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1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Jeffery D. McFarland (Bar No. 157628) 2 [email protected] Shahin Rezvani (Bar No. 199614) 3 [email protected] Aaron Perahia (Bar No. 304554) 4 [email protected] 865 South Figueroa Street, 10th Floor 5 Los Angeles, California 90017-2543 Telephone: (213) 443 3000 6 Facsimile: (213) 443 3100 7 Attorneys for Plaintiff Farhad Safinia 8 9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 WESTERN DIVISION 12 FARHAD SAFINIA, an individual, CASE NO. 2:17-cv-06902 13 Plaintiff, MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF 14 vs. PLAINTIFF’S APPLICATION FOR: 15 VOLTAGE PICTURES, LLC, a (1) TEMPORARY RESTRAINING California limited liability company; ORDER; AND 16 VOLTAGE PRODUCTIONS, LLC, a Nevada limited liability company; (2) ORDER TO SHOW CAUSE RE: 17 CHRISTCHURCH PRODUCTIONS PRELIMINARY INJUNCTION DAC, an Ireland designated activity AND IMPOUNDMENT 18 company; NICOLAS CHARTIER, an individual; and DOES 1 through 100, [Declarations of Farhad Safinia, Bruce 19 inclusive, Davey, and Shahin Rezvani filed concurrently herewith] 20 Deadline Defendants. Hearing Date: (None Set) 21 22 23 24 25 26 27 28

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1 TABLE OF CONTENTS 2 Page 3 PRELIMINARY STATEMENT ...... 1 4 NEED FOR IMMEDIATE RELIEF ...... 1 5 STATEMENT OF FACTS ...... 2 6 ARGUMENT ...... 4 7 I. THE COURT SHOULD TEMPORARILY RESTRAIN AND 8 PRELIMINARILY ENJOIN DEFENDANTS FROM INFRINGING MR. SAFINIA’S COPYRIGHT IN THE 2016 SCREENPLAY 9 DURING THE PENDENCY OF THIS ACTION ...... 4 10 A. A Substantial Likelihood Exists that Mr. Safinia Will Prevail on the Merits ...... 5 11 1. Mr. Safinia Has a Valid Copyright in the 2016 Screenplay ...... 5 12 2. Defendants Had Access to the 2016 Screenplay ...... 6 13 3. Defendants’ Film Is Substantially Similar to the 2016 14 Screenplay ...... 6 15 B. Mr. Safinia Will Suffer Irreparable Injury If Defendants Are Not Enjoined ...... 6 16 C. The Balance of Equities Tips Decidedly in Mr. Safinia’s Favor ...... 7 17 D. Issuing the Injunction Serves the Public Interest ...... 8 18 II. MR. SAFINIA IS ENTITLED TO A TEMPORARY RESTRAINING 19 ORDER ...... 8 20 III. DEFENDANTS’Deadline COPIES OF THE FILM SHOULD BE IMPOUNDED AND DELIVERED UP FOR DESTRUCTION ...... 9 21 CONCLUSION ...... 9 22 23 24 25 26 27 28

