
Sir/Madam:
evidence like that.
PLEASE TAKE NOTICE:

Mr Parks was involved in multiple instances of fraud relative to a previous attempt by his
For example:
In the various subpoena production materials I found two types of hand signatures for
Victor Parks. One I identify as the Northern California type. and the other is the Southern
court.
Therefore. the signature used on a Prequalification Letter, dated Sept 7, 2004, presented by

Page 3 of 4
content of that letter had no base in reality. and constituted Fraudulent Inducement. In
COllrt. Victor Parks and Samaan. failed to include that document in subpoena production. in
fact disO\vning it. When I introduced it. as an example of fraud perpetrated jointly by
Samaan and Parks. they tried to raise evidentiary objection to the document on the grounds
of "improper authentication". With that, in fact. they admitted that it \vas a case of
forgery.
On the other hanel. Samaan's 1003. which too - had no hase in reality. was signed by the
Northern California type of signature. In court. they tried to introduce a copy vvith no
entered that loan application. In deposition. Samaan stated that Parks had nothing to do
with that loan application. and that she and her husband completed it without even talking
with Parks. In that document Parks and Samaan eviJenced Bank Fraud against a
Government Bacj~ed Lender.
Also. in our transaction. Samaan (in LA) routinely sent and received fax communications
impersonating Parks (in Washington State at that time). That scheme that amount to »'ire
Fraud against an Individual. and also Wire Fraud against a Financial Institution. Parks'
fax line automatically fonvarded to Samaan's fax line. And when sending documents under
his personality. she would set her machine to show no header lD.
In short. you are provided more than sufficient warning. I demand to see any documents
Here are Iink to some hasic documents in this regard.

a) WIRE FRAtrD AGAINST AN INDIVIDUAL A~D AGAINST A FINANCIAL
INSTITUTION:
http://home.carthlink.neU~~jz 12345/COUj\.[TRYWI DE/04-1 O-18-9cmailsollwircfraud.pdf
Parks failed to respond. in fact tacitly admitting that his fax communications were
automatically diverted to Samaan all along without our knowledge.
h) BANK FRAlJD AGAINST A GOVERNMENT BACKED LENDER:

http://home.carthlink.netl~jz
12345/COUNTRYWIDEi04-09-27-1 003p 1-4.pdf
Note double Receipt Date stamps page 1
Note Parks signature on page 4, compare to c) below.
C)FRAUDULENTINDUCEME~T
http://home .earthlink.neU~iz12345/COUNTRY\VI D F>04-09-07prequalificationkttcr. pdf
d) FRAUD
http://home.earthlillk.net!~jL
1234j/COUNTRYWIDE/06_-1 0-
27parkssignaturei ncoul1declaration. pdf

I0I18/22l0KOQ7 _
Page -I- of 4
above are not the kind that are made lightly, and definitely not the type that would he taken
lightly by any body with a license in the financial tield. You are more than welcome to
share this communication with Mr Parks, and try to get his response in \"VTiting. [\\ould be
circumstances.
Joseph Zernik

Page 1 of 4
Moe Keshavarzi
From: Joseph zernJk UZ 12345@earthlink.net]

Sent: Wednesday. October 10, 2007 1204 PM
To: Alverson, Sheri
Subject: RE: LEGAL NOTICE: TIME IS OF THE ESSENCE. DEMAND FOR DOCUMENTS ORDER
#80701422-77
Ms Alverson:
As a title company, you have to operate within the terms of your lic~nse. Mr D7ien is not even coming
close to the conduct of 3. counse! acting in good faith. and he is representing himself as communicating
on your behal r
You noticed me, as you explained to me yourself, in compliance with requirements spelled out by law,
regarding actions you took against my property.
Please provide without 3.ny further delay the documentation. if any, that was the basis for such action.
If you indeed initiated such action based on a phone calL as you indicated, and had no documentation. I
would be fully satisfil:d and hav\.: no claims against you or your company, if you notice me that you
closed that order.
Your approach had common sense and honesty at its base. Your counsel's approach has none of that.
Please take notice and address the issues at hand \vithout any further delay.
Joseph Zernik
At 11:29 AM lOll 0/2007, you \\rote:
Do yOU really think that insulting people is the best way to achieve your goals? The problems that you face in
the litigation can understandably cause stress and [ ~im sorry for anyone who suffers in such circumstances.
Please do not take your frustrations out on others. Are you participating in legal proceedings other than the
litigation with Ms Sarnaan'J
From: joseph zernik [ mailto:jz12345@earthlink.netJ

Sent: Wednesday, October 10, 2007 10:54 AM
To: Dzien, Kenneth; Alverson, Sheri
Subject: RE: LEGAL NOTICE: TIME IS Of THE ESSENCE. DEMAND FOR DOCUMENTS. ORDER
#80701422-77
October 10. 2007
Mr Dzien:
Let me differ:
1) Ms Alverson inJicated on the phone that she closed the order as we were speaking on the
phone:
2) Ms Alverson indicated by phone that because of the concern that actions be initiated that
10/18/2007
Page 2 of 4
are not in compliance with the law, title companies are mandated by Imv to send notices
such as the one you sent to me. which is how I knew of your actions in the first place.
3) You are an attorney and should know better. than tell me about "certain proceedings" ..
This is a repeat dt:mand that you provide legal documentation for any action that United
Title took relative to my property.
r hope that this is not the way you establish the

legal foundation of titles at United Title.
But then again. if Mr Parks chose you to work with. there may be a reason....
Joseph Zcrnik
At 09:33 AM 10/10/2007. you wrote:
I hope that you will appreciate the fact that I want to be patient and show you respect. In my opinion veiled
threats. demands macle without basis. and a non businesslike approach only degrade one·s position. Allow me
please to respond then to the essential points of your email You.ot course. are aware of the legal proceedings
"to which you are a party". You are participating actively in that litigation. Please cite any legal authority for
you to request (you can call it a demand if you insist) infomlation from United Title. In order to clear up one
of your assertions I want to state that Lnited Title personnel have made no promises to you nor will they make
any promises to you in the future. You have no right to ask us to make prolTiiSeS to you.
From: joseph zernik. [ mailto:Jz12345@earthlink.net]

sent: Wednesday, October 10, 2007 4:54 AM
To: Dzien, Kenneth,: Alverson, Sheri
Subject: RE: LEGAI'_ NOTICE: TIME IS OF THE ESSENCE. DEMAND FOR DOCUMENTS. ORDER
#80701422-77
Att Dzicn:
Could you please be very specific regarding "certain court proceedings" referred below.
What documents were provided to you to initiate this process?
Ms Alverson indicated that it was opened based on a phone call, and a phone call alone.
Refusing to do so. and convincing Ms Alberson to reopen the file, after she promised me in
our first phone call that she closed it as we were speaking, would raise questions regarding
your conduct as a counsel.
Joseph Zernik
At 10:49 AM 10/9/2007. you wrote:
I am not trying to be confrontational with you. but I need to ask what is Jour legal authOrity to make any
demand upon Un ited Title? You are aware that lot 252 tract 7710 is the subject of certain court proceeding to
\\hich you are a party. I understand that you have concerns. but I would appreciate your understanding that
United Title has obligations \\ ith regard to the privacy rights of others.
From: joseph zernik [ mailto:jz12345@earthlink,net]

To: Dzien, Kenneth

0/18/2007
Page 3 of4
Subject: LEGAL NOTICE: TIrv'IE IS OF THE ESSENCE. DEMAND FOR DOCUMENTS. ORDER
#80701422-77
October 8. 2007
Mr Dzien. Ms Alverson - Lnited Title

Sir/Madam:
evidence that Victor Parks was authorized by la\\/ to do so. None of you provided any
evidence like that.
PLEASE TAKE NOTICE:
Did you ohtain any paper with Mr Parks signature?

For example:
Victor Parks. One I identity as the Northern California type, and the other is the Southern
court.
Therefore, the signature used on a Prequalification Letter, dated Sept 7,2004. presented by
content of that letter had no base in reality, and constituted Fraudulent Inducement. In
court. Victor Parks and Samaan, failed to include that document in subpoena production. in
fact disowning it. When I introduced it, as an example of fraud perpetrated jointly by
of "improper authentication". With that. in fact, they admitted that it was a case of
forgery.
On the other hand, Samaan's 1003. \vhich too - had no base in reality, was signed by the
entered that loan application. In deposition, Samaan stated that Parks had nothing to do
Also, in our transaction, Samaan (in LA) routinely sent and received fax communications

1()/18/20()~7~ _
Page 4 of
Fraud against an Individual, and also Wire Fraud again st a Finan

cial Institution. Parks'
sendin g~ docum ents under
fax line autom aticall y. forwar ded to Samaa n's fax line. And \vhen
his person ality. she \vould set her machi ne to show no header 10.
d to see any docum ents

In short. you are provid ed more than suffici ent warnin g. I deman
ity to initiatc the title and
that were presenh?d to you as the founda tion for Parks' author
apprai sal action. These are no fraud amateu rs.
Here are link to some basic docum ents in this regard .

NCIAL
a)WIRE FRAUlD AGAINST AN INDIVIDUAL AND AGAINST A FINA
INSTITUTION:
emails onwire fraud. pdf
http://1 1OI11 c.earth link.nc t/-jlI23 45/CO lJNTR YWI DE04 -1 0-18-g
explan ation. Such
Emails from realtor Libow to Parks and back. Libow is reques ting
reques ts were repeat ed 3 days in a row.
unicat ions were
Parks bi led to respon d. in fact tacitly admitt ing that his fax comm
autom aticall y diverte d to Samaa n all along withou t our knowl edge.
loan docum ents.
Same schem e was used in comm unicat ions with Count ry\vid e re:
ER:
b) BANK FRAll1D AGAINST A GOVERNMENT BACKED LEND
http://homc.caI1hlink.nct!~jzl2345/COUNTRYWI DE/04 -09-27 -1 003p] -4.pdf
Note double Receip t Date stamp s page 1
Note Parks signat ure on page 4. compa re to c) below.
C) FRAUDULENT INDUCEMENT
httpIh omc.e anhli nk.neU ~jz 1234 sIca U NTR YWI 0 E/04-09-07 preq
uali ticatio nktter . pdf
Note the hand signat ure on page 2. compa re to b) above.
d) FRAUD
http:// hornc. carthli nk.net !--jzl2 345/C OCNT RYWI DE/06 _1 0
:2 7parkssi gnatur ei ncourtde~ laration. pdf
us t\VO signat ures.
Parks signat ure on court declar ation bears no sembla nce to the previo
I would be glad to provid e additio nal infonn ation.
s. The statem ents
Pruden ce sugges t that you stay away from involv ement in such dealing
not the type that would be taken
above are not the kind that are made lightly, and definit ely
more than welco me to
lightly by any body with a license in the financial field. You are
se in writing . I would he
share this comm unicat ion \vith Mr Parks. and try to get his respon
minim al duty under such
gratefu l if you share such respon se with me. I believ e that is your
circulTIstances.
Joseph Zernik

10/18::::007
Notification for lORE: LEGAL NOTICE: TI\lE IS OF THE ESSENCE. DEMAND fOR ... Page 1 of 1
Moe Keshavarzi
From: Joseph zernik [jz 12345@earthlinknet)

Sent: Wednesday, October 10, 2007 5:16 PM
To: Alverson, Sheri
Subject: Notification for "RE: LEGAL NOTICE: TIME IS OF THE ESSENCE. DEMAND FOR
DOCUME"
Attachments: ATT1489184 txt
The message yOll sent on Wed. 10 Oct :?007 15::?0:21 -0'+00 regarding "RE: LEGAL NOTICE: rIME IS OF 1HE
ESSENCE. DEMAND fOR DOCUMENTS. ORDER 1"80701422-77" has been displayed by joseph zernik.

10/18(2007
Page I of 2
Moe Keshavarzi
From: Joseph zernlk UZ 12345@earthlinknet]

Sent: Friday, October 12,20071:18 PM
To: Alverson, Shen
Cc: Ballow, Deetta
Subject: Validity of legal notice provided by your company
October 12. 2007
Ms Alverson:
I tried to reach Cindy Markovitch, Title Officer vvho signed the enclose notice, as required by law.
This notice includes false and misleading information. I am not invol ved at present in any real estate
transaction. I have no escrow holder, etc. Following the warning in this notice, I was trying to contact
ms Markovitch to inform her of such.
[Iowever, Oeata vvho answered the phone indicated that Ms Markovitch has been on medical leave since
Sept \. 2007.
In compliance with the law. pleasl: send a valid notice signed by a Title Officer vvho is avvare of such
notice being sent, and who may accept information from me. and required in this notice. Failure to do
so. combined with your continued refusal to inform me of the status of order #80701422-77 RE: 320
South Peck Drive. may he deem in violation of the term of your license. The purpose of the legal
requirement is to eliminate ambiguity in a field where fraud is increasingly common in Southern
California. Refusal to inform me of the status of this order after I provided you with documentation of
fraud by the person vvho issued the request for such order is inexcusable.
Please immediately provide full and complete information in this regard.
Sincerely,
Joseph Zernik

10/18;2007
Page 2 of2
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SHOULD YOU, AS THE PROPERTY OWNER, HAVE NC

~FINANCE TRANSACTION, PLEASE CALL THE UNDERS
~E ~O~T0 LIKE TJ ~
DP -:- ~J ;:. ,~ "1
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/ /
10/18/ i 007
Page 1 of 4
Moe Keshavarzi

Sent: Wednesday, October 10,20071105 AM
To: Bruce Kocen; mike@pmloans.com
Cc: Dzien, Kenneth: Alverson, Sheri; Christina Pugh- PMC; Ty - Preferred Appraisals
Subject: LEGAL NOTICE TIME IS OF THE ESSENCE. DEMAND FOR DOCUMENTS RE ORDER
#80701422-77
October 10. 2007
LEGAL ~OTICE: TIME IS OF THE ESSENCE. DEMAND FOR DOClrME~TS RE: ORDER
#80701422-77
Mr Kocen and Mr O'Reilly:
J am not sure who proviueu you with the document you attached. However that document is
insufficient. This is NOT a legal JUDGMENT. Being a non-la\vyer myself, it took me time to digest
the fine points that are particularly confusing in this case. since the ~'lotion (Motion for Summary
Judgment) incorporates the word judgment in its name.
For example,
ENTERING a Motion for Summary Judgment is NOT entering a judgment...
NOTICI1'iG Motion for Summary Judgment is NOT noticing judgment...
i\ Rl iLiNG in favor of plaintiff in Motion for Summary Judgment is ;\len a judgment...
NOnCE OF RULING in Motion for Summary judgment is NOT a notice of judgment...
NOTICE OF ENTRY OF RULING in motion for summary judgment is NOT a notice of entry of
judgment...
ORDER granting summary judgment is NOT ajudgmenL.
NOTICE OF ORDER granting summary judgment is NOT notice of judgment...
NOTICE OF ENTRY OF ORDER granting summary judgment is NOT a notice of entry of judgment... ..
The document that should have been the source of authority had to be JUDGMENT itself. not any of the
trailers coming before the movie... these are just trailers, but \ve need to see the movie itself. ..
If you read it carefully, the document that you provided. at its very end. come close to it:
CQNCLUSION
IT IS THEREFORE ORDERED that plailltiffNivie Samaall's motion for summary

judgment is GRANTED and that judgment shall bt} entered fonhwith in filvor of Nivie 5amean
aIld against defendant Joseph Zernik on the single cause of action for specific perfonnance.
Dated: August 9. 2007 --JAy,OUEUNE A CONNor
HOIl. acquehne A. Connor
Jud~ of the Superior Court

10/18(2007 _
Page 2 01'4
But you have not been provided with any document showing that: ''judgment shall he entered
forthwith" had indeed ever taken place. Typically such action by the court would be documented by:
a) .Judgment, and
b) Notice of Entry of Judgment
1) Please let me know immediately if)!ou ever get any document of that nature, i.e. Jl!DGMENT,
and/or NOTICE OF ENTRY OF JUDGMENT relative to the property.
Since I am not a lawyer. I derive most of my legal knowledge from less than reliable sources. Here is
Wikipedia on the subject (emphasis. underlines in the original):
JU[)GMFNT:
[n the United States. under the rules of civil procedure goveming practice in tederal courts and most
state courts. the entry u!iwl,l.!,11!ent is the final order entered by the court in the case. leaving no further
action to be taken by the court \" i th respect to the issues contested by the parties to the law,ui t. With
certain exceptions. only a/ina/judgment is subject to appeal.
However. since your company is engaging in conduct against my property. that I notice you is out of
compliance with the law. 1hold that you carry have the burden of the proof
2) Please provide me a signed legal opinion of a counsel with his/her license number, that you are
allowed to engage in any conduct against my property based on "Order Granting Summary
.Judgment" alone, absent a JllDGMENT and NOTICE OF ENTRY OF JUDGMENT.
Absent such opinion and/or such documents [ demand the Pacific Mortgage Consultants provide me
valid legal notice no later than Thursday, October 11,2007, 5:00pm, that you have noticed:
a) United Title Company.
b) Ms Alverson
e) Ty
d) Preferred Appraisals
e) Christina Pugh of PMC, and
t) whoever else was involved in this. that any such conduct was lacking in legal foundation and must be
immediately be ceased and vacated.
Joseph Zernik
At 08:44 AiYl 10/10;2007. you wrote:
Ilello Dr. Lemik,

Sorry it has taken me 2 days to respond to you but getting information about Mr. Parks
heing authorized by law to proceed was difficult since you provided no infonnation about
the nature of the problem or the legal disputes involved with your property. You also failed
to mention the summary judgment against you.
Attached is a copy of the summary judgment against you that seems to legally dispute your
contentions of fraud and to allow Nivie Samaan to proceed with the transaction.
Could you please send me copies of any appeals or reversals of this judgment or the case
numbers for any other actions you may have submitted to the court'?
Thank you
1011812007
Page 3 01'4
Bruce Kocen
From: joseph zernik [ mailto:jzl2345@earthlink.net]

Sent: Tuesday, October 09, 2007 1:29 AM
To: Dzien, Kenneth
Cc: Bruce Kocen- PMC; Ms Alverwson - United Title; Christina Pugh- PMC; Ty - Preferred Appraisals
Subject: LEGAL NOnCE: TIME IS OF THE ESSENCE. DEMAND FOR DOCUMENTS. ORDER
#80701422-77
October 8. :2007
Mr Kocen. Ms Pugh - Pl\1C
Sir/Madam:
evidence like that.
PLEASE TAKE NOTICE:
Did you obtain any paper ,vith \!Ir Parks signature'!
Mr Parks ,,,as involved in multiple instances of fraud relative to a previous attempt by his
For example:
Victor Parks. One I identify as the Northern California type, and the other is the Southern
court.
Therefore, the signature used on a Prequalification Letter, dated Sept 7. 2004. presented by
his relative by marriage- Samaan - on his behalf - waS the Southern California type. The
court. Victor Parks and Samaan. failed to include that document in subpoena production, in
fact disowning it. When I introduced it. as an example of fraud perpetrated jointly by
Samaan and Parks. they tried to raise evidentiary objection to the document on the grounds
of "improper authentication". With that, in fact. they admitted that it was a case of
forgery.
On the other hand. Samaall's 1003, which too - had no base in reality. was signed by the
signature at all. In that document the signature indicates that Parks intervie\',ed Samaan and
entered that loan application. In deposition, Samaan stated that Parks had nothing to do
,,,,ith that loan application. and that she and her husband completed it without even talking

10/ 18/2007
Page 4 of 4
Also. in our transaction. Samaan (in LA) routinely sent and received fax communications
impasonating Parks (in Washington State at that time). That scheme that amount to Wire
Fraud against an Individual. and also Wire Fraud against a Fillanciallllstitution. Parks'
fax line automatically forwarded to Samaan's fax line. And \-vhen sending documents under
his personality. she would set her machine to show no header [D.
1n short. you are provided more than sufficient warning. I demand to see any documents
I !ere are link to some basic documents in this regard.
INSTITUTION:
http://home.earthlink.netl-jzl2345/COlJNTR YWIDE/04-1 0-18-gemailsonwirefraud.pdf
Parks faikd to respond. in fact tacitly admitting that his fax communications were
automatically diverted to Samaan all along without our knmvledge.
b) BANK FRAUD AGAINST A GOVERNMENT BACKED LENDER:

http:!,home.earthlink.netl~jz
1 2345/COlJNTRYWI[)[i(l4-09-n-l 003p 1-4.pdf
Note double Receipt Date stamps page 1
Note Parks signature on page .+, compare to c) below.
C) FRALJDllLENT INDUCEMENT
http://home.carthlink.netl~jz1 2345/COUNTR YWI 0 E/04-09-0 7prequalificationletter. pdf
0Jote the hand signature on page 2. compare to b) above.
d) FRAUD
http://home.earthlink.net/~jz 1 2345/COUNTRYWI OE/06-1 0
27 parkssignaturei ncourtdeclaration. pdf
above are not the kind that are made lightly. and definitely not the type that would be taken
share this communication with Mr Parks. and try to get his response in writing. [would be
circumstances.
Joseph Zernik

10I18::~007
Brief Update - 10/11/07 Judge O'Brien, ADR resign Page 1 of 1
Moe Keshavarzi
From: Joseph zernik UZ12345@earthlinknelj
Sent: Saturday, October 13, 2007625 PM
To: Bruce Kocen- PMC
Cc: Dzien, Kenneth; Alverson, Sheri; Christina Pugh- PMC; Ty - Preferred Appraisals
SUbject: Brief Update - 10/11/07 Judge O'Brien, ADR resign
Attachments: 07-10-13 BRIEF REVIEW (sigj pdf
FYI:
1) A brief update is attached.
2) I still expect notification from each of you separately

That any and all actions taken against the property at 320 South
Peck. BH CA 90212, without authorization by the owner, Joseph Zemik,
and without any other valid legal authorization that you could
document. were withdrawn and voided.
Joseph Zernik

10/18::::007
DECLARATION OF lVIOE KESHAVARZI
2 I, MOE KESHAVARZI, declare as follows:
3 1. I am an associate at the law firm of Sheppard, Mullin, Richter &
4 Hampton, LLP, counsel to plaintiff Nivie Samaan ("Samaan"). I have personal
5 knowledge of the facts stated in this declaration and, if called upon to testify to these
6 facts, I could and would competently do so.
7 ') On August 9,2007, the court (the Honorable Jacqueline Connor,
8 Department l) granted Samaan's Motion for Summary Judgment and ordered Zemik
9 to sell the Property to Samaan. On the same day the Court entered judgment in
10 favor of Samaan. Attached hereto as Exhibit I is a true and correct copy of the
11 Court's judgment. At a hearing on August 21,2007, Judge Connor informed both
12 parties that she had decided to appoint a referee to oversee the escrow and sale of
13 the Property and protect the interests of both parties. Judge Connor then asked both
14 parties to recommend three referees to be appointed. Subsequently, both parties
15 recommended three referees each. Both Samaan's and Zemik's list included the
16 Honorable Gregory O'Brien, Jr. (Ret.) of ADR Services, Inc. ("ADR Services").
17 On August 30, 2007, Jude Connor appointed Judge O'Brien as the referee and
18 ordered that the parties share his fee. Attached hereto as Exhibit 2 is a true and
19 correct copy of the Court's order appointing Judge O'Brien as the referee.
20 3. Upon being appointed as a referee, Judge O'Brien's assistant Ms.
21 Christie Woo scheduled a hearing on September 10 for Judge O'Brien to meet with
22 the parties and discuss escrow. On Friday, September 7, Zemik spoke
23 telephonically with Ms. Woo and asked for a conference call on that day to discuss
24 the case. Attached hereto as Exhibit 3 is a true and correct copy of Mr. Zemik's
25 email to Ms. Woo and Ms. Woo's email to Mr. Zemik. At2:17p.m.,Ms. Woo sent
26 both parties an email preliminary scheduling a conference call at 5: 15 p.m.
never took place because Zemik refused to participate. Instead Zemik wrote emails
Exh p 42 EXHIBITS
_____VOL V - RECEIVERSHIP
~------,-l~- _
ZERNIK V CONNOR ET AL DECLARl\TIO:\ OF \1OE KESHA VARZI
to Ms. Woo challenging Judge O'Brien's appointment and asking for copies of all
2 orders that authorize Judge O'Brien to act as a referee and hold conference calls.
3 Attached hereto as Exhibit 5 are Mr. Zernik's emails to Ms. Woo and ADR Services
4 challenging Judge O'Brien's appointment.
S 4. Zemik also did not appear at the September 10, conference with
6 Judge O'Brien. r appeared with my client's husband and discussed escrow with the
7 Judge. That morning Zemik gave notice of his ex parte application to recuse Judge
8 O'Brien, even though he had recommended Judge O'Brien. Attached hereto as
9 Exhibit 6 is a true and correct copy of Zemik's ex parte notice of September 10.
lO 5. Subsequently Zemik refused to pay his share of Judge O'Brien's
11 fee and on September 20 wrote an email addressed to Judge O'Brien saying he
12 would not pay the bill because "as I explained in the past, I would not be able to
13 participate in a processes that is out of compliance with the law. Moreover, I find it
14 a sad commentary that you, Judge O'Brien, did." Attached hereto as Exhibit 7 are
15 true and correct copies of email from Zemik to ADR stating that he would not pay
16 his share of fees.
17 6. Between September 20 to October 5, Zemik sent no less than 35
18 emails and letters to ADR's employees demanding documents, accusing Judge
19 O'Brien of "dubious conduct", claiming "I do not recognize the validity of the
20 appointment of Judge O'Brien, and object to any action by ADR in this regard".
21 Zemik also threatened Judge O'Brien to stop working on the case because "you are
22 personally involved and liable." Attached hereto as Exhibit 8 are true and correct
23 copies of some of the emai1s from Zemik to ADR. On October 15, after Zemik's
24 repeated threats and emails, in a letter to this Court resigned as the referee.
25 Attached hereto as Exhibit 9 is a true and correct copy of Judge O'Brien's letter to
26 Judge Segal.
27 7. Since August 9,2007, when Judge Connor granted Samaan's
28 Motion for Summary Judgment, Zemik has noticed no less than 37 ex parte
-2
ZERNIK V CONNOR ET AL DECL--\.R.c--\.TIO"l OF
W{Jc-\\E"r 1\I\lKJ -'U05IU26J I 'vI0E KESHA VAR71
applications. Among these ex parte applications are Zemik's repeated requests for
2 reconsideration of the order granting Samaan's motion for summary judgment. In
3 these ex parte applications Zemik also has repeatedly challenged the Court's
4 authority over him, called Judge Connor a "corrupt judge," calling Judge Segal "a
5 rogue judge" and asked Judge Segal "to cease and refrain from acting as the
6 presiding judge in Samaan v. Zemik". Attached hereto as Exhibit 10 is true and
7 correct copies of some of Zemik's Ex Parte to vacate the judgment.
8 8. The property located at 320 S. Peck Drive, Beverly Hills,

9 California is currently worth more than $1,718,000. Attached hereto as Exhibit 11
10 are true and correct copies of comparable recent sales near the Property. Attached
11 hereto as Exhibit 12 is a true and correct copy of a New York Time article regarding
12 the decline of real estate values.
13 9. During the litigation, while Samaan's motion for summary
14 judgment was pending, Zemik contacted Countrywide, a third-party witness and
15 asked that they sign false declarations. Because Countrywide would not do so,
16 Zemik began harassing its employees, including its president and General Counsel.
17 Eventually Countrywide obtained a protective order banning Zemik from harassing
18 Countrywide's employees.
19 I declare under penalty of perjury under the laws of the State of
20 California that the foregoing is true and correct.

