December ____, 2015

Ms. Jeannette Clack

U.S. District Clerk's Office
501 West Fifth Street
Suite 1100
Austin, Texas 78701
RE: Civil Action No.: _________________________________
Steve Lisson v. Darius Mohsenin a/k/a Steve Lisson
In The United States District Court
Western District of Texas, Austin Division
Dear Ms. Clack:
Enclosed, for filing with the Court, please find:

Filing Fee;
Civil Cover Sheet;
Notice of a Lawsuit and Request to Waive Service of a Summons;
Waiver of the Service of Summons;
Summons in a Civil Action; 1
Original Complaint.

Please file-mark the extra copies and return them to me.

Thank you for your assistance. Please call if any questions or requests.
Respectfully submitted,

(2) Failure to Waive. If a defendant located within the United States fails, without good
cause, to sign and return a waiver requested by a plaintiff located within the United
States, the court must impose on the defendant:
(A) the expenses later incurred in making service; and
(B) the reasonable expenses, including attorney's fees, of any motion required to
collect those service expenses.
FED. R. CIV. P. 4(d).

______________________________
STEVE LISSON, Pro Se
Post Office Box 204321
Austin, Texas 78720-4321
206.600.3737 (voice/fax)
[email protected]
Enclosures:
- as stated
cc:

Darius Mohsenin a/k/a Steve Lisson

[email protected]
Steve Lisson [[email protected]]
Steve Lisson [[email protected]]
Steve Lisson [[email protected]]
Steve Lisson [[email protected]]
Steve Lisson [[email protected]]
Steve Lisson [[email protected]]
Steve Lisson [[email protected]]
Steve Lisson [s.lisson eBay User ID]
(via overnight delivery):
Darius Mohsenin
390 Sixth Ave.
Santa Cruz, CA 95062
(in 48 hours):
Mitchel Winick
Wendy LaRiviere
Elizabeth Rindskopf Parker
Vanessa Holton
Jayne Kim
Hon. Howard Lloyd
John Brown
Elliott Stone
Page 2 of 3

Hon. Don Lane

Hon. Jeff Rosell
Hon. Len Augustine
Jacob Rodriguez
Cassandra Arsenault
Hon. Laura Kuhn
Jerry Hobrecht
Jennifer Hagan
James Hagan
Denise Mohsenin
Michael Wixom
Katie Weber
Hon. Gail Pellerin
Jondi Gumz
Anthony Condotti
Kenneth Fisher
Jeffery Silk
Andrew Teufel
Fred Harring
Tom Fishel
Norm Kolb [sic]
William Van Vleet
Michael Ready
James Doyle
Erik Lundberg
Jeff Reals
Michael Hoffman
Jim Buckmaster
Meg Whitman
Thomas Siebel
Mike Bazeley
Heidi Rozien [sic]
Lee Hirsch
Anoop Prassad [sic]
etc.

Page 3 of 3

AO 398 (Rev. 01/09) Notice of a Lawsuit and Request to Waive Service of a Summons

UNITED STATES DISTRICT COURT

for the
Western District of Texas
Steve Lisson
Plaintiff
v.

Darius Mohsenin a/k/a Steve Lisson

)
)

Civil Action No.

Defendant

NOTICE OF A LAWSUIT AND REQUEST TO WAIVE SERVICE OF A SUMMONS

To: Darius Mohsenin
(Name of the defendant or - if the defendant is a corporation, partnership, or association - an officer or agent authorized to receive service)

Why are you getting this?

A lawsuit has been filed against you, or the entity you represent, in this court under the number shown above.
A copy of the complaint is attached.
This is not a summons, or an official notice from the court. It is a request that, to avoid expenses, you waive formal
service of a summons by signing and returning the enclosed waiver. To avoid these expenses, you must return the signed
waiver within 30 days (give at least 30 days, or at least 60 days if the defendant is outside any judicial district of the United States)
from the date shown below, which is the date this notice was sent. Two copies of the waiver form are enclosed, along with
a stamped, self-addressed envelope or other prepaid means for returning one copy. You may keep the other copy.
What happens next?
If you return the signed waiver, I will file it with the court. The action will then proceed as if you had been served
on the date the waiver is filed, but no summons will be served on you and you will have 60 days from the date this notice
is sent (see the date below) to answer the complaint (or 90 days if this notice is sent to you outside any judicial district of
the United States).
If you do not return the signed waiver within the time indicated, I will arrange to have the summons and complaint
served on you. And I will ask the court to require you, or the entity you represent, to pay the expenses of making service.
Please read the enclosed statement about the duty to avoid unnecessary expenses.
I certify that this request is being sent to you on the date below.
Date: December

