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If pos­si­ble, review a few of the other links on the home page as well.

Contents:

01. Introduction

02. Jurisdiction and case numbers

03. List of 10 attorneys involved

04. List of others involved

05. Overview of the cases

06. Disclaimer on websites

07. Alleged defamation

08. Role of Sam Pawar

09. Role of Brian Martin

10. Role of Rachel Ghiringhelli

11. Detailed history of the cases

12. More allegations against Kiraly

Appendix A. Top half of Sam Pawar's EEOC filing

Appendix B. Sam Pawar's statement to Kiraly

01. Introduction.

This docu­ment discusses 3 legal cases initiated by 2 firms: an auto deal­er­ship named Fremont-Toyota and a law firm named Berliner-Cohen. One unusual part is that Berliner-Cohen is a party to the cases and doesn't sim­ply represent Fremont-Toyota.

Ten (10) attorneys have been in­volved directly or indirectly.

The goal of the cases is to obtain a gag order re­la­ted to alleged mass fraud, racist con­duct, hate speech, and attorney misconduct on the part of Fremont-Toyota and Berliner-Cohen.

The demand is that the respondent, Robert Kiraly aka “OldCoder”, be barred lit­er­al­ly from saying the “name” of anybody on the other side. The other side is try­ing for a life­time gag order and for a multi-year order if that fails. Surprisingly, a life­time gag order may actu­al­ly be pos­si­ble through 1 of the 3 cases.

This docu­ment is a draft. The date of this draft is 2023-10-28.

02. Jurisdiction and case num­bers.

03. List of 10 attorneys in­volved.

04. List of others in­volved.

05. Overview of the cases.

From 2020 to 2021, RJK work­ed with a P.I. named Brian Martin on a situation that in­clud­ed a kidnap­ped infant who'd been raised under a false name, adult-child sexual inter­ac­tions, pos­si­ble drug use by the adult in­volved, and other elements.

None of the peo­ple involved had any known con­nection to Fremont-Toyota or Berliner-Cohen.

Brian Martin had been a former “Reality P.I.” for Fox TV. At a later point, Berliner-Cohen made this an issue in the legal cases.

In Decem­ber 2020, B. Martin purchased a truck from Fremont-Toyota. In Spring 2021, he asked RJK to look at anomalies in the trans­ac­tion. RJK did so as a personal favor and found fraud. RJK then post­ed a state­ment by B. Martin online. To see the state­ment, click here.

In Decem­ber 2021, an ex-em­ploy­ee of the deal­er­ship saw B. Martin's state­ment and came for­ward. This was Sam Pawar. The ex-em­ploy­ee alleged systemic fraud, hate speech, and other con­duct on the part of Fremont-Toyota employees.

RJK post­ed S. Pawar's state­ment online. To see the state­ment, click here.

Fremont-Toyota filed anti-violence actions against both B. Martin and RJK immed­iate­ly after that. The dealer­ship didn't file against S. Pawar and instead threatened S. Pawar for months. As part of this, in June 2022, the deal­er­ship tried to force S. Pawar to sign a false pre-writ­ten state­ment.

RJK was never served in per­son. On the alleged date of ser­vice in February 2022, RJK was about 100 miles away.

However, Brian Martin was served in mid-Jan­uary 2022. Brian then re­ceived an unusual phone call from an ex-em­ploy­ee of the dealer­ship named Rachel Ghiring­helli. Rachel G. made sexual harass­ment allega­tions against the head of the dealer­ship, Kamal Sayed Hashimi aka Mark Hashimi.

RJK responded to the ser­vice on B. Martin and to the phone call from Rachel G. by wri­ting email to two parties, attorney Chris­tine Long and deal­er­ship lead Mark Hashimi. RJK sent copies of that email to a num­ber of peo­ple.

RJK also sent a smaller mailing that was intended to mock public statements by an em­ploy­ee, Raffi Hashemi, who was alleged to have taken money from Sam Pawar.

The other side responded to the email by filing two addi­tion­al actions against RJK: an anti-violence action on the part of the law firm Berliner-Cohen and a de­fa­ma­tion action on behalf of a dead man, Henry Kha­cha­tur­ian, as well as parties who weren't deceased.

Many of the al­le­ga­tions against RJK are false or frivolous. The cases have con­tin­ued regard­less be­cause of these ele­ments:

(a) RJK used the word “Jihadi” to charac­terize the be­ha­vior of the group at Fremont-Toyota that had allegedly engaged in hate speech. Chris­tine Long has focused on the word “Jihadi” to dis­tract atten­tion from the racist con­duct at Fremont-Toyota that Sam Pawar has alleged.

(b) RJK registered Internet domains for nom­in­a­tive and/or bio­graph­i­cal use. For example: “fremont­toyota.org”. Chris­tine Long has misrepresented nom­in­a­tive use as “impersonation”.

(c) Brian Martin's state­ment included a Cc list of snail-mail addresses. A LinkedIn photo of Mark Hashimi was used on an email page to identify Hashimi's email for the reader. A pos­si­ble residence address for Mark Hashimi was post­ed as part of an attempt to identify him con­clu­sive­ly for pro­cess service. Chris­tine Long has con­flat­ed these and simi­lar elements to sug­gest that a violence tar­get list existed.

The rest of the story is covered in detail in part 11 be­low, “Detailed history of the cases”.

