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Def.23.Motion for Security

Def.23.Motion for Security

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Published by Len Harris
Motion for Bond
Motion for Bond

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Categories:Types, Business/Law
Published by: Len Harris on Dec 01, 2012
Copyright:Attribution Non-commercial

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10/02/2013

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David Harris4632 E. Caballero ST Number OneMesa, AZ 85205(480) 297-9546troll.assassins@cyber-wizard.comDefendant Pro Se
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF ARIZONA
AF Holdings, LLCPlaintiff,vs.David HarrisDefendant.
)))))))))
Case 2:12-cv-02144-GMS
The Honorable G. Murray Snow
Motion for Security of Non-ResidentPlaintiff INTRODUCTION
C
omes now the Defendant, David Harris a proud, law abiding natural born citizenof the United States of America, a layperson unschooled in the practice of lawhaving reached the age of majority and living in Mesa, Arizona County of Maricopa.
MOTION
Under authority of LRCiv54.1[c]. ¶1.Plaintiff AF Holdings, LLC is not a resident of Arizona, in fact it is not known if they have ever experienced the pleasure of visiting our Great State. Plaintiff probablydoes not even live in the United States of America as they are limited liability co. of St.Kitts and Nevis [id at doc 1 caption] . ¶2.Defendant is of the opinion, they are here to peddle their porn and shake down our citizens like the instant case. Good men of conscience pray for the likes of these peoplethat their souls be saved from an eternity of fire and brimstone, but they run from them,they run as fast as they can. Defendant will not run from this vermin as this is his home.Page 1 of 8
Case 2:12-cv-02144-GMS Document 23 Filed 11/30/12 Page 1 of 8
 
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MEMORANDA
 ¶3.Your Honor, I know my language is a bit colorful in regards to the Plaintiff, but I promise you, soon you will understand why. Then you will understand that I have showna great deal of restraint! ¶4.Your Honor, I come before you today to move this court to provide a littleguarantee of the Plaintiff’s performance in this lawsuit, by way of a security bond. ¶5.Aforementioned security is both legal and necessary for Defendant to continue todefend himself in the instant action and to prosecute his counter claim without beinggravely prejudiced. The Plaintiff’s
 Modus Operandi
when facing an unfavorableoutcome of the court is to duck or cut and run, never looking back, even if that requiresthe Plaintiff to deceive, conceal and omit legally relevant and pertinent material facts tothe next district he trolls
1
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AMOUNT TO GUARANTEE PERFORMANCE
 ¶6.Defendant realizes that he can not calculate fees and costs based on lawyerscompensation. Layperson’s wages rarely if ever rise to that of the luxurious white collar status of a lawyer. ¶7.To be fair Defendant uses the highest wage he has earned, that of a NevadaLicensed C-25 Contractor (license 0020631). Defendant averaged $106.25/per hour. ¶8.In addition to hours spent researching and preparing briefs, Defendant is alsoentitled to costs to familiarize himself with the rules of this court in order to defendhimself in these proceedings as mandated by this court [id at doc 18 line18-21]. ¶9.It should also be taken into consideration that Plaintiff’s actions have causedDefendant to file and to prosecute counter claims against Plaintiff. For which Defendantwould be entitled to costs and fees.
1
This is not conjecture or speculation, just look at Plaintiff’s acts andomissions outlined in ¶18 thru ¶20 this doc.
Page 2 of 8
Case 2:12-cv-02144-GMS Document 23 Filed 11/30/12 Page 2 of 8
 
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 ¶10.Finally Defendant will be entitled to damages caused by the Plaintiff as set forth inDefendant’s counter claim. As the cause of action for such claims arose by Plaintiff’simproprieties in filing the instant case for inappropriate reasons. ¶11.Defendant has conservatively calculated the amount Plaintiff must deposit toguarantee his performance in this matter at one hundred and fifty thousand dollars($150,000.00)
2
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MORE LIKELY THAN NOT DEFENDANT WILL PREVAIL
 ¶12.Of the thousands of John Doe copyright infringement suits filed by this copyrighttrolls nationwide, as of the filing of the instant case, it sticks out like a sore thumb. It isdifferent than the typical case of this type as the necessary requisite for determining theidentity of a person connected to the alleged infringing IP address is absent. ¶13.Plaintiff asserts:“The degree of anonymity provided by the BitTorrent protocolis extremely low. Because the protocol is based on peers connectingto one another, a peer must broadcast identifying information(i.e. an IP address) before it can receive data. Nevertheless, the actualnames of peers in a swarm are unknown, as the users are allowed todownload and distribute under the cover of their IP addresses” [id at doc1¶14].However, this assertion is erroneous in and of it’s own contradiction, if an IP address isidentifying information, then it would be impossible to cover one’s identity under their “identity.” ¶14.It seems that the Plaintiff is the only one not aware that his theory does not stand toreason, or is this confusing nonsense meant to be just, a distraction? ¶15.Plaintiff’s claim states:
2
Plaintiff was ordered to post a $48,000.00 bond to guarantee fees andcosts for defending the case only, a case that follows the typical progression of acopyright infringement case of this type, while the instant action also includesprosecuting its counter claim and damages to Defendant by Plaintiff [
 AF Holdingsv Trinh
no12-02393 Northern District of California] .
Page 3 of 8
Case 2:12-cv-02144-GMS Document 23 Filed 11/30/12 Page 3 of 8

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