Herten
Burstein
Herten Burstein
Sheridan Cevasco Bottinelli Litt & Hasz llc
Counsellors at
Law
Patrick
Papalia
Member of the
firm
Member of NJ, NY
& DC Bars
Writer's Direct
Dial: (201)498-8504
Writer's Email:
ppapalia@HertenBurstein.com
December 3,
2009
21 Main Street,
Surre 353
Court Plaza South
- West Wing
Hackensack, New
Jersey 07601-7095
Tel: (201)
342-6000
Fax: (201)
342-6611
747 Third
Avenue
37th
Floor
New York, New
York 100Î7
Tel: (212)
363-1380
www.HertenBurstein.com
Please reply
to Hackensack
Civil Case
Processing
Middlesex County
Courthouse
56 Paterson
Street
New Brunswick, New
Jersey 08903
Re: Apex
Technology Group, Inc. and Sarvesh Kumar Dharayan v. John Does,
et
Docket No.:
MID-L-7879-09
1248.91076
Dear Sir or
Madam:
This office
represents the Plaintiffs, Apex Technology Group, Inc. and Sarvesh
Kumar
Dharayan with
respect to the above-entitled matter. Enclosed for filing on behalf of the
Plaintiffs
is an original and
one (1) copy of an Order to Show Cause with Temporary Restraints; Brief
in
Support of Order
to Show Cause; Certification of Sarvesh Kumar Dharayan; Certification
of
Counsel; and
Certification of Service. Kindly file the enclosed documents and return a
"filed"
copy in the
self-addressed stamped envelope provided for your convenience. Kindly charge
our
Attorney
Collateral Account No. 140660 for fees associated with filing of same. Please
use our
reference number:
1248.91076
Should you have
any questions, please da not hesitate to contact my
office.
PP/dkm
Enclosures
Via Hand
Delivery
cc: Honorable
Diane Pincus, J.S.C.
admin(Siendhlb,com via
email
mmillere2006f£ivahoo.corn
via email
CERTIFICATION
OF SERVICE
On December 3,
2009 the original and one copy of plaintiffs notice of cross-motion
was
delivered to the
Clerk's Office, Civil Case Processing, Middlesex County Courthouse,
56
Paterson Street,
New Brunswick, New Jersey 08903, Via Hand Delivery; and
A courtesy copy
was Hand Delivered to:
Hon. Diane
Pincus, J.S.C.
Middlesex County
Courthouse
56 Paterson
Street
Chambers
405
New Brunswick,
New Jersey 08903
A copy of the
aforementioned motion was forwarded, Via Email to:
Adminia).endhlb.com
and
mmillere2006(5),vahoo.com
I certify that
the foregoing statements made by me are true. I am aware that if any of
the
foregoing
statements made by me are willfully false, I am subject to
punishment.
Dawn K. Morena,
Legal Secretary
HERTEN,
BURSTEIN, SHERIDAN,
CEVASCO,
BOTTINELLI
LITT &
HARZ, LLC
CERTIFICATION
OF SERVICE
On December 3,
2009 the original and one copy of plaintiff s notice of cross-motion
was
delivered to the
Clerk's Office, Civil Case Processing, Middlesex County Courthouse,
56
Paterson Street,
New Brunswick, New Jersey 08903, Via Hand Delivery; and
A courtesy copy
was Hand Delivered to:
Hon. Diane
Pincus, J.S.C.
Middlesex County
Courthouse
56 Paterson
Street
Chambers
405
New Brunswick,
New Jersey 08903
A copy of the
aforementioned motion was forwarded, Via Email to:
Adminfgjendhl
b.com
and
mmiUere2006(5),vahoo,com
I certify that
the foregoing statements made by me are true. I am aware that if any of
the
foregoing
statements made by me are willfully false, I am subject to
punishment.
Dawn K. Morena,
Legal Secretary
HERTEN,
BURSTEIN, SHERIDAN,
CEVASCO,
BOTTINELLI
LITT &
HARZ, LLC
Reference No.
2009.91076
Account No.
140660
HERTEN,
BURSTEIN, SHERIDAN, CEVASCO,
BOTTINELLI,
LITT & HARZ, L.L.C.
Counsellors at
Law
Court Plaza
South, West Wing
21 Main Street -
Suite 353
Hackensack, New
Jersey 07601
(201)
342-6000
Attorneys for
Plaintiffs
Apex Technology
Group, Inc. and Sarvesh Kumar Dharayan
APEX TECHNOLOGY
GROUP, INC., and
SARVESH KUMAR
DHARAYAN,
Plaintiffs,
JOHN DOE (S) 1-10
(being fictitious names
for persons not
yet identified), JOHN DOE
(S) 11-20 (being
fictitious names for persons
not yet
identified), ABC Corporation (s) 1-10
(being fictitious
names for legal entities not
yet
identified).
Defendants.
SUPERIOR COURT
OF NEW JERSEY
LAW DIVISION:
MIDDLESEX COUNTY
DOCKET NO.
MID-L-7879-09
CIVIL
ACTION
ORDER TO SHOW
CAUSE WITH
TEMPORARY
RESTRAINTS
THIS MATTER,
having been opened to the Court by Herten, Burstein, Sheridan,
Cevasco,
Bottinelli, Litt & Harz, L.L.C., attorneys for plaintiffs, Apex Technology
Group, Inc.
("Apex") and
Sarvesh Kumar Dharayan, (collectively "Plaintiffs") Patrick Papalia,
Esq.
appearing for the
entry of the Order to Show Cause, on notice to admini5iendhlb.com.
HIBScam
and
mmillere2006fgivahoo.com, and the Court, having considered the Verified
Complaint, Legal
Brief and
Certification annexed hereto, and having heard oral argument, if any, and for
good
cause
shown;
IT IS on this
day of December, 2009,
ORDERED, that
the third party posting under the username admin(giendhl b.com show
cause before the
Honorable Diane Pincus, J.S.C, of the Superior Court of New Jersey,
Law
Division,
Middlesex County, at the Court House, 56 Paterson Street, New Brunswick,
New
Jersey 08903 in
Room on the day of December, 2009 at 9:00 a.m. or as
soon
thereafter as
counsel may be heard, as to why and Order should not be entered granting
the
following relief,
including, but not limited to:
1. A preliminary
injunction enjoining the third party posting and corresponding
under the
usernames admin(5jendhl b.com, HIBScam, and
mmillere2006(5).vahoo.com
from posting any false, defamatory and/or negative
statements
related to Apex and/or its officers and directors;
2. A preliminary
injunction compelling the third party posting and corresponding
under the
usernames admin(g),endhlb.com. HIBscam, and
mmülere2006(g!vahoo.com
to produce to Plaintiffs any and all information in
that party's
possession which would assist in identifying any individual posting
any information
about Plaintiffs on www.endhlb.com including, but not limited
to IP addresses,
email addresses and/or names; and it is further
3. A preliminary
injunction enjoining the third party posting and corresponding
under the
usernames admin@,endhlb.com, HIBScam, and
mmillere2006fq).vahoo.com
from destroying the IP address and any other
identifying
information of the individuals posting on www.endhlb.com in their
possession, and
shall remove and/or delete any postings regarding Plaintiffs or
any of their
employees, officers or agents;
ORDERED that,
pending the return date of the Order to Show Cause, the third party
posting and
corresponding under the usernames admin(a),endhlb,com, HIBScam, and
mmiliere2006@,vahoo.com
shall not destroy the IP address and/or any other identifying
information of
the defendants in their possession, and shall remove and/or delete any
postings
regarding
Plaintiffs or any of their employees, officers or agents; and it is
further
ORDERED that,
pending the return date of this Order to Show Cause, the third
party
posting and
corresponding under the usernames admin(g),endhl b.com, HIBScam,
and
2
mmiUere2006@vahoo.com
shall not post any false, defamatory and/or negative statements
regarding Apex
and/or its officers and directors; and it is further
ORDERED that the
third party posting and corresponding under the usernames
admin@endhlb.com,
HIBScam, and mmillere2006@vahoo.com shall immediately produce to
Plaintiffs any
and all information in that party's possession which would assist in
identifying
any individual
posting any information about Plaintiffs on www.endhlb.com including, but
not
limited to IP
addresses, email addresses and/or names; and it is
further
ORDERED that
Plaintiffs be and hereby are required to email to the third party
posting
and corresponding
under the usernames admin@endhl b.com, HIBScam, and
mmillere2006@,vahoo,com
notice of this Order to Show cause, and that if anyone wishes to
respond to this
proceeding that they must do so in accordance with this Court's Order which
can
be obtained by
contacting the Middlesex County Superior Court; and it is
further
ORDERED that the
third party posting and corresponding under the usernames
admin@endhlb.com,
HIBScam, and rnmillere2006@vahoo.com shall file and serve any
answering
affidavits, certifications, briefs or motions returnable on the return date
hereof no
later than eight
(8) days before the return date, and any reply thereto shall be filed at least
four
(4) days prior to
the return date; and it is further
ORDERED that the
third party posting and corresponding under the usernames
admin@endhlb.com,
HIBScam and mmillere2006@vahoo.com may move to modify or
dissolve the
temporary restraints contained herein on not less than three (3) days'
notice.
J.S.C.
APEX TECHNOLOGY
GROUP, INC,
SARVESH KUMAR
DHARAYAN,
and
Plaintiff,
JOHN DOE(S) 1-10
(being fictitious names for
persons not yet
identified) JOHN DOE (S) 11-
20 (being
fictitious names for persons not yet
identified, ABC
Corporation(s) 1-10 (being
fictitious names
for legal entities not yet
identified,
Defendants.