06. Disclaimer on web­sites.

RJK's web­sites have always in­clud­ed the fol­low­ing notice or simi­lar notices. These notices have been prom­inent­ly dis­play­ed on Site Notices pages:

“Statements of Fact. Statements are based on belief and best un­der­stand­ing of facts and are not neces­sarily statements of fact except where this is explicit­ly stated. People with knowledge of facts that may be rele­vant to content are invited to sug­gest cor­rec­tions or additions.”

07. Alleged de­fa­ma­tion.

These are initial notes on alleged de­fa­ma­tion. More in­for­ma­tion will be add­ed here as neces­sary.

08. Role of "Sam" Pawar.

The heart of the cases is a Fremont-Toyota ex-em­ploy­ee named Kulwant S. Pawar aka Sam Pawar.

Sam has alleged mass fraud and racial hatred on the part of Fremont-Toyota employees. Sam's most explicit remarks about mass fraud are in­clud­ed in part 11 be­low. See also Appendix A be­low, Sam's EEOC filing, and Appendix B be­low, Sam's state­ment to RJK.

In 2022, Sam was repeatedly threatened by the other side, told that a Court had ordered him to do a takedown, and directed to sign a false state­ment [which he refused to sign]. Chris­tine Long seems to have arranged these steps using Richard Oriakhi as a proxy.

C. Long's filings have repeatedly suggested that fraud al­le­ga­tions are about a single truck transaction and that Sam and his al­le­ga­tions of fraud and racial hatred don't even exist.

09. Role of Brian Martin.

Chris­tine Long has focused on Brian Martin for two reasons:

(a) The putative, and false rea­son is a colorful story Ms. Long has concocted to the effect that B. Martin hated Muslims and hired RJK to help him create false al­le­ga­tions against a virtuous Muslim group of fraud. Or vice versa. It's a muddle.

(b) The actual rea­son is that C. Long is hoping to find and use pattern evi­dence that RJK “harassed a former landlord”.

This allega­tion has already been made with­out evidence. Note: C. Long seems to have contacted the landlord in ques­tion in 2022 and asked him to testify in the gag-order cases. The landlord seems to have refused.

For the facts behind that situation, including notes on a kidnapping and incidents of adult-child sexual con­duct, see part 12 be­low.

The part where B. Martin does come into it is as fol­lows.

At one point, RJK lived with a couple whose wife had an adult daughter. The daughter used the name “Bianca”. Her actual birth name was ap­par­ent­ly “Maria”. Maria had used at least 6 names, regard­less, since coming to the U.S.

Maria took an infant out of the Philippines in the 1990s and raised the child in the U.S. This was a parental kid­nap­ping. The infant, a boy, is be­lieved to have been her biological son. However, this seems to have been against a Court order and the infant's biological father is be­lieved not to know what hap­pen­ed to his son.

RJK phoned the FBI and ICE about the kidnapping. This is part of the alleged “harassment”. RJK also asked B. Martin to try to find the infant's birth records. The idea was to identify the biological father and tell him that his son was still alive.

In an odd note, Maria had a second child, a boy named Logan, by another man in the U.S. and engaged in inap­pro­priate con­duct with the boy when he was age 9. A re­la­ted state­ment that Logan filed with the Court is in­clud­ed in part 12 be­low.

RJK hired an attorney to retrieve Court records re­la­ted to alleged sexual inter­ac­tions between Maria and Logan. RJK doesn't recall involving B. Martin in this part.

RJK asked B. Martin to retrieve other types of public records re­la­ted to Maria and the extended family in­volved. RJK located other public records himself as well. In this manner, RJK learned that his landlord had ap­par­ent­ly paid to fly Maria and the kidnapped infant out of the Philippines and had provided housing there­after.

Brian Martin did other things for RJK as well. He checked, RJK thinks, to see if RJK's parents were still aive, he acted as intermediary in a bus­i­ness matter, and he hosted a small birthday celebration for RJK in 2021.

None of this had any­thing to do with Fremont-Toyota. However, Chris­tine Long has been try­ing to claim that it did.

Brian Martin was a former “Reality P.I.” for Fox TV. In an odd note, one of Chris­tine Long's al­le­ga­tions against RJK is that “everyone knows that TV detectives are frightening”.

10. Role of Rachel Ghir­ing­hel­li.

Rachel G. is an ex-em­ploy­ee of Fremont-Toyota. In Jan­uary 2022, Rachel G. phoned Brian Martin. In the phone call, she allegedly made de­tail­ed allegations of sexual har­ass­ment against Kamal Sayed Hashimi aka Mark Hashimi. Rachel G. spoke in detail for half an hour.

Brian Martin had been served with a TRO. RJK had not been served. Both B. Martin and RJK be­lieved at the time that Rachel G.'s phone call was an attempt by C. Long to set up false al­le­ga­tions of TRO violations. This was one of the factors that led to RJK wri­ting email to the other side a few days later.

In Fall 2023, RJK learned that Rachel G. had ap­par­ent­ly left Fremont-Toyota be­fore the phone call to Brian Martin. The implication was that Rachel G.'s sexual har­ass­ment allegations against Mark Hashimi had been true after all.

11. Detailed history of the cases.

Some phrases are bolded be­low to make this easier to skim.

Spring 2012 to Spring 2013: RJK's father Jim and one brother, Tom, filed two RO cases, more or less combined, in a failed attempt to get a gag order against RJK. The gag order was intended to prevent dis­cus­sion of physical violence by Jim against RJK's mother Grace. The 2012 to 2013 cases are rele­vant today be­cause Christine Long has filed an al­le­ga­tion related to those cases. This is dis­cus­sed in part 12 be­low.

