Aaron Greenspan is very scared. He knows that if the truth gets out about his fraudulent charity’s criminal activity, he is done for. That’s why the Aaron Greenspan stalker story is keeping him up at night. As usual, Greenspan is doing everything he possibly can to keep evidence of his crimes from the public eye.

We still have five posts left to publish (chapters 8, 9, 10, 11, and the conclusion), but Aaron Greenspan is already starting to sweat. In fear and desperation, Greenspan has filed yet another ridiculous motion demanding an unconstitutional court order to remove all blog posts mentioning his name from this website. Once more, Aaron Greenspan’s embarrassingly poor understanding of the law shines through in his latest motion.

Aaron Greenspan submitted over 600 pages of documents to the court in today’s filings, but we’ll go through the highlights together here now.

Here is the proposed order Aaron Greenspan drafted, which explains what he wants the court to do:

First Greenspan wishes for us to “immediately and permanently remove” any “settlement correspondence from any website within [our] control”, and to “block access to or delete any posts concerning Aaron Greenspan published after September 2, 2020 until such time as the Court orders otherwise”. He also wishes to conduct discovery, despite being repeatedly told that discovery is stayed. Finally, he threatens our attorneys by asking that they be referred to the Standing Committee on Professional Conduct.

Why would Aaron Greenspan be so desperate to hide his attempts at extortion and the story about his charity’s criminal harassment? My guess is that he knows he’s headed to prison if the story stays up. Unfortunately for Greenspan, there is this obscure law called the “first amendment to the U.S. Constitution” that prohibits any law “abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances”. Perhaps he would have heard of this amendment to the constitution if Harvard Law hadn’t refused to let him take classes due to his low IQ.

Here’s what Aaron Greenspan wrote in his latest motion:

Plaintiff Aaron Greenspan (“Plaintiff”) will and hereby does move the Court to compel Defendants Omar Qazi and Smick Enterprises, Inc. (the “Qazi Defendants”) to immediately comply with the Court’s September 2, 2020 Order Re Default and Civility, ECF No. 72.

Greenspan Motion to Silence Critics

What was the court order on civility and default? For those who haven’t been following along too closely, let me refresh your memory:

Download the full court order as a PDF

In this September 2 court order, the judge admonished Aaron Greenspan for his complete lack of civility and professionalism in court. You can’t just go into court and harass people, deliberately wasting everyone’s time and money. There are guidelines for professional conduct that everyone must follow, whether you’re a real lawyer or just representing yourself. The civility order begins by saying:

From the start, this litigation has had an unusually high degree of friction between the parties, particularly pro se plaintiff Greenspan and defendant Qazi. This has led to a flood of entirely unnecessary disputes over technical issues of service and default in connection with the complaint, among other matters. See, e.g., Dkt. Nos. 15, 26, 44, 45, 51. The parties’ inability to work out an agreement on these simple procedural matters is an unacceptable departure from the civility and professionalism required of all litigants, whether pro se or represented by counsel, who appear in this District. This order resolves the default issues, and sets a course for avoiding further misuse of time, money, and judicial resources in this case.

Order on Civility and Default

Greenspan asked the court to hand him “victory by default” so many times that the judge forbade him from doing so again without the court’s permission:

No further applications for entry of default may be filed by any party without the Court’s prior approval.

Order on Civility and Default

Despite these clear instructions from the judge, Aaron Greenspan once again asked the court to hand him victory by default on December 28.

Now to the bigger picture. In the usual course of business, these relatively minor procedural issues would have been worked out with the civility and professionalism that counsel and parties typically bring to their cases in this District. That did not happen here, which led to a multiplicity of unwarranted filings and attendant waste of resources, including the Court’s. To avoid future incidents along these lines, all parties and their attorneys in this action are directed to read the District’s guidelines on civility and professionalism, which are available at https://www.cand.uscourts.gov/forms/guidelines-for-professional-conduct. All parties and counsel will be held accountable for conforming to the letter and spirit of the guidelines, including pro se litigant Greenspan. See Jacobsen v. Filler, 790 F.2d 1362, 1364 (9th Cir. 1986). The parties and counsel are advised that a failure to adhere to the guidelines may result in sanctions, including but not limited to claim or defense preclusion, exclusion of evidence, an award of attorney’s fees and costs to an opposing party, professional discipline, and dismissal under Rule 41(b).