21 Executed on October 26,2007, in Los Angeles, California.
22
23 By: ----------~------
24 Moe Keshavarzi
25
26
27
28
\\IIC'W~~ r ZERNIK V CONNOR ET AL DECL\RA. nON OF \10E
I \1\IKJ ·lO0503263 I KESIL\ VARZI
u
o ,I
8 SUPERlOR COLRT FOR THE STATE OF CALIfORNIA
COl~TY Of LOS A;"';GELES
10 WEST DISTRICT, SAr--;TA MOl'IC\
II
) Case ~o. SC 087400

12 .'\[VIF SAMAAN, )
) ORDER GRA\ITrNCr SC\1MARY
13 Plaintiff, \ JUDGMENT IN FA VOR OF PLAINTIFF

) NIVIE SAMAA.N
14 VS )
IS JUSEPH IER:"IK, ) Hearing Date: August 9. :::007
) Department I
I (, Defendant
) Han. Jacqueline A. Cormor
J~
18
19 PlaintiffNivie Samaan's motion for summary judgment came on regularly for hearing on
20 August 9, 2007 before this Court in Department I, HOD. Jacqueline A. Cormor presiding.
21 After full consideration of the evidence, the separate statements, and the authorities
22 submi [ted by each party, as well as oral argument, the Court finds that plaintiff has met her
2j summary judgment burden by proving each element oEher claim for specific performance,
2.. entitling her to Judgment on that cause of action. Defendant has failed to respond ""ith specific
25 tacts, .;upported by properly authenticated evidence, demonstrating a triable issue of material fact
:'6 eXists as to plaintiff s cause of action or an affirmative defense.
1~ A purchaser who fultills all obligations, except for timely depositing the purchase price
28 C5crOI)'. ',,", ill not be denied specific perfc)rmancc if that failure is anr:butable to the seller' s
- 1

suhstantial noncompliance with his escrow obligations. (\iim;tv i\int: [nvestrnent~Ltd. v.
Overseas_Couricr_5ef\lce (Singapore) Private. Ltd. 12(03) i!3 CaIApp.-+th ; IlS. IIJ-+;GJ.!~
v. Damish (2003) 113 Cal.App.4th 1331, 1)43.)
[ill:? declarations of Gail Hershovvitz. Vlctor PJrks. :md \b.ri:l \kLuurin s11ppon the
contcntion that \[5. Samaan \\as not pro\iJed with 1 rLl!~, I:?.'\ecllted purchase agreement. the
h ··Re~iJl>nti:.il Purcha~;e \greement :lnd Joint Escrov" [:;-;tnlctinr:s" in particular. ,wtiI SU;llC tine:
8 ;Vis. Hershowitz at Mara Escrow dated October 22.2004 at 3:42 p.m. (Moving Papers, Exhibit
q I 2'+) and the fax. from Victor Parks to Countryv.iJe on October 25.2004 (Opposition. Exhibit C).
!o Ms. Hershowitz states that, at the time afher fax at 3:-:1-2 p.m. on October 22, 2004. Mr. Zemik
II had continued to fail to provide .\1ara Escrow with a fully executed copy of the purchase
12 agreement. 'vIs. \1cLaurin states that. by October 25.2004, all loan apprO\al cond~tions had
13 been met by Ms. Samaan except for the provision of a fully executed purchase agreemect. Base
II on this evicence, the Court finds that Mr. Lcmik'3 noncompliance caused the delay by ~ls .
., Samaan in removing the appraisal contingency.
Iii As of October 2';, 2004, Ms. Samaan had fulti!Jed all ooligations, except for rcmoval of
17 I the appraisal contingency. The appraisal contingency could not be removed w1til Ms. Samaan
13 received loan approval. Approval of the loan was delayed because COllntrywide had not
19 received a fully executed copy of the purchase agreement. Despite multiple requests by Victor
20 Parks and/or \!1s. Samaan to Mara Escrow to provide the executed purchase agreement, it was
21 not provided until the late afternoon or evening of October 22, 2004 because Mr. Zemik had not
sivned
c
or initialed the "Residential Purchase Agreement and Joint Escrow Instructions" until
then. Ms. Samaan's failure to remove the appraisal contingency until 5: 18 pm on October 25,
24 .2004 ""as sakIy Clttributable to Mr. Zemik's noncompliance md, therefore, she is entitled under
25 the law to specitic performance. Repeated contentions by :Vir. Zemik that his signature on the
26 second counter-ofter \"as sufficient to complete the purchase agreement is simply not supported
27 oy ::L'l)' authority or expert declaration, but in fact is directly contradicted by the declarations of
2S .'vIr. Parks and ),,[:;. :VIcLaurin.

I
- i!
/\dditionally, 'vfs. Samaan faxed her final contingency removal to \Iichael Libow at 5: 18
, i p.m. un October 25, ~004. ~[r. Zanik's cancellation instructions wen:: not faxed to .\fs. Samaan
by ~Iari.l Escrow umil 5:23 p.m. on October 25, 2004. Mr. Lemik's contention that he canceled
t~<;; ce::1l by fax on October 21, 2004, is not supported by the undis~uted record of events. In his
.: initial fax. \fr. Zemik simply ~takd that he would be requesting that his realtor. \1r. LibO\s,
rycparc: .;zmcd\:1tion instruuJOns. This tax was follovied hy lJllgoing ,:unvcrsarions bcrv.een the
8 not occur until October 25.2004. Nothing in Mr. Zemik's fax indicated that he was canceling
i) escrow immediately or as of that or any date.
10 Finally, Mr. Lernik's lruudulent inducement claim, based on an allegedly fraudulent loan
11 prequalification letter by Victor Parks dated September 7.2004, is no more than a red herring.
12 ~tr. Zemik did not cancel escrow based on any question regard ing Ms Samaan' s
13 prequalification in September 2004. As set forth above, Ms. Samaan had obtained loan approval
14 on October ::'5, 2004 and final approval on October 29. 2004. before the escrow closing date of
15 November 1.2004. Ms. Samaan has also provided uncontroverted evidence establishing her
16 current ability to purchase the property. (Canino Declaration.)
17 While there were dubious actions on both sides, it is ultimately clear that Mr. Zcmik' s
18 own actions caused the delay in loan approval and resulting delay in Ms. Samaan's ability to
19 remove the appraisal contingency, the concededly sole basis for .\1r. Zemik's cancellation of
20 escrow. The evidence shows that .\1s, Samaan was ready, willing and able to complete the
21 purchase by the November 1,2004 closing date and is presently ready, w'illing and able as well.
22 CONCLUSION
n IT IS THEREFORE ORDERED that pJaintiffNivie Samaan's motion for summary

24 Judgment is GRA?\'TED and that judgment shall be entered forthwith in favor ofNivie Samaan
25 and against defendant Joseph Zemik on the single cause of action for specific performance.
26
'7 Dated lHlgust 9, 2007 JACQUELINE A CONNor~_

Hon. Jacqueline A. Connor
Judge of the Superior Court
..'

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Moe Keshavarzi
.,--.._........~~_-------------------
From: Christie Woo [Christie@adrservices.org]
Sent: Friday, September 07, 2007 10'.51 AM
To: joseph zernik
C:c: Moe Keshavarzi
Subject: RE: ADR SERVICEs
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•.---------------------------------------------
Moe Keshavarzi
From: joseph zernik [jz12345@earthlinknet]

Sent: Friday, September 07, 2007950 AM
To: christie@adrservices.org
Cc: Moe Keshavarzi
Subject: ADR SERVICEs
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Moe Keshavarzi
.------~~--------------------
From: Christie Woo [Chnstie@adrservicesorg]
Sent: Friday, September 07, 2007 10:51 AM
To: joseph zernik
Cc: Moe Keshavarzi
Subject: RE: ADR SERVICEs
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.,----;;,,;,..,.--------------------
Moe Keshavarzi
IFrom: Christie Woo [Christie@adrservices.org]

Sent: Friday, September 07, 20072: 17 PM
To: Joseph zernik
Cc: Moe Keshavarzi
Subject: RE: Samaan v. Zernik
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To: Christie WOC
Cc: Moe Kesnavarzi
~ubjeot: AC2 SERVICEs
H. ~ Christie
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2
-- ---------------------------------------------------1
Moe Keshavarzi
From: Joseph zernik Uz123 45@ea rthlinkn etj

Sent: Friday, Septem ber 07, 2007 300 PM
To: Christie Woo
Gc: Moe Keshavarzi
Subjec t: RE ADR SERVI CEs
Li/707
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could 'I'J~ do ~Lc1L S-J~eas e'?

.Moe,Keshavarzi
--------------------------
From: joseph zernlk Uz12345@earthlinknet]
Sent: Friday. September 07, 2007 304 PM
To: Christie Woo
Gc: Moe Keshavarzi
Subject: RE: Samaan v. Zernik
! '~~lS~ >~·::~e ~!1i' 2ITldil ~o '/C'J, KE::-.sta~v-"ar::i -',F -J. r-.,
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ny conv~r~dt~0~ Wi~~l Mr. :=ernlk, we understand t~~: ~i~.

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1/
"f!:::ilrloutioL, [' ',,'C'C fn c! this comrr:uni-:::aticm is stri,~tly pr()hi:!Lt~:l.

>l: i'O!] haVt~ recei'leJ (hLS transmissicn in errc)r, case immediate:;iy
ti~ us by U'lc::,p!'lOne at (31 ) 201-0010, 3.nd r"::'t\1Cl the origlrial
>messaqe ~o ADR Services Inc. at 1900 Ave[;~e of the Stars, Suite 2~C, )3
'Angoles, Callfornl3 90067.
>-----Jrigin~l ~essdqe-----
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Exh p 60 EXHIBITS VOL V 2- RECEIVERSHIP

Moe Keshavarzi
From: joseph zernik [jz12345@earthlinknet]

Sent: Friday, September 07, 20074:20 PM
To: Christie Woo
Cc: Moe Keshavarzl
Subject: RE Samaan v, Zemik
'V8Cl.f'j
~der v~ur ~lessaye te~~~ 1,,:0 L
r: (l',/~ '~n'-=t~l~d r:t;ly pi~ns .. '-'->- ,-1 FCl_ne a ~ ':">~ r::.oor.;'
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~rn Stat0rrl~~~t 3~(j
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'~OS les, Calltornla 90067-4303
>,~hone: jH) LOI-OOICI
>Fax: 131 201-0016
,'>This ~l.ectc\};lii.~: EleSSdQe con.tdi;-,:s q~i_\.riJ..cyed or- confidential ir~fo~:T.a,=::'n,

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>d;,,:l ciou r i:J", or .:opYlng 01' this:nrrnunication is S1:::::::, ['I crohibited.
>IE you 'Ie ::,?ce~ved this t.l::3n.s:Tlis:::::ion in er-ror, plpd.se ]fTlinedi_itely
notit'y j ; h'/ 'elepho:le at (31 ;',';1-0010, and return tr>, ur:ginal
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Exh p 62 EXHIBITS VOL V2 - RECEIVERSHIP

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3
Page 1 of 1
Moe Keshavarzi
From: joseph zernik Uz 12345@ earthli nknet]
Sent: Monday, September 10,20 07348 AM
To: Moe Keshavarzl; Shu/kin, Robert
12, 2007, TO STAY AND AND ALL ADR
SUbject: Notice of an ex parte appearance, WEDNESDAY, SEPT

PROCEDURES AND PROCESSES , TO RECUS E JUDGE O'BRIEN.
noticing it for Wed.

It was supposed to be for tomorrow, but since it is later than 10.00am, I am
Sept 6, 2007
At1. Kcsha varzi and Att Shulki n:
I will appear Et Parte in Depar tment I

I write to provid e notice that at 8:30 a.m. on WED Sept 12,200 7,
d at 1715 Main Street. Santa
of the West Distric t of the Los Angel es Count y Superi or Court locate
Monic a, Califo rnia 90401:
PROC ESSES IN SAMA AN V
TO STA Y ANY AND ALL ADR SERV ICES PROC EDUR ES AND
ZERN IK. TO RECU SE JUDG E O'BRI EN.
join a stipulation on this issue.

Please let me know if you plan to attend Please also let me know if you would
meant to ensure compliance with basic prodecures of the law.
Joseph Zernik

0/26/2 007
Moe Keshavarzi
Sent: Thursday, September 20,200712:10 PM
To: Christie Woo
Cc: Moe Keshavarzi
SUbject: FW Samaan v Zernik
Attachments: Minute Order appointing referee. PDF; Order Granting Summary JudgmentPDF: 07-09-20
MOTION EX PARTE DUE PROCESS w exh w sig.pdf; 07-09-10 MOTION ON 1703 to
disqulify judge[2] w sigpdf
Minute Order Order Granting 07-09-20 MOnON 07-09-10 MonON

appointing refere... ummary Judgmen.. EX PARTE DUE P... ON 170.3 to di...
recoivl.:ci i !':1:<: -,tJ~ '__

s c"/es, as far .3.3 1 a~ ,-~')rJ>::rn.~c:lf
h billi:-ig ~_:--~at
,"3S i_:ocIi~rr~(;t_ \-\:C-jf L~:~)K, 'Brien,
lnd i<eshavdLzi proceeded 'V'Ji-::.h -3
r::roce.::3s \-h(~'-,rhi"') 'f. ()f. (--=::>mpl~c~.'1ce ~;v-;_~~ t:_r,~ lawen !v1cnday, '''::'~~I_~:~Inbel~
10, IJC1/, ~ :-:._l,e ~r._-:iL ::u: r<::i-=-:--ll::J 1--::;, ctlt::: dUC"L:nenta-:ion r_'r:)T/l,~-i~j 'c"':/
cJl~-; l~OI) I ., j '. "1 'A C: ; ,~, C l _ I \- I:)
D ~_ ~SCCJ'l~:' r '/
A:-3 i zrJ~J-:". i ~~\ . r,t> ,-:1 ::_) ._ , ",';C,' ~_.:. ~_ j ;,~ r~.:-~ ::tole to p,-jr-=-~_,'~;:Ctr-:~ :'1'1.
prOCE_S~:)t:?:< tf- A __ '.-; ~_,,_ l ~ _::nJ 1 ~lr~:':c' ~\lJ: ~ h :he Lc.',\".
')u,
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BTW: BE::' ~\V~~~~·/t.hi:-.q 2~::3e, th,'3t "H~:iri.nq"/"Confc~.:-enc2", '"",:':::L:::

:--;(.-::hcdul~ci t--i r.t: L:,~<- >-Jith a hedrLo"-1 ():; ~'l:~)tion per I:C? :-:3':'::C:t.l'20 12,:.---:
j(~,iirL~r ~(:':')~'~,-i-J-:l2:: I '~d~:n c"a.:::-~~d ~L~S filinqs O~. ~f~~:-~dir:(J
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3 biq cii=f\::::re:--J.'':>~, .5":";~
u:ied that. ri;'S L~.t. t'J 3ec;e f~lirJj
per CC? sect.ion170.3 '"ith ~':rl,JC'
CcnnUL Lc\SL·:-l.], OJ f~::ai~y .iisquaiLfy her.
~---'cr your rt;::::-·-:'rc'rL:~, ~:n,,~:;" s<:::d is tn,}:, fil..Lng aod my fili~lq ~O(}dY: ~!<
p~irte toe S6~~'Jl~3~d : f dLle process.
/SubjecT_: C"11J: ':d:-'"':n--ill n Ze;:lik

/Date: :"ri,G" 7 :-6:10:21 -()'OJ
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/·agent res~ons~t~~ ~~ ~el~vering th~s ~e~sage ~o the intended ~ec:r~0~t,
"YOll are h~~LCY ~.,~~~~_~~d t~at any oisclcsc~e, dissemi~ar~c~,
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>messaqe t'J ;:.~,R ~~r·,,~~ .s :=nc. ae 1'9 C :~~,lenu~ -:=;t t:le Stars, ~ul:-_e ~ '~, Lcs
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'+loe Kesha'Ja yo: i
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·To: C'hrlsr.i..-: 1',ic'~J

>Cc: Moe Kpsndv~~:l
<Mi:lute nr>Jpc 1ppcc"tirg ~-8terC?e. !?DF» Ce <~Order Granting

>cludgmen t . F J~' L> c ~ ~'ils III
'Per Mr. Kp~~~,"'J;iL·:l.':~ :~,s~r'~':tions, "~f'JciJardinq the Mir,lJt:p

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,'r:::,rivilur '~C~~i(.~eLti,::ll It '!:JU r,--:,,-'ei',/pd :=-.his transmis51cn .:r1 ~~:'r. r,
>pl~dse notity tne sender: by ~eply ~-mail a~d delete the messag~ lnd ~ny
>attachments.
>Sheppard, Mull~n, ~ :hter & Hampton ~LP
>Piease ViSl~ ~t~r ~:e0Slte 3t www.shePPd~dmullin.com

2
Page 1 of:2
Moe Keshava rzi
From: joseph zernlk Uz12345@earthlinknet]

Sent: Tuesday, October 09, 2007 926 AM
To: Christie Woo: maraseales@adrservlcesorg
Cc: Moe Keshavarzi
Subject: RE Samaan v Zernlk, Statement for services dated September 19, 2007
October 9. 2007
Judge O'Brien
Mara Seales
Christie Woo
ADR SERVICES
Judge O'Brien. Ms Seales. Ms Woo:
I would like to up the antes: $1.000 to Mr Keshavarzi ifhe could produce a valid documentation that the
Motion ['or Sanctions per CCP section 128.7 was already denied.
Regardless of the fact that I do not recognize the validity of the appointment of Judge O'Brien, and
object to any action by ADR in this regard. I hold that it is ADR's obligation. hased on the pretension of
appointment. to acknowledge receipt of communications from a party.
Ms Woo and \ls Scales: Please acknowledge Receipt of this communication. and fcmvarding of the
message to .fudge O'Brien.
Joseph Zernik
At 09:52 AM 9/27/2007. you wrote:
fhe 128.7 motion was already denied. \1s. Woo. we would appreciate a hearing as soon as possible so that we
can stan the cscrow process.

sent: Thursday, September 27, 2007 12:44 AM
To: Moe Keshavarzi; mara@adrservices.org; Christie Woo
Subject: RE: Samaan v. Zernik, Statement for services dated September 19, 2007
Sept 26. 2007
Judge (,regory O'Brien

C/O ADR SFRVICES
RE: Samaan v. Zernik, Statement for services dated September 19,2007
Judge ()'Brien:

10/26/2007
Page 2 of2
I \\ould like to repeat my previous offer and up the antes:

$300 to Keshavarzi
$300 to Obrien
S300 to Woo
If Keshavarzi can tInd anything even REMOTEL Y close to
".Judge Goodman already acknowledged that the last hearing was not ex parte because :VIr. Zernlik had
notice of it.".
in the transcript of any Court session that I attended.
But the ex parte's I referred to went far beyond that meeting on Sept 102007... In transcript
of August 30. 2007. Status Conference. Keshavarzi had already reported his first
discussions with you. Judge O'Brien (page 6, lines 9-11. attached). And I must assume that
he was discussing your appointment as a "Receiver" the same way he discussed it with
Claudia and Christie at that time.
And on Labor Day Monday Keshavarzi was notifying me of arrangements for a "Hearing"
with a referee, that by Tuesday morning nobody in ADR knew about yet... and nobody
would answer or explain how that meeting came to be noticed on Labor Day Monday by
Keshavarzi. and scheduled in conflict with a court hearing where Keshavarzi was supposed
to explain why he had knowingly and repeatedly filed offending documents.
In short Keshavarzi took the necessary steps to corrupt the procedure before it even started,
and Judge Connor. as you can read in the transcript refused to spcll out the required terms
of app()intmenL because she did not want to allow the appointment of an independent
autonomous referee (p6 lines 13-22), thereby yielding some of her authority. she wanted to
reserve to herscl f the right to intervene... So no matter how clearly I presented to her the
terms that the law required to be defined. she could not find the papers (p6. lines 23 to p7
line 7).
By the way. the new Court hearing for the Motion for Sancations per CCP 128.7 is set ~Dr
Monday. November 5, 2007. 8:30am.
Again. I would appreciate some acknowledgment of receil.
Joseph Zernik
This message is sent by a law firm and may contain information that is privileged or confidential.
If you received this transmission in error, please notify the sender by reply e-mail and delete the
message and any attachments.
Sheppard, Mullin, Richter & Hampton LLP

Please visit our website at www.sheppardmullin.com

10/2612()07
Page I of ~
Moe Keshavarzi
From: joseph zernik UZ12345@earthlink.net]

Sent: Friday, October 12, 2007 11:46 AM
To: Judge O'Brien c/o Christie Woo
Cc: Moe Keshavarzi; mara@adrservices.org; Robert Mussig; Paul Malingagio
Subject: TIME IS OF THE ESSENCE: REQUEST FOR NOTICE/MINUTES OF PROCEEDINGS: SEPT 10,
2007 AND ANY OTHER PROCEEDINGS IN SAMAAN V ZERNIK
October 12,2007
SENT BY EMAIL AND BY FAX
TIME IS OF THE ESSENCE: REQUEST FOR NOTICEIMINUTES OF PROCEEDINGS

SEPT 10,2007 AND ANY OTHER PROCEEDINGS IN SAMAAN V ZERNIK
Judge O'Brien:
Needless to point out to a judge that disambiguation is a central tenant of Due Process. and derived from
it among others. are Notice and Minutes.
Your repeated billings through ADR Services document proceedings re: Samaan v Zemik. SC087400.
including hut not limited to that of Sept 10.2007 by you and Mr Keshavarzi. It is now over a month
later. and Notice/Minutes informing me of what transpired in such proceedings are long overdue. I have
requested such on several occasions in the past. and as a judge. I expected that you would havl; issued
such notice/minutes of your own volition even if I forgot to ask for such. especially since I was not
present or privy to any of such proceedings.
I request again that you immediately provide valid, authenticated notice/minutes of any proceedings or
communications. formal or infomlaL direct or indirect that you participated in RE: Samaan v Zernik. in
person, by email. by correspondence, or by phone, vvith counsel for Samaan and/or the court, including,
but not limited to:
I) Communication with Keshavarzi prior to Aug 30, 2007.recorded by Mr Keshavarzi in Status

Conference of Aug 30, 2007.
2) Direct or indirect communication with Keshavarzi on or around Lahor Day Monday, that
resulted in Kcshavarzi's illegitimate "notice of hearing" by email to me of that date.
3) "Hearing" \vith Keshavarzi on Sept 10. 2007
.+) Direct or indirect communication with Keshavarzi on or around Sept 14, 2007. that resulted in
your alleged hand signature on a Proposed Order "lodged" in court around that day.
5) Letter to Judge Goodman, on or around Oct 3,2007, documented by his response letter, copied
to me.
Failure to immediately provide such notice/minutes. even after repeated requests. mayor must be
deemed as abdication of your duties as a neutral in general, and a neutral in Samaan v Zernik in
particular.
Joseph Zernik
PS: Ms Woo. please confirm by email receipt of this email. and the respective fax. on behalf of Judge

10/2612007 ZERNIK V CONNOR ET AL
Page 20f2
O'Brien. Failure to confirm receipt of such communications must be deemed as abdication of your duties
as a provider of neutral services in generaL and in Samaan v Zernik in particular.
Exh10/26/2007
p 70 EXHIBITS VOL V - RECEIVERSHIP

FACSIMILE TRANSMITTAL
~DR'M
SEAVICES
ADR Services, Inc.
1900 Avenue of the Stars, Suite 250
Los Angeles, California 90067
WVWw'.adrservices.org
Digitally signed by Joseph
Joseph Zerr'ik
DN: cn=Joseph Zernlk,
email=Jzl234s@earthllnk. net1
DATE: October 11, 2007
Zernik
c=U';
DatE: 2007 10.13 13:26:07
-07'00'
RECIPIENT ~ FAX NUMBER 1if PHONE NUMBER

r----.--- w
- - - - - - -~
--,- _.
I MOE KESHAVARZI, ESQ. I (213) 620-1398 j (213) 620-1780
j
JOSEPH ZERNICK
----------~---_._-~
i (801) 998'()917 I
1(310) 435·9107
St=NDER
, CHRISTIE WOO : (310) 201-0016 : (310) 201-0010

I- - _ . _ - - - - " .- -~--------------
NUMB~R OF PAGES INCLUDING COVER: 2
RE: SAMAAN V. ZERNICK
ADRS Case No. 07-4107-GCO
LASe Case No. SC 08740D
Message:
Please find attached CORRESPONDENCE for the above--referenced matter.

