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J. Henk Taylor (016321)

RYAN RAPP & UNDERWOOD, P.L.C.

3200 N. Central Ave, Suite 2250

Phoenix, Arizona 85012

Telephone: (602) 280-1000

Facsimile: (602) 265-1495

Email: htaylor@rrulaw.com 

Jeffrey M. Eilender (admitted pro hac vice)

Bradley J. Nash (admitted pro hac vice)

Joshua Wurtzel (admitted pro hac vice)

SCHLAM STONE & DOLAN LLP

26 Broadway

New York, New York 10004

Telephone: (212) 344-5400

Facsimile: (212) 344-7677

E-Mail: jeilender@schlamstone.com 

E-Mail: bnash@schlamstone.com 

E-Mail: jwurtzel@schlamstone.com 

Attorneys for Defendants CWT Canada II Limited

Partnership, Resource Recovery Corporation, and

Jean Noelting

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

Wells Fargo Bank, N.A.

Plaintiff,

v.

Wyo Tech Investment Group, LLC, CWT 

Canada II Limited Partnership, Resources 

Recovery Corporation, and Jean Noelting,

Defendants.

Case No.: 2:17-CV-04140-DWL

CWT PARTIES’ EX PARTE

MOTION FOR LEAVE TO MAKE 

ALTERNATIVE SERVICE OF 

SUBPOENAS ON NONPARTY 

DENNIS M. DANZIK

Oral Argument Requested

And related claims.

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-iTABLE OF CONTENTS

Page

PRELIMINARY STATEMENT.......................................................................................... 1

STATEMENT OF FACTS................................................................................................... 2

ARGUMENT........................................................................................................................ 9

CONCLUSION .................................................................................................................. 12

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Defendants CWT Canada II Limited Partnership, Resource Recovery Corporation, 

and Jean Noelting (collectively, the “CWT Parties”) move this Court under Fed. R. Civ. P.

1 and 45 for entry of an order granting them leave to serve subpoenas for documents and 

testimony by alternative methods on nonparty Dennis M. Danzik. This motion is 

supported by the following memorandum of points and authorities and the Declaration of 

Joshua Wurtzel.

MEMORANDUM OF POINTS AND AUTHORITIES

PRELIMINARY STATEMENT

In this motion, we ask this Court to grant us leave to serve Mr. Danzik with 

subpoenas for documents and testimony by alternative methods—specifically, by 

overnight mail to his office and self-proclaimed home address, by e-mail to his e-mail 

account, and by e-mail to his Wyoming, New York, and Arizona counsel. As explained 

below, Mr. Danzik has been evading service of these subpoenas since April, and is well 

aware that we have been trying to subpoena him. Indeed, as explained below in greater 

detail, our process servers went to great lengths to attempt to serve Mr. Danzik in both 

Arizona (where he works) and Wyoming (where he claims to live). During these efforts, 

our Arizona server even spoke with Mr. Danzik by phone, who pretended to make 

arrangements to accept service in Wyoming. But despite our best efforts, we were unable 

to serve Mr. Danzik with a subpoena returnable in Arizona. And while we did serve him 

with a subpoena returnable in Wyoming, we believe Mr. Danzik no longer lives or 

regularly travels to Wyoming, so enforcement action against him there on the subpoena 

we already served (which Mr. Danzik disregarded) is likely to be futile.

This Court may “‘allow substitute service of a Rule 45 subpoena, such as mail 

delivery, so long as the method of service is reasonably calculated to provide timely, fair 

notice and an opportunity to object or file a motion to quash.’” In re: Ex Parte Application 

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of Pro-Sys Consultants & Neil Godfrey, 2016 WL 6025155, at *2 (N.D. Cal. Oct. 14, 

2016) (citation omitted). Thus, given that Mr. Danzik is a critical witness in this action, 

and given our extensive efforts to serve him in accordance with Fed. R. Civ. P. 45(b)(1), 

this Court should authorize alternative service on Mr. Danzik.

STATEMENT OF FACTS

On January 12, 2018, Wyo Tech served its MIDP responses, identifying Mr. 

Danzik as a person with relevant, discoverable information, and listing Mr. Danzik’s 

address as c/o Dennis Wilenchik of Wilenchik & Bartness—Wyo Tech’s counsel in this 

action. Wurtzel Decl. Ex. A. Wilenchik & Bartness also previously represented Mr. 

Danzik in (1) the case captioned CWT Canada II Limited Partnership, et al. v. Danzik, et 

al., Case No. 16-cv-607-PHX-DGC—which is a consolidated action pending in this 

District, and in which Mr. Danzik’s claims against the CWT Parties were dismissed on 

January 26, 2018; (2) the judgment-enforcement action captioned CWT Canada II Limited 

Partnership, et al. v. Danzik, et al., CV2017-005401, which is pending in Maricopa 

County Superior Court; (3) the underlying New York State action in which the CWT 

Parties got their judgment against Mr. Danzik, captioned GEM Holdco, LLC, et al. v. 

CWT Canada II Limited Partnership, et al., Index No. 650841/2013—in which Mr. 

