1 Cause No. 2012-27197A MOKARAM-LATIF WEST LOOP, LTD, § in the DISTRICT COURT § Plaintiff, § V. § § 333Rd JUDICIAL DISTRICT
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Cause No. 2012-27197A MOKARAM-LATIF WEST LOOP, LTD, § IN THE DISTRICT COURT § Plaintiff, § § v. § 333rd JUDICIAL DISTRICT § ALI CHOUDHRI, et al., § § Defendants. § HARRIS COUNTY, TEXAS OMNIBUS RESPONSE TO MOTIONS TO RECUSE Pursuant to Judge Susan Brown’s January 15, 2021 Letter Order, Defendant Ali Choudhri (“Choudhri”) files this Omnibus Response (“Response”) to the multiple Motions to Recuse (“Recusal Motions”) filed by PlaintiFF-in-Intervention Ali Mokaram (“Mokaram”) and would respectFully show as follows: PRELIMINARY STATEMENT Convicted felon Christopher Wyatt (“Wyatt”) is like one of those carnival fortune tellers who spews out— instead of generic fortunes — fake texts, lies, and whatever else suits his patron’s needs, if the price is right.1 After being paid to breach his fiduciary and contractual duties to his former employer, Wyatt made Mokaram and his co-recuser Osama Abdullatif’s (“Abdullatif”) wish of fabricated recusal evidence against newly-elected Judge Brittanye Morris (“Judge Morris”) come true. Every time Choudhri presents evidence to rebut Wyatt’s lies, Mokaram and Abdullatif simply put more money in the “Wyatt Lie Box” and out comes another lie. As discussed below, the Recusal Motions stand and fall on the testimony of a convicted felon that is heavily contradicted, ever changing with hoaxes and conspiracy theories, and is completely unreliable. As will be demonstrated herein, Wyatt was recorded confessing that he 1 See, e.g., https://www.youtube.com/watch?v=s6xEAaV8CIg. 1 intended to sell false evidence to Mokaram’s counsel unless he was paid. After Choudhri refused to be extorted, Wyatt’s testimony was purchased by Choudhri’s adversary AbdullatiF who has a troubled history of filing frivolous recusal motions, sponsoring litigation against his enemies, and was apparently involved in a failed suit seeking to have Judge Morris removed from the ballot before the latest attacks on her began. In addition, Abdullatif has hired a “consultant” named Wayne Dolcefino (“Dolcefino”) to act as though he is doing “investigative reporting” on Judge Morris as an independent journalist, when in reality he is a “presstitute”—a reporter for hire—who will “report” on whatever Abdullatif pays him to say. Abdullatif’s consultant even went so far as to try and make direct contact with Judge Morris to “interview” her about this matter and also attempted to intimidate a witness who testified against the recusal with a threat of criminal prosecution. Shockingly, Dolcefino’s latest “reporting” even involves Judge Susan Brown in further attempts at intimidation. Once the Wyatt-originated evidence is dismissed—as it should be—the Court is left with absolutely no evidence of recusal. There is no record of Judge Morris ever serving as counsel of record for any party in this case. Counsel for the parties that were alleged to have employed Judge Morris deny ever having worked with her or having used Wyatt as an intermediary to communicate with her. Mokaram’s additional evidence is nothing more than allegations of “seeing” Judge Morris in proximity to Choudhri and his attorneys at the courthouse while perhaps engaging in other activities. Mokaram’s witnesses to these events are Abdullatif’s employee Beth Mendez (“Mendez”) and Wyatt’s nephew, Courtland Sedlachek (“Sedlachek”). As discussed below, Sedlachek and Wyatt made bizarre false claims of murder-for-hire plots and hacking, which were dismissed by the Houston Police Department (“HPD”) as hoaxes. When those did not pan out, they launched the recusal scheme. In sum, this Court will have to determine whether the structural racism and white male 2 privilege that has plagued this Nation resulting in the reckoning of 2020 will carry over to 2021 and allow a young Black female judge chosen by the people of Harris County to be taken down by the testimony of a white male convicted felon who has stolen documents from his former employer, contrived hoax after hoax, and is a “liar for hire” to do the bidding of a vexatious litigant. While some people protested the national election by storming the U.S. Capitol – Mokaram/AbdullatiF have protested our local election by Fabricating evidence to recuse a judge they tried to keep off the ballot and by intimidating and threatening judges and witnesses. If the integrity of a white male ex-felon who is not even qualified to serve on jury duty and whose testimony is comically unreliable “trumps” the integrity of a law-abiding female Black judge elected by the people, then we surely have a long way to go toward equality and justice. PERTINENT FACTS TO RECUSAL The following factual timeline is pertinent to the recusal issues: • Abdullatif and Mokaram—who were both involved in litigation with Choudhri and his entities—entered into an agreement, whereby Abdullatif essentially controls Mokaram’s litigation rights against Choudhri in this case and prevents Mokaram from settling any of his claims without Abdullatif’s consent.2 Abdullatif also pays for Mokaram’s counsel. 