August 2012: Fremont-Toyota, an auto deal­er­ship in the S.F. Bay Area, settled an EEOC law­suit filed by Afghan-American ex-employees who had alleged hate speech and discrimination based on their eth­nici­ty.

2012 to 2020: Control of daily oper­a­tions at Fremont-Toyota shifted to an Afghan-Amer­ican and/or Muslim group. Ironically, the group seems to have engaged in the same type of hate speech and dis­crimination that had been alleged in the other direction.

February 2020: A man of India descent and Hindu faith, Kulwant S. Pawar aka Sam Pawar, joined Fremont-Toyota as a sales­per­son.

Winter to Summer 2020: Sam Pawar learned that the deal­er­ship was engaging in mass fraud. Employees also talked about how minorities were “smelly”.

Sam was confused by this be­ha­vior and reluctant to go along with it. His earnings were theref­ore confiscated and transferred to others, including a co-worker named Raffi Hashemi who plays a role in the current gag-order cases. The deal­er­ship stated that this was “punishment” for Sam's failure to com­mit fraud.

Sam was subjected as well to hate speech such as “Mother-F*cker you can't call us brother be­cause you aren't Muslim” and “Go and pray to your Hindu god be­cause no one else will help you”.

The “Mother-F*cker” state­ment is referenced in Sam's EEOC com­plaint, which you can see in Appendix A be­low.

Summer to Fall 2020: RJK initially engaged P.I. Brian Martin for steps dis­cus­sed earlier in this docu­ment. There was no known con­nec­tion to Fremont-Toyota or Berliner-Cohen.

August 15, 2020: Ex-em­ploy­ee Sam Pawar filed an EEOC com­plaint against Fremont-Toyota. He sign­ed up with an attorney named Richard Oriakhi. Neither RJK nor B. Martin knew Sam Pawar at this point. The three didn't become acquainted until over a year later.

Fall 2020: RJK relocated from Cal­i­for­nia to Washington State.

December 2020: Brian Martin purchased a truck from Fremont-Toyota. There were some unusual parts to this. For details, see Brian's state­ment on the web­site abuse of pro­cess dot net.

Winter to Spring 2021: RJK and Brian Martin re­main­ed in com­mun­i­ca­tion by phone. Brian is be­lieved to have work­ed on the infant birth records task dur­ing this period. RJK start­ed to think of Brian as a friend.

Spring 2021: Brian Martin's wife noticed some­thing odd about the truck loan pay­ments. Brian called Fremont-Toyota to dis­cuss the issue. Fremont-Toyota ignored Brian's calls.

May 11, 2021: A man named Henry Kha­ch­a­tur­ian aka “Hank Torian” died of being 90 years old. This was the current or past owner of Fremont-Toyota. It ap­pears that some attorneys used to sue Henry and/or his businesses for fraud on a reg­u­lar basis.

The May 11, 2021 date is worth noting be­cause Henry filed a law­suit against Robert Kiraly over half a year later despite the fact that he was now deceased.

Spring to Summer 2021: RJK return­ed to Cal­i­for­nia. Brian asked RJK to look at the details of the truck transaction. RJK did so. He found that the transaction had in­volved fraud. RJK edited a state­ment for Brian, post­ed the state­ment, and asked Brian to confirm that the details were accurate.

July 2021: The dealership's attorneys, Berliner-Cohen, reviewed the web­site. RJK noticed their visits and email­ed them to propose mediation. They didn't respond.

Half a year later, Chris­tine Long said that be­cause RJK had writ­ten to a “non-White” [sic] attorney when he could have chosen a “White” attorney, this was proof of racial hatred and intent to commit violence against the law firm.

December 2021: “Sam” Pawar, the Fremont-Toyota ex-em­ploy­ee who'd alleged fraud, contacted Brian Martin after seeing Brian's story online.

Another witness had turned up. Her story had been nearly iden­tical to Brian's story. But “Sam” was the clincher. He'd witnessed the fraud taking place. This is the condensed version of Sam's state­ment that you'll find in the Court papers:

See also Appendix A be­low, Sam's EEOC filing, and Appendix B be­low, Sam's state­ment to RJK.

Sam was Hindu and the majority of the Fremont-Toyota employees in­volved were Muslim. Sam add­ed that the employees had made statements to him such as “Mother-F*cker you can't call us brother be­cause you aren't Muslim” and “Go and pray to your Hindu god be­cause no one else will help you”.

In the end, Sam alleged, he was fired be­cause he wouldn't go along with the fraud. He filed an EEOC action.

RJK post­ed Sam's state­ment online. As dis­cus­sed below, the deal­er­ship then filed anti-violence actions against Brian Martin and RJK. RJK didn't know about this at the time be­cause he wasn't served. Fremont-Toyota didn't file against Sam. In filings, Chris­tine Long tried to pre­tend that Sam didn't exist. At the same time, Sam was threatened repeatedly.

January 2022: In mid-Jan­uary 2022, Brian Martin, was served as part of a WVRO action. Note: “WVRO” means workplace violence restrain­ing order. Brian was now under a TRO or temporary restrain­ing order.