Order on Civility and Default

The judge’s order was crystal clear: Stop wasting everyone’s time and money, including the Court’s. In every court case, attorneys on both sides are civil and professional enough to work out minor procedural issues without involving the court, despite any tension between their clients. The problem is, Aaron Greenspan can’t afford a lawyer so he has to represent himself. Because of his out of control anger issues, he is completely unable to even comprehend the concept of civility, let alone practice it.

Since Aaron Greenspan knows he cannot win on the merits of the case, his strategy is to bombard the court with a “multiplicity of unwarranted filings” designed to waste the defendants money and resources, as well as the court’s. Burning vital public funds on your silly grudges is not appreciated by anyone, especially the court. Greenspan even admitted his strategy of filing meritless motions in court to waste money, writing that the more we share about Aaron Greenspan’s harassment and threats “the more facts will be included in my proposed supplemental complaint, which means you will have to spend time reading and opposing it, which means it will cost Omar (and/or his donors) money”, in a recent email. Greenspan is essentially attempting to weaponize the court to silence journalists reporting on his fraudulent charity Think Computer Foundation’s years-long harassment campaign against Tesla customers, in violation of California’s anti-SLAPP law and the court’s Guidelines for Professional Conduct.

To avoid any further unwarranted filings and associated waste of time and money, including the Court’s, the Judge ordered all parties to read the district court’s guidelines on civility and professional conduct, explicitly highlighting that these guidelines also applied to “pro se litigant Greenspan”, citing the Ninth Circuit Court of Appeal’s 1986 decision in Jacobsen v. Filler.

Jacobsen v. Filler

So what was the Ninth Circuit’s 1986 decision all about? In a nutshell, it said that pro se parties (people representing themselves without a lawyer) are not excused from following the rules and orders of the court. Put another way, someone who is representing themself should not be treated more favorably than someone who can afford a real attorney.

In the original case, Harlan L. Jacobsen sued the city of Scottsdale without a lawyer for allegedly dismantling and confiscating the newspaper racks of Jacobsen’s tabloid publication. After Jacobsen filed the lawsuit, the defendants made a motion for summary judgement. Jacobsen was supposed to file a response to the motion, but didn’t because he was unaware of the rules requiring him to do so. Because he didn’t respond, the court ruled in favor of the defendants and threw out the case.

Jacobsen then appealed the decision to the Ninth Circuit Court of Appeals, arguing that the court should have told him he needed to file a response. There was actually a rule that said that the court must inform prisoners representing themselves of their need to respond to a motion for summary judgement, and Jacobsen argued that this rule should apply to everyone representing themselves –– not just prisoners.

Jacobsen did not respond to the motion with a written opposition, nor did he submit admissible evidence as required by Local Rule 11(h) and Fed.R.Civ.P. 56(e). However, he contends that he did not know that he had to do these things. Urging that rules applicable to pro se prisoners should be extended to all pro se litigants, see, e.g., Moore v. Florida,703 F.2d 516 (11th Cir. 1983); Roseboro v. Garrison,528 F.2d 309 (4th Cir. 1975); Hudson v. Hardy,412 F.2d 1091 (D.C.Cir. 1968), Jacobsen argues that it was the district court’s duty to advise him of the measures he should take to oppose the defendants’ motion; and that it was unfair to enter summary judgment without having done so.

Jacobsen v. Filler, 790 F.2d 1362, 1364 (9th Cir. 1986)

Unfortunately for Jacobsen, the Ninth Circuit affirmed the lower court’s ruling, setting a precedent that those representing themselves must follow the same rules as real lawyers.

