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| FL ___ RECEIVED | ile . — SERVED ON | een i rate pograd, COUNSELIPARTIES OF RECORD | 2 | BURN AND WEDGE eil Rd., Ste. 500 fn 3|P.0. Box 2311 FEB 13 2029 Reno, NV 89505 4 | Tele: (775) 688-3000 CLERK US DISTRICT COURT | Fax: (775) 688-3088 DISTRICT OF NEVADA 5 | [email protected] BY; CEPT 6 | Attorney for Plaintiff Christopher Bruneau 7 | UNITED STATES DISTRICT COURT rip 8| DISTRICT OF NEVADA boar 9 | CHRISTOPHER BRUNEAU, ) Case No. 3:19-cv-00634-MMD-CBC 10 Plaintiff, REQUEST FOR AMENDED EX PARTE | v. } ORDER FOR PUBLICATION □□ ll | COUNTRYWIDE MOVING PLUS, LLC: (1st Request to amend 1-22-2020 Order) 12 | SUPREME VAN LINES; and DOES |-X, ) | inclusive, \ 13 | Defendant(s). ) 14 | 15] Plaintiff CHRISTOPHER BRUNEAU (‘Plaintiff’), by and through his counsel of 16 | record, Ellen Jean Winograd, Esq. of the firm of Woodburn and Wedge, pursuant to LR IA 17 | 6-1 and FRCP 4(m) and 6(b), hereby requests an amendment of this Court's Order 18 | Allowing Service of Process by publication. 19 This ex parte motion is based on the accompanying Points and Authorities, the 20 | Declaration of Ellen Jean Winograd, Esq., previously filed on January 14, 2020 [Doc 11], 21 |the January 17, 2020 and January 22, 2020 Orders [Doc 13, 16] and all papers and 22 | pleadings on file herein. 23 |I. INTRODUCTION 24 | The instant matter arises from an interstate shipment of household goods from 25 | Reno, Nevada to Knoxville, Tennessee. The entire load was lost or destroyed in shipment. 26 | This matter is governed, inter alia, by Chapter 49 of the United State code. This Court has 27 | jurisdiction over this matter pursuant to

;1331 and 1367. 28 | The instant motion arises after this court previously ordered that Plaintiff may |

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1 | publish the Summons and Complaint in the Miami Herald [Doc 16}. 2|1. ARGUMENT 3 | On October 17, 2019 Plaintiff Christopher Bruneau filed suit against Countrywide 4 | Moving Plus, LLC and Supreme Van Lines. After numerous efforts to serve Defendants as 5 | set forth in Plaintiff's January 14, 2020 Ex Parte Motion to Extend Time to Serve Summons 6 | and Complaint and Ex Parte Motion for Order to Serve Defendants by Publication, this 7 | Court entered an Order granting the extension of time in which to serve Defendants, but 8 | denying the Motion because the name of the proposed publication was inadvertently 9 | omitted. [Doc 13] On January 22, 2020, pursuant to Motion, this Court granted Plaintiff's 10 | request for an Order allowing publication. [Doc 16] 11 | The publication designated in the January 22, 2020 Order was the Miami Herald. 12 | Plaintiff now seeks an amendment of the Order to allow the publication to occur in the 13 | Broward Daily Business Review for two reasons. 14 | First, the Broward Daily Business Review appears to be a business publication, 15 better suited to cover the geographic area in which both Defendants are physically located. 16 | Second, the price difference between publication in the Miami Herald ($1,672.68) and the 17 | Broward Daily Business Review ($306.40) see statements from Miami Herald and Broward 18 | Daily Business Review, submitted herewith as Exhibits 8 and 9. This price difference is 19] i 20 | 21 1 22.1 1) 23 Vl 24 V1 25 i 26 | 1 27 11 28 1 |

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1 | significant and in the interest of judicial economy, Plaintiff requests that the Order be 2 | modified to allow publication in the Broward Daily Business Review. 3 | RESPECTFULLY SUBMITTED this _// day of February 2020. 4 | WOODBURN AND WEDGE | . 6 2 By: Lach A herd Elleh’Jean Wiftdgrad, Esq. 7) Nevada State Bar No. 815 | 6100 Neil Rd., Ste. 500 8 Reno, NV 89505 [email protected] 9 Attorney for Plaintiff Christopher Bruneau 10 IT IS SO ORDERED:

12 | . ited States Magistrate Judge 13) DATE: B/ZOP EP 14 15 DECLARATION 16 1. Declarant, Ellen Jean Winograd, is an attorney duly licensed to practice law in 17 | Nevada and is attorney for Plaintiff Christopher Bruneau herein. 18] 2. All exhibits attached hereto are true and correct copies of the documents they 19 | purport to be. 20} 3. Declarant executes this declaration under penalty of perjury. 21 | 22| Ai 23 | Ellen Jean Winograd, Esq. Nevada State Bar No. 815 24 | 6100 Neil Rd., Ste. 500 5 Reno, NV 89505 | [email protected] 26 | Attorney for Plaintiff Christopher Bruneau 27 | 28 |