A woman named Rachel Ghir­ing­hel­li then phoned Brian Martin. Rachel spoke for half an hour about the dealership's general mana­ger, Kamal Sayed Hashimi aka Mark Hashimi. Rachel made de­tail­ed allega­tions of sexual har­ass­ment by Mark Hashimi.

RJK responded to the filing against B. Martin and Rachel G.'s phone call by sending email to Opposing Counsel Chris­tine Long and Mark Hashimi. RJK made no in­ap­pro­pri­ate threats and used no unredacted obscenities. He Cc'd quite a few peo­ple.

The other side had filed a WVRO against RJK but RJK didn't know this at the time. The other side responded to the email by filing a second WVRO — on behalf of Opposing Counsel's law firm — and a de­fa­ma­tion case.

The de­fa­ma­tion case was filed partly on behalf of a man, Henry Kha­ch­a­tur­ian, who'd died 7 months be­fore. He used to own about a dozen auto deal­er­ships in the Bay Area.

Henry Khachaturian's daughters Daphne Khacha­turian aka Daphne Kavich and Natasha Kha­ch­a­tur­ian aka “Tasha Torian” are be­lieved to be the peo­ple who are indirectly bankrolling the legal actions, though this is uncon­firm­ed.

February to March 2022: RJK was never served with the first WVRO. He was about 100 miles away when it was allegedly served.

RJK re­tain­ed attorney Nabiel Ahmed for the first WVRO. Nabiel obtained a continuance.

Nabiel was a practicing Muslim. During Ramadan 2022, he and RJK dined at dusk one evening. Nabiel grumbled that fasting made him feel unwell but he respected the rules.

The key al­le­ga­tion against RJK was that RJK had used the word “Jihadi”. Nabiel didn't have a problem with that. He agreed to go after Chris­tine Long's focus on the word. The agree­ment was that the cases would be “all Jihadi all the time”.

RJK start­ed to feel confident.

Nabiel was event­u­al­ly served with the second WVRO and the de­fa­ma­tion action. He agreed to handle the second WVRO case, but not the defam­a­tion case. RJK retain­ed attorney Seth Wiener for the latter case.

Spring 2022: Sam Pawar, the ex-em­ploy­ee of Fremont-Toyota, notified RJK that he [Sam] was being threat­ened.

In one incident, Sam was told that a judge had ordered Sam to make RJK take down Sam's state­ment about Fremont-Toyota. RJK had both Nabiel Ahmed and Seth Wiener check this. The matter had never gone be­fore a Court. It ap­pears that attor­ney Richard Oriakhi may have mis­in­form­ed his client Sam Pawar.

March to May 2022: Nabiel Ahmed and Seth Wiener work­ed on initial filings re­la­ted to the cases.

Nabiel exhibited passion. He seemed to dive into the WVRO cases. Seth was far more con­ser­va­tive and reserved on his side.

Nabiel start­ed to display stress re­la­ted to a Family Law case of his own. That case was about Nabiel's two pre-school children and vis­i­ta­tion rights.

Nabiel asked RJK if he [Nabiel] seemed to be mentally ill. Nabiel had fired two Family Law attorneys. RJK found him a third attorney. RJK also vetted some of the paper­work for Nabiel's personal case.

Nabiel felt that his new Family Law attorney wasn't work­ing out. One day, he was furious at his attorney and threw his phone. It struck his desk, skidded across, and narrowly missed RJK. RJK wasn't too concerned.

But Nabiel grew more distracted and disoriented. His ex-wife had alleged hard drug use and drug use may have been a factor. Ultimately, on the day that a num­ber of filings were due, Nabiel hadn't start­ed them. RJK phoned Nabiel. Nabiel said, “I'm sh*tting on the toilet and that's all the time I have for you”.

Seth W. took over the WVRO cases. The switch of attorneys was expensive. Nabiel had hosed RJK. But Nabiel asked RJK to continue to help with Nabiel's Family Law case. RJK agreed to do so. Seth con­sid­er­ed filing against Nabiel. However, Seth didn't do so be­cause, in part, RJK was still work­ing on Nabiel's case.

Nabiel sent other filings from his practice for RJK to review as well, continuing this part to October 2023. It was an unusual attorney-client relation­ship.

June 08, 2022: Sam Pawar notified RJK that some­thing unusual had hap­pen­ed. Sam Pawar's attorney, Richard Oriakhi, had hand­ed Sam a pre-writ­ten false state­ment re­la­ted to RJK's cases and ordered Sam to sign it. Sam had refused. Here is Sam's let­ter to RJK about the incident:

“Richard” above is Sam Pawar's EEOC attorney Richard Oriakhi of Lafayette, Cal­i­for­nia.

Fall 2022 anti-SLAPP issue : Nabiel Ahmed and Seth Wiener had filed 3 motions known as anti-SLAPPs between them. Neither attorney had warned RJK that, if you lose these motions, you may be exposed to large penalties.

The 3 motions lost. C. Long announced that she planned to seek the penalties. As of late 2023, the outcome isn't de­cid­ed. There are obstacles to what C. Long is attempting but some risk to RJK's side regard­less.

In one of many odd notes, in September 2023, Chris­tine Long es­sen­tial­ly sued Seth Wiener and not just RJK as part of the anti-SLAPP issue. Seth used to speak positively of Chris­tine but this is no longer the case.

Nabiel had de­cid­ed to do two anti-SLAPPs be­cause, he ex­plain­ed later, he thought that he'd be able to charge the other side a huge amount despite his not billing that amount to RJK. Nabiel was ap­par­ent­ly hoping to get $60,000 to $80,000.