SUPERIOR COURT
OF NEW JERSEY
MIDDLESEX
COUNTY: LAW DIVISION
DOCKET NO.
MID-L-7879-09
CIVIL
ACTION
BRIEF OF APEX
TECHNOLOGY GROUP, INC. AND SARVESH KUMAR
DHARAYANIN
SUPPORT OF THEIR APPLICATION FOR
AN ORDER TO
SHOW CAUSE
HERTEN,
BURSTEIN, SHERIDAN, CEVASCO,
BOTTINELLI, LITT
& HARZ, LLC
Attorneys for
Plaintiff
21 Main
Street
Hackensack, New
Jersey 07601
(201) 342-6000
Fax: (201) 342-6611
Of Counsel &
On the Brief:
Patrick Papalia,
Esq.
TABLE OF
CONTENTS
Page
STATEMENT OF
FACTS 1
ARGUMENT
5
L APEX TECHNOLOGY
GROUP, INC. IS ENTITLED TO A TEMPORARY
RESTRAINING
ORDER, PREVENTING THE THIRD PARTY POSING UNDER THE
USERNAME
ADMIN@ENDH1B.COM FROM POSTING ANY DEFAMATORY
STATEMENTS ON
ENDHIB.COM'S WEBSITE, AS WELL AS PROHIBITING
ADMIN@ENDH1B.COM
FROM DESTROYING ANY OF THE DEFAMATORY
INFORMATION FOR
THESE OR OTHER SIMILAR USERS, 5
II. APEX IS
ENTITLED TO THE DISCLOSURE OF THE IDENTITIES OF THESE
ANONYMOUS
POSTERS 8
CONCLUSION
11
STATEMENT OF
FACTS
Apex Technology
Group, Inc. ("Apex") is a New Jersey corporation engaged in the
business of
providing skilled computer consultants to its customers, or the end-clients of
its
customers for the
purposes of providing computer consulting services. Plaintiff Sarvesh
Kumar
Dharyan is a
principal of Apex. In the course of Apex' business they recruit highly
qualified
professionals
from overseas, and will work to secure HIB visa status for those individuals.
Apex
relies on its
reputation in the field and with the population of this and other countries such
as
India in order to
continue to recruit highly trained personnel in the competitive world
of
computer
consulting services.
Endhlb.com is a
website which promotes itself as a portal for information related to
the
HIB visa program.
Endhlb.com also offers message boards whereby individuals may
post
messages on a
variety of topics, or start a topic thread. On or about December 1, 2009
Apex
became aware of
several postings on endhlb.com from an anonymous person or persons
making
defamatory
statements against Apex, its agents, officers, and employees. See postings
from
endhlb.com
attached as Exhibit A to the Certification of Sarvesh Kumar Dharayan
("Dharayan
Cert."). These
individuals posted statements including:
Apex
Technology Group Ine is a H-1B slave trader.
" There are
several Indian companies operating from United States, like
the Apex
Technology Group Ine that you mentioned, employee
complaints range
from non-payment of salary which is illegal by the law
of the country
and using employee as a tool to pump jobs and illegaly
placing someone
else. There are resumes with unreal names and
imaginary
characters, these set of people attend job interviews and are
basically used
(I heard this as greivance) to get the other set of dumb
people jobs.
These people dont get paid and are considered to be "on-
bench" and are
given food and accomodation just as some refugees of a
war would be. Do
not get stuck with these companies like Apex
1
Technology Group
Inc. If you find that the company does not give you
salary / you are
attending interviews that are going no where/ you find
something fishy,
report to the Immigration / US Consulate or Authorities
Immediately.
Recession applies to all bodies and no just worker class and
labourers."
Fraud at Apex
Technology Group, Inc.
Apart from
above, employees don't receive their salary at the end of the
month. It is
usually received @ a random date in the following month,
provided you are
lucky. Else you would have to chase HR/Accounting to
get your pay
check. This process helps Apex technology group ine to
hold back pay
incase you choose to accept employment at another
location.
The most
important aspect of your transaction's with Apex Technology
Group Ine is
that they tell you one thing before you transfer your HIB to
their consulting
firm and then later do not stick to what they say(aka lies
& cheating).
In other words once you file/transfer your HIB to them you
more or less
become their slave and you will get entangled in thier web of
lies and legal
documents.
Sarvesh and his
wife Chhavi run the company, they are very
unprofessional
and treat employees with no respect. They will speak with
employees as if
they are doing a favor on them. They do not have any
direct client's
and their marketing folks in Noida would chase posting's
on job websites
to set you up for interviews.
Also some past
history about this company:
Apex Technology
Group Ine, was started by Alok Kumar Dharayan. At
some point Alok
inducted his brother Sarvesh who eventually took over
and Alok moved
out due to some differences but both the brother's play
along so that
they don't get into trouble.
During the time
when Alok was the President of the company, he filed
several
I-485/Labor's which he was able to transfer to HIB employees
for filing their
green cards. Those employees spread the word by mouth
and Apex grew in
numbers.However those days are now over and any
intention's/incentives
of green card will not come to fruition or will come
at a cost of
several years of servitude. So please be aware and do not be
deluded.
Apex Technology
Group Ine was able to quell their x/-employee's
voices on
www.goolti.com by using legal threat's. You can find more
info at the
following location
http://www.goolti.com/reviewdetail.php7companv
id=l 95 .Also I
thought you
would be interested in knowing that they were the biggest
spammer's on
www.goolti.com. where they initially tried to cover up
their deeds You
can find more info at the following location
http://goolti.blogspot.com/2008/07/this-months-biggest-spammers.html
Apex has,
individually and through counsel, contacted the endhl .com website in a
good
faith attempt to
have such false and defamatory statements removed. Apex received
responses
from a person or
persons on behalf of the website, alternately using screen names
admin(S),endh 1
b.com and mmiilere2006@,vahoo,com, A full recitation of the
correspondence
between
Plaintiffs and www.endhlb.com is set forth in the Dharayan Cert., and in Exhibit
B to
that
Certification. As of the date of this filing, www.endhlb.com has not only failed
and refused
to remove the
false and defamatory posts, but has launched a campaign of harassing
and
combative
communications to both Plaintiffs and Plaintiffs' counsel which that individual
which
contain false and
defamatory statements regarding Plaintiffs and Plaintiffs' counsel, and
levels
baseless threats
against both Plaintiffs and Plaintiffs' counsel. See Exhibit B to Dharayan
Cert,
and Exhibit A to
Certification of Patrick Papalia, Esq. ("Papalia Cert."). Apex complies with
all
Federal
Immigration and labor and employment laws. To Apex knowledge, they are not
under
any
investigation, State, Federal or otherwise, nor is any individual employee or
their
immigration
status under investigation. All of the allegations by these posters are false,
and
therefore
defamatory and actionable at law.
The world of
computer consulting is both high paced and competitive. Each agency
strives to secure
the most qualified individuals to become part of their team. The recruitment
of
these individuals
is based almost entirely upon the reputation of the company within the field
and
community.
Additionally, it is its reputation in the field, along with skilled individuals
recruited
by Apex that
allows Apex to maintain and attract new customers. These defamatory,
harassing,
and untrue
postings made by these unscrupulous individuals, which postings are being
allowed to
remain public by
www.endhlb.com, have caused irreparable damage to Apex' reputation in
the
field and to
Apex' ability to recruit. The failure of endhlb.com to immediately remove
these
blatantly
defamatory statements has caused irreparable injury to Apex. Over the course of
the
past ten (10)
days, Apex has had three (3) consultants refuse to report for employment with
Apex
as a direct
result of the foregoing, and has been advised that several of its current
employees are
aware of the
false and defamatory information contained on www.endhlb.com and
communicated by
the individual or individuals posting and communicating under the
usernames
admin@,endhlb,com
and mmiUere2006(q),vahoo,com, The failure of endhlb.com to disclose
the
identity of the
poster or posters and the individual or individuals posting and
communicating
under the
usernames admin@endhlb.com and mmiHere2006(q),vahoo,com has delayed
Apex
ability to seek
the appropriate legal remedies.
ARGUMENT
I. APEX IS
ENTITLED TO A TEMPORARY RESTRAINING
ORDER
COMPELLING PRODUCTION OF THE IDENTITY OF
THE THIRD
PARTY POSTING AND COMMUNICATING UNDER
USERNAMES
ADMIN@ENDH1B.COM AND
MMILLERE2006@YAHOO.COM:
PREVENTING THE THIRD
PARTY POSTING
AND COMMUNICATING UNDER
USERNAMES
ADMIN@ENDH1B.COM AND
MMILLERE2006(SYAHOO.COM
FROM POSTING ANY
FURTHER
DEFAMATORY STATEMENTS ON ENDHIB.COM'S
WEBSITE;
PROHIBITING ENDH1B.COM FROM DESTROYING
ANY OF
IDENTIFYING INFORMATION FOR THESE OR
OTHER SIMILAR
USERS; COMPELLING THE DISCLOSURE
OF ANY
IDENTIFYING INFORMATION FOR THE INDIVIDUAL
OR
INDIVIDUALS POSTING ABOUT PLAINTIFFS ON
ENDH1B.COM
In determining
whether to issue temporary restraints the Court must consider: (1)
such
relief should not
issue except when necessary to prevent irreparable harm; (2) the legal
right
underlying
plaintiffs' claim is settled; (3) there is a reasonable probability of ultimate
success on
the merits of its
underlying claim; and (4) the respective hardships to the parties favor
the
granting of
injunctive relief. Crowe v. DeGioia, 90 N.J. 126 (1982); see also
Citizen Coach Co.
v. Camden
Horse RR Co., 29 N.J.Eq. 299 (1878). In the matter at hand, it is clear that
Apex
continues to be
irreparably harmed by the actions of an individual or individuals
alternatively
utilizing the
usernames admin@,endhlb.com and mmillere2006@,vahoo.com, as well as
the
individual or
individuals www.endhlb.com is permitting to post on its site, through the use
of
public message
boards on www.endhlb.com. There is no question that these statements
which
have been posted
on the website are defamatory in nature, as a defamatory statement is
defined
as one which is
false and (1) injuries another person's reputation; (2) subjects the person
to
hatred, contempt
or ridicule; or (3) causes others to lose goodwill or competence in that
person.
