Record-linked conduct
- ECF 63 alleges he appeared remotely on May 12, 2023 for the moving defendants, including Frye, when the San Diego Superior Court stayed the action and discovery. ECF 63 ¶119A
- ECF 63 alleges that on October 27 and November 13, 2023, Rajaee sent him notice letters and materials; ECF 63 states these notices establish receipt, not the truth of every characterization in them. ECF 63 ¶119D
- ECF 63 alleges he signed a January 29, 2024 anti-SLAPP motion and a February 1, 2024 joinder adopting a motion to dismiss in Case No. 3:24-cv-00001-RSH-KSC. ECF 63 ¶119E
- ECF 63 alleges he signed the September 26, 2024 Talentcrowd/Lintz settlement individually and for his firm. ECF 63 ¶¶119A, 119E
- ECF 63 sues him solely under 18 U.S.C. § 1962(d) and states he is not charged with executing the earlier capital, takeover, transfer, judgment-procurement, or money-laundering predicates. ECF 63 ¶¶7A, 119B, 119E