Preview
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Hussein Ali
5730 N First St Suite 105-208
SLED
Fresno CA 93710
(559) 647-2360 _
OCT
= 9 2015
SPEEA fo
Superior Court of California
County Fresno
Hussein Ali
10 CASE NUMBER: 15CECG02419
ll
Plaintiff,
VS.
12 PLAINTIFF OBJECTION TO
DOLLAR RENT A CAR INC, DEFENDANT MOTION TO ORDER
13 An Oklahoma Corporation REQUIRING SECURITY PURSUANT
14
TO §371.1
is Defendant
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18 Date: November 10, 2015.
Time: 3:30 pm
19 Dept: 503
Judge: Hon Alan Simpson
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24 TBCECANZ410
ol
| inh un
Objection filed
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PLAINTIFF OBJECTION DEFENDANT MOTION TO
ORDER REQUIRING SECURITY
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TO ALL PARTIES HEREIN AND THEIR ATTORNEY'S OF RECORD:
NOTICE IS HEREBY GIVIN that on November 10, 2015 at 3:30 PM., or as soon
thereafter as the Matter may be heard in Department 503 of the above entitled court, located at
1130 “O” Street, Fresno, California 93721, Defendant moves for an Order Requiring security
Pursuant according to §371.1
DATED: October 9, 2015
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La
Pro Per
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PLAINTIFF OBJECTION DEFENDANT MOTION TO
ORDER REQUIRING SECURITY
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PRELIMINARY STATEMENT
Defendants filed a motion requiring security under California Code of Civil Procedure
§391.1 sets forth the procedure that is to be followed to determine whether a party is to be deemed
a vexatious litigant and required to post a security.
In any litigation pending in any court ofthis state, at any time until final judgment is
entered, a defendant may move the court, upon notice and hearing, for an order requiring
the Plaintiff to furnish security or for an order dismissing the litigation pursuant to
10 subdivision (b) of section 391.1. The motion for an order requiring the Plaintiff to furnish
11 security shall be based upon ground, and supported by showing that the Plaintiff is a
vexatious litigant and that there is not a reasonable probability that he or she will prevail
12
in the litigation against the moving defendant.
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Plaintiff had no intention to file this complaint after his life was threaten and he had to call the
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Orlando Police Department and filling a police report number 2015-262648. Then Defendant
16 charged Plaintiff’s
Credit Card (Exhibit 1) again after he settles the cost of the rental causing his
17 account to go into Negative. And be charged more charges that he could not afford. Plaintiff
18 called Defendant and pleaded with them to refund the second charge and was ignored and asked
19 even not to call again. So Defendant threaten Plaintiff Life and double charge him and now
calling Plaintiff Vexatious. If Plaintiff has no chance of Prevailing under these circumstances then
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the court should grant the order.
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Plaintiff travels to Orlando every month and rent autos from car rentals agencies and never
23
encounter the threat and unprofessionalism that he encountered with Defendant and on top of all
24 of that he get double charged.
25
26 On the Declaration of Marcus Echtler he states that Plaintiff insisted on FORD Focus is not true.
27 Dollar Counter Clerk instructed Plaintiff to pick a vehicle from Lane One Only. All the Autos in
28 lane one were either compact or subcompact. Plaintiff refused to select a vehicle from Lane One
-3-
PLAINTIFF OBJECTION DEFENDANT MOTION TO
ORDER REQUIRING SECURITY
since all Vehicles in Lane One are not from the class he paid for. When he inquired where are the
Standard cars he was threaten and feared for his life. Plaintiff Called Orlando Police and then the
Officers who found a vehicle for Plaintiff. Out of respect to the officers Plaintiff accepted the
vehicle even it was dirty and not acceptable to any person. Marcus Echtler either he does not have
all the facts all he is not telling the truth. The 2014 Dodge was selected by Orlando Police as a
temporary solution. The 2014 Dodge was not selected by Plaintiff. And when the Officers are
called to testify they will testify that they who selected the vehicle not Plaintiff. When Plaintiff
called Dollar national Number complaining about the Vehicle that was selected by Orlando Police
he was informed to travel to Daytona Beach Airport and pick up a slandered vehicle. When
Plaintiff arrived at the airport there was only vehicle available at that location and he has no
10 choice but to accept the vehicle Kia Soul.
