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MARC L. JACUZZI, State Bar No. 173220
NANCY L. MCCOY, State Bar No, 184983
Simpson, Garrity, Innes & Jacuzzi, P.C. .
2175 N. California Blvd., Suite 710
Walnut Creek, CA 94596
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Telephone: 925.322.8889 3 Awrumfifi '
Facsimile: 925.332.8890
Attorneys for Plaintiff
IMPACT PAPER & INK., LTD.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
llllllIllllllllllllllllllllllllll
IMPACT PAPER & INK LTD., Case No. CIV531938
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Plaintiff,
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DECLARATION OF NANCY L. McCOY IN
v. SUPPORT OF MOTION TO ENFORCE
SETTLEMENT AND FOR ENTRY OF
ALAN SAJADI; PACIFIC BUSINESS STIPULATED JUDGMENT
SUPPLIES and DOES 1 throUgh 10, inclusive, (C.C.P §§ 664.6 and 664.7)
Defendant. ‘
Date: April 10, 2018 :17”
Time: 9:00 am.
Place: Presiding Judge/Law & Motion I‘m
Moat
Complaint Filed: December 30, 2014
Trial Date: Not currently set
I, Nancy 'L. McCoy, declare:
1.I am an attorney duly licensed to practice law before all of the courts of the State of
California and before this Court. I am Senior Counsel with the law firm of Simpson,
Garrity, Innes
& Jacuzzi, P.C., attorneys of record for Plaintiff Impact Paper & Ink Ltd. in this action. I have
personal knowledge of the facts set forth herein, and
I
if called as a witness, I could and would
competently testify thereto.
2. Attached hereto as Exhibit A is a true and correct .copy of relevant excerpts of the
‘
deposition transcript of Alan Sajadi, taken on January 30, 2018.
{20394-2 00441904.DOCX 1 } -1- No. CIV531938
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3. Attached hereto as Exhibit B is a true and correct copy of relevant excerpts of the
deposition transcript of Alan Sajadi (Confidential Portion), taken on January 30, 2018.
4. Attached hereto as Exhibit 'C is a true and correct copy of relevant excerpts of the
deposition transcript of Matt Tigri, taken on February 15, 2018.
5. Attached hereto as Exhibit D is a true and correct copy of relevant excerpts of the
deposition transcript of Carl Hanson, taken on February 22, 2018
I declare under penalty and perjury under the laws of the state of California that the
foregoing is true and correct. Executed this 15th day of March, 2018 at Walnut Creek, California.
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NANCY L. Mc
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN MATEO
——oOo——
IMPACT PAPER & INK, LTD.,
Plaintiff,
vs. No. CIV53l938
ALAN SAJADI; PACIFIC VVVVVVVVVVVV
BUSINESS SUPPLIES and DOES 1
through 10, inclusive,
Defendant.
DEPOSITION OF ALAN ALI SAJADI, taken at 1001
Clark Avenue, Yuba City, California, on Tuesday,
January 30, 2018, at 9:30 A.M., before Samantha Hise,
Certified shorthand Reporter, in and for the State of
California.
Job: 24062
ALAN ALI SAJADI
January 30, 2018
A P P E A R A N C E S
For the Plaintiff, IMPACT PAPER & INK, LTD.:
Simpson Garrity Innes & Jacuzzi
BY: Marc L. Jacuzzi, Attorney at Law
2175 N. California Boulevard, Suite 710
Walnut Creek, California 94596
For the Defendant, AlAN SAJADI; PACIFIC BUSINESS
SUPPLIES and DOES 1 through 10, inclusive:
Griffith & Horne, LLP
BY: David R. Griffith,
Attorney at Law
1530 Humboldt Road, Suite 3
10 Chico, California 95928
ll Also present:
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Steve Christensen
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First Legal Deposition-Calendar@firstlegal.com
LA.85534&4997
ALAN ALI SAJADI
January 30, 2018
l I N D E X
2 WITNESS: ALAN ALI SAJADI
3 Examinations Page
4 By Mr. Jacuzzi 4
5 E X H I B I T S
No. Description Page
6
Exhibit 1 Settlement Agreement 88
7 And Mutual Release
8 Exhibit 2 Declaration of Alan Sajadi 94
in support of opposition to
9 to ex parte application for
order entering parties'
10 stipulated judgement
11 Exhibit 3 Exhibit D acknowledgment 118
of obligations
12
Exhibit 4 Fictitious Business Name 120
13 Statement
14 Exhibit 5 Cattlemen's Steakhouse Invoice 121
15 Exhibit 6 Specialty Restaurants Invoice 124
16 Exhibit 7 Stacks Redwood City Invoice 127
17 Exhibit 8 \Facebook profile page 132
18 Exhibit 9 Hilton Invoice
San Jose 133
19 Exhibit 10 Cybelle's Invoice 134
20 Exhibit 11 Tropicana Field Invoice 136
21 Exhibit ‘
12 Responses to request for 138
production of documents
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lmA.8553484997
ALAN ALI SAJADI
Janua[y 30, 2018
1 Tuesday, January 30, 2018, 9:30 A.M.
2 Yuba City, California,
3
4 Ali Sajadi,
Alan
5 having been first duly sworn, testifies as follows:
6
7 EXAMINATION BY MR. JACUZZl
8 Q. Good morning, Mr. Sajadi. My name is Marc
9 Jacuzzi. I'm counsel for plaintiffs, Impact Paper &
10 Ink?
11 A. Morning.
12 Q. I know we met informally, but now we're meeting
13 formally on the record.
14 A. to meet you.
Good
15 Q. Likewise. And so before we get going, there's
16 a few ground rules or instructions I'd like to go over
17 with you. First of all, could you say and spell your
18 full name, first, middle, and last assuming if you have
19 a middle name, for the record?
20 A. Alan, middle initial A, Sajadi, spelled
21 A—L—A—N, A is the middle initial, Sajadi, like S Sam,
22 -A—J-A-D-I.
23 Q. Does the middle initial -- does it have --
24 what's -- what's your middle name?
25 A. Um, Ali.
First Leqal Deposition-Calendar@firstleqal.com 4
L.A. 855.348.4997 _
ALAN ALI SAJADI
January 30, 2018
1 Q. A—L-I? Okay. All right. So you understand
2 that you‘re under oath today?
3 A. Sure.
4
Q. And it's ——
the testimony you give is subject
5 to penalty of perjury, and it‘s the same testimony and
6 type of testimony in the same oath if you were in the
7 court of law. Do you understand that?
8 A. Yes.
9 Q. Okay. Good. Um, I‘m entitled to your best
10 recollection but what I don't want you to do is to
11 guess. And I'll give you an example of that, between an
12 estimate and a guess. So about how long is this table?
13 Could you estimate it?
.14 A. I don't know. Ten feet?
15 IQ. It would be an estimate, right? Could you tell
16 me how far away the Smart and Final is down the street?
17 A. Can't tell you.
18 Q. That'd total guess, right? So I don't
be a
l9 want you to guess. All right?
20 A. Exactly. That's what I said. Can't tell you.
21 Q. Okay. Another thing is that the court reporter
22 is taking down everything that both of us say. And one
23 thing that she can not take down are head nods or
24 expressions or hand gestures and stuff like that. And I
25 see that you're kind of a head nodder, so I may ask you
First Legal Deposition-Calendar@firstlegal.com 5
llA.8553484997
ALAN ALI SAJADI
JanUary 30, 2018
1 any conversations that you may have had with your
2 lawyer. other than that, what did you
So do to prepare
3 for your deposition?
