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3-11-11 Kenneth Eade v Ihub Doc 15 Application for Leave of Plaintiff Kenneth Eade to Appear Telephonic Ally

3-11-11 Kenneth Eade v Ihub Doc 15 Application for Leave of Plaintiff Kenneth Eade to Appear Telephonic Ally

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Published by cbrenn2

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Categories:Types, Business/Law
Published by: cbrenn2 on Mar 12, 2011
Copyright:Attribution Non-commercial

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03/12/2011

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KENNETH G. EADESBN 937746399 Wilshire Blvd., Suite 507Los Angeles, California 90048(323) 782-8802
Attorney for
 
Plaintiff UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIAKENNETH EADE,Plaintiff,vs.INVESTORSHUB.COM, INC., a Florida corp.,DOE 1, aka NO DUMMY, DOE 2, akaJANICE SHELL, DOE 3, aka FASTER183,DOE 4, aka STOCK MAVIN, DOE 5, akaRENEE, DOE 6,aka VIRTUAL DREW, DOE7, aka BOB 41, DOE 8 aka OVERACHIEVER,DOE 9, aka DOBERMAN, and DOE 10.Defendants.))))))))))))))))CASE NO. CV11-01315 PA (CWx) 
[DISCOVERY MATTER]PLAINTIFF KENNETH EADE’SAPPLICATION TO APPEAR ONMOTION TO EXPEDITE DISCOVERYBY TELEPHONE
Date: March 15, 2011Time: 10:00 a.m.Courtroom: 640Magistrate Judge Carla WoehrlePlaintiff KENNETH EADE hereby moves this Court ex parte for an Order allowingtheir counsel to appear at the hearing on plaintiff’s motion to expedite discovery on March 15,2011, pursuant to Local Rule 7-19, in that good cause exists for the appearance of counsel bytelephone, as counsel resides out of the country and does not plan on being back in the UnitedStates for the near future./ / / / / / / / / / / / 
Case 2:11-cv-01315-PA -CW Document 15 Filed 03/11/11 Page 1 of 5 Page ID #:93
 
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Said motion is based on this motion, the attached declaration of Kenneth Eade, theattached memorandum of points and authorities, the papers and records on file herein and uponsuch other and further evidence as the Court may consider at the hearing of this motion.This motion is being made ex parte, due to the lack of time for it to be heard on regular notice,and the Court’s procedures with regard to applications to appear by telephone.Dated: March 11, 2011 /s/ Kenneth EadeKENNETH EADE, ESQ.Plaintiff, In Pro Per
Case 2:11-cv-01315-PA -CW Document 15 Filed 03/11/11 Page 2 of 5 Page ID #:94
 
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MEMORANDUM OF POINTS AND AUTHORITIESA. GOOD CAUSE EXISTS FOR ALLOWING ANAPPEARANCE BY TELEPHONE.The Court allows appearances by telephone in circumstances where counsel cannotpersonally appear. As can be seen from the attached declaration, plaintiff currently lives outsideof the United States, and has no plans to be in the United States for the near future , and wouldface an undue burden and expense to appear in person for one hearing.Respectfully submitted,Dated: March 11, 2011 /s/ Kenneth EadeKENNETH EADE, ESQ.Plaintiff, In Pro Per
Case 2:11-cv-01315-PA -CW Document 15 Filed 03/11/11 Page 3 of 5 Page ID #:95

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