ll
12
On Declaration of Marcus Echtler stated that Defendant charged Plaintiff credit card again due to
13
a technical error. Then why defendant did not refund the amount when Plaintiff called same day
14
the second charge appeared on. Plaintiff bank account since his account became negative. When
15
Plaintiff will requested the recorded conversation with Dollar Billing Department it will show that
16 Defendant’s Agent was rude and hostel and un-helpful and did not care if Plaintiff account is in
17 the negative.
18
19 On September 8, 2015 Plaintiff emailed Defendant Counselor an Email (Exhibit 2) suggesting
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that the case be moved to Middle Florida District Court since all witnesses is residing in Orlando
area. Defendants Counselor emailed Plaintiff a copy of the letter that was mailed (Exhibits 3),
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Informing Plaintiff that it is impossible to Transfer the case to Middle Florida District Court.
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Plaintiff researched the matter and it was not impossible. All what the Defendant has to do is
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Transfer the case to Eastern District of California and file a motion to Transfer the case Middle
24 Florida District Court.
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PLAINTIFF OBJECTION DEFENDANT MOTION TO
ORDER REQUIRING SECURITY
—
Il
CONCLUSION
Based upon the foregoing. Defendants’ motion Requiring Security should be overruled. In the
alternative Plaintiff requests for leave to amend to add any additional information pertaining to
the sufficiency of the allegations asserted
DATED: October 9, 2015
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PLAINTIFF OBJECTION DEFENDANT MOTION TO
ORDER REQUIRING SECURITY
Ne
ALI vs, DOLLAR 15SCECG02419
Fresno County Superior Court -UN limited Jurisdiction —
PROOF OF SERVICE
I, the undersigned, declare that I am over the age of 18 and am not a party to this action. I am employed in the cityof
Fresno, California; my business address is $730 N FIRST ST SUITE 105-208 Fresno CA 93710
On the date belowI served a copy, with all exhibits, of the following document(s).
PLAINTIFF OBJECTION DEFENDANT MOTION TO ORDER REQUIRING
SECURITY
On all interested parties in said case addressed as follows.
Steven McQuillan
1690 West Shaw Avenue, Suite 201
Fresno, California 93711
10
1i GY MAIL) I am familiar with the business practice for collection and processing mail. The above-described
documents(s) will be enclosed in a sealed envelope, with first class postage thereon fully prepaid, and deposited with
12 the United States Postal Service at Fresno CA on this date October 9, 2015. The Sealed envelope was addressed to:
13
Steven McQuillan
14 1690 West Shaw Avenue, Suite 201
Fresno, California 93711
15
16 October 9, 2015
17
Jorge Feces
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PLAINTIFF OBJECTION DEFENDANT MOTION TO
ORDER REQUIRING SECURITY
“\ ae a:
~
2 :; ______
tovgants ~ Account Transactions: Bank ofthe Sierra _.
