Preview
CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Sl!l(e Ber number, end ltddrws): FOR COURT USE OM.Y
Tanzeel Hak (SBN 331248) I]
940 Saratoga Avenue #112
San Jose, CA 95129
TELEPHONENO.: (510) 362-6791 FAXNO. (Optionsl):
E-MAILAODRESs (Optfonal): tanzeel@bythelaw.co
ATTORNEY FO R (NameJ: Sean Tabatabai
SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Cruz
STREET ADDR Ess: 701 Ocean Street
MAILN
I GADDRESS:
c1TY AND z1P coDE: Santa Cruz, CA 95060
BRANCH NAME:
PLAINTIFF/PETITIONER: Shahram Tabatabai
DEFENDANT/RESPONDENT: Jeanne Turner
CASE MANAGEMENT STATEMENT CASENUMBER:
(Check one): w UNLIMITED CASE
(Amount demanded
D LIMITED CASE
(Amount demanded is $25,000
18CV02004
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: 5/15/2023 Time: 8:30 a.m. Dept.: 5 Div.: Civil Room:
Address of court (if different from the address above):
[LI Notice of Intent to Appear by Telephone, by (name): Tanzeel Hak
INSTRUCTIONS: All appllcable boxes must be checked, and the specified Information must be provided.
1. Party or parties (answer one):
a. W This statement is submitted by party (name): Cross-Complainant/Plaintiff Shahram Tabatabai
b. D This statement Is submitted Jointly by parties (names):
2. Complalnt and cross-complalnt (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): July 9, 2018
b. W The cross-complaint, if any, was filed on (d ate): 1/30/19
3. Service (to be answered by plaintiffs and cross-complainants only)
a. D All parties named In the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. W The following parties named in the complaint or cross-complaint
(1) D have not been served (specify names and explain why not):
(2) D have been served but have not appeared and have not been dismissed (specify names):
(3) W have had a default entered against them (specify names):
Deborah Olinyk
C. D The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be seNed):
4. Description of case
a. Type of case in W complaint W cross-complaint (Describe, including causes of action):
Please refer to attad1ment.
P 1 ors
Fonn Adopted for Mandatory Uee
Judldal Council of Callfomla
CASE MANAGEMENT STATEMENT Cal. Rules of Court,
rulea 3. 720--3. 730
CM-110 [Rev. July 1, 2011] www.ooutfll.ca.gov
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Nemat Maleksalehi
- 18CV02004
DEFENDANT/RESPONDENT: Shahram Tabatabai, Jeanne Turner
4. b. Provide a brief statement of the case, including any damages. (ff personal injury damages are sought, specify the injury and
damages claimed, Including medical expenses to date [Indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief Is sought, describe the nature of the relief.)
Please refer to attachment.
W (If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trlal
The party or parties request W a jury trial D a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. D The trial has been set for (date):
b. W No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
Original date was vacated.
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
7. Estimated length of trlal
The party or parties estimate that the trial will take (check one):
a. W days (specify number): 7-10 days
b. D hours (short causes) (specify):
8. Trlal representation (to be answered for each party)
The party or parties will be represented at trial [ZJ by the attorney or party listed in the caption D by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
D Additional representation is described in Attachment 8.
9. Preference
D This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR Information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 for Information about the processes available through the
court and community programs In this case.
(1) For parties represented by counsel: Counsel Dx has D has not provided the ADR information package identified
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party ------
W has D has not reviewed the ADR Information package identified In rule 3.221.
b. Referral to Judlclal arbitration or clvll action mediation (If available).
(1) D This matter Is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount In controversy does not exceed the
statutory limit.
(2) D Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified In Code of
Civil Procedure section 1141 . 11.
