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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'

John W. Amberg
Direct: 1-310-576-2280
Fax: 1-310-576-2200
jwamberg@bryancaye.com

Bryan Cave llP

120 Broadway, Suite 300


July 9, 2007
Santa Monica, CA 90401-2386

Tel (310) 576-2100

Fax (310) 576-2200

www.bryancave.com
VIA FACSIMILE AND OVERNIGHT MAIL

G. Richard Green, Esq.


Green & Marker Chicago

1875 Century Park East, Suite 1880 Hong Kong

Los Angeles, California 90067 Irvine

Jefferson City
Re: Nine Samaan v. Tosevh Zernik
~ :L
Kansas City
Los Angeles County Superior Court, Case No. SC087400 Kuwait

los Angeles
Subject: SECOND CEASE AND DESIST LETTER New York

Phoenix
Dear Mr. Green: Shanghai

St. LOUIS
We write again to demand that your client Joseph Zernik cease and desist from Washington. DC
harassing Countrywide and its officers and employees.
And Bryan Cave,
A Multinational Partnership,
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 London

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.

The July 6 cease and desist letter demanded the following:

S~ 10 1DOCS\ 644186.1
Bryan Cave LLP
G. Richard Green, Esq.
July 9, 2007
Page 2

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. That Joseph Zernik retract the false and malicious statements that he has published to third
parties, including but 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 Monday
morning, 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, but 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
SMOlDOCS\644186.1

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