FILED

5/10/2021 4:05 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Cassandra Walker DEPUTY

CAUSE NO. DC-20-09713

MOHAMlVIAD SOHAIL, IN THE DISTRICT COURT

§§§§§§§§§
Plaintiff,

V.
101 ST JUDICIAL DISTRICT
ANWAR KAZI’ ZAMEER
SACHEDINA, ROHIT
SHARMA, AND WISEMAN
INNOVATIONS, LLC.
Defendant. DALLAS COUNTY, TEXAS

RESPONSE TO VERIFIED APPLICATION FOR TEMPORARY RESTRAINING

ORDER AND TEMPORARY INJUNCTION

TO THE HONORABLE COURT:

Defendants Anwar Kazi, Zameer Sachedina, Rohit Shanna, and Wiseman Innovations,

LLC file this Response to Verified Application for Temporary Restraining Order and Temporary

Injunction. Defendants attach the following declarations and evidence in support of this response

for the Court’s consideration.

Exhibit A — Declaration of Rohit Sharma

Exhibit B — Declaration of Zameer Sachedina.

Moreover, Defendants object to the attached verification to Plaintiff” application as it does

not comport with Section 132.001 of the Texas Civil Practice and Remedies Code.

Response to Verified Application for Temporary Restraining Order and Temporary Injunction PAGE 1
 Dated: May 10, 2021 Respectfully submitted,

/s/ Jervonne D. Newsome

Michael K. Hurst
Texas Bar No. 10316310
mhurstglenllgeom
J ervonne D. Newsome
Texas Bar No. 24094869
jnewsome@ly§nllp.com
LYNN PINKER HURST & SCHWEGMANN, LLP
2100 Ross Avenue
Suite 2700
Dallas, Texas 75201
Telephone: (214) 981 -3000
Facsimile: (214) 981—3839

ATTORNEYS FOR DEFENDAN TS

ANWAR KAZI, ZAlVIEER SACHEDINA,
ROHIT SHARMA, AND WISEMAN
INNOVATIONS, LLC

Response to Verified Application for Temporary Restraining Order and Temporary Injunction PAGE 2
 CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing document was
served via ECF on all counsel of record this 4th day of May, 2021.

/s/ Jervonne D. Newsome

J ervonne D. Newsome

Response to Verified Application for Temporary Restraining Order and Temporary Injunction PAGE 3
 CAUSE N0. DC-20-09713
MOHAMMAD SOHAIL, IN THE DISTRICT COURT
Plaintifl,
V.

ANWAR KAZ], ZAMEER 101 ST JUDICIAL DISTRICT

SACI-IEDINA, ROHIT
SHARMA, AND WISEMAN
INNOVATIONS, LLC.
Defendant. DALLAS COUNTY, TEXAS

DECLARATION 0F ROI-HT SHARMA

Myy name is Rohit Shanna. My date of birth is March 14, 1973. My business address is
4100, Midway Road, Suite 2105, Carrollton, TX 75005, . I am over 18 years of
age, of sound mind,
and capable of making this declaration. I have never been convicted of a
felony or any crime
involving moral turpitude. I declare under penalty of perj ury that the following is true and correct.

I currently hold the position of

Engineering & Innovation Lead at Wiseman Innovations.
The following attached emails are true and correct.

l. This Wiseman case started when financial investigations

starting early March, 2020,
months before Sohail filed a lawsuit showed money trails of
money removed from United
States to Pakistan in a concerted manner
leading to Sohail’s family members, his two
brothers (Mohammad Junaid, Mohammad Waqas), Sohail’s sister—in-Iaw
(Maria Bibi) and
other accomplices Waleed Khalid and some individuals who were not connected to the
company. As Pakistan is under FATF Watchlist for money laundering, terrorist financial
and proliferation funding, the company has an
obligation to report to FINCEN (Financial
Crimes Network) in USA, the FIA (Federal Investigation
Agency) in the United. We also
found fake invoice made for Sohail’s Sister Nazneen N (a
google employee and a resident
of California) as well as saw a bank account where Sohail’s mother, a resident of United
States received funds as a co-owner of a salaried account of Mohammad
Waqas (a ghost
employee). As per Pakistan laws, salary accounts cannot be joint accounted. These
investigations and significant documentary evidence lead to concerns about concemed tax
evasion in the United States and money laundering activities. The
company reported the
above to IRS and also was in a process of reporting these serious
transgressions to FINCEN
in the United States. These were important as our main
corresponding bank in Pakistan,
Meezan has been cited and fined for money laundering and also cited
recently for terrorist
financing based on a security incident in Pulwama, India. Based on the evidence they had

DECLARATION
Exhibit PAGE 1

A
 seen, I believe our corresponding bank were about to report or have
already reported
suspicious money laundering activities to authorities in Pakistan.

2. Waleed Khalid, the former HR Manager created a fake

company for Tenant Improvement
in Pakistan, fronted by his real brother Ahmad
Khalid, and was at the centre of the fiaud.
During the investigations, the company found money trails back to Sohail’s two brothers
Mohammad Waqas, Mohammad Junaid and his sister-in-law Maria Bibi from the fake
entity.

