{ Converted to text using OCR. The PDF is the controlling document. The Exhibit is in the PDF. JM}

 

 

SEVERIN A. CARLSON

Nevada Bar No. 9373

KAEMPFER CROWELL

510 West Fourth Street

Carson City, Nevada 89703

Telephone: (775) 882-1311

Fax: (775) 882-0257

scarlson@kcnvlaw.com

 

Attorneys for Defendant REZA ZANDIAN

 

IN THE FIRST JUDICIAL COURT OF THE STATE OF NEVADA

IN AND FOR CARSON CITY

 

  

JED MARGOLIN, an individual,

            Plaintiff,

VS.

 

OPTIMA TECHNOLOGY CORPORATION, a California corporation, OPTIMA TECHNOLOGY CORPORATION, a Nevada corporation, REZA ZANDIAN aka GOLAMREZA ZANDIANJAZI aka GHOLAM REZA ZANDIAN aka REZA JAZI aka J. REZA JAZI aka G. REZA JAZI aka GHONONREZA ZANDIAN JAZI, an individual, DOE Companies 1-10, DOE Corporations 11-20, and DOE Individuals 21-30,

             Defendants.

 

 

Case No.: 090C00579 1B

Dept. No.: 1

 

 

 

 

 

 

AFFIDAVIT OF SEVERIN A. CARLSON IN RESPONSE TO AMENDED ORDER GRANTING MOTION TO WITHDRAW

 

 

STATE OF NEVADA            )  ss.

COUNTY OF WASHOE        )

 

SEVERIN A. CARLSON, being first duly sworn, under penalty of perjury, deposes and states:

 

Page 1 of 5

 

 

1.   I am an attorney licensed to practice law in the State of Nevada and am a partner with the law firm of Kaempfer Crowell, counsel for Defendant REZA ZANDIAN aka GOLAMREZA ZANDIANJAZI aka GHOLAM REZA ZANDIAN aka REZA JAZI aka J. REZA JAZI aka G. REZA JAZI aka GHONONREZA ZANDIAN JAZI ("Zandian") in the above-entitled action.

 

2.   I have personal knowledge of all matters stated herein and could and would competently testify as to the matters set forth herein and make this affidavit under penalty of perjury.

 

3.   On January 7, 2016, the Court entered an Amended Order Granting Motion to Withdraw as Counsel ("Amended Order").

 

4.   In the Amended Order, the Court placed a condition on the withdrawal of counsel, stating that withdrawal would not be complete until a service address for Zandian in Nevada and/or California had been provided.

 

5.   This Affidavit is made in response to the Amended Order with respect to the conditional withdrawal.

 

6.   On or about January 7, 2016, Zandian provided to this office a residency certificate setting forth his residential address in France, albeit in French. A true and correct copy of said certificate is attached hereto as Exhibit 1.

 

7.   Zandian's son lives in California and his address has been provided by Zandian as an acceptable means of service on Zandian.

 

8.   Zandian's son's name is Alborz Zandian and his address is 9 MacArthur Place, Unit 2105, Santa Ana, California 92707-6753.

 

Page 2 of 5

 

 

9.   This address has been the. address where correspondence and invoices for my firm have been sent since March 5, 2014. None of the correspondence or invoices have been returned as undeliverable at any point in time.

 

10.   I am unaware of any other address where Zandian may reside or conduct business in Nevada or California.

 

11.   Zandian's last known email address is rezazand@hotmail.com.

 

FURTHER AFFIANT SAYETH NAUGHT.

 

 

____________________________

SEVERIN A. CARLSON

 

 

SHERYL A. HASCALL

Notary Public State of Nevada

No. 13-11538-2

My appt. exp. Nov. 2, 2016

 

Subscribed and sworn to before me by Severin A. Carlson this 12th day of January, 2016.

 

_______________________________

NOTARY PUBLIC in and for said

County and State

 

My Commission Expires: 11/2/2016 

 

Page 3 of 5

 

 

CERTIFICATE OF SERVICE

 

I, the undersigned, hereby certify that on the 12th day of January, 2016, I caused the foregoing AFFIDAVIT OF SEVERIN A. CARLSON IN RESPONSE TO AMENDED ORDER GRANTING MOTION TO WITHDRAW to be served this date by depositing a true copy of the same for mailing at Reno, Nevada, first class postage fully prepaid and addressed to the following:

 

Matthew D. Francis, Esq.

Adam P. McMillen, Esq.

Watson Rounds

5371 Kietzke Lane

Reno, Nevada 89511

775.324.4100

775.333.8171 - facsimile

Attorneys for Plaintiff

 

Reza Zandian

c/o Alborz Zandian

9 MacArthur Place, Unit 2105

Santa Ana, California 92707-6753

Defendant

 

Gholam Reza Zandian Jazi

6 rue Edouard Fournier

75116 Paris

France

Defendant

 

 

I also caused the foregoing AFFIDAVIT OF SEVERIN A. CARLSON IN RESPONSE TO AMENDED ORDER GRANTING MOTION TO WITHDRAW to be served this date by e-mail to Defendant as follows:

 

rezazand@hotmail.com

 

 

____________________________

an employee of Kaempfer Crowell

 

Page 4 of 5

 

 

EXHIBIT INDEX

 

EXHIBIT

DESCRIPTION

PAGES

1

French residency certificate

4

                       

Page 5 of 5

 

 

The French Residency Permit was so poorly reproduced that it is worthless. Carlson’s office sent us some better ones.

 

If you want to see what Reza Zandian (aka .............) actually looks like click here.

 

JM