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Joseph Zernik
Jenna Moldawsky DN: cn=Joseph
Zernik, o, ou,
email=jz12345@e
120 Broadway
Suite 300
November 19, 2008
Santa Monica, CA 90401-2386
www.bryancave.com
David J. Pasternak
PASTERNAK, PASTERNAK & PATIO T LLP Chicago
Irvine
Re: Samaan v. Zernik, L.A.S.C. Case No. SC087400 Jefferson City
Kansas City
Dear Mr. Pasternak: Kuwait
london
As you know, we represent Countrywide Home Loans, Inc. ("Countrywide"), a non-
Los Angeles
party in the above-referenced matter. As reflected in the Court's Judgment dated
Milan
March 11,2008 (a copy of which Countrywide provided to you on March 11, 2008),
New York
Judge Friedman found that the Protective Order entered on July 23, 2007 directing
Phoenix
Dr. Zernik to communicate solely with Countrywide's designated counsel and no
Shanghai
other officers or employees regarding the present action was valid and enforceable.
St. Louis
The Court also found that Dr. Zernik had committed thirteen separate acts of
Washington, DC
contempt by willfully violating the Protective Order, and that he was to pay a fine to
Countrywide in the amount of $7,500 for the thirteen separate acts of contempt.
Bryan Cave International Trade
A TRAOE CONSULTING SUBSIOIARY
The collection of the $7,500 fine was suspended subject to certain conditions. The OF NON-LAWYER PROFESSIONALS
Court's Judgment states that "if Defendant Joseph Zernik further violates the www.bryancavetrade_com
Protective Order, upon five (5) days' written notice from Countrywide to Zernik, the Bangkok
Receiver shall pay $7,500 from the Receiver's Fund to Countrywide in care of its Jakarta
Manila
On November 12, 2008, Dr. Zernik violated the Protective Order by communicating
Shanghai
with Countrywide officers and employees regarding the present action. A copy of
Singapore
this email is attached for your reference. That same day, Countrywide sent a letter to
Tokyo
Dr. Zernik, informing him that he had violated the Protective Order. A copy of that
letter was sent to you on November 12, 2008. Bryan Cave Strategies
A GOVERNMENT RELATIONS ANO
POUTICAL AFFAIRS SUBSIOIARY
Pursuant to the Court's Judgment, in the event that Dr. Zernik violated the Protective www.bryancavestrategies.com
Order, you, as the Receiver in this matter, are authorized to pay the total amount of Washington, DC
the contempt sanctions to Countrywide in the care of its counsel of record, Bryan St. Louis
SMOlDOCS708953.1
Bryan Cave UP
David J. Pasternak
November 19, 2008
Page 2
Cave LLP, from the Receiver's Fund. Countrywide's letter to Dr. Zemik providing notice of his
violation is also attached for your reference.
Accordingly, at your earliest convenience, please provide me with a check in the amount of $7,500
made out to Countrywide Home Loans, Inc. reflecting payment from the Receiver's Fund. Please feel
free to contact me with any comments or questions.
~A-~vl&P~
J enna Moldawsky 0
JM:ak
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