Ocrober 1 J, 2007 1tDR~
E1iDII
1900 Avenue of (he Stars
Hon John Segal 5u ire .250
WEST DISTRICT SU1)ERIOR COURT Los Angeles, (!.,. 90067
Santa Monica Courthouse [310) 201-0010 T~I
(3\0) 2010016 F4'
1725 Main Street
Santa Monica., Califomia 90401 www.~d rservicQI,orl'
REo' SAJ"}iAAN v. ZERNIK

LASe No. SC087400
Dear Judge Segal:
I understand that the above matter has been reassigned to your depanmcnt. Unfortw:l.,tely,
since the case was first referred to me by Judge Cormor, certain cirClUnstances have arise:) I that
make it imprudent fl)r me to remain as the referee. After further discussion with members c, ( this
firm, 1 must reluctantly decline to participate further in this reference. This is om a recusal, a~, [ am
otherwi~e prepared to engage this matter impartially, and I know of nO fact Or appearanc,: that
would require my disqualification. Please also consider this letter to be on behalf of ADR Sel vices,
Inc., which shall decline any further reference as to this case
If you would like to discuss this with me personally, please do not hesitate to call.
V cry truly your~,
,~(t'-'6'?~~-?
Judge Gregory C. O'Brien, Jr., Ret.
ce. Moe Keshavarzi. Esq.
D,- Joseph Zernik

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Sl PERIOR COlRT OF THE STATE OF C\LlFOR:\IA
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I~ ll.lo,rpf-I-;r:R'IK. ;\I~;I~J;~~J'\I~I: I CO'\-IPL\I':\ ' r s EX P.\RTF \PPE:H,:

II FOR \i\ ORDER TO v.\C\n:
I') I <. .ross-C pm p lalll :lilt. H()\IE""T 1'1 PL\IYrlFF"S 'lOTIO'\(
FOR Sl \lU-\RY Jl OG\lEVr. .\,[)
, I .'
-( I 2) TO FI~[) PL\Ii\TIFF'S "\CnO'l \
2\ I CUI. 0\\ ELl. fl\\.KER RESIDE'.<TI \L \1:\UnO[5 PROSEClTlO:'l RASED
BROI\..ER.\CrF. \llC H.\EL l.mow. an 0'\ FRo\LDLLE:\T CL\I\lS.
,~ I indi\ Idual.
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27 I I ..JOSEPH ZER:\Ih:.. DEFE\D \\TA:\D CROSS-CO\IL\l'l,.\"T.

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I Uf.~~· \ D\ \ T..£ (K( I~) ( 0' If)L.\!\\\! E- \ ?\R r f:. \PPL!C\ fiO\ TO \V \ n.
il .It [)\IE:~ r OF PL-\ 1\ T!FFS \IOTlO,\; FOR "l \!\I.\RY Jl D(;\IE\ T. TOFI'\D P[\I'\TIFF
II RI \\[",G \J,\ll( 1m..; PROSrc l.T1u,\ B.-\SED ()\ FR-\IDl U:\T Cl\l\IS

II
I'
DECL.\RTIO~ OF .JOSEPH ZER:\IK

I" ~l"PPORT OF HIS ~PPE \L
TO V.\C\T£ .JlO\I£Yf I'\; PL\''iTIFF'S 'IOTfO'J FOR
-, I) Sl\l\l.\R\ .Jl'DG'IE~T. .\~D TO FI~D PL\I.'TIFF·S\CTIO;\ ,\ \I.\L1CIOrS
, Ii PROSECl TIO~ 8,\SfO 0" FR\tDlI.EYf CI."\IS.
.' '
.~
I. I hen e personal kn(m kJge (,f the facts ~ct forth hcrt:in \\< hich I kno'\< (0 be true
5
and com:d and. If called as a \\ itness. 1 could and \\ ould competentl) tcstif\ \\ Ith rc-;pect
7I
thereto. fhis declaration is opposition to Plaintil1s E'\. P~u1e application n.:lt:n.:nccd abO\c.
8 i\ I. .\. Fraudulent Induccment - against SeBcr - Joseph Zernik:

l) II Side .\'mnuan l're....e nted to me j'lIriowifraudulent document..· between ,\'eptemher .J ami
I
I () I!
Septemher 1.1, ]O()4, ill order to com'ince me to enter a real eMate ('ontract with Iter, at lea....t
\1
one ofthcl1l (Preqaulf!;cution l,et1er) was prohah~r pre....ented with .";ome le1'el (~l('(Jllahorati(}n
12
by 'letor PaTh.
13
'1
In summer ~O()4 I listed my residencc (320 South Peck DI;\e. B~ I 9(J~ 11) for sale
14
_ I\\ ith realwr \ li~had Libl..1w.
I) I
i 3. On September 4. 2004. I \\ as presented by \1ichael l ibo\\' \\ ith an otTer by \,: i\ ie
16 'I
, Samaan. She represented herself as an interested buver. \'. ho doubled as a realtor. \\ ho "doses a
17 I!
k\\< deal a \ car". and \\<ho was reTJresenting herself in this transactipn.
18 I I - t '
4. I did not want to e'Cn look at the otTer. since it \\as a realtor rcprescming self and
19
"as concerned that she was not qualified as a huver buv an ohjectivc third party.
20 !I' . " .
")1 I'! 5. III reSlxmsc.

t
stat1inl!
'
Sept 7. .2004.~amaan presented sc\eral documents to
-
Y) I I com mee me to cllkr the ag.reement. Ihose documents willed out to be ti-aud.
23 II: 6. To 0\ crCOIlle Ill\"• eoncems. she tlJn:sented. throuuh

~
Ill\"
•
realtor (\\ 110 could eontrIlll
")4 : £111 the 1:1ets in this I\:poni. \ lichaell ibow. a Prequalitication ktter bealing the signature of a
~-
...:.)
I Ltnll1 Broker. \'ICfor Parks. '-t)\\ \\C kIltm that the;: si!.!.nature on that letter is fraud.
'-
~md probabl\ 01
'1(
- ) II
i i the hl\ as a \\hole is fraud.
,
~~
I
She ,ubmitted a sceuTh.Ikner iI1 \\ hi\.h ~he "ald that "he' ..;II '''eel a kw I"cal L·~tate
28 deab a \ car. \ll\'. \\l: h.no\\ that :-.hc Ilt,'\tT e\en a:,si~ted in an\ ~ka1.
iI -2
Exh p 76 II
r\~: ..: r : , n \ ' T EXHIBITS VOL VU
I-'·{-D{)-:~(("I\'D' - ,RECEIVERSHIP
I , T C V OIDT"C IODlli\T/(), rf\\"I('\
Ii
iI
8. ~he submitted a third letter in whi~h she said that she lmned stock cll.:COlllltS. \;o\V
., I: \\t: knov.. that at that time sht: l)\\IlCd Ill) stol.:k aC~Ol1nt.
3 C) She submitted a kner saying that she \\ as going on bus mess out of to\\ n. 1:lter on
4- 'I she infonned llS, after I sl~'l1ed the contract. that she got manicd liuling. that trip. That made a
.5 III dilfcrencc. since in Califomia. in such situation. we could not complete the deal \\ ithout a
() i IClmS~'Ilt from the husband. In tact :lhc \\as hiding from us fhat then: \\ollid be a Ile\\ party to thl'
7 III deal.
9
B. ''"ire Fraud - against Joseph Zernik, Seller; and against a financial institution
10 Countrn~ide:
1\ Sil'ie Samaan with coopt..7ation (~l lidor Parks enKtlged in a ,'1'e/teme hy whk·h .,lte K.'wifaxing
p
and receil'ingfaxe~ion heha(l(~f lidor Parks, a /.oan Broker who was ha,'\etl in
13
Washington State, on herfax machine in to.. .' AnKele~: Thefaxes lhat ~'he . . .e nt on heha(lof
I~
r idor Park,', exceptfor thefirst one (Prequal!fication retter) were mi\·.\'ing The If) required
15
hy law at the lop (~l theflL~ L'sing ,\'Uch a .\'cheme ,,.he pre'''''ented documents, el'en in court,
16
which she claimed were sent hy I [ctor Park.. , to ('ountrywide. III fact, .mch documents
17
werefaxed hy Sit'ie Samaan to .Iae ,(rre IJ(~rd (her hushand, prior to 20(H 11£.. , identity was
18
Timothy /.h~rd Jforrow)and f. 7ctor PlIrk\~
19
The he~·t example fif·that i.. . /he "CtJlijornia Re,\'idential Purchase AKreement"~ It Iw.\· aflL'\
.2u
cm'er sheet hearing the name of Park.., and tlte fax ('m'er sheet . . .u gge.. .·t.. .· t!tat it wa,,, fiu'ed to
]1
., ., (tmlltrywide ofJice ill flortherll ('a/({orl1ia (Sail Rafael). TlteflL'\ header then .\ugKe,\1S tltat
theflL'\ 'Was reeeh'ed Oil ()ctoher 2.', ]()1)4, at ';:()3pm. Tltat i . .· exacT~r Itow it WlIS repre.\'entetl
-"
--'
in ('ourt, lIllder penalty (~lperjur.r.
'4 .
;5 i III fact, i{ we check on tlte/ax log, we reuli:.e that !hi'\flL'\ wa."" ....ent hy Samaan, no! Park.."
alld H'U,\',cllt lO Park\, /lot [() CtIll/ltrJ'H'ide. Therefore, we do !1ot AllOW wltat time it Wt/.\'
.26
.,..., receh'ed in Countrywide, whid, wo.. .' (l critical i'\,me in tlti.. , litiKation.
...: ,/
.28
.,
-.
Exh p 77 f'\~.T 1-, f\ \ ' TEXHIBITS
~, {'prj';';:,,' , 'VOL V-
RECEIVERSHIP
\ '\ T r.'v 0 \ ern::
( n Inr\" \ nor Jr· \ T·,f)'\" TI) \. \ r \ rl-:
Id. Later \)/1. on October 18. :O()4. whm sill: did not gd the loan appro\t?d b~
Clluntt\.\\ ide. Llbo\\ \\as t3'\.ing a document to Parks. fo his surp,;se. he noticed that the fax
i~ s\\ itching numbers and going to Samaan.

10 [ibow then scnt an email to Parks nn October 18. 200..t , asking to e"pJain this.
b i i Parl\s did nut n.:spond lO that qu.:stilHl (Libo,\ .s Email :::.1 )

7 II. Liho\\ thL'n ~('nt an crnaillo Parks also on Ocotober 19. and October 20. repealing
s these qucstil)ns. Parks did not respond. ( Libo\'" . s F mail tt.2~.
9 p By then I n:aJized that [ \\3'i the victim of a fraud and b} Ocotober :? I. ,2 ()04. I
10 (41ncded the lkal.
\ I 1\ I~. Recently (abollt 1-2 months ago. October-'\O\ember 2(07). \\hile I \\as l"C\levving
I ~ II, documt:nts Samaan submitted in (\)lu1. I finally rt:alized that I had the proof of this \\ ire li·aud.
I
13
Samaan submitted in COLu1. \\ i th other dlKuments. also her t:n log. It ..,110\-\ s that she \\ as using
\4
an HP 13SCI~jt't tin. printl'f copieL Such a machme C<in be ca,>r1~ pwgrammcd to :-;how mnrc than
15
one pcrsonality at that fax header imprint. Sean.:hing this fax h'g J could find various uocuments
16
that \\ l:fC faxed h) Samaan LInder her own name (Spellbound) and others that v. ere f~lxed \\ hen
17 , . . k
I she was IInpersonatmg Par' s (anonymous).
IR I!
10
\ make this lkdaration under penalty of perjury according to the la\\s of the ';'Talc of
.20
California. Signed here in Be\erl~ Hills on Octoba II. 2007.
~ 1
,~:1"-"1
/' . I
/ I
//
~ - ~. ~. L,,---,
JOSfPH If:R\/K
DF- FE'\. D \ '\.T & CROSS CO\! PI \ 1'\ \'\T
{II 1"'(1 fl'r
-4
Exh p 78 rn'[..·r:;\. n \ EXHIBITS 'n,
VOL
\.T Ii. {'i){,~~lOTVl "
,. - RECEIVERSHIP
\ \. T ~v CJ \ 0 rr:: l DDr I{' \ TT{Y\. T i l \. \ { ' \T<:'
11
II
li.\
I
TT\CHED DOCr"E\TS:
~ I
~I \ Parks has thrc~ t~ pes l)f signatures in documents.
-+ II! H.9 270-1- Samaan's Loan .\pplicatioTl with Parks signature.
I
-; ! t. 9. 7. O-l . Samaan's Prequalitication Letter \-\ tth Parks signature
(1 j: [) 10 18 Cl-t Fmail from I ibo\\ to Parks questioning the fax fraud.
7 il F 10 19.()-'- Fmail response from P:uks to Libov.. avoiding. the question.
8 II FlO Il) 0-'- Fmail from LibO\\ to Parks. again asking about the fax fraud
G. 10 27 04 Fax log submitted hy Samaan in Court. showing both documents Sfllt under her
<)
(I\\n ID: Spellhound. and under 10: .\nl.mymous. \\hid \\-as typically used for Parks. It i:.
10
like!)' that the ID:P'\rc. used in the PrcquaJitication Letter (Doc C) is from the same
\I
machine. but \\e do not have the fax log for that da).
p
H.IO 4 U-l Contmgency Rcmoyal: One.
13
Fax recei\cd bv Libow from Samaan \.-\ith ID: Anonymous
I·t
L 10 20 (}-\- Contingency Rel1l1.J,al: 1\\0
15
Fax n:cl:i\ed by LibO\\ frmn Sarnaan with II): Spellbound
16
J. \ 0<::'5 o-t C ontil\gency Removal: Three
17
Ihl\ received by LlhoV'. from Samaan with ID: .\non»mous. marked ~Ith * III Fax Log
18 II
I (Document G)
19
K. THIS I)OCl"IE~T PROOlTEO HY COl':\TRY'\,IOE .\PPE.\RS ''''ITH 10:
.20
"\~O~Y\lOrs". IT APPPE..\RS f'i THE F.\X LOG ,\:\0 SHO\\'S TJI.\ T IT
~I
\\.\S F.\XEO BY SA.'t\.\" TO.\ F\X .\SSOCI.\TEO \\'-TII .IR LLOYD
')')
('lARKED \\'1'1'11 **). I' COLRT IT "'.\5 CL,\I'lED l',\DER PE'\.\LTY OF
I;
23 i I PERJLRY BY BOTH P.\RKS .\'\0 KESH.\ V\RZI TH.\TIT \\·.\S F.\XEO O~

I
""·t !
- I OCT 25.200-4. 5:0JP\1 BY P,\Rh:S TO COl·,\TRY\\IOE.
-, - II
'.
-) L\ F \CT. TIIF:RE IS '\0 \VA \' TO TELL \\ HE' .\:\0 HO\\ IT \\·.\S
26 !I DELIVERED TO COr\TRY\\'fDF'
i:
"~II
.;,.
I
OF ,\OTE: P.\RKS SIG\.\fl RE DOES '\01' .\PPE.\R BERL
i
.28 II L Dcp..hitil)!l ~)f Samaan 011 July 10. 2006.
I -'1
Exh p 79 rH.. h L ' f) \ , EXHIBITS

T VOL
\.'. (. [) 1', ..... ;;,: (- V \-J RECEIVERSHIP
( ) \ lOT '\ \ " T r. Y 0 \ 0 1'r: \ D D I If \ Tin, T / \ \ . \ {- \ T C
i)
I: \
j I
I In this deposition she contradicts many or her O\ln prc\ious statements,
I
) II ~hl: hdd Ill.) npl:IICIh.:C in real ~'Sla{~. !l(;\ cr dos('d a deal or c\ en .ISSlSh:d prior to Sept
~, II
" ~O()4
I
-l II
I'
\
She nc\ cr t)\\Tlcd 311\ stock accounts in Sept 2004
5 I(
Parl..s was !wt at all im olH~d in her iL)an application
() !i Parks \\as her hushand's OR r loyd_ formerly Timothy Ilo,d \IOlTO\\) fil';f cousin and
"7 ,I
II bu~inL'ss associate,
10
\ I
12
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16
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Exh p 80 r,;~r;r:'\"" T
EXHIBITS
Y. f
VOL V - RECEIVERSHIP
Drll.:' I ' { , \ l o r , I ' , " T I V D ' UTI' \ DOl If - t TI{\\.' 'If', \ ' ' f ' \ Tr:
:I\TT\CHED
,' DOCT:\IE:\TS:
, 'I
"' II
) i I) :\OTI("[ OF EX P.\RT[ :\PPE.\L
.+ II 2) Sl'PPLE\IE'TAL OECL\RATIO:\ OF .JOSEPH ZER'IK
51 1
6 ;!. \ Parks has thret: types of si~n3turt:s in dlll.:uments.

.., B.9 27 (\.+ Samaan's Loan Application \-\ith Parks sigJ1ature .
8 lie 97 n.+ S:lI11aan'S Preqllalification Letter ,\ith Parks "iignature
<) I: D. 10. 1R 04 Fmail from Liho\\ to Parks questioning [he fax fraud.
10
E. 10 1904 Email response from Parks to l.ibow, avoiding the question.
F. 10/19/04 [mail from Libo\v to Parks, again asking about the fax fraud.
II
G. /0,27()4. Fax log submitted b~ Samaan in Court,sh(ming both documents ~cnt under her
12
(l\\ll ID: ~pellbolllld, and under ID: Anonymous. \\hich \\3S typil.:ally used for Parks. It IS
13
likely that the ID:P\IC llsed in the PrequaliJicatilHl letter (Dl)C C) is from the -;ame
]·l
i I llIaChlllC, but \\1.: do not have the fax log for that day.
I:; !I ... •
: H. I0 ~ Ocl Contingency RcmO\al: One
/6 il
I Fax received bv Libow from Samaan with IO:\non\Tllous
17 II -
'II. ICk~Oi()4 Contingency RernO\aJ: Two

18 I
! Fax It:-:ei\t:d by Liho\\ from Samaan \\ith 10 Spdlbollnd
19 II J. ICt25 '0'+ Contingency Rcmmal: fhrce
~o !\ Fax recein:d b~ Libow from Samaan with ro: .\nonymous, marked \\ith * in Fax log
2J I!. (lh..-ument
f) "
e,)
,
" I
!i I\.. THIS OOCT\lE:\T PROOL"CfO BY COl-:\TRY\\"IDE APPEARS \\TTH 10:
23;[ ".\:\O'Y\IOL"S". IT .\PPPK\RS I~ THE F.\.\. LOG .\:\0 SHO\\'S TH\T IT
~.+ i:
\\".\S F.\.'ED B\ S,\:\I.\.\' TO.\ fAX .\SSOCI.\TED \\ITH .JR LLOYD
" II :I ('lARKED "'Til **)." COl"RT IT \\'.\S CL\I\I£D ["HER PE:\\LTY OF
i
26 I
P[RJlR\ B\ ROTH PARKS \:\0 KESH.\ V:\RZI TH.\ T IT \\".\S fAXED 0'
..,~
_/
OCT 25. 200-4. 5:0JP'1 BY P.\RKS ro COl 'TR\\\ IU£.
.::?R
-,,
Exh p 81 EXHIBITS VOL V"-YRECEIVERSHIP
flL.!.--r,.·"n\'Tv·([)(\CI,.("(l\lfJl " T C V OlDT.: lDDlrr\Trny rn,',( \T~'
iI
Ii,
II
Ii 1\ F.\CT, THERE IS \0 'VA Y TO TELL 'VHE\ .\:'0 HO'V IT "-,\S
) II DELIVERED TO COl':\TR\\\Il)E~
~ I! OF 'OTE' PARh:S SIG'\ATl'RE DOES '\or .\PPE.\R HERE.
-l- !I L. Deposition of Samaan on July 10. 2006.
!
s In this deposition she contradicts many or her own previous statements:
() She had no c,perlcnce in rcaJ estate. never closed a deal or even assisted prior to Sept
7 20\l,l
~
She ne\ er 0\\ ned any "tock accounts in Sept 2004
9
Parks \\as not at all imohed in her loan application
Parks \\as her husband"s (JR Lloyd. fomlerly Timothy U\lyd \lorrm\) tirst cousin and
to
,I business assm:iate.
I~
ii
13 II
14 Ii
15 :1
16 II
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.28 I I
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EXHIBITS
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VOL V - RECEIVERSHIP,OI)l
r-on.;;.;,: r'r\\lor \T' 1'"TI~" Olole Ir' ' T I n , Tl--\ '" I t ' ITL
Datc \\'ed. I\l Oct :007 0..+.38 ~2 -()7\H)
1'0 "\Ioc Kesha\arzi" -\IKesha\arzil,'sheppardmullin CO III , "Shulkin
R,\h:rt" R\~h:rtShtilkin(Icamo\cs c~,m'
From joseph zernik jz 123-l5 ll\:anhlink nd '
<
Suhj('ct "otice of ex parte appearClflce. Thur'. Oct I I, :::n07

Cc pmalingagio(l( sheppardmullincom
October I (). :()07
.\tt Kesh:n arzi and An Shulkin,
I v, rite to prc)\ ide notice that at 8,0 a m on Thurs. Oct I I :007 I \\ ill
appear Fr Fal'le in Department O. or any other department \\ here a judge
\\CHIId he duly assigned as requirt.'d bv la\\ tor Samaan \ Zernik. ill the
West District ufthe Los Angeles County Superior Court. located at 1"72:
\Jam Street. Santa \tonica. California qO-lO I
ttl appeall()f a hearing on a motion to \ acate judgment, alternativelv - to

judgment. anti
:-.tClv
l\) 1ppl~ llx an nrder to lind Art Kcsha\arLi in contempt for his C~)l1dllC[ in
Samaan \' 7t'nuk

al obstruction nfjustice by undermining: discover\'.
h) aiding and abetting Judge Clmnor in subver~ion ofjustlCe In lh~ currupt
Judge Connor's Court.
c) dccei\ ing .\DR and Judge O'Brien on nllm~rous instances and
subversion of justice of the Reference.
d) deliberate sub\ ersion of due process in Judge Goodman's court \\ ith the
"lodging" of a prop{)sed order.
l') undermining 7ernik's access to legal counsel,
n nlultiple \ i~llation of Due Process of the Lm.
g) deliberatdy conducting malicious prosecution based on fraudulent
claims
Please let me 1\£10\\ ifvou plan to attend.
Inseph !.:rni/.;

Josep tk~·' ','1
Zer~.
Sl PPLE\IF:YL\l OECL\.RA Tlo,", OF OEFL'OA'" T JOSEPH ZER"'Ih..

~ Ii JlARA.\'SJ/E.\TA.\D 1/0,\'1nE E,\ VlRO.\JIE.\T IS COL RT
3 Ii L JOSEPH lER'.IK. hereb~ declare as rolkms

4 \1\' ), I ;1I111he ddl'ndanllCl';amaan \ LemJ!". LI-'s \ngde,> (',\llnt~ SUpeflL)r Court Case ,",,0
" SC I,X 741)t) .\s ~u(h. I hJ\ l' personal knc'\\ Iedge ,) l' the racls set forth herem \\ hlch I klhH\
(, to he trill' and currl~ct and. I r (;:11 kd :l'; ~ \\ I tness. I coul d :md \\ ()ul d c' Hllpetenth 1",,111\
7 \\dh resped thereto Thb Jeclaratlon is submitted in c,'nnecti,'n \\ith fIl\ ft.·ph fur
S Defendant's \'IOllOn to F'ptmge LI'i Pendens
(j II ~ Be\ond the aouse \)C my ci\ iI fights through delllal,)f Oue Process. thIS litigatIOn lIas
III \ en dJaJknglng JIld stressful

II i J At one h~\ d. such stress stemmed from the concern that possibh 1m Lounsds ,1I' I II ere
12 not represt:nlln~ 111\ pO~lfion pmperh For L'\:Jmple S,1Il1:lan\ ,-'lmduct Ifllhis C;IS,",.
\ .~' 1m 01\ ed blatant l'ruud. \\ 1)J(~h manIk~IL'J l\,df III IlIull! pIe appearances I counted IJ
14 Jilrerent maml·t.'Slations 111 th~ hearing of \IL)tion fl)r Summ~ Judgment. from
I"
Fraudulent Inducement to Bank Fraud. Wire Fraud. and Statutt' "f FrauJs The l'me ,If II
Ii, II a, ",c,sed from 111\ papers,
II,I
17 ii 4 But regarliless ho\\ much \\e \\ould elahorate ,m It. Judge (,)f\nor seemed not to notIce It
IX FInal". II hen she notIced it. It \\ as deemed "red hernng" \11 argument CIrcular logIC
I'> .1Ild dubioUS \ alldlt' I consider such argumenlln and uf itself a di\ l'rsl,ln tadic It took
2iJ lime before I realiled that it dId not matter \\hat the l':1c1s \\ere. \\hat the 1<1\\ 1\ as. It \\i!.'i
21 gOing to be ruled againsl me And It took some more time before Judge Connor real lied
that I figured It l)ut ,\fter that. it g,)t a different le\ eI of ahuse.
22 II 10
_.' I
."
.'1. \t Ih,lt 11.'\ eL the under" lilt' lTlessa~e I\a:,: I k"o... tlUlJyou /(11(111' flrtlt/IIIII corrupt, hut
2·~ Il'IlIIr,:et tIlftly with it.\nd indeed '~hl' (;Ul'

I 1
25 II IS. PrhSI hh the hesl e,alllple fur Ihat \\ as the tollo\\ II1g passage from the heaflng on
ii,
:1, PI:\! 11!!f'!-" \I(;l!dn Ii, I' Summaf\ JUth,:rT'el1t
27 :1/ \fR /f.'R\/A, J)() lot iI' 1:1 r IV HI:' liE IRJ)~)
:1 I/R /l:R.'/A' IIUS7' OF. ILL III 1.\ 11'11 HJ ISK 1m R
.::X
c.,l\ppkm~l1tal [k.:lar~111on of Jos.::ph Z~nHk: Harass.m.:nt and ho,tllc ~11\ ,rcnm.:nt .1\ :hc .:o,i1ibousc
- l

21 HONOR IF YOll C4N CLARIFY WHA T IS THE REASOlV THA T
23 A TTOR/VEY FOR COl'.VTR YWIDE IS PRESENT IN TilE COl'R TlW01U
") 24 RIGHT ,VOW?
25 THE COURT: SHE WA.VTS TO BE HERE. *
26 .'-fR. ZER/VIK: SO SHE HAS Fl'LL RIGHT TO PARTICIPATE
3 27 IN THESE PROCEEDINGS?
28 THE COeRT: YOU HAVE A PROBLEM? *
4 I MR. ZERNIK: YES. I HAVEA PROBLEM BECAl'SE I
2 BELIEVE SHE'S .VOTA PARTY.
5 J THECOl/RT: MR. ZERNIK, I HAVE TWO TENTATHES.
4 WOVLD YOl' LIKE TO ADDRESS ANY OBJECTION? WllleH ONE DO
6 5 YOU WANT TO START ON?
7 7. It was a strange and very distressing feeling - dealing with a Judge who had the authority
8 to determine critical issues regarding my life. and did not even made an attempt to appear
9 as conducting the courtroom in compliance with the law.
10 8. Another blatant example from the same hearing is the following:

/0 {THE COURTI T HAVE A SEPARATE ST4TEMENT THAT'S FILED
11 1/ JerLY 26 TH• IT'S SIGNED BY YOU. THE STGNATl'RES APPEAR
/2 TO BE THE SAME SIGNA TL'R ES.
12 /3 ,tlR ZERNIK: IT'S NOT MY SIGNA H'RES.
U THE COURT: I HAVE A STA TEMENT. YOlI ARE ,VOT GOING
13 /5 TO HAVE THIS CONTINVED. THE MATTER IS NOT CONTlNl'ED.
/6 WOULD YOU LIKE TO ADDRESS SOME OF THE OTHER OBJECTIONS?
14 17 JfR. ZERlVIK: BROl/GHT [it-jzJ VP IN THE EX PARTE I WAS WITH
IS OTHER COUNSEL AND I WAS DILlGENTL Y LOOKING FOR COliNSEL.
15 /9 I ALSO HAD A LETTER FROM COUNSEL, BUT
20 COUNSEL AGAIN REFUSED TO ACCEPT UNLESS
16 21 THERE WAS CONTINUANCE BECAUSE CONSCIENTlOi/SLY THEY COVLD
11 NOT APPEAR FOR SUMMARY JUDGMENT HEARING WITHIN SOCH A
I7 13 SHORT TIME FRAME'.
24 THE COl/RT: HOW MANY ATTORNEYS HA VE YOU HAm' SIX? *
I8 15 SEVEN? EIGHT'! NINE? *
16 JfR. ZERNIK: THE NUMBERS YOU JUST QUOTED I DON'T
19 27 THINK IT'S A,VYWHERE CLOSE TO REALITY. THE ATTORNEYS I
18 DID HAVE INCLUDED ATTORNEYS CUMMINGS AND SCHORR.
20
21 119. I was bringing a legitimate issue. a matter of fact. That my filings were adulterated. But
")") II she \\-as fixated with the issue of no continuance. She had the option of not continuing
23 the hearing. but eliminating thc filings from the record. But that too was not an option.
24 was to have papers that were not mine. no mattcr what. And the truth a f the facts in the
25 matter did not really matter much.
26 10. I was bringing a legitimate issuc. a matter of fact. That I could not retain any lcgal
27 counsel because she would not agree to any continuance of the Summary Judgment (but
28 she did agree to have it heard later than permitted by law at PlaintifTs requeslt). But she
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was responding with irrelevant lies meant to paint me as a person of bad faith - that J had
'1 as many as nine attorneys appear in court for me.
~
3 I I. In fact, Plaintiff by that time had employed three different law offices that [ can readily
4 recall. and if one was to count individual attorneys appearing on her behalf. the number
5 was higher. probably close to that quoted by the Judge.
6 12. But even more distressful that the constant attempt to paint me as a person of bad faith,
7 was the strange coordination between the Judge and Keshavarzi. He too was repeating
8 that lie to attorneys that [ tried to engage, with the added icing that most of them ended
9 up going to court to ask to be relieved. I then had to exonerate myself before such
10 potential counsels. which immediately put our relationship in a strange point, because it
I1 was obvious to me, that if they believe Keshavarzi more than they believe me. they are
12 not the right attorney for me. Att Schorr. Att Scott. Att Hoffman and others reported to
13 me that Keshavarzi told them this story.

