John W.

Amberg
Direct: 1-310-576-2280
Fax: 1-310-576-2200
jwamberg@bryancave.com

Bryan Cave LLP

120 Broadway, Suite 300

January 14, 2008
Santa Monica, CA 90401-2386

Tel (310) 576-2100

Fax (310) 576-2200

www.bryancave.com
VIA E-MAIL AND OVERNIGHT MAIL

Dr. Joseph Zernik

Chicago
2415 Saint George Street
Hong Kong
Los Feliz, California, 90027
Irvine
E-mail: jz12345@earthlink.net
Jefferson City

Re: Nivie Samaan v. Joseph Zernik Kansas City

Los Angeles County Superior Court, Case No. SC087400 Kuwait

Los Angeles

Subject: THIRD CEASE AND DESIST LETTER New York

Phoenix

Dear Dr. Zernik: Shanghai

St. Louis
We write for the third time to demand that you cease and desist from harassing Washington, DC
Countrywide Home Loans, Inc. ("Countrywide") and its officers and employees.
Your continued direct communications with Countrywide officers and employees are And Bryan Cave,
A Multinational Partnership,
in violation of the Court's Protective Order dated July 23, 2007, which orders you to
London
communicate solely with Countrywide's designated counsel and no officers or
employees (the "Protective Order"). Your repeated violations are knowing and
willful,. and in contempt of the Court's Order. Your recent e-mails are also
defamatory.

At the January 11, 2008 hearing, Judge Friedman clearly stated that the Protective
Order remains in full force and effect. However, on the very next day, January 12,
2008, you emailed Angelo Mozilo, the Chief Executive Officer of Countrywide's
parent company, Countrywide Financial Corp., and Sandor Samuels, the Chief Legal
Officer of Countrywide, in violation of the Protective Order. As with your previous
emails, about which we have complained, your latest emails are false and defamatory.
They falsely accuse Countrywide of mortgage fraud and wire fraud, which is an
outrageous and damaging accusation. The recipients of your latest defamatory emails
apparently include not only members of the Bet Tzedek Board of Directors, but also
others in the local Jewish and/or business community.

You have also apparently altered or created an invitation to an upcoming Bet Tzedek
event, by including false and defamatory comments, as well as offensive remarks

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Dr. Joseph Zernik
January 14,2008
Page 2

regarding the religious affiliations of certain individuals. This doctored invitation is intentionally
misleading.

Countrywide reiterates its demand for the following:

1. That you inunediately cease and desist from contacting represented Countrywide officers and
employees, and shall communicate solely with Countrywide's designated legal counsel in the future,
pursuant to the Protective Order entered in this case on July 23, 2007;

2. That you inunediately cease and desist from contacting any personal associates of
Countrywide's officers and employees about the business practices of Countrywide and its officers
and employees;

3. That you retract the false and malicious statements that you have published to third parties,
including but not limited to your false and outrageous statements that Countrywide and its officers
and employees have committed fraud and colluded with plaintiff Nivie Samaan and various judicial
officers of the Los Angeles Superior Court; and the above-described doctored Bet Tzedek invitation.
Retraction should be made in the same form and to the same persons to whom the defamatory
statements were made, and proof of the retractions shall be provided to the undersigned; and

4. That you cease and desist from publishing any new defamatory statements about Countrywide
and its officers and employees.

These false and offensive communications must stop. You continue to willfully and flagrantly violate
the Protective Order, and continue to mount an unprovoked assault on Countrywide and its officers
and employees. You have persisted in spreading defamatory statements across the community to
persons with no connection with this lawsuit. We demand that you cease and desist from violating the
Protective Order and communicating with Countrywide officers and employees. We also demand that
you cease and desist from making defamatory statements to their personal and business associates.

Your continued violations of the Protective Order and defamatory comments will not be tolerated.
Countrywide and its officers and employees reserve the right to take all available legal action against
you, and to seek all available remedies.

vf truly yours,

JWA:jcc

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