, 2015
Signature of the attorney or unrepresented party

STEVE LISSON. Pro Se

Printed name

P.O. Box 204321 Austin, TX 78720-4321

1

Address

[email protected]
E-mail address

206 - 600-3737 (voice / fax)

Telephone number

AO 399 (01/09) Waiver of the Service of Summons

UNITED STATES DISTRICT COURT

for the
Western District of Texas
Steve Lisson
Plaintiff

v.

Darius Mohsenin a/k/a Steve Lisson

Civil Action No.

)
)

Defendant

WAIVER OF THE SERVICE OF SUMMONS

To: STEVE LISSON. Pro Se

(Name of the plaintiff's attorney or unrepresented plaintiff)

I have received your request to waive service of a summons in this action along with a copy of the complaint,
two copies of this waiver form, and a prepaid means of returning one signed copy of the form to you.
I, or the entity I represent, agree to save the expense of serving a summons and complaint in this case.
I understand that I, or the entity I represent, will keep all defenses or objections to the lawsuit, the court's
jurisdiction, and the venue of the action, but that I waive any objections to the absence of a summons or of service.
I also understand that I, or the entity I represent, must file and serve an answer or a motion under Rule 12 within
60 days from December , 2015 , the date when this request was sent (or 90 days if it was sent outside the
United States). If I fail to do so, a default judgment will be entered against me or the entity I represent.
Date:
Signature of the attorney or unrepresented party

Printed name of party waiving service of summons

Printed name

Address

E-mail address

Telephone number
Duty to Avoid Unnecessary Expenses of Serving a Summons
Rule 4 of the Federal Rules of Civil Procedure requires certain defendants to cooperate in saving unnecessary expenses of serving a summons
and complaint. A defendant who is located in the United States and who fails to return a signed waiver of service requested by a plaintiff located in
the United States will be required to pay the expenses of service, unless the defendant shows good cause for the failure.
"Good cause" does not include a belief that the lawsuit is groundless, or that it has been brought in an improper venue, or that the court has
no jurisdiction over this matter or over the defendant or the defendant's property.
If the waiver is signed and returned, you can still make these and all other defenses and objections, but you cannot object to the absence of
a summons or of service.
If you waive service, then you must, within the time specified on the waiver form, serve an answer or a motion under Rule 12 on the plaintiff
and file a copy with the court. By signing and returning the waiver form, you are allowed more time to respond than if a summons had been served.

AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURT

for the

Western District of Texas

Steve Lisson
Plaintiffs)

Civil Action No.

V.

Darius Mohsenin a/k/a Steve Lisson

Defendant(s)

SUMMONS IN A CIVIL ACTION

To: (Defendant's name and address)

Darius Mohsenin 1 390 Sixth Ave. I Santa Cruz, CA 95062

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney,
whose name and address are:

STEVE LISSON, Pro Se I P.O. Box 204321 1 Austin, TX 78720

If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.

CLERK OF COURT

Date:
Signature of Clerk or Deputy Clerk

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS
AUSTIN DIVISION
STEVE LISSON,

vs.

DARIUS MOHSENIN,

aka Steve Lisson,

aka Steven N. Lisson,

aka S.Lisson,

aka SLisson,

aka InsiderVC,

aka Alexi Stoltzfus,

aka Amala Khoistani,

aka Anita Walker,

aka Ashok Chaterjee (Fisher Invesments [sic]),

aka Austin Slisson,

aka Ayellet Berger,1

aka Cheryl Maranto,2

aka Craigs List [sic],3

aka Damman,

aka Darius,

aka Darius M,

aka Darius Mezzari,

aka Darius xxxxxx,

aka David Anderson,

aka David Morgan,4

aka Dr. Doeen [sic] Smith,

aka Dr. Ras Tanura,

aka Erol Toker,

aka Heather,

aka Jacob V.O. Mullins,

aka Jane Geddes,

aka Janet Novatny,5

aka Jay Boddu,

aka Jennifer Bryson,

aka Jonathan,

aka Julia Morgenstern,

Plaintiff,

I'LL BE WATCHING YOU!!!