14 13. Strangely enough, he repeated it also by email, I am not sure how to interpret that game.
15 14. Another example of blatant disregard of the truth by Judge Connor from the Hearing on
16 the Motion for Summary Judgment is the following long sequence regarding fraud, which
17 Judge Connor insists on failing to notice:
18 28 .../ ALREADY DISCUSSED TO SOME DEGREE THE ISSUE
I OF WIRE FRAUD WIHC YOU DIDN'T LET ME FINISH. BUT I
19 2 SAID THIS ONE SHOWED ALREADY THAT THIS IS THE ONE THAT
3 WAS FAXED /A TI 3:42.
20 -4 THRE'S SOME MORE OFFENDING CONDUCT THAT
5 JJ~S DONE IN THIS DOCUMENT. BEYOND IT, THIS DOCUMENr IS
21 6 STATED BYMR KESHAVARFIIN TODAY'S {FlNDINGJlHEARIN(H THAT IT W4S

7 SENT BY MR PARKS. I CONTEND THAT IT WAS NEVER SENT B:Y
22 8 JfR PARKS.
9 THERE'S A HUGE DIFFEREVCE IN THE PREMlliM
23 10 A:VD DIFFERENCE IN MATERIAL FACT BECAUSE OYf' POINTElJ OliT
II ALREADY THAT THIS IS A FULLY EXEC~TED DOCUM£"'iT, IS A KEY
24 /2 ISSVE IN THIS CASE AND /',U SA n\iG THAT ON THIS
/3 DOC~'MENTWE FILED STAnTE/SI OF FRAl"DS ON THE VERY
25 14 BEGINN/VING OF THE CASE. IT TOOK l/.VTlL THE VERY LAST
15 DOC~·.UENT 1:'11 THE VERY UST FlU:'VG OF MR KESHAV4RZ/ TO
26 /6 SLPPL Y THE COeNT WITH A COpy OF THIS DOCCME,VT. AiVD I
/7 CONTEND THAT I ALREADY SCBM/TTED TO MR KESHAVARZI THAT
27 /8 THIS IS A.V OFF£.VDI,VG DOCl'JfE:VT. AND :VOW IT PASSED 21 DA Y
/9 OF SAFE H4RBOR AND AS QlJOTE I SCBMITTED FOR F1UiVG
28 20 FOR A FULL H£4RING L'1\"DER ASSUPTION OF BAD F4ITH, NOT GOOOD
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21 FAITH LIKE {IT! {youl NORMALLY JfOl'LD DO HERE. THAT THIS DOCUJIElVT
22 W4S NEVER SENT BY JIR PARKS, W4S i'iEVERI- THE "'EVER--I
.., 23 THE DOCCMENT THAT HE SAID HE lllMEDIATELY SENT BECllSE HE
Received it Friday 3:42pm and sent it
3 24 SENT IT AT {3:42115:03pml ON MONDA Y, IT WAS FAXED MONDA Y. HOW
25 COULD IT BE lJfMED1A TEL Y?FROM FRIDA Y TO JfO/'iDA Y IS ,VOT
26 IMMEDIATELY,-tTALL.
4
27 THE COL'RT: IT'S ,VEXT BeSINESS DA Y, *
5 28 JIR ZERNIK. IT'S IMMEDI,-tTELY THE FOLLOWING BUSI,VE5S *
I DATE. *
1 MR ZER,VlK: I RECEIVED ITlandllJIMEDIATEL Y{ A:VO} TUNRED
6 3 IT A ROVND AND FAXED IT. DEFINITE/... Y NOT THREE OR FOl'R
7 4 DAY/sl LATER. BEYOND THAT, THIS ISA F-tRCDl'LET'v
8 15. I clearly remember how stunned I was when Judge Connor was smiling at me and stating
9 "It's next business day, Mr Zernik. It's immediately the following busine,ss date".(lines
to marked with an asterisk near the right margin).
11 16. That contract was the central document in this case. She already made one unusual
12 decision in this regard. denying the demurrer on Statute of Frauds and allowing the case
13 to go on without having Plaintiff amend her claim and present the contract. And then the
14 contract is presented as surprise in the last minute. And this is a document that I had
15 already declared to Keshavarzi as offending document. They claimed repeatedly that it
16 was faxed by Parks to Countrywide. but the evidence shows that it was not faxed by
17 Parks. and it was not faxed to Countrywide either
18 17. And beyond that. Mr Parks declared that he received it on Friday. Oct 22. 2004. 3:42pm
19 and "immediately" faxed it to Countrywide, and that Countrywide rejected it. ... And then
20 later on. by Monday, October 25. 2004. he managed finally after all his eff0l1s get
21 another document from escrow. And that later document was indeed signed. And then he
..,..,
later faxed that later document to Countrywide. and then later the finally got the loan
23 approved. and then the appraisal was done! Bingo! All done!
24 18. But it just did not fit the facts. The document has a fax header imprint on it that it was
25 received on Friday. October 22.2004. 3:42pm, from Mara Escrow. and that the very
26 same document was faxed to Countrywide on Monday. October 25. 2004. at 5:03pm.
27
19.5o in essence. the facts show that there were no two separate fax transmissions
28 of the contract document from escrow to Samaan (claiming to be Parks as
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1 part of wire fraud), only one. And the history of that transmission was as
2 follows:
3 II a. Came from escrow to Samaan (claiming to be Parks as part of wire
4 II fraud) at 3:42pm on Friday, October 22,2004,
5 II b. Went from Samaan to her husband, JR (claiming to be
6 II Countrywide) on Monday, October 25, 2004, 5:03pm.
7 20. Therefore, there is no proof here that the document arrived at Countrywide at
8 5:03pm or any other time on that day or any other day.

9 1121. And therefore, there is no relationship between this fax transaction and
10 II Samaan's loan approval or appraisal approval.
II 1122. This claim was central to Plaintiffs fraudulent claim - that Parks tinally got one l:ontract
12 lion Friday, 3:42pm. faxed it. and it was rejected by Countrywide. Then Zemik went to
13 II eSl:row after that. and added the initials. And then Parks got it sometime later. and by
14 II Monday he faxed it to Countrywide. and then it was accepted. and then the appraisal
15 II review was immediately done. and the loan was approved. and Samaan removed the
16" contingency on Monday afternoon. Bingo. all done.
17 23. Some litigants may feel that their case did not get the treatment it deserved in court
18 because the judge was somewhat slow, or not knowledgeable. or inattentive. I never had
19 any such consideration. I hold that Judge Connor is sharp as a razor. I hold that she is
20 very knowledgeable in the law, and otherwise. I hold that she was very attentive.
21 24. At that particular point I was talking without interruption for a few minutes. on a very dry
22 and technical issue of the wire fraud. But she was very focused. and when it came to the
23 point where the evidence diametrically contradicted Plaintiffs version of events. she
24 provided in a blink the explanation: "Immediately" can still describe receiving a fax on
25 Friday 3:42pm and sending it on Monday. 5:03pm. Immediately can be used in the sense
26 of "Immediate next business day".
27 25. It was obvious to me all along, that if a person reviewed the case, they \vere extremely
28 likely not only to doubt. but to conclude that that had I argued that "immediately" could
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(l •• _ _ .t
mean immediate next business day, it would be laughable argument at best more likely
')
seen as pathetic.
3 26. Beyond that. the speed with which Judge Connor responded to this point indicated that
4 she noticed this major contradiction in advance. and prepared a response in advance. But
5 the response never even meant to be serious. rt was a joke. She was sitting there. smiling
6 at me. and telling me it was "'immediately next business day."
7 27. The reason it felt as harassment was that it was clear that Judge Connor was gifted by
8 brightness, was well-educated, was granted a position of authority and privilege, and then
9 using it all of the above, combined. for ill ends. with a joy.
10 28. That is for me corrupt. by definition!
11 29. Further stress. both physical and psychological was mounted when I was left with no
12 alternative but remain in pro per. Sleep deficit and tiredness became almost constant.
13 30. I substantially gained weight. to the point that I get negative comments on a daily basis.
14 about looking tired. stressed out, and in need of rest.
15 31. [n addition. there is the harassment in the courthouse it: since the first or second time I
16 showed up in court. I have sheriffs following me everywhere. I thought that would end
17 now that 1 am out of Department I. but it was still there yesterday. Tue, October 10. 2007.
18 32.1 believe that the very first time I realized it. was from communication with an attorney
19 that I was trying to engage for counsel. He informed me that Keshavarzi informed him
20 that I was considered by Judge Connor dangerous and potentially violent, and that she
:n had alerted the Sheriffs and asked them to watch me when I was in her courtroom. I then
')')
startcd noticing it. and realized that it was indeed the case.
23 33. That comment by Keshavarzi raised two concerns: It was again once ofthosle instances of
24 extrasensory communication between Keshavarzi and Judges: Connor. Goodman. and
25 O'Brien. He knew what they think and say. but based some pronouncements that were
26 never mani fest to me in court or in any other writings equally available to both parties.
27
28
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34. A person reviewing the situation as a whole is reasonably going to conclude, or at least
., entertain the doubt that Keshavarzi was engaging in routine ex parte communications
3 with these three judges.
4 35. Even today, anywhere I go in the court. there is surely going to be a sheriff walking
5 hehind me. When [ entered department 0 yesterday, a sheri ff entered atter me and sat
6 and waited until I finished my business. Soon after [ left the courtroom, he left the
7 courtroom as well.
8 36. And the same treatment followed me to the West Side court, for the first few days.
9 37. But on om: of the first few days in the West Side, I was followed by a sheriff with a
10 German Sheppard. [t struck me as escalation - an armed sheriff was not sufficient to
11 subdue my violent nature anymore, and there was a need for canine help!
12 38. In Santa Monica. that situation was used by staff to harass me. For example, if! asked
13 for printouts of minute orders in the clerk's room, and they did not want to provide it,
14 then Darleen may start screaming at me, and another staff would call the sht:ritTs, with
15 the appearance that I disturbed the peace.
16 39. On this hostile background, one has to evaluate the incident in the Courtroom of Dept A
17 Supervising Judge, on August 31, 2007. I passed in Department A for the first time ever
18 on the previous day, August 30, 2007. I asked Ruth, the Judicial Assistant, what the
19 procedure was for submitting complaints. She dismissed the question as trivial and said
20 it just had to be in writing.
21 40. The next day, August 31, 2007, I brought a written complaint. The immediate response
'1'1
was that Ruth raised her voice and started yelling that I had to immediately cover it with
23 a brown paper envelope. [said I had no clue. she never told me that the previous day.
24 She was still yelling at me - that had to immediately go to the clerk's oftice and get a
25 brown paper envelope there, and only then return to her courtroom. I was already
26 apprehensive, looking around to see how the sheriffs were responding. in the room, and
27 what their response was. It was clearly a situation that had the potential to become
~8 explosive.
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41. I got the brown paper envelope and finally submitted the complaint. A bit later the
" supervising judge came in and Ruth presented to him the envelope. He opl.:ned it and
3 started reading, and he was visibly upset. The main issue was access to Court File.
4 42. He angrily said to me he will show me that it was easily accessible. He called a few
5 places, but seemed to have no luck. After that he said to me: "now I will show you hand
6 on management" still in an angry tone. And he left the Courtroom. apparently searching
7 for the file. Eventually, he came back, with only 3 out of 6 volumes. IIe was visibly even
8 angrier than before when he came back.
9 43. He tossed the volumes on the table in the well in front of bench. and told me to mark the
10 pages I wanted to copy, then the Clerk's room will arrange the copying. I told him that I
I1 wanted to copy it all. He said tine. Then said that my understanding is that the copies
12 will not be done on the spot. and I wanted to be able to compare the original and the
13 copies at the time 1 pick up the copies.
14 44. He got even more upset with me. He said something to the effect that I was: implying that
15 they were going to cheat. 1said that it was standard procedure, if later I had to declare
16 that this was a full and complete copy. He then agreed. but was visibly very upset. Then
17 before he was going to leave the room, he tossed at me my complaint and said that now.
18 that he got me the court file, I could take my complaint back.
19 45. I refused to take it. I said that it was the copy that I tiled with the court. And he said
20 something like: are you trying to tell me that there is more there than just gdting you to
21 copy the tile. And I said: yes, there are a number of issues. He then got more and more
"" upset, and said I had to take it back. and I repeated my position.
23 46. Immediately, the two armed guards in the courtroom approached me. and trit:d to force
24 me to take the complaint back. I was fearful. I did not know these two particular
25 guards. I also did not even notice them as individuals. it was just persons trying to force
26 me to do something against my will. I was not '-going to Yield. But I immediately
....... ~ . raised
27 my hand to my head. I was very fearful that somehow they \\ ill fake an incidence of
28
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violence on my part and shoot me. I slowly retreated from the courtroom, 'with my hands
')
all the time still up to my head.
3 47. I was \valking to the Clerk's Office to ask them to copy the tile. [was still with my
4 hands up on my head. And the two sheriffs were still around me all the time, trying to
5 plant the complaint on my body, but I was no longer afraid, since there were people
6 around us.
7 48. At the derk's office (Room 102) they len that brown envelope on the counter, next to
8 me, and left the room. I finished my business, and then left that room as wdl. I left the
9 brown envelope behind me. Within seconds, Darlene was running behind me. asking me
10 to take the envelope. I told her that it was not mine. that it belonged to Dept A.
11 49. She then went to Dept A and I assume she gave them the envelope.
12 50. I was shaken by that event. It brought it all into a focus. Everything that happened to me
13 in court in this litigation: It combined extreme dishonesty of a person in high office and a
14 position of authority. combined with willingness to break the law. even to use physical
15 force to that effect in a very crude way. Obviously it implied immunity and confidence
16 that they are above the law. Since they were part of the system. they must know. It felt
17 like something that could not happen to me in the US, but it did happen.
18 51. I was initially wavering whether to include the incident with the Supervising Judge in any
19 writing. Some smart people would have advised me that it may sound "extremist" and
20 objectionable. However. I see that type of advice in line with the position of some pricey
21 real estate attorneys that I should have never mentioned any type of fraud by Samaan in
')')
court. because it may sound objectionable to the judge. or the traditional opinion that rape
23 victim should keep it secret. because one way or another. these women brought it on
24 themselves...
25 52. All of that \\-as definitely considered when I wrok the ex parte application to restore and
26 safeguard due process rights. I hold Judge Segal in high regard. but I cannot expect a
27 relatively young judge to accept the role of an outcast in the courthouse. where he may be
28 appointed for life.
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Exh p 92 EXHIBITS VOL V - rRECEIVERSHIP
---------~.----~-------------------- -- -~~--------~-------------~---~---------
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53. For that rt?ason I phrased the first proposed order, regarding assignment due by law. as a
2 II sit and wait position. But I still hold that the minimum standard of recusal in the absence
3" of valid assignment is a must.

4 "54. During the very short hearing on October 10. 2007, Judge Segal started reading, and
5 II immediately asked me if what I expected that he would make demands or orders
6 II addressed at his supervisor. Judge Rosenberg. I answered that I never expected anything
7 II like that. And that the proposed order is accordingly phrased.

8 1155. Judge Segal then asked why [ did not submit this as a complaint to Supervising Judge
9 II Gerald Rosenberg. I said that I had indeed submitted a complaint in that regard to the
10 II Supervising Judge. but was instructed to submit it in Dept O. I also added that I had been
II II physically harassed in Dept A.

12 1156. [ write these statements in part so inform other parties who were not present in this
13 II hearing. which did not last more than a few minutes. I also ordered the transcript. and
14 II will share it with other parties if they so wish.

15 1157. Hopefully this approach could be reciprocal. .. for example, there is the ex parte
16 II appearance of Kcshavarzi before Judge Connor. on August 14. and August :~ 1, 2007,
17 II Both are still a mystery to me. If a person had reviewed the case as a whole, he would
18 II reasonably conclude that the only rationale explanation for these two ex parte
19 II appearances was a sham. acted out in collaboration between Keshavarzi and Connor. in
20 II an attempt to mislead me. Any other account of what transpired there and what was the
21 II logic of it, would be most welcome. but Keshavarzi did not respond to email inquiry in
-V) II that regard.
23 1158. [f a person reviewed the case as a whole. that person may also reasonably conclude that
24 II the Peremptory Challenge of Keshavarzi against Judge Goodman was also a sham. acted
25 out in order to mislead.
26 59. If a person reviewed the case as a whole, and then was sitting in on the few minutes ex
27 parte on Tuesday. that person may reasonably conclude that Judge Segars questions
28
-10-
---
Exh p 93 EXHIBITS VOL .... V - rr
RECEIVERSHIP
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expressed an extreme unease with the situation and with the need to adjudicate this case,
'")
since it may put him in an uncomfortable position with his colleagues.
3 60. I have the highest regard for Judge Segal, but I do not believe I can expect him to enter
4 such a conflict on my behalf. It appears that the reasonable solution under the
5 circumstances may be to have the case heard in a different District of the Court or
6 outside the County of Los Angeles. I believe that Supenising Judge Rosenberg would be
7 fully supportive of such a move, and therefore would not allow Judge Segall to be duly
8 assigned.
9 I make this declaration under penalty of perjury according to the laws of the state of
10 California. Signed here in Beverly Hills October 10. 2007.

.,
.I
11 --~._--
12 --.--._--------- -~ --- --- --- -_.~-+~--~----------

_.-/
13 JOSEPH ZERNIK
14 DEFENDANT & CROSS COMPLAINANT
15 in pro per
16
17
18
19
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23
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VICTOR PARK -
MULTIPLE SIGNATURES UJ
4J
TRUE FALSE FALSE E

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SOURCE: SOURCE: SOURCE:
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LA SUPERIOR COURT COUNTRYWIDE NIVJE SAMAAN -M
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~ppiclbiL Co-llo<rowor Inlcnnllion muS1 aIIo be plIl'ftIed (..,d lie beat c!ledIIoIl) _ 0 U10 lna>rno .. _ _ 01 • _ oU1o' than UliI "1lomMOl"
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quoiliealllln. but his .. her r.a!lU!S must be sldel1!d _ l i e _ _ In. aII1IIIUIIIly ~ SlIIiII. tI10 IlIICUIIIT prllpIIr\y I. _ n. I:o,nrnlll'll,
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l\eIIOnltnl CIlOiiiiU __ WIDfliIUIie ~ I'iIPliilI+

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An UlIlIIOITled Woman
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V. IlIONTJ1lY INCOMe AND CO",SIlEO HOUSIHG EXPEHSL: INFORMA11ON
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Sef 07
Ser 04
07 04 05:12p
05,12p PMC
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SO~ 271 7El15 p.
Pacific Mortgage Consultants ZERNIK V CONNOR ET AL
Fax Cover EXHIBITS VOL V - RECEIVERSHIP Exh p 102
Victor Parks
(8'B8)
('8'B8) 575-5693 OirE!.et
S75-5693 Oire.tt
(509) 271-7845 F",x
F<,x
o iJrge"l~
Urgerl~ r Please RCVl8\rl U Apprcw
Please Approve
P1~ase o ?1frase Rl.,?ly
To:
'Ter. Michael Ubow
Libow P,.,.,
P,.,. Nunohar. {310) 278-4934
Nurnhar. (310l
Nurnbef" {lIf Page.,
"~or 2
9"'1;. 2 ....
From: Victor
Vietor Parll;s
Pa~s {1,,,;1.,.jiro:J t:ouo,fj
1,,,<:;1...dirt:J 0:>08',1')
Oat.., Sept€"l'nbl'lr 7,2004
COl'llm&nts~
CGl1Yl/'l1lfnts~ Nivie Prequalflcation Leta
Nivje Samaan Prequalmcation
Hello Mr. Libow:
Ms. Sam<lan
Samaan has been PrequaJifled
Prequalifled for an 80110/10 JUmbo
Jumbo 5/1 InterestOniy mortga.ge at 4 375%
Interest Only 1~ mortgage
Ml
and a 4,5% Fico/, good
4.5% Interest Orly 2 no mortgage. She has excellent credit {748 Fico), income--lo-detlt
gOOd inc:ome-1o-debt
ratios and
rntios ancJ aver il"'l lierifled
$200,000 ir.
over $200.000 "erif~ liquefiable assets.
Respectful~.
Respectful~,
Vietor Parks
Victor
U 38\1<::
~:II 38'12 ;~dO?;9 LO' 0 -Nvr t8St LiZ
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IL~ ');r ;l;J3>U,"v8 113N,C1C~ : ..12 .L'GS
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,,-~
Exhibit 1
Exhibit 2 Exhibit 3 Exhibit 4
, . ,--
Se~ 07 0'" 05:1Zp
0 ... 05:12p Pf'fC_ 509 271 71345 p,2
p.2
EXHIBITS VOL V - RECEIVERSHIP P~cif:c MOrtag(l Cono;uJ:t.l':'~:'~ Exh p 103
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Exhibit 1
Exhibit 2 Exhibit 3 Exhibit 4 Exhibit 5 Exhibit 6fj
From: 'v') i:nw@ao:om
To: Vrtor@pmlcans.com
Date: MOr1, 18 Oct 2004 21:01:40 EDT
Subject: Re: Samail" I,.oan Apprq~\tl
V CTOR.
IT WAS ODD THIS MORNING AS I FAXED TO YOU THE NOTICE: TO PERFORM AND THE. NJMRER
TRAt>.SFERRELl TO NIVIE'S SECONDARY FAX LINE SHE HAD GIVF-N ME. ARE YOU IN T.~E SA'v1E
OFFICE AT GILLERAN GR\FFINn PLEASE EXPLAJN...WE DO NEED HER TO RE\AOVE HER LOM
CONTINGENCY AT THIS TIME AND r HOPE THAT YOU I-'AVE SATlSF:ED HER ENOUGH TO ENA6LE-lER
TO DO SO.. THE OWNER IS 'N NEED OF SECJRING ANOTHER PROPERTY AND CAN NOT DO SO L'' '- TIL
THE CO'llTINGE"lCY IS REMOVED. WE ARE ALREADY DELAYED ON THE REMOVAL BY SEVEN DAYS
r,,1'CI1AEL L,BCW
50323
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DOCUMENT D: 10/18/04 EMAIL FROM LIBOW TO PARKS QUESTIONING THE FAX FRAUD

Pag~ t of 1
SUbject : Re: Samaan Loan Approval

Date Tue, 19 Oct 2004 09:1100 -0700
Linked to: Michael J Libow
from VICtor Parks <Victor@PMloans com>
To MIchael J. Llbow <mJltbow@aol com>
Good Morning Michael. Regarding the loan contingency, you'll need to speak to Ms. Samaan about it. I've
informed her that although the loan is approved, it's not over until the appraisal review is back. As you know, if
for some reason the appraisal is cut, we don't have a deal. That being said, Countrywide is very good with
appraisals and it's been a long-time since I've had an appraisal cut. I've reviewed the camps and the value is well
supported, but there's a~ways the possibility.
I should have the review by Friday which still gives everyone ten days until the close of escrow. Plea5ie te€1 free
to call me should you have any further questions.
Respectfully,
Victor Parks
Sr. loan Officer
Pacific Mortgage Consultants
Victor@PMLoans.com
DOCUMENT E: PARKS' RESPONSE, AVOIDING THE QUESTION.
310.275.5353 Office
310.Q96.3256 Fax

