Ebrahimi v. Fields et al

On February 8, 2023, Shamim Ebrahimic (“Plaintiff”), self-represented, filed a civil rights lawsuit against Michael R. Fields, Netflix, Inc., Electronic Arts, Inc., The Allstate Corporation, Pizza Hut, Domino's Pizza, Inc., Uber Technologies, Inc., and others (collectively, “Defendants”), seeking injunctive relief and damages for alleged violation of Texas Code. This case was filed in the U.S. District Court for the Northern District of Texas, with Judge Ed Kinkeade presiding.

In the complaint, the plaintiff alleged, “Plaintiff and almost every listed Defendant have no personal relationship. As a matter of fact, Plaintiff has exchanged more than a hundred words with less than a handful of the nearly quadruple digit number of Defendants and, even then, Plaintiff has not communicated with those few individuals in over six years.

The plaintiff then alleged, “Defendants—primarily through Azita Erfani and Michael R. Fields—have subjected Plaintiff to no less than 5,000 known actionable events, dating back to approximately the year 2000 or when Plaintiff was sixteen years old and continuing to present day.”

Plaintiff further alleged, “Those 5,000 actionable events do not include the over 330 simulated attorney-client cases, the over 5,000 phone calls and text message exchanged along with those simulated cases, the over 2,000 e-mails exchanged in association with those simulated cases, or the over 15,000 fraudulent government documents in association with those simulated cases—all of which occurred between 2014 and 2019.”

Plaintiff additionally alleged, “Those 5,000 actionable events also do not include the over 5,700 e-mail threads exchanged on the Harris County Criminal Lawyers Association (‘HCCLA’) listserve between September 2017 and July 2019 alone, approximately 1/3rd of which were composed and published with the intention of harassing Plaintiff and/ or dissuading him from reporting the commission of criminal offenses.”

The plaintiff also alleged, “Plaintiff has satisfied the legal definition of a disabled individual since November 25, 2014, having suffered a severe traumatic brain injury two days prior.”

The plaintiff then alleged, “No Defendant has had the legal authority to disrupt Plaintiff in the enjoyment of his protected legal rights. No Defendant has been legally justified in committing acts in violation of the law. Defendants’ acts influenced official proceedings, influenced the reporting of the commission of a federal offense to a federal officer of the law, and influenced government policy.”

Plaintiff further alleged, “Defendants materially breached their duties to Plaintiff, made material misrepresentations to Plaintiff with the intent that Plaintiff act thereupon to which he did, prevented Plaintiff from acquiring information likely to affect his judgment in matters, and failed to correct their false impressions knowing them not to be true.”

Plaintiff presented several claims for relief, including for the alleged violations of Tex. Code Jud. Conduct, Canons 1, 2A, 2B, 2C, 3A, 3B(1), 3B(2), 3B(3), 3B(5), 3B(6), 3B(7), 3B(8), 3B(9), 3B(11), 3C(1), 3C(2), 3C(3), 3C(4), 3D(1), 3D(2), 4A(1), 4A(2), 4C(1), 4D(1), 4D(4), 4I, 5(1)(ii), 5(4), 6, and 6H; Tex. Disciplinary R. Prof'l Conduct 8.03(a) and (b), 8.04(a)(1), 8.04(a)(3), 8.04(a)(2), 8.04(a)(4), 8.04(a)(9), 8.04(a)(5), 8.04(a)(6), 8.04(a)(12), 1.01(b), 3.01, 3.03, 3.04(b), 3.09, 4.01, 5.01, 5.08, 7.02, and 7.03; and Fed. Code of Conduct for United States Judges, Canons 1, 2, and 3.

In the prayer for relief, the plaintiff requested injunctive and declaratory relief along with an award of damages, including exemplary damages with pre- and post-judgment interest.  

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