When the anti-SLAPPs failed and C. Long brought up the penalties, Nabiel said he'd tell the State Bar that he'd warned RJK of the risks. He add­ed, “That's my story and I'm sticking to it.”

Seth Wiener, in comparison, was honest about his own anti-SLAPP. Seth's com­ment was, “I can't tell you everything”.

Fall 2022 with Seth Wiener : There was nothing connecting RJK phy­si­cal­ly to Fremont-Toyota or Berliner-Cohen. So, to shore up the WVROs, Chris­tine Long alleged that RJK had post­ed a photo of Mark Hashimi online that RJK had taken himself in per­son. Hashimi said that this was, quote, “scary”. But it was his LinkedIn photo.

Seth Wiener filed a suborn per­jury allegation against Chris­tine Long in re­sponse. The Court ignored the filing.

Note: Nabiel Ahmed had filed an al­le­ga­tion of a conscious lie by Chris­tine Long herself previously. The Court ignored that as well.

Fall 2022 with Nabiel Ahmed : In Fall 2022, RJK rewrote a key motion in Nabiel's Family Law case. The motion succeeded. Nabiel now had more access to his two preschool children.

Nabiel bought steaks for himself and RJK to celebrate. RJK estimated that his steak had cost him $15,000.

Nabiel didn't want to do any­thing for RJK, steak notwithstanding. However, Nabiel in­volved RJK further in his life.

Nabiel had had an older son with a past lover. In 2022, the boy, then about age 13, had an alleged sexual affair with his de facto step­father; i.e., the boy's mother's adult male lover.

Nabiel reported this to the police. The boy and his mother were furious about the police report. Nabiel put RJK on the phone in a call with them. The point was for RJK to be a witness. RJK wanted to help but felt that this was an unusual attorney-client rela­tion­ship.

Note: This isn't the adult-child sexual situation that Chris­tine Long has tried to use to her advan­tage. The details of that situ­a­tion are in part 12 be­low.

On a lighter note, one day, Nabiel found a little bird, a fledging, in the street, unable to fly. He captured it and phoned RJK to ask RJK how to save the bird's life. It's tricky be­cause it isn't safe for peo­ple to feed fledglings.

RJK sent Nabiel to the Alexander Lindsay Junior Museum in Walnut Creek. RJK remem­ber­ed it from the 1960s and it was still there over 50 years later. They knew what to do with the little bird.

Christmas 2022: Chris­tine Long said to Seth Wiener that RJK was in vio­la­tion of mul­ti­ple ROs in unre­la­ted cases and of the TROs in the current cases. In fact, there were no other cases and no other ROs existed.

Chris­tine Long demanded that RJK agree never in his life to state the “name”, lit­er­al­ly just the name, of any party on her side. The penalty for saying the words “Christine Long” was to be $100,000. C. Long add­ed that they might drop it to $75,000.

If RJK didn't agree to this, Chris­tine Long said, she'd file a false al­le­ga­tion of a TRO vio­la­tion with the Court. RJK refused. C. Long didn't repeat the threat.

Winter 2023: Chris­tine Long seemed to drop most of the other side's demands. The other side now seemed to want mostly things that RJK had already agreed to. This in­clud­ed the transfer of a dozen Internet domains to the other side's pos­ses­sion. RJK was fine with that. He'd offer­ed the other side the domains months be­fore, but they hadn't been inter­est­ed at the time.

However, in mid-February 2023, C. Long demanded that set­tle­ment be reworked be­cause RJK might have “lied” in some unspeci­fied manner about the domains.

RJK had had enough nonsense. He sur­ren­der­ed the domains to the reg­is­trar involved. This meant that RJK no longer had the domains.

Chris­tine Long's re­sponse to that was to tell Seth Wiener that RJK must have hidden the domains some­where and there would be no settle­ment with­out them.

The domain reg­is­trar was Namecheap. Seth Wiener and RJK refer­red Christine Long to Namecheap's attorney, Eugene Rome. Note: You can Google Eugene Rome. He's well-known in this context.

In March 2023, Eugene Rome said that he'd try to find out what had hap­pen­ed to the domains. But he didn't fol­low through at the time.

Spring 2023: In Spring 2023, RJK re­tain­ed another attorney, Andrew Dósa, spec­i­fic­al­ly to talk with Chris­tine Long. C. Long told Andrew Dósa that there would be “no remaining issues” as long as she got the 12 Internet domains.

May to July 2023: RJK had sur­ren­der­ed 12 Internet domains in February 2023. He no longer had control of them. However, he event­u­al­ly persuaded attorney Eugene Rome, who now control­led the domains, to release them.

The domains were to go to Chris­tine Long as part of a settle­ment. However, C. Long now demanded that she get the domains with­out an agree­ment. RJK declined to go along with that.

Eugene Rome said that he'd release the Internet domains on a particular date in July 2023. The idea was that whoever registered the domains first after that would get them. But the domains were released two days early with­out notice to RJK's side. It's be­lieved that peo­ple working for Chris­tine Long took most of the domains immed­iate­ly.

Eugene Rome disclaimed responsibility for the early release of the domains. However, his ex­plana­tion contra­dict­ed earlier email. So, Mr. Rome may have violated attorney con­duct rules, but this is a side issue.

