John Alessio (Procopio), Brigid Heid (Eastman & Smith), Mary Wright (Wright & Supple)

Page 1


May 28, 1993

Zubeida Moorjani, MD

500 Riverside Drive Rossford, OH 43460

Dear Dr. Moorjani:

Thank you very much for your letter regarding the St. John's High School news article on my thoughts about the Jesuit School.

I also appreciate you sending me the resume on your son, Deepak. He certainly looks like an outstanding young person. I would suggest that the next time he is in Toledo for the holidays, you ask him to give us a call, as we would be happy to chat with him about his career objectives and aspirations.

Thank you again for^our no^e,

SJM/gc

cc: Carl Hirsch

a memo from the desk of

Deepak Moorjani

Wednesday, December 8, 2021

Adult Protective Services Health and Human Services Agency County of San Diego 1600 Pacific Hwy #206 San Diego, CA 92101

to: Adult Protective Services

subject: Zubeida Moorjani, MD

San Diego Superior Court Case No. 37-2021-00033119-CU-OR-CTL

On November 19, 2021, I called Adult Protective Services (“APS”) in San Diego to request an investigation on the elder abuse of Zubeida Moorjani. My mother is an elder person who is a retired medical doctor.

On November 19, 2021, I spoke with Pam (intake) at 800.399.2021. Based on our conversation, Pam believed that an investigation would commence based on (i) emotional abuse and (ii) financial abuse. On November 19, 2021, I mailed written information to APS in San Diego, and this letter provides additional information.

Adult Protective Services: San Diego and Lucas County

On May 25, 2021, I contacted APS in San Diego. My desired outcome was to move my mother from her house in Lucas County, Ohio to her house in San Diego County, California.

On May 25, 2021, I spoke with Tiffany of APS in San Diego, and she provided guidance on the issues that APS considers in its investigations.

My mom is an elder with the following issues

• A medical condition (e.g. high blood pressure)

• A recent hospitalization (e.g. broken pelvis)

• A person who is unable to manage her finances (e.g. pay her bills, balance her checkbook).

• A person who has had previous interventions (e.g. Notification: Suicide Risk on January 10, 2019).

At the time, my mother was living in Lucas County, Ohio; therefore, Tiffany with APS in San Diego suggested that I contact APS in Lucas County, Ohio.

On May 25, 2021,I filed a report with Colleen of APS in Lucas County, Ohio for (i) neglect and abandonment and (ii) financial abuse.

These issues are described in the First Amended Complaint filed in San Diego Superior Court Case No. 37-2021-00033119-CU-OR-CTL. The First Amended Complaint is item #14 in the Register of Actions, and the First Amended Complaint contains information and exhibits which may assist APS of San Diego’s investigation.

Personal Contacts in San Diego County

In San Diego, Zubeida Moorjani’s contacts are

1. John Alessio. c/o Procopio, Cory, Hargreaves & Savitch, LLP. 525 B Street, Suite 2200, San Diego, CA 92101. (619) 238-1900. john.alessio@procopio.com

2. Manisha Moorjani. c/o Gossamer Bio. 3013 Science Park Road, Suite 200, San Diego CA 92121. (858) 684-1300. ladybird_7@hotmail.com

3. Seema Moorjani. 11881 Cypress Valley Drive, San Diego, CA 92131-3762. (858) 342-2837. seemakulkarni@yahoo.com

4. Sunil Moorjani. 11881 Cypress Valley Drive, San Diego, CA 92131-3762. (858) 342-2837. moorjani @gmx.com

John Alessio (Bar No. 174900), Procopio, Cory, Hargreaves & Savitch, LLP

Additionally, I would like APS of San Diego to investigate John Alessio (Bar No. 174900) for elder abuse. As a member of the California bar, John Alessio is currently the managing partner of Procopio, Cory, Hargreaves & Savitch, LLP (“Procopio”).

John Alessio and Sunil Moorjani are former classmates at the University of San Diego Law School (’94), and John Alessio may have allowed a personal relationship to compromise his legal judgment. As a member of the California bar, John Alessio should have recognized the conflict of interest, and he should have declined to represent the defendants.