Page I of I
Subfect : Re Samaan Loan Approval

Date Tue, 19 Oct 2004 094400 -0700
Linked to: Michael J Libow
From Mihbow@aol com
To <Victor@pmloans.com">
Cc <NSamaan 1@aotcom>
VICTOR.
THE PROBLEM IS THAT THE SELLER VV1LL LIKELY EXERCISE HIS RIGHT TO CANCEL THE CONTRACT
AT THIS POINT I DON'T WANT THIS TO HAPPEN. THE MAJORITY OF MY DEALS HAVE LOAN
CONTINGENCIES REMOVED SUBJECT TO CERTAIN CONDITIONS LETS FACE IT THE LENDER
COULD GO BANKRUPT PRIOR TO ESCROW CLOSE THERE HAS TO BE SOME RISK ASSUMED BY THE
BUYER IN THIS CASE. SHE HAS AN EXTREMELY LOW DEPOSIT IN ESCROW (LESS THAN 2f>ERCENT)
AND I VYOULD FIND IT HARD TO BELIEVE THAT IMTH YOUR TRACK RECORD AND ASSURANCES THA T
SHE \MJULD NOT BE COMFORTABLE .BY THE WAY. YOU NEVER RESPONDED TO MY QUERY
ABOUT YOUR FAX NUMBER FORWARDING TO N1VIE'S.
MICHAEL L1BOW
COLDWELL BANKER
PS - AS I AM NOT AT THE COMPUTER MUCH I VVOULD APPRECIATE A CALL FROM YOU ASAP AT 310-
991-2689 MY CELL
DOCUMENT F: 10/19/04 EMAIL FROM LIBOW TO PARKS AGAIN ASKING ABOUT FAX FRAtID,
S0031
aboutblank 10/27/2004

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Oct 19 7~26p1n m &1!t 62:J71iil 1r.34 t OK
(kt 19 8:~ Fax Sent B'Z172II 0';" r ~
Oct 20 10: Fax Sent SS87842 1:30 4 OK
Oct 20 10:12am Fax Sent 2784934 1:~ 4 OX
* Oct 20 10: 19am Fax Sent 2784934 1:22 4 OK
Oct 20 1~23am PIx Seat 8587842 1:20 4 OK
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<kt 21 Ii:l Fax Sent 1818~61l33 0:37 1 OK
Oct 21 li:3q)lII Fa Sent 823721' 0:43 1 OK
~ 1'1 ~Hpm",,-sa. .181HS '6:45 i. -Ermr"-1
Oct 21 SllSpm Fa: Sent 47821~ 1:44 2 Error 350
ClicL2L "i139pe E. s.. . . BOn121&-- 2;54- 7- OL
Oct 22 9~.54am Fax Scot 8237218 0:00 0 No answer
Oct 22 11:2(km Fa Salt 19258927966 12:39 14 OK
Oct 22 11;j7am Fu SCn! 141'5321301 0:50 2 OK
Oct 22 1ll~ ~ Settt i2i~ ~~ -4 £ftoior~
Oct 22 1 :.31pm F"ax Sen( 12132256288 r:33' .f <X
Oct 2S 1~:43pDl Pax Sent 181S:W11897 1: 10 2 OK
Oa ~ 4~1= Fax Sent 141S2.SCJ08jj 4:39 15 OK
Oct ~ 4ti Fax Seal I4U2590166 0:.37 0 Error 386
(kt 2.5 4:l59pDl Fax Sent 14152S90866 0:'6 1 Error 441
**
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Oct 27 9:52am Fax Sent 8237218 I: 10 2 OK
OOCl~ENT G: FAX LOG SUBMITTED BY SAMAAN IN COL~T/LTSTTNG BOTH DOCL~ENTS

THAT WERE FAXED UNDER 10: SPELLBOUNG, AND SUCH THAT WERE FAXED L~DER
TO: ANONYMOUS.
ACJENT DETAIL Pa~e I of 2
).j< T .~
I\JIVie ~ama8n
Gilleran Griffin Realtors

1575 Westwood Blvd., Suite 300, Westwood, CA 90024
31 0-849<3816 nsamaan~sbcglobal.net
STATUS: Sold ADDRESS: 261 S CAMDEN DR t SEVERlY HIllS tCA 90212 SP: $2,320,000
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Add'l Photos Larger Hap Plat Hap Aer al t'lap
RESIDENTIAL SINGLE FAMILY AREA: (1) Beverly Hills MlS#: 06-127679 MAP: 632/F2 BR: 3
STYLE: Spanish SUB: PUD: YB: 1930 BA: 2.50
APN: 4328-025-016 ZONE: BHR1YY HOD: $0.00 STO: 1 APX SF: 2,456/AS
ADP: VU: No Pl: No APX lDM: 50Xl27/AS APX lSZ: 6,400/AS
APX ACREAGE: GH: Det'd FP: 2 PKGT: 2
HORSE PROP: lSE: lOP: FUR: No PKGC:
ElEM: BEVERLY VISTA JRHS: SRHS: BHHS
DIRECTIONS: SOUTH OF WILSHIRE-NORTH OF OLYMPIC-WEST OF BEVERLY DRIVE

REMARKS: IMHACULATE/RESTORED/AUTHENTIC OLD WORLD 1-STY COURTYD SPAN W/3BR+2.5BA+STUDY/DEN+DETACHED
OFFICE(OFC WiD PERMIT). GOURMET KIT W/ VIKING APPL & CARRERA MARBLE OPENING TO PRIVATE GATED FRONT COURTYD.
LOVELY MASTER SUITE W/FRENCH DOORS OPENING TO YARD W/SPA & BBQ. GRAND 2-STORY ENTRY W/ LEADED GLASS
WINDOWS & STENCILED CEIUNG. LRG DINING & UVING RMS W/BEAMED CEIUNGS & ORIGINAL ART DECO DETAILS BEYOND
DESCRIPTION. COZY STUDY/DEN ALSO W/FAB DETAILS & 2ND FIREPLACE. A/C, HARDWD FLRS, SEC SYS. rTEpo;:G-~rJ]
ROOMS: Basement, Breakfast Area, Center Hall, Den, Dining, Living,Office, Pa ntry, Patio Open,Powder,Service Entrance
EQUIP: Barbeque, Built- Ins,Cable,Celllng Fan, Dishwasher, Garbage Disposal, Hood Fan, Microwave,Range/Oven, Refrigerator
AIR: Central HEAT: Central
FLOOR: Carpet,Hardwood,Marble,Tile lAUNDRY: Inside,Room
FIREPL: Den,Gas,Livlng Room ROOF: Composltlon,Tile
POOL: TENNIS: None
PARK: Side By Side,Uncovered SPA: Bath Tub,Hot Tub,Prlvate
VIEW TYPE: None WATERFRONT: None
SEC: Gated,Owned FIN: Cash,Cash To New Loan
SEWER: In Street POSS: Close Of Escrow
DISC: As Is, Listing Broker Advantage SZONE: Property Report
OCC/SHOW: 24-hr Notice,Call LA l.Listing Agent Accompanies
lP: $2,295,000 DOM: 155 SP: $2,320,000 SSP: OlP: $2,295,000

LD: 09/06/2006 CD: 02/08/2007 SD: 03/26/2007 WD:
LAl: Steven Geller lAl#: 310-777-6237 lAl CElL: lAl OTHER:

LA2: lA2#: LA2 CELL: lA2 OTHER:
LAl EMAIL: lA2 EMAIL:
L01: Coldwell Banker-BH lOl#: 310-777-6200 lAl FAX#: 310-278-7192
l02: l02#: lA2 FAX#:
SAl: Drew Fenton SA1#: 310-248-6409 SAl CElL: 310-560-3777 SAl OTHER:
SA2: SA2#: SA2 CELL: SA2 OTHER:
SAl EMAIL: drew.::;pruestates.com SA2 EMAIL:
SOl: Prudential California Realty SOl#: 310-777-7800 SAl FAX#: 310-858-1295
S02: S02#: SA2 FAX#:
CSO: 2.5% IT: ER lBA: Yes BAC: Yes lS: No EO: No PROBATE:
Broker/Age'lt riDes 'rot guar"antee the dC(JrdC,t of the squarp footage, !ot :.lze cr otner mformat',on concerning the c:Jndl~'ons or Features of ~~e pro~erty ~rO""lded by the 'CElier or cbtalf"led
fr:JI'1 Pub\l,c ;:t.pcords or o~f-Ier sourcps. BU'Ier is dt1Vlsed to ,ndecerdently venFy the accuracy of all mforma(ion through oersonal Inspection and with aporopnate oroFeSSIOnals. CJpvrlght 'C
200/ by CCrTHJ:ned L.A./\'jestSJde ~~LS, Inc inform,atlon deemed .ellat,le but not ojuarallteed.
http:pro.thcmls,com/ AII_Scarchcs_Prcvic,\_Fi lesione_agent_detaiI_previcw.c fm'.)functio... 8/11/2007

AGENT DETAIL Page 2 of2
http:! pro. themb.com All_Searches_Preview_Files/one_agent_detail_prevlew.cfm'.'functio... 8; 11 /2007

ACiENT DETAIL Page I of I
Nivie Samaan
310·849-3816 nsamaan@sbcglobai.net
STATUS: looking For Backup ADDRESS: 242 S MCCARTY DR, BEVERLY HIllS ,CA 90212 lP: $3,249,000
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RESIDENTIAL SINGLE FAMILY AREA: (1) Beverly Hills MlS#: 07-205753 MAP: 632/F2 BR: 4
STYLE: Traditional SUB: PUD: No YB: 1935 BA: 4.50
APN: 4328·1)16-022 ZONE: HOD: $0.00 STO: 2 APX SF: 3,514/AS
ADP: VU: Yes Pl: Yes APX lDM: 60x128!AS APX lSZ: 7,680!AS
APX ACREAGE: GH: N/A FP: PKGT:
HORSE PROP: No lSE: No lOP: No FUR: No PKGC:2
ElEM: EI Rodeo JRHS: EI Rodeo SRHS: BHHS
DIRECTIONS: S. of Wilshire
REMARKS: 4BD;4.5 BA ELEGANT 2 STORY, REMODELED TRAD HOME ON PRIME ST IN SOUTHWEST BH.CURB APPEAL
GALORE.CENTER HALL PLAN W! SPIRAL STAIRCASE,GRAND LIV RM W! MOLDINGS AND FRPC,FORMAL DIN RM,COZY PANELLED
DEN W/ FP,GENEROUS REMODELED KIT W! BKFST AREA,LRG BRIGHT FAM RM W/ FR DRS LEADS TO THE PRIVATE & SERENE BCKY
Wi PEROGLA COVERED PATIO, INVmNG POOL & GRASSY YARD, LRG f\olSTR SUITE AND 2 ADD'L BEDROOM SUITES UPSTAIRS,
MAIDS RM & BA DOWN,HDWD FLOORS THROUGHOUT FIRST OPEN HSE 7/29 2-5 AND 7/31 11-2 & 5-7 [!il;~ViOG,-;:;Om
ROOMS: Breakfast Area,Breakfast Bar,Cabana,Center Hal',Den,Dining,FamiIY,Living,Patio Open,Powder,Service Entrance

EQUIP: Ba rbeque. BUllt- Ins, Dlshwasher,Freezer, Garbage Disposal, Hood Fan, Range/Oven, Refrigerator
AIR: Central,Multi/Zone HEAT: Central
FLOOR: Carpet,Hardwood,Tile lAUNDRY: Inside
FIREPl: Den,Llvlng Room ROOF: Shingle
POOL: Heated, Private TEN NIS:
PARK: Carport,Direct Entrance,Tandem SPA: Private
VIEW TYPE: other WATERFRONT: None
SEC: Owned FIN: Cash To New Loan
DISC: As Is SZONE: Property Report
OCC/SHOW: Call LA 2,Listing Agent Accompanies
lP: $3,249,000 OOM: 7 SP: SSP: OlP: $3,249,000

lO: 07 ;26/ 2007 CD: 08;02/2007 SO: WO:
LA1: Nancy Ross lA1#: 310-552-9398 lA1 CEll: 310-968-4180 lA10THER:

LA2: Laura Barton LA2#: 310-248-6472 lA2 CEll: 310-600-2746 lA2 OTHER:
LA1 EMAIL: nro5s50ld :aoleam lA2 EMAIL: laura.barton 'g'yahoocom
l01: Prudential California Realty l01#: 310-777-7800 lA1 FAX#: 310-858·1295
l02: Prudential California Realty l02#: 310-777-7800 LA2 FAX#: 310-858-1295
CSO: 2.5% IT: ER lBA: No BAC: Yes lS: No EO: No PROBATE: No
BrokerjP-,gent does not gcarantee the accuracy of the square footage, lot SIze or other :nformatlon concerning the conditions or features of th~ oroperty prav'ded by tre seller Jr Jbtalned
from PubliC Records or otr.er sources- Buyer 5 adVised ~o If\dependently verify the acc:.;racy of ail Information through personal inspection andl,\llt'r'I apprODnate prafesslonai~ C,OP\iTlght c
200 7 by Combined L.A.. ;"NestSide MLS. :nc. Information deemed reliable but '"\ot guaranteed
http://pro. themls.com/ AII~Searches_Pre\iew_Files/one_agent_detail_pre .... lew.cfm'.>functlO... 8, 11::2007

AGE:\T DETAlr_ Page 1 of 2
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21 O-f: 49-3816 nsarnaan:@sbcgiobalnet
STATUS: Sold ADDRESS: 249 S CAMDEN DR LBEVERLY HIllS ,CA 90212 SP: $ 2,834,0 28
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RESIDENTIAL SINGLE FAMILY AREA: (1) Beverly Hills MLS#: 07-167783 MAP: 632, F2 BR: 3
STYLE: Spanish SUB: PUD: VB: 1928 BA: 2.50
APN: 43.'8-0:'5-013 ZONE: BHR1YY HOD: $0.00 STO: 2 APX SF: 2,932/0T
ADP: VU: No PL: Yes APX LDM: 55x128/AS APX LSZ: 7,040/VN
APX ACREAGE: GH: N/A FP: 1 PKGT: 5
HORSE PROP: LSE: LOP: FUR: No PKGC:3
ElEM: CK W/CITY JRHS: SRHS: BEVERLY HILLS
DIRECTIONS: S. OF WILSHIRE/ W. OF BEVERLY DR

REMARKS: STUNNING SPACIOUS TASTEFULLY REDONE 2STY SPANISH. LG SUNLIT RMS W/HI CLNGS/GORGEOUS DRK WD
FLRS/FRENCH DRS. FANTASTIC NEW KITCHEN & BATHS W/TOP APPLIANCES & FIXTURES. 3BD UPSTAIRS INCLUDING GREAT
fvlASTER W/DUAL WALK-INS/SUNDECK,'BALCONY. DRAMATIC 2STY TURETTED ENTRY W/SWEEPING STAIRCASE. HUGE BEAUT FAM
RM W/BLT-INS. KITCHEN OPENS TO REAR YARD W/PATIO SPACE & POOL. REMARKABLE LIVING & DINING RMS OVERLOOK
PROFESSIONALLY LANDSCAPED GROUNDS. INTENSE CURB APPEAL ENHANCED BY GATED COURTYARD ENTRY. ~""v3te RE~
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ROOMS: Breakfast Area,Dlning,FamIIY,Living,Patlo Open,Powder

EQUIP: Built- Ins
AIR: Central HEAT: Central
FLOOR: Carpet,Hardwood LAUNDRY: Inside
FIREPL: liVing Room ROOF:
POOL: Private TENNIS:
PARK: Carport,Detached,Garage SPA:
VIEW TYPE: None WATERFRONT:
SEC: FIN: Cash,Cash To New Loan
SEWER: POSS:
DISC: As Is SZONE: Property Report
OCC/SHOW: listing Agent Accompanies
LP: $2,599,000 DOM: 8 SP: $2,834,028 SSP: OLP: $2,599,000

LD: 03/08/2007 CD: 03/16/2007 SO: 04/17/2007 wo:
LAl: Michael Libow lAl#: 310-285-7509 LAl CElL: LAIOTHER:
LA2: LA2#: LA2 CElL: LA2 OTHER:
LAl EMAIL: mJilbow~aDI.COm LA2 EMAIL:
lOl: Coldwell Banker-BH L01#: 310-273-3113 LAl FAX#: 310-278-4934
L02: L02#: LA2 FAX#:
SAl: Laurence Young SA1#: 310-777-2879 SAl CElL: SAl OTHER:
SA2: SA2#: SA2 CEll: SA2 OTHER:
SAl EMAIL: !acrvvourg '.'oru!a.corr. SA2 EMAIL:
SOl: Prudential California Realty SOl#: 310-777-7800 SAl FAX#: 310-205-Q136
S02: S02#: SA2 FAX#:
CSO: 2.50% IT: ER LBA: No SAC: Yes lS: No EO: No PROBATE:
-5rokeriAgent does. nor ,.:;uarartpe i\l,p acc'Jracv of 'tle sauare footaqe, lot ~ze or other Information concern:ng the conditions or fpatves of the property prol/,jed ~~v the seller )r obtained
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http: Ipro.themls,com All_Searches_Previe\\ Jiles/One_agent_detail_preVlew.cfm':functIO... 8/1\ ::2007

AGENT DET AIL Page I of I
Nivie Samaan
310-84'9-3816 nsam33n(@sbcglobolnet
STATUS: Active ADDRESS: 201 S RQXBURYDR,BEVERLY HILLS ,CA 90212 LP: $3,100,000
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RESIDENTIAL SINGLE FAMILY AREA: (1) Beverly Hills MLS#: 07-197281 MAP: 632/F2 BR: 4
STYLE: Contemporary Mediterranean SUB: PUD: YB: 1926 BA: 4.50
APN: 4328-016-001 ZONE: BHR1* HOD: $0.00 STO: 2 APX SF: 2,905/AS
ADP: VU: No PL: Yes APX LDM: APX LSZ: 7,040/AS
APX ACREAGE: GH: N/A FP: 1 PKGT:
HORSE PROP: LSE: LOP: FUR: No PKGC:2
ELEM: JRHS: SRHS:
DIRECTIONS: 1 block S of Wilshire

REMARKS: Location, Location, Location. Gated with many updates. Grand living room with high, coved ceilings and fireplace,
formal dining room or office, two level family room. Mald's/malds bath down, family bedrooms up. Combination of wood and
travertine flOOring. Private pool area with 3/4 bath changing room In garage. Listing agent must accompany. I ~n~ate Remarks]
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ROOMS: Basement, Dlnlng,Famlly, liVing

EQUIP: BUilt-Ins,Cable,Dlshwasher, Dryer, Garbage Disposal, Microwave, Range/Oven, Refrigerator
AIR: Multi/Zone HEAT: Other
FLOOR: Hardwood,Stone LAUNDRY: Inside
FIREPL: living Room ROOF: Tile
POOL: Private TENNIS: None
PARK: Door Opener,Garage,Gated SPA: None
VIEW TYPE: None WATERFRONT:
SEC: Other FIN:
DISC: As Is SZONE: Flood,Property Report,Seismic Hazard,Special Study
OCC/SHOW: Call LA 1
LP: $3,100,000 DOM: 52 SP: SSP: OLP: $3,100,000

LD: 06/20/2007 CD: SO: WO:
LA1: John Donahue LA1#: LA1 CElL: 310-779-6450 LA10THER:

LA2: LA2#: LA2 CELL: LA2 OTHER:
LA1 EMAIL: Jwdre • .:earthllrk.net LA2 EMAIL:
L01: Gilleran Griffin Company L01#: 310-478-1835 x 132 LA1 FAX#: 310-388-5626
L02: L02#: LA2 FAX#:
CSO: 2.5% LT: ER LBA: No BAC: Yes lS: No EO: No PROBATE:
Broker/Agent does not ';Jl,arantee the accurac'v' of the S<luare footage, lot SIze or other Infonnatlon concernlrg the conditIons or features of the proper0' proVided ~y the seller or :Jbtalned
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http:.' pro. th~mls.comi AII_Scarches_Preview_Filesione.agent__ddail_previe\v.cfm':functio... 8/112007

ClosingPoint I Tools: Property 'Jearch I Print Property Details Page I of 2
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320 S Peck Dr, Beverly Hills, CA 90212 Hide Map

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Ownership Information
APN: 4328024023 Map: 42-B2
Primary Owner: Zernik,Joseph H Census Tract: 7010.002
Secondary Owner: >/.'\
';i"-"I Legal Desc: Tract # 7710 Lot 252
Mail Address: 320 S Peck Dr, Beverly Hills, CA Vesting: ;'j/A
90212
Phone Number: o
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Sale & Loan Information
Transfer Value: $442,500 Lender: Southern Cal S&L
Transfer Date: 05/30/1997 Loan Type: :'j/:~
Document 0000808718 Last Transfer: 10/16/2002

Number:
Assessment & Tax Information

Land Value: $738,956 Exemption: y
Structure Value: $315,791 Tax Amount: $11,530
Total Value: $1,054,747 Tax Area: 2410
Percent Improved: 29.94
Property Information
Land Use: Residential (Single Family Structure sqft: 2650
Residence)
Zoning: BHR1 Lot sqft: 6400 sq ft I 0.0 acres
HOUSing Tract: 7710 No, of Units: 1
Year Built: 1930 Fireplace: y
No. of Rooms: 12 Pool: i\
Bedrooms: 4 Garage: VIi
Bathrooms: 3.0 View: ~; !-'
Property data is compiled from public records. The Information presented here IS believed to be accurate but IS not
guaranteed.
http://\\WW .c losingpoint.com start Tools PrintDetalls.aspx'!origin=too!sdetalls 8lY2007

ClosingPoint Tools IProperty Jearch I Print Property Details Page 2 of 2
http:w\\w.c 10:) i ngpo i nt.comistarvT 00 Is PrintDetai Is.aspx ')origm=too Is details 8 i LV2007

Drop Foreseen in Median Price of U.S. Homes - New York Times of~
.•
Page I
mhc ~rt(l !Jork mimes " ".," " ,';";;'.,',:-:
August 26, 2007
Drop Foreseen in Median Price of U .8. Homes

By DAVID LEONHARDT and VlKAS BAJAJ
The median price of American homes is expected to fall this year for the first time since federal
housing agencies began keeping statistics in 1950.
Economists say the decline, which could be foreshadowed in a widely followed government
price index to be released this week, will probably be modest - from 1 percent to 2 percent -
but could continue in 2008 and 2009. Rather than being limited to the once-booming
Northeast and California, price declines are also occurring in cities like Chicago, Minneapolis
and Houston, where the increases of the last decade were modest by comparison.
The reversal is particularly striking because many government officials and housing-industry
executives had said that a natiomvide decline would never happen, even though prices had
fallen in some coastal areas as recently as the early 1990S.
While the housing slump has already rattled financial markets, it has so far had only a modest
effect on consumer spending and economic growth. But forecasters now believe that its impact
will lead to a slowdown over the next year or two.
"For most people, this is not a disaster," said Nigel Gault, an economist with Global Insight, a
research firm in Waltham, Mass. "But it's enough to cause them to pull back."
In recent years, many families used their homes as a kind of piggy bank, borrowing against
their equity and increasing their spending more rapidly than their income was rising. A recent
research paper co-written by the vice chairman of the Federal Reserve said that the rise in
home prices was the primary reason that consumer borrowing has soared since 2001.
Now, however, that financial cushion is disappearing for many families. "We are having to start
from scratch and rebuild for a down payment," said Kenneth Schauf, who expects to lose
money on a condominium in Chicago he and his wife bought in 2004 and have been tI).ing to
sell since last summer. "We figured that a home is the place to build your wealth, and now it's
going on three years and we are back to square one."
http://\v\\w.nytimes.com!2007 i 08/26/business/26housing.html?_r= 1&th=&emc=th&page... X;2h/2007

Drop Foreseen in Median Price of U.S. Homes - New York Times Page 2 of-+
On an inflation-adjusted basis, the national median price - the level at which half of all homes
are more expensive and half are less - is not likely to return to its 2007 peak for more than a
decade. according to :Yloody's Economy.com, a research firm.
Unless the real estate downturn is much worse than economists are expecting, the declines will
not come close to erasing the increases of the last decade. And for many families who do not
plan to move, the year-to-year value of their house matters little. The drop is, of course. good
news for home buyers.
It does, however, contradict the widely held notion that there is no such thing as a nationwide
housing slump. A 2004 report jointly \-VTitten by the top economists at five organizations - the
industry groups for real estate agents, home builders and community bankers, as well as
Fannie Mae and Freddie Mac, the large government-sponsored backers of home mortgages-
was typical. It said that "there is little possibility of a widespread national decline since there is
no national housing market."
Top government officials were more circumspect but still doubted that the prices would decline
nationally. Alan Greenspan, the former Fed chairman, said the housing market was not
susceptible to bubbles, in part because every local market is different.
In 2005, Ben S. Bernanke, then an adviser to President Bush and now the Fed chairman, said
"strong fundamentals" were the main force behind the rise in prices. "We've never had a
decline in housing prices on a nationwide basis," he added.
But Global Insight the research firm, estimates that the home-price index to be released
Thursday by the Office of Federal Housing Enterprise Oversight, a regulatory agency, will show
a decline of about 1 percent between the first and second quarter of this year. Other forecasters
predict that the index will rise slightly in the second quarter before falling later this year.
In all, Global Insight expects a decline of 4 percent, or roughly 10 percent in inflation-adjusted

terms, between the peak earlier this year and the projected low point in 2009. In California,
prices are expected to decline 16 percent - or about 20 percent after taking inflation into
account.
The government's index, which compares the sales price of individual homes over time, is
intended to describe the actual value of a typical house. Since the index began in 1975, it has
slipped from one quarter to the next on a few occasions, but it has never fallen over a full year.
Another index dating back to 1950, calculated by Freddie Mac, has also never shown an annual
http://\v\V\\.nytimes.com/2007/08/26/business/26housing.html,?_r= I&th=&emc==th&page... 8;26/2007