We reject Jacobsen’s argument, for a number of reasons. First and foremost is that pro se litigants in the ordinary civil case should not be treated more favorably than parties with attorneys of record. Trial courts generally do not intervene to save litigants from their choice of counsel, even when the lawyer loses the case because he fails to file opposing papers. A litigant who chooses himself as legal representative  should be treated no differently. In both cases, the remedy to the party injured by his representative’s error is to move to reconsider or to set aside; it is not for the trial court to inject itself into the adversary process on behalf of one class of litigant.

Imposing an obligation to give notice of Rule 56’s evidentiary standards would also invite an undesirable, open-ended participation by the court in the summary judgment process. It is not sensible for the court to tell laymen that they must file an “affidavit” without at the same time explaining what an affidavit is; that, in that, in turn impels a rudimentary outline of the rules of evidence. Unlike the conversion of a 12(b)(6) motion into a motion for summary judgment, which only requires notice of what the motion now is,  Jacobsen’s proposal  requires advice as to what the motion must mean. To give that advice would entail the district court’s becoming a player in the adversary process rather than remaining its referee. 

Jacobsen v. Filler, 790 F.2d 1362, 1364 (9th Cir. 1986)

Abraham Lincoln once said “the man who represents himself has a fool for a client”, and never has this expression been more true than in the case of Aaron Greenspan. The Ninth’s Circuit’s ruling in Jacobsen v. Filler basically says “if your lawyer is a moron, that’s not our problem”. Whether you hired a moron or are one yourself, forgetting to file a response can definitely cost you the case. It’s not the court’s job to try and help you: They can throw out any case for not following the rules, even if the moron who brought the case to court has never heard of that rule before.

In citing Jacobsen v. Filler, the court’s message to Aaron Greenspan was clear: Just because you’re representing yourself doesn’t mean you don’t have to follow the rules. Based on the 1986 decision, the judge didn’t even owe Greenspan a warning that he was required to follow the district court’s guidelines for professional conduct –– Greenspan should have already known this before he was warned. But the judge spelled out the consequences of continuing to disobey the guidelines to him anyway:

The parties and counsel are advised that a failure to adhere to the guidelines may result in sanctions, including but not limited to claim or defense preclusion, exclusion of evidence, an award of attorney’s fees and costs to an opposing party, professional discipline, and dismissal under Rule 41(b)

Order on Civility and Default

The court order could not have been more clear: Any further violations of the Guidelines for Professional Conduct would have serious consequences –– including an award of fees attorney’s fees and costs to the opposing party, and dismissal under Rule 41(b). In other words, should the court find Greenspan violated the order, he will be forced to pay all our legal bills and his ridiculous case will be thrown out of court.

Rule 41(b) states:

(b) Involuntary Dismissal; Effect. If the plaintiff fails to prosecute or to comply with these rules or a court order, a defendant may move to dismiss the action or any claim against it. Unless the dismissal order states otherwise, a dismissal under this subdivision (b) and any dismissal not under this rule—except one for lack of jurisdiction, improper venue, or failure to join a party under Rule 19—operates as an adjudication on the merits.

Federal Rules of Civil Procedures, 41(b)

In other words, a case dismissed under Rule 41(b) is just like one that the defendants won based on the merits of the case. Facing dismissal and tens of thousands of dollars in fines, the stakes could not be higher for Greenspan. With his future on the line, will Greenspan be smart enough to actually read the rules and try and follow the court order? Let’s find out.

Back to Greenspan’s Motion

The Court should grant Plaintiff’s motion because the Qazi Defendants have repeatedly and brazenly violated the Court’s September 2, 2020 Order Re Default and Civility (the “Civility Order”) in successive attempts to seemingly prove that they are above the laws of the United States and the Orders of this Court.

Greenspan Motion to Silence Critics

Covering Aaron Greenspan’s fraudulent charity and its campaign of criminal harassment is not only lawful –– it is protected by the first amendment. Unfortunately for Aaron Greenspan, there is no law on the books that prevents us from laughing at him. Perhaps such a law exists in the parallel universe of Greenspan’s delusions, where he is the inventor of Facebook.

Aaron Greenspan claims we have “repeatedly and brazenly” violated the court’s order on civility and default. But what did this court order actually say? Recall that the order opened by summarizing itself: “This order resolves the default issues, and sets a course for avoiding further misuse of time, money, and judicial resources in this case“. The court order was intended to resolve default issues, and make sure no more time, money, or judicial resources were wasted in this case.