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1 TABLE OF AUTHORITIES 2 Page 3 Cases 4 Acad. of Motion Picture Arts & Scis. v. Creative House Promotions, Inc., 944 F.2d 1446 (9th Cir. 1991) ...... 5 5 Brookfield Commc’ns, Inc. v. W. Coast Entm’t Corp., 6 174 F.3d 1036 (9th Cir. 1999) ...... 7 7 Corning Glass Works v. Jeannette Glass Co., 308 F. Supp. 1321 (S.D.N.Y. 1970), aff’d on the opinion below, 432 8 F.2d 784 (2d Cir. 1970) ...... 7. 8 9 Disney Enters., Inc. v. VidAngel, Inc., 2017 WL 3623286 (9th Cir. Aug. 24, 2017) ...... 6 10 EMI April Music, Inc. v. Keshmiri, 11 2012 WL 5986423 (D. Nev. Nov. 28, 2012) ...... 6, 8 12 First Tech. Safety Sys., Inc. v. Depinet, 11 F.3d 641 (6th Cir. 1993) ...... 9 13 FMC Corp. v. Control Solutions, Inc., 14 369 F. Supp. 2d 539 (E.D. Pa. 2005) ...... 8 15 Forged Threadworks, Inc. v. Infidel Industries LLC, 2015 WL 11438100 (C.D. Cal. June 2, 2015) ...... 6 16 Jewelers’ Circular Publ’g Co. v. Keystone Publ’g Co., 17 274 F. 932 (S.D.N.Y. 1921), aff’d, 281 F. 83 (2d Cir. 1922) ...... 9 18 Landsberg v. Scrabble Crossword Game Players, Inc., 736 F.2d 485 (9th Cir. 1984) ...... 5 19 Perfect 10, Inc. v. Google, Inc., 20 653 F.3d 976Deadline (9th Cir. 2011) ...... 4 21 Regents of Univ. of California v. Am. Broad. Cos., Inc., 747 F.2d 511 (9th Cir. 1984) ...... 6 22 Salinger v. Colting, 23 607 F.3d 68 (2d Cir. 2010) ...... 6 24 United Tactical Sys., LLC v. Real Action Paintball, Inc., 2014 WL 6788310 (N.D. Cal. Dec. 2, 2014) ...... 8 25 Warner Bros. Entm’t Inc. v. WTV Sys., Inc., 26 824 F. Supp. 2d 1003 (C.D. Cal. 2011) ...... 7 27 WPOW, Inc. v. MRLJ Enters., 584 F. Supp. 132 (D.D.C. 1984) ...... 9 28

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1 Statutory Authorities 2 17 U.S.C. §106 ...... 5 3 17 U.S.C. §410(c) ...... 5 4 17 U.S.C. §503(a) ...... 9 5 17 U.S.C. §503(b) ...... 9 6

7 8 9 10 11 12 13 14 15 16 17 18 19 20 Deadline 21 22 23 24 25 26 27 28

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1 MEMORANDUM OF POINTS AND AUTHORITIES 2 Preliminary Statement 3 Without the consent of Plaintiff Farhad Safinia, Defendants Voltage Pictures, 4 Voltage Productions, Christchurch Productions, and Nicolas Chartier used Mr. 5 Safinia’s screenplay entitled “The Professor and the Madman” to cobble together a 6 motion picture. They then screened their film for members of the film industry to 7 offer the film for sale and/or distribution here in the United States. Defendants did 8 that, too, without Mr. Safinia’s authorization or consent, and they intend to continue. 9 Upon learning of their activities, Mr. Safinia demanded Defendants cease and desist; 10 they refused. Thus, he has no choice but to seek injunctive relief: Defendants’ 11 continued acts of willful infringement are causing irreparable injury to Mr. Safinia 12 as a director and screenwriter in the entertainment industry. Their conduct is also 13 eviscerating any value in his screenplay. 14 Need for Immediate Relief 15 A clear, present, and substantial danger exists that without immediate relief, 16 Defendants’ exhibition, distribution and offering for sale of their unauthorized 17 derivative work will irreparably harm Mr. Safinia’s reputation as a talented 18 screenwriter and director. The press, and film industry generally, misunderstand 19 that the film, derived from Mr. Safinia’s screenplay, is the version Mr. Safinia wants 20 released. His name Deadlinehas been tied to this project in trade publications, and in the 21 entertainment industry generally. Moreover, bringing “The Professor and the 22 Madman” to the big screen has been a labor of love for Mr. Safinia, who envisions 23 the depiction of his screenplay to be the most important work of his career. 24 Just as important, Defendants’ conduct will essentially make Mr. Safinia’s 25 work worthless. It will be virtually impossible for him to find anyone who will 26 license the rights to make a film from his screenplay, or for Mr. Safinia to make a 27 film on his own, once Defendants release their film. 28