Romine v.
Kallìnger, 102 N.J. 282, 289 (1988). Defamatory statements harm the
reputation of
another in a way
that lowers the estimation of a community about the person or deters
third-
person from
associating or dealing with him. McLaughlin v. Rosanio, Ailets and Talamo,
Inc.,
331 N.J.Super.
303, 312 (App. Div. 2000). Additionally New Jersey Courts have ruled
that
when the words
themselves are so defamatory on their face that they damage an
individual's
reputation face,
a matter is actionable per se. Printing Mart-Morristown v. Sharp
Electronics
Corp.,
116 N.J. 739, 765 (1989). Apex is aware that in the past ten (10) days
alone, three (3)
consultants have
refused to report to work for Apex and abandoned their employment with
Apex
as a direct
result of the false and defamatory statements at issue. Apex management is
also
aware of growing
concern about Apex status among its current employees, which concern
has
been triggered
by the statements at issue. Apex business is centered entirely on its ability
to
provide
qualified consultants to its customers. Apex continuing loss of consultants as a
result of
these statements
constitutes clear irreparable harm.
As noted above,
the standard regarding defamation is clear, and these statements
are
defamatory on
their face, giving Apex at very least a reasonable likelihood of success on
the
merits. Finally,
www.endhlb.com stands to suffer no harm from removal of the false
and
defamatory
postings or disclosure of the identity of the individual or individuals posting
on the
website and/or
posting and corresponding using the usernames admin@,endhl b.com
and
mmillere2006(5),vahoo.eom.
On the contrary, Apex is has and continues to suffer damage based
on the
statements at issue.
Based on the
foregoing, there is no question that Apex is entitled to injunctive relief
as
they have
suffered and continue to suffer irreparable injury in the form of lost
employees; that
the legal
standard regarding defamation is well-settled; that Apex has a reasonable
likelihood of
success on the
merits; and that the balance of the equities weighs in favor of
Apex.
II. VISION
IS ENTITLED TO THE DISCLOSURE OF THE
IDENTITIES
OF THESE ANONYMOUS POSTERS.
Under Federal
and State law individuals are granted protections for speech.
U.S.
Constitution
First Amendment; N.J.S.A Const. Art. I, Para. 6. However, Courts
have
acknowledged
that in the age of internet technology and the advancement of the world wide
web
as a source for
a new form for the people, individuals deserve a right to be protected
from
defamatory and
damaging statements which are baseless. The Courts have held that although
the
conditions of
anonymity have been generally protected, at times, upon appropriate
application,
an internet site
will be required to release all identifying information regarding its
members,
users or posters
if necessary to protect others from damaging speech. Dendrite
International,
Inc. v. John
Doe, No. 3, 342 N.J.Super. 134, 141 (App. Div. 2001). New Jersey has
further
recognized that
"[although anonymous speech on the Internet is protected, there must be
an
avenue for
redress for those who are wronged. Individuals choosing to harm another or
violate
an agreement
through speech on the Internet cannot hope to shield their identity and
avoid
punishment
through invocation of the First Amendment." Immunomedics, Inc. v. Doe,
342 N.J.
Super. 160, 167
(App. Div. 2001). In the instant matter, an individual or individuals
have
anonymously made
false, defamatory and baseless claims regarding Plaintiffs which have
caused
and continue to
cause damage to Plaintiffs.
The Court in
Dendrite, supra, set forth a four part test regarding the application of
a party
for the
identification of anonymous posters and users of an internet website. The four
parts are:
(1) plaintiff
should undertake efforts to notify the anonymous posters that they are subject
of a
subpoena or
application for an order of disclosure; (2) the Court shall also require the
plaintiff to
identify and set
forth the exact statements purportedly made by each anonymous poster that
the
plaintiff
alleges constitutes actionable speech; (3) plaintiff must demonstrate that its
action can
withstand a
motion to dismiss for failure to state a claim; and (4) plaintiff must
produce
sufficient
evidence supporting each element of its cause of action, on a prima facie
basis, prior to
the Court
ordering the disclosure of the identity of an unnamed defendant. Id. If
the plaintiff
satisfies the
test, the Court will balance the defendant's First Amendment Right of
anonymous
speech against
the strength of'the prima facie case presented.
Id.
In the case at
bar, Apex meets the required standards set forth in Dendrite and
is
therefore
entitled to disclosure of the identity of both the individual alternatively
using the
username
admin@.endh 1 b.com and mmillere2006(q).vahoo.com; as well as the
anonymous
individuals who
have posted negative and defamatory comments against the Plaintiffs and
their,
directors and/or
employees. As per the relief requested in this Order to Show Cause plaintiff
has
already
forwarded this filing to the individual alternatively using the
username
adminfgiendhlb.com
and mmiilere2006(a)/yahoo.com, and will notice the anonymous users
subject to the
subpoena being issued, that this application has been filed and set forth for
the
return date.
Additionally, per the Certification of Suresh Kumar Dharayan, and
attached
exhibits,
plaintiffs have sufficiently set forth all of the defamatory statements which
have been
made by the
defendant John Does. Furthermore, the Plaintiffs set forth the standard
for
defamation and
defamation per se, and clearly demonstrated that they meet the standard
and
pursue and
prima facie case against the individual or individuals posting on
www.endhlb.com.
as well as the
individual or individuals posting and corresponding using the
usernames
admin@.endhlb.com and
mmillere2006(a),yahoo.com. As evidenced by the statements which
were listed in
the Dharayan Certification, and attached as Exhibit A to said Certification,
these
Statements made
by the anonymous posters clearly meet the standard of defamation as they
are
false, and are
damaging to Apex' reputation within the community and their field.
Additionally
as demonstrated
by Plaintiffs, these statements have subject Plaintiffs to the loss of employees
in
an industry
centered on recruiting and retaining qualified employees, and therefore have
directly
damaged
Plaintiffs through the loss of contracts as well as the loss of qualified
individuals who
are current or
prospective employees of a company. Individuals are not protected when
they
make knowingly
false and defamatory statements which cause damage to other individuals
or
entities. In the
case sub judice, Plaintiffs clearly demonstrated that they are and
continue to be
damaged by the
defamatory postings of the anonymous individual or individuals posting
on
www.endhlb.com,
as well as the postings and correspondence by the individual or
individuals
under the
usernames admin(£iendh 1 b.com and mmillere2006@,vahoo.com and that they
are
entitled to the
relief requested.
10
CONCLUSION
For the
foregoing reasons Plaintiffs respectfully requests that the Court grant their
Order
to Show Cause in
its entirety.
Dated: December
2, 2009
<ELLI,
LITT & HARZ, L.L.C
s fori
Plaintiffs
HERTENj
BURSTEIN, SHERIDAN, CEVASCO,
BOTTII«
Attorneys
By:.
..-Patrick
Papalia
11
Reference No.
2009.91076
Account No.
140660
HERTEN,
BURSTEIN, SHERIDAN, CEVASCO,
BOTTINELLI,
LITT & HARZ, L.L.C.
Counsellors at
Law
Court Plaza
South, West Wing
21 Main Street -
Suite 353
Hackensack, New
Jersey 07601
(201)
342-6000
Attorneys for
Plaintiffs
Apex Technology
Group, Inc. and Sarvesh Kumar Dharayan
APEX TECHNOLOGY
GROUP, INC., and
SARVESH KUMAR
DHARAYAN,
Plaintiffs,
JOHN DOE (S)
1-10 (being fictitious names
for persons not
yet identified), JOHN DOE
(S) 11-20 (being
fictitious names for persons
not yet
identified), ABC Corporation (s) 1-10
(being
fictitious names for legal entities not
yet
identified).
Defendants.
SUPERIOR COURT
OF NEW JERSEY
LAW DIVISION:
MIDDLESEX COUNTY
DOCKET NO.
MID-L-7879-09
CIVIL
ACTION
CERTIFICATION OF
SARVESH
KUMAR
DHARAYAN
Suresh Kumar
Dharayan, of full age, hereby certifies as follows:
1. I, Suresh
Kumar Dharayan, am the President of Apex Technology Group, Inc.
("Apex"), the
plaintiff in the above-entitled action, and am an individual plaintiff in this
matter.
I am the duly
authorized agent for the plaintiff for purposes of making this Certification. I
am
fully familiar
with the facts set forth herein. I make this Certification in support of
Plaintiffs'
Order to Show
Cause.