. _
~
MM conicasierra
Account 60 Int 0002 Current Time: 08/01/16 8:34:32 AM Current Balance: -531.47 Avaliable Balance: -531.47
Datev RefiCheck No|Description Debit! Balance}
jo7rsa2018 Paid item Fae 36.00} ~831.47}
poresOa0ts HOBT CRD 0030 07/90/15 04031284 DOLLAR RENT-A-CAR MCOO ORLANDO FL Cardi 7244 807.83} 496.47}
jo7rae/2016 DET CRD 0103 07/28/15 00082018 MYFREEECORENOW.COM 888-6482008 CA Card 7244 20.85) 11.08)
jo7raer2018 }PO8 DEB 1724 07/28/16 00181280 FOODMAXQW414 FR FREENO CA Card# 7244 41.01
07/28/2018 DBT CRD 2036 07/28/16 00038847 STARBUCKS #08378 FRESN Fresno
CA Carde 7244 49,68)
jo7v2a2018 Maw Image/Depoat 30.00] 50.08)
j07/28/2018
jo7/27/2018
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MT 600 3 re (8607 WA Cardh 7244
=7.85}
107,93}
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27.83}
jo7/27/2018 ‘View Image] Depoat 126.00) 136.88)
}o7/24/2018 DBT CRD 2044 07/23/16 00013074 NETFLIX.COM NETFLIX.COM CA Cardi 7244 11.99] 10.86)
jo7r24i2018 POS DEB 2006 07/23/16 00581988 FOODMAXX#414 FR FRESNO CA Card# 7244 8.60] 22.86}
jO7/24/2016 |DET CRD 2032 07/25/16 00016210 STARBUCKS #05375 FRESN Freano CA Card# 7244 31.18}
07/23/2018 }OBT CRD 0108 07/23/15 04031284 DOLLAR RENT-A-CAR MCOO ORLANDO FL Cardi 7244 -507.58]
07/23/2018 DBT CRD 0031 07/23/18 04738313 BEST BUDGET INN FREBNO CA Card 7244 342.15}
lo7z3/2018 POS DEB 1118 07/23/15 00700085 CNG RITE AID CORP. 381 FRESNO CA Cardi 7244 48.08}
0724/2016 DBT CRO 2026 07/22/18 00013872 AMERICAN ORLANDO FL Card# 7244 26.00) 48.14)
07/23/2018 723160808) Traf trom PerSav 0003 Confrmation number 723180808 873.14)
or2av2018 View Image|Depost 686.14]
07/42/2016 DBT CRO 0101 07/22/18 00040814 CHICK-FIL-A #0488 PALM COAST FL Cerd# 7244 17.73} 488.14)
0722/2018 POS DEB 2028 07/21/18 00082168 ARCO PAYPOINT FREGNO CA Card# 7244 13.24]
forrezao1s DBT GRO 0731 07/22/16 COOPBES® PANDA EXPRESS #562 FRESNO CA Cards 7244 10.74 496.11)
07/22/2018 DBT GRO 0388 07/22/16 00068008 OREILLY AUTO 00028005 FREGNO CA Card# 7244 -7.01
07/22/2018 IDBT CRD 2040 07/21/18 00000837 GOOGLE “‘Minscraft GOOGLE.COM/CHCA
Curd 7244 -6.99] 613.83
a7/azr2016 POS DEB 1822 07/22/15 00820886 TRADER JOE §# FRESNO CACard® 7244 1.98
lo7r21/2016 Transfer Requested
By: Hussain Al -20.00) 822.80
jo721/2016 DBT CRD 2027 07/20/18 00044638 ACT*Palm Cosst Rec 677-228-4881 CA Card# 7244 -20.00)
07/21/2016 POS DEB 0037 07/21/16 00681642 SEMORAN FOODS ORLANDO FL Carde 7244 =20,00}
lo7a1/2016 ‘Mew Image] Depost 882.80)
lo720/2018 DBT CRD 0422 07/20/16 00002682 TERRA GAUCHA JACKSONVILLE FL Card# 7244 253.76}
lo7ear2018 |POS DEB 1614 07/10/16 00008804 PUBLIX SUPER MAR PALM COAST FL 64.41
Totate: Transactions: 30 Debits: -1,788.43 |Credits: 563.00
file YDOLLAR/Dollar_731.htm! 4A
ase st ae
7
nD:
From: ‘Hussein.
