8/9/2019 07-07-09 Samaan v Zernik (SC087400) Countrywide Extortionist Letter by John Amberg Bryan Cave Llp -s

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John W. Amberg

Direct: 1-310-576-2280

Fax: 1-310-576-2200

jwamberg@bryancaye.com

July 9, 2007

VIA FACSIMILE AND OVERNIGHT MAIL

G. Richard Green, Esq.

Green & Marker

1875 Century Park East, Suite 1880

Los Angeles, California 90067

Bryan Cave ll P

120 Broadway, Suite 300

Santa Monica, CA 90401-2386

Tel (310) 576-2100

Fax (310) 576-2200

www.bryancave.com

Chicago

Hong Kong

Irvine

Re:

Subject:

Nine Samaan v. Tosevh Zernik:L

Los Angeles County Superior Court, Case No. SC087400

SECOND CEASE AND DESIST LETTER

Jefferson City

Kansas City

Kuwait

los Angeles

New York

Dear Mr. Green:

We write again to demand that your clientJoseph Zernik cease and desist from

harassing Countrywide and its officers and employees.

As you know, we represent Countrywide Home Loans, Inc. and related companies

("Countrywide"), and its officers and employees, who continue to be the targets of a

campaign of harassment by Joseph Zernik directed at them and through their

personal and business associates. Please give this second cease and desist letter to

your client.

On July 6, 2007, we sent you a cease and desist letter in response to Dr. Zernik's

unrelenting harassment of Countrywide officers and employees, his defamatory

statements about them, and his repeated efforts to contact personal and business

associates of Countrywide officers, including religious leaders, a retired judge, and

members of charity boards - despite the fact that none of these third parties have

anything to do with this lawsuit. Dr. Zernik's contacts with them were scurrilous and

malicious, and were intended solely to injure the reputation of Countrywide's officers

and employees in the community, and to attempt to pressure Countrywide.

TheJuly 6 cease

anddesist letter

demandedthe following:

S 101DOCS\644186.1

Phoenix

Shanghai

St. LOUIS

Washington. DC

And Bryan Cave,

A Multinational Partnership,

London

Digitally signed by

Joseph Zernik 

DN: cn=Joseph

Zernik, o, ou,

email=jz12345@e

arthlink.net, c=US

Date: 2010.05.12

11:16:57 +03'00'

8/9/2019 07-07-09 Samaan v Zernik (SC087400) Countrywide Extortionist Letter by John Amberg Bryan Cave Llp -s

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G. Richard Green, Esq.

July 9, 2007

Page 2

Bryan Cave LLP

1. That Joseph Zernik immediately cease and desist from contacting represented Countrywide

officers and employees, and shall communicate solely with Countrywide's designated legal counsel

regarding this case in the future;

2. That Joseph Zernik immediately cease and desist from contacting any personal associates of

Countrywide's officers and employees about this case or the business practices of Countrywide and its

officers and employees;

3. ThatJoseph Zernik retract the false and malicious statements that he has published to third

parties, including bu t not limited to his defamatory statements that Countrywide and its officers and

employees have committed fraud and colluded with plaintiff. Retraction should be made in the same

form and to the same persons to whom the defamatory statements were made, and proof of the

retractions shall be provided to the undersigned; and

4. That Joseph Zernik refrain from publishing any new defamatory statements about

Countrywide and its officers and employees.

We have learned that Dr. Zernik flagrantly ignored these demands, and published new defamatory

statements to personal and business associates of Countrywide's officers and employees. On Mondaymorning, July 9, 2007, at 3:36 a.m. and 5:33 a.m., Dr. Zernik sent outrageous emails to various

recipients regarding Countrywide and its officers, calling for the resignation of Countrywide's Chief

Legal Officer as President of the charity Bet Tzedek's Board of Directors, and maliciously mocking his

involvement with the organization. As with the previous emails about which we complained, Dr.

Zernik's latest emails continue to falsely accuse Countrywide of committing mortgage fraud and wire

fraud, which is outrageous. The recipients of Dr. Zernik's latest scurrilous emails included not only

members of the Bet Tzedek Board of Directors, bu t also others in the local business community.

These false and offensive communications must stop. Dr. Zernik has abandoned all professional

decency, and continues to mount an unprovoked assault on Countrywide and its officers and

employees. He has spread his defamatory statements across the community to persons with no

connection with his lawsuit. We reiterate our demand that Dr. Zernik must cease and desist.

Countrywide and its officers and employees reserve their rights to take any and all available legal

action against Dr. Zernik, and to seek all available remedies against him.

John W. Amberg

JWA:jcc

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