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.

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 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.

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As well as others in the plaintiff’s presence

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 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: river9000@yahoo.com

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

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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

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 _/s Chris Ryder_____________________-

Chris Ryder September 1, 2010