The attached Notification: Suicide Risk is dated January 10, 2019, and this letter was sent via certified mail to Rosemarie Osowik, MD with a cc: to Jennifer Compton of Sun Federal, Louise Jackson of Eastman & Smith, and Sunil Moorjani. Additional, this letter was sent via certified mail to Thomas Osowik, a judge in the Ohio Sixth District Court of Appeals.

Despite the filing of the First Amended Compliant, John Alessio and Procopio have still failed to recuse themselves; consequently, I filed a Notice of Motion and Motion to Disqualify, a Memorandum of Points and Authority, and a Declaration of Plaintiff. The San Diego Superior Court Case No. 37-2021-00033119-CU-ORCTL is being heard in C-65 by Honorable Ronald F. Frazier.

In the Motion to Disqualify, John Alessio and Procopio’s emails have been produced, and John Alessio and Procopio’s emails show that they have consistently sought to force a dismissal with prejudice. However, John Alessio has client relationships with Gulab Moorjani, Seema Moorjani, Sunil Moorjani and Zubeida Moorjani.

In his November 30, 2021 email (attached), one of John Alessio’s junior associates admits that the First Amended Complaint has been filed; however, the junior associate (Zagros Bassirian, Bar No. 299581) is actively soliciting a settlement proposal.

Note: The First Amended Complaint was served to the defendants directly via USPS certified mail. USPS tracking information (#70163010000034555499) shows: (i) on November 22, 2021 at 8:48am, the package was “Held at Post Office, At Customer Request,” (ii) on November 26, 2021 at 12:11pm, the package was not delivered but “Notice Left (No Authorized Recipient Available)”, and (iii) on November 27, 2021, the package was not delivered but “The customer has requested that the Postal Service redeliver this item on November 29, 2021 in SAN DIEGO, CA 92131.”

Thank you for your kind attention.

cc: Brigid Heid, Eastman & Smith

cc: Lynn Balshone Jacobs

cc: Manisha Moorjani, Gossamer Bio

cc: Soueja Kummar, S.K. Financial, LLC

Deepak Moorjani <deepak@moorjani.com>

To: Carlotta de Franceschi <carlotta.defranceschi@credit-suisse.com>

Fwd: Mom: Update

Hey. Sent this to a few relatives. Gives you the story. Thanks for your thoughts.

Begin forwarded message:

From: DEEPAK MOORJANI <deepak@alumni.duke.edu>

Date: February 16, 2009 5:49:38 PM SST

Subject: Mom: Update

February 17, 2009 5:45 PM

Last week was not fun. Mom was in a lot of physical pain. Basically, she was not able to function, so she had a minor outpatient procedure (facet block). It took a few days to start seeing the results. She is now pain-free.

The other issues (high blood pressure, anxiety, tremors, etc) were harder to solve. We took a few trips to the ER due to the high-blood pressure (which regularly hit 170-190). Consulted with nephrologist, family doctor, neurologist, and the ER physicians. Luckily, she knew everyone (they are colleagues).

The doctors were very concerned. I was told that a major cause was the physical pain as well as loneliness. Basically, the doctors could not find the solution, so they told her it was anxiety. I spent last week looking into options: assisted-living, homecare, etc. I was also considering moving to Toledo.

In the end, the nephrologist did some blood tests. The high blood pressure (and anxiety, tremors, etc) were caused by too high doses of one medication which led to hyperthyroidism. The subsequent reduction in dosage of this drug is having the desired effect. Recovery is under way. Blood pressure is about 140.

eKimura-san

Daiki Kajino/db/dbaom

2007/05/09 19:19

To cc Tomohiko Kimura/Tokyo / DBJ apan/ D euBa@DBAPAC

Subject Fw: Staff - Privileged & Confidential

As we discussed in this morning, t exptained the current situation to Murakami-san in HR' Afterthat, I arranged "onfãtén"-ä cali with Srnil N¿ã¿"" and it is alreadv fixed on tomorrow at 17:00 (Tokvo I tme/.

Mffif,am¡-san and I will have a oonference call with him and ask him about our ooncerns. If you need to join it, please let me know.

As to investigation of Frank's e-mail for Pipeline issue, I will start it as soon as I obtain Mitch's approval'

Regards,

Daiki Kajino (F¿EÍ X*!)