(3) D This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courter from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM-110 [Rev. July 1, 2011] Page 2 of 5
CASE MANAGEMENT STATEMENT
CM-110
CASE NUMBER:
PLAINTIFF/PETITIONER: Nemat Maleksalehi
18CV02004
DEFENDANT/RESPONDENT: Shahr am Tabatabai, Jeanne Turner
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate In, or
have already participated in (check all that apply and provide the specif,ed infonnation):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are wllllng to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the perties' ADR
processes (check all that apply): stipulation):
D Mediation session not yet scheduled
D D Mediation session scheduled for (date):
(1) Mediation
D Agreed to complete mediation by (date):
m Mediation completed on (date): 1/5/2022
m Settlement conference not yet scheduled
(2) Settlement [2J D Settlement conference scheduled for (date):
conference
D Agreed to complete settlement conference by (date):
D Settlement conference completed on (date):
D Neutral evaluation not yet scheduled
(3) Neutral evaluation D D Neutral evaluation scheduled for (date):
D Agreed to complete neutral evaluation by (date):
D Neutral evaluation completed on (date):
D Judicial arbitration not yet scheduled
(4) Nonbinding judicial D D Judicial arbitration scheduled for (date):
arbitration
D Agreed to complete judicial arbitration by (date):
D Judicial arbitration completed on (date):
D Private arbitration not yet scheduled
(5) Binding private D D Private arbitration scheduled for (date):
arbitration
D Agreed to complete private arbitration by (date):
D Private arbitration completed on (date):
D ADR session not yet scheduled
D D ADR session scheduled for (date):
(6) Other (specify):
D Agreed to complete ADR session by (date):
D ADR completed on (date):
CM-110 [Rev. July 1, 20111
CASE MANAGEMENT STATEMENT
ru.11n
CASE NUMBER:
PLAINTIFF/PETITIONER: Nemat Maleksalehi
18CV02004
DEFENDANT/RESPONDENT: Shahram Tabatabai, Jeanne Turner
11. Insurance
a. D Insurance carrier, If any, for party filing this statement (name):
b. Reservation of rights: D Yes D No
c. D Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
D Bankruptcy D Other (specify):
Status:
13. Related cases, consolidation, and coordination
D There are companion, underlying, or related cases.
a. [2J
(1) Name of case: In re marriage of Tabatabai
(2) Name of court: Santa Cruz Superior Court
(3) Case number: 16FL00655
(4) Status: pending as to evaluations of property division
D Additional cases are described in Attachment 13a.
b. D A motion to D consolidate D coordinate will be filed by (name perty):
14. Bifurcation
D The party or parties Intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. other motions
D The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
16. Discovery
a. D The party or parties have completed all discovery.
b. D The following discovery will be completed by the date specified (describe all anticipated discovery):
� Description Date
c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. July 1, 2011]
CASE MANAGEMENT STATEMENT "-Ge 4ot5
CM-110
PLAINTIFF/PETITIONER: Nemat Maleksalehi CASE NUMBER:
18CV02004
DEFENDANT/RESPONDENT: Shahram Tabatabai, Jeanne Turner
17. Economic litigation
a. D
This is a limited civil case (i.e., the amount demanded Is $25,000 or less) and the economic litigation procedures In Code
of Civil Procedure sections 90-98 will apply to this case.
b. D This is a limited civil case and a motion to withdraw the case from the economic lltlgatlon procedures or for additional
discovery will be flied (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other Issues
D The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a. D
The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules
of Court (If not, explain):
b. After meeting and conferring as required by rule 3. 724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any): 2
I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, Including the written authority of the party where required.
Date: 4/28/2023
Tanzeel Hak â–º
(TYPE OR PRINT NAME)
(lYPE OR PRINT NAME)
â–º (SIGNATURE OF PAR1Y OR ATTORNEY)
D Addltlonal signatures are attached.
Cl\4-110 [Rev. July 1, 2011]
CASE MANAGEMENT STATEMENT Page 5of 5
MC-025
CASE NUMBER:
SHORT TITLE:
- Maleksalehi v. Tabatabai et al 18CV02004
ATTACHMENT (Number): _4_
A_ _ _ __
(This Attachment may be used with any Judicial Council form.)
The Maleksalehi Complaint's causes of action are breach of contract, interference w/ economic advantage, and
breach of fiduciary duty.
The Sean Tabatabai Cross-Complaint's causes of action are intentional interference with contractual relations
and conspiracy to interfere with contractual relations, intentional interference with prospective economic
advantage and conspiracy to interfere with prospective economic advantage, fraudulent transfer, libel, slander,
equitable indemnity.
(If the item that this Attachment concerns is made under penalty of perjury, all statements In this Page 1 of 1
Attachment are made under penalty of perjury.)
(Add pages as required)
Form Approved for Optional Use
ATTACHMENT www.courttnro.cs.gov
Judicial Col6lcll of California
MC-025 [Rev. July 1, 2009) to Judicial Council Fonn
MC-025
CASE NUMBER:
SHORT TITLE:
- Maleksalehi v. Tabatabai et al 18CV02004
ATTACHMENT (Number): _4_B_ _ _ __
(This Attachment may be used with any Judicial Council form.)
Plaintiffs Complaint against Sean Tabatabai and Jeanne Turner. The premise of this lawsuit is that Plaintiff
had loaned money to the community for community businesses. Further installments were made and were
corporate loans. Enabledware was unable to pay back the loan to Plaintiff after multiple sales for the company
failed.