GO FUCK YOURSELF!
3
I am an attorney (emphasis supplied).
4
As I said, I am an attorney (emphasis supplied).
5
"Asshole"
2

Civil No. __________________________

aka Kevin Jolivette,

aka Leslie Burnside,
aka Matt Driscoll,
aka Michelle Stecker,
aka Pat Flanders,
aka Rakesh Jain,
aka Redbook Residential,
aka Reddy,
aka Richard (Rick) Mora,
aka Robin Moran,
aka Sportsfan,
aka Srini,
aka Steve Lorenz,
aka Suirad Jabani (The Hagan Law Firm),
aka Sursap,
aka The Freebie Lodge,
aka TheHardcoreMag,
aka threeflinthills,
aka Tropeco Plaza,
aka Tubeflix,6
Defendant.

ORIGINAL COMPLAINT
A. Parties
1.

Plaintiff, Steve Lisson, resides in Austin, Travis County, Texas.

2.

Every name, address, and telephone number, which Defendant has provided for

service of process, is false. For example, according to Defendant, as always, in his own words:
a.

You know my name, it's on the agreement I signed! (emphasis supplied).

b.

Steve Lisson 650.233.0330

c.

My address for service is 120 Meadow Lane, State College, PA. Would you like my
phone number for your process server to call me to make sure he can serve me? I look
forward to your "lawsuit", faggot.
3.

Upon information and belief, Defendants true name is Darius Mohsenin

(Defendant or Mohsenin) who -- along with all his self-described deceptive identities,
infra -- for example, according to Mohsenin, in his own words:
6

See, if necessary, the amended complaint for Mosheims description of this obscene, vulgar, filthy, disgusting site.

Page 2 of 13

a.

As for your concern with deceptive identities, like, dude, have you ever hear [sic] of the
INTERNET?????

b.

I am attorney with a firm that represents many Silicon Valley start-ups as well as VC
firms (emphasis supplied).

c.

I am a paralegal at a Palo Alto law firm that works with many VC firms, both local and
in Texas and the Boston area. I have significant access to very, very valuable information
of interest to those in the VC community and those that want to seek VC funding. I have
"sold" inside information through a series of cut-outs that shield me as the source. I
would like to have a more legitimate, less cloaky, portal to expand my information
business (emphasis supplied).

d.

I was a barrister in England before relocating to the US. I have to take the California bar
exam before I become fully credentialed in CA. I am performing more paralegal-like
work here at Hagan...that is why I am casting about for other opportunities (emphasis
supplied).

e.

I am a medical doctor now practicing in Las Vegas in a small partnership. I am also an

angel investor. Do you accept PayPal?

f.

If your [sic] wondering about the email address, its [sic] my stip [sic] mall in Hawaii
which I typically use for tenant, vendor communications.

and other fraudulent impersonations may be served at: 390 Sixth Ave., Santa Cruz, CA 95062;
telephone: (408) 830-7003.
B. Jurisdiction
4.

The amount in controversy exceeds the jurisdictional minimum and is between

citizens of different states. 28 U.S.C. 1332; see also, 28 U.S.C. 1367.

5.

As more fully detailed -- if necessary -- in the amended complaint, this Court has

federal-question jurisdiction. For example, according to Mohsenin, in his own words:

a.

My hacker friend noticed some vulnerabilities in your site. I'll let you find the changes he
made! (emphasis supplied).

b.

I'm trying to login to your stupid-ass site now (emphasis supplied).

c.

I have copyrighted all rights to "InsiderVC". This is formal notice to cease and desist
from using any and all instances of "InsiderVC." When's the trial? Are your parents first
cousins or something?

Page 3 of 13

d.

[T]he name "InsiderVC" has been trademarked by our company long before you have
[sic] on InsiderVC.com.

e.

I registered www.stevelisson.com to start a blog site. With my SEO skills, I'll have all the
goods on you.
6.