Compliahce Deparlment

Deutsche Bank AG, TokYo Branch

Tel : +81-3-5156-7738

Fax +81-3-51 56-6006 daiki.kajino@db.com ****'***'**'******

---- Forwarded by Daiki Kajino/db/dbaom on 2007/05/09 19:13

Mark Grolman/SYdneY/D BAustralia /DeuBa@DBAPAG

2007/05/09 19:09 To

"Díck Walker" (riohard'h.walker@db'oom), ianic e.reznick@db.oom, raohe I'blanshard@db.com' iË"ãj!r"æ¿u.com, "tiivoshi Murakami" tkil;;h#;rkamiddb.cbm), "Andrew Hume" i"í¿*",.f,rr"@db.com), "Daiki Kajino" (daiki.kajino@db'oom), ''Mr. Tomohiko (Tom) Kimura" (tomohiko'kimura@db'oom)

Srbj; Staff - Privileged & Confidential

PRIVILEGED & CONFIDENTIAL

Below are draft notes of the interview I had with Frank Forelle yesterday.

NEXT STEPS

I suggest for your condsideration that the next steps should be:

(a) we interview Sunil Madan. Tom Kimura has agreed to do that by telephone as soon as possible this week;

(b) when Deepak Moorjani returns to Tokyo from the- US next week, we pres.s him aga.in to produce all evidence he has or rnv åll"Ë"ã violations or wJongaoing. In the two weeks since he was interviewed he has not produced any evidence;

(c) agree a letter to Mr Moorjani in response to his letter. .l suggest that.this. letter be siened by David Hatt as presideni "n¿ òËö'oi'ósílti.r" "rõLï"i "i Ni lr¡oorjani). oãvi¿ Hatt has been briefed on this matter. I will draft ttre r"rJoÃs. letter for yori i"ui"*. Once-agreed, that letter should be delivered to Mr Moodani.

I also propose gíving the draft notes of meeting to Frank Forelle to check for accuracy'

January 29, 2008

Deutsche Bank AG

Legal Department

60 Wall Street, MS NYC60-3601

New York, NY 10005

Tel 212-250-8200

Fax 212-797-4569

richard.h.walker@db.com

Mr. Gary

113 King Street Armonk, NY 10504

Dear Gary:

I have concluded that I should resign from MBIA’s Board. I do so with great regret and only after very careful consideration of the interests of both MBIA and Deutsche Bank.

When I joined MBIA’s Board in 2006, existing business relationships between MBIA and Deutsche Bank provided no basis to believe that I would be unable to give both institutions my full attention and undivided loyalty. Given the events of the past week, however, I am now in a position where I can no longer be confident that continuing to act on behalf of both institutions will not lead to the possibility of an appearance that I may have reason to favor one over the other on a matter of great importance to both. In these circumstances, my ability to continue to act on behalf of either institution may be constrained. Given the importance of restoring credibility in the marketplace, I would not want my role to become a distraction to ongoing efforts to achieve this goal.

I am proud to have been associated with MBIA, and I would have liked to continue serving on MBIA’s Board. I leave the Board with great affection for all my fellow directors and with appreciation for their wisdom and dedication. I would also be remiss if I did not applaud the exceptional MBIA staff. I am confident that this top-flight staff, with the Board’s support, will guide MBIA to future successes.

Sincerely,

cc: Members of the Board of Directors

"Kohlenberg, Kerstin" <Kerstin.Kohlenberg@zeit.de>

To: DEEPAK <deepak@moorjani.com>

AW: Links to Articles

Hi Deepak,

oh yes, I read them and after that went to your scribt-page and read everything that is there.

May 13, 2009 2:03 PM

What you discovered at Deutsche Bank in regards to almost 100percent loans and the connection to bonuses is exactly what apparently happened at Hypo Real Estate (only that they offered 160 percent commercial real estate loans which in German is actually against the law. I am researching that story right now) so I am a little familiar with the topic. I just did a story about Merkel and her advisers and how badly their bank-overview functions. (http://www.zeit.de/2009/15/DOS-Kanzleramt)

I believe what you discovered in a heartbeat. I think your demands for better risk management and a different incentive structure need more audience - and connected with that very case that you are presenting, it would make a big, big story. I write 8000 word features (kind of like a New York times Magazine Story) and I would very much write about you and the case you are making. There are a lot of people out there that demand change, but there is you who can show how rotten the system still is, and how the managers say one thing to the media and something else to people like you.