Sean Tabatabai's cross-complaint focuses on Enabledware's failed sales to NXChain and Verify Smart. The
money from the sales would have been used to pay all of Enabledware's debts and loans. The remainder was
intended to be used as a retirement fund for the Tabatabais. The cross-complaint focuses on the actions of
Cross-Defendants that affected Sean Tabatabai and Enabledware's reputability that detrimentally impacted
both sales. The damages are to pay for the loan and failed sales.
(Please note that "Plaintiff" refers to the original Plaintiff, Mr. Maleksalehi)
(If the item that this Attachment concerns Is made under penalty of perjury, all statements in this Paga 1 of 1
Attachment are made under penalty of perjury.)
(Add peges as required)
Form Approved for OpUonal Use www.courlfnfo.c•.gov
Judldal Cot.ncll of Cellfomla ATTACHMENT
MC-025 (Rev, July 1, 2009] to Judlclal Council Fonn
PROOF OF SERVICE
1 I am a resident of the State of California, over the age of eighteen years, and not a party to the within
action. My business address is 940 Saratoga Avenue #112, San Jose, CA 95129. On date below, I
2 served the within document:
3
CM-110
4
[ ] BY PERSONAL DELIVERY: I caused each such envelope to be delivered by hand to the offices
5 of each addressee below.
6
[ ] BY MAIL: I deposited such envelope, with postage thereon fully prepaid, to be placed in the
7 United States mail at San Jose, California to each addressee below.
8 [ ] VIA FACSIMILE: I faxed said document to be transmitted by facsimile transmission to each
9 addressee below. The transmitting facsimile machine reported the transmission complete and without
error.
10
[ x ] BY ELECTRONIC TRANSMISSION: I transmitted this document by electronic mail to each
11
addressee below.
12
[ ] BY OVERNIGHT DELIVERY: I deposited such envelope for collection and delivery by Federal
13 Express with delivery fees paid or provided for in accordance with ordinary business practices.
14
Service was made on the parties involved addressed as follows:
15
Lesley Harris
16 Law offices of Lesley Harris
17 55 River Street, Suite 100
Santa Cruz, CA 95060
18 Email: lesleyharrisesq@gmail.com
19 Robert Lindow
20 P.O. Box 2107
Aptos, CA 95001
21 Email: lindow1@gmail.com
22
23
24 I declare under penalty of perjury under the laws of the State of California that the above is
true and correct. Executed on April 28, 2023, at San Jose, California.
25 ________/s/__________
26 Tanzeel Hak
27
28
_________________________________________________________________________________
PROOF OF SERVICE
-1-
Preview
CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Sl!l(e Ber number, end ltddrws): FOR COURT USE OM.Y Tanzeel Hak (SBN 331248) I] 940 Saratoga Avenue #112 San Jose, CA 95129 TELEPHONENO.: (510) 362-6791 FAXNO. (Optionsl): E-MAILAODRESs (Optfonal): tanzeel@bythelaw.co ATTORNEY FO R (NameJ: Sean Tabatabai SUPERIOR COURT OF CALIFORNIA, COUNTY OF Santa Cruz STREET ADDR Ess: 701 Ocean Street MAILN I GADDRESS: c1TY AND z1P coDE: Santa Cruz, CA 95060 BRANCH NAME: PLAINTIFF/PETITIONER: Shahram Tabatabai DEFENDANT/RESPONDENT: Jeanne Turner CASE MANAGEMENT STATEMENT CASENUMBER: (Check one): w UNLIMITED CASE (Amount demanded D LIMITED CASE (Amount demanded is $25,000 18CV02004 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 5/15/2023 Time: 8:30 a.m. Dept.: 5 Div.: Civil Room: Address of court (if different from the address above): [LI Notice of Intent to Appear by Telephone, by (name): Tanzeel Hak INSTRUCTIONS: All appllcable boxes must be checked, and the specified Information must be provided. 1. Party or parties (answer one): a. W This statement is submitted by party (name): Cross-Complainant/Plaintiff Shahram Tabatabai b. D This statement Is submitted Jointly by parties (names): 2. Complalnt and cross-complalnt (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): July 9, 2018 b. W The cross-complaint, if any, was filed on (d ate): 1/30/19 3. Service (to be answered by plaintiffs and cross-complainants only) a. D All parties named In the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. W The following parties named in the complaint or cross-complaint (1) D have not been served (specify names and explain why not): (2) D have been served but have not appeared and have not been dismissed (specify names): (3) W have had a default entered against them (specify names): Deborah Olinyk C. D The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be seNed): 4. Description of case a. Type of case in W complaint W cross-complaint (Describe, including causes of action): Please refer to attad1ment. P 1 ors Fonn Adopted for Mandatory Uee Judldal Council of Callfomla CASE MANAGEMENT STATEMENT Cal. Rules of Court, rulea 3. 720--3. 