Drop Foreseen in \ledian Price of U.S. Homes - New York Times Page 3 of4
decline. Price data published by the National Association of Realtors, based on the prices of
houses sold in a given year, have also never declined. According to the association, the median
home price is now about $220,000.
Mr. Schauf and his wife, Leslie Suarez, put their condo in the Sheridan Park neighborhood of
Chicago up for sale shortly before moving to Texas last year so he could take a new job. They
bought the two-bedroom unit in September 2004 for $255,000, \Vith a 5 percent down
payment. They redid the floors, installed new window treatments and repainted the walls.
They said they expected the condo to sell quickly. Instead, they have cut the price several times
and have yet to receive an offer. The current list price is $279,000, though they expect to settle
for less.
Without the money for a new down payment, they are renting an apartment in Austin. They
also expect the monthly payment on their adjustable-rate mortgage to go up $200 in October.
Ms. Suarez, who grew up in the Dallas-Fort Worth area, says she is not as surprised because
she remembers home prices falling after the oil bust in the late 1980s. "Growing up in Texas,
real estate has never been a windfall," she said. "For me, I always just wanted to break even."
Housing prices have previously declined for long stretches in various regions. Most recently,
prices fell in California and in the Northeast during the recession of the early 1990S.
The current slump is different from that one, though, in both depth and breadth. In fact, the
national median price rose only slightly faster than inflation from 1950 to the mid-1990s.
But as interest rates fell and lending standards became looser, prices started rising rapidly in
the late 1990S, even in places like Chicago, which had rarely seen a real estate boom. The result
was a "euphoric popular delusion" that real estate was a can't-miss investment, said Edward W.
Gjertsen II, president of the Financial Planners Association of Illinois. "That's just human
nature."
Many families are clearly richer because of the boom. In the Old Town neighborhood of
Chicago, the town house that Ian R. Perschke, a technology consultant, and Jennifer Worstell,
a lawyer, bought in late 2004 has appreciated more than 30 percent, they estimated. The gain
was big enough to allow them to take out a larger mortgage and renovate two rental units in the
house. But :VIr. Perschke said he understood that he was "not going to see that appreciation
over the next three years."
http://www .n; ti mes.cOlw2007/08/26/business/26hollsing. htmJ?_r= 1&th=&emc=th&page... 8/26/2007

Drop Foreseen in :Y1edian Price of U.S. Homes - New York Times Page 4 of 4
Prices in Chicago peaked in September 2006 and have since dipped 1.7 percent, according to
the Case-Shiller home-price index, which is tabulated by MacroMarkets, a research firm.
For all the attention that the uninterrupted growth in national house prices received, some
economists argue that it was misplaced. The Case-Shiller index, which many experts consider
more accurate than the government measure, did show a drop in prices in the early 1990S.
(Unlike the government's measure, it includes mortgages of more than $417,000, which are
not held hy Fannie Mae or Freddie Mac.)
After adjusting for inflation - the most meaningful way to look at any price, economists say-
even the government's index fell in the early 1990s.
Dean Baker, an economist in Washington who has been arguing for the last five years that
houses were overvalued, said the idea that house prices could go only up had fed the bubble.
"It was very misleading," said Mr. Baker, co-director of the Center for Economic and Policy
Research, a liberal research group. There are a lot of people, he said, who bought "homes at
hugely inflated prices who are going to take a hit. You also have a lot of people who borrowed
against those inflated prices."
Perhaps the most prominent housing booster was David Lereah, the chief economist at the
National Association of Realtors until April. In 2005, he published a book titled, "Are You
Missing the Real Estate Boom?" In 2006, it was updated and rereleased as "Why the Real
Estate Boom Will Not Bust." This year, Mr. Lereah published a new book, "All Real Estate Is
Local."
In an interview, Mr. Lereah, now an executive at Move Inc., which operates a real estate Web
site, acknowledged he had gotten it wrong, saying he did not fully realize how loose lending
standards had become and how quickly they would tighten up again this summer. But he
argued that many of his critics have also been proved wrong, because they were bearish as early
as 2002.
"The bears were bears way too early, and the bulls were bulls too late," he said. "You need to
know when you are straying from fundamentals. It's hard, when you are in the middle of the
storm, to know."
CopyngN 2007 Toe New York Times Company
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In a CredIt Crisis. Large :-Vlortgages Crow Costly - \Jew York Times Page I of4
0f)r ~l"lJ !fork (t'tmt5 '.;'" 'S .:;:,' ' , ' : ; ' ; : I;
August 12, 2007
In a Credit Crisis, Large Mortgages Grow Costly

By FWYD :,,/,ORRIS and ERIC DASH
'ADen an investment banker set out to buy a 51.5 million home on Long Island last month, his
mortgage broker quoted an interest rate of 8 percent. Three days later, when the buyer said he
would take the loan, the mortgage banker had bad news: the new rate was 13 percent.
"I have been in the business 20 years and I have never seen" such a big swing in interest rates.
said the broker, Bob Moulton, president of the Americana Mortgage Group in Manhasset, N.Y.
'There is a lot of fear in the markets," he added. "When there is fear. people have a tendency to
overreact."
The investment banker's problem was that he was taking out a so-called jumbo mortgage - a
loan greater than the 5417,000 mortgage that can be sold to the federally chartered
enterprises, Freddie lVlac and Fannie ~lae. The market for large mortgages has suddenly dried
up.
For months after problems appeared in the subprime mortgage market - loans to customers
with less-than-sterling credit - government officials and others voiced confidence that the
problem could be contained to such loans. But now it has spread to other kinds of mortgages,
and credit markets and stock markets around the world are showing the effects,
Those vvith poor credit, whether companies or individuals, are finding it much harder to
borrow, if they can at all. It appears that many homeowners who want to refinance their
mortgages - often because their old mortgages are about to require sharply higher monthly
payments - vvill be unable to do so.
Some economists are trimming their grovvth outlook for the this year. fearing that businesses
and consumers win curtail spending.
"In the last 60 days, we've seen a substantial reduction in mortgage availability," said Robert
Barbera, the chief economist of lTG, a brokerage finn. "That in turn suggests that home
purchases ""ill fall further. Rising home prices were the oil that greased the wheel of this engine
http://W\VW.nytlmes.com/200708: 12'business 12mongage.html'!_r= 1&th=&emc=th&page... 8 12/2007

In a Credit Cri~i~. Large Mortgages Grow Costly - New York Times Page 2 of4
of growth, and falling home prices are the sand in the gears that are causing it to grind to a
halt. "
At the heart of the contagion problem is the combination of complexity and leverage. The
securities that financed the rapid expansion of mortgage lending were hard to understand, and
some of those \":ho m\ned them had borrowed so much that even a small drop in value put
pressure on them to raise cash.
'You find surprising linkages that you never would have expected," said Richard Bookstaber, a
former hedge fund manager and author of a new book, "A Demon of Our Own Design:
~larkets, I ledge Funds and the Perils of Financial Innovation."
"What matters is who owns what, who is under pressure to sell, and what else do they own," he
said. People with mortgage securities found they could not sell them, and so they sold other
things. "If you can't sell what you want to sell," he said, "you sell what you can selL"
He recalled that the crisis that brought down the Long-Term Capital Management hedge fund
in 1998 started with Russia's default on some of its debt. Long-Term Capital had not invested
in Russia's bonds, but some of those who owned such bonds, and needed to raise cash, sold
instruments that Long-Term Capital also owned, and on which it had borrowed a lot of money.
It appears that in this case, securities backed by subprime mortgages were owned by people
who also owned securities backed by leveraged corporate loans. VVith the market for mortgage
paper drying up, and a need to raise cash, they sold the corporate securities and that market
began to suffer.
The 'Vall Street investment banker who wanted a jumbo mortgage had a good credit score, and
is not a subprime borrower. But private mOltgage securities are now hard to sell, leading to his
problem. In the end, he was able to get a mortgage ""ith a lower interest rate, but it will adjust
in five years. possibly to a much higher leveL
The size of the rate increase he faced is unusual. But all jumbo lenders have raised rates.
Bankrate.com reports that conventional 3D-year mortgages cost about 6.23 percent now, less
than they did a few weeks ago, due to a decline in Treasury bond rates. But the average jumbo
rate is now 6.94 percent. The spread between the two rates rose from less than a quarter of a
percentage point to more than two-thirds of a point.
Jumbo mortgages are most important in areas with high home prices, most notably on the East
and vVest coasts. "In California, it has shut down the purchase market," said Jeff Jaye, a
http://\\ww.nytimes.com/2007 I 08/12business/12mortgage.html'?_r= I &th=&emc=th&page... 81 12 12007

In a Credit CrisIs. Large rVfortgages Grow Costly - Nn\ York Times Page 3 of 4
mortgage broker in the Bay area. "It has shut down the refi market.·'
The problems "vith subprime mortgages erupted as home prices began to slip in some markets,
making it harder to refinance mortgages. There were reports that a surprisingly large number
of loans made in 2006 were defaulting only months after the loans were made.
Many of those mortgages had been financed by securities, highly rated by credit agencies, that
suddenly seemed less secure than they had. Hedge funds that owned those securities, and had
borrowed against them, were asked to put up more money to secure their loans.
Two Bear Stearns hedge funds were forced to liquidate, and investors lost everything. Investors
shied away from buying new mortgage securities, and several lenders went out of business,
unable to finance the mortgage loans they had promised to make.
'With the credit gears clogged, there has been a sudden lust for cash at many levels of the
financial system. Last week banks in Europe and the United States tried to borrow so much
money that central banks had to step in to keep interest rates from rising.
"\Vhat I suspect is that there is a demand for credit by institutions that don't want to sell the
securities they own, because the bids are so low, and the banks are extending credit to them,"
said \Villiam L. Silber, a professor of economics and finance at ~ew York University and the
author of the book "\Vhen \Vashington Shut Down Wall Street: The Great Financial Crisis of
1914 and the Origins of .\merica 's Monetary Supremacy."
Fannie :\1ae and Freddie Mac, the gO\'ernment-sponsored enterprises, can still purchase
mortgages and issue securities, guaranteeing that the underlying mortgages ",ill not default.
Those guarantees are still accepted by investors, and borrowers who meet their standards -
meaning they can get so-called conforming mortgages - still can borrow. But those who want
larger mortgages, or cannot make down payments, face a harder burden.
Homeowners ",ith adjustable mortgages can refinance them at any time, so long as they qualify
for a new loan, so some facing a payment increase may be able to wait it out and refinance
later, if the market improves.
There have been sudden changes in the mortgage market before, but this one may be both
more severe and more damaging than those in the past.
In past years most borrowers had 30-year mortgages with fixed rates. If such borrower kept his
job, he usually could meet the monthly payments, even if the value of the home had declined so
http://www.nytlmes.com!2007 /08.12.busineSSiI2mortgage.html.?_r= 1&th=&emc=th&page... 8,12/2007

In a Credit Crisis, Large \:lortt'ages Crow Costly - ~e\v York Times Page 4 of 4
much that he could not et a new mortgage.
Now, however, many mortgages call for sharply rising monthly payments after a few years, and
borrowers were given loans vvithout regard to their ability to meet the higher payments.
Lenders assumed the mortgage could be refinanced, and that rising home prices would assure
repayment of the loan. It became common to offer homebuyers loans to finance the entire
purchase price of a home.
In June. banking regulators ordered that adjustable-rate loans be given only to borrowers who
could afford the rate at which it was likely to be reset, meaning that many borrowers would not
qualify for refinancings even if their homes had not lost value. Such a rule three years ago
might have prevented the crisis, Mr. Barbera said, but imposing it now may worsen the
problem.
Investors made the mistake of assuming that housing prices would continue to rise. said
Dvvight M. Jaffee, a real estate finance professor at the University ofCalifornia, Berkeley. "I
can °t believe these sophisticated guys made this mistake," he said. "But I would remind you
that lots of investors bought dot-com stocks,"
He added, "V,,11en you are an investor, and everybody else is doing the same thing and making
money. you often forget to ask the hard question."
.:\nd that is how a problem that began vvith Wall Street excesses that provided easy credit to
borrowers - and made it possible for people to pay more for homes - has now turned around
and severely damaged the very housing market that it helped for so long.
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10/24/2007 1 7 :14 318372,"",,-,.33 PREFERRED APPRAISAL:; PA'oE 01/01
1 DECLARATION OF JARED HARRIS

'1 I, Jared Hams, state and declare as follows:
3 1. I am an appraiser for Preferred Appraisals, Inc. I have personal

4 II knowledge of all facts set forth in this declaration, and if called as a witness could and
5 II would testify competently thereto.
6 2. Sometime in late September 2007, Preferred Appraisals received a

7 request from Pacific Mortgage Consultants for an appraisal of the property located at 320
8 S. Peck Drive, Beverly Hills, California 90212 (the "Property"). The president of
9 Preferred Appraisals, Ty Lum asked that I and another colleague Kris Wallace appraise the
10 II Property. On October 5, 2007, at approximately 10:00 a.m. we appeared at the Property to
11 II begin the appraisal of the Property. We began measuring and inspecting the Property. A
12 II few minutes later a man came outside, identified himself as Joseph Zemik, the owner of
13 II the Property and asked us what we were doing. We explained that Victor Parks of Pacific
l411 Mortgage Consultants had requested the appraisal. Mr. Zemik said that Victor Parks is "a
15 II fraud" and that he would not permit that inspection and we were to leave the Property. We
16 II left inunediate1y.
1711 3. In the days that followed Mr. Zemik sent several emails to Preferred
18 II Appraisals. Between October 5 and October 13 Mr. Zemik sent us five emails stating that
19 II Preferred Appraisal should stay away from the transaction involving his Property and that
20 II he had "filed a report with the Beverly Hills Police Department." Attached hereto as
21 II Exhibit B are true and correct copies of Zernikts emails to me.
-"').." I declare under penalty of perjury under the laws of the State of California
23 II that the foregoing is true and correct.
24 II Executed on October 2 ¥, 2007 at !!erf"'JOS4 &~~alifomia.
25
26 0/iL
~ARRJS
27 U
28
I WO~-WE5TIMMKI'400498J84.1
-1-
DECLARAnON OF TYRUS LUM
".J. :'-1.' :'·JIJ' 15: cl:' 31·)372~533 PREFERRED ;:;PRoAI';i4L; ::'t..<;E 02/ ·J'3
Page] of::'
Request
From: Joseph zemik [jZ:12345@earthlink.net]

Sent: Friday, Octobl;lr 05,2007 11.12 AM
To: pghChnstian@sbcglobal.com, bruce@pmloans, com; Jbakshandeh@hotmail.com: request@prefapp.conn;
pr~f~rred@dc, rr.com; salverson@untitedtitle com; Moe Keshavarzi, Mara@ADRservices.org
Subject: LEGAL NOTICE
October 5. 2007
Victor Parks, Keren Landucchi, :vfichael James O'Reilly, Bruce Kocen, Christina Pugh
Pacific Mortgage Consutants
Ty
\1s '\lverson
{Tnited Title Company
tyjara Seales, Retired Judge O'Brien

CO Mara Seales
ADR Services
RE: LEGAL :"iOTICE
To All Listed Ahove, .Jointly and/or Severally:
Employees of Preferred Appriasal \-vere fOWld today on my property, listed below, they were requested to leave
lDunediately, and they left with me a paper showing that they were instructed to do so by Christina Pugh of Pacific
.lfortgage Consultants.
T alsoreceived a Jetter from Fnited Title that they were requested to searen title for the property bv Victor Parks of
Pacifici Mortgage Consultants.
Please take notice:
J am filing a report with the Beverly Hills Police.
You are instructed to cease and refrain from any action relative to my property that is out of compliance with the law
and without my authorization.
I f you have any lav.ful authorization for any of these actions, please forward proof of such authorization to me no later
chan 5 :OOpm today, Friday, October 5, 2007, to this email address or by fax to: (80 I) 998-0917.
Absent proof of such legal authority. you may be listed in legal action.
Joseph Zemik. Owner

,20 South Peck Drive
Beverly Hills. CA 90212
cc:
~~ eren Landucch i
\Iichael James O'Reillv
700 tarkspur Landing Circle #275
I. 'lTkSpur. CA 9,"939
S88.1689'\02
Bruce Kocen
'+15-259-6380
brLlce:~ pmloans.com
Christina Pugh
., pghChristian'~sbcgla bal.com>
\' ictor Parks

C/O Att Bakhstandeh

10 S:ZO(l '7 ZERNIK V CONNOR ET AL
_D/=~,'~007 :5:~2 31037::'4533 P,"EFERPED .:.PPRAl ::.4L:' P':"3E 0 ,;, 'J9
Page 2 ('{ ::
<j bakshandeh c!:hotmail.com>
(S()())-528-.:2 7 2()
-". preferred'.0·dc.u.com>
"reqtlesl!.cyprefapp.com>
Fnited Title
I\r~ Alverson
<saJverson.0'unti tedtitle .com>
Judge O'BTit>n
t>.1ara Seales
ADR Services
<.Mara@ADRservices.org>
Nivie Samaan
cio Att KeshavarZl

\05.'(j{)7 ZERNIK V CONNOR ET AL
lQ!~~;:007 lS:~~ ~lJ37~~b33 FPEFEPPED ;:'PPF'AISALS CAGE ,N/Og
Page I of 2
Request
From: Joseph zernik Uz 12345@earthlinknetJ

Sent; Tuesday, October 09,2007 129 AM
To: Dzien Kenneth
Cc: Bruce Kocen- PMC Ms Alverwson - United Title: Christina Pugh- PMC; Ty - Preferred Appraisals
Subject: LEGAL NOTICE TIME IS OF THE ESSENCE DEMAND FOR DOCUMENTS ORDER #80701422-77
October 8. 2007
'Ar Dzien, 1Is Alverson· Clnited Title

:VIr Kocen. 1\[s Pugh - P\K
Sir/Madam:
Your name came: up n:cently relative to an initiative by Mr Victor Parks to get you involved in a real estate transaction,
I called your respective offices and requested that you produce evidence that Victor Parks was authorized by law to do
so . .'Jone of you provided any evidence like that.
I again repeat my demand that you produce to me any and all documents used by :VIr Parks to establish hlS legal
authority to initiate this action.
PLEASE TAKE :-JQII(:J,':

7\1, Parks was involved in multiple instances of fraud relative to a previous attempt by his relative Samaan to purchase
my property in 2004.
For e;<l:~m.I2k~

In the "arious SUbpoena productIOn matenals I found two types of hand signatures for Victor Parks. One r identify as
tile Korthem Callfomia lvpe, and the other is the Southern California type. But none beiiIs any semblance tc) VIctor
Parks' signature on declarations in court.
Therefore, the signature used on a PrequalUlCat;on Letter. dated Sept 7. 2004, presented by his relatiYe by marriage-
Samaan' on hjs behalf - was the Southern California type. The content of that letter had no base in reality, and
constituted Fraudulent Inducement. Tn court, Victor Parks and Salnaan, failed to include that document in subpoena
production, in fact disowning it. When I introduced it as an example of fraud perpetrated jointly by Samaan and Parks.
they tried to raise evidentiary objection to the document on the grounds of" improper authentication". With that.. in
fact, they admi tted that it was a case: of forgery.
On the other hand, Samaan's 1003. which too - had no base in reality, was signed by the Northern California type of
5ignature. In court~ they tried to introduce a copy with no signature at all. In that document the signature indicates that
Parks interviewed Samaan and entered that loan application. In deposition, Samaan stated that Parks had nothing to do
with that loan application, and that she and her husband completed it without even talking with Parks. Tn that
document Parks and Samaan evidenced Bank Fraud again,rt a Government Bac./sed Lendl!~
Also, in our transaction, Samaan (in LA) routinely sent and received fax communications imper'5onating Parks (in
\Vasrungton State at that time). That scheme that amount to Wire Fraud qgaimt a!l Individual, and also }Vir{.Fralld
qggi.!!Jf !LEl!Jall~iJlUtlstitution. Parks' fax line automatically forwarded to Samaan's fax line. And when sending
documents under his personality, she would set her machine to show no header ID.
In short. you are provided more than sufficient warning. I demand to see any documents that were presented to you as
the foundatIOn for Parks' authon!)' to initiate the title and appraisal action. These are no fraud amateurs.
Here are link to some ba'5ic documents in this regard.

al.WIRE FR-\{JD AC!AI;'JST A:'Il INDIVIDUAL A:'ID AGAI~_ST A fI~ANCJM, !~sorlTUTI01'{;
bJij):1h0me .qrthlink.')lW--jZ I234.21_COUNTR Y\\'lDE/04-1!2:18-gemailsonwirefraud pdf

Emails from realtor Libow to Parks and back. Libow is requesting explanation. Such requests were repeated 3 days in
a row
Parks faJled to respond, in fact tacitly admitting that his fax communications were automatically diverted to Samaan all
along wi:hout our knowledge.
Same scheme was used 111 communications ,"vith Countrywide re: loan doc uments.
bL~A:'lJ(.FR~q) ~GAI.~JiT A (;QYERNMENT BACJ<:F.:.D LENDER:

11}9:'007 ZERNIK V CONNOR ET AL
1a:~4(~807 16:42 31 a 37:'46 33 PREFERREL ?<PPPAI'O,ALS °,0/.1E 05/·J'3
Page 2 of 2
http;!holI1e.e.MbJink.neti.:.~jz 12345 'CQLTJ:iTRY\V1DE!04~09-2 7-1 003 pl-~. pdf

~ote double Receipt Date stamps page 1
C) FRA{)DULF.;XI I~DllC~~lli~T
ilt1I2;//h9me .earthli!1k.Jl~ "'j z 12)1~/ CQl};";TR.Y\\T[).E/01:.-09-0 Ipreq\l~1 i ficati orU et1er. pdf
"lote the hand sIgnature on page 2. compare to bl above.
d) F~AliD
httpino1Tl~cearthlink.llet·-jz\ 234 S,-C.QUNJR LWIDE/~6-1 0-2 ?parkssignaturejpcourtdecl'!l:ation..R-<if
Parks sIgnature on court declaratlon hears no semblance to the previous two signatures.
1 would be glad to pro,ide additional infonnation.
Pmdence suggest that you stay away from involvement in such dealings. The statements above are not the kind that are
made llghtly. and definitely not the type that would be taken lightly by any body with a license in the financiBI field.
You are more than welcome to share this corrummication v.ith Mr Parks, and try to get his response In \\Titing. 1 would
he grateful if you share such response with me. I believe that is your minimal duty wlder such cIrcumstances.
Joseph Zermk

10/9:2007 ZERNIK V CONNOR ET AL
10/~4/~007 It:4~ 31037:24533 PPEFEPPED APPPAISALS PA I3E 05/ ,J9
Page 1 of J
Request
From: joseph zernlk [jz 12345@earthltnk.net]

Sent: Wednesday October 10. 2007 1105 AM
To: Bruce Ko<.:en rnike@pmloans com
Cc: DZlen. Kenneth: salverson@unitedtit1e.com: Christina Pugh- PMC; Ty - Preferred Appraisals
Subject: LEGAL NOTiCE. TlME IS OF THE ESSENCE. DEMAND FOR DOCUMENTS RE ORDER #80701422-77
October 10,2007
LEGAL ]\'OTICE: TIME IS OF THE ESSENCE. DEMAND FOR DOCUMENTS RE: ORDER #80701.t22-77
Mr Kocen and Mr O'Reilly:
I am not sure \vho provided you with the document you attached. However that document is insufficient. This is :NOT
a legal .TIJ])GJ'0:E'lT Bemg a non-lawyer myself, it took me time to digest the fme pawts that are particularly
confusing in this case. since the \-!otion l\-lotiOll tOT Summary Judgment) incorporates the word judgment in its name.
For example,
ENTERING a 'vIotion for Summary Judgment is NOT entering a judgment...
T'OTICING ?vtotion for Summary Judgment is ~_OT noticing judgment...
A RU1ING in favor of plaintiff in \fotion for Summary Judgment is NOT a judgment...
0l0TICE OF RUUJ\(J in Motion for Summary judgment is ~~ a notice ofjudgment...
NOTICE OF ENTRY Of RLTLING in motion for summary judgment is NOl: a notice of entry of judgment...
ORDER granting summary judgment is NOT a judgment..,
\lOnCE OF ORDER granting summary judgment is NOT notice of judgment...
\lanCE OF E::'-!TRY OF ORDER granting summary judgment is NOT a notice of entry of judgment... ..
The document that ShO~lld have heen the SOurce of authority had to be JGDGME.:'-lT itself, not any of the trailers
coming before the movIe ... these are Just trailers, but \ve need to see the movie itself..
If you read it careful I"" the document that you provided, at its very end, come close to it:
3D
But you have not been provided with any document sho\'vi_ng that: "judgment shaY be enteredforthwith" had indeed
€\'er taken place Typically such action by the court would be documented by:
a) Judgment, and
b) :'oIotice of Entry of Judgment
l) Please let me know immediately if you ever get any document of that nature, i.e. JUDGMENT, and/or
'(OTICE OF ENTRY OF Jl.:DGMENT relative to the property.
Since I am not a lawyer, I derive most of my legal knowledge from less than reliable sources_ Here is Wikipedia on the
subiect (emphasis. underline,; in the original)'
.lUDGrvfENT:
In the UT.ll1eg ~~t~~. under the rules of civil proced1JI~ governing practice in federal courts and most state courts. the
enln' o{Judgmenr is the final order entered by the court in the case, leaVlng no further action to be taken by the CQurt
"·nth respect to the issues contested by the parties to the lawsuit. With certain exceptions, only aj/lwljudgmel1/ is
,,11 bJ eet to appeal.
However. since your ~ompany is engaging in conduct against my propt.."rty, that I notice you lS out nf compliance with
the law, 1 hold that \'()1J carry 'lave the burden of the proof.
2) Please prOVide me a signed legal opinion of a counsel with hisiber license number, that you are allowed to

10' I0;:2007 ZERNIK V CONNOR ET AL
lO!:~/2007 15: ~2 c:l 03724533 FF'EFEF'F'ED APPPAISALS ~':"GE (j7/1:3'3
Page':: of-,
engage in any conduct against my property based on "Order Granting Summary ,Judgment" alone, absent a
JlTDGl\-IENT and NOnCE OF ENTRY OF .RDCMENT.
Absent such opllllQn aud/O( such documents I demand the Pacific Mortgage Consultants provide me valid legal notlce
no later than IhuI~day, Qctob_eLJl, 2m
5:09PllL that you have noticed:
a) United Title Company.
b) ~ls Alverson
c) Ty
d) Preferred Appraisals
e) Christina Pugh of P:v1 c. and
f) whoever else ,"vas involved in this, that any such conduct was lacking in legal foundation and must be immediately
be ceased and vacated.
Joseph lemik
At 08:44 A:Yl1 0/1 012007. you ""'Tote:
Hello Dr Zemik.
Sorry it has taken me 2 days to respond to you but getting information about :VIr. Parks being authorized by
law to proceed was difficult since you provided no information abOut the nature of the problem or the legal
disputes involved with your property. You also failed to mention th·.; swmnary judgment against you.
Attacbed is a copy of the summary judgment against you that seems to legally dispute your contentions of
fraud and to allow ;-';iyie Samaan to proceed with the transaction.
Could y0u please send me copies of any appeals or reversals of this judgment or the case numbers for any
other actions you rna)' have submitted to the court?
"nlan.k you
Bruce Koeen
From: joseph zernik [ mailto...J~1234~earthlin!i. netJ

sent: Tuesday, Uctober 09,20071:29 AM
To: Dzien, Kenneth
Cc: Bn.Jce Kocen PMl.; Ms Alverwson - United Title; Christina Pugh- PMC; Ty - Preferred Appraisals
SUbject: LEGAL NOnCE: TIME IS OF THE ESSENCE. DEMAND FOR DOCUMENTS. ORDER #80701422·77
October 8. ':-007
Mr Dzien. f\.ls .·\herson - United Title