4 A. This right here.
5 Q. Did you look at any documents?
6 A. Yes.
7 Q. What documents did you look at?
8 A. What my lawyer's looking at.
9 Q. What's your -~ what documents did you look at?
10 MR. GRIFFITH: Deposition notice.
11 THE WITNESS: Deposition notice.
12 Q. BY MR. JACUZZI: Anything else?
13 A. No.
14 Q. Okay. And before the deposition got started
15 there was an individual who was sitting in here, and you
16 had indicated that she works with you. Who is that?
17 A. That's my future wife.
18 Q. What's her name?
19 A. Amy Nelson.
20 Q. And is it A-M-Y and N-E-L-S-O-N?
21 A. Yes.
22 Q. And does Ms. Nelson reside with you?
23 A. Yes.
24 Q. And where do you reside?
25 A. In Chico.
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lmA.8553484997
ALAN ALl SAJADI
January 30,2018
1 Q. What's your address?
2 A. 100 Sterling Oaks Drive, apartment 268, Chico,
3 California 95928.
4 Q. How long have you resided there?
5 A. Approximately -- about four years, give or
6 take.
7 Q. And has Ms. Nelson resided at the same
8 apartment?
9 A. Yes.
10 Q. And how long has she resided there?
11 A. About four years, give or take.
12 Q. Um, does anyone else reside with you at this
13 apartment?
14 A. My dog.
15 Q. All right. And, um, did you speak with Ms.
16 Nelson about this deposition?
17 A. Sure.
18 Q. What did you and Ms. Nelson discuss?
19 A. Just what's going on.
20 Q. In particular, what did you ~—
21 A. What's going on.
22 Q. What did you tell her what was going on?
23 A. What's here.
24 Q. When you say "whatls here," what do you mean by
25 that?
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ALAN ALI SAJADI
January 30. 2018
1 Q. Did you review any phone records for the
2 purposes of today's deposition?
3 A. No.
4 Q. No? Did you review any tax returns in
5 preparation for today's deposition?
6 A. No.
7 Q. Other than Amy Nelson, did you speak with
8 anyone else regarding today‘s deposition?
.
9 A. Yes.
10 Q. Who?
11 A. Carl Hanson.
12 Q. When did you speak to Carl Hanson about today's
13 deposition?
14 A. Yesterday.
15 Q. And did Mr. Hanson call you, or did you call
16 him?
17 A. Can't recall.
18 Q. Pardon?
19 A. Can't recall.
20 Q. You don't remember if you called him or if he
21 called you, and this was yesterday. And do you know how
22 Mr. Hanson spells his name?
23 A. What you have on your papers. You could read
24 it.
25 Q. I don't have anything on my papers.
First Legal Deposition-Calendar@firstlegal.com 12
L.A. 855.348.4997 .
ALAN ALI SAJADI
January 30, 2018
1 A. You don't have any papers --
2 Q. How ——
do you know how Mr. Hanson spells his
3 name?
4 A. H-A-N-S-O—N.
5 Q. Okay. And his first name?
6 A. C-A-R-L.
7 Q. Does Mr. Hanson go by any other name besides
8 Carl?
9 A. Chuck.
10 Q. So Chuck Hanson and Carl Hanson are the same
11 person?
12 A. Yes.
13 Q. How long was your conversation yesterday with
14 Mr. Hanson?
15 A. Fifteen seconds.
16 Q. Fifteen seconds. Okay. And in this
17 fifteen—second conversation, um, what did you discuss?
18 A. Basketball.
19 Q. And what particular about basketball did you
20 discuss?
21 A. Sports.
22 Q. When you say -- so you -- you're not certain if
23 Chuck called you, or you called Chuck?
24 A. I believe I called him.
25 Q. Okay. And did you talk about the deposition?
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L.A. 855.348.4997
ALAN ALI SAJADI
January 30, 2018
1 A. No.
2 Q. I thought that you had just testified that you
3 had —- when I asked you who else did you talk about the
4 deposition, you had said Carl Hanson?
5 A. Yeah, that was days ago.
6 Q. Okay. yesterday's conversation did not
And so
7 deal with the deposition?
8 A. Nope.
9 Q. Okay. And so when was it that you spoke to Mr.
10 Hanson about your deposition today?
11 A. Over the weekend.
12 Q. And did you call him, or did he call you?
13 A. He called me.
14 Q. When Mr. Hanson calls you, does he call you on
15 your cell phone?
16 A. Yes.
17 Q. And what's that phone number?
18 A. 902—5421.
19 Q. 902—54?
'20 A. 21.
21 Q. 21. What area code?
22 A. 415.
23 Q. And do you also ——
do you have any other cell
24 phone numbers?
25 A. Nope.
First Legal Deposition-Calendar@firstlegal.com
L.A. 855.348.4997
ALAN ALI SAJADI
Januagy 30, 2018
1 Q Do you have any landline numbers?
2 A My company line.
3 Q. And what is that?
4 A 530-592-3620.
5 Q And do you and Mr. Hanson text message each
6 other?
7 A. Yeah.
8 Q. Do you know what Mr. Hanson's cell phone number
9 is?
10 A. Um, I believe it's ——
I got to look it up on my
11 phone.
12 Q. Do you have a guess on what it is. I don't
13 want you to guess. Do you have any idea of what it is?
14 A. Right now I can't. It's on my phone.
15 Q. And so Mr. Hanson called you about ——
and you
16 discussed the deposition today, correct?
17 A. No.
18 Q. You said that Mr. Hanson called you over the
19 weekend and ——
20 A. You just said today, no.
21 Q. About today's deposition. So oVer the weekend
22 you had a conversation with Mr. Hanson, correct?
23 A. Yes.
24 Q. And in that conversation, you discussed the
25 deposition that you‘re sitting for today, correct?
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LA. 855.348.4997 _
ALAN ALI SAJADI
January 30, 2018
l A. Yes.
2 Q. And what did you talk about?
3 A. I have a deposition.
4 Q. Okay. Other than that, what did you say?
5 A. That's it.
6 Q. Did Chuck let you know that he had also been
7 subpoenaed for a deposition?
8 A. Yes.
9 Q. And what did he say about that?
10 A. That's it.
11 Q. No other discussion. Did you tell him -— did
12 he ask you what this case was about?
13 A. Well, no because there's so many papers. He's
14 dealing with his own lawyer.
15 Q. So at no time during your conversation this
16 weekend with Chuck about the deposition that you're
17 having to sit through today did he ask you what the case
18 is about?
19 A. Nope.
20 Q. Have you ever had any conversation with Mr.
21 Hanson about this lawsuit?
22 A. Yes.
23 Q. Okay. And at any time have you told Mr. Hanson
24 what this lawsuit is about?
25 A. Not really. We're letting our lawyers deal
First Legal Deposition—Calendar@firstlegal.com
L.A. 855.348.4997
ALAN ALI SAJADI
Januam 30, 2018
1 with it.
2 Q. Have you ever had -- has Mr. Hanson ever asked
3 you what this lawsuit was about?
4 A. Not really. We don't even really know deep
5 down inside what it's about.
6 Q. Do you speak to Mr. Hanson approximately ten
7 times a week?