2. On or about
November 30, 2009 Apex became aware that an anonymous person
or individuals
were posting untrue, defamatory, harassing and damaging statements about
Apex,
its officers and
agents on www.endhl b.com. and were communicating such statements
under
usernames
adminfgiendhlb.com and mmülere2006(S¡yahoo.com,
3. Plaintiffs
contacted endhlb.com directly and informed its administration of
these
defamatory and
untrue statements, thereby making it aware that these statements are
causing
damage to Apex'
reputation and business. A true and accurate copy of the
correspondence
between
Plaintiffs and an individual alternately using the usernames admin(a),endhlb,eom
and
mmillere2006@vahoo.com
is attached to this Certification as Exhibit B.
4. Endhlb.com
has failed to work with Plaintiffs in removing the defamatory
postings, and
preventing any additional defamatory postings. Endhlb.com has also refused
to
provide
Plaintiffs with the identity or whatever identifying information it may have
regarding the
identity of the
posters.
5. By way of
example, the individual known as "pjainatapextgi" made a post
entitled
"Fraud @ Apex
Technology Group Inc.," wherein that individual falsely and for the sole
purpose
of defaming
Apex, stated:
Apart from
above, employees don't receive their salary at the end of the
month. It is
usually received @ a random date in the following month,
provided you
are lucky. Else you would have to chase HR/Accounting to
get your pay
check. This process helps Apex technology group ine to
hold back pay
incase you choose to accept employment at another
location.
The most
important aspect of your transaction's with Apex Technology
Group Ine is
that they tell you one thing before you transfer your HIB to
their
consulting firm and then later do not stick to what they savfaka
lies
&
cheating). In other words once you file/transfer your HIB to them
you
more or less
become their slave and you will get entangled in thier web of
lies and legal
documents.
Sarvesh and his
wife Chhavi run the company, they are very
unprofessional
and treat employees with no respect. They will speak with
employees as if
they are doing a favor on them. They do not have any
direct client's
and their marketing folks in Noida would chase posting's
on job websites
to set you up for interviews.
Also some past
history about this company:
Apex Technology
Group Ine, was started by Alok Kumar Dharayan. At
some point Alok
inducted his brother Sarvesh who eventually took over
2
and Alok moved
out due to some differences but both the brother's play
along so that
they don't get into trouble.
During the time
when Alok was the President of the company, he filed
several
I-485/Labor's which he was able to transfer to HIB employees
for filing
their green cards. Those employees spread the word by mouth
and Apex grew
in numbers.However those days are now over and any
intention's/incentives
of green card will not come to fruition or will come
at a cost of
several years of servitude. So please be aware and do not be
deluded.
Apex Technology
Group Ine was able to quell their x/-employee's
voices on
www.goolti.com by using legal threat's. You can find more
info at the
following location
http://www.goolti.com/reviewdetail.php7companv
id=l95 .Also I
thought you
would be interested in knowing that they were the biggest
spammer's on
www.goolti.com. where they initially tried to cover up
their deeds You
can find more info at the following location
http://goolti.blogspot.com/20Q8/07/this-months-biggest-spammers.html
(Emphasis
added.)
6. Another
individual, under username "HIB Scam," which is believed to be
the
same person,
posted a headline stating "Apex Technology Group Ine is a H-1B slave
trader,"
with the
following false and defamatory comments:
" There are
several Indian companies operating from United States, like
the Apex
Technology Group Ine that you mentioned, employee
complaints
range from non-payment of salary which is illegal by the law
of the country
and using employee as a tool to pump jobs and illegaly
placing someone
else. There are resumes with unreal names and
imaginary
characters, these set of people attend job interviews and are
basically used
(I heard this as greivance) to get the other set of dumb
people jobs.
These people dont get paid and are considered to be "on-
bench" and are
given food and accomodation just as some refugees of a
war would be.
Do not get stuck with these companies like Apex
Technology
Group Inc. If you find that the company does not give you
salary / you
are attending interviews that are going no where/ you find
something
fishy, report to the Immigration / US Consulate or Authorities
Immediately.
Recession applies to all bodies and no just worker class and
labourers."
(Emphasis
added.)
7. That same
individual posted another comment titled "More Apex Technology
Group Frauds
Exposed." which stated:
"Read ur
postings, fst of all let me make it cler to u all that Apex
Technology
Group Inc. and Apex Technology Systems, Inc. r not d same
one. As posted
by Krishna, Apex Technology Systems, Inc. may be a gud
co but Apex
Technology Group Inc., pis 4 god sake don't even dream of
joining them.
This company is run by a big cheat Sarvesh and one of his
CHAMCHA, Alok.
One of my friends applied 4 Hlb thru them last yr.
these cheats
charged him a huge amount and lured him by giving all sort
of temptations.
He was told that they have their own projects and own
development
center. But he realized the truth after paying them when
they didn't
send his docs for appearing before the consulate for interview.
He had to chase
them like mad for getting his docs. They don't entertain
ur mails if u
seek any info. They don't reply
to ur calls.
They always try to hold u responsible for every mistake even
committed by
them. Especially the so called president of the company,
Sarvesh. Their
system is not transparent at all. They don't send u the docs
to appear for
the consulate interview in time. If at all they send, it will be
incomplete and
supported by fake project report. They do it intentionally
because when u
appear for d interview with these type of docs, u r caught
at the
consulate and ur visa is rejected and this so called president and
his
CHAMCHA blame
you by saying that you were not prepared well and
could not
perform before the consulate. So now they are not responsible
if ur visa gets
rejected and they wud not refund ur money
too. Actually
this is their modus operandi for making money. So pis. for
god sake don't
waste ur or ur parents hard earned money by giving it to
these cunning
people. They r not trust worthy at all - believe me. "
In an effort to
have these false, defamatory and damaging posts removed from the
website, Apex,
contacted endhlb.com through an email address provided on the site for
contact
purposes. That
email address is admin(a),endhl b.com. The full text of that initial contact is
as
follows:
Dear Sir or
Madam;
On 11/23/2009
Apex Technology Group, Inc. came to an attention about
your website
www.endhlb.com
<http://click.icptrack.com/icp/relav.php?r=15468897&msgid=152212&a
ct=RFFI&c=546921&admin=0&destination=http%3A%2F%2Fwww.end
hlb.com%2F>
which provided artificial and untruthful statement to the
public which
can't even confirmed by this specific indiduals who claim
himself as Mr.
Pankaj Jain and is defaming Apex Technology Group
reputation in
many other websites which are currently cooperating with
our Attorney. I
would like to bring this to you attention that our Attorney
has went
forward with legal proceedings against this culprit. As per you
if owner is not
responsible for the information posted on this website has
full right to
remove the article requested by Apex TGI.
I am
disappointed because your services didn't check the authenticity of
the person who
posted our legal document which has defamed our Apex
Technology
Group's image and could lead to heavy losses to the revenue
which has
reputation and been in the business since 2001. To further
minimizing the
damage to Apex Technology Group's reputation I purpose
you remove the
article linked to your website. I further request you to
provide us the
contact details of the individual who posted this legal
agreement
without permission since we are the copyright owner of the
legal document.
We request that you investigate the substance of our
complaint, and
provide us with the contact details of the individual in
fault, pursuant
to Section 512(f) of the DMCA, any person who
knowingly
materially misrepresents that material or activity is infringing
may be subject
to liability, as suggested in your website, if these
allegation are
found valid. Please respond to us in writing.
To resolve the
problem I would appreciate and require you to take the
action to
remove the link attached below:
http://endhlb.eom/Webfologs/endhlb/archive/2009/l
1/19/indentured-
servitude-is-part-of-the-business-model.aspx
<http://click.icptrack.com/icp/relav.php?r=15468897&msgid=152212&a
ct=RFFI&c=546921&admin=0&destination=http%3A%2F%2Fendhlb.c
om%2FWeb%2Fblogs%2Fendhlb%2Farchive%2F2009%2Fl
1 %2F19%
2Findentured-servitude-is-part-of-the-business-model.aspx>
I look forward
to hearing from you and to a resolution of this problem. I
will wait till
12/04/2009 before arranging for the matter to be removed
from your
website by a third party (Company's Attorney) at your cost or
seeking help
from Consumer Protection Agency. Please feel free to reach
me for any
further inquiries at the contact information below.
8. In response
we received an email from admin(g),endhlb,com which stated,
in
pertinent
part:
We at
www.endhlb.com received this email from what appears to be an
Indian bodyshop
in New Jersey. They want us to take down a post from
Desicruch, and
"provide contact details of the individual who posted this
legal
agreement." We have not posted a legal agreement and don't have
the contact
details of anyone of our contributors. We will also protect the
privacy of any
members of our community.
This is clearly
an attempt to apply Indian legal standards to American
citizens. We
will not be intimidated and are ready to defend our 1st
Amendment
Rights. If you would like to contribute to this cause, please
make a donation
that well help us defer our legal costs.
9.
Notwithstanding the combative nature and plainly incorrect and
defamatory
statements
ofthat email, we again attempted to resolve this matter by requesting assistance
from
the website.
Plaintiffs response email stated:
Dear Sir or
Madam;
Our email was
not to threat your organization instead a request to
cooperate with
us to guide us through a process in which we could reach
out to the
individual who has been harassing and defaming our
companies
reputation by posting wrong information on the other
websites. Our
company has been in good standing from the day 1 it
started. Again
I would really appreciate if you could come out with a
feedback on
this issue. Looking forward to hear from you.
10. That
individual, under username admin@,endh 1 b.com sent further
correspondence
to Plaintiffs
again refusing to remove any of the false postings.
11. The same
individual who was corresponding with Plaintiffs under username
admin(5),endhlb,com
then continued corresponding with Plaintiffs using the email
address
mmillere2006(q).vahoo.com.