The fact that your letter was ccd to Angela Merkel makes it even more interesting, because I could confront her with it, and ask about her real interests in changing the system ( like she said on the G20 summit)

So any clue when you will be back in New York?

Kerstin

-----Ursprüngliche Nachricht-----

Von: DEEPAK MOORJANI [mailto:deepak@moorjani.com]

Gesendet: Mi 13.05.2009 18:50

An: Kohlenberg, Kerstin

Betreff: Links to Articles

Hi Kerstin,

Have you read these articles? If so, I'd welcome your thoughts.

A.

http://seekingalpha.com/article/137071-zero-hedge-exclusive-whistleblower-s-fight-with-deutsche-bank-over-definition-of-risk B.

http://seekingalpha.com/article/136859-deutsche-bank-s-socialization-of-risk-culture-redux

Deepak

On May 14, 2009, at 12:57 AM, Kohlenberg wrote: Deepak,

That's really unfortunate. When so you come back to the States?

Kerstin

Am 13.05.2009 17:51 Uhr schrieb "DEEPAK MOORJANI" unter <deepak@moorjani.com>:

Hi Kerstin,

Unfortunately, I am stuck in Asia. Hearings are discontinuous, and I'm not sure when the next hearing will be. The April hearing was public, but most are closed hearings (including this Friday's hearing).

I'll recommend that we "meet" via videoconference. It's the next-best alternative and better than a phone call. Maybe even this weekend.

Thanks, Deepak

On May 14, 2009, at 12:10 AM, Kohlenberg wrote:

Hi Deepak,

Thanks again. Just two quick questions in order to plan my trip next

Richard G. Joseph <rgjphone4@yahoo.com>

To: Deepak Moorjani <deepak@alumni.duke.edu>

Update

Deepak, Hope all is well with you.

March 20, 2010 6:51 PM

I took your mom to Flower Hospital (NOT St. Anne's) at her doctor's request. She's OK. Her doctor called me tonight around 7 and asked if I would do this. Apparently, your mom saw the doc at 2 p.m. and then called her around 6 p.m. to say she was getting a headache. The doctor thinks she needs to be evaluated for many reasons, some of them psychological. She seems obsessed with her health, and her docs are growing impatient with her. Dr. Osowik, when she called tonight, was lovely and very determined to get to the bottom of all this. Flower Hospital, she said, has many more services than St. Anne's and that's why she wants her there. Mom is in Room 517, two very nice nurses greeted us at the door to her lovely private room. Hospital No. is 419 824 1444. I left two bowls of dry cat food and water for Tigger. He should be OK for two days or until you return on Monday. Please stay in touch.

Love, Mrs. J

9:47 p.m. Saturday

DEEPAK MOORJANI <deepak@alumni.duke.edu>

To: tulsi@moorjani.com

Reply-To: "DEEPAK MOORJANI" <deepak@alumni.duke.edu>

Fw: Re: Fw: Update

Mom's newest crusade is to find a new primary care physician. I think Osowick did a nice job of taking Mom away from her old hospital (Too much dependency. Jun felt that Mom liked going to the hospital because it was a way to deal with loneliness. I think it was an issue as well).

I don't think she liked some of the advice that Osowick gave, but Mom seems healthier. She tends to shoot the messenger.

-------Original Message-------

To: DEEPAK MOORJANI <deepak@alumni.duke.edu>

Subject: Re: Fw: Update

Sent: Mar 22 '10 12:25am

Sheesh man, kind of a tough situation to deal with. One the one hand, you want to be cautious, and not brush aside any of your mom's health concerns, but some times people get kind of paranoid about their health too (at least in my family Ive seen it with my grandmas sister). It sounds like she has one good doctor who's looking out for her though (osowik), maybe take her to the hospital where she practiced and knows people as opposed to the place where they are getting 'impatient'. Just average primary care docs aren't ideal for dealing with the elderly, try to find someone who really has a strong geriatric practice or at least knows how to deal with the issues, medicinal and psychological, that older patients go through.

Aging is tough man, im dreading it.

Talk soon.