To that end, the order advised all parties to read and follow the guidelines on civility and professionalism: “to avoid future incidents along these lines, all parties and their attorneys in this action are directed to read the District’s guidelines on civility and professionalism”.

So which part does Greenspan contend we violated? We have not asked the court to place him in default –– it is Greenspan who recently requested leave to file default, months after a court order required him to ask permission before attempting to file for default yet again. We have not wasted time, money, or judicial resources –– it is Greenspan who has continued to do so, with his multiplicity of unwarranted filings.

That must mean that Aaron Greenspan is claiming we’ve failed to read and follow the Guidelines for Professional Conduct. But has Aaron Greenspan been able to read and understand those guidelines? Here is how they begin:

These Guidelines for Professional Conduct are adopted to apply to all lawyers who practice in the United States District Court for the Northern District of California. Lawyers owe a duty of professionalism to their clients, opposing parties and their counsel, the courts, and the public as a whole. Those duties include, among others: civility, professional integrity, personal dignity, candor, diligence, respect, courtesy, cooperation and competence.

Guidelines for Professional Conduct

That’s right –– these are guidelines for how lawyers must act in court, in all cases before the United States District Court for the Northern District of California. Not only do these rules apply to all “real” lawyers, they also apply to Aaron Greenspan because he is representing himself in this case, even though he’s not a lawyer and in fact has an extremely poor understanding of the law. That’s why the judge cited Jacobsen v. Filler: “Just because you chose a shitty lawyer who happens to be a total moron and never actually went to law school doesn’t mean the rules don’t apply to you”. These guidelines do not in any way forbid us from telling the Aaron Greenspan stalker story or restrict our speech at all, contrary to what Aaron Greenspan claims to believe. Clearly, we are not lawyers practicing in the district court –– but for the purposes of this case, Aaron Greenspan is. The judge was very clear about that.

Every attorney who enters an appearance in this matter shall be deemed to have pledged to adhere to the Guidelines. Counsel are encouraged to comply with both the spirit and letter of these Guidelines. Nothing in these Guidelines, however, shall be interpreted to contradict or supersede any Order of the Court or agreement between the parties. The Court does not anticipate that these Guidelines will be relied upon as the basis for a motion; rather, it is the Court’s expectation that they will be followed as Guidelines.

These Guidelines should be read in the context of the Federal Rules of Civil Procedure, the Local Rules of the United States District Court for the Northern District of California (including, specifically, Civil Local Rule 11-4), the standards of professional conduct required of members of the State Bar of California, and all attorneys’ underlying duty to zealously represent their clients. Nothing in these Guidelines should be read to denigrate counsel’s duty of zealous representation. However, counsel are encouraged to zealously represent their clients within highest bounds of professionalism. The legal profession must strive for the highest standards of attorney behavior to elevate and enhance the service to justice.

Guidelines for Professional Conduct

The guidelines are so clear, even an elementary school student could understand them -– but Aaron Greenspan apparently cannot. It’s unclear whether Greenspan suffers from extremely poor reading comprehension skills or is merely playing dumb so that his misunderstanding can form the basis of yet another meritless motion. In case of the latter, Greenspan would be deliberately and willfully violating the court order to stop wasting everyone’s time and resources, and should face dismissal and other sanctions as a result.

Plaintiff Aaron Greenspan respectfully moves the Court for an Order compelling Defendants Omar Qazi and Smick Enterprises, Inc. to immediately comply with the clear directives of the Court’s Civility Order specifically regarding professionalism.

Since September 2, 2020, Qazi Defendants have published approximately 600 pages of aggressive insults and outrageous lies about Plaintiff on the personal website of Defendant Qazi at http://www.wholemars.net (the “Personal Website”), which does not even remotely resemble “professional” conduct.