In that correspondence, the individual forwarded an email titled
"Re: Apex of New
Jersey Engaging in Extortion," to askconsumeraffairsfSJps.state.nj.us,
an
email address
apparently affiliated with the State of New Jersey, Department of
Consumer
Affairs. A true
and accurate copy ofthat email is attached to this Certification as Exhibit
A.
12. The full
text of the postings and this correspondence is attached to this
Certification as
Exhibits A and B, respectively.
13. In
response, we received another refusal to cooperate which contained threats of
a
baseless
referral to the USCIS. At that time, we referred this matter to our legal
representation,
14. The
aforementioned: postings must be stopped immediately since they are
irreparably
damaging the company. These postings allege unlawful activity against my
company
and 1, which
allegations are false, baseless and malicious.
15. As an
example, three employment candidates scheduled to begin work for
Apex
have declined to
take up employment with Apex in the last ten (10) days, citing these
postings
and emails as
their reason. Additionally, current Apex employees have approached
management
and advised that
they are concerned about I) whether the statements- contained herein
are
truthful; and 2)
what effect this will have on the company moving forward. These postings
are
causing severe
damage to the company and must cease or the business of Apex will
be
destroyed.,
I certify that
the foregoing statements made by me are true, I am aware that if any of
the
foregoing
statements made by me are willfully false, I am subject to
punishment.
Sarvesh Kumar
Dharayan
©ated: December
2,2009
CERTIFICATION OF
FACSIMILE SIGNATURE
Pursuant to R.
l:4-4(c) of the Rules Governing the Courts of the State of New Jersey,
I
do hereby
certify that the affiant has acknowledged the genuineness of the signature
attached to
the
certification. I will provide the Court with a copy of this Certification and an
original
signature
affixed thereto if I am requested to do so by the Court or a party to this
action.
HERTEN,
BURSTEIN, SHERIDAN,
CEVAácO,
BOTTINELLI, LITT & HARZ
Attorneys for
Plaintiff
—Eatrick
Papalia
Dated: December
2, 2009
Page 1
of3
Patrick
Ascoiese
From:
millere2006 millere2006 [mmillere2006@yahoo.com]
Sent:
Monday, November 30, 2009 6:03 PM
To:
Shawn.Gibson@apextgi.com
Subject:
ALIPAC Exposes Truth About Apex
Follow Up
Flag: Follow up
Flag Status:
Flagged
http://www.alipac.us/ftopicp-987113.html#987113
Oversight of the
H-1B labor program is so lax that Indian companies are adding illegal riders to
work
contracts that
force payment from workers that are against the law:
http://www.desicrunch.com/DisplavReviews.aspx?company=Apex_Technologv_Systems._Inc.
Not so good
things About Apex Technology Systems, Inc. :
Title:-
Fraud,cheating,lies and legal agreement @ Apex Technology Group Ine
www.apextgi.com
This information
is being mailed to you as a reply to your post regarding fraud @ Apex
Technology
Group Ine
(http://www.apextgi.com/). Please find the employment agreement
letter
http://www.docstoc.com/docs/10702214/agreement.
which I received after I started working for Apex at
a client
location. None of the terms were part of the initial agreement between me and
Apex Technology
Group Inc. I
would like to take this opportunity to highlight several aspect's of the 9 page
legal
agreement which
might be important for you. For example: 30 day termination notice or forget
your last
paycheck when
you quit, If you join a company (including any level between you and Apex) then
pay
$35000 or face a
law suit, $9000 for legahtraining and guest services when you quit. $35000 if
you quit
in between a
contract...etc. The legalities of the agreement are convoluted,complex and
can/will be used
against you if
you displease Apex technology Group Inc. So once you sign that document you are
at the
mercy of the
employer and much worse than a bonded labour in India. Apart from above,
employees
don"t receive
their salary at the end of the month. It is usually received @ a random date in
the
following month,
provided you are lucky. Else you would have to chase HR/Accounting to get your
pay
check. This
process helps Apex technology group ine to hold back pay incase you choose to
accept
employment at
another location. The most important aspect of your transaction"s with Apex
Technology
Group Ine is
that they tell you one thing before you transfer your HIB to their consulting
firm and then
later do not
stick to what they say(aka lies & cheating). In other words once you
file/transfer your HIB
to them you more
or less become their slave and you will get entangled in thier web of lies and
legal
documents. They
run the company, they are very unprofessional and treat employees
w
[Another website
ran the above letter and got this response from an American legal representative
of
Apex who wrote
in mysteriously bad English.]
htto://endhlb.conVWeb^logs/endhlb/archive/2009/ll/30/threaterling-email-from-indian-bodyshop.aspx
12/2/2009
Page 2
of3
We at
www.endhlb.com received this email from what appears to be an Indian bodyshop in
New Jersey.
They want us to
take down a post from Desicrach about the experiences a quest worker had with
the
bodyshop, and
"provide contact details of the individual who posted this legal agreement." We
have not
posted a legal
agreement and don't have the contact details of anyone of our contributors. We
will also
protect the
privacy of any members of our community.
This is clearly
an attempt to apply Indian legal standards to American citizens. We will not
be
intimidated and
are ready to defend our 1st Amendment Rights. If you would like to contribute to
this
cause, please
make a donation that well help us defer our legal
costs.
Dear Sir or
Madam;
On 11/23/2009
Apex Technology Group, Inc. came to an attention about your website
www.endhlb.com
which provided artificial and untruthful statement to the public which can't
even
confirmed by
this specific indiduals who claim himself as Mr. Pankaj Jain and is defaming
Apex
Technology Group
reputation in many other websites which are currently cooperating with
our
Attorney. I
would like to bring this to you attention that our Attorney has went forward
with legal
proceedings
against this culprit. As per you if owner is not responsible for the information
posted on this
website has full
right to remove the article requested by Apex TGI.
I am
disappointed because your services didn't check the authenticity of the person
who posted our legal
document which
has defamed our Apex Technology Group's image and could lead to heavy losses to
the
revenue which
has reputation and been in the business since 2001. To further minimizing the
damage to
Apex Technology
Group's reputation I purpose you remove the article linked to your website. I
further
request you to
provide us the contact details of the individual who posted this legal agreement
without
permission since
we are the copyright owner of the legal document. We request that you
investigate the
substance of our
complaint, and provide us with the contact details of the individual in fault,
pursuant to
Section 512(f)
of the DMCA, any person who knowingly materially misrepresents that material
or
activity is
infringing may be subject to liability, as suggested in your website, if these
allegation are
found valid.
Please respond to us in writing.
To resolve the
problem I would appreciate and require you to take the action to remove the link
attached
below:
http://endhlb.comAyeb/blogs/endhlb/archive/2009/ll/19/mdentured-servitude-is-part-of-the-business-
model.aspx
I look forward
to hearing from you and to a resolution of this problem. I will wait till
12/04/2009 before
arranging for
the matter to be removed from your website by a third party (Company's Attorney)
at your
cost or seeking
help from Consumer Protection Agency. Please feel free to reach me for any
further
inquiries at the
contact information below.
Thanks and
Regards
Shawn
Gibson
HR/Legal
Department
12/2/2009
Page 1
of4
Patrick
Ascolese
From:
millere2006 millere2006 [mmillere2006@yahoo.com]
Sent:
Monday, November 30, 2009 6:37 PM
To:
Shawn.Gibson@apextgi.com
Cc:
askconsumeraffairs@lps.state.nj.us
Subject:
New Jersey Division of Consumer Affairs to hear complaint against
Apex
Follow Up
Flag: Follow up
Flag Status:
Flagged
Re: Apex of New
Jersey Engaging in Extortion
Monday, November
30, 2009 6:17 PM
From:
"AskConsumerAffairs
AskConsumerAffairs" <AskConsumerAffairs@dca.lps.state.nj
.us>
Add sender to
Contacts
To:
"millere2006
millere2006" <mmillere2006@yahoo.com>
Dear
Consumer,
Thank you for
your e-mail to the New .Jersey Division of Consumer Affairs. This is an
initial
automated
response to your inquiry so please do not respond. Your question will be
forwarded to the
appropriate unit
here at the Division.
Information
about how to file a complaint with the Office of Consumer Protection can be
found at:
http://www.state.nj.us/lps/ca/comp.htm
If you want to
fill out our complaint form on line, please go to:
http://www.state.nj.us/lps/ca/ocp/ocpform.htm
Once your
complaint has been received, it will be subjected to
review.
Please call
either 1-800-242-5846 or {?73)504-6200 if you would like to speak with a
Consumer Service
Center
representative.
Licensee Search
is available at:
http://www.state.nj.us/cgi-bin/consumeraffairs/search/searchentry.pl
Tips regarding
Home Improvements can be found at:
http://www.state.nj.us/lps/ca/brief/improve.pdf
If you would
like to be added to the Division's e-mailing list to receive electronically
distributed
consumer news
and updates, please fill out the form at:
http://www.state.nj.us/lps/ca/mailing/mailist.htm
Thank
You
>»
millere2006 mi11ere2006 <mmillere2006(g).yahoo.com> 11/30/09 18:12
>»
12/2/2009
Page 2
of4
Apex of New
Jersey Engaging in Extortion
askconsumeraffairs(S),lps.state.nj.us
Shawn.Gibson(a>,apextgi.com
Oversight of the
H-1B labor program is so lax that Indian companies are adding illegal riders to
work
contracts that
force payment from workers that are against the law:
http://www.desicrunch.com/DisplavReviews.aspx?company=Apex_Technology_Systems,_Inc.
