Seeking comments related to unusual
SLAPP actions
SLAPP actions
Some PDFs will go here
What is this page?
On this page, you can get PDFs related to the Berliner-Cohen and Fremont-Toyota barratry cases. A few are readable. Some are complicated or a muddle.
These are the two PDFs that it's easiest to start with:
PDF 01:
Link: gagorder-cases.pdf
Case: All cases
Title: 25-page overview, read this one first
PDF 02:
Link: gagorder-trial-brief.pdf
Case: The two WVRO cases
Title: WVRO trial brief (2 combined cases)
Next, these are some of the original allegations and responses, including the anti-SLAPP motions:
PDF 03:
Link: 21CV004608-wv120.pdf
Case: 21-CV004608 (1st WVRO case)
Title: 1st WVRO filed against RJK.
PDF 04:
Link: 21CV004608-wv120-response.pdf
Case: 21-CV004608 (1st WVRO case)
Title: RJK's response to 1st WVRO.
PDF 05:
Link: 21CV004608-memo.pdf
Case: 21-CV004608 (1st WVRO case)
Title:
Respondent RJK's memorandum of points and authorities in support of
motion to strike complaint pursuant to code of civil procedure
S 425.16 (1st WVRO case).
PDF 06:
Link: 22CV005860-berliner-cohen.pdf
Case: 22-CV005860 (2nd WVRO case)
Title: 2nd WVRO filed against RJK.
PDF 07:
Link: 22CV005860-wv120-response.pdf
Case: 22-CV005860 (2nd WVRO case)
Title: RJK's response to 2nd WVRO.
PDF 08:
Link: 22CV005860-memo.pdf
Case: 22-CV005860 (2nd WVRO case)
Title:
Respondent RJK's memorandum of points and authorities in support of
motion to strike complaint pursuant to code of civil procedure
S 425.16 (2nd WVRO case).
PDF 09:
Link: 22CV006171-defamation.pdf
Case: 22-CV006171 (defamation case)
Title:
Fremont-Toyota and “Hank Torian” defamation complaint against RJK.
This one is odd
in that “Hank Torian” was deceased as of the date of filing. A dead
man isn't permitted to file this type of action.
PDF 10:
Link: 22CV006171-memo.pdf
Case: 22-CV006171 (defamation case)
Title:
Defendant RJK's memorandum of points and authorities in support of
motion to strike complaint pursuant to code of civil procedure
S 425.16 (defamation case).
Finally, assorted additional PDFs:
PDF 11:
Link: exhibits-04-pawar-hrletter.pdf
Title: Sam Pawar letter to Fremont-Toyota HR department
PDF 12:
Link: exhibits-11-ghiringhelli.pdf
Title: Brian Martin text messages related to Rachel Ghiringelli call
PDF 13:
Link: exhibits-12-pawar-220608.pdf
Title: Key Sam Pawar email from June 08, 2022
PDF 14:
Link: pawar-2020-08-15.pdf
Title: Sam Pawar EEOC filing August 15, 2020
PDF 15:
Link: sam-pawar-texts.pdf
Title: Sam Pawar text messages 2021 to 2022
PDF 16:
Link: fremont-toyota-inquiry.pdf
Title: PDF version of Brian Martin's story
PDF 17:
Link: gagorder-exhibits.pdf
Case: The two WVRO cases
Title: Exhibits filed by RJK (warning: large)