Additionally, according to Mohsenin in his own words, his -- literally -- thousands

of intentional contacts and other interactions with this forum also include, inter alia:
a.

Seven days and counting till I get to Austin!

b.

I'll just come by your house.

c.

Have you noticed a white Dodge Neon with a guy with a green Oakland A's cap on
sitting in it? That's me. Ive been waiting for you to come out to discuss your website.

d.

Are you in there?.7

e.

Was that your wife that came out of your house when I was waiting down the street for
you to come out? Fuggly! Steve, what's the deal, are you just too lazy to jack off?

f.

Must be a slow day in Austin cumlips! Are you're [sic] parent's first cousins or
something? Was that your dog barking when I was there?

g.

I did take a piss on your yard.

C. Facts
7.

Mohsenin perpetrates his unauthorized, actionable behavior and other unlawful

activities through, inter alia, myriad fraudulent artifices and, to this day, still refuses to stop and
transfer all (or any) of his illegal imposter and stalking accounts. For example:
a.

Steve Lisson [[email protected]]

b.

Steve Lisson [[email protected]]

c.

Steve Lisson [[email protected]]

d.

Steve Lisson [[email protected]]

e.

Steve Lisson [[email protected]]

On multiple occasions -- including via telephone from Fisher Invesments [sic] -- emphasis in original each time.

Page 4 of 13

f.

Steve Lisson [[email protected]]

g.

Steve Lisson [[email protected]]

h.

Steve Lisson [s.lisson eBay User ID].

8.

For over eight years, Mohsenin has been crudely, profanely, sexually,

propositioning, impersonating, harassing, stalking, spamming, spoofing, blackmailing,

obsessing, advertising, misrepresenting, misappropriating, threatening, defrauding, hacking,
extorting, infringing upon and copying, annoying, defaming, tormenting, terrorizing, and
soliciting Plaintiff and Plaintiffs properties. For example, Mohsenin, in his own words:
a.

My name is Steve Lisson and I write a highly regarded newsletter for the venture capital
community that is accessed at www.insidervc.com (bolface supplied).8

b.

What do I tell the folks that respond to my ad for www.insidervc.com??? Ive got it all
over craigslist and other classified sites.

c.

Craislist [sic] never "cut" me. What is shit-nuts talking about now?

d.

Yes, craigslist did remove it but its been posted on five other cities. I've even had
inquiries. In fact, maybe you can answer this question: One guy wanted to know if is built
with any "PHP scripts"? Do you know what that is and what is the answer. Hurry back to
me, he's waiting for a reply.

e.

I'm working ten cities (I just added five more since I last emailed you).

f.

Got another inquiry about our site...I tried to log into the web host but forgot the
password. Can you refresh my memory again?

g.

You don't own this domain name nor the website.

h.

Why don't you modify the site by adding a page www.insidervc.com/alexi.html with a
message to me.

i.

I request you park your car in your garage (if you can afford oneunlikely), start the
engine and roll down the windows.

j.

I see we share the same name and similar email addresses.9

8
9

See, EXHIBIT A.
See, Group EXHIBIT B at 1.

Page 5 of 13

k.

I see that you are in Texas' Megan's Law database.

9.

Repeatedly, Mohsenin claimed that his motives, purposes, goals, etc., were his own

financial gain, at Plaintiffs expense. For example, according to Mohsenin, in his own words:
a.

[M]y "extra employment" income.

b.

I will seek a lien on your home if you do not pay me.

c.

Would you like my paypal [sic] account info?

d.

I see Julia forced you to buy www.insider.net! Ha, ha! What a lameass!

e.

[I]t is a social networking startup for the VC industry.

f.

It is for a social networking project in entrepreneurship as part of my thesis at the

Wharton School My project has outside funding and I plan on spinning this into a
sustainable business.

g.

It's basically a Web 2.0 social-networking site for a very select, niche group of wealth
management folks. We have a very high profile angel investor backing us "We" is our
team. Investor, develoers [sic], subscribers.

h.

And stop using my "insidervc" credentials. I'm the original InsiderVC!!!!!

i.

If I get my price [for illegally advertising and selling your site],10 I'll consider buying
your site for $5000 (emphasis supplied).
10.