Seth Wiener asked Chris­tine Long to state what she wanted, now that she had the domains. C. Long didn't respond at the time.

Early October 2023: RJK re­tain­ed another attorney, Arkady Itkin, to speak with Chris­tine Long. The goal was to fig­ure out what C. Long was think­ing.

Chris­tine Long's focus on the gag order had odd aspects. She was seeking lit­er­al­ly to bar the mention of “names”. A gag order of that magnitude could be used to call attention to it­self. It would have the oppo­site of the desired effect.

No gag order can prevent a victim of abuse of pro­cess from pointing to the gag order it­self. Addi­tion­al­ly, the victim can't be barred from posting pleadings. Put the two facts together and gag orders can lead to the publicity that a petitioner or plaintiff is seek­ing to avoid.

For example, some­body could send physical postcards to news media that read like this:

RJK wanted to know if Chris­tine Long understood that it would ulti­mate­ly be impossible to keep the story out of public awareness. That the ap­pro­priate thing to do would be to set­tle. So, RJK pressed Arkady Itkin to speak with Ms. Long.

Arkady spoke by phone with Chris­tine wice. The calls seem to have been about listen­ing to Chris­tine reiterate demands. In the end, RJK knew no more than be­fore.

October 12, 2023: Seth Wiener and RJK showed up in per­son for a Court hearing. Chris­tine Long was there was well.

Seth and RJK dis­cus­sed Chris­tine Long at lunch afterward. The conclusion was that there were three pos­si­ble explan­a­tions for her behavior:

(a) Chris­tine might be focused on an unrealistic gag order so as to get more fees out of her clients. Assess­ment: Possible but unlike­ly.

(b) Chris­tine might be accommodating the unrealistic demands of one of her clients, Kamal Sayed Hashimi aka Mark Hashimi. Assess­ment: Likely.

(c) Chris­tine might be so emotionally in­volved so that she was irrational. Assess­ment: Possi­ble but not cer­tain.

Late October 2023: A new attorney, Douglas Vining, stepped into the de­fa­ma­tion case on RJK's side. Seth Wiener con­tin­ued to handle the WVRO cases.

12. More al­le­ga­tions against Kiraly.

The 3 legal cases include frivolous al­le­ga­tions against RJK. For example:

* RJK chose to write to a “non-White” attorney when a “White” attorney was avail­able.

* RJK is autistic.

* RJK proposed mediation.

* RJK talked about going to the police.

* RJK's associate Brian Martin was “frightening” be­cause he'd been a television P.I.

These are actual al­le­ga­tions in the Court papers. It seems strange. There are, how­ever, more sig­ni­fi­cant allegations. Some are dis­cus­sed below.

* “Kiraly refer­red to Chris­tine Long as a rapist of an attorney.” The al­le­ga­tion is true.

* “Kiraly described the Muslim hate-speech group as Jihadis.” The al­le­ga­tion is true. The word “Jihadi” is dis­cus­sed in detail in part 07 above.

* “Kiraly boasted about possessing guns and being skilled with them.” The al­le­ga­tion is false. Chris­tine Long filed this al­le­ga­tion based on a blog post and omitted a key element of the post. The omission is a viola­tion of evi­dence rules.

In fact, be­fore Thanksgiving 2021, RJK had never fired a gun in his life and wouldn't live in a house where guns were present. But, to show respect for Brian Martin, RJK went with B. Martin to Martin's preferred shoot­ing range dur­ing the holiday period and expressed pride in managing to hit a tar­get.

* “Kiraly said that Chris­tine Long's parents, long deceased, would be ashamed of her.” The al­le­ga­tion is true.

* “Kiraly wrote to minors.” The al­le­ga­tion is false. RJK provided Brian Martin with a Cc list for a snail-mail let­ter. RJK email­ed the other side as well. In both contexts, RJK made a good-faith effort to identify adults who were asso­ciated with the companies in­volved. If there were minors on any list, RJK wasn't aware of it at the time.

* “Kiraly post­ed the phone num­bers of every em­ploy­ee online.” The al­le­ga­tion is false. RJK post­ed Kamal Sayed Hashimi's bus­i­ness cell-phone num­ber online. Hashimi had sent it to Brian Martin himself and RJK post­ed it as part of an effort to confirm his identity.

RJK also post­ed screenshots of text messages that a Fremont-Toyota em­ploy­ee had sent to Brian Martin. A bus­i­ness phone num­ber may have been visi­ble there.

RJK doesn't recall posting a non-bus­i­ness phone num­ber for anybody in the cases.

* “Kiraly post­ed the residence addresses of every em­ploy­ee online.” The al­le­ga­tion is false. Aside from the Cc list dis­cus­sed below, RJK post­ed residence addresses for two parties that he pre­sent­ly recalls and for specific reasons.

Chris­tine Long had said that Brian Martin must be using illegal means to obtain in­for­ma­tion. RJK pulled addresses for Chris­tine and Kamal Sayed Hashimi out of Google to show that Chris­tine was lying. RJK also post­ed a pos­si­ble address for Kamal Sayed sep­ar­ate­ly with the intention of locating him so that he could be served and sued.

There was also a Cc list buried in a PDF that Brian Martin had snail-mailed. RJK hadn't redacted the Cc list but he did so when he realized that it was being mis­repre­sent­ed.