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1 Statement of Facts 2 Farhad Safinia: Farhad Safinia’s first feature was Apocalypto which he co- 3 wrote and co-produced with director Mel Gibson and which was nominated for three 4 Academy Awards and a Golden Globe for Best Foreign Language Film. 5 Declaration of Farhad Safinia dated September 18, 2017 (“Safinia Decl.”) ¶2. Mr. 6 Safinia is also the creator, executive producer and show-runner of the Golden Globe 7 nominated series Boss for which Kelsey Grammer was awarded the Golden Globe 8 for Best Actor in a Drama. Id. His other film projects include an adaptation of the 9 Aldous Huxley novel Brave New World for Universal Pictures (with Leonardo 10 DiCaprio attached to star and Ridley Scott to direct), Sony Pictures’ The Allen 11 Counter Project (for Will Smith to star in and produce), and an adaptation of Neal 12 Bascomb’s historical novel Sabotage (aka The Winter Fortress) for director Michael 13 Bay and Paramount Pictures. Id. In addition to these, Safinia has also developed 14 projects for Warner Brothers, DC Comics, Walt Disney Studios, Robert Zemeckis’ 15 ImageMovers and CBS Network, among others. Id. 16 “The Professor and the Madman”: The story was an originally a book written 17 by Simon Winchester about the creation of the Oxford English Dictionary. Safinia 18 Decl. ¶3. It tells the tale of professor James Murray, who began compiling the 19 Oxford English Dictionary in 1857, and Dr. William Chester Minor, who submitted 20 more than 10,000 entriesDeadline while he was an inmate at an asylum for the criminally 21 insane. Id. 22 Mr. Safinia’s Rights in the Screenplay: Mr. Safinia completed his draft of the 23 screenplay in September 2016. Safinia Decl. ¶4 and Exh. A (screenplay). He has 24 since applied to the Copyright Office for registration of the screenplay as a 25 derivative work, and the registration, No. PAu003847498, was granted. Id., Exh. B 26 (copyright registration). 27 Defendants’ Willful Infringement: Defendants teamed with Icon Pictures to 28 make a film telling the stories of Messrs. Murray and Minor. Declaration of Bruce

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1 dated September 18, 2017 (“Davey Decl.”) ¶2. They had a screenplay written in 2 2001 by Todd Komarnicki and John Boorman, and Mr. Safinia had originally been 3 asked to revise that screenplay in 2007. Davey Decl. ¶3; Safinia Decl. ¶5. Mr. 4 Safinia revised that screenplay as a work-for-hire. Safinia Decl., Exh. C (certificate 5 of authorship). He does not claim any copyright with respect to that screenplay. 6 Safinia Decl. ¶5 and Exh. C. 7 Years later, during August and September 2016, Mr. Safinia wrote a new 8 screenplay (the “2016 Screenplay”). Safinia Decl. ¶6. Importantly, unlike the work 9 done with respect to the 2006 Komarnicki/Boorman screenplay, Mr. Safinia did not 10 execute an assignment or work-for-hire agreement in 2016. Id. 11 Mr. Safinia provided Defendants a copy of the 2016 Screenplay. Safinia 12 Decl. ¶7. With that screenplay in hand, Defendants worked with Mr. Safinia to 13 shoot scenes for a film. Id. At some point, however, they decided to curtail Mr. 14 Safinia’s vision. Id. For example, key scenes in the 2016 Screenplay were to be 15 shot on the campus of Oxford University. Id. But Defendants decided they would 16 not pay for the scenes to be shot there, so they weren’t. Id. 17 Ultimately, Defendants decided they would complete their version of the film 18 without Mr. Safinia. Safinia Decl. ¶8. They took the existing footage, and pieced it 19 together themselves without Mr. Safinia’s vision or input. Id. Mr. Safinia never 20 authorized DefendantsDeadline to make their version. Id. 21 But Defendants did not stop there. They screened a portion of their film at 22 the Cannes Film Festival in May 2017, and the Toronto Film Festival this month. 23 See Safinia Decl. ¶9; Declaration of Shahin Rezvani dated September 20, 2017 24 ("Rezvani Decl."), Exh. F at 7. They also brought it stateside, exhibiting it for 25 individuals at United Talent Agency and Creative Artists Agency, both located in 26 Los Angeles, California, during June and July of this year for the purpose of 27 soliciting the sale or distribution of their version to movie theaters in the United 28

