Notice of Motion to Strike SLAPP

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Hyde Mulvihill APC Lawyers
216 W. Foothill Blvd (91016) PO Box 1007
Monrovia CA 91017
(626) 358-7471 Fax: (626) 358-2894

Cynthia Coulter Mulvihill, Esq. SBN 171909
Sheral A. Hyde, Esq. SBN 131452
LAW OFFICES OF CYNTHIA COULTER MULVIHILL, APC
216 W. Foothill Boulevard (91016)
PO Box 1007, Monrovia CA 91017-1007
(626) 358-7471 Fax: (626) 358-2894
E-Mail: Cmulvihill@cmsynergy.com
Attorneys for Defendant THE REVEREND DR. FAHED ABU-AKEL

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ORANGE – UNLIMITED JURISDICTION

PAUL ROLF JENSEN,

Plaintiff,

vs.

FAHED ABU-AKEL,

Defendant

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CASE NO.: 03CC06949

THE REVEREND DR. FAHED ABU-AKEL’S NOTICE OF MOTION AND MOTION TO STRIKE SLAPP [STRATEGIC LITIGATION AGAINST PUBLIC PARTICIPATION] OF PAUL ROLF JENSEN, ESQ.

[DOCUMENTS FILED CONCURRENTLY HEREWITH DESCRIBED IN “INDEX OF DOCUMENTS FILED WITH THE COURT” ALSO FILED CONCURRENTLY HEREWITH]

DATE: May 28, 2003

TIME: 3:30 p.m.

LOC: C19

JUDGE: Randell L. Wilkinson

TO THE COURT AND TO PLAINTIFF, AN ATTORNEY APPEARING IN PRO-PER:

THE REVEREND DR. FAHED ABU AKEL (THE REV. ABU-AKEL) hereby moves to strike Plaintiff’s Complaint, in its entirety, on the basis that the lawsuit is Strategic Litigation Against Pubic Participation (SLAPP), brought by PAUL ROLF JENSEN, ESQ. primarily to chill the valid exercise of constitutional rights of THE REV. ABU-AKEL (California Code of Civil Procedure §425.16).

This Motion to Strike is based upon this Notice of Motion and Motion to Strike; the Memorandum of Points and Authorities submitted concurrently herewith; the Verified Complaint of PAUL ROLF JENSEN; the Declaration of THE REVEREND DR. FAHED ABU-AKEL submitted concurrently herewith; the Declaration of ERIC GRANINGER submitted concurrently herewith; the Declaration of CYNTHIA COULTER MULVIHILL submitted concurrently herewith; the Exhibits to the Reverend Dr. Fahed Abu-Akel’s Special Motion and Motion to Strike SLAPP; on such Opposition and Reply papers that may be filed with the Court; and upon such other evidence as the Court may consider at the time of Hearing.

Dated: July 16, 2003 The Law Offices of Cynthia Coulter Mulvihill, APC

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Cynthia Coulter Mulvihill
Attorneys for THE REVEREND DR. FAHED ABU-AKEL