On Mon, Mar 22, 2010 at 9:37 AM, DEEPAK MOORJANI <[LINK: mailto:deepak@alumni.duke.edu] deepak@alumni.duke.edu> wrote: FYI

Subject: Update

Sent: Mar 21 '10 10:51am

Deepak, Hope all is well with you.

I took your mom to Flower Hospital (NOT St. Anne's) at her doctor's request. She's OK. Her doctor called me tonight around 7 and asked if I would do this. Apparently, your mom saw the doc at 2 p.m. and then called her around 6 p.m. to say she was getting a headache. The doctor thinks she needs to be evaluated for many reasons, some of them psychological. She seems obsessed with her health, and her docs are growing impatient with her. Dr. Osowik, when she called tonight, was lovely and very determined to get to the bottom of all this. Flower Hospital, she said, has many more services than St. Anne's and that's why she wants her there.

Mom is in Room 517, two very nice nurses greeted us at the door to her lovely private room. Hospital No. is 419 824 1444. I left two bowls of dry cat food and water for Tigger. He should be OK for two days or until you return on Monday.

Please stay in touch.

Love, Mrs. J

9:47 p.m. Saturday

April 1, 2010 10:40 AM

New text message from (419) 320-7036 1 message

Google LLC 1600 Amphitheatre Pkwy Mountain View CA 94043 USA https://mail.google.com/mail/u/0/h/1bsp3eokpzepb/?&th=1682ee88e5baed6d&ser=AIKcX57ojWiR9dw-vbPfpBIH2b07EyF_qw&v=pt

deepak . <dxxpak@gmail.com>

(419) 320-7036 <16502341111.14193207036.w38lfrcn14@txt.voice.google.com> Tue, Jan 8, 2019 at 7:20 PM

To: dxxpak@gmail.com

Hi Deepak I'm here with your mom and I'm really worried about her.. she is walking in circles and shaking and talking about things I can't understand .. I m asking you should I contact someone to come out and check her she is not doing good ... I dont know to help her medically

To respond to this text message, reply to this email or visit Google Voice.

YOUR ACCOUNT HELP CENTER HELP FORUM

To edit your email preferences for text messages, go to the email notification settings in your account.

531 LASUEN MALL #18685

STANFORD, CA 94309

Notification: Suicide Risk

Via Certified Mail

Rosemarie Osowik, MD

4041 Sylvania Ave., Suite 204

Toledo, Ohio 43623

Dear Rosemarie,

On January 08, 2019, Jennifer Compton of Sun Federal visited Mom at 6036 Quarrys Edge Lane, and Mom stated, "I should just commit suicide."

The possibility of suicide should never be underestimated, and this is a direct cry for help. In Jennifer Compton's opinion, "She cannot stay in Toledo."

The working plan is for Mom to stay at her house in San Diego at 11881 Cypress Valley Drive, San Diego, CA 92131. During this two-month period, we will work on a longerterm plan, since Mom cannot live alone. She is lonely and depressed, and she is not able to make her own decisions. Most likely, Mom should move to an assisted-living facility, preferably in San Diego.

Jennifer Compton is director of business development at Sun Federal Credit Union, and she has advised my Mom on her financial affairs for approximately two decades. She is cc’d to this letter, and her phone number is 419.794.7482. She may contact you directly.

Sincerely yours,

Deepak

cc:

Jennifer Compton, Sun Federal Credit Union

Louise A. Jackson, Eastman & Smith

Sunil Moorjani

NOTIFICATION: SUICIDE RISK

Jennifer Compton <jennifer.compton@sunfcu.org>

Resent-From: <deepak@alumni.duke.edu>

To: "moorjani@gmx.com" <moorjani@gmx.com>

Cc: "Deepak (deepak@alumni.duke.edu)" <deepak@alumni.duke.edu> Your Mom

Hi Sunil,

February 1, 2019 5:15 AM

I just wanted to give you a little bit of information regarding your mom. I visited her a few weeks ago to help with her bills and checking account. She was not doing good that day. She was very upset and extremely anxious. She couldn’t remember if she had taken her medicine. She was very shaky. She was really mad at herself that she left California and thought it was a big mistake.