Ali September 10, 2015
5730 N First Street Suite 105-208
Fresno, CA 93710
hali41559@gmail.com
To: Jacobson, Hansen & McQuillan
1690 West Shaw Avenue, Suite 201
Fresno, California.93711
Ref Ali vs Dollar 15CEGG02419
Mr. McQuillan
Just recelved your motion to require security. | belleve since you think it is going to cost your client extra
Moitey’to litigate the’case in Fresno for travel Expenses and so. I will:not have any-objection If you file a
motion to transfer thé casé to the-U.S. District Court for the Middle District of Florida In Orlando. By
transferring the case‘to the U.S. District court In Orlando-you Cllent-does not have.to:incur the extra
expenses that you claim they will. | will have no probiem litigating the case in The U.S. District Court in
Orlando Florida.
Your atceptanice Is Important $6.1 do not have to file an Objection to your motion.
Thank 7)
jusseln All
~
ee EXHIBIT 3 Ee
nN
v7
LEE M, JACOBSON attornep@yiinlamyers.com
JACOBSON, HANSEN & MCQUILLAN LEITH B, HANSEN
A Profesional Corporation STEVEN M, MCQUILLAN Opies: (359) 448-0400
Fax: (359) 448-0123
JASON A. DECKER
Ra W, Shaw Avene, Suite 201 DAVID O. FLEWALLEN DEBORAH NEELY
Frosno, California 993411 STEPHEN T. KNUDSEN Office Adwinteratar
KRISTINA D, GARABEDIAN
September 10, 2015
Hussein Ali
5730 N. First Street, Suite 105-208
Fresno, CA 93710
Re:
Fresno County Superior Court No. 15CECG02419
Dear Mr. Alt:
lam in receipt of your letter and thank you for your proposal. Unfortunately what you have
proposed is procedurally impossible, We therefore have no choice but to require you to
post security or dismiss the action you have filed in the Fresno Superior Court.
Very truly yours,
JACOBSON, HANSEN & McQUILLAN
A Professional Corporation
DICTATED BUT NOT READ
SENT TO AVOID DELAY
Steven M. McQuillan
(mcq@jhmlawyers.com)
SMQ/dp
Preview
. ¥ Hussein Ali 5730 N First St Suite 105-208 SLED Fresno CA 93710 (559) 647-2360 _ OCT = 9 2015 SPEEA fo Superior Court of California County Fresno Hussein Ali 10 CASE NUMBER: 15CECG02419 ll Plaintiff, VS. 12 PLAINTIFF OBJECTION TO DOLLAR RENT A CAR INC, DEFENDANT MOTION TO ORDER 13 An Oklahoma Corporation REQUIRING SECURITY PURSUANT 14 TO §371.1 is Defendant 16 17 18 Date: November 10, 2015. Time: 3:30 pm 19 Dept: 503 Judge: Hon Alan Simpson 20 21 22 23 24 TBCECANZ410 ol | inh un Objection filed 25. ee 26 27 28 -1- PLAINTIFF OBJECTION DEFENDANT MOTION TO ORDER REQUIRING SECURITY mf 7 TO ALL PARTIES HEREIN AND THEIR ATTORNEY'S OF RECORD: NOTICE IS HEREBY GIVIN that on November 10, 2015 at 3:30 PM., or as soon thereafter as the Matter may be heard in Department 503 of the above entitled court, located at 1130 “O” Street, Fresno, California 93721, Defendant moves for an Order Requiring security Pursuant according to §371.1 DATED: October 9, 2015 10 11 12 La Pro Per 13 14 15 16 v7 18 19 20 21 22 23 24 25 26 27 28 -2- PLAINTIFF OBJECTION DEFENDANT MOTION TO ORDER REQUIRING SECURITY 7 I PRELIMINARY STATEMENT Defendants filed a motion requiring security under California Code of Civil Procedure §391.1 sets forth the procedure that is to be followed to determine whether a party is to be deemed a vexatious litigant and required to post a security. In any litigation pending in any court ofthis state, at any time until final judgment is entered, a defendant may move the court, upon notice and hearing, for an order requiring the Plaintiff to furnish security or for an order dismissing the litigation pursuant to 10 subdivision (b) of section 391.1. The motion for an order requiring the Plaintiff to furnish 11 security shall be based upon ground, and supported by showing that the Plaintiff is a vexatious litigant and that there is not a reasonable probability that he or she will prevail 12 in the litigation against the moving defendant. 