Greenspan Motion to Silence Critics

We’re glad Aaron Greenspan is enjoying the story. However, he fails to identify or cite any part of the guidelines that prohibits blogging. Whether he finds our story to be “unprofessional” or not is completely irrelevant. He is unable to cite any such section of the guidelines, as they concern the conduct of lawyers in court –– not the free speech rights of journalists.

Embedded in these hundreds of pages comprising Qazi Defendants’ endless smear campaign against Plaintiff, partly in retaliation for filing this lawsuit, is a copy of a confidential settlement communication, published anew by Qazi Defendants on December 25, 2020, which is also governed by Rule 408 of the Federal Rules of Evidence.

Greenspan Motion to Silence Critics

We can understand why Aaron Grenspan is desperate to make sure nobody finds out about his extortionate demands for $50,000 in cash (among other things) before he would consider dropping his lawsuit –– it doesn’t look good, and definitely reveals his true colors and true intentions. But in yet another embarrassing legal blunder by Aaron Greenspan, Rule 408 of the Federal Rules of Evidence does not in any way prohibit me from telling you that he demanded $50,000 cash and other concessions to make the lawsuit go away.

In reality, Rule 408 of the Federal Rules of Evidence concerns what kind of evidence is admissible in court –– not what journalists are allowed to say:

Rule 408. Compromise Offers and Negotiations

(a) Prohibited Uses. Evidence of the following is not admissible — on behalf of any party — either to prove or disprove the validity or amount of a disputed claim or to impeach by a prior inconsistent statement or a contradiction:

(1) furnishing, promising, or offering — or accepting, promising to accept, or offering to accept — a valuable consideration in compromising or attempting to compromise the claim; and

(2) conduct or a statement made during compromise negotiations about the claim — except when offered in a criminal case and when the negotiations related to a claim by a public office in the exercise of its regulatory, investigative, or enforcement authority.

(b) Exceptions. The court may admit this evidence for another purpose, such as proving a witness’s bias or prejudice, negating a contention of undue delay, or proving an effort to obstruct a criminal investigation or prosecution.

This rule describes types of evidence that are admissible in court. It has nothing to do with journalism. In another embarrassing mistake showcasing Aaron Greenspan’s complete ignorance of the judicial system, Greenspan let his guard down and admitted his true intentions with his settlement offer. A cursory Google search on the topic would have been enough to warn him not to make this sophomoric error:

One particularly powerful purpose for admitting settlement communications is to show a party’s intent.  As described above, parties are typically their most candid during settlement communications and are likely to make statements indicative of their true intent.  For example, in a recent case, the plaintiff’s representative acknowledged during settlement negotiations that the plaintiff’s goal was to shut down the defendant’s business.  Subsequently, the defendant filed an abuse of process claim essentially alleging that the plaintiff had brought its lawsuit for the improper purpose of shutting down the defendant’s business.  The court found that the statements by the plaintiff’s representative during settlement negotiations were admissible as to the plaintiff’s intent.

Once again, the lesson here is that your company should keep up its guard—even if it believes it’s engaged in settlement negotiations.  And the exceptions to Rule 408 make clear that even statements of bluster and/or perceived strength made during settlement communications could come back to bite your company under certain circumstances.

Conclusion

The Rules of Evidence protect settlement communications from admissibility in many cases.  They do this to promote frank and candid settlement discussions.  However, they don’t provide as much protection as many commonly think.  Therefore, it’s important to know the parameters of the rules governing protection of settlement communications and to consider them when engaging in negotiations.

Ward and Smith

While settlement negotiations are inadmissible as evidence in some situations, there are many other situations were these negotiations can be admitted as evidence. This confidentiality rule doesn’t provide nearly as much protection as some people might think, and it certainly doesn’t mean I can’t tell you what Greenspan wanted. I made the decision to publish Greenspan’s demands myself, without consulting anyone else. While Aaron Greenspan may be embarrassed to see his cash-grab publicized, we determined that the journalistic interests of the public and our donors in understanding Aaron Greenspan’s true motivations far outweighed any other considerations, including any understanding or misunderstanding that his demands would not be made public.