Not so good
things About Apex Technology Systems, Inc. :
Title:-
Fraud,cheating,lies and legal.agreement @ Apex Technology Group Ine
www.apextgi.com
This information
is being mailed to you as a reply to your post regarding fraud @ Apex
Technology
Group Ine
(bJ^//www^pextgixom/). Please find the employment agreement letter
http://www.docstoc.com/docs/10702214/agreement.
which I received after I started working for Apex at
a client
location. None of the terms were part of the initial agreement between me and
Apex Technology
Group Inc. I
would like to take this opportunity to highlight several aspect's of the 9 page
legal
agreement which
might be important for you. For example: 30 day termination notice or forget
your last
paycheck when
you quit, If you join a company (including any level between you and Apex) then
pay
$35000 or face a
law suit, $9000 for legal,training and guest services when you quit. $35000 if
you quit
in between a
contract...etc. The legalities of the agreement are convoluted,complex and
can/will be used
against you if
you displease Apex technology Group Inc. So once you
sign
that document
you are at the mercy of the employer and much worse than a bonded labour in
India.
Apart from
above, employees don"t receive their salary at the end of the month. It is
usually received @
a random date in
the following month, provided you are lucky. Else you would have to
chase
HR/Accounting to
get your pay check. This process helps Apex technology group ine to hold back
pay
incase you
choose to accept employment at another location. The most important aspect of
your
transaction"s
with Apex Technology Group Ine is that they tell you one thing before you
transfer your
HIB to their
consulting firm and then later do not stick to what they say(aka lies &
cheating). In other
words once you
file/transfer your HIB to them you more or less become their slave and you will
get
entangled in
thier web of lies and legal documents. They run the company, they are very
unprofessional
and treat
employees w
[Another website
ran the above letter and got this response from an American legal representative
of
Apex who wrote
in mysteriously bad English.]
http://endli1b.com/WebMogs/endlilb/arcMve/2009/ll/30/threatening-email-from-indian-bodvshop.aspx
We at
www.endhlb.com received this email from what appears to be an Indian bodyshop in
New Jersey.
They want us to
take down a post from Desicruch about the experiences a quest worker had with
the
bodyshop, and
"provide contact details of the individual who posted this legal agreement." We
have not
posted a legal
agreement and don't have the contact details of anyone of our contributors. We
will also
protect the
privacy of any members of our community.
12/2/2009
Page 3
of4
This is clearly
an attempt to apply Indian legal standards to American citizens. We will not
be
intimidated and
are ready to defend our 1st Amendment Rights. If you would like to contribute to
this
cause, please
make a donation that well help us defer our legal
costs.
Dear Sir or
Madam;
On 11/23/2009
Apex Technology Group, Inc. came to an attention about your website
www.endhlb.com
which provided artificial and untruthful statement to the public which can't
even
confirmed by
this specific indiduals who claim himself as Mr. Pankaj Jain and is defaming
Apex
Technology Group
reputation in many other websites which are currently cooperating with
our
Attorney. I
would like to bring this to you attention that our Attorney has went forward
with legal
proceedings
against this culprit As per you if owner is not responsible for the information
posted on this
website has full
right to remove the article requested by Apex TGI.
I am
disappointed because your services didn't check the authenticity of the person
who posted our legal
document which
has defamed our Apex Technology Group's image and could lead to heavy losses to
the
revenue which
has reputation and been in the business since 2001. To further minimizing the
damage to
Apex Technology
Group's reputation I purpose you remove the article linked to your website. I
further
request you to
provide us the contact details of the individual who posted this legal agreement
without
permission since
we are the copyright owner of the legal document. We request that you
investigate the
substance of our
complaint, and provide us with the contact details of the individual in fault,
pursuant to
Section 512(f)
of the DMCA, any person who knowingly materially misrepresents that material
or
activity is
infringing may be subject to liability, as suggested in your website, if these
allegation are
found valid.
Please respond to us in
writing.
To resolve the
problem I would appreciate and require you to take the action to remove the link
attached
below:
http://endhlb.com/WebMogs/endhlb/archive/2009/ll/19/indentured-servitude-is-part-of-the-business-
model.aspx
I look forward
to hearing from you and to a resolution of this problem. I will wait till
12/04/2009 before
arranging for
the matter to be removed from your website by a third party (Company's Attorney)
at your
cost or seeking
help from Consumer Protection Agency. Please feel free to reach me for any
further
inquiries at the
contact information below.
Thanks and
Regards
Shawn
Gibson
HR/Legal
Department
Apex Technology
Group Inc.
LPtaaejrJRoaAJSmtefjÇ
Edison, NJ
08817
12/2/2009
endhlb.com
Newsletter
Page 1
of2
Patrick
Ascolese
From:
admin endhlb [admin@endh1b.com]
Sent:
Monday, November 30, 2009 7:06 PM
To:
Shawn.Gibson@apextgi.com
Subject:
Threatening Email From Indian Bodyshop
Follow Up
Flag: Follow up
Flag Status:
Flagged
Sign in |
Join
"mwwi®n
EndH1b.com
Newsletter v 11.0 - Nov 30th, 2009
Threatening
Email From Indian Bodyshop
We at www.endhl
b.com received this email from what appears to be an Indian bodyshop in
New
Jersey. They
want us to take down a post from Desicruch, and "provide contact details of
the
individual who
posted this legal agreement." We have not posted a legal agreement and don't
have
the contact
details of anyone of our contributors. We will also protect the privacy of any
members of
our
community.
This is clearly
an attempt to apply Indian iegal standards to American citizens. We wil! not
be
intimidated and
are ready to defend our 1 st Amendment Rights, if you would like to contribute
to
this cause,
please make a donation that well help us defer our legal
costs.
Dear Sir or
Madam;
On
11/23/2009 Apex Technology Group, Inc. came to an attention about your
website
www, endh 1
b. com which provided artificial and untruthful statement to the public which
can't even
confinned by
this specific indiduals who claim himself as Mr. Pankaj Jain and is defaming
Apex
Technology
Group reputation in many other websites which are currently cooperating with
our
Attorney. I
would like to bring this to you attention that our Attorney has went forward
with legal
proceedings
against this culprit As per you if owner is not responsible for the infonnation
posted
on this
websäe has full right to remove the article requested by Apex
TGI.
I am
disappointed because your services didn't check the authenticity of the person
who posted
our legal
document which has defamed our Apex Technology Group's image and could lead
to
heavy losses
to the revenue which has reputation and been in the business since 2001.
To
further
minimizing the damage to Apex Technology Group's reputation I purpose you remove
the
article
linked to your website. I further request you to provide us the contact details
of the
individual
who posted this legal agreement without pemiission since we are the copyright
owner
of the legal
document. We request that you investigate the substance of our complaint,
and
provide us
with the contact details of the individual in fault, pursuant to Section
512(f) of the
DMCA,
any person who knowingly materially misrepresents that material or activity
is infringing
may be
subject to liability, as suggested in your website, if these allegation are
found valid.
Please
respond to us in writing.
To resolve
the problem I would appreciate and require you to take the action to remove the
link
attached
below:
12/2/2009
endhlb.com
Newsletter Page 2 of 2
http://endh1b.comA4/eb/bloas/endh1b/aœhive/2009/11/19/indentured-ser/itude-is-part-of-the-
business-model,
aspx
I look
forward to hearing from you and to a resolution of this problem. I will wait
till 12/04/2009
before
arranging for the matter to be removed from your website by a third party
(Company's
Attorney) at
your cost or seeking help from Consumer Protection Agency. Please feel free
to
reach me for
any further inquiries at the contact infonnation
below.
Emaü Marketina
bv
This message was
sent from admin endhlb to Shawn.Gibson@apextgi.com. It was sent from: ^
_.
admin endhlb,
P.O. Box 887 , Beverly Hills, CA 90210. You can modify/update your subscription
' /COHtclCt
via the link
beiow.
&T ». „ ■-,
„ Ö FORWARD TO A. FRIEND
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12/2/2009
endhlb.com
Newsletter Page 1 of 3
Patrick
Ascolese
From:
admin@endh1b.com
Sent:
Monday, November 30, 2009 9:19 PM
To: 'Shawn
Gibson'
Subject:
RE: Threatening Email From Indian Bodyshop
Follow Up
Flag: Follow up
Flag Status:
Flagged
Ms.
Gibson,
i doubt that
your name is Shawn Gibson. You sound like an Indian who is trying to intimidate
American citizens
exercising their
First Amendment rights. We are not in the business of helping exploitative Desi
bodyshops
target their
H-1B victims for harassment, retribution, or violence.
Since you are
not a U.S. citizen, you have no standing and your empty threats will be ignored.
We have already
contacted the
USCIS to investigate your firm. And this newsletter goes out to thousands of
executives in the I.T.
industry and
hundreds of media contacts. Be prepared to answer some questions from the feds
and the press.
BTW, one of the
members of our organization ¡s Business Week writer Steve Hamm and he has
received this
newsletter. You
may be familiar with him — he wrote this cover story:
America's
High-Tech Sweatshops
U.S. companies
may be contributing unwittingly to the exploitation of workers imported from
ìndia and
elsewhere by
tech-services outfits
http://www.businessweek.com/magazine/content/09_41/b4150034732629.htm
Regards,
Admin
www.endhlb.com
From:
Shawn Gibson [mailto:shawn.gibson@apextgi.com]
Sent:
Monday, November 30, 2009 4:21 PM
To: 'admin
endhlb'
Subject:
RE: Threatening Email From Indian Bodyshop
Dear Sir or
Madam;
Our email was
not to threat your organization instead a request to cooperate with us to guide
us through a process
in which we
could reach out to the individual who has been harassing and defaming our
companies reputation by
posting wrong
information on the other websites. Our company has been in good standing from
the day 1 it
started. Again I
would really appreciate if you could come out with a feedback on this issue.