3 Thus, Abdullatif is essentially the controlling party seeking this recusal, making Mokaram a pawn. • Abdullatif also enlisted Choudhri’s ex-wife, Hira Azhar (“Azhar”), to bring suit against Choudhri for allegedly not being divorced, giving rise to a flurry of litigation over Choudhri’s entities and properties. 4 Abdullatif funded the 2 Ex. 3-1-B at ¶¶ 5, 10. 3 Ex. 3-1-B at ¶¶ 5, 10. 4 Ex. 3-1-A-1. 3 litigation to the tune of over $1,000,000.00.5 Ultimately, after years of frivolous litigation, the court in that case ruled that Choudhri and Azhar were already divorced in Pakistan many years ago. 6 • Unhappy with the rulings in the Azhar case, Abdullatif funded a recusal campaign against Judge Wooldridge based on his alleged (which would be 100% accurate if he had truly made them) claims that Azhar was being used as a pawn by Abdullatif against Choudhri and that AbdullatiF’s conduct in sponsoring frivolous litigation was the real problem. 7 The campaign against Judge Wooldridge failed. • Steve Kherker (“Kherker”), an attorney who represented Azhar (and thus paid by Abdullatif),8 sought to have Judge Morris removed from the Democratic ticket in Harris County based on allegations that Judge Morris was allegedly not qualified to be on the ballot. 9 This attack by yet another Abdullatif pawn was also unsuccessful, with mandamus being denied in June 2020. 10 • While Choudhri does recall seeing Judge Morris at the Harris County courthouse before she took the bench (presumably engaging in activities in preparation to become a judge), she never appeared as counsel for him or participated in any hearings, although Choudhri and/or some of his legal team may have exchanged pleasantries with her. 11 5 Ex. 3-1-A-1. 6 Ex. 3-1-A-3. 7 Ex. 3-A-2. 8 Ex. 6. 9 Ex. 7. 10 Ex. 7. 11 Ex. 8 at ¶ 4; Ex. 9. 4 • Shortly after the failed challenge against Judge Morris, in September of 2020, Wyatt, who was an employee of one of Choudhri’s companies, Jetall Companies, Inc. (“Jetall”), was discovered to have multiple felony charges and convictions and an extensive criminal history. 12 Wyatt had lied about his criminal history to obtain employment with Jetall. 13 • Around this same time, Wyatt inexplicably began having text communications with Judge Morris (who was yet to assume the bench). 14 The authenticity of the texts has not been confirmed and they appear in a strange format. Choudhri/Jetall was unaware of the texts. 15 Judge Morris was not involved in any representation of Jetall or any of the parties to this case. 16 She has never represented Choudhri or any entity he owns or controls. 17 Harris County records further support this. 18 There is no reason why Wyatt should have been contacting Judge Morris for any “legal advice” on any case. • Around this same time, Choudhri confronted Wyatt regarding his criminal history.19 Wyatt—in a recorded conversation—threatened to “call Scott Funk” who is counsel for Mokaram and invite him to take Wyatt’s deposition. 20 Wyatt 12 Ex. 3 at ¶ 5; Ex. 5-1 at ¶¶ 4-6; Exs. 5-1-A; 5-1-B. 13 Ex. 3 at ¶ 5; Ex. 5-1 at ¶¶ 4-6; Exs. 5-1-A; 5-1-B. 14 See Purported Texts attached to Third Supplement to Recusal Motions filed on Jan. 14, 2021 (“Purported Texts”). 15 Ex. 3 at ¶¶ 3-4. 16 Ex. 3 at ¶¶ 3-4; Ex. 1; Exhibit 9 (Declarations from Counsel in this case). 17 Ex. 1. 18 Ex. 2. 19 Ex. 3 at ¶ 5; Ex. 5-1 at ¶¶ 4-6. 20 Ex. 8-A. 5 demanded that Choudhri pay him a ransom to avoid this. 21 Wyatt also described a bizarre allegation that “Stephanie” at Jetall had divulged an alleged plot by Choudhri to hack into Google. 22 Wyatt can be heard cackling on the recorded extortionate conversation, sounding like “The Joker” from Batman. 23 • Wyatt’s nephew Sedlachek had been hired by Jetall—upon Wyatt’s insistence—to be a maintenance man at Jetall. 24 Choudhri agreed because he considered Wyatt like Family prior to the criminal history expose, even giving Wyatt’s son a job.25 In proximity with Choudhri’s conversation with Wyatt above, Sedlachek made a strange report to the HPD that Choudhri was attempting to use “Stephanie” at Jetall to use a Mexican cartel to assassinate Abdullatif. 26 HPD records show that Abdullatif (who was also investigated For criminal stalking as evidenced by the records) contacted HPD concerning this strange theory and, therein, admitted that he talked to a “coworker” of Sedlachek concerning this theory. 27 This “coworker” has to be Wyatt, demonstrating that Wyatt was already in contact with Abdullatif immediately after Choudhri rebuffed Wyatt’s extortion attempt.