WVdAoe V.Le UU0DOS WINVIL □□ LD UUUUTTICIIL Sh PURO Veit □□□ Pays FT Viv 1] CERTIFICATE OF SERVICE 2 | Haleigh Valenta, being first duly sworn, deposes and says: 3 | 1. Affiant is over 21 years of age, and not a party to the within action. 41 2. On February 12, 2020, Affiant mailed the Request for Amended Ex Parte Order for 5 | Publication, enclosed in sealed envelopes, certified mail return receipt requested, and 6 | postage prepaid, addressed to the last known addresses of Defendants as follows:

g Resident Agent | c/o Supreme Van Lines, Inc. 9 1411 NE 2nd Avenue | Hallendale, FL 33009 10 | | Conor Slaight, Resident Agent 11} fo Countrywide Moving Plus, LLC 12 | 1119 New Lake Drive | Boynton Beach, FL 33426 13 | | Supreme Van Lines, Inc. 14 | Attn: Claims 201 King of Prussia Road, Suite 650 15 | Randor, PA 19087 16 | Countrywide Moving Plus, LLC 17 | 4701 North Federal Highway, Suite 430 Lighthouse Point, FL 33064 18 | 19 | Affirmation 20 | The undersigned affirms that this document does not contain the Social Security | number of any person. 22 33 | ignature 24| 25 | 26 |

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1| EXHIBIT LIST 2] 8. Miami Herald statement □□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□ 2 PAGES 3 | 9. Broward Daily Business Review statement □□□□□□□□□□□□□□□□□□□□□□□□□□□ 1 page 4} 6| 7] 9} 10 12| i3| 14] 15] 16 | 17] 18 20 | 21 □□ □ 23 | 24 | 26 27 | 28 |

EXHIBIT 8

EXHIBIT 8

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Order Confirmation Customer Payor Customer WOODBURN AND WEDGE WOODBURN AND WEDGE Customer Account Payor Account 767563 767563 Customer Address Payor Address 6100 NEIL RD., STE 500 6100 NEIL RD., STE 500 RENO NV 89511 USA RENO NV 89511 USA Customer Phone Payor Phone 775-688-3051 775-688-3051 Customer Fax Customer EMail Sales Rep Order Taker [email protected] [email protected] PO Number Payment Method Blind Box Tear Sheets Proofs Affidavits legal notice Credit Card 0 0 1 NetAmount Jax Amount Total Amount Payment Amount Amount Due $1,672.68 $0.00 $1,672.68 $0.00 $1,672.68 Ad Order Number Order Source Ordered By Special Prictn 0004554638 Haleigh Valenta Invoice Text Promo Type legal notice Package Buy Materials

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AAD Ds he FOU VOTIVE EVE Nr Bh EA I NN nl REN ew Ad Order Information Ad Number Ad Type Productlon Method Production Notes 0004554638-01 MIA-CL Liner AdBooker External Ad Number Ad Attributes Ad Released Pick □□ No Ad Size : Color 1X Product Placement Times R hedute Cost MIA-Miami Herald 0300 - Legals Classified 4 $1,672.68 Run Schedule Invoice Text Position CHRISTOPHER BRUNEAU, Plaintiff, v. COUNT 0301 - Legals & Public Notices Run Dates 02/06/2020, 02/13/2020, 02/20/2020, 02/27/2020

CHRISTOPHER BRUNEAU, Plaintiff, ve COUNTRYWIDE MOVING PLUS, LLC; SUPREME VAN LINES; and DOES |-x, inclusive, Defendant(s) Gase No. 3:16-cv-00634-MMD- CBC A lawsuit has been filed against you, The claims asserted against you include a violation of federal law pursuant to

for joss of house- hold goods, and fraud, and the relief Sought includes compen- satory and punitive damages, an award of reasonable attor- ney’s fees and costs, damages, and interest for any damages awarded, Within 21 days atter service of this summons on you (not counting the day you re- ceived it) — or 60 days if you are the United States or a Unit- ed States agency, or an officer or employee of the United States described in Fed. R. Civ. P.12 (2X2) or {3} sai must serve on the plaintiff an answer to the attached complaint ora motion under Rule 12 of the Federa! Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plain- tiff's attorney, whose name and address are: Ellen Jean Winograd Woodburn and edge 6100 Neil Rd., Ste 50 Reno, NV 89511 If you fail to respond, judgment by default will be entere against you for the relief de- manded in the complaint. You also must file your answer or motion with the court. NRCP 4.4(c)(2)(C).

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EXHIBIT 9

EXHIBIT 9

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Public Notice Order Confirmation Ad Text This is not an Invoice Case No. 3:16-cv-00634-MMD-CBC CHRISTOPHER BRUNEAU, Plaintiff, ve COUNTRYWIDE MOVING PLUS, Daily Business Review LLC; SUPREME VAN LINES; and DOES !-X, Inclusive, Defendant(s) A lawsuit has been filed against Zone: Florida - Broward you, The claims asserted against you Include a violation of federal law pursuant to

for . loss of household goods, and fraud, Ad Order #: 0000465860 and the relief sought includes com- pensatory and punitive damages, an . award of reasonable attomey's fees Account #: 9045476 and costs, damages, and interest for any damages awarded, Within 21 days after service of this summons Acet Name: WOODBURN AND WEOGE on you {not counting the day you received it) - or 60 days If you are the United States or a United States PO #: 3:16CV-00834-MMD-CBC agency, or an officer or employee of the United States described in Fed, R. Clv. P. 12 (a\(2) or (3) - you must Phone: 775-688-3051 serve on the plaintiff an answer to the atlached complaint or a motion under Rute 12 of the Federal Rules Placement: Other Notices of Civil Procedure. The answer or motion must be served on the plalntiff or plaintiff's attomey, whose name Miscel! Notl and address are: Position: ecellaneous / Other Notices Ellen Jean Winograd Woodbum and Wedge . 6100 Nall Rd., Ste 600 Ad Size: §,08 inches Reno, NV 89511 if you fall to respond, judgment by dafault will be entered against Run Dates: 02/11, 02/16, 02/26, 03/03 you for the rellef demanded in the complaint. You also must file your answer or motion with the court. Firm Intemal #: NRCP 4.4(c)(2)(C). 9/11-18-25 3/3 20-68/0000465860B PO# 2: Amount Due: 306.40