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Tanzeel Hak, State Bar No., 331248
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By the Law, APC
940 Saratoga Ave., #112,
3 San Jose, CA 95129
Tel: (510) 362-6791
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Email: tanzeel@bythelaw.co
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6 Attorney for Sean Tabatabai,
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Plaintiff, Cross-Complainant
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9 SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 IN AND FOR THE COUNTY OF SANTA CRUZ
11 Unlimited Jurisdiction
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NEMAT MALEKSALEHI, Case No.: 18CV02004
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PLAINTIFF SHAHRAM
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Plaintiff, TABATABAI’S DECLARATION
vs. RE: ROBERT LINDOW’S CASE
15 MANAGEMENT STATEMENT
SHAHRAM TABATABAI, an individual; JEANNE Date: 5/15/2023
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TURNER TABATABAI, an individual; and DOES Time: 8:30 a.m.
17 1 through 10 inclusive Dept.: 5
Hon. Timothy Volkmann
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Defendants.
19 ____________________________________________
SHAHRAM TABATABAI,
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Cross-Complainant,
22 vs.
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JEANNE TURNER TABATABAI, an individual;
24 ROBERT LINDOW, an individual; DEBORAH
OLINYK, an individual, Any Cross-Defendant,
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and ROES 1-15.
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Cross-Defendants.
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PLAINTIFF SHAHRAM TABATABAI’S DECLARATION RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 1
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JEANNE TURNER TABATABAI,
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Cross-Complainant,
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vs.
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5 NEMAT MALEKSALEHI, SHAHRAM
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TABATABAI, and ROES 1 through 10,
7 Cross-Defendants.
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DECLARATION OF SHAHRAM TABATABAI
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I, Shahram Tabatabai, under the penalty of perjury under the laws of the state of
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California, declare:
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1. I am the Plaintiff and Cross-Complainant in this matter at this particular time.
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2. If called upon as a witness, I could and would competently testify as to the
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truthfulness of the following facts, all of which are within my own personal
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knowledge except for those stated on information and belief, and as to those, I
16 am informed and believe them to be true. I request that the court receive this
17 declaration into evidence as my direct testimony.
18 3. This declaration is not intended to be, nor should it be construed as being a
19 waiver of any information protected by any applicable privilege including
20 privacy, confidentiality, attorney-client privilege or the attorney work-product
21 doctrine. The matters set forth herein were stated and/or observed in non-
22 privileged settings and are not the result of privileged work-product matters.
23 4. After reviewing Mr. Lindow’s Case Management Statement that was provided to
24 me by Mr. Hak, I simply felt obligated to respond.
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5. Given that my attorney will attend the case management conference on my
behalf, and I will not be participating, I believe this was the appropriate venue in
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addressing Mr. Lindow.
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PLAINTIFF SHAHRAM TABATABAI’S DECLARATION RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 2
6. Upon the Court’s own review of Mr. Lindow’s Case Management Statement, it
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will realize that Mr. Lindow is continuing to provide his non-sensical,
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unsubstantiated statements.
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7. His Case Management Statement is filled with endless statements which are
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inaccurate, and nothing short of complete irrelevance.
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a. He claims that there was an agreement entered between Matt and me in
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an attempt to devalue assets of my marital relationship (Attachment, page
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1, 13-17). He follows this by explaining how a Santa Clara action was filed,
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followed by this Santa Cruz action when problems arose in the
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dissolution.
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b. He misstates the circumstances surrounding “membership interest” in
11 Enabledware and Matt’s deposition as it relates to this alleged interest
12 (Attachment, page 2, lines 9-26). He also is not an expert on businesses,
13 membership interests, and losses.
14 c. He continues to allege a “Klein conspiracy” between everyone involved
15 and attacks the Court and me in the process as he has done in many filings
16 (Attachment, page 3, lines 1-10).
17 d. He wrongfully alleges that the sale of Enabledware is a “classic con job”
18 and that I have lived off of women for years (Attachment, page 3, lines 3).
19 e. He believes that the San Mateo case was dismissed because the “court
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became annoyed” (Attachment, page 3, lines 23-26). This statement is not
even sound.
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f. In “paragraph 7” he claims that this case will require 40 to 60 days of trial
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because he was not provided discovery responses by anyone and the hard
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drive the Court ordered him to turn into the clerk’s office was not
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returned back to him. These statements are incorrect in that he was
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provided over a thousand pages of discovery. He also refused to stipulate
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to keep discovery open, but then continued harassing my attorney for
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discovery responses after discovery had already closed. He reiterates his
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misstated points in “paragraph 16” as well. This Court should also
PLAINTIFF SHAHRAM TABATABAI’S DECLARATION RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 3
recognize that he already filed a Motion in this action to retrieve the hard
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drive and it was denied.
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g. He once again attacks the Court in paragraphs 15 and 18. Given the fact
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that he consistently attacks the Court for no apparent reason, his
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statements as a whole should be scrutinized.