She stated that she is not doing good and thought she should “just commit suicide”. I told her that I was extremely worried about her and that I was going to call 911. She really got upset and made me promise that I wouldn’t call 911. When I got back to the office I contacted Deepak because I didn’t know who else to contact and I would never forgive myself if something happened to her.

She really shouldn’t be driving and being by herself seems very hard for her.

If you would like to talk please feel free to contact me.

Thanks and have a good weekend.

Jennifer Compton

Director of Business Development (NMLS #809440)

Phone: 419.794.7482

Fax: 419.893.5071

Follow Sun Federal:

This email and any files transmitted with it are the property of Sun Federal Credit Union, are confidential, and are intended solely for the use of the individual or entity to which this e-mail is addressed. If you are not one of the named recipient(s) or otherwise have reason to believe that you have received this message in error, please notify the sender and delete this message immediately from your computer. Any other use, retention, dissemination, forwarding, printing, or copying of this email is strictly prohibited. Any opinions expressed are those of the sender and do not necessarily represent those of Sun Federal Credit Union.

Warning: Computer viruses can be transmitted via email. Although the credit union has taken reasonable precautions to ensure no viruses are present in this email, the credit union cannot accept responsibility for any loss or damage arising from the use of this email or attachments.

From: profferg <profferg@aol.com>

Sent: Wednesday, October 13, 2021 11:15 PM

To: Jim Maser

Subject: Re: referral

Hi Jim. It's great to hear from you, as always. It would be great to see you again. We're leaving 10/20 for 3 weeks in Italy, but will be back 11/12-so anytime after that. Re: your friends: the first thing to do is to report the situation to Adult Protective Services in the County in which the parents live. Here are the links for Alameda and Contra Costa Counties, respectively:

https://www.alamedacountysocialservices.org/our-services/Abuse-and-Protection/adultand-senior-abuse/index

https://www.contracosta.ca.gov/914/Adult-Protective-Services

Re an attorney to help: I'd suggest you contact Kathryn Korn in Orinda. Here's the link to her website:

https://www.kornlawgroup.com/

I hope this helps. Let me know if you have other questions.

Warmest regards, Mike

—Original Message—

From: Jim Maser <Jim.Maser@picanteberkeley.com>

To: profferg <profferg@aol.com>

Sent: Wed, Oct 13, 2021 6:28 am

Subject: referral

Hey Mike, Hope all is well with you and your family.

I am beginning to remodel Picante today. Not sure how all this will roll out.

Do you have a referral for a lawyer who specializes in elder care abuse? Parents I know have kids who are bad actors, and they need help.

Thanks, and I hope it's sooner than later that I see you again.

Best, Jim

Oriet Cohen-Supple <oriet@wrightandsupple.com>

Resent-From: <deepak@alumni.duke.edu>

To: Deepak Moorjani <deepak@alumni.duke.edu>

Fwd: Moorjani: Confirmation of Extension (October 18, 2021)

Hi Deepak

See below. I expected him to contact me… so I am following up on my email from yesterday. Let’s further discuss …

Oriet Cohen-Supple, Partner Cell: 1-510-495-5749

Begin forwarded message:

From: "Bassirian, Zagros S." <zag.bassirian@procopio.com>

Date: November 30, 2021 at 1:03:34 PM PST

To: Oriet Cohen-Supple <oriet@wrightandsupple.com>

November 30, 2021 1:15 PM

Cc: "Turpin, Melissa Avitia" <Melissa.Turpin@procopio.com>, "Alessio, John D." <john.alessio@procopio.com>, Mary Wright <mary@wrightandsupple.com>

Subject: RE: Moorjani: Confirmation of Extension (October 18, 2021)

Oriet –

Hope all is well. We did not receive the proposal you mentioned in October, and while I see the FAC was filed on 11/22, we were not served with a copy. Please let us know the status of this case and whether you intend to serve the FAC. Thank you.

Best,

ZAG S. BASSIRIAN ASSOCIATE PROCOPIO

P. 619.906.5759 | F. 619.744.5478 | zag.bassirian@procopio.com

525 B STREET, SUITE 2200, SAN DIEGO, CA 92101

View Profile | LinkedIn | procopio.com

From: Oriet Cohen-Supple <oriet@wrightandsupple.com>

Sent: Thursday, October 21, 2021 9:14 AM

To: Bassirian, Zagros S. <zag.bassirian@procopio.com>

Cc: Turpin, Melissa Avitia <Melissa.Turpin@procopio.com>; Alessio, John D. <john.alessio@procopio.com>; Mary Wright <mary@wrightandsupple.com>

Subject: Re: Moorjani: Confirmation of Extension (October 18, 2021)

As to a proposal, I will reach out next week via email. Stay tuned.