8 A. Yes.
9 Q. Sometimes more, right?
10 A. Yes.
11 Q. Sometimes up to twenty times a week?
12 A. Yes.
13 Q. Thirty times a week?_
14 A. Yes.
15 Q. Forty times a week?
16 A. Yes.
17 Q. Fifty times a week?
18 A. Sure.
19 Q. So you're talking to Mr. Hanson fifty times a
20 week?
21 A. Sure.
22 Q. And on those ——
are those telephone calls
23 you're having with Mr. Hanson?
24 A. Sure.
25 Q. And that's on average, fifty times a week?
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L.A. 855.348.4997
ALAN/HJSAJADI
January 30, 2018
1 A. Sure.
2 Q. Is that yes?
3 A. Sure.
4 Q. It's a yes or no question.
5 A. Yes. That's the first time you've said
6 anything about "sure." But she's taking all my answers.
And so —- and on these phone
7 Q. conversations that
8 you're having with Mr. Hanson is it on your cell phones?
9 A. Yes.
10 Q. Where does Mr. Hanson live?
11 A. Camino.
12 Q. Camino? Is that in California?
13 A. Yes.
14 Q. Have you been to his house?
15 A. Yes.
16 Q. Is it a house or an apartment?
17 A. House.
18 Q. And does he live alone?
19 A. Um, yes.
20 Q. How long has Mr. Hanson lived in Camino?
21 A. Don‘t really recall.
22 Q. Okay. We'll get to ——
back to Mr. Hanson in a
23 minute. I have a few more background questions for you
24 as well. Have you ever been convicted of a crime?
25 A. Nope.
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L.A. 855.348.4997
ALAN ALI SAJADI
January 30, 2018
1 Q. Did you attend high school?
2 A. Yes.
3 Q. And where did you attend high school?
4 A. Burlingame High School.
5 Q. And did you graduate?
6 A. Yes.
7 Q. Did you attend college?
8 A. Yes.
9 Q. Where did you attend college?
10 A. Chico State.
11 Q. Did you graduate?
12 A. Yes.
13 Q. So would you say that you read, write, and
14 understand the English language?
15 A. Yes.
16 Q. And what year did you graduate from Chico?
17 A. '93, spring '93. .
18 Q. And did Mr. Hanson go to Burlingame High School
19 as well?
20 A. Yes.
‘
21 Q. Did you know him in high school?
22 A. Yes.
23 Q. And so -- and I know I asked you this question,
24 but I didn't write it down. So when did you graduate
25 from high school?
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ALAN ALI SAJADI
January 30, 2018
1 A. '87.
2 Q. '87. And so, um, did you know Mr. Hanson even
3 before high school?
4 A. Yes.
5 Q. So how long have you known Mr. Hanson?
6 A. Since I was 10.
7 Q. And you're -— how old are you currently?
8 A. 48.
9 Q. 48. So about 38 years or so you've known
10 Mr. Hanson. Other than, um, Amy Nelson and Carl
11 Hanson —- and so for the record, if I use the name Carl
12 Hanson or Chuck Hanson, you understand that we're
13 talking about the same person?
14 A. Oh, yes.
15 Q. Okay. So, um, other than Amy Nelson and Carl
16 Hanson, who else have you spoken to about this lawsuit
17 other than your attorney?
18 A. My mom.
19 Q. And what's your mom's name?
20 A. Vida Sajadi.
21 Q. And is that V—I—D—A?
22 A. Correct.
23 Q. And where does she reside?
24 A. Currently she resides in San Francisco.
25 Q. When was the last time you talked to Vida
First Legal Deposition-Calendar@firstlegal.com 20
L.A. 855.348.4997
ALAN ALI SAJADI
January 30, 2018
1 Sajadi regarding this lawsuit?
2 A. I believe it was, like, Thursday of last week.
3 Q. And, um, what did you say to Vida Sajadi about
4 this lawsuit?
5 A. That there's a deposition on Tuesday.
6 Q. Other than that?
7 A. That's it. She wished me good luck.
8 Q. Have you had any prior conversations with Vida
9 Sajadi regarding this lawsuit?
10 A. Yes.
11 Q. When?
12 A. I can't really recall.
13 Q. How many conversations have you had with Vida
14 Sajadi regarding this lawsuit?
15 A. Can't really recall.
16 Q. More than ten?
17 A. Can't recall. Less than ten.
18 Q. Less than ten. Conversations with Chuck Hanson
19 regarding this lawsuit, how many would you say? More
20 than twenty?
21 A. Less than ten.
22 Q. Less than ten. Okay. How about with Amy
23 Nelson regarding this lawsuit, how many conversations?
24 A. Anywhere between 100 to 500.
25 Q. So it sounds like you've had a lot of
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ALAN ALI SAJADI
January 30, 2018
1 conversations about this lawsuit with her?
2 A. Yes.
3 Q. So --
in your conversations with
other than so
4 Vida Sajadi about this lawsuit, what did you talk about?
5 What'd you tell her?
6 A. Not much.
7 Q. You had to have told her something.
8 A. These guys are suing me.
9 Q. Did you tell her why?
10 A. No.
11 Q. Did she ask you why?
12 A. Yeah.
13 Q. Okay. And what did you
i
tell her when she asked
14 you why?
15 A. I don't really know.
16 Q. So you have no idea why you're being sued?
17 A. Nope.
18 Q. So other than Vida Sajadi, Amy Nelson, and Carl
19 Hanson, anyone else you talked to about this lawsuit?
20 A. Not really.
21 Q. Not really?
22 A. Um, I mean I —— I've mentioned it to a couple
23 of my friends.
24 Q. Who is that?
25 A. Gentleman named Carl Gervasi. Actually, I've
First Legal Deposition-Calendar@firstlegal.com 22
[1A.8553484997
ALAN ALI SAJADI
January 30, 2018
1 Q. None of these people asked you why your old
2 company was suing you?
3 A. Not really.
4 Q. How did the conversation come up? Did you say,
5 "My old company‘s suing me"?
6 A. They just said, "How you doing? How's it been
7 going, Al?"
8 Q. And you said, "My old company's suing me"?
9 A. Yeah, in a conversation, sure.
10 Q. None of them asked you why?
11 A. No, not really.
12 Q. When you say "not really," what do you mean by
13 that?
14 A. Don't know. Can't recall.
15 Q. So as you sit here today, you can't recall
16 whether or not they asked you why your old company was
17 suing you?
18 A. I'm just saying the truth. That's all. You
19 asked me a question so ——
20 Q. So what I'm asking -— can you repeat the
21 question?
22 (Whereupon, the record was read.)
23 Q. BY MR. JACUZZI: Yeah. So when you —- I'll
24 rephrase it. So what I'm trying to find out is as you
25 sit here today, you don't —- you can't recall whether or
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llA.8553484997
ALAN ALI SAJADI
Januam 30, 2018
1 not these individuals asked you why your old company was
2 suing you?
3 A. No.
4 Q. Who's your old company?
5 A. Impact Paper & Ink.
6 Q. And when did you first start working for Impact
7 Paper & Ink?
8 A. 1994.
9 Q. And how long did you work for Impact Paper &
10 Ink?
11 A. Till 2014, I believe.
l2 Q. So approximately 20 years?
13 A. Yeah.
14 Q. Do you know who David Sklar is?
15 A. Yes.
16 Q. Who‘s Mr. Sklar?
17 A. Um, the ——
one of the owners of Impact Paper &
18 Ink.
l9 Q. And did you know Mr. Sklar prior to him hiring
I
20 you?
