"The price of justice is eternal publicity." Arnold Bennett
Ken Hamidi's Request For Admission
Ken Hamidi's request for admissions, set3 Ken Hamidi's request for admissions, set 2 Intel's response to request for admissions, set 1 Ken Hamidi's request for admissions, set 1
KOUROSH KENNETH HAMIDI 7349 CROSS DRIVE CITRUS HEIGHTS, CA 95610 (916) 729 3097 In Propia Persona
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SACRAMENTO
INTEL CORPORATION, No. 98AS05067
Plaintiff
v. REQUEST FOR ADMISSIONS
KOUROSH KENNETH HAMIDI and FACE - Intel, a purported California nonprofit organization, Defendant
PROPOUNDING PARTY: DEFENDANT- KOUROSH KENNETH HAMIDI
RESPONDING PARTY- PLAINTIFF- INTEL CORPORATION
SET NUMBER: THREE (3)
YOU are requested to admit within thirty (30) days after service of this Request for Admis sions that each of the following facts below are true.
DEFINITIONS
In connection with these Requests for Admissions, the following definitions shall apply:
I . "HAMIDI" shall mean Defendant KOUROSH KENNETH HAMIDI.
2. "YOU" and "YOUR" shall mean Responding Party and any agent, officer, employee, group of employees, employer, attorney, accountant, investigator, wholly owned subsidiary, OR anyone else acting on YOUR behalf.
3. Terms not defined in these Requests for Admissions shall have their ordinary AND usual meanings.
REQUESTS FOR ADMISSIONS REQUEST FOR ADMISSION NO. 1: YOU submitted YOUR internet usage guideline, entitled "E-mail, Internet, and Computer-use Guideline. HR Guidelines:Work Environment 20.014a," as an exhibit to a declaration in support of YOUR Motion for Preliminary Injunction. REQUEST FOR ADMISSION NO. 2: YOUR internet usage guideline, entitled "E-mail, Internet, and Computer-use Guideline. HR Guidelines:Work Environment 20.014a," permits reasonable personal use by employees of networked computer equipment, but reminds employees that the resources are YOUR property.YOU submitted YOUR internet usage guideline, entitled "E-mail, Internet, and Computer-use Guideline. HR Guidelines:Work Environment 20.014a," as an exhibit to a declaration in support of YOUR Motion for Preliminary Injunction. REQUEST FOR ADMISSION NO. 2: YOUR internet usage guideline, entitled "E-mail, Internet, and Computer-use Guideline. HR Guidelines:Work Environment 20.014a," permits reasonable personal use by employees of networked computer equipment, but reminds employees that the resources are YOUR property.
Dated: February 12, 1999
Kourosh Kenneth Hamidi
| KOUROSH KENNETH HAMIDI |
| 7349 CROSS DRIVE |
| CITRUS HEIGHTS, CA 95610 |
| (916) 729 3097 |
| In Propia Persona |
SUPERIOR COURT OF THE STATE OF CALIFORNIA |
COUNTY OF SACRAMENTO |
| INTEL CORPORATION, | No. 98AS05067 |
Plaintiff |
|
| v. | REQUEST FOR ADMISSIONS |
| KOUROSH KENNETH HAMIDI and | |
| FACE - Intel, a purported California | |
| nonprofit organization, | |
Defendant |
|
PROPOUNDING PARTY: DEFENDANT- KOUROSH KENNETH HAMIDI
RESPONDING PARTY: PLAINTIFF- INTEL CORPORATION
SET NUMBER: TWO (2)
YOU are requested to admit within thirty (30) days after service of this Request for Admis sions that each of the following facts below are true.
DEFINITIONS
In connection with these Requests for Admissions, the following definitions shall apply:
I . "HAMIDI" shall mean Defendant KOUROSH KENNETH HAMIDI.
2. "YOU" and "YOUR" shall mean Responding Party and any agent, officer, employee, group of employees, employer, attorney, accountant, investigator, wholly owned subsidiary, OR anyone else acting on YOUR behalf.
3. Terms not defined in these Requests for Admissions shall have their ordinary AND usual meanings.
REQUESTS FOR ADMISSIONS
REQUEST FOR ADMISSION NO. 1: YOU submitted YOUR internet usage guideline, en titled "E-mail, Internet, and Computer-use Guideline. HR Guidelines:Work Environment 230.014a," as an exhibit to a declaration in support of YOUR Motion for Preliminary Injunction.
REQUEST FOR ADMISSION NO. 2: YOUR internet usage guideline, entitled "E-mail, Internet, and Computer-use Guideline. HR Guidelines:Work Environment 230.014a," permits reasonable personal use by employees of networked computer equipment, but reminds employees that the resources are YOUR property.
REQUEST FOR ADMISSION NO. 3: Reasonable personal use by some of YOUR employees includes internet access for the purposes of sending or receiving appropriate electronic mail.
REQUEST FOR ADMISSION NO. 4: YOU connect directly or indirectly to the internet in sending or receiving some electronic mail.