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1 States. Id. All this, too, was without Mr. Safinia’s authorization, permission, or 2 consent. Id. 3 Mr. Safinia’s Efforts to Avoid Litigation: Mr. Safinia did what anyone in his 4 position would: he asked Defendants to stop. Safinia Decl., Exh. D (cease and 5 desist letter). Defendants denied his request. Rezvani Decl., Exh. B. 6 Defendants Intend to Continue Exhibiting and Offering the Film for Sale and 7 Distribution: Defendants have taken the position they own the 2016 Screenplay and 8 the film they cobbled together therefrom (see Rezvani Decl., Exhs. B, C), and are 9 therefore entitled to continue screening and offering it for sale or distribution. 10 Accordingly, to prevent Defendants’ ongoing infringement of Mr. Safinia’s 11 intellectual property rights, he applies to the Court for a temporary restraining order 12 and preliminary injunction. 13 Argument 14 I. THE COURT SHOULD TEMPORARILY RESTRAIN AND 15 PRELIMINARILY ENJOIN DEFENDANTS FROM INFRINGING MR. 16 SAFINIA’S COPYRIGHT IN THE 2016 SCREENPLAY DURING THE 17 PENDENCY OF THIS ACTION 18 In this circuit, an application for preliminary injunctive relief will be granted 19 if the plaintiff can show: (1) he is likely to succeed on the merits, (2) he is likely to 20 suffer irreparable harmDeadline in the absence of preliminary relief, (3) the balance of 21 equities tips in his favor, and (4) an injunction is in the public interest. Perfect 10, 22 Inc. v. Google, Inc., 653 F.3d 976, 979 (9th Cir. 2011). 23 Here, Mr. Safinia more than satisfies the requirements for preliminary 24 injunctive relief. He wrote the 2016 Screenplay. Safinia Decl. ¶6. Defendants had 25 a copy of it, but were never authorized to prepare, screen or otherwise attempt to 26 distribute their cut of the film -- which is a derivative work of that screenplay. Id. 27 ¶¶7, 8, 9. They further failed to agree to cease and desist from exhibiting, offering 28

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1 for sale, and/or distributing their unauthorized derivative work. See Rezvani Decl., 2 Exhs. B, C. Mr. Safinia will thus succeed on the merits of his infringement claim. 3 Mr. Safinia will suffer irreparable harm absent a temporary restraining order 4 and preliminary injunction, both to his reputation, and to the value of his 5 copyrighted work. Safinia Decl. ¶14. Further, the balance of equities tips decidedly 6 in Mr. Safinia’s favor, as Defendants have no right to market their unauthorized 7 derivative work, and any “harm” to them from not being able to shop their film is 8 merely pecuniary. Finally, the public interest will be well served. Simply put, Mr. 9 Safinia deserves the relief he seeks. 10 A. A Substantial Likelihood Exists that Mr. Safinia Will Prevail on the 11 Merits 12 To prove copyright infringement pursuant to 17 U.S.C. §106, Mr. Safinia 13 must show (1) he owns the copyright to the 2016 Screenplay; (2) Defendants had 14 access to the screenplay; and (3) the screenplay and Defendant’s film are 15 substantially similar.” Landsberg v. Scrabble Crossword Game Players, Inc., 736 16 F.2d 485, 488 (9th Cir. 1984). 17 1. Mr. Safinia Has a Valid Copyright in the 2016 Screenplay 18 Mr. Safinia wrote the 2016 Screenplay, and therefore owns it. Safinia Decl. 19 ¶6. Moreover, Mr. Safinia registered his copyright, and the certificate of registration 20 constitutes prima facieDeadline evidence of the copyright's validity and Mr. Safinia’s 21 ownership thereof. See 17 U.S.C. §410(c); Acad. of Motion Picture Arts & Scis. v. 22 Creative House Promotions, Inc., 944 F.2d 1446, 1451 (9th Cir. 1991) (“‘The 23 principle that a certificate represents prima facie evidence of copyright validity has 24 been established in a long line of court decisions, and it is a sound one.’”). And Mr. 25 Safinia did not grant Defendants any license to prepare a motion picture from the 26 2016 Screenplay by themselves. Id. ¶8. 27 28