730 CM-110 [Rev. July 1, 2011] www.ooutfll.ca.gov CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Nemat Maleksalehi - 18CV02004 DEFENDANT/RESPONDENT: Shahram Tabatabai, Jeanne Turner 4. b. Provide a brief statement of the case, including any damages. (ff personal injury damages are sought, specify the injury and damages claimed, Including medical expenses to date [Indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief Is sought, describe the nature of the relief.) Please refer to attachment. W (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trlal The party or parties request W a jury trial D a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. D The trial has been set for (date): b. W No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): Original date was vacated. c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): 7. Estimated length of trlal The party or parties estimate that the trial will take (check one): a. W days (specify number): 7-10 days b. D hours (short causes) (specify): 8. Trlal representation (to be answered for each party) The party or parties will be represented at trial [ZJ by the attorney or party listed in the caption D by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: D Additional representation is described in Attachment 8. 9. Preference D This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR Information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 for Information about the processes available through the court and community programs In this case. (1) For parties represented by counsel: Counsel Dx has D has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party ------ W has D has not reviewed the ADR Information package identified In rule 3.221. b. Referral to Judlclal arbitration or clvll action mediation (If available). (1) D This matter Is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount In controversy does not exceed the statutory limit. (2) D Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified In Code of Civil Procedure section 1141 . 11. (3) D This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Courter from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-110 [Rev. July 1, 2011] Page 2 of 5 CASE MANAGEMENT STATEMENT CM-110 CASE NUMBER: PLAINTIFF/PETITIONER: Nemat Maleksalehi 18CV02004 DEFENDANT/RESPONDENT: Shahr am Tabatabai, Jeanne Turner 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate In, or have already participated in (check all that apply and provide the specif,ed infonnation): The party or parties completing If the party or parties completing this form in the case have agreed to this form are wllllng to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the perties' ADR processes (check all that apply): stipulation): D Mediation session not yet scheduled D D Mediation session scheduled for (date): (1) Mediation D Agreed to complete mediation by (date): m Mediation completed on (date): 1/5/2022 m Settlement conference not yet scheduled (2) Settlement [2J D Settlement conference scheduled for (date): conference D Agreed to complete settlement conference by (date): D Settlement conference completed on (date): D Neutral evaluation not yet scheduled (3) Neutral evaluation D D Neutral evaluation scheduled for (date): D Agreed to complete neutral evaluation by (date): D Neutral evaluation completed on (date): D Judicial arbitration not yet scheduled (4) Nonbinding judicial D D Judicial arbitration scheduled for (date): arbitration D Agreed to complete judicial arbitration by (date): D Judicial arbitration completed on (date): D Private arbitration not yet scheduled (5) Binding private D D Private arbitration scheduled for (date): arbitration D Agreed to complete private arbitration by (date): D Private arbitration completed on (date): D ADR session not yet scheduled D D ADR session scheduled for (date): (6) Other (specify): D Agreed to complete ADR session by (date): D ADR completed on (date): CM-110 [Rev. July 1, 20111 CASE MANAGEMENT STATEMENT ru.11n CASE NUMBER: PLAINTIFF/PETITIONER: Nemat Maleksalehi 18CV02004 DEFENDANT/RESPONDENT: Shahram Tabatabai, Jeanne Turner 11. Insurance a. D Insurance carrier, If any, for party filing this statement (name): b. Reservation of rights: D Yes D No c. D Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. D Bankruptcy D Other (specify): Status: 13. Related cases, consolidation, and coordination D There are companion, underlying, or related cases. a. [2J (1) Name of case: In re marriage of Tabatabai (2) Name of court: Santa Cruz Superior Court (3) Case number: 16FL00655 (4) Status: pending as to evaluations of property division D Additional cases are described in Attachment 13a. b. D A motion to D consolidate D coordinate will be filed by (name perty): 14. Bifurcation D The party or parties Intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. other motions D The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. D The party or parties have completed all discovery. b. D The following discovery will be completed by the date specified (describe all anticipated discovery): � Description Date c. D The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT "-Ge 4ot5 CM-110 PLAINTIFF/PETITIONER: Nemat Maleksalehi CASE NUMBER: 18CV02004 DEFENDANT/RESPONDENT: Shahram Tabatabai, Jeanne Turner 17. Economic litigation a. D This is a limited civil case (i.e., the amount demanded Is $25,000 or less) and the economic litigation procedures In Code of Civil Procedure sections 90-98 will apply to this case. b. D This is a limited civil case and a motion to withdraw the case from the economic lltlgatlon procedures or for additional discovery will be flied (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other Issues D The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. D The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (If not, explain): b. After meeting and conferring as required by rule 3. 