Case 2:12-cy-08333-ODW-JC (Dpcument 201 Filed 07/02/13 Page } of 5 Page ID #:3675
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John Steele 1111 Lincoln Road, Suite 400
os FILED Miami Beach, Florida 33139 CLERK, U.S. DISTRICT COURT
JUL - 2 2013
Pro Se
RAL PISTRICT OF CALIFORNIA PISTRICT OF CALIFORNK,
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
CASE NO. 2:12-CV-8333-ODW (JCx) INGENUITY 13 LLC,
Plaintiff, Judge: Hon, Otis D. Wright, IT
Magistrate Judge: Hon. Jacqueline Chooljian V.
JOHN DOE, MOTION FOR RECONSIDERATION OF THE COURT’S JUNE 21 ORDER IN Defendant. LIGHT OF PIETZ’S RECENT ADMISSIONS
On June 21, 2013, the undersigned filed a motion asking the Court to hold attorneys Pietz and Ranallo accountable for their failure to serve their papers in this case. The Court summarily denied the motion. Since then, attorney Pietz has made damaging admissions that may cause the Court to reconsider its position. Specifically, Pietz admitted in an e-mail that he has not served any of the pro se persons in this case with any papers. (See June 23, 2013, e-mail from Morgan Pietz, attached hereto as Exhibit A.) Further, on or around June 27, 2013, the undersigned finally received copies of all of the papers that have been filed by Pietz in this matter. (See Steele Aff.)
Now that there is no factual dispute regarding whether the pro se persons have been denied their Due Process right of notice and an Opportunity to be heard, the undersigned hopes that the Court will take appropriate measures to correct this massive injustice by reconsidering its prior denial of the June 21, 2013, motion and by taking any other actions it believes are appropriate under the circumstances. The Court swore an oath to defend the Constitution, and this includes ensuring that litigants are afforded their due process rights. The record clearly establishes that attorneys Pietz
MOTION FOR RECONSIDERATION CASE NO. 2:12-CV-8333-ODW (JCx)
Case 2:12-cv-08333-ODW-JC (Dpcument 201 Filed 07/02/13 Page ? of 5 Page ID #:3676
MOTION FOR RECONSIDERATION
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and Ranallo have fraudulently invoked the Court’s coercive power by filing requests for relief without notifying the undersigned and others. The undersigned hopes that the Court will carefully consider the profound implications of this fraud on the due process rights of the pro se persons and
reconsider its prior summary denial of the undersigned’s request for relief,
Respectfully submitted,
DATED: June 28, 2013
1111 Lincoln Réade Miami Beach, Florida 33139
Pro Se
CASE-NO, 2:12-CV-8333-ODW (JCx)}
Case 2:12-cv-08333-ODW-JC (Dpcument 201 Filed 07/02/13 Page $ of 5 Page ID #:3677
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UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
INGENUITY 13 LLC, CASE NO. 2:12-CV-8333-ODW (JCx)
Plaintiff, v. Judge: Hon. Otis D. Wright, II Magistrate Judge: Hon. Jacqueline Chooljian JOHN DOE, Defendant. CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED THAT: . I, the undersigned, am a citizen of the United States and am at least eighteen years of age.
My address is 1111 Lincoin Road, Suite 400, Miami Beach, FL 33139. I have caused service of:
MOTION FOR RECONSIDERATION OF THE COURT’S JUNE 21 ORDER IN LIGHT OF PIETZ’S RECENT ADMISSIONS
On the following parties via U.S. Mail first-class, postage prepaid:
COUNSEL OF RECORD/PRO SE
Klinedinst PC
501. West Broadway, Suite 600
San Diego, California 92101
Telephone: (619) 239-8131
Fax: (619) 238-8707
e-mail: hrosing@klinedinstlaw.com e-mail: dmajchrzak@klinedinstlaw.com
Prenda Law, Inc. 161 N.Clark St. Ste. 3200 Chicago, IL 60601
Ingenuity 13, LLC Springates East Government Road Charlestown, Nevis Livewire Holdings, LLC Pro Se 2100 M Street Northwest, Suite !70-417
Washington, D.C, 20037 6881 Forensics, LLC Springates East Government Road Charlestown, Nevis
MOTION FOR RECONSIDERATION
CASE NO. 2:12-CV-8333-ODW (JCx)
Case 2:12-cv-08333-ODW-JC (Dpcument 201 Filed 07/02/13 Page ¥ of 5 Page ID #:3678
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AF Holdings, LLC Pro Se Springates East Government Road Charlestown, Nevis Breit L, Gibbs Pro Se 38 Miller Avenue, #263 Mill Valley, CA94941 Mark Lutz Pro-Se 2100 M Street Northwest, Suite | 70-417 Washington, D.C. 20037
Paul Duffy. ProSe 2 N..La Salle St. St., 13th Floor Chicago, IL 60602
Paul Hansmeier
Alpha Law Firm, LLC 900 IDS Center
80 South 8" St. Minneapolis, MN 55402 Peter Hansmeier
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Pro Se
10 2100 M Street Northwest, Suite 170-417
fi] Washington, D.C. 20037 — _ Angela Van Den Hemel Pro Se 2 2100 M Street Northwest, Suite: 170-417
Washington, D.C. 20037 13 Non-Party Putative John Doe
Morgan Pietz (SBN 260629) The Pietz Law Firm 3770 Highland Ave., Ste. 206
Manhattan Beach, CA 90266 15 mpietz@pietzlawfirm.com Telephone: (310) 424-5557 16 Facsimile: (310)546-5301 17 18 I declare under penalty of perjury that the foregoing is true and correct. Executed on June 28, 19 2013. oe Signatu € 21 22 23 24 25 26 27 DR 4
MOTION FOR RECONSIDERATION | CASE NO; 2:12-CV-8333-ODW (JCx)
Case 2:12-cv-08333-ODW-JC /Dycument 201 Filed 07/02/13 Page 3 of 5 Page ID #:3679
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UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
CASE NO..2:12-CV-8333-ODW (JCx) INGENUITY 13 LLC,
5 Plaintiff, Judge: __- Hon. Otis D. Wright, I , Magistrate Judge: Hon. Jacqueline Chooljian Vv. 7 || JOHN DOE, 8 Defendant. 9 10 DECLARATION OF JOHN STEELE ‘LT Ul, John Steele; declare as follows: 12 3 1. Attached as Exhibit A: hereto is a true and correct. copy of an e-mail I received from Morgan E. Pietz on June 23, 2013. 14 2. On or around June 27, 2013, I received for the first time copies of documents that 15 have been filed in this matter. 16 a I declare under penalty of perjury that the foregoing is true and correct. Executed on June 28, L7 2013. 18 19 i 20 Signatury | 21 22 | 23 24 25 26 | 27 Ll 28 : a : CASE NO, 2:12-CV-8333-ODW (JCx) |