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1 2. Defendants Had Access to the 2016 Screenplay 2 Mr. Safinia gave Defendants a copy of the 2016 Screenplay. Safinia Decl. ¶7. 3 Defendants thus had access to the work, satisfying the second element. 4 3. Defendants’ Film Is Substantially Similar to the 2016 Screenplay 5 As set forth in the currently filed Declaration of Bruce Davey, Defendant’s 6 motion picture lifts dialogue and scenes wholesale from Mr. Safinia’s screenplay. 7 Davey Decl. ¶4. Although the sequence of some scenes has been changed, anyone 8 who reads the 2016 Screenplay and sees Defendants’ film will recognize the former 9 as the blueprint for the latter. Id. What’s more troubling, Defendants have shown 10 their cut of the film to members of the public in an effort to license or sell the rights 11 to release the film in movie theaters here in the United States. Safinia Decl. ¶9. 12 B. Mr. Safinia Will Suffer Irreparable Injury If Defendants Are Not 13 Enjoined 14 The threat of the losing prospective customers, goodwill, or reputation 15 supports a finding of irreparable harm. See, e.g., Disney Enters., Inc. v. VidAngel, 16 Inc., 2017 WL 3623286, at *13 (9th Cir. Aug. 24, 2017); Forged Threadworks, Inc. 17 v. Infidel Industries LLC, 2015 WL 11438100, at *5 (C.D. Cal. June 2, 2015) (“The 18 threat of the loss of prospective customers, goodwill, or reputation also supports a 19 finding of irreparable harm.”); Regents of Univ. of California v. Am. Broad. Cos., 20 Inc., 747 F.2d 511, 519-20Deadline (9th Cir. 1984) (“We do not think, however, a trial 21 court’s recognition of the obvious -- i.e., that monetary losses can indeed attend the 22 infliction of intangible injuries -- requires that this court ignore an otherwise 23 unambiguous finding of intangible injury.”). Moreover, “[i]n the context of 24 copyright infringement cases, the harm to the plaintiff’s property interest has often 25 been characterized as irreparable in light of possible market confusion. And courts 26 have tended to issue injunctions in this context.” EMI April Music, Inc. v. Keshmiri, 27 2012 WL 5986423, at *6 (D. Nev. Nov. 28, 2012) (quoting Salinger v. Colting, 607 28 F.3d 68, 81 (2d Cir. 2010)).

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1 Here, while Defendants were working with Mr. Safinia, various articles 2 identified Mr. Safinia as the screenwriter and director on the project. Safinia Decl., 3 Exh. E. Indeed, the Internet Movie Database still lists Mr. Safinia as the director, 4 and Defendants' promotional materials for their film still do, too. Safinia Decl., 5 Exh. F; Rezvani Decl., Exh. F at 7. But Defendants’ derivative work is not the work 6 of Mr. Safinia. And if Defendants remain unchecked, it will be difficult for Mr. 7 Safinia to correct the misconception that Defendants’ film is his. 8 Just as important, allowing Defendants to release their film to the public will 9 eviscerate the value of the 2016 Screenplay. It will be difficult to find anyone who 10 will license the 2016 Screenplay once Defendants release their infringing work -- at 11 least and until the memory of Defendants’ film has faded from the public’s mind. 12 Safinia Decl. ¶14. It will be just as difficult for Mr. Safinia to convince others to 13 finance a film based on the same screenplay as Defendants’ film, especially if 14 Defendants’ version is panned by critics or the public generally. Id. 15 C. The Balance of Equities Tips Decidedly in Mr. Safinia’s Favor 16 The harm to Mr. Safinia absent an injunction will be irreparable, damaging 17 his reputation and eviscerating the value of his copyright. On the other hand, the 18 inconvenience to Defendants will be merely economic: even if Defendants somehow 19 ultimately win on the merits, they will have lost the mere monetary value of 20 releasing their film Deadlinesooner rather than later.1 Given “the probable outcome of this 21 22 1 In that vein, Mr. Safinia will post a bond in the amount of $50,000 against 23 which Defendants may claim reimbursement for damages stemming from the temporary restraining order and preliminary injunction in the (highly) unlikely event 24 they ultimately prevail on the merits. Safinia Decl. ¶13. That amount is in line with 25 bond amounts ordered by other courts in this circuit. See, e.g., Brookfield Commc’ns, Inc. v. W. Coast Entm’t Corp., 174 F.3d 1036, 1043 (9th Cir. 1999) 26 (issuing injunction effective upon plaintiff posting $25,000 bond); Warner Bros. 27 Entm’t Inc. v. WTV Sys., Inc., 824 F. Supp. 2d 1003, 1015 (C.D. Cal. 2011) (ordering plaintiff post $50,000 bond within two days after court signs injunction); 28 (footnote continued)