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8. Mr. Lindow has been shown to blatantly lie time and time again, and his Case
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Management Statement is nothing different.
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9. This Court must remember who it is dealing with.
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10. Mr. Lindow’s history is well documented such as;
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a. His days as a Michigan attorney to being reprimanded and eventually
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losing his license to practice law;
11 b. His decision to produce methamphetamine and run from authorities with
12 his wife under fake aliases when it became apparent that he would be
13 charged for his actions;
14 c. Eventually being caught by authorities, accepting a plea deal, and
15 spending time in prison;
16 d. His brother providing him a place to live next door to my former spouse
17 and me, and Mr. Lindow taking advantage of his own brother and
18 exploiting the fact that his brother was suffering from Alzheimer’s. This
19 leading to a probate matter that was ongoing for years;
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e. Him also taking advantage of my former spouse, who failed to realize that
she was being exploited too, even though Mr. Lindow (under oath)
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testified that he wanted to make money off of my former spouse and me;
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f. Him continuing to practice law unlawfully as he provided services to my
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former spouse and our former community business when she was given
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control of it during our dissolution;
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g. This unlawful practice of law also included his attempt to start a business
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with my former spouse’s assistance, in which legal forms would be
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prepared and provided to those who needed legal assistance;
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PLAINTIFF SHAHRAM TABATABAI’S DECLARATION RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 4
h. His decision to provide his legal services on Craigslist, but steal money
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from his clients, which resulted in a pending criminal matter against him
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(Case No. Case No. 22CR03126).
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11. If it was not already widely understood and accepted, Mr. Lindow is far from his
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credible and his misstatements should not be tolerated by anyone involved.
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I declare under penalty of perjury under the laws of the State of California
7 that the foregoing is true and correct.
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Executed this May 5, 2023 at Aptos, California.
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________________________________
11 Sean Tabatabai,
Plaintiff
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PLAINTIFF SHAHRAM TABATABAI’S DECLARATION RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 5
5/5/2023
5/5/2023
Service List
Lesley Harris Attorney for Former Defendant
Law offices of Lesley Harris Jeanne Turner Tabatabai
55 River Street, Suite 100 Tel: (831) 458-0502
Santa Cruz, CA 95060 Email: lesleyharrisesq@gmail.com
Robert Lindow Cross-Defendant (In Pro Per)
P.O. Box 2107 Tel: (831) 818-5512
Aptos, CA 95001 Email: lindow1@gmail.com
Preview
1 Tanzeel Hak, State Bar No., 331248 2 By the Law, APC 940 Saratoga Ave., #112, 3 San Jose, CA 95129 Tel: (510) 362-6791 4 Email: tanzeel@bythelaw.co 5 6 Attorney for Sean Tabatabai, 7 Plaintiff, Cross-Complainant 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 IN AND FOR THE COUNTY OF SANTA CRUZ 11 Unlimited Jurisdiction 12 NEMAT MALEKSALEHI, Case No.: 18CV02004 13 PLAINTIFF SHAHRAM 14 Plaintiff, TABATABAI’S DECLARATION vs. RE: ROBERT LINDOW’S CASE 15 MANAGEMENT STATEMENT SHAHRAM TABATABAI, an individual; JEANNE Date: 5/15/2023 16 TURNER TABATABAI, an individual; and DOES Time: 8:30 a.m. 17 1 through 10 inclusive Dept.: 5 Hon. Timothy Volkmann 18 Defendants. 19 ____________________________________________ SHAHRAM TABATABAI, 20 21 Cross-Complainant, 22 vs. 23 JEANNE TURNER TABATABAI, an individual; 24 ROBERT LINDOW, an individual; DEBORAH OLINYK, an individual, Any Cross-Defendant, 25 and ROES 1-15. 26 Cross-Defendants. 27 28 PLAINTIFF SHAHRAM TABATABAI’S DECLARATION RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 1 1 JEANNE TURNER TABATABAI, 2 Cross-Complainant, 3 vs. 4 5 NEMAT MALEKSALEHI, SHAHRAM 6 TABATABAI, and ROES 1 through 10, 7 Cross-Defendants. 8 9 DECLARATION OF SHAHRAM TABATABAI 10 I, Shahram Tabatabai, under the penalty of perjury under the laws of the state of 11 California, declare: 12 1. I am the Plaintiff and Cross-Complainant in this matter at this particular time. 13 2. If called upon as a witness, I could and would competently testify as to the 14 truthfulness of the following facts, all of which are within my own personal 15 knowledge except for those stated on information and belief, and as to those, I 16 am informed and believe them to be true. I request that the court receive this 17 declaration into evidence as my direct testimony. 18 3. This declaration is not intended to be, nor should it be construed as being a 19 waiver of any information protected by any applicable privilege including 20 privacy, confidentiality, attorney-client privilege or the attorney work-product 21 doctrine. The matters set forth herein were stated and/or observed in non- 22 privileged settings and are not the result of privileged work-product matters. 23 4. After reviewing Mr. Lindow’s Case Management Statement that was provided to 24 me by Mr. Hak, I simply felt obligated to respond. 25 5. Given that my attorney will attend the case management conference on my behalf, and I will not be participating, I believe this was the appropriate venue in 26 addressing Mr. Lindow. 27 28 PLAINTIFF SHAHRAM TABATABAI’S DECLARATION RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 2 6. Upon the Court’s own review of Mr. Lindow’s Case Management Statement, it 1 will realize that Mr. Lindow is continuing to provide his non-sensical, 2 unsubstantiated statements. 3 7. His Case Management Statement is filled with endless statements which are 4 inaccurate, and nothing short of complete irrelevance. 5 a. He claims that there was an agreement entered between Matt and me in 6 an attempt to devalue assets of my marital relationship (Attachment, page 7 1, 13-17). He follows this by explaining how a Santa Clara action was filed, 8 followed by this Santa Cruz action when problems arose in the 9 dissolution. 10 b. He misstates the circumstances surrounding “membership interest” in 11 Enabledware and Matt’s deposition as it relates to this alleged interest 12 (Attachment, page 2, lines 9-26). He also is not an expert on businesses, 13 membership interests, and losses. 14 c. He continues to allege a “Klein conspiracy” between everyone involved 15 and attacks the Court and me in the process as he has done in many filings 16 (Attachment, page 3, lines 1-10). 17 d. He wrongfully alleges that the sale of Enabledware is a “classic con job” 18 and that I have lived off of women for years (Attachment, page 3, lines 3). 19 e. He believes that the San Mateo case was dismissed because the “court 20 became annoyed” (Attachment, page 3, lines 23-26). This statement is not even sound. 21 f. In “paragraph 7” he claims that this case will require 40 to 60 days of trial 22 because he was not provided discovery responses by anyone and the hard 23 drive the Court ordered him to turn into the clerk’s office was not 24 returned back to him. These statements are incorrect in that he was 25 provided over a thousand pages of discovery. He also refused to stipulate 26 to keep discovery open, but then continued harassing my attorney for 27 discovery responses after discovery had already closed. He reiterates his 28 misstated points in “paragraph 16” as well. This Court should also PLAINTIFF SHAHRAM TABATABAI’S DECLARATION RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 3 recognize that he already filed a Motion in this action to retrieve the hard 1 drive and it was denied. 2 g. He once again attacks the Court in paragraphs 15 and 18. Given the fact 3 that he consistently attacks the Court for no apparent reason, his 4 statements as a whole should be scrutinized. 5 8. Mr. Lindow has been shown to blatantly lie time and time again, and his Case 6 Management Statement is nothing different. 7 9. This Court must remember who it is dealing with. 8 10. Mr. Lindow’s history is well documented such as; 9 a. His days as a Michigan attorney to being reprimanded and eventually 10 losing his license to practice law; 11 b. His decision to produce methamphetamine and run from authorities with 12 his wife under fake aliases when it became apparent that he would be 13 charged for his actions; 14 c. Eventually being caught by authorities, accepting a plea deal, and 15 spending time in prison; 16 d. His brother providing him a place to live next door to my former spouse 17 and me, and Mr. Lindow taking advantage of his own brother and 18 exploiting the fact that his brother was suffering from Alzheimer’s. This 19 leading to a probate matter that was ongoing for years; 20 e. Him also taking advantage of my former spouse, who failed to realize that she was being exploited too, even though Mr. Lindow (under oath) 21 testified that he wanted to make money off of my former spouse and me; 22 f. Him continuing to practice law unlawfully as he provided services to my 23 former spouse and our former community business when she was given 24 control of it during our dissolution; 25 g. This unlawful practice of law also included his attempt to start a business 26 with my former spouse’s assistance, in which legal forms would be 27 prepared and provided to those who needed legal assistance; 28 PLAINTIFF SHAHRAM TABATABAI’S DECLARATION RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 4 h. His decision to provide his legal services on Craigslist, but steal money 1 from his clients, which resulted in a pending criminal matter against him 2 (Case No. Case No. 22CR03126). 3 11. If it was not already widely understood and accepted, Mr. Lindow is far from his 4 credible and his misstatements should not be tolerated by anyone involved. 5 6 I declare under penalty of perjury under the laws of the State of California 7 that the foregoing is true and correct. 8 Executed this May 5, 2023 at Aptos, California. 9 10 ________________________________ 11 Sean Tabatabai, Plaintiff 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PLAINTIFF SHAHRAM TABATABAI’S DECLARATION RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 5 5/5/2023 5/5/2023 Service List Lesley Harris Attorney for Former Defendant Law offices of Lesley Harris Jeanne Turner Tabatabai 55 River Street, Suite 100 Tel: (831) 458-0502 Santa Cruz, CA 95060 Email: lesleyharrisesq@gmail.com Robert Lindow Cross-Defendant (In Pro Per) P.O. Box 2107 Tel: (831) 818-5512 Aptos, CA 95001 Email: lindow1@gmail.com