13 14 Plaintiff had no intention to file this complaint after his life was threaten and he had to call the 15 Orlando Police Department and filling a police report number 2015-262648. Then Defendant 16 charged Plaintiff’s Credit Card (Exhibit 1) again after he settles the cost of the rental causing his 17 account to go into Negative. And be charged more charges that he could not afford. Plaintiff 18 called Defendant and pleaded with them to refund the second charge and was ignored and asked 19 even not to call again. So Defendant threaten Plaintiff Life and double charge him and now calling Plaintiff Vexatious. If Plaintiff has no chance of Prevailing under these circumstances then 20 the court should grant the order. 21 22 Plaintiff travels to Orlando every month and rent autos from car rentals agencies and never 23 encounter the threat and unprofessionalism that he encountered with Defendant and on top of all 24 of that he get double charged. 25 26 On the Declaration of Marcus Echtler he states that Plaintiff insisted on FORD Focus is not true. 27 Dollar Counter Clerk instructed Plaintiff to pick a vehicle from Lane One Only. All the Autos in 28 lane one were either compact or subcompact. Plaintiff refused to select a vehicle from Lane One -3- PLAINTIFF OBJECTION DEFENDANT MOTION TO ORDER REQUIRING SECURITY since all Vehicles in Lane One are not from the class he paid for. When he inquired where are the Standard cars he was threaten and feared for his life. Plaintiff Called Orlando Police and then the Officers who found a vehicle for Plaintiff. Out of respect to the officers Plaintiff accepted the vehicle even it was dirty and not acceptable to any person. Marcus Echtler either he does not have all the facts all he is not telling the truth. The 2014 Dodge was selected by Orlando Police as a temporary solution. The 2014 Dodge was not selected by Plaintiff. And when the Officers are called to testify they will testify that they who selected the vehicle not Plaintiff. When Plaintiff called Dollar national Number complaining about the Vehicle that was selected by Orlando Police he was informed to travel to Daytona Beach Airport and pick up a slandered vehicle. When Plaintiff arrived at the airport there was only vehicle available at that location and he has no 10 choice but to accept the vehicle Kia Soul. ll 12 On Declaration of Marcus Echtler stated that Defendant charged Plaintiff credit card again due to 13 a technical error. Then why defendant did not refund the amount when Plaintiff called same day 14 the second charge appeared on. Plaintiff bank account since his account became negative. When 15 Plaintiff will requested the recorded conversation with Dollar Billing Department it will show that 16 Defendant’s Agent was rude and hostel and un-helpful and did not care if Plaintiff account is in 17 the negative. 