Oriet Cohen-Supple, Partner Cell: 1-510-495-5749

On Oct 21, 2021, at 9:12 AM, Bassirian, Zagros S. <zag.bassirian@procopio.com> wrote:

Good Morning, Oriet –

Understood. Please confirm our clients need not respond to the complaint and your client will not seek a default in the interim.

On resolution, I believe you were going to make a proposal. Please do that under separate cover.

Oriet Cohen-Supple <oriet@wrightandsupple.com>

Resent-From: <deepak@alumni.duke.edu>

To: Deepak Moorjani <deepak@alumni.duke.edu>

FW: Moorjani: Confirmation of Extension (October 18, 2021)

Fyi and file

From: Oriet Cohen-Supple <oriet@wrightandsupple.com>

Sent: Tuesday, December 7, 2021 3:16 PM

To: Bassirian, Zagros S. <zag.bassirian@procopio.com>

December 7, 2021 3:16 PM

Cc: Turpin, Melissa Avitia <Melissa.Turpin@procopio.com>; Alessio, John D. <john.alessio@procopio.com>; Mary Wright <mary@wrightandsupple.com>

Subject: RE: Moorjani: Confirmation of Extension (October 18, 2021)

The client is in the process of transitioning to a new counsel. Either the client or the new counsel will contact you soon.

From: Bassirian, Zagros S. <zag.bassirian@procopio.com>

Sent: Tuesday, December 7, 2021 3:12 PM

To: Oriet Cohen-Supple <oriet@wrightandsupple.com>

Cc: Turpin, Melissa Avitia <Melissa.Turpin@procopio.com>; Alessio, John D. <john.alessio@procopio.com>; Mary Wright <mary@wrightandsupple.com>

Subject: RE: Moorjani: Confirmation of Extension (October 18, 2021)

Oriet –

I received a copy of the amended complaint in the mail and it was filed in pro per. Are you no longer representing Deepak?

Best,

ZAG S. BASSIRIAN ASSOCIATE PROCOPIO

P. 619.906.5759 | F. 619.744.5478 | zag.bassirian@procopio.com

525 B STREET, SUITE 2200, SAN DIEGO, CA 92101

View Profile | LinkedIn | procopio.com

From: Bassirian, Zagros S.

Sent: Tuesday, November 30, 2021 1:03 PM

To: 'Oriet Cohen-Supple' <oriet@wrightandsupple.com>

Cc: Turpin, Melissa Avitia <Melissa.Turpin@procopio.com>; Alessio, John D. <john.alessio@procopio.com>; Mary Wright <mary@wrightandsupple.com>

Subject: RE: Moorjani: Confirmation of Extension (October 18, 2021)

Oriet –

Hope all is well. We did not receive the proposal you mentioned in October, and while I see the FAC was filed on 11/22, we were not served with a copy. Please let us know the status of this case and whether you intend to serve the FAC. Thank you.

Best,

ZAG S. BASSIRIAN ASSOCIATE PROCOPIO

P. 619.906.5759 | F. 619.744.5478 | zag.bassirian@procopio.com 525 B STREET, SUITE 2200, SAN DIEGO, CA 92101

View Profile | LinkedIn | procopio.com

From: Oriet Cohen-Supple <oriet@wrightandsupple.com>

Sent: Thursday, October 21, 2021 9:14 AM

To: Bassirian, Zagros S. <zag.bassirian@procopio.com>

Cc: Turpin, Melissa Avitia <Melissa.Turpin@procopio.com>; Alessio, John D. <john.alessio@procopio.com>; Mary Wright <mary@wrightandsupple.com>

Subject: Re: Moorjani: Confirmation of Extension (October 18, 2021)

Turn static files into dynamic content formats.

Create a flipbook
Issuu converts static files into: digital portfolios, online yearbooks, online catalogs, digital photo albums and more. Sign up and create your flipbook.