ase 2:12-cv-08333-ODW-JC Document 75-4 Filed 03/08/13 Page 1of3 Page ID #:2046

Morgan E. 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

Attorney for Putative John Doe in 2:12-cv-08333-ODW-JC

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

INGENUITY 13, LLC, a Limited Case Number: 2:12-cv-08333-ODW-JC
Liability Company Organized Under

the Laws of the Federation of Saint

é Case Assigned to:
Kitts and Nevis,

District Judge Otis D Wright, II
Plaintiff,

Discovery Referred to:
Magistrate Judge Jacqueline Chooljian
Vv.
Case Consolidated with Case Nos:.:
JOHN DOE, 2:12-cv-6636; 2:12-cv-6669; 2:12-cv-
6662; 2:12-cv-6668
Defendant.

[PROPOSED] ORDER DENYING EX
PARTE APPLICATION FOR ORDER
WITHDRAWING ORDER FOR JOHN
STEELE, PAUL HANSEMEIER,
PAUL DUFFY, AND ANGELA VAN
DEN HEMEL TO APPEAR

ORDER

Case 2:12-cv-08333-ODW-JC Document 75-4 Filed 03/08/13 Page 2of3 Page ID #:2047

ORDER

The Court, having duly considered the “Ex Parte Application for Order
Withdrawing Order for John Steele, Paul Hansemeier, Paul Duffy, and Angela Van
Den Hemel to Appear” (the “Application’”’) filed by specially appearing counsel,
and the opposition thereto, hereby rules as follows:
(a) Personal Jurisdiction

John Steele has sent at least one demand letters into the State of California,
seeking to pressure Internet users into settling copyright infringement claims. Dec’!
of Nicholas Ranallo, Exh. 1. Further, Mr. Steele has conducted media interviews,
with California publications, about his California cases. See

http://www.sfgate.com/business/article/Lawsuit-says-grandma-illegally-
downloaded-porn-2354720.php. Accordingly, both general and specific jurisdiction

exists over John Steele.

Paul Hansemeier travelled to San Francisco California to appear as the
30(b)(6) deponent of AF Holdings, LLC in a case pending in the Northern District 0
California. See ECF No. 69. Accordingly, both general and specific jurisdiction
exists over Paul Hansemeier.

Paul Duffy is a member of the State Bar of California.’ Further, he
substituted in as counsel of record in various AF Holdings and Ingenuity 13 cases
pending in the Northern District of California (see e.g., Exhibit EE’) and has
attempted, at his own initiative, to meet and confer regarding this case, C.D. Cal. 12-
cv-8333 (see Exhibit P). See also ECF No. 52, p. 10. Accordingly, both general and

specific personal jurisdiction exists over California courts for Paul Duffy.

' See http://members.calbar.ca.gov/fal/Member/Detail/224159

* The Exhibit lettering used herein refers to the Exhibits to prior declarations previously filed in
this case see ECF Nos. 40-1; 40-2; 53-1; 53-2; 59-1; 59-2.

2

ORDER

Case 2:12-cv-08333-ODW-JC Document 75-4 Filed 03/08/13 Page 3of3 Page ID #:2048

Angela Van Den Hemel was identified by Mr. Gibbs as being the person who
violated this Court’s discovery order. Accordingly, specific jurisdiction exists over
Angela Van Den Hemel.

(b) Time
The Court finds the argument that the amount of time for the moving parties

to respond unpersuasive.

Accordingly, the Court DENIES the Application. The moving parties are ordered to
appear at the Monday March 11, 2013 hearing in this matter.

DATED: March 8, 2013
Honorable Otis D. Wright, II
United States District Judge

ORDER