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12-cv-08333-ODW-JC Document 209 Filed 07/10/13 Page1of4 Page ID #:3778

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John Steele 1111 Lincoln Road, Suite 400 Miami Beach, Florida 33139

JUL 1.0 2018

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Pro Se

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

CASE NO. 2:12-CV-8333-ODW (JCx) INGENUITY 13 LLC, ao |

_ Plaintiff, Judge: Hon. Otis D. Wright, II Magistrate Judge: Hon. Jacqueline Chooljian V.

JOHN DOE, MOTION TO APPEAR VIA TELEPHONE Defendant.

On July 2, 2013, the Court issued a notice (ECF No. 200) scheduling a hearing for July 12, 2013, on'the undersigned’s motion for reconsideration. The undersigned resides in Florida and just received notice on July 8, 2013 via U.S. Mail. The undersigned has a previously scheduled family matter that prohibits his in-person attendance at the July 12, 2013, hearing. Further, nine days’ notice—over the Fourth of July holiday weekend, in particular—is a prohibitively narrow window of time for to receive notice of a hearing via U.S. Mail, and schedule travel arrangements to appear cross-country. Finally, attending a hearing in California is an extremely expensive proposition as it requires plane fare, a hotel room and other incidental expenses.

In light of these circumstances, the undersigned attempted to arrange for a telephonic appearance, but was informed by the Court’s clerk that he would have to file a motion if he wished to participate in the hearing telephonically. The undersigned has very important interests that are implicated by his motion for reconsideration. Of singular importance is that the upcoming hearing

on the motion for reconsideration will be the undersigned’s first opportunity he will have ever had to

MOTION TO APPEAR VIA TELEPHONE CASE NO. 2:12-CV-8333-ODW (JCx)

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12-cv-08333-ODW-JC Document 209 Filed 07/10/13 Page 2of4 Page ID #:3779

respond to pleadings filed by Attorney Ranallo and Attorney Pietz that were never served upon the undersigned, and resulted in ex-parte orders clearly detrimental to him. The undersigned is not aware of any harm that would be caused by his appearance by telephone instead of in-person. Further, the undersigned is concerned that many of the pro se persons—all of whom reside far outside of California—would have first received the Court’s mailed scheduling notice today (at the earliest) and will similarly be unable to travel to California on such short notice. Further, several of the pro se persons in this matter are of limited income and cannot afford the extreme financial

hardship associated with missing work and flying across country on 3 days notice. As an aside, it

appears that the scheduling order may not yet have even been mailed to several of the pro se persons. For these reasons, the undersigned respectfully requests that the Court allow him (and other pro se persons, if they so request) to appear telephonically. If the Court denies this request, there is a substantial likelihood that the concerns discussed above will prohibit some or all of the pro se persons from attending the July 12, 2013, hearing on the undersigned’s motion for reconsideration. Such a result would deny the Court of the benefit of adversary presentation and would deny the pro se persons their due process right to be heard which is the very subject matter of the undersigned’s

motion for reconsideration.

DATED: July 8, 2013

MOTION TO APPEAR VIA TELEPHONE CASE NO. 2:12-CV-8333-ODW (JCx)

Case 21112-cv-08333-ODW-JC Document 209 Filed 07/10/13 Page 3of4 Page ID #:3780

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UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

INGENUITY 13 LLC, CASE NO. 2:12-CV-8333-OD W (JCx)

Plaintiff, v. Judge: Hon. Otis D. Wright, IT 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 Lincoln 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

PARTIES

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 170-417 Washington, D.C. 20037

6881 Forensics, LLC Springates East Government Road Charlestown, Nevis

MOTION TO APPEAR VIA TELEPHONE

CASE NO. 2:12-CV-8333-ODW (JCx)

Case 2{112-cv-08333-ODW-JC Document 209 Filed 07/10/13 Page 4of4 Page ID #:3781

AF Holdings, LLC Springates East Government Road Charlestown, Nevis Brett L. Gibbs

38 Miller Avenue, #263 Mill Valley, CA94941 Mark Lutz

2100 M Street Northwest, Suite 170-417 Washington, D.C. 20037

Pro Se

Alpha Law Firm, LLC 900 IDS Center

80 South 8" St. Minneapolis, MN 55402 Peter Hansmeier

2100 M Street Northwest, Suite 170-417 Washington, D.C. 20037

Angela Van Den Hemel

2100 M Street Northwest, Suite 170-417 Washington, D.C. 20037 Non-Party Putative John Doe

Morgan Pietz (SBN 260629) The Pietz Law Firm

3770 Highland Ave., Ste. 206 Manhattan Beach, CA 90266 mpietz@pietzlawfirm.com Telephone: (310) 424-5557 Facsimile: (310)546-5301

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 8,

2013.

Signatyre

MOTION TO APPEAR VIA TELEPHONE CASE NO. 2:12-CV-8333-ODW (JCx)