Michael Steinhauer, Defendant in pro per

1641 Poinsettia #15

Los Angeles, CA 90046
Telephone (323) 850-5414
Temporary Fax (323) 874-8838

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

ABC ESCROW, INC., a California corporation; ) CASE NO.: BC312678

Alcohol Enterprises, Inc., a California corporation )
) Defendant Michael Steinhauer's
Declaration in
Response to Order to
Show Cause
Plaintiffs )
v. )
)
)
MICHAEL STEINHAUER, an individual ) Date: April 5th, 2004
) Time: 8:30 A.M.
) Dept.: 46
) Hon. Rodney E. Nelson
)

1, Michael Steinhauer, declare as follows;

1 am a defendant in this action ("the quote action"), in response to the courts' order to

show cause, I make this declaration. The facts stated herein are within my

l?,~sonal knowledge and, if called to testify as to these facts, I could and would testify

~mpetently
, ,. thereto. I am making no admission that I did anything wrong. I had no
;i.
i~tention of interfering with or breaching any contracts. I was only informed of the entire

.,-
~ :~,

_I
F:0pe of this matter at the time of our last hearing (March 29, 2004).

Declaration in Response to Order to Show Cause


My position of employment with plaintiff's was abruptly terminated and I was told to

leave the office on March 5th , 2004. Following my termination, there were loose ends

with respect to an outstanding telephone call regarding the client in question. The

contact with the client in question was initiated prior to my termination and in the course

and scope of my duties of employment. I made an effort to speak with the Plaintiff's

regarding this client on the day of my termination. However they refused to speak with

me. My intention was not to bring harm, ill will or conspire or interfere with regard to

any manner at all. If this action is immediately resolved as set forth herein, I will not

contest the validity, sufficiency or enforceability of any of the provisions of the

employment agreement, including, without limitation, the confidentiality, non-

disclosure and non-solicitation, prohibition on unfair competition and arbitration

provisions contained therein. As a condition of settlement and in order to ensure my

adherence to those specific provisions of the employment agreement, I hereby request

that plaintiff's immediately provide me with an exhaustive list of those persons and/or

entities who they legitimately believe were their customers and clients as of March 5th,

2004 (the date of my termination). I request this information/documentation so that there

will be no question as to whom I can or cannot have communications with, should I

decide to continue working in this field. Based on my proffered position to not contest

either
~.\.
the allegations brought against me or the validity and enforceability of any of the

~rovisions of the employment agreement under which this action has been brought
" J'
:1-
~ainst me with the Superior Court, I am willing to enter into a settlement agreement
';,.
P:ased upon my and the plaintiffs' compliance with all of the forgoing,
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Declaration in Response to Order to Show Cause

I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct.

Signed and dated as of today, April I"', 2004, Hollywood, California.

f!/d-$ilk~
Michael Stei auer

Page 3
Declaration in Response to Order to Show Cause

I:,
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,.11
 PROOF OF SERVICE

STATE OF CALIFORNIA)

COUNTY OF LOS ANGELES)

I reside in the county of Los Angeles, State of California. I am over the

age of 18 and am a party to the within action. My residence address is
1641 Poinsettia #15, Los Angeles, CA 90046.

On April 1, 2004, I served the foregoing document described as

Declaration of Defendant Michael Steinhauers' Declaration In Response
to Order to Show Cause on the interested parties in this action by
placing true copies thereof enclosed in sealed envelopes addressed as
follows:

Robert P. Wargo, Law Offices of Ronald Jason Palmieri, 911 Linda

Flora Drive, Los Angeles, CA 90049

X (BY MAIL) As follows: I am "readily familiar" with the firm's practice of

collection and processing correspondence for mailing. Under that
practice it would be deposited with U.S. postal service on that same day
with postage thereon fully prepaid at Hollywood, California in the
ordinary course of business. I am aware that on motion of the party
served, service is presumed invalid if postal cancellation date or
postage meter date is more than one day after date of deposit for
mailing in affidavit. [G. CP. 1012 and 1013(a)}

(BY FAX) As follows: On April 1, 2004, at approximately 2

p.m. by use of facsimile machine number (323) 874-8838, I
served as copy of the foregoing on the interested parties in
this action by transmitting by facsimile machine to the
following: 310-471-3511

(STATE) I declare under penalty of perjury under the laws

of the State of California that the foregoing is true and
correct.

Executed on April ,1, 2004, at Los Angeles, CA.

tfWu/J)S) tUZL Michael Steinhauer