Case
fP:12-cv-08333-ODW-JC Document 230 Filed 07/23/13 Page 1of4 Page ID #:4228
HELLER & EDWARDS
Lawrence E. Heller, Esq. - Bar No. 69770 Iheller@hellerandedwards.com
9454 Wilshire Boulevard, Suite 500 BEVERLY HILLS CA 90212-2982 Telephone: (3 18 550-8833
Facsimile: 310) 858-6637
Specially Appearing for Morgan E. Pietz and Nicholas Ranallo
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
INGENUITY 13, LLC, a Limited Liability | USDC Case No.; 2:12-cv-08333-ODW-JC
Company Organized Under the Laws of the | [Consolidated with Case Nos. 2:12-cv-6636; Federation of Saint Kitts and Nevis, 2:12-cv-6669; 2:12-cv-6662; 2:12-cv-6668] Plaintiff, | Courtroom: 11 [The Honorable Otis D. Wright vs. STIPULATION TO BE RELIEVED OF JOHN DOE, OBLIGATION TO FILE NOTICED
MOTION FOR SANCTIONS
Defendant.
({Proposed] Order E-mailed Directly in Judge Otis Wright's Chambers]
IT IS HEREBY STIPULATED by and between Morgan Pietz (“Pietz”) and Nicholas Renallo (“‘Renallo”), through their attorneys of record, Heller & Edwards, on the one hand, and John Steele, appearing pro se, on the other hand, that Pietz and Renallo shall be relieved of any obligation they may have to file a noticed motion for sanctions under Fed. R. Civ. P. Rule 11 in connection with John Steele’s Motion for Reconsideration of his Emergency Motion to Vacate Orders and for Order to Show Cause.
The parties make this stipulation predicated upon the fact that the court in its Order Denying the Motion for Reconsideration “directed” Pietz and Renallo to file the a motion for sanctions, To the extent this direction is an order Pietz and Renallo seek to be relieved of any
obligation under that order.
| Stip re Sanctions Motion.wpd
Case | ceaoeiaepaimicras Document 230 Filed 07/23/13 Page 2 of 4 Page ID #:4229
i This stipulation is based on John Stcele’s agreement to forthwith pay the attorney's fees ‘incurred by Pietz and Renallo for opposing the Motion for Reconsideration in the sum of $5,400.00 as delineated in the declaration of Lawrence E. Heller filed in support of the
Opposition to the Motion for Reconsideration. IT IS SO STIPULATED:
| DATED: July 19, 2013. HELLER & EDWARDS
By: 11 ‘Cawrence E. Heller
Attorney for Plaintiff Morgan Pietz and Nicholas 12 Renallo
Sco O0U wm ND NH F&F WN
131 DATED: July 24, 2013 By:
Z Stip re Sanctions Motion.wpd
Case
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b:12-cv-08333-ODW-JC Document 230 Filed 07/23/13 Page 3 of 4 Page ID #:4230
PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
_ I declare that I am over the age of eighteen (18) years and not pi Paty to this action. My business address is 9454 Wilshire Boulevard, Fifth Floor, Beverly Hills, California, and | am employed in the office of a member of the bar of this Court at whose direction this service was made.
On July 23, 2013, I served the foregoing document described as
STIPULATION TO BE RELIEVED OF OBLIGATION TO FILE NOTICE MOTION FOR SANCTIONS
on all interested parties in this action by placing a true and correct copy of the document in a sealed envelope addressed as follows:
SEE PROOF OF SERVICE LIST
Q BY MAIL as follows: I am “readily familiar” with the firm’s practice of collection and processing of correspondence for mailing with the United States Postal Service. | know that the correspondence was deposited with the United States Postal Service on the same day this declaration was executed in the ordinary course of business. I know that the envelope(s) was (\ere) sealed, and with postage thereon fully prepaid, placed for collection and mailing on this date in the United States Mail at Los Angeles, California.
a BY PERSONAL SERVICE as follows: I caused such envelope(s) to be delivered by hand to the addressee(s) by Messenger Service. Delivery was made to the attorney or at the attorney's office by Teaving the documents, in an envelope or package clearly labeled to identify the attorney being served, with a receptionist or an individual in charge of the office, between the hours of nine in the morning and five in the evening.
Qa BY OVERNIGHT COURIER SERVICE as follows: I caused the above-referenced document to be delivered to for overnight courier service to the addressee(s).
a BY ELECTRONIC MAIL (email) as follows: I electronically filed the document(s) with the Clerk of the Court by using the CM/ECF electronic filing system. Participants in the case who are registered CM/ECF users will be served by the CM/ECF system. Participants in the case who are not registered CM/ECF users will be served by mail or by other means permitted by the court rules.
I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct and that this declaration was executed on July 23, 2013, at Beverly Hills, California.
/s/Cora Mayrina Cora Mayrina
Case [P:12-cv-08333-ODW-JC Document 230 Filed 07/23/13 Page 4of4 Page ID #:4231
1 PROOF OF SERVICE LIST 2 Ingenuity 13, LLC v. John Doe USDC Case No.: 2:12-cv-08333-ODW-JC 3 [Consolidated with Case Nos. 2:12-cv-6636; 2:12-cv-6669; 2:12-cv-6662; 2:12-cv-6668] 4
Via U.S. MAIL and email (where available)
wn
John Steele, Pro Se 1111 Lincoln Road MIAMI BEACH FL 33139
Mark Lutz, Pro Se
Peter Hansmeier, Pro Se
c/o Livewire Holdings, LLC 2100 M Street Northwest Suite 170-417
Washington, D.C, 20037
Angela Van Den Hemel, Pro Se
1 || PRENDA LAW INC.
161 North Clark Street, Suite 3200 12 || Chicago, IL 60601
3 || Peter Hansmeier
c/o Livewire Holdings, LLC
14 || 2100 Street Northwest, Suite 170-417 Washington DC 20037
xan a
oo
6|| By ECF Electronic Notice:
7|| Brett L. Gibbs, Esq., Pro Se 28 Altamont Avenue
18 || Mill Valley, CA 94941 (415) 381-3104
19 | brett.gibbs@gmail.com
20 || Paul Hansmeier, Pro Se Alpha Law Firm LLC
21 || 80 S. 8th Street, Suite 900 Minneapolis, MN 55402 22 || (612) 234-5744 prhansmeier(@thefirm.com
Paul Duffy, Pro Se
24 || 2.N. LaSalle Street, 13th Floor Chicago, IL 60602
25 |] 312-952-6136
Fax: 312-346-8434
26 || paduffy@wefightpiracy.com
27]| Pro se and for Ingenuity 13, LLC and for AF Holdings, LLC
28 || Prenda Law, Inc., through counsel Heather Rosing, Esq., and Philip Vineyard, Esq. Putative John Doe, through counsel Morgan Pietz, Esq., and Nicholas Ranallo, Esq. Morgan Pietz and Nicholas Ranallo, through special counsel Lawrence Heller, Esq