Mohsenin continued violating numerous notices to cease and desist, receipt of

which (from Plaintiff,11 EarthLink,12 Hostgator,13 Google, Gmail, and others) he freely and
voluntarily confirmed, in his own words:
a.

I've already written your email for you to cut and paste STOP ALL YOUR
ACTIONABLE BEHAVIOR! (emphasis in original).

b.

There you go being uncooperative again! Ill fix that.14

10

$15,000. For but one of Mohsenins countless illegal ads over the years, see EXHIBIT C.
See, Group EXHIBIT D at 3, for an example. Mohsenin -- who refused to answer the simplest of questions
(e.g., his name) -- is, inter alia, overweight.
12
Mohsenin replied: boo hoo, waaa! Geez, what a bawl baby.
13
Pursuant to, inter alia, THE DIGITAL MILLENNIUM COPYRIGHT ACT. Mohsenin admitted he is a repeat offender.
14
See, Group EXHIBIT D at 2.
11

Page 6 of 13

c.

You want a threat you can take to the police...read on.

d.

Leave for Austin todayso send me what I want to know about your web site for sale or
Ill have to come to you in person to get the info out of you!

e.

How far is the Salt Lick from Austin? I've heard its a great place to go.

f.

Hey Douchebag! What does inter alia mean?

g.

You [sic] on a webcam for my downtown apartment.

h.

Can you see me in you [sic] message preview?

i.

When George Bush left Austin the average IQ of the city rose slightly.

j.

Catch me in [sic] you can!

k.

Are you implying i [sic] created [email protected] and [email protected]?

l.

Fat geek that thinks google [sic] or gmail [sic] will even give a shit! You just flushed a
grand down the shit hole dipshit!

m.

Are you interested in joining forces?

n.

I can see that I am annoying you (emphasis supplied).

11.

Mohsenin still refuses to stop all (or any) of his actionable, even felonious

behavior. For example, not only falsely holding himself out as a lawyer, but also falsely
simulating legal processes. According to Mohsenin, as always, in his own words:
a.

I have a default judgment of $9,764 against you in California from three years ago by the
wayyou never showed up for the small claims hearing! I'm getting the judgment
domesticated in Travis County so I can seize your assets.

b.

U know u [sic] have a judgement [sic] against you here in CA?

12.

Mohsenin is such a deranged sociopath that he prepares -- then uses interstate

wire communications to transmit -- fraudulent legal agreements.15

13.
15

Mohsenin is such a certifiable sociopath that he pleasures himself by sending --

See, EXHIBIT E, for one of them.

Page 7 of 13

to himself -- profane messages impersonating Plaintiff,16 and then complains about them.
14.

Mohsenin is such an obsessed sociopath that -- again using interstate wire

communications -- he registers confusing and very similar domain names.17

15.

Mohsenin is such a screwed-up sociopath that he creates fake websites and

fraudulent eBay listings, illegally impersonating Plaintiff. For example, according to Mohsenin:
Found someone selling this on ebay [sic] for $100 Buy It Now http://insidervc.info
So you had no luck with .com for years? You actually think ".info" will help?????
Geez, you are warped...or a really bad businessman. Both likely.
16.

Mohsenin is such a warped and really bad sociopath that -- abusing both

private registration and interstate wire communications -- he fakes complaints about his own
illegally copied, fraudulent, imposter, stupid .info site. For example, according to Mohsenin:
Looks like my complaint to your hosting company worked to get your stupid .info
site off the radar! HA HA! So much for our private registration--trying to hide
from us, eh?
17.

Mohsenin is such a sick sociopath that he even fakes answering his own

fraudulent advertisements. For example, Mohsenin, again in his own words -- about himself, his
own deceptive identities and listings -- each time violating repeated notices to stop:
a.

Are you the owner of insider.info [sic] as well (the registration is shown as private). If so,
could you provide that domain as well?.18

b.

Are you Srini that was also selling the insidervc.info site on the same craigslist site?.19

c.

I also saw someone trying to sell your same site or one awfully close to it on craigslist?
Is that you shilling or something? I bet you've got all kinds of folks that think you're off
he [sic] hook emailing you (emphasis supplied).

d.

What is this all about?? I thought you'd be interested that someone listed a name similar
to yours on craigslist (emphasis supplied).

16

For example: Go fuck yourself!