21 A. Yes.
22 Q. How long have you known Mr. Sklar?
23 A. Approximately 32 years, 334years.
24 Q. Did you go to high school with him?
25 A. Yes.
First Leqal Deposition-Calendar@firstleqal.com 25
L.A. 855.348.4997
ALAN ALI SAJADI
Januam 30I 2018
1 Q. So he also went to Burlingame High School?
2 A. Yes.
3 Q. And did you know him in high school?
4 A. Yes.
5 Q. Okay. And during the time that you, um, worked
6 with Impact Paper & Ink, did Carl Hanson also work
‘
7 there?
8 A. Yes.
9 Q. Do you know how long Mr. Hanson worked there
10 for?
11 A. Don't really know.
12 Q. More than ten years?
13 A. I don't know.
14 Q. At some point were you, Mr. Hanson, and
15 Mr. Sklar roommates?
16 A. Yes.
17 Q. In Seattle?
18 A. Yes.
19 Q. How long weregyou roommates in Seattle?
20 A. Approximately, maybe -— I was rooming maybe,
21 like, eight months.
22 Q. Okay. During the time that you worked for
23 Impact, they paid you commission, your wages, and all
24 that, correct?
25 A. Yes.
First Leqal Deposition-Calendar@firstleqal.com 26
L.A. 855.348.4997
ALAN ALI SAJADI ,
January 30, 2018
1 Q. They allowed you to work from home when you
2 wanted to relocate —- strike that. They allowed you to
3 relocate up to Chico, correct?
4 A. Yes.
5 Q. And they allowed you while you were -— and that
6 was your choice to move up to Chico, right?
7 A. Sure. Yes.
8 Q. And Impact Paper & Ink allowed you to work from
9 home while you were up in Chico?
10 A. Yes.
11 Q. And how many years were you, um, working from
12 home when you were up in Chico?
13 A. I think maybe nine, eight.
14 Q. Years?
15 A. Yes.
16 Q. So for about nine years you were allowed to
17 work from home?
18 A. Or eight years, yeah.
19 Q. And Impact set you up with a computer up there,
20 correct?
21 A. Yes.
22 Q. And on that computer you had access to Impact's
23 customer list, correct?
24 A. Yes.
25 Q. Pardon?
First Legal Deposition—Calendar@firstlegal.com 27
LA. 855.348.4997
ALAN ALI SAJADI
Januagy 30, 2018
1 A. Yes.
2 Q. And you also had access to Impact's pricing,
3 correct?
4 A. Yes.
5 Q. And so you knew how much Impact paid for its
6 products, correct?
7 A. Yes.
i
8 Q. And you knew how much Impact sold those
9 products to its customers, correct?
10 A. Yes.
11 Q. And you also -— not only having the customer
12 list, you also had the customer's telephone numbers,
13 correct?
14 A. Yes.
15 Q. And the contact information?
16 A. Yes.
17 Q. And you knew which customers —- you knew how
18 much each customer paid for specific products, correct?
19 A. No.
20 Q. So weren't you selling the products to the
21 specific customers?
22 A. Yes.
23 Q. So you didn't know how much they were paying
24 for the products?
25 A. No, because it varied.
First Leqal Deposition-Calendar@firstleqal.com 28
L.A. 855.348.4997
ALAN ALI SAJADI
January 30, 2018
1 Q. So -- but for a specific customer, you know how
2 much that customer ~—
3 A. No.
4 Q. No? Okay. What -— what is Impact's business?
5 You worked for them for twenty years. What do they do?
6 A. They sell paper rolls.
7 Q. Paper rolls. Who do they sell paper rolls to?
8 A. Anybody that uses them.
9 Q. Okay. And what are these paper rolls used for?
10 A. registers, credit card printers, point
Cash
11 sale printers, computer printers, handheld devises.
12 Q. So there are different sizes of paper rolls
13 that they sell?
14 A. All different sizes.
15 Q. Okay. Other than paper rolls, does ——
during
16 the twenty years that you worked for Impact, did they
17 sell any other products?
18 A. Yes.
19 Q. What other products did they sell?
20 A. Ink cartridges.
21 Q. So we got paper rolls of varying sizes. We
22 have ink cartridges.
23 A. Of all types.
24 Q. Colors and --
25 -
A. Colors.
First Legal Deposition-Calendar@flrstlegal.com 29
L.A. 855.348.4997
ALAN ALI SAJADI
January 30, 2018
1 Q. ——
brands and ~-
2 A. Brands, types, toners, cartridges, desktop
3 cartridges, spools.
4 Q. A spool? What's a spool?
5 A. A spool is a little ribbon that's like old
6 school that you put into, like, various old school cash
7 registers and adding machines, also ink rollers.
8 Q. Ink rollers?
9 A. Yes.
10 Q. So we have paper rolls, all different types of
11 ink cartridges. We've got spools and ribbons. What's
12 the last one you said?
13 A. Um, computer paper also.
14 Q. Anything else?
15 A. Yes. Gloves.
16 Q. Gloves?
17 A. Food service gloves, vinyl gloves, nitrile
l8 gloves.
19 Q. Nitrile or nitro?
20 A. Nitrile.
21 Q. Okay. What else?
22 A. Um, it's pretty much it.
23 Q. Okay. And when you worked for Impact Paper &
24 Ink, um, what was your job?
25 A. Sales.
First Legal Deposition-Calendar@firstlegal.com 30
LA. 855.348.4997 .
ALAN ALI SAJADI
Januag 3Ol 2018
1 Q. So your job was to reach out to end users?
2 A. And customer service.
3 Q. So you would reach out to various types of
4 business and try to sell them paper rolls, ink
5 cartridges, spools, various types of gloves if they
6 needed them, right?
7 A. Yes.
8 Q. And you established relationships with these
9 customers, right?
10 A. Yes.
11 Q. So you would -— there'd be a contact person and
12 you would call them up as part of your regular sales
13 calls, correct?
14 A. Yes.
15 Q. And most of your sales, was that done over the
16 phone?
17 A. Yes.
18 Q. Okay. Would you ever go and knock on doors?
19 A. Very rarely.
20 Q. All right. did Impacts provide you with
And
21 call sheets of perspective customers?
22 A. Yes.
23 Q. And so they would have a database of names for
24 you to call, right?
25 A. Sure. Yes.
First Leqal Deposition-Calendar@firstleqal.com
e.8553484997
ALAN ALI SAJADI
January 30, 2018
1 Q. The database was sent up to you electronically?
2 A. Yes.
3 Q. And when I say "sent up to you electronically,"
4 that was they either e-mailed it to you, or did you -—
5 did they e—mail it to you?
6 A. No.
7 Q. When you were in ——
up in Chico, did you have
8 direct access into, um, the Impact servers?
9 A. No.
10 Q. How would you communicate with them? Did you
11 have an e—mail address?
12 A. Um, yup, I had a personal e-mail address.
13 Q. Okay. So did you have an Impact e—mail address
14 as well?
15 A. Yes, at the very end of my career there which I
16 barely used, if ever.