Greenspan undoubtedly knew that his outrageous demands would be relayed to me at some point, and once they were I could not stay quiet about what he was asking for, despite being advised to do so to continue settlement discussions in good faith. It is simply appalling that someone who stalked, harassed, threatened, slandered and smeared me so relentlessly for years would have the gall to ask for $50,000 and a donation to his charity. For the public good, the world must know the depths of Aaron Greenspan’s depravity.

Also I love how what Greenspan calls a “smear campaign” involves simply sharing an e-mail he sent us. If all we need to smear Greenspan is his own words, this “smear campaign” is going to be pretty easy. If Greenspan feels he has been embarrassed by his own e-mail, who was it that smeared him? Was it me, or did he smear himself by revealing what he really wanted?

At risk of being redundant due to Qazi Defendants’ constant infractions, the Court’s Civility Order explicitly required all parties and counsel to conform to both the spirit and the letter of the Northern District of California Guidelines for Professional Conduct (“Guidelines”). ECF No. 72. Regarding Qazi Defendants, this clearly has not happened. At the very least, since Qazi Defendants will not remove the confidential settlement communication from the Personal Website voluntarily, the Court must enforce its Order insofar as professional conduct is concerned.

Greenspan Motion to Silence Critics

Unlike Aaron Greenspan, we have complied with the court’s civility order. That this has “not happened” is anything but “clear” –– Greenspan again fails to cite any part of the court order or guidelines at all that he claims have been violated. Instead, he merely expresses a general opinion that refusing to remove content Greenspan doesn’t like from this website is “unprofessional”. However, the guidelines for professional conduct say nothing about removing blog posts an opposing party finds unflattering. If it did, Aaron Greenspan himself would be forced to delete PlainSite and every slanderous tweet on the “charity” Twitter account.

The initial Complaint in this case was filed on May 20, 2020. The First Amended Complaint (“FAC”) was filed on July 2, 2020. ECF No. 20. With the consent of the parties, the Second Amended Complaint (“SAC”) was filed on August 26, 2020. ECF No. 70. Between the filing of the initial Complaint and the FAC, a number of avoidable issues arose that led to the Qazi Defendants questioning the status of their own default. ECF No. 51. The Court resolved these issues in an Order Re Default and Civility issued on September 2, 2020 and directed all parties and counsel to act in a professional manner consistent with the Northern District of California Guidelines for Professional Conduct. ECF No. 72.

Plaintiff filed a motion for sanctions against Qazi Defendants and their counsel on August 19, 2020, which was withdrawn as a good-faith measure on September 9, 2020. ECF Nos. 66, 73. Plaintiff filed a motion for an Order to Show Cause Why [Qazi Defendants and their counsel] Should Not Be Held In Contempt Of Court on September 28, 2020. ECF No. 77. Plaintiff filed a second motion for sanctions against Qazi Defendants and their counsel on October 26, 2020. ECF No. 83. These motions have been fully briefed and are before the Court.

The conduct at issue here took place after the filing of the aforementioned motions.

Greenspan Motion to Silence Critics

In other words, Aaron Greenspan openly admits to creating “a multiplicity of unwarranted filings” in direct violation of the September 9 court order.

C. Defendant Qazi’s “Story” Regarding Plaintiff Epitomizes Unprofessional Behavior

Defendant Qazi is in the midst of publishing a promised ten-part series (plus associated articles) entitled “The Story” at https://wholemars.net/aaron-greenspan/ that purports to explain the events leading up to and surrounding this legal action. Mostly, it is an attack vehicle for all Defendants to target Plaintiff in lieu of using a more precarious Twitter account, which operates in violation of numerous rules and policies such that it could be suspended at any moment.

Greenspan Motion to Silence Critics

Actually, the story is far too long to fit on Twitter. We’re writing it to let everyone know the truth about what really happened, and who Aaron Greenspan really is.

While Qazi Defendants are entitled to express their point of view under the First Amendment, the Civility Order restricts free speech rights to a certain degree, and wherever that line is, it has clearly been crossed. “I find EJ in CONTEMPT OF COURT for posting these videos and keeping them up… EJ’s cursory argument that preventing it from sharing these articles might implicate the First Amendment is unpersuasive.” Just Goods, Inc. v. Just, Inc., Case No. 3:18-cv-02198-WHO (N.D. Cal. September 11, 2020).