REQUEST FOR ADMISSION NO. 5: Some of YOUR employees use the internet, directly or indirectly, to send or receive electronic mail.
Dated: February 2, 1999
(Signed by Ken Hamidi)
Kourosh Kenneth Hamidi
Intel's response to Hamidi's request for admissions (set 1)
| LINDA E. SHOSTAK (Bar No. 64599) |
| MICHAEL A. JACOBS (BAR No. 111664) |
| KURT E. SPRINGMANN (BAR NO. 196813) |
| MORRISON & FOERSTER |
| 425 Market Street |
| San Francisco, California 94105-2482 |
| Telephone: (415)268-7000 |
| Attorneys for Plaintiff |
| INTEL CORPORATION |
SUPERIOR COURT OF THE STATE OF CALIFORNIA |
COUNTY OF SACRAMENTO |
| INTEL CORPORATION, | No. 98AS05067 |
Plaintiff |
|
| v. | Department: 53 |
PLAINTIFF INTEL |
|
| CORPORATION'S RESPONSES | |
| KOUROSH KENNETH HAMIDI and | TO DEFENDANT KOUROSH |
| FACE - Intel, a purported California | KENNETH HAMIDI'S |
| nonprofit organization, | REQUEST FOR ADMISSIONS |
Defendant |
SET ONE |
| Trial Date: Not set. | |
REQUESTING PARTY: Defendant Kourosh Kenneth Hamidi
RESPONDING PARTY: Plaintiff Intel Corporation
SET NUMBER: One
Pursuant to California Code of Civil Procedure section 2033, plaintiff
INTEL CORPORATION ("Intel") submits the following responses and objections to defendant Kourosh Kenneth Hamidi's Requests for Admission, Set No. One (the "Requests"), served on December 17, 1998:
PRELIMINARY STATEMENT
ntel has conducted a diligent search and reasonable inquiry in response tothe Requests. However, Intel has not completed its investigation of the factsstates that Intel does not sell software that prevents unauthorized electronic mail access to computer systems.
| Dated: January 14, 1999 |
| LINDA E. SHOSTAK |
| MICHAEL A. JACOBS |
| KURT E. SPRINGMANN |
| MORRISON & FOERSTER LLP |
related to this case, has not completed discovery in this action, and has not completed its preparation for any trial that might be held herein. Its responses to these Requests are based upon information currently known to Intel and are given without prejudice to Intel's right to supplement, add to, amend, or modify its responses to these Requests. Moreover, Intel reserves the right to make use of, or introduce at any hearing or at trial, documents or facts not known to exist at this time, including, but not limited to, documents obtained in the course of discovery in this action.
Subject to and without waiving the foregoing Preliminary Statement, Intel makes the responses to the Requests:
RESPONSES TO INDIVIDUAL REQUESTS FOR ADMISSION REQUEST FOR ADMISSION NO. 1: REQUEST FOR ADMISSION NO. 1:
YOU submitted YOUR internet usage guideline, entitled "E-mail, Internet, and computer-use Guideline. HR Guidelines: Work Environment 230.014 as an exhibit to YOUR Motion for Preliminary Injunction.
RESPONSE TO REQUEST FOR ADMISSION NO. 1:
Intel denies this Request. Intel submitted Intel's internet usage guideline, "E-mail, Internet, and Computer-use Guideline HR Guidelines: Work Environment 20.014a" as an exhibit to a declaration in support of Intel's Motion for Preliminary Injunction.
REQUEST FOR ADMISSION NO. 2:
YOUR internet usage guideline, entitled "E-mail, Internet, and Computeruse Guideline. HR Guidelines: Work Environment 230.014a," does not prohibit reasonable personal use by employees of networked computer equipment. RESPONSE TO REQUEST FOR ADMISSION NO. 2:
Intel denies this Request. Intel's internet usage guideline, "E-mail, Internet, and Computer-use Guideline HR Guidelines: Work Environment 20.014a" permits reasonable personal use, but reminds employees that these resources are the property of Intel.
REQUEST FOR ADMISSION NO. 3:
Reasonable personal use by YOUR employees of YOUR networked computer equipment includes accessing the internet for the purposes of sending and receiving electronic mail.
RESPONSE TO REQUEST FOR ADMISSION NO. 3:
Intel denies this Request. This Request is overly broad because Intel determines reasonable personal use as circumstances require. Reasonable personal use for some Intel employees includes internet access for the purposes of sending or receiving appropriate electronic mail.
REQUEST FOR ADMISSION NO. 4:
YOU received electronic mail from FACEINTEL over the internet. RESPONSE TO REQUEST FOR ADMISSION NO. 4:
Intel admits this Request.
REQUEST FOR ADMISSION NO. 5:
YOU must connect to the internet in order to receive electronic mail transmitted over the internet.