17 Q. And what is your, um, personal e—mail address?
18 A.
Preview
MARC L. JACUZZI, State Bar No. 173220 NANCY L. MCCOY, State Bar No, 184983 Simpson, Garrity, Innes & Jacuzzi, P.C. . 2175 N. California Blvd., Suite 710 Walnut Creek, CA 94596 . . D TY E00W: Telephone: 925.322.8889 3 Awrumfifi ' Facsimile: 925.332.8890 Attorneys for Plaintiff IMPACT PAPER & INK., LTD. SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO llllllIllllllllllllllllllllllllll IMPACT PAPER & INK LTD., Case No. CIV531938 g; E Plaintiff, 7 633:? ~ DECLARATION OF NANCY L. McCOY IN v. SUPPORT OF MOTION TO ENFORCE SETTLEMENT AND FOR ENTRY OF ALAN SAJADI; PACIFIC BUSINESS STIPULATED JUDGMENT SUPPLIES and DOES 1 throUgh 10, inclusive, (C.C.P §§ 664.6 and 664.7) Defendant. ‘ Date: April 10, 2018 :17” Time: 9:00 am. Place: Presiding Judge/Law & Motion I‘m Moat Complaint Filed: December 30, 2014 Trial Date: Not currently set I, Nancy 'L. McCoy, declare: 1.I am an attorney duly licensed to practice law before all of the courts of the State of California and before this Court. I am Senior Counsel with the law firm of Simpson, Garrity, Innes & Jacuzzi, P.C., attorneys of record for Plaintiff Impact Paper & Ink Ltd. in this action. I have personal knowledge of the facts set forth herein, and I if called as a witness, I could and would competently testify thereto. 2. Attached hereto as Exhibit A is a true and correct .copy of relevant excerpts of the ‘ deposition transcript of Alan Sajadi, taken on January 30, 2018. {20394-2 00441904.DOCX 1 } -1- No. CIV531938 heel' (H- Nnnev I. Meenv In Rnnnnrt (If Mnfmn Tryl-Infnree SettlementCase et a] 3. Attached hereto as Exhibit B is a true and correct copy of relevant excerpts of the deposition transcript of Alan Sajadi (Confidential Portion), taken on January 30, 2018. 4. Attached hereto as Exhibit 'C is a true and correct copy of relevant excerpts of the deposition transcript of Matt Tigri, taken on February 15, 2018. 5. Attached hereto as Exhibit D is a true and correct copy of relevant excerpts of the deposition transcript of Carl Hanson, taken on February 22, 2018 I declare under penalty and perjury under the laws of the state of California that the foregoing is true and correct. Executed this 15th day of March, 2018 at Walnut Creek, California. 11 ii 6%? flit? NANCY L. Mc 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I 20394-2 00441904 DOCX l } -2- Case No. CIV531938 Hr—‘nl (H Nannv I, Mnnnv In Rnnnnrt m Mntmn Tn Pntnrne Settlement Bi” 2] 100% Recycled 30% PCW $3 (3 SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO ——oOo—— IMPACT PAPER & INK, LTD., Plaintiff, vs. No. CIV53l938 ALAN SAJADI; PACIFIC VVVVVVVVVVVV BUSINESS SUPPLIES and DOES 1 through 10, inclusive, Defendant. DEPOSITION OF ALAN ALI SAJADI, taken at 1001 Clark Avenue, Yuba City, California, on Tuesday, January 30, 2018, at 9:30 A.M., before Samantha Hise, Certified shorthand Reporter, in and for the State of California. Job: 24062 ALAN ALI SAJADI January 30, 2018 A P P E A R A N C E S For the Plaintiff, IMPACT PAPER & INK, LTD.: Simpson Garrity Innes & Jacuzzi BY: Marc L. Jacuzzi, Attorney at Law 2175 N. California Boulevard, Suite 710 Walnut Creek, California 94596 For the Defendant, AlAN SAJADI; PACIFIC BUSINESS SUPPLIES and DOES 1 through 10, inclusive: Griffith & Horne, LLP BY: David R. Griffith, Attorney at Law 1530 Humboldt Road, Suite 3 10 Chico, California 95928 ll Also present: 12 Steve Christensen 13 14 ——oOo—— 15 16 17 18 19 20 21 22 23 24 25 First Legal Deposition-Calendar@firstlegal.com LA.85534&4997 ALAN ALI SAJADI January 30, 2018 l I N D E X 2 WITNESS: ALAN ALI SAJADI 3 Examinations Page 4 By Mr. Jacuzzi 4 5 E X H I B I T S No. Description Page 6 Exhibit 1 Settlement Agreement 88 7 And Mutual Release 8 Exhibit 2 Declaration of Alan Sajadi 94 in support of opposition to 9 to ex parte application for order entering parties' 10 stipulated judgement 11 Exhibit 3 Exhibit D acknowledgment 118 of obligations 12 Exhibit 4 Fictitious Business Name 120 13 Statement 14 Exhibit 5 Cattlemen's Steakhouse Invoice 121 15 Exhibit 6 Specialty Restaurants Invoice 124 16 Exhibit 7 Stacks Redwood City Invoice 127 17 Exhibit 8 \Facebook profile page 132 18 Exhibit 9 Hilton Invoice San Jose 133 19 Exhibit 10 Cybelle's Invoice 134 20 Exhibit 11 Tropicana Field Invoice 136 21 Exhibit ‘ 12 Responses to request for 138 production of documents 22 23 24 25 First Legal Deposition-Calendar@firstlegal.com 3 lmA.8553484997 ALAN ALI SAJADI Janua[y 30, 2018 1 Tuesday, January 30, 2018, 9:30 A.M. 2 Yuba City, California, 3 4 Ali Sajadi, Alan 5 having been first duly sworn, testifies as follows: 6 7 EXAMINATION BY MR. JACUZZl 8 Q. Good morning, Mr. Sajadi. My name is Marc 9 Jacuzzi. I'm counsel for plaintiffs, Impact Paper & 10 Ink? 11 A. Morning. 12 Q. I know we met informally, but now we're meeting 13 formally on the record. 14 A. to meet you. Good 15 Q. Likewise. And so before we get going, there's 16 a few ground rules or instructions I'd like to go over 17 with you. First of all, could you say and spell your 18 full name, first, middle, and last assuming if you have 19 a middle name, for the record? 20 A. Alan, middle initial A, Sajadi, spelled 21 A—L—A—N, A is the middle initial, Sajadi, like S Sam, 22 -A—J-A-D-I. 23 Q. Does the middle initial -- does it have -- 24 what's -- what's your middle name? 25 A. Um, Ali. First Leqal Deposition-Calendar@firstleqal.com 4 L.A. 855.348.4997 _ ALAN ALI SAJADI January 30, 2018 1 Q. A—L-I? Okay. All right. So you understand 2 that you‘re under oath today? 3 A. Sure. 4 Q. And it's —— the testimony you give is subject 5 to penalty of perjury, and it‘s the same testimony and 6 type of testimony in the same oath if you were in the 7 court of law. Do you understand that? 8 A. Yes. 9 Q. Okay. Good. Um, I‘m entitled to your best 10 recollection but what I don't want you to do is to 11 guess. And I'll give you an example of that, between an 12 estimate and a guess. So about how long is this table? 13 Could you estimate it? .14 A. I don't know. Ten feet? 15 IQ. It would be an estimate, right? Could you tell 16 me how far away the Smart and Final is down the street? 17 A. Can't tell you. 18 Q. That'd total guess, right? So I don't be a l9 want you to guess. All right? 