For example: InsiderVC.info.
18
Mohsenin himself was the owner of insider.info [sic].
19
Mohsenin himself was Srini that was also selling the insidervc.info site on the same craigslist site.
17

Page 8 of 13

18.

Mohsenin is such a twisted sociopath that he fakes telephone calls to himself and

even fakes sales to himself. For example, Mohsenin, again in his own words, about himself, each
time violating repeated warnings to stop:
a.

One of your craigslist ads. There seems to be two. One is asking $50 and includes the
".info." Now I'm confused??? (emphasis supplied)

b.

I called the phone from the other ad and I am dealing with them (emphasis supplied).20

c.

www.insidervc.info I found this on craigslist for $25, so I bought it. The owner hasn't
transfered [sic] yet. It looks like your site? Are you involved with it somehow? Care to
join forces? (emphasis supplied).

d.

I never heard from you regarding teaming up on insidervc.info. We have very similar
names, you think so, right? (emphasis supplied).
19.

The amended complaint -- if necessary -- features every single one of Mohsenins

filthy, vulgar, obscene, pornographic, scatological, felonious, and other disgusting, hard-core
harassment, advertisements, solicitations, and impersonations (literally, thousands of pages)
including vile racial slurs, bestiality, extremely offensive sexual acts, photos and images,
pedophilia, and child molestations. For example, according to Mohsenin, in his own words:
a.
Check me out here
http://www.nudetube.com/viewVideo.php?video_id=1731&title=Latina_does_the_handjob.
b.

20

NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER

NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER
NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER
NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER
NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER
NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER
NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER
NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER
NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER
NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER
NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER
NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER
NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER
NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER

[T]he phone from the other ad belongs to the sociopath Mohsenin himself.

Page 9 of 13

NIGGER NIGGER NIGGER NIGGER NIGGER NIGGER (emphasis in original).

c.

You must have a small penis.

d.

motherfuckingwackjob.21

e.

iwantmylawsuit.

f.

Dickeater.
20.

Mohsenin falsely, recklessly, maliciously accuses Plaintiff of hacking an

unspecified gmail address.22

21.

Contemporaneously,23 Mohsenin tries -- and fails -- to engage Plaintiff via

telephone,24 voice-mail, social media and, of course, e-mail. For example, Mohsenin, in his own
words, each time violating repeated notices to cease and desist:
a.

Wanna split the cost and be partners?

b.

I noticed my last email was deleted by mistake without you being able to read it.

c.

I will take that as permission TO send you email (emphasis in original).

d.

I keep getting these read receipts saying "not read." I bet you're really reading them.

e.

Read it, dickbag.

f.

Read it, dickwad!

g.

Bite me.

h.

Earthlink accounts go away on July 31 also. Would you like my new email address?

i.

Do you wish to be added to our "unsubscribe" list?

j.

Are you interested in buying my domain?

22.

Mohsenin still purports that Anoop Prassad [sic], whose practice focuses on

21

See, EXHIBIT F. Mohsenin bid from his illegal, fraudulent, imposter eBay account.
What gmail addresses are you referring to? The only gmail address I have is [email protected].
23
What does contemporaneous mean?
24
Including, for example: at 1:47 a.m. CDST on Saturday, June 06, 2015 (yes, this is how Mohsenin spends a
Friday night).
22

Page 10 of 13

low-income Asian Pacific Islander immigrants in deportation proceedings,25 represents him in all
(or any of) these matters. For example, according to Mohsenin, in his own words:
a.

I've given Mr. Prassad [sic] permission to contact you. What number should he use?

b.

If you want my attorney to contact me [sic], you've GOT to give me a phone number!

c.

As I said, I am an attorney. I don't cut my own hair just as I don't represent myself. What
form would you like to be contacted? My attorney prefers a phone call first (emphasis
supplied).

d.

My attorney is curious as to what you want. You can contact him at 415.568.3777. Ask
for Anoop Prasad.

e.

So you called my attorney. Excellent. What did he say? You mean, you actually picked
up the phone and called this guy I sent you to! That's one for me, shit-nuts!!
23.

No one with whom Mohsenin purports to act in concert (or even know) has ever

heard of him (save those who, like Plaintiff, requested Mohsenin stop). For example:
a.