Mr Kl'cen. \1s Pugh - P~fC
Sir/:\ladam:
Your name came up recently relative to an initiative by Mr Victor Parks to get you involved in a real estate
transaction I called your respective offices and requested that you produce evidence that Victor Parks was
authorized by law to do so. None of you provided any evidence like that.
I again repeat my demand that you produce to me any and all documents used by Mr Parks to establish his
legal authority to initiate this action.
EJ.E~SE.TAKE;,,!()_·U!:B:

.'Ar Parks was involved in multiple msta.nces offraud relative to a previous attempt by his relative Samaan
to purchase my property m 2004.
J:Qu:><;ampl~
In the various subpoena product1on materials I found two types of hand signatures for Victor Parks. One T
;dentify as ute ~orthem California type, and the other IS the Southern California type. But none bears any
semblance to V;ctor Parks' signature on declarations in court.
Therefore. the signature used on a Prequalijicatinn l.etter. dated Sept 7, 2004, presented by his relative by
marriage- Samaan - on his behalf - was the Southern California type. The content of that letter had no base
in reality. and constituted Fraudulent Inducement. In court, Victor Parks and Samaan, failed to include
that document in subpoena production. in fact disowning It \\'hen I introduced it. as an example of fraud
perpetrated.i oilltly by Samaan and Parks. they tried to raise evidentiary objection to the document on the

1010·:007 ZERNIK V CONNOR ET AL
lOi~4'~007 15:42 3103724533 ?P~FEF'RED AF'PF'AISALS ::Jhl~E J8'" 8'3
Page 3 of ~
grotmds of" i!!JJ2t:<!per authentication". With that. in fact, they admitted that it was a case offorgery
On the other hand. Samaan 's 10tH. which too - had no base in flcalitl', was signed by the Northern
California type of signature. In court, they tried to introduce a copy with no signature at all. In that
document the signature indicates that Parks interviewed Samaan and mtered that loan application. Tn
deposition, Samaan stated that Parks had nothing to do with that Joan application. and that she and her
husband completed it \vithout even talking with Parks Tn that document Parks Md Samaan evidenced
111utk FralulJlgginsl {! GlD!-ermtumt Baclsed L;nder.
Also. in our transaction, Samaan (in LA) routinely sent and received fax communications impersonating
Parks \In Washington State at that time). That scheme that amount to Wire Fraud against an IndividJi{]j,
and also Wir! E~(Iud against a F;'lanci~l [~titutio~ Parks' fax line automatically fonvarded to Samaan's
['LX: line And when sending documents under his personality, she would set her machine to show no header
rD.
In shon, you are provided more than sufficient wammg. I demand to see any documents that were
presented to you as the foundation for Parks' authority to initiate the title and appraisal action. These are
no fraud amateurs.
Here are link to some basic documents in thlS regard.

aIWJRE!'J~~_!LP AGAJrIl~T Al'I INPIVIDUAL AN)) AGAINST A FIj\'ANCIALI~STITUTJON;
bt!.R:/hl)m~.~nkllet/-::iZ.1J 345/COUNTR yWIDE/04-1 O-18-geJ.!lai lsonwi,refraud.pdf

Ernails from realtor Libow to Parks and back. Libow is requesting explanation. Such requests were
repeated 3 days \n a row.
Parks failed to respond, in fact tacitly admitting that his fax communications were automatically diverted
tl' Samaan all along without our knowledge.
Same scheme wa$ used in commuDlcations Vvith Countrywide re: loan documents.
hl.. »J.NKYRArO AG.AI~ST A G..QVERNJ\...1ENT BACJq.PU::'iDER;

tttp.home.earthlink.~!L-.:JzI2345!CQJ.lbIRYWlDE/04~09-27-lJ.)03pL-4IJQf
0iotc double Receipt Date stamps page I
010te Parks signature on page 4, compare to c) below.
~) F]{..\VDLLE:.NTI:"IDUCE~lE.~I
b.np- ·r,OllleearthliJ1k.nt:Jl--jz 123 45!COU1\TF-, YWIDE/Q4-09-07 pre.qualificationletter. pdf
!':ote the hand signature on page 2, compare to b) above.
d) FRAeD
b~ttP--::~ome·~arthIiJlknetl-jz 12345iCOl.;NTRY\V1D.E:/Q!5-1 0-:2 7parkssignatureincou,rtcieclarS!llon. pdf
Parks signature on court declaration bears no semblance to the previous t\vo signatures.
I would be glad to provide additional infonnation.
Pruden.ce suggest that you stay away from involvement in such dealings. The statements above are not the
kind that are made lightly, and detinitely not the type that would be taken lightly by any body with a
license in the fmancial field. You are more than welcome to share this communication with Mr Parks, and
try to get his response in \.\Tiring. I would be grateful if you share such response with me. t believe that is
your minimal duty under such circumstances.
Joseph Zernik

10.] 0120() 7 ZERNIK V CONNOR ET AL
18i:~,':007 ~S: J: 318372~533 FPEFEPPED APPPAI'SALS PAGE [)9iO'3
ReCfuest
From: Joseph zernik Uz12345@earthllnk.net]

Sent: Saturday, October 13 20076:25 PM
To: Bruce Kocen- PMC
Cc: Dzien, Kenneth- United Title; Alverson - United Title: Christina Pugh- PMC; Ty - Preferred
Appraisals
SubJect: Brief Update - 10/11/07 Judge O'Brien, ADR resign
Attachments: 07-10-13 BRIEF REVIEW [Slgjpdf
~
~
07-10,13 BRIEF
REVIEW (slaj,pd,.
- FYI
1) A brief update is attache,d.
:' ) I still expect notlfication from each of you separate Iy - That any and all actions taken against the property at
320 South Peck. BH CA 90:'12. 'Nithout authorization hy the owner, Joseph lemik, and without any other valid
legal amhorization that you could document, were withdrawn and voided.
Joseph Zemik

1 - .- -: '\ ,
2
~ ,
3
4 ...::;:: .. ,';'.'It •
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF LOS ANGELES, WEST DISTRICT
10
11 • __ '. ~ • , ... A •
12
13 DECLARATION OF DAVID J.
PASTERNAK
14
15
16
17
_.,:" • • T
18 .....'l'"\."
_~
..... ....J PASTEF~~AKf he~eby declare:
19 -=-~e :.~.. :,:)r:nat:-()n set. :8~-t!: be::'ow i.s ~:r;.<:)tl'ln ::0 7.e t:'ro·,~g:--~
20;::rs:-~a~d ~~owledge. If ~aLled ~s a wltness in ~~~S ~aLter_
21 ccu:d ~~d ~ould clJmpetencly ~esc~fy ~nder ~at~ as ~o ~he ~ac~s
22 3e*: =.~::-::: te:'cT.. l .
.23 am a~ ~=t2r~ey :i~e~sed ~~ ~ractlc~ ~::~ ~~~~::=_~g
24 :=:e::::,:-e :-1':" =-
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25 c~ ?3s~e~~a~1 ~as:eY~a~ & ?a::on i ~ Law C8rpcr3=:2D.
26 ~a';e ser-:ed 32 ~ ~:a:e =2urt ~eCe~7ey ~e_~ ':er
27 ~ :- '7":,2.3 ::;:':-~2e _;'1~~ .:t.~~"::~(~ >{'1·~A ~el'~/~j ~3 '1 3a :-:.r:";:- '.::: ::="/ .
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EXHIBITS VOL V - RECEIVERSHIP Exh p 136
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EXHIBITS VOL V - RECEIVERSHIP Exh p 137
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S2iC: I.Li.: C:
DAVID .1. PASTERNAK
PASTERNAK, PASTERNAK & PATTON
A Law Corporation
1875 Century Park East Suite 2200
Los Angeles, California 90067-2523
Telephone: 310.553.1500
Fax: 310. 553.1540
E-mail: djp(~paslaw.com

PERSONAL A~D PROFESSIONAL INFOR'1AnON
Date of Birth: March 5, 1951

Married: Cynthia F, Pasternak
Children: Gregory (March 24, 1981)
Kevin (February 23, 1990)
Matthew (August 9, 1993)
B.A. (Political Science), Cum Laude, UCLA 1973

J.D., Cum Laude, Loyola University 1976
1976 - 1979 CALIFORNIA DEPARTMENT OF CORPORATIONS

Staff Counsel, Enforcement Division
1979 - 1980 CALIFORNIA DEPUTY ATTORNEY GENERAL

Business and Tax Section
1980 - 1993 TYRE KAMINS KATZ & GRANOF, A Law Corporation

(managing partner (formerly TYRE & KAMINS)
1989 - 1991)
1993 - Present PASTERNAK, PASTERNAK & PATTON, A Law

Corporation (formerly APPLETON, PASTERNAK &
PASTERNAK, A Law Corporation)
Civil Litigation and Receivership Practice
Los Angeles Superior Court Mediator
RECEIVERSHIPSHIP EXPERIENCE AND RELATED APPOINTMENTS
Co-Chair of California Receivers Forum (1995 - 1997)

Board Member of California Receivers Forum (both State and Los
Angeles/Orange County Chapter) (1998 - Present)

Named on previously maintained Los Angeles Superior Court
Receivers List
Member of Los Angeles Superior Court Ad Hoc Committee On
Receivership (1993)
Conservator of Beach Escrows, Inc. (appointed by California
Commissioner of Corporations)
(March 1982)
Recelver of Beach Escrows, Inc.
Commissioner of Corporations of the State of California v.
Beach Escrows, Inc.
(Los Angeles Superior Court Case No. C 405 730)
(March 1982 - April 1988)
Conservator of Apollo Escrows, Inc. (appointed by California
Commissioner of Corporations)
(June 1982 - 1991)
Appraiser of minority shareholder's interest (pursuant to
Corpora~ions Code §2000(c))
Florez v. Jamex Records, et al.
-----
(November 1982 - December 1983)
Referee (appointed pursuant to Code of Civil Procedure §873.0l0
to sell real property)
Nakao v. Vahabzadeh, et al.
---~- - -

(September 1983 - April 1984)
Receiver (appointed to sell real property and hold proceeds)
Parrish v. Starr, et al.
(March 1985 - March 1986)
Receiver (appointed to manage 13 luxury condominium units)
Lopez v. Golden State Sanwa Bank
(February 1986 - January 1987)
Receiver (appointed to manage run down "hotel" facility)
Sears Savings Bank v. Mulholland Estates, Inc.
(October - November 1988)
Counsel for Receiver of Tyler Medical Clinic
In _r~_Tyl_er Medical Cl inic
(Los Angeles Superior Court Case No. WEC 139 502)
(September 1990 - January 1993)
Recelver (appointed to manage and sell West Hollywood
residential property)
760, Inc. v. Jane Bernice Block, et al.
--_._--
(Los Angeles Superior Court Case No. C743 001)

W:\.99999 :~p Resume\DJP Res~me 06-17-0S.doc

Counsel for Conservator of Bay Escrow Co., Inc. and QVS Escrow
Inc.
(March 1992 - October 1993)
Receiver (of single family residence)
Imperial Thrift & Lo?n Assn. v. Robert Draper, etc., et al.
(Los Angeles Superior Court Case No. BC 057 739)
(June 1992 - December 1992)
Receiver of collateral (accounts receivable and equipment)
Cosmetic Gr~up/APT, Inc., et a. v. Advanced Packaging
!ecb0iques, et al.
(Los Angeles Superior Court Case No. PC 006 067W)
(July 1992 - September 1993)
Receiver (of condominium development)
9al V. Hughes, etc. v. Halsted Financial Company, et al.
(September 1992 - March 1993)
Counsel for Conservator of Irvine Escrow Company, Inc.
(December 1990 - November 1994)
Receiver (of 10-unit apartment building)
Navin H~_Q?shi v. Sally Beamish Neff, et al.
(December 1992 - May 1993)
Counsel for Conservator of Ruth Altman Escrow Company
Receiver (of S-unit apartment building)
Allan Herschderfer v. Sally Beamish Neff, et al.
(March 1993 - July 1993)
Counsel for Receiver of Fountain Valley office complex
Bank of California v. Claire Zerez, et al.
(Orange County Superior Court Case No. 705 890)
(March 1993 - June 1993)
Mechanics National Bank v. Faustino Abat, et al.
(April - November 1993)
Receiver (of Beverly Hills Italian marble designer business)
Mario Di Donato, et al. v. Italian Country, Inc.
(April - September 1993)
Wilshire State Bank v. Young Taik Park
(April - October 1993)
W:\q9999\DJP'Rpsuree\:JP Resume 06-17-05.doc

Receiver (of Newport Beach office building)
ITT F~deral Bank v. 833 Dover Investment Company, et al.
(Orange County Superior Court Case No. 710815)
(May 1993 - August 1994)
Receiver and Bankruptcy Court Custodian (of car wash)
Westamco Investment Co., et al. v. Un Sook Yang, et al.
In re Un Sook Yang_aka Eun Sook Chung
(U.S. Bankruptcy Court Case No. LA 93-27855-SB)
(May 1993 - November 1993)
Receiver (to liquidate clothing manufacturer)
Kenneth Grier v. Kristin Hoffman, et al.
(May 1993 - March 1995)
ITT Federal Bank v. 621 East Chestnut, Ltd.
-- ----
(June 1993 - October 1994)
Receiver (of dry cleaning business)
Welan v. Ha, et al.
(July 1993)
Receiver (to collect judgment)
So~!hern Califor~ia Broadcasting Co. v. Sch~artz
(Los Angeles Superior Court Case No. NCC18521G)
(July 1993 - August 1994)
Counsel for Receiver of Glendale office building
Wells Fargo Bank v. Gerald J. Chazen, et al.
(Los Angeles Superior Court Case No. EC 011 704)
(August - September 1993)
Receiver (of 46-unit Santa Ana apartment complex)
ITT Federal Bank v. Stana, Ltd.
(September 1993 - August 1994)
Receiver and Bankruptcy Court Custodian (of landscaping business
and real property)
f~! East National Bank v. Hacienda Landscape, I~c.
In re Hacienda Landscape, Inc.
(U.S. Bankruptcy Court Case No. LA 93-54424-ER)
(October 1993 - February 1994)
Receiver (of 160-unit Van Nuys apartment complex)
Sentinel Real Estate Fund v. Meadow BrOOK Venture, et al.
(Los Angeles Superior Court Case No. SC 023 050)
(October 1993 - July 1996)
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ITT Federal Bank v. Vinay R. Pai, et al.
(~ovember 1993 - June 1994)
ITT Federal Bank v. Sixth & Mortimer Street Ltd.
(November 1993 - August 1994)
Receiver (to transfer liquor license)
Cho Hung Bank, et al. v. Hu Am Hughes Chong, etc., et al.
(November 1993 - January 1995)
Receiver and Bankruptcy Court Custodian (of 28-unit Agoura and
24-unit San Bernardino apartment complexes)
FGB Realty Advisers, Inc. v. AWL Group, Inc.,~et al.
In re Agoura Willowcreek, Ltd.
(U.S. Bankruptcy Court Case No. 94-02414-M11)
Provisional Director (of retail bookstore and publishing
corporation)
Sohrab Rostamian v. Ketab Corporation
(February 1994 - September 1994)
Recelver (of Newport Beach office complex)
ITT Fegera~~~nk v. 881 Investment Company
(March 1994 - June 1995)
Receiver (of Los Angeles strip shopping mall)
Union Bank, etc. v. Uri P. Harkham, etc., et al.
(March 1994 - August 1994)
Receiver (of 28-unit Fontana apartment complex)
State Street Bank And Trust Co., etc. v. Joe J. Jeon, et al.
(San Bernardino Superior Court Case No. SCV 10931)
(March 1994 - January 1995)
Recelver (of Warner Center office complex)
The Prudential Insurance Co. of America v. Warner Properties
III
(March 1994 - January 1995)
Receiver (of 32-unit Los Angeles apartment complex)
Irving Shapiro, etc. v. Kenneth S. Froland, etc., et al.
(March 1994 - November 1994)
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Counsel for Conservator of 7 Days Escrow, Inc.
(March 1994 - November 1994)
Counsel for Conservator of Sierra Pacific Escrow Company
(June 1994 - Present)
Receiver (of button manufacturer)
First Business Bank v. Padcraft, Inc.
(Los Angeles Superior Court Case No. 106 069
(July 1994)
Receiver (of West Los Angeles apartment complex)
Joseph F. Mlller, etc. v. The Goshen Group, et al.
(September 1994 - June 1995)
Receiver (of Whittier office building)
Fremont Investme~~ & Loan, etc. v. Whittier Instorage
Associates, etc., et al.
(Los Angeles Superior Court Case No BC 115 105)
(October 1994 - August 1995)
Receiver (of orthopedic surgery practice)
Harvard Ellman,_ M.D. v. Eugene Harris M.D. Irwin L. Bliss M.D.
Scot_t_~_g_.L_a}~~rn M. D. And Stephen P. Kay M. D. A Profess~onal
Corporat ion ~ et a~
Counsel for Receiver of 7 Days Escrow, Inc.
?eopl~__ ?_~ys Escrow, Inc. , etc.
(Los Angeles Superior Court Case No. BS 030 328)
(November 1994 -- December 1999)
Receiver and Bankruptcy Court Custodian (0£ San Diego medical
office building)
Fremont Investment & Loan, etc. v. 2850 Associates, Ltd.,
etc., et al.
(San Diego Superior Court Case No. 682 246)
In re 2850 Associates Ltd., etc.
(U.S. Bankruptcy Court Case No. 95-01624-M11)
(November 1994 - November 1997)
Provisional Director (of clothing manufacturer)
In re By Kimberly, Inc, etc.
(January 1995 - November 1996)
Receiver (of mortgage loan brokerage business)
Spencer Howard, et al. v. Beverly Hills Investment & Loan
Association, Inc., et al.
(United States District Court Case No. CV 95-0500 RG (MCx))
(February 1995 - August 1995)
Receiver (to facilitate examination of earthquake damage)
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La Brea Vista Townhouses Association, etc. v. Beatrice DeGara
Glanz, et al.
Counsel for Receiver placed in receivership
J.E. Robert C~~pany, Inc., etc. v. DeVere H. Anderson, etc.,
et al.
(April 1995 - Present)
Receiver (of West Hollywood commercial property)
Palray Gold Land, etc. v. Richard Hechtman, etc., et al.
(May 1995 - Present)
Provisional Director (of mirror manufacturing corporation)
In re Head West, Inc.
(July 1995 - July 1999)
Receiver (of Isla Vista apartment complex)
c::()~0~rywide Lending Corp. v. Robert L. Lovgren, et al.
(Santa Barbara Superior Court Case No. 208 515)
(July 1995 - November 1997)
Counsel for Receiver (of 153-unit low income condominium
development)
WE:~s Farqo Bank,.~~.' A., etc. v. Aviv Real ty & Development
C2-.£P., etc., et~al:.-
(August 1995 - Present)
Receiver (of 144-unit apartment complex)
First National Bank of Chicago, etc. v. ~waranjit S. Nijjar,
etc., et al.
(September 1995 - February 1996)
Counsel for Receiver (collecting accounts receivable)
Advanced Funding & Support Systems, Inc. v. Pacifica
~anagement Consultants, etc. et al.
(September 1995 - May 1996)
Receiver (of Reseda commercial property)
Regency Savings Bank, F.S.B. v. Nasser Aghaee, etc., et al.
Receiver (of West Los Angeles apartment complex)
California Federal Bank, F.S.B. v. Daya Corporation, etc., et
al.
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(September 1995 - May 1996)
Counsel for Receiver (of Sierra Pacific Escrow, Inc.)
People__v. Slerra Pacific Escrow, Inc.
(San Diego Superior Court Case No. 691 469)
(October 1995 ~ November 1999)
Receiver (to take possession of $10 million in u.S. Treasury
Notes)
Jinro ~merica, Inc., etc., et al. v. Saratoga Futures, Inc.,
etc., et al.
~--------------
(Santa Clara Superior Court Case No. CV 753 290)

(November 1995 - July 1999)
Counsel for Receiver (re reconsideration of Receiver charges)
f~~st Republic Thrift & Loan v. Scott & Scott Land Co~pany,
etc., et al.
(December 1995 - January 1996)
Counsel for Receiver (of office complex)
First Interstate Bank of California, etc. v. Aviation/El
Segundo Office Building, Ltd.
(December 1995 - Present)
Receiver (of aged care facility)
Casa Bonita Stanton, etc. v. Nida Q. Madamba, et al.
(December 1995 - December 1996)
Receiver (of Los Angeles apartment complex)
First Republic Thrift & Loan v. Wilshire Tax Credit Partners,
etc., et al.
(December 1995 - July 1996)
Receiver (of 212-unit Moreno Valley apartment complex)
Citibank, etc. v. Vista Springs, Ltd, etc., et al.
(Riverside Superior Court Case No. 275 390)
(December 1995 - November 1996)
Receiver (of South Central Los Angeles apartment complex)
~ountrywide Lending Corp. v. Jose B. Jimenez, et al.
(December 1995 - May 1996)
Receiver (of Lake Forest car wash)
Cenf~_d__ Bank, etc. v. Lake Forest Auto Wash, Inc., etc., et al.
In re Lake Forest Auto Wash, Inc.
(United States Bankruptcy Court Case No. SA 96-11042 JR)
(January 1996 - June 1996)
Receiver (of Van Nuys office complex)
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First BanJ<;._C?f Beverly Hills, F.S.B. v. Bijan K~~lil~~_al.
(February 1996 ~ May 1998)
Receiver (of Los Angeles garment center retail complex)
Commerclal Bank of Korea v. Ehsan Kashani, et al.
~ ~ - - - - -

(February 1996 ~ September 1996)
Counsel for Receiver (of apartment complex)
Home Savings of _America, F.S.B. v. Don Braham, et al.
(March 1996)
~ome Savin9~_ of America, F.S.B. v. Don Braham, et al.
(March 1996)
Receiver (of 22-story Los Angeles office building)
Centu~y~996 Funding, L.P., etc. v. Howard-David, etc., et al.
(March 1996 - September 1996)
Home SaviIlgs of America, F. S_J3~__",,-"-~. J. Properties No.2,
L. P.,
- - -
et al.
(Los Angeles Superior Court Case No. LC 036 098)
(April 1996)
Counsel for Receiver (of multi-unit commercial real property)
Home Savings of America, F.S.B. v. 215 South La Cienega Co.,
et
al.
(April 1996)
Receiver (to dissolve corporation owning night club)
Mark P. F~anagan v. Alboma, Inc., etc., et al.
(April 1996 - April 1997)
Home__~~~~.ngs of America, F. S. B. v. Howard Yonet, et al.
(May 1996 December 1996)
Home Savings of America, F.S.B. v. Timothy J. Lavalli, et al.
(May 1996)
Counsel for Receiver (of 153-unit low income condominium
development)
:,~': \99999\DJP\ReS 1J.Tre' C~~? Eesume 06-17-05.doc

City_~%Los Angeles, etc. v. Aviv Realty & Development Corp.,
etc.,
--
et al.
.. _ - -
------_
(Los Angeles Superlor Court Case No. BC 147 626)

Receiver (of Los Angeles apartment complex)
Alto Investment Co. v. Fedora Investment Corp.
(Los Angeles Superior Court Case No. BC 149460)
Receiver (to permit environmental inspection)
State
---
Street
-----
Bank, etc. v. Jose Martinez, etc., et al.
Receiver (to transfer Long Beach residential property)
Ma~dana Rassuli Shemirani v. N.E.W. Elektroproduktion
G.M.B.H. ,
etc.
(May 1996 - September 1996)
Counsel for Receiver (of six apartment complexes)
~~1~J~rnla Federal Bank, F.S.B. v. Mary Drapel, etc., et al.
Counsel for Receiver (of produce corporation)
:r.r-J~ _Ti.paE_~:r-.9_dLlc'=., Inc., etc.
Expert witness (re performance of Receiver of 155-unit Los
Angeles apartment complex)
ynion__Xederal Bank, etc. v. Regent Place Apartments, etc., et
al.
Counsel for Receiver (of 52-unit apartment complex)
Hom~ Savings of America, F.S.B. v. The Hodge Family Trust,
Dated 6-6-85
(June 1996)
Home Savings of America, F.S.B. v. Wickham H. Loh, etc. , et
al.
(July 1996)
0?~e _§~vings of America, F.S.B. v. Orest L. Dolyniuk, et al.
~. 99999 D~P ~esume\DJP ?esu~e J6-17-05.doc

(July 1996)
Hom~__§av~ngs of America, F.S.B. v. Lorenzo Espinoza, etc., et
al
(August 1996)
Counsel for Receiver (of industrial office building)
San~a_~~nk California v. The Magnon Companies, etc., et al.
(Riverside County Superior Court Case No. 282 665)
Counsel for Receiver (of Paradise Cemetery)
Sta~~~rnE:OteFY Board v. Victor Fortner, et al~

(December 1996 - August 1999)
Receiver (to collect medical accounts receivable)
Carlmont Capital Special Purpose Corp., et al v. MB Martin
Health Service, etc., et al.
(January 1997 - March 1997)
Receiver (of multiple real property entities and corporation)
Jack Evers, et al. v. Javier D. Salas, etc., et al.
(January 1997 - December 2000)
Receiver (of 42-unit apartment complex)
Ho~a~~ Alexander, D.D.S., etc., et al. v. H. Eric Crumpton,
etc., et al.
(January 1997 - September 1997)
Receiver (of personal injury case settlements)
Denise Breakman, et al v. Eric Bryan Seuthe, et al.
Receiver (of Pomona industrial real property and equipment)
Francis and Joyce Foreyt v. William Kitchen, et al.
(Los Angeles Superior Court Case No. KC 023 977)
Joint Agent (to sell art)
~b~ntal S. Kilroy v. John B. Kilroy
(Los Angeles Superior Court Case No. BD 142 469)
(May 1997 - May 1998)
Receiver (of Laguna Niguel industrial/retail real property)
Ruth F. Brazeau, etc. v. John Napoli, et al.
(Orange county Superior Court Case No. 780 627)
(June 1997 - July 1997)
Receiver (of Los Angeles residential real property)
'tI,',99999'DJ?\?esume\ClJP Resume 06-1 7 OS.doc