20 A. Exactly. That's what I said. Can't tell you. 21 Q. Okay. Another thing is that the court reporter 22 is taking down everything that both of us say. And one 23 thing that she can not take down are head nods or 24 expressions or hand gestures and stuff like that. And I 25 see that you're kind of a head nodder, so I may ask you First Legal Deposition-Calendar@firstlegal.com 5 llA.8553484997 ALAN ALI SAJADI JanUary 30, 2018 1 any conversations that you may have had with your 2 lawyer. other than that, what did you So do to prepare 3 for your deposition? 4 A. This right here. 5 Q. Did you look at any documents? 6 A. Yes. 7 Q. What documents did you look at? 8 A. What my lawyer's looking at. 9 Q. What's your -~ what documents did you look at? 10 MR. GRIFFITH: Deposition notice. 11 THE WITNESS: Deposition notice. 12 Q. BY MR. JACUZZI: Anything else? 13 A. No. 14 Q. Okay. And before the deposition got started 15 there was an individual who was sitting in here, and you 16 had indicated that she works with you. Who is that? 17 A. That's my future wife. 18 Q. What's her name? 19 A. Amy Nelson. 20 Q. And is it A-M-Y and N-E-L-S-O-N? 21 A. Yes. 22 Q. And does Ms. Nelson reside with you? 23 A. Yes. 24 Q. And where do you reside? 25 A. In Chico. First Legal Deposition-Calendar@firstlegal.com 9 lmA.8553484997 ALAN ALl SAJADI January 30,2018 1 Q. What's your address? 2 A. 100 Sterling Oaks Drive, apartment 268, Chico, 3 California 95928. 4 Q. How long have you resided there? 5 A. Approximately -- about four years, give or 6 take. 7 Q. And has Ms. Nelson resided at the same 8 apartment? 9 A. Yes. 10 Q. And how long has she resided there? 11 A. About four years, give or take. 12 Q. Um, does anyone else reside with you at this 13 apartment? 14 A. My dog. 15 Q. All right. And, um, did you speak with Ms. 16 Nelson about this deposition? 17 A. Sure. 18 Q. What did you and Ms. Nelson discuss? 19 A. Just what's going on. 20 Q. In particular, what did you ~— 21 A. What's going on. 22 Q. What did you tell her what was going on? 23 A. What's here. 24 Q. When you say "whatls here," what do you mean by 25 that? First Legal Deposition-Calendar@firstlegal.com ' 10 lmA.8553484997 ALAN ALI SAJADI January 30. 2018 1 Q. Did you review any phone records for the 2 purposes of today's deposition? 3 A. No. 4 Q. No? Did you review any tax returns in 5 preparation for today's deposition? 6 A. No. 7 Q. Other than Amy Nelson, did you speak with 8 anyone else regarding today‘s deposition? . 9 A. Yes. 10 Q. Who? 11 A. Carl Hanson. 12 Q. When did you speak to Carl Hanson about today's 13 deposition? 14 A. Yesterday. 15 Q. And did Mr. Hanson call you, or did you call 16 him? 17 A. Can't recall. 18 Q. Pardon? 19 A. Can't recall. 20 Q. You don't remember if you called him or if he 21 called you, and this was yesterday. And do you know how 22 Mr. Hanson spells his name? 23 A. What you have on your papers. You could read 24 it. 25 Q. I don't have anything on my papers. First Legal Deposition-Calendar@firstlegal.com 12 L.A. 855.348.4997 . ALAN ALI SAJADI January 30, 2018 1 A. You don't have any papers -- 2 Q. How —— do you know how Mr. Hanson spells his 3 name? 4 A. H-A-N-S-O—N. 5 Q. Okay. And his first name? 6 A. C-A-R-L. 7 Q. Does Mr. Hanson go by any other name besides 8 Carl? 9 A. Chuck. 10 Q. So Chuck Hanson and Carl Hanson are the same 11 person? 12 A. Yes. 13 Q. How long was your conversation yesterday with 14 Mr. Hanson? 15 A. Fifteen seconds. 16 Q. Fifteen seconds. Okay. And in this 17 fifteen—second conversation, um, what did you discuss? 18 A. Basketball. 19 Q. And what particular about basketball did you 20 discuss? 21 A. Sports. 22 Q. When you say -- so you -- you're not certain if 23 Chuck called you, or you called Chuck? 24 A. I believe I called him. 25 Q. Okay. And did you talk about the deposition? First Legal Deposition-Calendar@firstlegal.com 13 L.A. 855.348.4997 ALAN ALI SAJADI January 30, 2018 1 A. No. 2 Q. I thought that you had just testified that you 3 had —- when I asked you who else did you talk about the 4 deposition, you had said Carl Hanson? 5 A. Yeah, that was days ago. 6 Q. Okay. yesterday's conversation did not And so 7 deal with the deposition? 8 A. Nope. 9 Q. Okay. And so when was it that you spoke to Mr. 10 Hanson about your deposition today? 11 A. Over the weekend. 12 Q. And did you call him, or did he call you? 13 A. He called me. 14 Q. When Mr. Hanson calls you, does he call you on 15 your cell phone? 16 A. Yes. 17 Q. And what's that phone number? 18 A. 902—5421. 19 Q. 902—54? '20 A. 21. 21 Q. 21. What area code? 22 A. 415. 23 Q. And do you also —— do you have any other cell 24 phone numbers? 25 A. Nope. First Legal Deposition-Calendar@firstlegal.com L.A. 855.348.4997 ALAN ALI SAJADI Januagy 30, 2018 1 Q Do you have any landline numbers? 2 A My company line. 3 Q. And what is that? 4 A 530-592-3620. 5 Q And do you and Mr. Hanson text message each 6 other? 7 A. Yeah. 8 Q. Do you know what Mr. Hanson's cell phone number 9 is? 10 A. Um, I believe it's —— I got to look it up on my 11 phone. 12 Q. Do you have a guess on what it is. I don't 13 want you to guess. Do you have any idea of what it is? 14 A. Right now I can't. It's on my phone. 15 Q. And so Mr. Hanson called you about —— and you 16 discussed the deposition today, correct? 17 A. No. 18 Q. You said that Mr. Hanson called you over the 19 weekend and —— 20 A. You just said today, no. 21 Q. About today's deposition. So oVer the weekend 22 you had a conversation with Mr. Hanson, correct? 23 A. Yes. 24 Q. And in that conversation, you discussed the 25 deposition that you‘re sitting for today, correct? First Leqal Deposition-Calendar@firstleqal.com 15 LA. 855.348.4997 _ ALAN ALI SAJADI January 30, 2018 l A. Yes. 2 Q. And what did you talk about? 3 A. I have a deposition. 4 Q. Okay. Other than that, what did you say? 5 A. That's it. 6 Q. Did Chuck let you know that he had also been 7 subpoenaed for a deposition? 8 A. Yes. 9 Q. And what did he say about that? 10 A. That's it. 11 Q. No other discussion. Did you tell him -— did 12 he ask you what this case was about? 13 A. Well, no because there's so many papers. He's 14 dealing with his own lawyer. 15 Q. So at no time during your conversation this 16 weekend with Chuck about the deposition that you're 17 having to sit through today did he ask you what the case 18 is about? 19 A. Nope. 20 Q. Have you ever had any conversation with Mr. 21 Hanson about this lawsuit? 22 A. Yes. 23 Q. Okay. And at any time have you told Mr. Hanson 24 what this lawsuit is about? 25 A. Not really. We're letting our lawyers deal First Legal Deposition—Calendar@firstlegal.com L.A. 855.348.4997 ALAN ALI SAJADI Januam 30, 2018 1 with it. 2 Q. Have you ever had -- has Mr. Hanson ever asked 3 you what this lawsuit was about? 