Looking forward to
hear from
you.
Thanks and
Regards
Shawn
Gibson
HR/Legal
Department
12/2/2009
endhl b.com
Newsletter Page 2 of 3
Apex Technology
Group Inc.
2 Kilmer Road.,
Suite# C
Edison, NJ
08817
Tel: (732)
572-1800
Direct: (732)
964-1300
Fax: (732)
572-7900
Website:
www.apextgi.com
Email:
Shawn,Gibson@,apextgi.com
S^ Please
consider the environment before printing this email.
"Winner of
2007 NJBIA Awards for Excellence in the Job Creation
Category".
"Winner of
2008 & 2007 NJBIZ New Jersey's Finest Award" honoring SO Fastest Growing
Companies in NJ".
We respect your
Online Privacy. This is not an unsolicited mail. Under Bills. 1618 Title III
passed by
the 105th U.S.
Congress this mail cannot be considered Spam as long as we include Contact
Information
and a method to
be removed from our mailing list. If you are not interested in receiving our
emails then
please reply
with a "REMOVE" in the subject line and mention all the email addresses to be
removed
with any email
addresses.
From:
admin endhlb [mailto:admirKaendhlb.com]
Sent:
Monday, November 30, 2009 7:06 PM
To:
Shawn.Gibson@apextgi.com
Subject:
Threatening Email From Indian Bodyshop
Sjgn in I
Join
EndH1b.com
Newsletter v 11.0 - Nov 30th, 2009
Threatening
Email From Indian Bodyshop
We at www.endhl
b.com received this email from what appears to be an Indian bodyshop in
New
Jersey. They
want us to take down a post from Desicruch, and "provide contact details of
the
individual who
posted this legal agreement." We have not posted a legal agreement and don't
have
the contact
details of anyone of our contributors. We will also protect the privacy of any
members of
our
community.
This is clearly
an attempt to apply Indian ¡egal standards to American citizens. We will not
be
intimidated and
are ready to defend our 1 st Amendment Rights. If you would like to contribute
to
this cause,
please make a donation that well help us defer our legal
costs.
Dear Sir or
Madam;
On
11/23/2009 Apex Technology Group, Inc. came to an attention about your
website
www,endhlb.com
which provided arííñcial and untmthful statement to the public which can't
even
confirmed by
this specific indiduals who claim himself as Mr. Pankaj Jain and is defaming
Apex
Technology
Group reputation in many other websites which are currently cooperating with
our
Attorney. I
would like to bring this to you attention that our Attorney has went forward
with legal
proceedings
against this culprit. As per you if owner is not responsible for the information
posted on
this website
has full right to remove the article requested by Apex
TGI.
12/2/2009
endhlb.com
Newsletter Page 3 of 3
/ am
disappointed because your services didn't check the authenticity of the person
who posted our
legal
document which has defamed our Apex Technology Group's image and could lead to
heavy
losses to
the revenue which has reputation and been in the business since 2001. To further
minimizing
the damage
to Apex Technology Group's reputation I purpose you remove the article linked to
your
website. I
further request you to provide us the contact details of the individual who
posted this legal
agreement
without permission since we are the copyright owner of the legal document. We
request
that you
investigate the substance of our complaint, and provide us with the contact
details of the
individual
in fault, pursuant to Section 512(f) of the DMCA, any person who
knowingly materially
misrepresents
that material or activity is infringing may be subject to liability, as
suggested in your
website, if
these allegation are found valid. Please respond to us in
writing.
To resolve
the problem I would appreciate and require you to take the action to remove the
link
attached
below:
http://endh1b.comAA/eb/blOQs/endh1b/archive/2009/11/19/indentured-sen/itude-is-part-of-'the-business~
model.aspx
I look
forward to hearing from you and to a resolution of this problem. I will wait
till 12/04/2009 before
arranging
for the matter to be removed from your website by a third party (Company's
Attorney) at your
cost or
seeking help from Consumer Protection Agency. Please feel free to reach me for
any further
inquiries at
the contact information below.
Email Marketing
by
This message was
sent from admin endhlb to Shawn.Gibson@apextgI.com. It was sent from: admin
(r _
endhlb, P.O. Box
887 , Beverly Hills, CA 90210. You can modify/update your subscription via the
link /COfìtaCt
below.
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23:31:00
12/2/2009
Fraud at Apex
Technology Group Ine - EndHlB.com Blog - End Hl-B Page 1 of
2
Fraud at Apex
Technology Group Ine
Fraud@ Apex
Technology Group ine
October 30, 2009
by pjainatapextgi
This information
is being mailed to you as a reply to your post regarding fraud @ Apex Technology
Group Ine (
(www.apextqi.com
) visit http://ripoffatapextqi.bloqspot.com/
Please find the
employment agreement letter http://www.docstoc.com/docs/10702214/aqreement ,
which I re
client location.
None of the terms were part of the initial agreement between me and Apex
Technology Group II
I would like to
take this oppurtunity to highlight several aspect's of the 9 page legal
agreement which might be i
termination
notice or forget your last paycheck when you quit, If you join a company
(including any level betwei
law suit, $9000
for legal.training and guest services when you quit. $35000 if you quit in
between a contract...e
The legalities
of the agreement are convoluted.abstract and can/will be used against you if you
displease Apex
document you are
at the mercy of the employer and much worse than a bonded labour in
india.
Apart from
above, employees don't receive their salary at the end of the month. It is
usually received @ a rand
are lucky. Else
you would have to chase HR/Accounting to get your pay check. This process helps
Apex technt
choose to accept
employment at another location.
The most
important aspect of your transaction's with Apex Technology Group Ine is that
they tell you one thing
consulting firm
and then later do not stick to what they say(aka lies & cheating). In other
words once you file/tre
become their
slave and you will get entangled in thier web of lies and legal
documents.
Sarvesh and his
wife Chhavi run the company, they are very unprofessional and treat employees
with no respe
are doing a
favor on them. They do not have any direct client's and their marketing folks in
Noida would chase
interviews.
Also some past
history about this company:
Apex Technology
Group Ine, was started by Alok Kumar Dharayan. At some point Alok inducted his
brother Sa
moved out due to
some differences but both the brother's play along so that they don't get into
trouble.
During the time
when Alok was the President of the company, he filed several l-485/Labor's which
he was able
green cards.
Those employees spread the word by mouth and Apex grew in numbers.However those
days are
green card will
not come to fruition or will come at a cost of several years of servitude. So
please be aware anc
Apex Technology
Group Ine was able to quell their x/-employee's voices on www.goolti.com by
using legal t
following
location http://www.qoolti.com/reviewdetail.php7companv id=195 .Also I thought
you would be inte
spammer's on
www.qoolti.com , where they initially tried to cover up their deeds You can find
more info at th«
http://qoolti.bloqspot.com/2008/07/this-months-biqqest-spammers.html
http://endhlb.com/Web^ogs/endhlb/archive/2009/12/01/fraud-at-apex-technology-group...
12/2/2009
Fraud at Apex
Technology Group Ine - EndHlB.com Blog - End Hl-B
Page 2
of2
I would like to
take this opportunity and ask other fellow victims who are current or were past
employees to rep
available @
http://www.dol.gov/esa/whd/forms/fts wh4.htm
Also you need
mail the documents to
Pat
Reilly
District
Director
Southern New
Jersey District Office
US Dept. of
Labor
ESA Wage &
Hour Division
3131 Princeton
Pike, Bldg. 5, Rm. 216 Lawrenceville, NJ 08648
or you can call
them ©Phone: (609) 538-8310, 1 -866-4-USWAGE,
(1-866-487-9243)
Remember one
thing, any inconsistencies with your pay can only be solved by the department of
labour, if the
from the time it
has been commited.
http://ripoffatapextqi.wordpress.com/
http://www.complaintsblog.com/Company/apex-technology-group-inc-www-apextgi-com.html
Posted 1 Dec
2009 8:45 PM by WBScam
Filed under:
h1b, fraud, apex technology group ine
More
Community
server
EXPRESS
EDITION
5ftemeter.*ill<
5,426
llttp://endlllb.comAVeb^logs/endhlb/archive/2009/12/01/fraud-at-apex-tecnnology-g^oup...
12/2/2009
Apex Technology
Group Ine is a H-IB slave trader. - EndHlB.com Blog - End
Hl-B
Page 1 of
1
Apex
Technology Group Ine is a H-1B slave trader.
" There are
several Indian companies operating from United States, like the Apex Technology
Group Ine that y<
from non-payment
of salary which is illegal by the law of the country and using employee as a
tool to pump job
are resumes with
unreal names and imaginary characters, these set of people attend job interviews
and are ba
the other set of
dumb people jobs. These people dont get paid and are considered to be "on-bench"
and are gì
refugees of a
war would be. Do not get stuck with these companies like Apex Technology Group
Inc. If you fine
you are
attending interviews that are going no where/ you find something fishy, report
to the Immigration / US C
Recession
applies to all bodies and no just worker class and
labourers."
http://qoolti.bloqspot.com/2008/07/this-months-biqqest-spammers.html
Posted 1 Dec
2009 5:24 AM by HIBScam
Filed under: Mb,
slave, apex technology group ine
More
POWERED
BY
Community
server
'
EXPRESS
EDITION
sitemeteMÜli
5,426
http://endhlb.comAVebMogs/endhlb/archive/2009/12/01/apex-technology-group-inc-is-a-...