* “Kiraly sought intimate personal secrets of Chris­tine Long.” The al­le­ga­tion is false. RJK sought in­for­ma­tion for the purpose of wri­ting a book that was far less intimate or personal than that which is found in any typical biography. A biography or other book that is intend­ed to serve the pub­lic in­ter­est isn't sim­ply legal; it may be protect­ed.

* “Kiraly impersonated peo­ple.” The al­le­ga­tion is false. RJK registered Internet domains for nom­in­a­tive use. If le­gi­ti­mate and reason­able purposes are in­volved, this use isn't a “cyber­attack”, “cyber­squatting”, or illegal or even inappro­priate in any way.

RJK hosted email addresses on the same domains. He was careful to use qualifiers so as to protect his right to nom­in­a­tive use. The email name “Fremont-Toyota Review” is an example of this type of use.

* “Kiraly harassed a former landlord and he post­ed terrible lies.” The al­le­ga­tion is false.

Actually, RJK was dragged into a situation where a woman named Maria had kidnapped an infant. Years later, Maria engaged in inappro­priate acts with that child's younger half-brother Logan when Logan was 9 years old. These events are dis­cus­sed in part 09 above.

The image be­low is a hand-writ­ten statement that Logan filed with the Court at age 9. Chris­tine Long of Berliner-Cohen has tried to use adult-child miscon­duct to serve her own ends. A reason­able per­son will agree that this is inappro­priate:

Statement filed by 9-year-old boy

The kidnapping men­tion­ed previously is equally important. Chris­tine Long has little to be proud in her con­duct.

* “Kiraly harassed Raffi Hashemi in particular”. RJK did, in fact, send email that mocked public statements Raffi Hashemi had made.

Raffi Hashemi was a Fremont-Toyota em­ploy­ee who took money from Sam Pawar that Sam had earned. It appear­ed at the time that this was part of Sam's [quote] “punishment” for not going along with a practice of fraud. Note: There is no known family con­nec­tion between Raffi Hashemi and Kamal Sayed Hashimi.

So, Raffi Hashemi was part of an oper­a­tion that con­sid­er­ed minorities to be inferior and that sanctioned fraud. But Raffi post­ed online that he was raising his sons to be honorable.

RJK email­ed about four of Raffi's neighbors and mocked the thought that Raffi was honorable. But what RJK was referring to wouldn't have been known to anybody out­side of Fremont-Toyota, so it was pointless.

* “Kiraly boasted about violating past restraining orders.” The al­le­ga­tion is false. Actually, RJK was never in his life under any restraining order other than TRO and Chris­tine Long wasn't talking about TRO. This was a conscious false state­ment by Chris­tine.

C. Long was referring to a pair of gag-order cases that had run from 2012 to 2013. RJK's father Jim and one brother, Tom, had sought a gag order re­la­ted to marital violence. There was never even a Court-backed settle­ment in the cases; the Court declined to be in­volved in one. So, RJK was never under an order in those cases even at the set­tle­ment level.

RJK was also never under any order other than TRO either be­fore or after that.

The “boasts” that Chris­tine Long was referring to were about the fact that two attorneys had left their companies. One attorney had been attempting to trade physical favors for legal services and the other attorney wasn't properly licensed. RJK did nothing but point out these issues.

If Chris­tine Long approves of attorney misconduct, that is her decision. It hardly constitutes a valid al­le­ga­tion against RJK.

In closing:

But, then, it isn't a surprise. We're talking about an attorney, Chris­tine Long of Berliner-Cohen, who said that an offer to go to medi­ation with the State Bar was a threat of physical violence. Who said that remarks about talking to the FBI were illegal as well. And who add­ed that “everyone knows television detectives are frightening” and sought an anti-violence order on that basis. Who tried to use an infant kidnapping and adult-child sexual con­duct to her advan­tage as well. Sure, the cases make perfect sense.

Appendix A. Top half of Sam Pawar's EEOC filing.

Note: Naqib Halimi's full state­ment to Sam Pawar about the Muslim faith was as follows: “Mother-F*cker, you can't call us brother be­cause you aren't Muslim”. That state­ment is, in and of it­self, a reason­able definition of “Jihadi”.

Sam Pawar's EEOC state­ment

Appendix B. Sam Pawar's state­ment to Kiraly.

The happiest day of my life came when I got a job at Fremont-Toyota as an Internet Auto Sales Manager. It seemed like a great op­por­tun­ity.

Things turned negative, though, within a few days.

Sam's story: The Dodge van:

I sold a Dodge van to an Indian couple. They asked me, “Can we get a lower in­ter­est rate?”

I told them, “I'm in the Sales Depart­ment. I can handle the sale but for interest-rate ques­tions, you'll need to talk to the Finance per­son.”

I took the couple to the Finance Depart­ment and left them there. The Finance Manager on duty was Ayub Mohammad Jalal.

After 5 to 10 minutes, I heard raised voices. I went back to that office to see what was hap­pen­ing. The Indian couple was very upset. They said that they didn't want to buy the van or any vehicle from Fremont-Toyota in the future.

I asked, “What happened?” They said that Ayub had told them to get out of his office. I asked them to calm down and said I'd go talk to Ayub.

I asked Ayub Mohammad Jalal the same question: “What happened?”

Ayub was furious. He shouted at me, “Why you tell them about the lower in­ter­est rates?! How can we make money if we tell them about those rates?!”

I was shocked but re­main­ed calm. I responded, “Sir, only the Finance per­son can answer the type of ques­tions that the cus­tom­ers were asking. I brought them to you be­cause that is the pro­ce­dure.”