RESPONSE TO REQUEST FOR ADMISSION NO. 5:
Intel objects to this Request on the grounds that it is ambiguous and would require Intel to speculate as to the nature and scope of the admission sought in the use of the phrase "must connect." Subject to and without waiving this objection, Intel states that Intel connects directly or indirectly to the internet in sending or receiving some electronic mail.
REQUEST FOR ADMISSION NO. 6:
YOU have never received electronic mail from FACEINTEL other than by YOUR voluntary accessing of the internet.
RESPONSE TO REQUEST FOR ADMISSION NO. 6:
Intel objects to this Request on the grounds that it seeks information that is not in Intel's possession, custody or control. Intel further objects to this Request on the grounds that it is ambiguous because of the use of the phrase "voluntary accessing." Subject to and without waiving these objections, Intel states that Intel has received at least six mass electronic mailings from defendants by the internet. Intel further states that Intel has insufficient knowledge to answer as to whether defendants have ever sent electronic mail using any means other than the internet.
REQUEST FOR ADMISSION NO. 7:
YOU have one or more intranet communications systems that do not require YOU to access the internet for YOUR intra-company communications via the use of YOUR networked computers.
RESPONSE TO REQUEST FOR ADMISSION NO. 7:
Intel states that some Intel employees communicate without accessing the internet, but that many employees require internet access for electronic mail communication.
REQUEST FOR ADMISSION NO. 8:
YOUR employees make use of the internet for the purposes of sending and receiving electronic mail.
RESPONSE TO REQUEST FOR ADMISSION NO. 8:
Intel states that some Intel employees use the internet, directly or indirectly, to send or receive electronic mail.
REQUEST FOR ADMISSION NO. 9:
YOU sell software designed to prevent unauthorized access to proprietary computer systems.
RESPONSE TO REQUEST FOR ADMISSION NO. 9:
Intel objects to this Request on the grounds that it seeks information outside the scope of the instant lawsuit. Intel further objects to this Request on the grounds that it is ambiguous because of the use of the phrase "designed to prevent unauthorized access." Subject to and without waiving these objections, Intel
(sigend by Kurt E. Springmann)
Kurt E. Springmann
Attorneys for Plaintiff INTEL CORPORATION
Hamidi's request for admissions (set 1)
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SACRAMENTO
INTEL CORPORATION, No. 98AS05067
Plaintiff
v. REQUEST FOR ADMISSIONS
KOUROSH KENNETH HAMIDI and FACE - Intel, a purported California nonprofit organization, Defendant
PROPOUNDING PARTY: DEFENDANT- KOUROSH KENNETH HAMIDI RESPONDING PARTY. PLAINTIFF- INTEL CORPORATION SET NUMBER: ONE (1)
YOU are requested to admit within thirty (30) days after service of this Request for Admis-sions that each of the following facts below are true.
DEFINITIONS:
In connection with these Requests for Admissions, the following definitions shall apply:
1. "HAMIDI" shall mean Defendant KOUROSH KENNETH HAMIDI.
2. "YOU" and "YOUR" shall mean Responding Party and any agent, officer, employee, 6 group of employees, employer, attorney, accountant, investigator, wholly owned subsidiary, OR anyone else acting on YOUR behalf.
3. Terms not defined in these Requests for Admissions shall have their ordinary AND usual meanings.
4. FACEINTEL shall mean Defendant FACE-INTEL, a purported California nonprofit organization.
REQUESTS FOR ADMISSIONS:
REQUEST FOR ADMISSION NO. 1: YOU submitted YOUR internet usage guideline, entitled "E-mail, Internet, and Computer-use Guideline. HR Guidelines:Work Environment 230.014a," as an exhibit to YOUR Motion for Preliminary Injunction.
REQUEST FOR ADMISSION NO. 2: YOUR internet usage guideline, entitled "E-mail, Internet, and Computer-use Guideline. HR Guidelines:Work Environment 230.014a," does not prohibit reasonable personal use by employees of networked computer equipment.
REQUEST FOR ADMISSION NO. 3: Reasonable personal use by YOUR employees of YOUR networked computer equipment includes accessing the internet for the purposes of sending and receiving electronic mail.
REQUEST FOR ADMISSION NO. 4: YOU received electronic mail from FACEINTEL over the internet.
REQUEST FOR ADMISSION NO. 5: YOU must connect to the internet in order to receive electronic mail transmitted over the internet.
REQUEST FOR ADMISSION NO. 6: YOU have never received electronic mail from FACEINTEL other than by YOUR voluntary accessing of the internet.
REQUEST FOR ADMISSION NO. 7: YOU have one or more intranet communications systems that do not require YOU to access the internet for YOUR intra-company communications via the use of YOUR networked computers.
REQUEST FOR ADMISSION NO. 8: YOUR employees make use of the internet for the purposes of sending and receiving electronic mail.
REQUEST FOR ADMISSION NO. 9: YOU sell software designed to prevent unauthorized access to proprietary computer systems.
Dated: December 11, 1998
(Signed by Ken Hamidi)Kourosh Kenneth Hamidi