18 19 On September 8, 2015 Plaintiff emailed Defendant Counselor an Email (Exhibit 2) suggesting 20 that the case be moved to Middle Florida District Court since all witnesses is residing in Orlando area. Defendants Counselor emailed Plaintiff a copy of the letter that was mailed (Exhibits 3), 21 Informing Plaintiff that it is impossible to Transfer the case to Middle Florida District Court. 22 Plaintiff researched the matter and it was not impossible. All what the Defendant has to do is 23 Transfer the case to Eastern District of California and file a motion to Transfer the case Middle 24 Florida District Court. 25 26 27 28 -4- PLAINTIFF OBJECTION DEFENDANT MOTION TO ORDER REQUIRING SECURITY — Il CONCLUSION Based upon the foregoing. Defendants’ motion Requiring Security should be overruled. In the alternative Plaintiff requests for leave to amend to add any additional information pertaining to the sufficiency of the allegations asserted DATED: October 9, 2015 ier 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -5- PLAINTIFF OBJECTION DEFENDANT MOTION TO ORDER REQUIRING SECURITY Ne ALI vs, DOLLAR 15SCECG02419 Fresno County Superior Court -UN limited Jurisdiction — PROOF OF SERVICE I, the undersigned, declare that I am over the age of 18 and am not a party to this action. I am employed in the cityof Fresno, California; my business address is $730 N FIRST ST SUITE 105-208 Fresno CA 93710 On the date belowI served a copy, with all exhibits, of the following document(s). PLAINTIFF OBJECTION DEFENDANT MOTION TO ORDER REQUIRING SECURITY On all interested parties in said case addressed as follows. Steven McQuillan 1690 West Shaw Avenue, Suite 201 Fresno, California 93711 10 1i GY MAIL) I am familiar with the business practice for collection and processing mail. The above-described documents(s) will be enclosed in a sealed envelope, with first class postage thereon fully prepaid, and deposited with 12 the United States Postal Service at Fresno CA on this date October 9, 2015. The Sealed envelope was addressed to: 13 Steven McQuillan 14 1690 West Shaw Avenue, Suite 201 Fresno, California 93711 15 16 October 9, 2015 17 Jorge Feces 18 19 20 21 22 23 24 25 26 27 28 -~6- PLAINTIFF OBJECTION DEFENDANT MOTION TO ORDER REQUIRING SECURITY “\ ae a: ~ 2 :; ______ tovgants ~ Account Transactions: Bank ofthe Sierra _. . _ ~ MM conicasierra Account 60 Int 0002 Current Time: 08/01/16 8:34:32 AM Current Balance: -531.47 Avaliable Balance: -531.47 Datev RefiCheck No|Description Debit! Balance} jo7rsa2018 Paid item Fae 36.00} ~831.47} poresOa0ts HOBT CRD 0030 07/90/15 04031284 DOLLAR RENT-A-CAR MCOO ORLANDO FL Cardi 7244 807.83} 496.47} jo7rae/2016 DET CRD 0103 07/28/15 00082018 MYFREEECORENOW.COM 888-6482008 CA Card 7244 20.85) 11.08) jo7raer2018 }PO8 DEB 1724 07/28/16 00181280 FOODMAXQW414 FR FREENO CA Card# 7244 41.01 07/28/2018 DBT CRD 2036 07/28/16 00038847 STARBUCKS #08378 FRESN Fresno CA Carde 7244 49,68) jo7v2a2018 Maw Image/Depoat 30.00] 50.08) j07/28/2018 jo7/27/2018 1 on Bo ‘008 00168136 FOODMAK0WA14 COOTER WO SER xECU RESNO NG CA MT 600 3 re (8607 WA Cardh 7244 =7.85} 107,93} 20.08) 27.83} jo7/27/2018 ‘View Image] Depoat 126.00) 136.88) }o7/24/2018 DBT CRD 2044 07/23/16 00013074 NETFLIX.COM NETFLIX.COM CA Cardi 7244 11.99] 10.86) jo7r24i2018 POS DEB 2006 07/23/16 00581988 FOODMAXX#414 FR FRESNO CA Card# 7244 8.60] 22.86} jO7/24/2016 |DET CRD 2032 07/25/16 00016210 STARBUCKS #05375 FRESN Freano CA Card# 7244 31.18} 07/23/2018 }OBT CRD 0108 07/23/15 04031284 