I wasn't sure of what to do next. I brought the couple back in and tried to straight­en things out.

Ayub Mohammad Jalal start­ed to rage again. He said, “All of you Indians are like that!!” He threw a file on the floor and shouted at me, "Stupid salesperson!! Why you tell­ing them about lower in­ter­est rate!!"

I said, “Sir, you can't talk to me like this”. Ayub shouted, "F*ck you! Get out of my office, you stupid man!"

It took 15 to 20 minutes to calm everybody down. In the end, a deal was reached and the cus­tom­ers bought a vehicle.

I felt distressed by the incident. Ayub had made in­sult­ing remarks about Indians and the remarks about “F*ck you” and “you stupid man” weren't espe­cial­ly respect­ful.

However, the part that concerned me the most was the fact that Fremont-Toyota's goal in this case seemed to be, not to profit from a le­gi­ti­mate sale, but to drive up the customers' costs by, in effect, lying to them.

Sam's story: The Toyota RAV4:

I sold a Toyota RAV4. It was late at night. The Finance per­son on duty was Naqib U. Halimi.

I went to the office and asked, “When can I bring my current cus­tom­ers in to sign?” Naqib told me to get out and wait. He called me in and I was surprised to learn that he'd credit­ed half of the deal to another sales-per­son.

I asked Naqib, “What's going on? What are you doing?” He said, “You asking lower in­ter­est rate from Ayub Mohammad Jalal and that's your pun­ish­ment. I'm taking your half-deal and giving to other per­son.”

“You can't do that,” I said. “I'll com­plain to the manager”. Naqib start­ed to laugh. He said, “Go and com­plain to your Hindu god also and no one will help you”.

I complained and Naqib was correct. Nobody in man­age­ment did a thing. They seemed to think that it was amusing.

This hap­pen­ed more than once. In fact, it became a reg­u­lar oc­cur­rence.

Sam's story: The Toyota Thundra:

I sold my first Toyota Thundra truck. I asked one ques­tion of an Internet sales mana­ger named Raffi Mohammed Hashemi.

To complete the deal, I was required to enter cus­tom­er in­for­ma­tion into soft­ware that I hadn't been trained on. It was sup­posed to be Raffi's role to answer ques­tions about this. So I asked him, “How do I do this?”

Raffi came and sat at my table and pressed a button and filled in the cus­tom­er in­for­ma­tion. That was all.

We were paid two types of checks, one for base salary and one for com­mis­sion. A few weeks after the Thundra deal closed, I re­ceived the com­mis­sion check that was sup­posed to cover that deal It showed just half the amount.

The pro­ce­dure was that we were sup­posed to ask the desk mana­ger about pay­ment issues. I did so. He told me that they'd given Raffi half of my com­mis­sion be­cause Raffi had helped me. He add­ed, “Don't waste time asking about this. Go make another sale.”

Every company has its own policies. But this wasn't normal.

Sam's story: Trying to stop the racial attacks:

I talked to my boss Abdul Alocozy. I told him that Naqib Halimi was giving me a hard time.

Abdul talked to the two of us about the situation. He told me, “You've only been here a week. Why are you causing problems?” But that was only a little. He said a lot more to Naqib. So, I thought that things would improve.

But things didn't improve.

The sales pro­cess required me to get num­bers from the Sales Desk. When I tried to get the num­bers, they called me “Mr. Curry”. They called me “Mr. Turtle” as well be­cause I walked slowly due to age and medical issues. They mocked me in other ways. It was unpleas­ant.

I asked one per­son, “Why is this happening?” He said, “It's be­cause you complained about Naqib Halimi. It isn't just that these peo­ple are all Afghans and Muslims. They're re­la­ted by marriage. So, they're going to make you pay for in­sult­ing a rela­tive.”

I said to myself, “It's O.K. Time and patience will solve the problems. I'll just con­cen­trate on my work. I drive 2 hours to get here, 2 hours to go home, and they're calling me Mr. Curry and Mr. Turtle. But I love my job even if it isn't going well at Fremont-Toyota.”

Sam's story: Ajmal Mohabat:

Ajmal Mohabat, a closer, tar­get­ed me.

A closer is the per­son who's assigned to manipulate cus­tom­ers who are sus­pi­cious about pos­si­ble fraud. Their role is to soothe the cus­tom­ers and tell them that every­thing is fine and they should just agree to the deal that is being offer­ed.

Ajmal lied to anybody about any­thing. I don't think that he'd know a true state­ment if it bit him on the rear end. In my case, he sabotaged my sales. I found out that he was talking to cus­tom­ers who'd come in to buy from me and try­ing to per­suade them to buy from Muslims instead.

I asked Ajmal about one cus­tom­er that he'd talked to. Ajmal said, “Oh, he doesn't want to buy and he has bad credit besides.”

I called the cus­tom­er. He said, “I told Ajmal Mohabat that I was there to buy from Kulwant Pawar and nobody else and he tried to change my mind”.

I ended up selling that cus­tom­er a truck. Ajmal Mohabat was angry. His reaction was, “You in­sult­ed me by selling to a cus­tom­er when I said he didn't want to buy”.

The sales­people in the aud­i­ence under­stand that sales sabotage is con­sid­er­ed not just disrespectful but open warfare. Good sales­people feel strongly about cus­tom­ers and sales.

(end of document)