Greenspan Motion to Silence Critics

As much as Greenspan might wish to silence us, the mere existence of his absurd lawsuit does not restrict our first amendment rights in any way. The case of Just Goods v. Just, Inc. is a trademark case where two companies had a dispute around the name “Just”. The court ordered Just Goods to stop referring to itself as Just, but after the court order they continued to post videos where they called themselves “Just” anyway. The contempt of court designation makes sense in that context, as using another company’s name in your videos is not “free speech”. However, the case says nothing about the guidelines for professional conduct, nor does it concern journalists writing about serious criminal activity.

Guideline for Professional Conduct 8, with which Qazi Defendants must comply via the Civility Order (regardless of lawyer status), states as follows:

“A lawyer should at all times be civil, courteous, and accurate in communicating with opponents or adversaries, whether in writing or orally.”

Furthermore, the Guidelines explicitly state that parties required to abide by them “owe a duty of professionalism to their clients, opposing parties and their counsel, the courts, and the public as a whole” and encourages that they “comply with both the spirit and letter” of their text (emphasis added).

Greenspan Motion to Silence Critics

I must have missed when I became a lawyer. Guidelines for Professional Conduct 8 is titled “Communications with Opponents or Adversaries”. I have not communicated with Aaron Greenspan at all, at any point during this process. As a matter of fact, I’ve had all his e-mails blocked for a long time (as has Tesla). Greenspan’s argument is weak, and falls flat on its face.

Furthermore, despite not being a medical professional or a professional of any kind (“To be clear, I’m not a doctor nor am I trying to diagnose Aaron Greenspan via a Wikipedia article”), Defendant Qazi proceeds to do exactly that in “Chapter 7” of his self-serving, falsehood-laden tirade. This is both literally and figuratively unprofessional.

Greenspan Motion to Silence Critics

Chapter 7 of the Aaron Greenspan story was mostly just us quoting Aaron Greenspan’s own words about his life, as well as other primary sources. If there are any falsehoods, they are Greenspan’s. We are open to correcting anything that is actually inaccurate, but to date Greenspan has not provided us with a single correction to any part of the story.

To be clear, Defendant Qazi may express his viewpoint. But the Civility Order requires that he do so in a matter that is both professional and accurate. To the extent he has deliberately endeavored to do the opposite, those efforts should be circumscribed immediately.

Greenspan Motion to Silence Critics

Again, if there really is anything inaccurate or incorrect, we’re happy to make a correction. The fact that no corrections have been provided, and Greenspan instead demanded the court order the story be taken down, suggests that there may be more truth to the story than Aaron Greenspan would like to admit.

CONCLUSION

For all the reasons stated, Plaintiff respectfully requests that in addition to the relief previously requested, the Court enter an Order requiring Qazi Defendants to comply with its September 2, 2020 Order Re Default and Civility by removing and refraining from further publishing confidential materials of any kind, and by removing posts concerning Plaintiff published after September 2, 2020 from any server, anywhere in the world, to the extent that they violate the Guidelines for Professional Conduct. Plaintiff further requests the ability to conduct written discovery regarding the narrow matters described in this motion as a form of sanction, and that attorney Karl Kronenberger be referred to the Northern District of California’s Standing Committee on Professional Conduct.

Greenspan Motion to Silence Critics

So there you have it! Aaron Greenspan’s latest attempt to hide evidence of his criminal activity. We’ll see what the judge thinks about Aaron Greenspan’s legal argument that filing a lawsuit against someone immediately restricts their right to free speech. Imagine if that were true –– someone stalks and harasses you for years and as long as they sue you’re not allowed to talk about it.

The lengths Aaron Greenspan has gone to to hide evidence of his crimes is simply astounding. What could he have done that’s so bad he needs to fight for his life to hide it? Are our lives in danger as we move into the most shocking chapters of the story yet? Tune in next time to find out.

You can download the full 616 page declaration Aaron Greenspan submitted to court here.