Case Status page for

 Silverstein v. Alivemax, Nauder Khazan, Mellisa Khazan, Stiforp, NameCheap, Inc., et al.

 

Spam Home

Barbie SLAPP

Sorehands.com

Spam case status

Spam resources

About this site

Some humor

Press coverage

Feedback

Home

 In Association with Amazon.com

October 12, 2012Court overruled NameCheap's demurrer. NameCheap still refuses to respond to discovery.
August 24, 2012Filed a motion to compel further responses to my second set of interrogatories propounded upon NameCheap. It only asked for the list of the domain names they provide WhoisGuard for.

Filed a motion to compel the deposition of Raquel Khazanedar. She has no defense to her failure to appear, as she neither objected nor respond to my letter to her asking about her failure to appear.

August 14, 2012Filed 4 Motions to Compel Further Responses against Even though NameCheap waived objections, by not responding in time, the responses consisted solely of objections. NameCheap's primary objection is that they are immune from prosecution, therefore they do not have to respond to discovery.
July 13, 2012Raquel Khazanedar did not appear at a properly noticed deposition.
July 11, 2012Filed a demurrer to the answer of Nadar Khazanedar, as it contains boilerplate and nonsensical affirmative defenses. In California when filing an answer to a well pled verified complaint, you must answer with the same level of pleading -- meaning you can't just give boilerplate answers without any facts behind it.

 

Also, filed a motion to strike the answer and enter default or in the alternative enter a judgment on the pleadings. Nadar Khazanedar's attorney, David Gold, had already admitted, uder oath, admitted that the complaint is true. Since Gold admitted that the complaint is true, there is nothing to dispute.

July 5, 2012Nadar Khazanedar filed an amended answer. Almost identical to the prior answer, but this time the attorney verified the answer, instead of admitted that the complaint is true. Why would the attorney verify the answer, unless Nadar Khazanedar has something to hide? This practice is frowned upon under California law, because the Courts are suspicious when the party fails to swear under oath that a pleading is true.
June 11, 2012Default entered against Raquel Khazanedar.
July 6, 2012Filed a demurrer to the answer of Nadar Khazanedar, as it contains boilerplate and nonsensical affirmative defenses. In California when filing an answer to a well pled verified complaint, you must answer with the same level of pleading -- meaning you can't just give boilerplate answers without any facts behind it.

Also, filed a motion to strike the answer and enter default or in the alternative enter a judgment on the pleadings. Nadar Khazanedar's attorney, David Gold, admitted that the complaint is true. Since Gold admitted that the complaint is true, there is nothing to dispute.

  
July 1, 2012Defendant NameCheap filed a demurrer against Plaintiff's complaint. NameCheap is being sued as the owner of some of the domain names being advertised, WhoisGuard. NameCheap is claiming immunity under 47 USC 230 because it is a registrar. However, courts have ruled NameCheap that WhoisGuard is outside of its role as registrar and therefore not entitled to immunity.
June 28, 2012NameCheap served responses to discovery. All objections, claiming that it is not responding because it is immune from lawsuit. However, it had waived all objections, because it had missed the discovery response deadline.
May 31, 2012Default entered against Build4Future, LLC.
May 24, 2012David Gold, Nadar Khazanedar's attorney, admitted that the allegations in the complaint is true.

Nadar Khazanedar filed an answer, but left his wife, Melissa Khazanedar, and daughter, Raquel Khazanedar to fend for themselves. Nadar does not verify the answer, but has his verified that my complaint is true.

April 23, 2012Added the names, Build4Future, LLC Nadar Khazanedar, Melissa Khazanedar, and Raquel Khazanedar as Does.
 Went down the the address they have listed on the web site for the business. It is not a real address, but at the UPS store.  I examined the records of the UPS store and found that there is no  Nauder Khazan, but the name on his drivers license is really Nadar Khazanedar. The name of the company is really Build4Future, LLC, a Nevada LLC. The officers of Build4Future, LLC, are Nadar Khazanedar, Melissa Khazanedar, and Raquel Khazanedar.  If Alivemax is why wouldn't they use their real names and identify the company? Legitimate businesses don't hide.
April 5, 2012Filed the First Amended Verified Complaint to include NameCheap, and Alivemax's other name, stiforp.
March 16, 2012Filed a the original verified complaint.
January 1, 2012Sent a certified letter complaining of spam to Nauder and Melissa Khazan. According to their web site, they founded Alivemax. There is no such entity as Alivemax registered with the state of California.
January 1, 2012In 2011, I started receiving spam advertising Alivemax. Alivemax seems to be a multi-level marketing scheme for vitamin supplement This spam was to a unique e-mail address I used with only one unrelated company. Then, I got similar spam for Stiforp, which looks like a multi-level scheme to market Alivemax.

Alivemax.com, according to the whois information is owned by "Nutri Max Ltd" at 5753 G Santa Ana canyon Road Unit #512 Anaheim Hills, CA 92807. However, there is no Nutri Max Ltd registered anywhere in the United States, according to Knowx.com. I found out that the the address was not a legitimate address. Stiforp.com, on the web site states that its address is also the same as Alivemax's address. However, the whois information on stiforp.com states that stiforp.com is owned by NameCheap.

Why would any legitimate business lie about the names of the people who run it? Why would any legitimate business lie about it's real address? Why would any legitimate business hire NameCheap to hide its identity.

 

Shop Amazon's Outlet Deals in Computers, Office & Software Computers,


Another William Silverstein site. Copyright ©2002-2013 William Silverstein. All rights reserved.

This site is copyrighted material and its use is subject to non-exclusive license. If you do not agree to the terms of this license, leave this site immediately, or you are bound by the terms of the license. Your use of this site signifies your agreement to be bound by the terms of this license. The use of this site is free for personal and non-commercial use - particularly for those wish to learn about and protect the rights of employees and those who oppose their abuse by employers and large corporations, but there are significant fees charged for certain other uses.

This page are the opinions of William Silverstein based on facts and information provided to him.  This is not to be construed as legal advice. Mattel is the manufacturer of Barbie, Matchbox, and Hot Wheels. This site is neither approved nor endorsed by Mattel. All trademarks belong to their respective owners.

Your use of this site acknowledges that you waive for yourself, your client, and your employer any and all claim against Silverstein for any action that relating to this site. If you don't agree to this, leave this site immediately.  Your use of this site signifies your acceptance of these  terms in this paragraph and the terms of use for the_ site. Assume that any email going to the barbieslapp.com domain will be going to a California resident and to a fax machine. All e-mail going to this domain is being handled by a California e-mail service provider using servers in California that prohibit unsolicited commercial e-mail.