3. We already suspected Sajid to have enabled an IT breach

earlier, however due to lack of
clear evidence, we were not able to investigate and
discipline. When the Premier breach
happened, I and Bilal Aslarn the CEO of Wisernan PK started tracing the breach. All roads
led to Sajid who was questioned in formal
settings. Sajid was reluctant to admit his
wrongdoing but agreed to be truthful. During these calls Sajid claimed that he was
inadvertently involved in money transactions with the accused in Pakistan and alluded to
money laundering activities by Junaid and Waleed Khalid (by placing black money into
legitimate systems). What raised our red flag was when Sajid informed me and Asad Ali
Abro, VP admin in Pakistan, that Sohail’s brother Mohammad Junaid maybe involved in
running illegal call centers. With this new information, the PI-H breach became very serious
as most of the [RS Scamsters originate from India and Pakistan. We were concerned
that
Sohail, his brother and others had possibly sold or planning to sell the PHI data to black
market for misuse.

4. Sohail has always been concerned about federal agencies

investigating him and his family
members. He also bragged to me in March, 2020 about how he
got his US Green Card by
fraud by outsmarting the USCIS and company processes. I have evidence to
prove how
Waleed Khalid worked in concert with Sohail Mohammad to cheat the Labor Certification
Process in the United States. Sohail and his son Mohammad Jee, a resident of Texas made
implicit threats to me while returning the laptop in Wiseman office in early July, 2020 and
threatened that if the investigation proceeds, they have long reach in US, Canada and
Pakistan and we will loose everything. These threats were of
implicit violence and other
actions and I reported it to the company. I was assured that I and
my family members in
Canada are safe in North America.

5. I deny ever threatening Sajid Fiaz or Waleed Khalid, had

very limited interaction with
Waleed Khalid and believe that Sohail and other accused in this case came to know
through
their sources that Wiseman is planning to report the violations to FINCEN,
USA, FIA
(Pakistan), USCIS and other federal authorities to protect the company from any criminal
or civil penalties. In addition, Sajid Fiaz had already volunteered a lot of
damning
information about illegal call centres and some funny business that Sohail’s brother was
involved in. This imminent reporting to authorities including the HIPAA violation and PHI
breach soon caused red flags for them as Sohail’s all fatnily members (two brothers in
Pakistan, two sisters in US, a sister-in—Iaw in Pakistan) and others have significant exposure

DECLARATION
PAGE 2
 from this reporting. Sohail has made
multiple attempts to stop these investigations so far
which have failed so far.

Executed this 10"1 day of May, 2021 in Dallas County, Texas.

ROHIT S

DECLARATION
PAGE 3
 CAUSE NO. DC-20-09713

MOHAMMAD SOHAIL, IN THE DISTRICT COURT

§§§§§§§§§
Plaintiff,
v.

ANWAR KAZI, Z AMEER .

101 51‘ JUDICIAL DISTRICT
SACHEDINA, ROHIT
SHARMA, AND WISEMAN
INNOVATIONS, LLC.
Defendant. DALLAS COUNTY, TEXAS

DECLARATION OF ZAMEER SACHEDINA

May name is Zameer Sachedina. My date of birth is April 5, 1971. My business address is 4100
Midway Road #2105, Carrollton, TX 75007. I am over 18 years of age, of sound mind, and capable
of making this declaration. I have never been convicted of a felony or any crime involving moral
turpitude. I declare under penalty of perjury that the following is true and correct.

I currently hold the position of CEO at Wiseman Innovations.

I deny ever threatening Saj id Faiz or Waleed Khalid over the phone or by any other method. They
were being investigated for HIPPA breach and Financial Crimes, respectively. Both resigned from
their position on their own accord.

Executed this 10th day of May, 2021 in Dallas County, Texas.

RSA

Exhibit

DECLARATION
PAGE 1
 Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.

Tonia Ashworth on behalf of Jervonne Newsome

Bar No. 24094869
tashworth@lynnllp.com
Envelope ID: 53290548
Status as of 5/12/2021 9:25 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

LuCretia Milam LMilam@LegalTexas.com 5/10/2021 4:05:59 PM SENT
Charles Gameros 796596 bgameros@legaltexas.com 5/10/2021 4:05:59 PM SENT
Jennifer Noelle Rauch 24033108 jrauch@legaltexas.com 5/10/2021 4:05:59 PM SENT
Douglas Wade Carvell 796316 wcarvell@legaltexas.com 5/10/2021 4:05:59 PM SENT
Darla Pound dpound@munckwilson.com 5/10/2021 4:05:59 PM SENT
Kim James krj@sbaitilaw.com 5/10/2021 4:05:59 PM SENT
Samuel WallaceDunwoody wdunwoody@munckwilson.com 5/10/2021 4:05:59 PM SENT
Patricia Lucio plucio@munckwilson.com 5/10/2021 4:05:59 PM SENT
Jonathan E.Bridges jeb@sbaitilaw.com 5/10/2021 4:05:59 PM SENT
MAZIN SBAITI mas@sbaitilaw.com 5/10/2021 4:05:59 PM SENT
Charlotte Casso bcc@sbaitilaw.com 5/10/2021 4:05:59 PM SENT