Heidi Roizen [sic].26 See, EXHIBIT G.27

b.

Margaret C. Whitman, then-CEO of eBay.28

c.

Thomas Siebel, an American business executive.29

d.

Erik Lundberg, Chief Investment Officer, University of Michigan.30

e.

Anoop Prassad [sic], staff attorney at Asian Americans Advancing Justice - Asian Law
Caucus in the Immigrant Rights Program.

f.

Exclusive Resorts, a destination-club company.31

g.

Michael Bazeley, UC Berkeley Law School / San Jose Mercury News,32 who responds:

25

See, http://www.advancingjustice-alc.org/staff-member/anoop-prasad.
I'm chaperoning a party at Heidi Rozien's [sic] house My kid goes to school with her daughter and I've been
asked to help out.
27
Had Mohsenin been telling the truth and not trying to scam or defraud someone (for the first time in his pathetic
life), then he would have known that Heidi Roziens [sic] employer subscribed to Plaintiffs site.
28
I bumped into Meg Whitman I'll let Meg know your subpoena is coming.
29
One of my trim carpenters is working on his job.
30
I did get an answer from Lundberg--he [sic] not happy man!
31
and other sites appealing to high-net worth individuals. The sooner we can put together a deal the better!
(emphasis supplied).
32
Mike Bazeley says your [sic] a fraud.
26

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How did I get sucked into this? And who is Darius?.33

24.

Incredibly, even Defendant himself, Darius Mohsenin, in his own words, each

time violating repeated notices to cease and desist, asks:

a.

Who is "darius"???

b.

Explain this "darius" thing?

c.

Who the fuck is Anoop Prasad????

d.

Impressive site! What are you asking for it?.34

e.

There's a similar ad for your same site on the NYC craigslist and the guy wants $500!
(emphasis supplied).35

f.

I'm offering $2,000. If that is acceptable, do you take PayPal?.36

g.

I brought your domain to the attention of some other folks at my company now that we're
all back at work. They are possibly willing to entertain a higher offer. What are you
interested in selling it for?

h.

Were you born in NJ in Aug 1961?

i.

Would you take $5000 for both domains together with integrating a blog into the site? Do
you take Paypal?

j.

GO FUCK YOURSELF! (emphasis in original)

k.

What's this all about?

http://dockets.justia.com/docket/texas/txwdce/1:2013cv00854/652788.

l.

What are you asking for the domain name you have on craigslist? What is your phone
number to discuss details?.37

m.

Once again, I am asking for a contact phone number for Mr. Prassad [sic].

n.

I'm now gathering that last week's Forbes' cover story was about folks like you. It's a
business magazine in case you aren't familiar with it. Can you get it in Nigeria?.38

33

See, EXHIBIT H.
Mohsenin knows full well that, since the price is more than 99 ($0.99), he cannot afford it.
35
As always, Mohsenin himself was the guy illegally advertising Plaintiffs site.
36
See, Group EXHIBIT I at 1.
37
See, Group EXHIBIT J at 1.
38
For a partial compilation of familiar business magazines stories (including from heart of Silicon Valley) -- none of
which ever featured, quoted, cited, attributed or sourced Mohsenin, in any manner at all -- see EXHIBIT K.
34

Page 12 of 13

o.

WHERE'S THE FUCKIN' LAWSUIT! (emphasis in original)

p.

Please, please file on...please! I'm begging you!

q.

Have you considered jacking off?

D. Conditions Precedent
25.

All conditions precedent have occurred or have been performed.

E. Prayer

THEREFORE, Plaintiff demands judgment against Defendant, Darius Mohsenin, for

damages, costs, plus all other appropriate relief, including orders requiring Mohsenin,
immediately, to transfer all his unlawful imposter accounts and forward certified copies both of
his Bar and Barrister cards as well as his default judgment of $9,764.
Respectfully submitted,

__________________________________
STEVE LISSON, Pro Se
Post Office Box 204321
Austin, Texas 78720-4321
206.600.3737 (voice/fax)
[email protected]

DECLARATION
I declare under penalty of perjury that the facts stated and documents contained in the
above and foregoing instrument are true and correct.
EXECUTED on this ______ day of December 2015.

__________________________________
Steve Lisson

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