DOLLAR RENT-A-CAR MCOO ORLANDO FL Cardi 7244 -507.58] 07/23/2018 DBT CRD 0031 07/23/18 04738313 BEST BUDGET INN FREBNO CA Card 7244 342.15} lo7z3/2018 POS DEB 1118 07/23/15 00700085 CNG RITE AID CORP. 381 FRESNO CA Cardi 7244 48.08} 0724/2016 DBT CRO 2026 07/22/18 00013872 AMERICAN ORLANDO FL Card# 7244 26.00) 48.14) 07/23/2018 723160808) Traf trom PerSav 0003 Confrmation number 723180808 873.14) or2av2018 View Image|Depost 686.14] 07/42/2016 DBT CRO 0101 07/22/18 00040814 CHICK-FIL-A #0488 PALM COAST FL Cerd# 7244 17.73} 488.14) 0722/2018 POS DEB 2028 07/21/18 00082168 ARCO PAYPOINT FREGNO CA Card# 7244 13.24] forrezao1s DBT GRO 0731 07/22/16 COOPBES® PANDA EXPRESS #562 FRESNO CA Cards 7244 10.74 496.11) 07/22/2018 DBT GRO 0388 07/22/16 00068008 OREILLY AUTO 00028005 FREGNO CA Card# 7244 -7.01 07/22/2018 IDBT CRD 2040 07/21/18 00000837 GOOGLE “‘Minscraft GOOGLE.COM/CHCA Curd 7244 -6.99] 613.83 a7/azr2016 POS DEB 1822 07/22/15 00820886 TRADER JOE §# FRESNO CACard® 7244 1.98 lo7r21/2016 Transfer Requested By: Hussain Al -20.00) 822.80 jo721/2016 DBT CRD 2027 07/20/18 00044638 ACT*Palm Cosst Rec 677-228-4881 CA Card# 7244 -20.00) 07/21/2016 POS DEB 0037 07/21/16 00681642 SEMORAN FOODS ORLANDO FL Carde 7244 =20,00} lo7a1/2016 ‘Mew Image] Depost 882.80) lo720/2018 DBT CRD 0422 07/20/16 00002682 TERRA GAUCHA JACKSONVILLE FL Card# 7244 253.76} lo7ear2018 |POS DEB 1614 07/10/16 00008804 PUBLIX SUPER MAR PALM COAST FL 64.41 Totate: Transactions: 30 Debits: -1,788.43 |Credits: 563.00 file YDOLLAR/Dollar_731.htm! 4A ase st ae 7 nD: From: ‘Hussein. Ali September 10, 2015 5730 N First Street Suite 105-208 Fresno, CA 93710 hali41559@gmail.com To: Jacobson, Hansen & McQuillan 1690 West Shaw Avenue, Suite 201 Fresno, California.93711 Ref Ali vs Dollar 15CEGG02419 Mr. McQuillan Just recelved your motion to require security. | belleve since you think it is going to cost your client extra Moitey’to litigate the’case in Fresno for travel Expenses and so. I will:not have any-objection If you file a motion to transfer thé casé to the-U.S. District Court for the Middle District of Florida In Orlando. By transferring the case‘to the U.S. District court In Orlando-you Cllent-does not have.to:incur the extra expenses that you claim they will. | will have no probiem litigating the case in The U.S. District Court in Orlando Florida. Your atceptanice Is Important $6.1 do not have to file an Objection to your motion. Thank 7) jusseln All ~ ee EXHIBIT 3 Ee nN v7 LEE M, JACOBSON attornep@yiinlamyers.com JACOBSON, HANSEN & MCQUILLAN LEITH B, HANSEN A Profesional Corporation STEVEN M, MCQUILLAN Opies: (359) 448-0400 Fax: (359) 448-0123 JASON A. DECKER Ra W, Shaw Avene, Suite 201 DAVID O. FLEWALLEN DEBORAH NEELY Frosno, California 993411 STEPHEN T. KNUDSEN Office Adwinteratar KRISTINA D, GARABEDIAN September 10, 2015 Hussein Ali 5730 N. First Street, Suite 105-208 Fresno, CA 93710 Re: Fresno County Superior Court No. 15CECG02419 Dear Mr. Alt: lam in receipt of your letter and thank you for your proposal. Unfortunately what you have proposed is procedurally impossible, We therefore have no choice but to require you to post security or dismiss the action you have filed in the Fresno Superior Court. Very truly yours, JACOBSON, HANSEN & McQUILLAN A Professional Corporation DICTATED BUT NOT READ SENT TO AVOID DELAY Steven M. McQuillan (mcq@jhmlawyers.com) SMQ/dp