4 A. Not really. We don't even really know deep 5 down inside what it's about. 6 Q. Do you speak to Mr. Hanson approximately ten 7 times a week? 8 A. Yes. 9 Q. Sometimes more, right? 10 A. Yes. 11 Q. Sometimes up to twenty times a week? 12 A. Yes. 13 Q. Thirty times a week?_ 14 A. Yes. 15 Q. Forty times a week? 16 A. Yes. 17 Q. Fifty times a week? 18 A. Sure. 19 Q. So you're talking to Mr. Hanson fifty times a 20 week? 21 A. Sure. 22 Q. And on those —— are those telephone calls 23 you're having with Mr. Hanson? 24 A. Sure. 25 Q. And that's on average, fifty times a week? First Leqal Deposition-Calendar@firstleqal.com 17 L.A. 855.348.4997 ALAN/HJSAJADI January 30, 2018 1 A. Sure. 2 Q. Is that yes? 3 A. Sure. 4 Q. It's a yes or no question. 5 A. Yes. That's the first time you've said 6 anything about "sure." But she's taking all my answers. And so —- and on these phone 7 Q. conversations that 8 you're having with Mr. Hanson is it on your cell phones? 9 A. Yes. 10 Q. Where does Mr. Hanson live? 11 A. Camino. 12 Q. Camino? Is that in California? 13 A. Yes. 14 Q. Have you been to his house? 15 A. Yes. 16 Q. Is it a house or an apartment? 17 A. House. 18 Q. And does he live alone? 19 A. Um, yes. 20 Q. How long has Mr. Hanson lived in Camino? 21 A. Don‘t really recall. 22 Q. Okay. We'll get to —— back to Mr. Hanson in a 23 minute. I have a few more background questions for you 24 as well. Have you ever been convicted of a crime? 25 A. Nope. First Legal Deposition-Calendar@firstlegal.com 18 L.A. 855.348.4997 ALAN ALI SAJADI January 30, 2018 1 Q. Did you attend high school? 2 A. Yes. 3 Q. And where did you attend high school? 4 A. Burlingame High School. 5 Q. And did you graduate? 6 A. Yes. 7 Q. Did you attend college? 8 A. Yes. 9 Q. Where did you attend college? 10 A. Chico State. 11 Q. Did you graduate? 12 A. Yes. 13 Q. So would you say that you read, write, and 14 understand the English language? 15 A. Yes. 16 Q. And what year did you graduate from Chico? 17 A. '93, spring '93. . 18 Q. And did Mr. Hanson go to Burlingame High School 19 as well? 20 A. Yes. ‘ 21 Q. Did you know him in high school? 22 A. Yes. 23 Q. And so -- and I know I asked you this question, 24 but I didn't write it down. So when did you graduate 25 from high school? First Legal Deposition-Calendar@firstlegal.com 19 llA.8553484997 ALAN ALI SAJADI January 30, 2018 1 A. '87. 2 Q. '87. And so, um, did you know Mr. Hanson even 3 before high school? 4 A. Yes. 5 Q. So how long have you known Mr. Hanson? 6 A. Since I was 10. 7 Q. And you're -— how old are you currently? 8 A. 48. 9 Q. 48. So about 38 years or so you've known 10 Mr. Hanson. Other than, um, Amy Nelson and Carl 11 Hanson —- and so for the record, if I use the name Carl 12 Hanson or Chuck Hanson, you understand that we're 13 talking about the same person? 14 A. Oh, yes. 15 Q. Okay. So, um, other than Amy Nelson and Carl 16 Hanson, who else have you spoken to about this lawsuit 17 other than your attorney? 18 A. My mom. 19 Q. And what's your mom's name? 20 A. Vida Sajadi. 21 Q. And is that V—I—D—A? 22 A. Correct. 23 Q. And where does she reside? 24 A. Currently she resides in San Francisco. 25 Q. When was the last time you talked to Vida First Legal Deposition-Calendar@firstlegal.com 20 L.A. 855.348.4997 ALAN ALI SAJADI January 30, 2018 1 Sajadi regarding this lawsuit? 2 A. I believe it was, like, Thursday of last week. 3 Q. And, um, what did you say to Vida Sajadi about 4 this lawsuit? 5 A. That there's a deposition on Tuesday. 6 Q. Other than that? 7 A. That's it. She wished me good luck. 8 Q. Have you had any prior conversations with Vida 9 Sajadi regarding this lawsuit? 10 A. Yes. 11 Q. When? 12 A. I can't really recall. 13 Q. How many conversations have you had with Vida 14 Sajadi regarding this lawsuit? 15 A. Can't really recall. 16 Q. More than ten? 17 A. Can't recall. Less than ten. 18 Q. Less than ten. Conversations with Chuck Hanson 19 regarding this lawsuit, how many would you say? More 20 than twenty? 21 A. Less than ten. 22 Q. Less than ten. Okay. How about with Amy 23 Nelson regarding this lawsuit, how many conversations? 24 A. Anywhere between 100 to 500. 25 Q. So it sounds like you've had a lot of First Legal Deposition-Calendar@firstlegal.com 21 ILA.8553484997 ALAN ALI SAJADI January 30, 2018 1 conversations about this lawsuit with her? 2 A. Yes. 3 Q. So -- in your conversations with other than so 4 Vida Sajadi about this lawsuit, what did you talk about? 5 What'd you tell her? 6 A. Not much. 7 Q. You had to have told her something. 8 A. These guys are suing me. 9 Q. Did you tell her why? 10 A. No. 11 Q. Did she ask you why? 12 A. Yeah. 13 Q. Okay. And what did you i tell her when she asked 14 you why? 15 A. I don't really know. 16 Q. So you have no idea why you're being sued? 17 A. Nope. 18 Q. So other than Vida Sajadi, Amy Nelson, and Carl 19 Hanson, anyone else you talked to about this lawsuit? 20 A. Not really. 21 Q. Not really? 22 A. Um, I mean I —— I've mentioned it to a couple 23 of my friends. 24 Q. Who is that? 25 A. Gentleman named Carl Gervasi. Actually, I've First Legal Deposition-Calendar@firstlegal.com 22 [1A.8553484997 ALAN ALI SAJADI January 30, 2018 1 Q. None of these people asked you why your old 2 company was suing you? 3 A. Not really. 4 Q. How did the conversation come up? Did you say, 5 "My old company‘s suing me"? 6 A. They just said, "How you doing? How's it been 7 going, Al?" 8 Q. And you said, "My old company's suing me"? 9 A. Yeah, in a conversation, sure. 10 Q. None of them asked you why? 11 A. No, not really. 12 Q. When you say "not really," what do you mean by 13 that? 14 A. Don't know. Can't recall. 15 Q. So as you sit here today, you can't recall 16 whether or not they asked you why your old company was 17 suing you? 18 A. I'm just saying the truth. That's all. You 19 asked me a question so —— 20 Q. So what I'm asking -— can you repeat the 21 question? 22 (Whereupon, the record was read.) 23 Q. BY MR. JACUZZI: Yeah. So when you —- I'll 24 rephrase it. So what I'm trying to find out is as you 25 sit here today, you don't —- you can't recall whether or First Legal Deposition-Calendar@first|egal.com 24 llA.8553484997 ALAN ALI SAJADI Januam 30, 2018 1 not these individuals asked you why your old company was 2 suing you? 3 A. No. 4 Q. Who's your old company? 5 A. Impact Paper & Ink. 6 Q. And when did you first start working for Impact 7 Paper & Ink? 8 A. 1994. 