724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 2 I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, Including the written authority of the party where required. Date: 4/28/2023 Tanzeel Hak ► (TYPE OR PRINT NAME) (lYPE OR PRINT NAME) ► (SIGNATURE OF PAR1Y OR ATTORNEY) D Addltlonal signatures are attached. Cl\4-110 [Rev. July 1, 2011] CASE MANAGEMENT STATEMENT Page 5of 5 MC-025 CASE NUMBER: SHORT TITLE: - Maleksalehi v. Tabatabai et al 18CV02004 ATTACHMENT (Number): _4_ A_ _ _ __ (This Attachment may be used with any Judicial Council form.) The Maleksalehi Complaint's causes of action are breach of contract, interference w/ economic advantage, and breach of fiduciary duty. The Sean Tabatabai Cross-Complaint's causes of action are intentional interference with contractual relations and conspiracy to interfere with contractual relations, intentional interference with prospective economic advantage and conspiracy to interfere with prospective economic advantage, fraudulent transfer, libel, slander, equitable indemnity. (If the item that this Attachment concerns is made under penalty of perjury, all statements In this Page 1 of 1 Attachment are made under penalty of perjury.) (Add pages as required) Form Approved for Optional Use ATTACHMENT www.courttnro.cs.gov Judicial Col6lcll of California MC-025 [Rev. July 1, 2009) to Judicial Council Fonn MC-025 CASE NUMBER: SHORT TITLE: - Maleksalehi v. Tabatabai et al 18CV02004 ATTACHMENT (Number): _4_B_ _ _ __ (This Attachment may be used with any Judicial Council form.) Plaintiffs Complaint against Sean Tabatabai and Jeanne Turner. The premise of this lawsuit is that Plaintiff had loaned money to the community for community businesses. Further installments were made and were corporate loans. Enabledware was unable to pay back the loan to Plaintiff after multiple sales for the company failed. Sean Tabatabai's cross-complaint focuses on Enabledware's failed sales to NXChain and Verify Smart. The money from the sales would have been used to pay all of Enabledware's debts and loans. The remainder was intended to be used as a retirement fund for the Tabatabais. The cross-complaint focuses on the actions of Cross-Defendants that affected Sean Tabatabai and Enabledware's reputability that detrimentally impacted both sales. The damages are to pay for the loan and failed sales. (Please note that "Plaintiff" refers to the original Plaintiff, Mr. Maleksalehi) (If the item that this Attachment concerns Is made under penalty of perjury, all statements in this Paga 1 of 1 Attachment are made under penalty of perjury.) (Add peges as required) Form Approved for OpUonal Use www.courlfnfo.c•.gov Judldal Cot.ncll of Cellfomla ATTACHMENT MC-025 (Rev, July 1, 2009] to Judlclal Council Fonn PROOF OF SERVICE 1 I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is 940 Saratoga Avenue #112, San Jose, CA 95129. On date below, I 2 served the within document: 3 CM-110 4 [ ] BY PERSONAL DELIVERY: I caused each such envelope to be delivered by hand to the offices 5 of each addressee below. 6 [ ] BY MAIL: I deposited such envelope, with postage thereon fully prepaid, to be placed in the 7 United States mail at San Jose, California to each addressee below. 8 [ ] VIA FACSIMILE: I faxed said document to be transmitted by facsimile transmission to each 9 addressee below. The transmitting facsimile machine reported the transmission complete and without error. 10 [ x ] BY ELECTRONIC TRANSMISSION: I transmitted this document by electronic mail to each 11 addressee below. 12 [ ] BY OVERNIGHT DELIVERY: I deposited such envelope for collection and delivery by Federal 13 Express with delivery fees paid or provided for in accordance with ordinary business practices. 14 Service was made on the parties involved addressed as follows: 15 Lesley Harris 16 Law offices of Lesley Harris 17 55 River Street, Suite 100 Santa Cruz, CA 95060 18 Email: lesleyharrisesq@gmail.com 19 Robert Lindow 20 P.O. Box 2107 Aptos, CA 95001 21 Email: lindow1@gmail.com 22 23 24 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed on April 28, 2023, at San Jose, California. 25 ________/s/__________ 26 Tanzeel Hak 27 28 _________________________________________________________________________________ PROOF OF SERVICE -1-