12/2/2009
Threatening
Email From Indian Bodyshop - EndHlB.com Blog - End HI -B Page 1 of
5
Threatening
Email From Indian Bodyshop
We at
www.endh1b.com received this email from what appears to be an Indian bodyshop in
New Jersey. The)
about the
experiences a quest worker had with the bodyshop, and "provide contact details
of the individual wh(
posted a legal
agreement and don't have the contact details of anyone of our contributors. We
will also prated
community.
This is clearly
an attempt to apply Indian legal standards to American citizens. We will not be
intimidated and í
Rights. If you
would like to contribute to this cause, please make a donation that well help us
defer our legal cc
Dear Sir or
Madam;
On 11/23/2009
Apex Technology Group, Inc. came to an attention about your website
www.endh1b.com
statement to
the public which can't even confirmed by this specific indiduals who claim
himself as Mr. Pan
Group
reputation in many other websites which are currently cooperating with our
Attorney. I would like to
has went
forward with legal proceedings against this culprit. As per you if owner is not
responsible for the
right to
remove the article requested by Apex TGI.
I am
disappointed because your services didn 't check the authenticity of the person
who posted our legal
Technology
Group's image and could lead to heavy losses to the revenue which has reputation
and been
minimizing
the damage to Apex Technology Group's reputation I purpose you remove the
article linked to
us the
contact details of the individual who posted this legal agreement without
permission since we are tl
request that
you investigate the substance of our complaint, and provide us with the contact
details of the
of the
DMCA, any person who knowingly materially misrepresents that material or
activity is infringing ma
website, if
these allegation are found valid. Please respond to us in
writing.
To resolve
the problem I would appreciate and require you to take the action to remove the
link attached I
http://endh1b.comAVeb/bloos/endh1b/archive/2009/11/19/indentured-servitude-is-part-of-the-business-mc
1 look
forward to hearing from you and to. a resolution of this problem. I will wait
till 12/04/2009 before arra,
website by a
third party (Company's Attorney) at your cost or seeking help from Consumer
Protection Age
further
inquiries at the contact information below.
Thanks and
Regards
Shawn
Gibson
HR/Legal
Department
Apex
Technology Group Inc.
2 Kilmer
Road., Suite* C
http://enalilb.comAVeb^logs/endhlb/arcMve/2009/ll/30/1lireatenmg-email-from-indian-b...
12/2/2009
More Apex
Technology Group Frauds Exposed - EndHlB.com Blog - End
Hl-B
Page 1 of
1
More Apex
Technology Group Frauds Exposed
"Read ur
postings, fst of all let me make it cier to u all that Apex Technology Group
Inc. and Apex Technology !
Inc. r not d
same one. As posted by Krishna, Apex Technology Systems, Inc. may be a gud co
but Apex Techn
Inc., pis 4 god
sake don't even dream of joining them. This company is run by a big cheat
Sarvesh and one of I
CHAMCHA, Alok.
One of my friends applied 4 H1 b thru them last yr. these cheats charged him a
huge amount
by giving all
sort of temptations. He was told that they have their own projects and own
development center. Bi
realized the
truth after paying them when they didn't send his docs for appearing before the
consulate for inter*
He had to chase
them like mad for getting his docs. They don't entertain ur mails if u seek any
info. They don't
to ur calls.
They always try to hold u responsible for every mistake even committed by them.
Especially the so i
president of the
company, Sarvesh. Their system is not transparent at all. They don't send u the
docs to appea
consulate
interview in time. If at all they send, it will be incomplete and supported by
fake project report. They c
intentionally
because when u appear for d interview with these type of docs, u r caught at the
consulate and ur
rejected and
this so called president and his CHAMCHA blame you by saying that you were not
prepared well ;
perform before
the consulate. So now they are not responsible if ur visa gets rejected and they
wud not refund
too. Actually
this is their modus operandi for making money. So pis. for god sake don't waste
ur or ur parents h
earned money by
giving it to these cunning people. They r not trust worthy at all - believe me.
"
http://web.archiYe.org/web/20080801032709/www.goolti.com/reviewdetail.php?company
Posted 2 Dec
2009 9:28 PM by HIBScam
Filed under:
jilb, fraud, slave, apex technology group ine
|
More
h POWERED
f
¡(immunity
¡server
*
'EXPRESS
EDITIÜM
sitemrtet.il.ilit
5,615
http://enalilb.coni/Web/blogs/endhlb/archive/2009/12/02/more-apex-technology-group-&...
12/3/2009
The Latest
Harassment From Apex Tech - EndHlB.com Blog - End Hl-B Page 1 of
5
The Latest
Harassment From Apex Tech
The last we
heard, Apex's lawyer Patrick Papalla was sending emails to our organization,
talking about "false, I
demanding the
name of our lawyer and law firm:
Dear
Sir/Madam:
Please provide
me with the name of your lawyer and law firm. This is a serious
matter
defamatory
statements you have made as to Apex will not go unaddressed. Any further
ur
will further
expose you to punitive damages for your intentional and malicious
conduct
Patrick Papalia,
Esq.
We don't want to
waste our money on legal counsel over what is clearly an attempt to intimidate
and silence us
with our lawyer.
We spoke with our attorney yesterday, and he assures that these threats are
bogus.
Thanks to all
who made contributions to our cause. We are now prepared to make contact with
Apex's clients
they are dealing
with. This was our last response to Mr. Papalia:
Mr.
Papalia,
Sorry, we are
not some exploited visa workers that take your threats seriously. Our
organization knows tf
H-1B workers who
Apex has sponsored and abused by sending them phony legal threats. And I have
evi
India of visa
workers who dare to expose the labor violations and visa fraud committed by
Apex.
You are
complicate in human trafficking and have now encountered an adversary that is
more than happy
practices of
bodyshops like Apex and predatory law firms like yours.
Be prepared to
account for your actions and the actions of your client in the court of public
opinion. We hi
Programmer's
Guild, WashTech, the Communications Workers Of America, Numbers USA, Bright
Future
Together we are
talking about tens of thousands of IT. workers that can donate funds and
resources to te
You and I both
know that there are no "unlawful and disparaging publications" and your case has
no meril
comment from
another website.
But it is useful
for our cause - to expose the high-tech slave trade that you profit from and the
bullying tac
displace
millions of American tech workers. And we have more information from other
victims of Apex, ar
As for your
client, you should counsel them not to pick a fight with well-funded groups who
are not afraid c
www.endhl b.com.
And because of that, our organization is preparing to share this entire dialogue
with al
begin our
protest, it is highly unlikely these companies will want to do business with a
firm engaged in sue
#AIG
Insurance
http://encUilb.comAVeb/blogs/endhlb/archive/2009/12/03/the-latest-harassment-&om-apex...
12/3/2009
The Latest
Harassment From Apex Tech - EndHlB.com Blog - End Hl-B Page 2 of
5
#
Ajilon
# All State
Insurance
# Alliance
Consulting
# Ameriprise
Financial
#Avon
#AT&T
# AXA Financial,
Inc.
# Bank of
America
# Bank of New
York
# Barclays
Capital
# Blue Cross
Blue Shield
# BMW North
America
# Brown Brothers
Harriman
#
Bunge
# Capital
One
# Cingular
Wireless
# Cognizant
Technology Solutions
#
Comcast
# Commerce
Bank
#
Comsys
#
CooperVision
# Country Wide
Insurance
# Credit
Suisse
# Doreen Evans
Associates
# Dow
Jones
# Eliassen
Group
http://enQlilb.comAVeb/blogs/endhlb/archive/2009/12/03/the-latest-harassment-&om-apex...
12/3/2009
The Latest
Harassment From Apex Tech - EndHlB.com Blog - End Hl-B Page 3 of
5
(feme
#ETS
# Fannie
Mae
# Fairleigh
Dickinson University
# Fidelity
Investments
# Goldman
Sachs
#
Heinz
# Helios &
Matheson
#IBM
# JP Morgan
Chase
# Kforce
Technology Staffing
#
KPMG
# Loews
Corporation
# McGraw
Hill
#
Medco
#
Mercer
#
Merck
# Merrill
Lynch
#
MetLife
# Miami Dade
County
# Microsoft
Corportation
# Modis
IT
# Moody's
Investors Service
# National
Basketball Association
# National City
Corporation
# Nationwide
Insurance
http://endhlb.comAVeb/blogs/endhlb/archive/2009/12/03/the-latest-harassment-fxom-apex...
12/3/2009
The Latest
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# New York Stock
Exchange
# Optical
Research Associates
# Pfizer,
Ine
# Price
Waterhouse Coopers
# Sapphire
Technologies
#
Scanbuy
# Schering
Plough
# Siemens Health
Services
# State
Street
# Sun
Microsystems
# Sun Trust
Bank
# Tek
Systems
# The
Hartford
# Thompson
Reuters
#UBS
#UNFCU
# United
Healthcare
# Verizon
Wireless
# Wells
Fargo
#WillkieFarr&
Gallagher
Regards,
Admin
www.endh1b.com
Posted 3 Dec
2009 2:48 PM by EndHIBAdmin
Filed under:
apex technology group ine
http://endhlbxom/Web/blogs/endhlb/archive/2009/12/03/the-latest-harassment-from-apex...
12/3/2009