Securities and Exchange Commission v. Bronson et al

Filing 423

MEMO ENDORSEMENT on PRO SE MOTION TO APPEAR AT HEARING VIA REMOTE ELECTRONIC VIDEO: granting 421 Motion for Leave to Appear. ENDORSEMENT: Granted. SO ORDERED. (Signed by Judge Kenneth M. Karas on 11/22/2022) (ama)

case 7:12-cv-06421-KMK Document 421 Filed 11/16/22 Page 1 of 3

Case 7:12-cv-06421-KMK Document 423 Filed 11/22/22 Page 1 of 3

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

SECURITIES AND EXCHANGE
COMMISSION
Plaintiff
v.

CASE NO. 12 Civ. 6421. 6421

EDWARD BRONSON, E-LIONHEART
ASSOCIATES LLC b/b/a FAIRHILLS CAPITAL
Defendants

And
FAIRHILLS CAPITAL, LLC
Relief Defendant

- - - - - - - - - - - - - - - - - -I
PRO SE MOTION TO APPEAR AT HEARING VIA REMOTE
ELECTRONIC VIDEO.
COMES NOW, Mark E. Pena prose, and moves this Honorable court for an
Order allowing him to appear at the December 12, 2022 Motion for Contempt
Hearing in this matter via remote electronic video (ZOOM) and in support would
state:
1.

In July of 2021, the undersigned was diagnosed with congestive heart failure

by his cardiologist.
2.

Since that time, I have been on a medicine, including seven pills daily, and

dietary and exercise regime in an attempt to avoid another cardiac event.

case 1:1~-cv-06421-KMK Document 421 Filed 11/16/22 Page 2 of 3

Case 7:12-cv-06421-KMK Document 423 Filed 11/22/22 Page 2 of 3

3.

I suffer from extreme loss of breath and can barely walk ten feet before

having to stop and recuperate.
4.

All forms of travel are a hardship and can cause a cardiac event due to the

stress placed on my heart.

5.

I have been called as a witness to testify regarding this matter and I am not a

party.
6.

Whatever testimony I can give can just as easily be made via remote video

live stream third party.
7.

Allowing me to appear remotely causes no party any prejudice.

8.

Counsel for the Securities & Exchange Commission has been made aware of

my motion and has no objection to it as neither does counsel for the Defendant.

9.

I am a practicing attorney but am not representing anyone as an attorney in

this matter and am not licensed before the Southern District ofNew York

WHEREFORE, I would respectfully request that this Honorable Court Grant my
motion and
allow me to appear and testify via remote electronic means.

Respectfully Submitted,
Isl Mark E. Pena
Pro Se
4230 So. MacDill Ave, Suite I
Tampa, FL. 33611
Telephone: [phone]

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Case 7:12-cv-06421-KMK Document 423 Filed 11/22/22 Page 3 of 3

Facsimile: [phone]

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing
has been furnished via electronic mail to Plaintiff at [e-mail] and to the
Defendant at Paul Rachmuth [e-mail] on this 16th day ofNovember, 2022.

Isl Mark E. Pena
MARKE. PENA, ESQUIRE