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1 action, this is a loss which [defendants] may justifiably be called upon to bear.” 2 Corning Glass Works v. Jeannette Glass Co., 308 F. Supp. 1321, 1328 (S.D.N.Y. 3 1970), aff’d on the opinion below, 432 F.2d 784 (2d Cir. 1970). And requiring 4 Defendants “to obey copyright law” does not present them an undue hardship. EMI 5 April Music, Inc., 2012 WL 5986423, at *7. 6 D. Issuing the Injunction Serves the Public Interest 7 It is well-settled that “[p]rotecting a company’s rights to its intellectual 8 property is in the public interest.” FMC Corp. v. Control Solutions, Inc., 369 F. 9 Supp. 2d 539, 578 (E.D. Pa. 2005); accord, EMI April Music, Inc., 2012 WL 10 5986423, at *7 (“[A]n injunction is in the public interest because it helps uphold 11 copyright law.”). That interest applies with no less force to protecting the 12 intellectual property of an individual. 13 II. MR. SAFINIA IS ENTITLED TO A TEMPORARY RESTRAINING 14 ORDER 15 Mr. Safinia has shown (1) the likelihood of success of his copyright 16 claim; (2) the irreparable injury he will suffer if Defendants are not enjoined; (3) the 17 balance of the equities favor Mr. Safinia; and (4) the injunction will serve the public 18 interest. Accordingly, the Court should temporarily restrain and preliminarily enjoin 19 Defendants, as well as all persons acting under the direction, control, permission, or 20 authority of Defendants,Deadline or any of them, and all persons acting in concert therewith, 21 from displaying, marketing, distributing, circulating, advertising, offering to sell, 22 transferring or selling any copies of their film. 23 24 25 26 United Tactical Sys., LLC v. Real Action Paintball, Inc., 2014 WL 6788310, at *25 27 (N.D. Cal. Dec. 2, 2014) (granting injunction contingent upon plaintiff posting $20,000 bond within 30 days). 28

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1 III. DEFENDANTS’ COPIES OF THE FILM SHOULD BE IMPOUNDED 2 AND DELIVERED UP FOR DESTRUCTION 3 Under 17 U.S.C. §503(a), the Court may order the impounding of all copies 4 “claimed to have been made or used in violation of the copyright owner’s exclusive 5 rights.” Impounding is intended to ensure the eventual destruction of the infringing 6 articles when the plaintiff prevails. Jewelers’ Circular Publ’g Co. v. Keystone 7 Publ’g Co., 274 F. 932 (S.D.N.Y. 1921), aff’d, 281 F. 83 (2d Cir. 1922). 8 Impoundment is ordered when the plaintiff shows a likelihood of success. See, e.g., 9 WPOW, Inc. v. MRLJ Enters., 584 F. Supp. 132, 135 (D.D.C. 1984). 10 Section 503 of the Copyright Act also provides, among other things, that: 11 [a]s part of a final judgment or decree, the court may order 12 the […] reasonable disposition of all copies […] found to have been made or used in violation of the copyright 13 owner’s exclusive rights, and of all plates, molds, 14 matrices, masters […] or other articles by means of which 15 such copies […] may be reproduced. 16 17 U.S.C. §503(b). 17 Impoundment is necessary here because Defendants (1) intend to continue to 18 display, distribute and use their version of the film, and (2) are likely to cause 19 irreparable damage to Mr. Safinia’s reputation in the film industry and to the value 20 of his copyrighted work.Deadline 21 The Court should further order all items seized be appropriately tagged to 22 permit identification, Defendants be provided a receipt therefor, and all such items 23 impounded be placed in the custody or control of Mr. Safinia or his attorneys. See 24 First Tech. Safety Sys., Inc. v. Depinet, 11 F.3d 641, 648 (6th Cir. 1993). 25 Conclusion 26 For all the foregoing reasons, Mr. Safinia respectfully requests the Court grant 27 his application for temporary restraining order in toto, and issue an order to show 28

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1 cause why Defendants should not be preliminary enjoined from further acts of 2 infringement pending final adjudication of the merits. 3 4 DATED: September 20, 2017 QUINN EMANUEL URQUHART & SULLIVAN, LLP 5 6 By/s/ Jeffrey D. McFarland 7 Jeffery D. McFarland Shahin Rezvani 8 Aaron Perahia Attorneys for Plaintiff 9 Farhad Safinia

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