9 Q. And how long did you work for Impact Paper & 10 Ink? 11 A. Till 2014, I believe. l2 Q. So approximately 20 years? 13 A. Yeah. 14 Q. Do you know who David Sklar is? 15 A. Yes. 16 Q. Who‘s Mr. Sklar? 17 A. Um, the —— one of the owners of Impact Paper & 18 Ink. l9 Q. And did you know Mr. Sklar prior to him hiring I 20 you? 21 A. Yes. 22 Q. How long have you known Mr. Sklar? 23 A. Approximately 32 years, 334years. 24 Q. Did you go to high school with him? 25 A. Yes. First Leqal Deposition-Calendar@firstleqal.com 25 L.A. 855.348.4997 ALAN ALI SAJADI Januam 30I 2018 1 Q. So he also went to Burlingame High School? 2 A. Yes. 3 Q. And did you know him in high school? 4 A. Yes. 5 Q. Okay. And during the time that you, um, worked 6 with Impact Paper & Ink, did Carl Hanson also work ‘ 7 there? 8 A. Yes. 9 Q. Do you know how long Mr. Hanson worked there 10 for? 11 A. Don't really know. 12 Q. More than ten years? 13 A. I don't know. 14 Q. At some point were you, Mr. Hanson, and 15 Mr. Sklar roommates? 16 A. Yes. 17 Q. In Seattle? 18 A. Yes. 19 Q. How long weregyou roommates in Seattle? 20 A. Approximately, maybe -— I was rooming maybe, 21 like, eight months. 22 Q. Okay. During the time that you worked for 23 Impact, they paid you commission, your wages, and all 24 that, correct? 25 A. Yes. First Leqal Deposition-Calendar@firstleqal.com 26 L.A. 855.348.4997 ALAN ALI SAJADI , January 30, 2018 1 Q. They allowed you to work from home when you 2 wanted to relocate —- strike that. They allowed you to 3 relocate up to Chico, correct? 4 A. Yes. 5 Q. And they allowed you while you were -— and that 6 was your choice to move up to Chico, right? 7 A. Sure. Yes. 8 Q. And Impact Paper & Ink allowed you to work from 9 home while you were up in Chico? 10 A. Yes. 11 Q. And how many years were you, um, working from 12 home when you were up in Chico? 13 A. I think maybe nine, eight. 14 Q. Years? 15 A. Yes. 16 Q. So for about nine years you were allowed to 17 work from home? 18 A. Or eight years, yeah. 19 Q. And Impact set you up with a computer up there, 20 correct? 21 A. Yes. 22 Q. And on that computer you had access to Impact's 23 customer list, correct? 24 A. Yes. 25 Q. Pardon? First Legal Deposition—Calendar@firstlegal.com 27 LA. 855.348.4997 ALAN ALI SAJADI Januagy 30, 2018 1 A. Yes. 2 Q. And you also had access to Impact's pricing, 3 correct? 4 A. Yes. 5 Q. And so you knew how much Impact paid for its 6 products, correct? 7 A. Yes. i 8 Q. And you knew how much Impact sold those 9 products to its customers, correct? 10 A. Yes. 11 Q. And you also -— not only having the customer 12 list, you also had the customer's telephone numbers, 13 correct? 14 A. Yes. 15 Q. And the contact information? 16 A. Yes. 17 Q. And you knew which customers —- you knew how 18 much each customer paid for specific products, correct? 19 A. No. 20 Q. So weren't you selling the products to the 21 specific customers? 22 A. Yes. 23 Q. So you didn't know how much they were paying 24 for the products? 25 A. No, because it varied. First Leqal Deposition-Calendar@firstleqal.com 28 L.A. 855.348.4997 ALAN ALI SAJADI January 30, 2018 1 Q. So -- but for a specific customer, you know how 2 much that customer ~— 3 A. No. 4 Q. No? Okay. What -— what is Impact's business? 5 You worked for them for twenty years. What do they do? 6 A. They sell paper rolls. 7 Q. Paper rolls. Who do they sell paper rolls to? 8 A. Anybody that uses them. 9 Q. Okay. And what are these paper rolls used for? 10 A. registers, credit card printers, point Cash 11 sale printers, computer printers, handheld devises. 12 Q. So there are different sizes of paper rolls 13 that they sell? 14 A. All different sizes. 15 Q. Okay. Other than paper rolls, does —— during 16 the twenty years that you worked for Impact, did they 17 sell any other products? 18 A. Yes. 19 Q. What other products did they sell? 20 A. Ink cartridges. 21 Q. So we got paper rolls of varying sizes. We 22 have ink cartridges. 23 A. Of all types. 24 Q. Colors and -- 25 - A. Colors. First Legal Deposition-Calendar@flrstlegal.com 29 L.A. 855.348.4997 ALAN ALI SAJADI January 30, 2018 1 Q. —— brands and ~- 2 A. Brands, types, toners, cartridges, desktop 3 cartridges, spools. 4 Q. A spool? What's a spool? 5 A. A spool is a little ribbon that's like old 6 school that you put into, like, various old school cash 7 registers and adding machines, also ink rollers. 8 Q. Ink rollers? 9 A. Yes. 10 Q. So we have paper rolls, all different types of 11 ink cartridges. We've got spools and ribbons. What's 12 the last one you said? 13 A. Um, computer paper also. 14 Q. Anything else? 15 A. Yes. Gloves. 16 Q. Gloves? 17 A. Food service gloves, vinyl gloves, nitrile l8 gloves. 19 Q. Nitrile or nitro? 20 A. Nitrile. 21 Q. Okay. What else? 22 A. Um, it's pretty much it. 23 Q. Okay. And when you worked for Impact Paper & 24 Ink, um, what was your job? 25 A. Sales. First Legal Deposition-Calendar@firstlegal.com 30 LA. 855.348.4997 . ALAN ALI SAJADI Januag 3Ol 2018 1 Q. So your job was to reach out to end users? 2 A. And customer service. 3 Q. So you would reach out to various types of 4 business and try to sell them paper rolls, ink 5 cartridges, spools, various types of gloves if they 6 needed them, right? 7 A. Yes. 8 Q. And you established relationships with these 9 customers, right? 10 A. Yes. 11 Q. So you would -— there'd be a contact person and 12 you would call them up as part of your regular sales 13 calls, correct? 14 A. Yes. 15 Q. And most of your sales, was that done over the 16 phone? 17 A. Yes. 18 Q. Okay. Would you ever go and knock on doors? 19 A. Very rarely. 20 Q. All right. did Impacts provide you with And 21 call sheets of perspective customers? 22 A. Yes. 23 Q. And so they would have a database of names for 24 you to call, right? 25 A. Sure. Yes. First Leqal Deposition-Calendar@firstleqal.com e.8553484997 ALAN ALI SAJADI January 30, 2018 1 Q. The database was sent up to you electronically? 2 A. Yes. 3 Q. And when I say "sent up to you electronically," 4 that was they either e-mailed it to you, or did you -— 5 did they e—mail it to you? 6 A. No. 7 Q. When you were in —— up in Chico, did you have 8 direct access into, um, the Impact servers? 9 A. No. 10 Q. How would you communicate with them? Did you 11 have an e—mail address? 12 A. Um, yup, I had a personal e-mail address. 13 Q. Okay. So did you have an Impact e—mail address 14 as well? 15 A. Yes, at the very end of my career there which I 16 barely used, if ever. 17 Q. And what is your, um, personal e—mail address? 18 A.