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    Hagen Motion For Change of Venue

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    interpol2548
    The plaintiff requests that the court transfer the case to the District of Massachusetts. The plaintiff initially filed the case in the Western District of Washington based on the defendant's statements that she resided in Washington. However, it has become clear that the defendant has actually resided in Massachusetts for several years. Transferring the case would make the pending motions to dismiss for lack of personal jurisdiction moot and is in line with the requests of the defendant and her counsel. The plaintiff asks the court to grant the motion to transfer the case.

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    Hagen Motion For Change of Venue

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    interpol2548
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    The plaintiff requests that the court transfer the case to the District of Massachusetts. The plaintiff initially filed the case in the Western District of Washington based on the defendant's statements that she resided in Washington. However, it has become clear that the defendant has actually resided in Massachusetts for several years. Transferring the case would make the pending motions to dismiss for lack of personal jurisdiction moot and is in line with the requests of the defendant and her counsel. The plaintiff asks the court to grant the motion to transfer the case.

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    Hagen Motion for Change of Venue

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    The plaintiff requests that the court transfer the case to the District of Massachusetts. The plaintiff initially filed the case in the Western District of Washington based on the defendant's statements that she resided in Washington. However, it has become clear that the defendant has actually resided in Massachusetts for several years. Transferring the case would make the pending motions to dismiss for lack of personal jurisdiction moot and is in line with the requests of the defendant and her counsel. The plaintiff asks the court to grant the motion to transfer the case.

    Copyright:

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    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    639 views5 pages

    Hagen Motion For Change of Venue

    Uploaded by

    interpol2548
    The plaintiff requests that the court transfer the case to the District of Massachusetts. The plaintiff initially filed the case in the Western District of Washington based on the defendant's statements that she resided in Washington. However, it has become clear that the defendant has actually resided in Massachusetts for several years. Transferring the case would make the pending motions to dismiss for lack of personal jurisdiction moot and is in line with the requests of the defendant and her counsel. The plaintiff asks the court to grant the motion to transfer the case.

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    Attribution Non-Commercial (BY-NC)
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
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    The plaintiff is requesting that the case be transferred from the Western District of Washington to the District of Massachusetts due to the defendant residing in Massachusetts rather than Washington as originally claimed.

    The plaintiff is requesting that the court issue an order transferring the case from the Western District of Washington to the District Court of Massachusetts.

    The defendant had originally claimed to reside in Washington state but it has now become apparent that she resides and has been domiciled in Massachusetts for a number of years.

    IN THE UNITED STATES DISTRICT COURT

    FOR THE WESTERN DISTRICT OF


    WASHINGTON

    RYDER, CHRIS
    : CASE NO: 10-cv-1002
    : JUDGE MJP
    Plaintiff :
    :
    :
    v. : August 31, 2010

    HAGEN, KATRINA, M.

    Defendant

    MOTION FOR CHANGE OF VENUE

    Pursuant to the Federal Rules of Civil Procedure, particularly 28 USC 1404 the Plaintiff hereby

    requests that the Court issue an order for a change of venue for the case at bar. The granting of

    this Motion would thus serve the re-articulated request of the defendant, through her counsel(s)

    that the venue of the Western District of Washington is not the proper venue. The statute, 28USC

    1404 states in part:

    Sec. 1404. Change of venue

    (a) For the convenience of parties and witnesses, in the


    interest of justice, a district court may transfer any civil
    action to any other district or division where it might have been
    brought.(b) Upon motion, consent or stipulation of all parties,
    any action, Suit or proceeding of a civil nature or any motion or
    hearing thereof ,may be transferred, in the discretion of the
    court, from the division in which pending to any other division
    in the same district. Transfer of proceedings in rem brought by
    or on behalf of the United States may be transferred under this
    section without the consent of the United States where all other
    parties request transfer.

    1
    Curiously, the defendant had over and again told the plaintiff1 that she resided in the State

    of Washington. Based upon these statements it was reasonable for the plaintiff to then reach the

    conclusion that diversity existed under 18USC 1332 wherein complete diversity existed and this

    Court was the controlling one for purposes of both diversity and jurisdiction.

    It has now become apparent that the defendant now resides and has maintained domicile

    in the Commonwealth of Massachusetts for ‘a number of years’. Her initial protestations that she

    resided in Washington- to which this plaintiff had no reason to doubt- appears to be just an

    extension of her misleading and egregious conduct. The defendant’s incantations regarding her

    lawful domicile were, retrospectively, merely subterfuges. She has supplied and the plaintiff

    accepts the heavily redacted ‘proof’ that she has produced for this Court. Given that, contrary to

    her statements and assertions that she resided in Washington, it is now convincing that she

    resides in Massachusetts.

    Accepting this harkened awakening, the plaintiff requests that the case be transferred to

    the Commonwealth (District Court of Massachusetts) of Massachusetts in toto. Of obvious note

    are that the many pended motions seeking dismissal based upon lack of personal jurisdiction

    would become moot. Secondly, the defendant’s counsel has stated over and again that the case

    belongs in the District on Massachusetts. Plaintiff hereby request that this motion be granted in

    lieu of: a) holding a hearing in this Court and b) to preserve scarce judicial resources of having

    the clerk’s in the District on Massachusetts having to wade through the morass of a newly minted

    case. A transfer seems to accomplish the many requests of the defense counsel(s), and causes the

    least inconvenience for the defendant as she is already ‘there’. An order seeking this Court’s

    granting of this, if viewed as judicially sensible, is attached.

    1
    As well as others in the plaintiff’s presence

    2
    Respectfully submitted,
    s/ Chris Ryder
    CHRIS RYDER
    Pro Se
    P O Box 380949
    Cambridge, Mass 02138
    Telephone: 202. 489-9292
    Fax: 202-380-9121
    Email: [email protected]

    IN THE UNITED STATES DISTRICT COURT


    FOR THE WESTERN DISTRICT OF
    WASHINGTON

    RYDER, CHRIS
    : CASE NO: 10-cv-1002
    : JUDGE MJP
    Plaintiff :
    :
    :
    v. : September _____ 2010

    HAGEN, KATRINA, M.

    Defendant
    ORDER

    3
    The Plaintiff’s Motion for an a Change of Venue is hereby granted/denied.

    Date________________

    __________________________

    Hon. Marsha J. Pechman, UDCJ

    Certification

    The plaintiff certifies that a copy of this motion has been transmitted to the defendant by way of

    her counsel through the electronic filing system (Pacer) ECMF.

    To:

    Adam Belzberg
    Graham & Dunn, PC
    Pier 70, 2801 Alaskan Way, Suite 300
    Seattle, WA 98121-1128

    Bradley E. Abruzzi
    Office of the General Counsel
    Harvard University
    980 Holyoke Center
    1350 Massachusetts Avenue
    Cambridge, MA 02138

    4
    _/s Chris Ryder_____________________-

    Chris Ryder September 1, 2010

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