Michael Steinhauer, Defendant in pro per
1641 Poinsettia #15
Los Angeles, CA 90046
Telephone (323) 850-5414
Temporary Fax (323) 874-8838

ABC ESCROW, INC., a California corporation; )
Alcohol Enterprises, Inc., a California corporation )
CASE NO.: BC312678
Defendant Michael Steinhauer's
Declaration in
Response to Order to
Show Cause
1, Michael Steinhauer, declare as follows;
Date: April 5
, 2004
Time: 8:30 A.M.
Dept.: 46
Hon. Rodney E. Nelson
1am 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
knowledge and, if called to testify as to these facts, I could and would testify
thereto. I am making no admission that I did anything wrong. I had no
, ,.
of interfering with or breaching any contracts. I was only informed ofthe entire

F:0pe ofthis matter at the time ofour last hearing (March 29, 2004).
.,- _I
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 5
, 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 ofthe provisions ofthe
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 ofthe employment agreement, I hereby request
that plaintiff's immediately provide me with an exhaustive list ofthose persons and/or
entities who they legitimately believe were their customers and clients as of March 5
2004 (the date ofmy 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 ofthe
ofthe employment agreement under which this action has been brought
" J'
me with the Superior Court, I am willing to enter into a settlement agreement
P:ased upon my and the plaintiffs' compliance with all ofthe forgoing,
'j:, _
Declaration in Response to Order to Show Cause

I declare under penalty of perjury under the laws ofthe State of California that the
foregoing is true and correct.
Signed and dated as oftoday, April I"', 2004, Hollywood, California.

Michael Stei auer
Page 3
Declaration in Response to Order to Show Cause


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
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
Executed on April ,1, 2004, at Los Angeles, CA.
tfWu/J)S) tUZL Michael Steinhauer