(Source:  FACE Intel website)
 
 
KOUROSH KENNETH HAMIDI
7349 CROSS DRIVE
CITRUS HEIGHTS, CA 95610
In Propia Persona
 
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SACRAMENTO
 
INTEL CORPORATION,     Case No. 98AS05067
Plaintiff,
vs.    DECLARATION OF 
   KOUROSH KENNETH HAMIDI 
KOUROSH KENNETH HAMIDI and    IN OPPOSITION TO MOTION FOR
FACE - Intel, a purported California    PRELIMINARY INJUNCTION.
nonprofit organization,
Defendant,
   Opposition Due: November 12,1998
   Moving Party Reply:
   Hearing Date: November 17, 1998
   Trial Date: Not Set
I, Kourosh Kenneth Hamidi, declare as follows:

I . I am over 18 years old and I am the defendant In this case. The facts set forth in this declaration are personally known to me and I have first hand knowledge of the same. If called as a witness I could competently testify thereto.

2. 1 was hired in April of 1986.

3. In September 1990, 1 was injured in a car accident while returning from a business trip. At the time of the accident, I was a Senior Customer Quality and Reliability Engineer ('*CQE") in Intel's Automotive Group.

4. 1 was on a medical leave of absence from January 27, 1992 through the date of my termination on April 28, 1995.

5. On December 2, 1997 1 attended the deposition of Kirby Dyess, Vice President, and former Director of Human Resources, Intel Corporation. Attached is a true and correct copy of the of the deposition of Kirby Dyess taken on that day.   Exerpts from this deposition are attached as Exhibits A, B, and C.

6. Attached as Exhibit D is a true and correct copy of the FINDINGS AND AWARD from the WORKERS COMPENSATION APPEALS BOARD OF THE STATE OF CALIFORNIA that I received on April 3, 1996. Despite my efforts to bring this matter to a conclusion, I have received no payment from Intel on this award.

7. 1 formed AXE-INTEL, later renamed FACE-INTEL in concert with other employees, and ex-employees of Intel. The purpose of this organization was for the promotion of mutual benefit as it related to employment matters at Intel. In addtion, organization is devoted to helping other current Intel employees improve their working conditions, through the peaceful means of education, information and persuasion.

8. The policy of FACE-INTEL has been to use the Internet and e-mail as the medium by which we communicate to Intel employees scattered about the globe.

9. FACE-INTEI's e-mailings have been conducted for the purpose of pursuing valid labor interests of both FACE-INTEL members that are currently Intel employees, as well as the labor interests of other Intel employees throughout the globe.

I declare under penalty of perjury and the laws of the State of California that the foregoing is true and correct. Executed this day November 12, 1998 in Sacramento, California.
 
 

Dated:  November 12, 1998

(Signed by Kourosh Kenneth Hamidi)

KOUROSH KENNETH HAMIDI