California C~~ter Bank, etc. v. L & L Partnership, etc., et
al.
(June 1997 - January 1999)
?ay Conv~lescent Hospltal, Inc., etc. v. Long Beach Medical
Investors, etc., et al.
(Los Angeles Superior Court Case No. NC 022 077)
Receiver (to collect medical accounts receivable)
.tICR fv1~?i~~_BecE'O_~vable Funding Corp. -1, et al. v .yort Bay
Care Center, etc., et al.
(September 1997 - October 1998)
Counsel for Receiver (re employee discrimination claim)
First R~E~blic Savings Bank v. Constance Moore Lop~~, et al.
Receiver and Custodian (of office building)
Bankers Trus~_Company v. Fred Janz, et al.
(December 1997 - January 2000)
Receiver (of corporation owning Big Bear Lodge and other assets
and real properties)
CPF Advl--"'l.:)ry Corp., etc., e~_al. v. California Properties
Fund,
--".__ _-
..
etc. , et al. ._-~-

(January 1998 - December 1999)
Counsel for Provisional Director (of lighting distribution
company)
Rouhollah Esmailzadeh v. Saeed Cohen
(March 1998 - August 1998)
In Re A & H Properties, Inc.
(U.S. Bankruptcy Court Case No. LA 98-27008 TD)
(May 1998 - January 2000)
Provisional Director (of automobile dealership)
Marc J. Spizzirriv. Steven L. Vickers, et al.
(April 1998 - November 1998)
Receiver (to sell taxi medallions re collection of judgment)
pavjd Praisman, et al. v. Vadim Levotamn, etc., et al.
(August 1998 -
Counsel for Receiver (of multiple real properties)
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In r~Sha~on Lynne Boyar
(United States Bankruptcy Court Case No. SV 97-19054 KL)
(February 1999 - February 2000)
Receiver (to purchase and sell real property)
Elie~er Appel v. Arie Joffe, et al.
(February 1999 - July 2001)
Receiver (of San Pedro restaurant)
Joh I1__Georgoul is, et al: v. Christ Koutroumbi s, et al.
(Los Angeles Superior Court Case No. YC 034 466)
(March 1999 - December 1999)
Special Master (re disputed corporate records and files)
William Chavanne v. Band Pinsky, et al.
Los Angeles Superior Court Case No. LC 048 067
(March 1999 - March 2000)
Provisional Director (of trucking company)
In re Briggs Superior Transportation, Inc., etc.
(Los Angeles Superior Court Case No. VS 007 950)
(June 1999 - March 2000)
Counsel for Receiver (of real estate partnership)
~oyc~Rok, et al. v. David Fok, et al.
(November 1999 - March 2000)
~amni Bank, etc. v. Kyoo Jung Lee, etc., et al.
(April 2000 - September 2000)
ADF Enterprises, Ltd., etc. v. Boris Blumkin, etc., et al.
(June 2000 - July 2000)
Receiver (of joint venture to reconstruct Malibu pier)
~cc~~t Builders Inc., etc. v. Darian Construction Co., etc.,
et al.
- - -
(Los Angeles Superior Court Case No. SC 061016)

(June 2000 - present)
Receiver (of fabric dyeing business)
Fariba Minoo Achvan v. Chosrov Achvan
(Los Angeles Superior Court Case No. BD 312699)
(September 2000 - October 2001)
Partition Referee (of Hollywood real property)
Dav~9 Dartnell v. Gant Griffis, etc., et al.
(September 2000 - Decerrber 2000)
Expert Witness (re Receiver's services)
'Ii: ,99999\DJP:Resume\JJP Resume 06-17-0S,doc

Imperial Bank v. Alpan, Inc.
(Ventura Superior Court Case No. CIV 179 584)
(October 2000 - April 2001)
Receiver (to operate and sell residential real properties)
Yvonne Hammel v. Jose C. Martinez
Partition Referee (or Northridge residential real property)
Diane Deschenes, etc. v. Joe Albarran, Jr.
-----
(Los Angeles Superior Court Case No. PC 025 790 W)
(April 2001 - November 2001)
Receiver (to take possession of contents of safe)
~i~~ Ile12~ Gropp v. Kevin l2§l:ns Gropp
(June 2001 - July 2001)
Receiver (of Beverly Hills single family residence)
California National Bank v. Ahmad Khalilian, etc., et al.
(July 2001 - October 2001)
Receiver (of commodity futures business)
A~~_£ica~Performance Corp. dba C.G.A.R. Futures & Options,
etc., et al. v. Gabriel Robles, etc., et al.
---_._-----
(Los Angeles Superior Court Case No. VC 036755)

(April 2002 - May 2002)
Counsel for Partition Referee
Robert Johnson, et al. v. W.R. Burchette, etc., et al.
~ - - - _ . - -

(October 2002 - January 2003)
Receiver (of Death Row Records)
In r~Ivl.9rriage of Marion Hugh Knight and Sharitha Golden
Receiver (of newspaper distribution businesses)
In l~_~arriage of Iravani
(November 2002 - December 2002)
Partition Referee (of unimproved Moreno Valley real property)
Estate of Sidney L. Krawitz
(Riverside Superior Court Case No. 082 785)
(December 2002 - February 2004)
Receiver (re $150 million mortgage fraud)
Lehm~~~rothers Bank, FSB v. Beverly Hills Estates Funding,
Inc., -- etc., et al.
~--- - - - - - -
(U.S. Dlstrlct Court Case No. 03-2702-DDP(Plax))

(April 2003 - Present)
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Partition Referee (to sell Wilmington commercial real property)
Pe~l:"0 r:;. Hernandez, et al. v. Rail Prop, LLC, etc., et al.
(Los Angeles Superior Court Case No. NC 040 459)
(May 2003 -
Receiver (to sell screenplay copyrlght to satisfy judgment)
ACS Construction, LP, etc. v. PC And The Web, Inc., etc., et
-~---
al.
(Los Angeles Superior Court Case No. BC 281270)
(October 2003 -May 2004)
Counsel for Receiver (of West Los Angeles commercial real
property)
E.:~lbourY:-y_Corp., ~t al. v. Peter G . Joseph, et al.
(October 2003 - November 2005)
Partition Referee (of real property)
Sarah _S'-Le__ Bradford, etc. v. Rober_t E. Mitchell, etc.
(Los Angeles Superior Court Case No. VC 037 325)
(February 2004 - March 2005)
Provisional Director
In re LA--
~--,----
Cad, Inc.
(Los Angeles Superior Court Case No. YS 012 338)
(February 2004 - April 2004)
Counsel for Partition Referee
()!ga yar~~~ '~. Ofelia Zambrano, __~~

(March 2004 - June 2004)
Receiver (to close escrow following specific performance
judgment)
Man~~c~~b~_Q~1djie, et al. v. Barbara Darwish, et al.
(May 2004 - July 2006)
Receiver (of adult high school business)
Peop~_e v. California Alternative High School, etc., et al.
(Los Angeles Superior Court Case No. VC 042 820)
(August 2004 -
Partition Referee (of Los Angeles single family residence)
Lucille M. Collette v. Veronica-_.. Clee Franklin, et al.
---
Los Angeles Superior Court Case No. BC 299 907

(September 2004 - January 2005)
Receiver (to sell limited partnership interest)
Jo~~ __qoldri_c;h, etc. v. WLB-RSK Venture, etc., et al.
(February 2005)
Receiver (to sell liquor licenses to satisfy judgment)
~al i~orr.ia Parking Systems, _Inc. v. Cahuenga, Inc., etc., et
W: 9999~ ~~~ ?esume'~~JP Resume 06-17-05.doc

al.
(March 2005 - August 2005 and September 2006 - October 2007)
Receiver (of California Research and Assistance Fund)
People v. 21 st Century Insurance Co., etc.
(March 2005 - Present)
Expert witness (re Receiver's sale of patents, trademarks, etc.)
Ch~~§ Lacy etc. v. Burstein Technologies, Inc.
(Orange County Superior Court Case No. 03 CC 05254)
Partitlon Referee (to obtain certified appraisal of real
property)
Rolando
~
A. Calderon, et al. v. Maria Carmen Juarez, et al.
---------._-
(June 2005 - December 2005)
Provisional Director (of hair treatment salon business)
In re Euro Hair International, Inc.
(Los Angeles Superior Court Case No. SS 013 368)
(September 2005 - December 2006)
Receiver (to dissolve medical partnership)
Alec S. Koo, M.D., etc., et al. v. Norman R. Zinner, M.D.,
---- - ~ _ . ~ -
etc., et- al.

~ - _. ---
---~._- - -"

(September 2005 - August 2007)
Partition Referee (of Canyon Country and Siskyou County real
properties)
Gloria J. Paul-Schmidt, etc. v. Herma B. Neff, etc. i et al.
(May 2006 - July 2007)
Receiver (to collect judgment from operation of printing
business)
Avery Dennison Corporation, etc. v. S & 0 Development, Inc.,
etc.
(Orange County Superior Court Case No. 01 CCl2 646)
(July 2006 - September 2006)
Receiv~r (to sell real property per Penal Code § 186. ll(l))
People v. Magdalena Rosalia Zanoletti
(Los Angeles Superior Court Case No. BA 303 537)
(June 2007 - present)
Special Master (of 79 unit apartment/condominium complex)
~gmerica Bank, etc. v. Lexington 800, LLC, etc., et al.
(San Dlego Superior Court Case No. 37-2007-00S9972-CU-OR-EC)
(July 2007 - present)
Special Master (of 68 unit condominium development)
~. ?999 DCPResume\OJP Resume D6-17-0S.doc

Comerlca Bank, etc. v. 520 Mollison, LLC, etc., et al.
(San Diego Superior Court Case No. 37-2007-0059973-CU-OR-EC)
(July 2007 - present)
Commissioner (to close escrow)
Edward L. Marriott v. The DJJ Family Limited Partnership, et
al.
(August 2007 - present)
Partition Referee (of North Hollywood real property)
Valera Stepanenko v. Caran Ebert, et al.
(Los Angeles Superior Court Case No. EC 041 862)
Partition Referee (to sell Fontana real property)
Herbert Matsumoto, et al. v. Standley Tukuo Terada, et al.
(San Bernardino Superior Court Case No. SCVSS 142 886)
Receiver (of toy company and various real properties)
~n re Marriage of Cecilia Siu Wai Yee Lee and Shun Ming Lee
Receiver (of Palmdale housing development)
lNg_Bank, FSB, etc. v. First Pacifica Housing Corp. , etc., et
al.
(Los Angeles Superior Court Case No. MC 018 463)
Receiver (of multiple real properties and non-profit entity)
People v. Nigisti Tesfai, et al.
(Los Angeles Superior Court Case No. BA 328 605)
(October 2007 - present)
BAR ACTIVITIES
AMERICAN BAR ASSOCIATION (1976 - Present)

American Bar Association Fellow
Coordinating Committee on Gun Violence
Member (1997 - 1999)
Chair (1999 - 2002)
House of Delegates Select Committee (2000 - 2001)
Judicial Administration Division
(1981 - 1992)
Litlgation Section (1976 - Present)
1999 Midyear Meeting Advisory Committee (1998 - 1999)
Young Lawyers Division
Citizenship Education Committee
Vice-Chair (1985 - 1986)
W:\999 9'CJ? Pesume\DJP Resume 06-17 JSdoc

Member (1984 - 1985, 1986 - 1987)
Affiliate Assistance Program Vice-Chair (1985 - 1986)
Host CommIttee Co-Chair for Spring 1987 Meeting in Beverly
Hills
STATE BAR
MCLE Standing Committee (1990 - 1994)
Provider Approval Subcommittee Chair (1991)
Litigation Section Dinner Chair (1988)
State Bar Task Force On Lawyer Education (1988 - 1989)
Bench Bar Coalition (1996 - 1999)
LOS ANGELES COUNTY BAR ASSOCIATION (1976 - Present)

President (1997 - 1998)
President-Elect (1996 - 1997)
Senior Vice President (1995 - 1996)
Vice President and Treasurer (1994 - 1995)
Executive Committee (1983 - 1985, 1994 - 1998)
Board of Trustees (1983 - 1985; 1989 - 1991, 1994 - 1998)
Delegate to American Bar Association
House of Delegates (1986 - 1987, 1999 - Present)
Alternative Dispute Resolution Associates and Litigation,
Prejudgment Remedies, and Environmental Law Sections
Alternative Dispute Resolution Section Executive Committee
(1993 - 1996)
Litigation Section (Executive Committee, 1987 - 1996)
Chair (1994 - 1995)
Vice-Chair (1993 - 1994)
Treasurer (1992 - 1993)
Secretary (1991 - 1992)
Seminar Chair (1989 - 1990)
Program Chair (1988 - 1989)
Ad Hoc Committee On Gun Control
Chair (1993 - 1994)
Ad Hoc Committee On Changing Economics of the Practice of Law
1993 - 1994)
Ad Hoc Committee On Taxation of Services
Chair (1991)
Ad Hoc Committee To Study Court Unification
Chair (1991 - 1993)
ABA Relations Committee
Co-Chair (1986 - 1987)
Member (1987 - 1995)
Bicentennial of the Constitution Committee
Co-Chair (1984 - 1988)
W· 93999 DJP\Resume'DJP Resume 06-1' OS.doc

Member (1988 - 1991)
Dinner Chair (1989)
Continuing Legal Education Advisory Board (Rutter Committee)
(1982 - 1984, 1986 - 1988, 1989 - 1991)
Chair (1988 - 1989)
Continuing Legal Education Planning Committee
Chair (1989 - 1992)
Member (1988 - 1989,1992 - 1993)
Guns & Violence Committee
Cha i r ( 1999 - 2000)
Member (1994 - 1999,2000 - 2003)
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Los_J\ngE:_1_es DCii~y Journal Report 3 (June 19, 1981); and
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No. 82-6 ~~s Angeles Daily Jour~al~epor~ 18 (March 19, 1982)
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Handbook Provisional
------
Remedies.
---- - - ------
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~: 99999 D~P\Resume\D:P Resume C6-17-0S.doc

',= : 15 17 'I 2 ~:.. J(
~J:2If)I~':
1 DECLARATION OF CHRISTfNA PUGH

I
')1 I, Christina Pugh. state and declare as follows:
"-:
3 I. I am an independent loan processor and work for Pacific Mortgage
4 II Consultants.
5 2. Sometime after August 9,2007, Ms. Samaan retained the services
6 II Pacitic Mortgage Consultants procure her loan for purchase of the Property located at 320
7 i S. Peck Drive, Beverly Hills. California (the "Property").
8 3. Upon learning ofPacitic Mortgage Consultant's involvement with Ms.
9 Samaan's loan. Mr. Zernik sent us emails claiming that the transaction for purchase of the
10 Property invohed "fraud" and threatened them with a complaint to the California
II Department of Real Estate ifthey did not immediately cease participating in the
12 transaction. Attached hereto as Exhibit C are true and correct copies of emails sent by
13 Zemik to Pacific Mortgage Consultants.
14 1declare under penalty of pedury under the laws of the State of California
15 II that the foregoing is true and correct.
16 Executed on October ~. 2007 at I .1 cxxitucei , California.
okJ£\*
17
18
CHRISTINA PUGF
19
20
21
22
23
24
25
26
27
28
WO)·WEST : ~MKIAOO50J252 I
-1-
DECLARA TJO~ OF CHRlSTP."A PUGH

Page I of I
Moe Keshavarzi
From: Christina Pugh [pughchristina@sbcglobal.net]

Sent: Friday, October 26, 2007 120 PM
To: Moe Keshavarzi
Subject: FWD Brief Update - 10/11/07 Judge O'Brien, ADR resign
Attachments: 07-10-13 BRIEF REVIEW [sig].pdf
---------- Forwarded Message ----------
FROM: joseph zernik <jz12345@earthlink.net>

TO: "Bruce Kocen- PMC" <bruce@pmloans.com>
DATE: Sat, 13 Oct 2007 18:25:29 -0700
RE: Brief Update - 10/11/07 Judge O'Brien, ADR resign
FYI:
1) A brief update is attached.
2) I still expect notification from each of you separately -

That any and all actions taken against the property at 320 South
Peck, BH CA 90212, without authorization by the owner, Joseph Zernik,
and without any other valid legal authorization that you could
document, were withdrawn and voided.
Joseph Zernik

10/26/2007 ZERNIK V CONNOR ET AL
Page I of 3
Moe Keshavarzi
From: Christina Pugh [pughchristina@sbcglobal.net]

Sent: Friday, October 26, 2007 1: 12 PM
To: Moe Keshavarzi
Subject: FWD Fwd LEGAL NOTICE: TIME IS OF THE ESSENCE. DEMAND FOR DOCUMENTS. ORDER
#80701422-77
----------------------- Forwarded Message -----------------------
From: joseph zernik <jz12345@earthllnk.net>

To: "Bruce Kocen- PMC" <bruce@pmloans.com>
Date: Fri, 19 Oct 2007 22:55:50 -0700
Subject: Fwd: LEGAL NOTICE: TIME IS OF THE ESSENCE. DEMAND FOR DOCUMENTS. ORDER
#80701422-77
October 19, 2007
Ladies and Gentlemen:
[ have never heard back from any of you following the message below. Claims of fraud and deceit
should not be lightly made, and never lightly taken by anybody operating in the financial industry.
Therefore. the utter silence is questionable ... But then again. possibly Mr Parks took his cue from Judge
Connor. who when face with similar claims, just declared that she was not admitting any of them and
recused hersel f from the case...
Michael James O'Reilly. PMC, has the duty to supervise Mr Parks, and therefore, I expect at least a
response from PMC so that I do not have to burden the California Department of Real Estate with a
complaint.
Joseph Zernik
Date: Tue. 09 Oct 2007 01 :28:57 -0700

To: "Dzien, Kenneth" <kdzien@LANDAM.com>
From: joseph zernik <jzI2345@earthlink.net>
Subject: LEGAL NOTICE: TIME IS OF THE ESSENCE. DEMAND FOR
DOCUMENTS. ORDER #80701422-77
Cc: , "Ms Alvenvson - United Title" <salverson@unitedtitle.com>. "Christina Pugh- PMC"
<pughchristina((l!sbcglobaLnet>, "Ty - Preferred Appraisals" <request@prefapp.com>
October 8, 2007
Mr Dzien, Ms Alverson - United Title


10/2612007 ZERNIK V CONNOR ET AL
Page:2 of 3
Sir/Madam:
in a n:al estate transaction. I called your respective offices and requested that you produce
evidence that Victor Parks was authorized by la\v to do so. None of you provided any
evidence like that.
PLEASE TAKE NOTICE:

For example:
Victor Parks. One I identifY as the Northern California type, and the other is the Southern
Cali fornia type. But none bears any semblance to Victor Parks' signature on declarations in
court.
Therefore. the signature used on a Prequaliflcation Letter. dated Sept 7. 2004, presented by
court. Victor Parks and Samaan, failed to include that document in subpoena production, in
fact disowning it. When I introduced it, as an example of fraud perpetrated jointly by
of "improper authentication". With that, in fact, they admitted that it was a case of
forgery.
On the other hand, Samaan's 1003, which too - had no base in reality, was signed by the
signature at all. In that document the signature indicates that Parks interviewed Samaan
and entered that loan application. In deposition, Samaan stated that Parks had nothing to do
Also. in our transaction, Samaan (in LA) routinely sent and received fax communications
Fraud against an Individual, and also Wire Fraud against a Financial Institution. Parks'
fax line automatically forwarded to Samaan's fax line. And when sending documents under
his personality, she would set her machine to show no header ID.
In short. you are provided more than sufficient warning. I demand to see any documents

Page 3 of 3

INSTITVTION:
http: /homc.carthlink.netJ~jz I2345/COUNTRYWIDE/04-1 0- I8-gemailsonwirefraud.pdf
Parks failed to respond, in fact tacitly admitting that his fax communications were
automatically diverted to Samaan all along without our knowledge.
b) BANK FRAVD AGAINST A GOVERNMENT BACKED LENDER:

http://homc.carthlink.netl-jzl2345/COUNTRYWl DE/04-09-27-1 OOJp 1-4.pdf
Note double Receipt Date stamps page I
C)FRAVDULENTINDUCEMENT
http://home.carthlink.netl~jzI2345/COUNTRYWIDE/04-09-07prequalificationletter. pdf
d) FRAUD
http://home.carthlink.netl~jz1 2345/COUNTRYWIDE/06-1 0-
27parkssignaturei ncourtgec laration. pdf
Prudence suggest that you stay away from invol vement in such dealings. The statements
above are not the kind that are made lightly. and definitely not the type that would be taken
share this communication with Mr Parks, and try to get his response in writing. I would be
circumstances.
Joseph Zernik

PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
3 I am employed in the County of Los Angeles; I am over the age of eighteen

years and not a party to the within entitled action; my business address is 333 South Hope
4 II Street, 48th Floor, Los Angeles, California 90071-1448.
5 liOn October 26,2007, I served the following document(s) described as PLAINTIFF

NIVIE SAMAAN'S NOTICE OF MOTION AND MOTION FOR APPOINTMENT
6 II OF RECEIVER on the interested party(ies) in this action by placing true copies thereof
encloscd in scaled envelopes and/or packages addressed as follows:
7
Robert J. Shulkin, Esq. Joseph Zcrnik
8 The Law Department 320 S. Peck Drive
Coldwell Banker Residential Beverly Hills, California 90212
9 Brokerage Company iz12345@.earthlink.net
I 161 1 San Vicente Blvd., Ninth Floor
10 Los Angeles, CA 90049-6510
Facsimile: (310) 447-1902
11 robc11.shulkin(clicamoves.com
12 0 BY MAIL: I am "readily familiar" with the firm's practice of collection and

processing correspondence for mailing. Under that practice it would be deposited
13 with the U.S. postal service on that same day with postage thereon fully prepaid at
Los Angeles, California in the ordinary course of business. I am aware that on
14 motion of the party served, service is presumed invalid if postal cancellation date or
postage meter date is more than one day after date of deposit for mailing in
15 affidavit.
16110 BY OVERNIGHT DELIVERY: I served such envelope or package to be

delivered on the same day to an authorized courier or driver authorized by the
17 overnight service carrier to receive documents, in an envelope or package
designated by the overnight service carrier.
18 ..
~ BY HAND DELIVERY: I caused such envelope(s) to be delivered by hand to the
"
19 office of the addressee(s).
20 0 BY ELECTRONIC MAIL: I caused to be prepared and sent an email to the party

listed below at the e-mail address shown on the service list.
21 ..
~ STATE: I declare under penalty of perjury under the laws of the State of
22 California that the foregoing is true and correct.
23 Executed on October 26, 2007, at Los Angeles, California.

24
25
David Zasloff
26
27
28


07-11-09 Samaan V Zernik (SC087400) Nivie Samaan: Sheppard Mullin's Motion To Appoint Pasternak Receiver S

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07-11-09 Samaan V Zernik (SC087400) Nivie Samaan: Sheppard Mullin's Motion To Appoint Pasternak Receiver S

Diunggah oleh

Hak Cipta:

Format Tersedia

Digitally signed

07-11-09. Samaan’s Motion for Order Appointing Pasternak Receiver

The order is deemed fraud by the court on numerous counts:

A Limited Liability Partnership

2 Including Professional Corporations

PHILLIP A. DAVIS, Cal. Bar No. 110430

3 MOE KESHAVARZI, Cal. Bar No. 223759

333 South Hope Street, 48th Floor

4 Los Angeles., California 90071-1448

. ,- ·i:::··.~- -. ~_ ~~._ .. " .:

Attorneys for Plaintiff Nivie Samaan

10 FOR THE COUNTY OF LOS ANGELES -- WEST DISTRICT

II NIVIE SAMAAN, an individual; Case No. SC 087400

12 Plaintiff, Honorable John L. Segal

13 v. PLAINTIFF NIVIE SAMAAN'S

Exh p 2 EXHIBITS VOL V - RECEIVERSHIP

2l A. The Court Enters Judgment in Favor of Samaan, Orders Zernik to Sell

22 the Property and Appoints a Referee Recommended by Zernik.

23 On August 8, 2007, the Court (the Honorable Jacqueline A. Connor,

Exh p 5 EXHIBITS VOL V - RECEIVERSHIP

7 demanded that we [United Title] cancel the order." (~)

Among these ex parte applications are Zemik's repeated requests for

6 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

9 Attorneys for Plaintiff

1 DECLARATION OF SHERI ALVERSON

2 I, Sheri Alverson, state and declare as follows:

3 1. I am the office manager of Westlake Village office of United Title

6 2. On or about September 26, 2007, United Title was requested to open

From: joseph zernik IJz12345@earthlink.net]

SENT BY EMAIL AND BY FAX

[ received a letter (attached) dated September 27,2007, signed by

Cindy MarkOVich, Title Officer, United Title Company. That letter

falsely stated that I selected your otlice to provide title insurance

for my "current real estate sale or refinance transaction".

None of that is true.

Mortgage Consultants. They were surprised to hear that I had never

approached V ictor Parks in th is regard.

Ms Alverson and Terry both promised me that the letter wasjust a

safety instrument required by law for that purpose, moreover, Ms

Alverson promised me that she was closing that order #80701422-77, as

we were speaking on the phone.

Both promised me fax to contirm such understanding within 15-30 minutes.

When 1 called back more than 30 minutes later, Ms Alverson brought Mr

written demand from me to close order ;,80701422-77 , which is hereby served.

to stop such fraudulent action is astonishing' Your conduct raises

violation of the terms of you Lcense.

Please contirm no later than 2 OOpm today, Wed, Oct 3, 2007,

that order #80701422-77 was irreversibly and permanently

closed. Please send copies by email, for expediency, and by fax, so

that [ have the hand signature image on it.

320 South Peck Drive

Exh p 12 EXHIBITS VOL V - RECEIVERSHIP

hvd: ORDER #80701422-77 Page 1 of 3

From: Joseph zernik Uz 12345@earthlink.net]

Sent: Wednesday, October 03,2007 12:53 PM

To: Alverson, Sheri

Subject: Fwd ORDER #80701422-77

Pkasc take notice.

This is to confirm that you acknowledged by phone receit of the email

[ expect your immediate attention to this matter to mitigate harm.

Date: Wed. 3 Oct 2007 12:00:22 -0700

'Subjtct: Successful transmi~,sion to 18009318888. Re:

-X-ELNK-Info: sbv~O: sbrc=.O; sbf=OO: sbw=OOO: