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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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DECLARATION OF TANZEEL
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Plaintiff, HAK RE: ROBERT LINDOW’S
vs. CASE MANAGEMENT
15 STATEMENT
SHAHRAM TABATABAI, an individual; JEANNE
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TURNER TABATABAI, an individual; and DOES
17 1 through 10 inclusive
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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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DECLARATION OF TANZEEL HAK RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 1
DECLARATION OF TANZEEL HAK IN SUPPORT OF THE EX PARTE
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APPLICATION
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I, Tanzeel Hak, 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 attorney at law, duly admitted to practice before all of the courts in the
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State of California. I am familiar with the aspects of this case, including all of the
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matters which are set forth in this Declaration.
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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
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am informed and believe them to be true. I request that the court receive this
11 declaration into evidence as my direct testimony.
12 3. This declaration is not intended to be, nor should it be construed as being a
13 waiver of any information protected by any applicable privilege including
14 privacy, confidentiality, attorney-client privilege or the attorney work-product
15 doctrine. The matters set forth herein were stated and/or observed in non-
16 privileged settings and are not the result of privileged work-product matters.
17 4. My firm and Mr. Tabatabai have reviewed Mr. Lindow’s Case Management
18 Statement and have found several misstatements.
19 5. This Declaration is only intended to address Mr. Lindow’s claims of being unable
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to serve Ms. Turner (whether directly or through her former attorney, Lesley
Harris.)
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6. As with Mr. Lindow’s normal filings, his statements are unsubstantiated, and he
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has not provided any evidence that he attempted to serve Ms. Turner on three
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separate occasions through process servers, but failed.
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7. Mr. Lindow and Ms. Turner have had a long-standing relationship.
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8. During discovery in Ms. Turner and Mr. Tabatabai’s dissolution, upwards of two
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thousand emails were produced between Ms. Turner and Mr. Lindow, and these
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emails were only over the span of a couple of years.
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DECLARATION OF TANZEEL HAK RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 2
9. Mr. Lindow is involved in this matter due to his relationship with Ms. Turner,
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and this has been reflected through many documents.
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10. Ms. Turner has resided in the same place for over twenty years.
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11. She has continued to be employed at the same place for years.
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12. Mr. Lindow has attempted to make it appear as if Ms. Turner is evading service,
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yet Mr. Lindow has failed to explain the actual facts to support this position.
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13. Regardless of Mr. Lindow’s claims, it does not change the fact that this Court
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ordered him to serve his Cross-Complaint by September 28, 2023.
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14. I inquired into whether it had been served, and Mr. Lindow did not respond.
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15. His Case Management Statement does reflect that it was not served.
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16. At the September 13th hearing, this Court informed Mr. Lindow that if the Cross-
11 Complaint was not served, the Court would proceed with setting trial on this
12 matter at the next case management conference.
13 17. At this time, it would be appropriate to set trial.
14 18. Additionally, this Court should refer to the attached Exhibit which reflects that
15 my firm and Mr. Tabatabai had no issues with serving Ms. Turner earlier this
16 year in a separate matter.
17 I declare under penalty of perjury under the laws of the State of California that
18 the foregoing is true and correct.
19 Executed on October 24, 2023, at San Jose, California.
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________________________________
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Tanzeel Hak
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DECLARATION OF TANZEEL HAK RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 3
EXHIBIT 1
DocuSign Envelope ID: 82D1C331-5048-4C9A-A48F-DBCF30FB40F3
MInds Eye Intermediary
DBA Minds Eye Courier
Carla Kidd
3400 Richmond Parkway
Ste 1617
San Pablo, CA 94806
CarlaKidd1@proton.me
510-407-7879
October 24, 2023
Superior Court of California
County of Santa Cruz
Civil Division
Santa Cruz, California
Re: Case 18CV02004 Tabatabai vs Tabatabai
Your Honor,
I, Carla Kidd, hereby declare the following under penalty of perjury:
I am writing this letter to inform the court about an encounter I had with Jeanne Turner on April 20th,
2023 in Santa Cruz county. I arrived at the specified location, Envision Media, to serve Jeanne Turner
in the aforementioned case. Upon my arrival, I promptly made contact with her and informed her of
the purpose of my visit. I had anticipated a potentially difficult interaction, but to my surprise, Jeanne
Turner was cooperative and immediately agreed to meet.
She profusely apologized, arriving a couple of hours later; it was about an hour after the scheduled
time we designated on the phone upon my arrival. I found her demeanor to be pleasant and
approachable. During our conversation, Jeanne Turner was open to both receiving information and
divulging information about the new developments in her case. She was receptive and showed a
willingness to engage in a discussion about the matter at hand.
I would like to emphasize that Jeanne Turner was easily accessible, and her willingness to discuss
the case was evident. Her openness to receiving the information demonstrated a cooperative
attitude, which I believe is vital for the progress of any case.
I declare under penalty of perjury under the laws of the State of California that the forgoing is true and
correct. Executed on 24th of October, 2023 in Berkeley, California.
Sincerely,
Carla Kidd
1 Service List
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Robert Lindow
3 P.O. Box 2107
Aptos, CA 95001
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Email: lindow1@gmail.com
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Service List Page 1
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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 DECLARATION OF TANZEEL 14 Plaintiff, HAK RE: ROBERT LINDOW’S vs. CASE MANAGEMENT 15 STATEMENT SHAHRAM TABATABAI, an individual; JEANNE 16 TURNER TABATABAI, an individual; and DOES 17 1 through 10 inclusive 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 DECLARATION OF TANZEEL HAK RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 1 DECLARATION OF TANZEEL HAK IN SUPPORT OF THE EX PARTE 1 APPLICATION 2 I, Tanzeel Hak, under the penalty of perjury under the laws of the state of 3 California, declare: 4 1. I am the attorney at law, duly admitted to practice before all of the courts in the 5 State of California. I am familiar with the aspects of this case, including all of the 6 matters which are set forth in this Declaration. 7 2. If called upon as a witness, I could and would competently testify as to the 8 truthfulness of the following facts, all of which are within my own personal 9 knowledge except for those stated on information and belief, and as to those, I 10 am informed and believe them to be true. I request that the court receive this 11 declaration into evidence as my direct testimony. 12 3. This declaration is not intended to be, nor should it be construed as being a 13 waiver of any information protected by any applicable privilege including 14 privacy, confidentiality, attorney-client privilege or the attorney work-product 15 doctrine. The matters set forth herein were stated and/or observed in non- 16 privileged settings and are not the result of privileged work-product matters. 17 4. My firm and Mr. Tabatabai have reviewed Mr. Lindow’s Case Management 18 Statement and have found several misstatements. 19 5. This Declaration is only intended to address Mr. Lindow’s claims of being unable 20 to serve Ms. Turner (whether directly or through her former attorney, Lesley Harris.) 21 6. As with Mr. Lindow’s normal filings, his statements are unsubstantiated, and he 22 has not provided any evidence that he attempted to serve Ms. Turner on three 23 separate occasions through process servers, but failed. 24 7. Mr. Lindow and Ms. Turner have had a long-standing relationship. 25 8. During discovery in Ms. Turner and Mr. Tabatabai’s dissolution, upwards of two 26 thousand emails were produced between Ms. Turner and Mr. Lindow, and these 27 emails were only over the span of a couple of years. 28 DECLARATION OF TANZEEL HAK RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 2 9. Mr. Lindow is involved in this matter due to his relationship with Ms. Turner, 1 and this has been reflected through many documents. 2 10. Ms. Turner has resided in the same place for over twenty years. 3 11. She has continued to be employed at the same place for years. 4 12. Mr. Lindow has attempted to make it appear as if Ms. Turner is evading service, 5 yet Mr. Lindow has failed to explain the actual facts to support this position. 6 13. Regardless of Mr. Lindow’s claims, it does not change the fact that this Court 7 ordered him to serve his Cross-Complaint by September 28, 2023. 8 14. I inquired into whether it had been served, and Mr. Lindow did not respond. 9 15. His Case Management Statement does reflect that it was not served. 10 16. At the September 13th hearing, this Court informed Mr. Lindow that if the Cross- 11 Complaint was not served, the Court would proceed with setting trial on this 12 matter at the next case management conference. 13 17. At this time, it would be appropriate to set trial. 14 18. Additionally, this Court should refer to the attached Exhibit which reflects that 15 my firm and Mr. Tabatabai had no issues with serving Ms. Turner earlier this 16 year in a separate matter. 17 I declare under penalty of perjury under the laws of the State of California that 18 the foregoing is true and correct. 19 Executed on October 24, 2023, at San Jose, California. 20 ________________________________ 21 Tanzeel Hak 22 23 24 25 26 27 28 DECLARATION OF TANZEEL HAK RE: ROBERT LINDOW’S CASE MANAGEMENT STATEMENT Page 3 EXHIBIT 1 DocuSign Envelope ID: 82D1C331-5048-4C9A-A48F-DBCF30FB40F3 MInds Eye Intermediary DBA Minds Eye Courier Carla Kidd 3400 Richmond Parkway Ste 1617 San Pablo, CA 94806 CarlaKidd1@proton.me 510-407-7879 October 24, 2023 Superior Court of California County of Santa Cruz Civil Division Santa Cruz, California Re: Case 18CV02004 Tabatabai vs Tabatabai Your Honor, I, Carla Kidd, hereby declare the following under penalty of perjury: I am writing this letter to inform the court about an encounter I had with Jeanne Turner on April 20th, 2023 in Santa Cruz county. I arrived at the specified location, Envision Media, to serve Jeanne Turner in the aforementioned case. Upon my arrival, I promptly made contact with her and informed her of the purpose of my visit. I had anticipated a potentially difficult interaction, but to my surprise, Jeanne Turner was cooperative and immediately agreed to meet. She profusely apologized, arriving a couple of hours later; it was about an hour after the scheduled time we designated on the phone upon my arrival. I found her demeanor to be pleasant and approachable. During our conversation, Jeanne Turner was open to both receiving information and divulging information about the new developments in her case. She was receptive and showed a willingness to engage in a discussion about the matter at hand. I would like to emphasize that Jeanne Turner was easily accessible, and her willingness to discuss the case was evident. Her openness to receiving the information demonstrated a cooperative attitude, which I believe is vital for the progress of any case. I declare under penalty of perjury under the laws of the State of California that the forgoing is true and correct. Executed on 24th of October, 2023 in Berkeley, California. Sincerely, Carla Kidd 1 Service List 2 Robert Lindow 3 P.O. Box 2107 Aptos, CA 95001 4 Email: lindow1@gmail.com 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Service List Page 1