Wilenchik was recently admitted pro hac vice and remains as Mr. Danzik’s counsel; and 

(4) Mr. Danzik’s most-recent bankruptcy case, captioned In re Danzik, Case No. 19-

20116—which was dismissed on June 24, 2019, and in which Mr. Wilenchik was recently 

admitted pro hac vice. Id. ¶ 3.

On February 3, 2019, we served Wyo Tech’s counsel with a Rule 30 deposition 

notice for Mr. Danzik’s deposition. Id. Ex. B.

On February 21, 2019, Wyo Tech’s counsel told us that “Dennis Danzik is not an 

employee of Wyo Tech and therefor under the rules will need to be subpoenaed if you 

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want to take his deposition.” Id. Ex. C.

Later that day, we responded, stating that Wyo Tech’s MIDP responses listed Wyo 

Tech’s counsel as the care-of address for Mr. Danzik, and asking Wyo Tech’s counsel to 

either confirm that it would accept service of a subpoena on Mr. Danzik or provide Mr. 

Danzik’s home and business addresses. Id.

Getting no response, we followed up with Wyo Tech’s counsel on February 26, 

2019, and again on February 27, 2019. Id. Finally, later on February 27, Wyo Tech’s 

counsel responded, refusing to accept service or provide Mr. Danzik’s home or business 

address, and stating: “Josh: We do not represent him and therefore cannot accept service. I 

am unaware of his current address but you may be able to find it in other court filings in 

cases you are involved in. I am unaware of any rule that would require me to attempt to 

figure that out for you.” Id.

This response was intended to obstruct our efforts to take critical discovery in this 

case. Indeed, in previous testimony in other cases, Mr. Danzik refused to answer questions 

about where he lived—claiming that he did not know his own address. Id. Ex. D at 15:21-

24. And in response to a question about where he was located during his video deposition

in the related federal case listed above, Mr. Danzik’s counsel there, Dennis Wilenchik, 

frivolously stated: “I’m going to object and instruct him, he doesn’t have to answer that 

question and he can invoke his Fifth Amendment right, considering that you are trying to, 

as I understand it, arrest him, so that’s my instruction to him.” Id. Ex. E at 5:13-22.

In response to Wyo Tech’s counsel’s response in this case, we then pointed out 

that, according to his most-recent bankruptcy case, Mr. Danzik is employed by the same 

people who run Wyo Tech, e.g., Wyo Tech CEO Bill Hinz, so Wyo Tech must know 

where Mr. Danzik lives and works. Id. We further demanded that Wyo Tech amend its 

MIDP responses to include these addresses. Id.

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But Wyo Tech’s counsel still refused to cooperate, claiming that “[i]t is my 

understanding at this time that Wyo Tech does not know this information.” Id.

On March 4, 2019—after further demands—Wyo Tech amended its MIDP 

responses to state that it is “currently unaware of Dennis Danzik’s physical residential 

address.” Id. Ex. F.

Upon receiving this amended response, we asked Wyo Tech to identify Mr. 

Danzik’s business address, since Wyo Tech’s amended MIDP response conspicuously 

referred only to Mr. Danzik’s “physical residential address.” Id. ¶ 9. Wyo Tech’s counsel 

stated that they would get back to us on this, but did not promptly do so. Id. ¶ 9.

On April 12, 2019, in advance of a meet and confer, we followed up, again 

demanding that Wyo Tech provide Mr. Danzik’s business address—emphasizing again 

that Wyo Tech’s CEO, Bill Hinz, regularly works with Mr. Danzik. Id. Ex. G. On April 

15, 2019, the parties’ counsel held a meet and confer, during which Wyo Tech’s counsel 

agreed to ask Mr. Hinz if he knows Mr. Danzik’s business and home addresses and, if so, 

provide them to us. Id.

After some follow up, on April 18, 2019, Wyo Tech’s counsel responded, stating 

that, “[t]he last known business address for Dennis Danzik, according to Hinz is: 7543 E 

Tierra Buena Ln., Scottsdale, AZ 85260,” but that Mr. Hinz “does not know what his 

home address is.” Id.

On April 22, 2019, our process server attempted service at this Scottsdale address, 

but was unsuccessful. Id. Ex. H. Specifically, the server buzzed the intercom bell at the 

building and asked the woman who answered for Mr. Danzik; the woman asked why the 

server was there, to which the server said that he had a subpoena for Mr. Danzik. Id. But 

the woman then claimed that Mr. Danzik “did not office” out of this building, and hung up 

on the server. Id. The woman refused to provide her company name or business card. Id.

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Also on April 22, 2019, another process server attempted service at Mr. Danzik’s 

purported home address in Cody, Wyoming. Id. Ex. I. This is the home address that Mr. 

Danzik listed on his most-recent bankruptcy petition, though this home has been in 

foreclosure for years, and we do not believe that Mr. Danzik regularly lives there any 

more. Id. ¶ 12. When the server arrived, she encountered an older man, who identified 

himself as the caretaker and who said that Mr. Danzik was not there. Id. Ex. I. This 

caretaker also said that he never knows when Mr. Danzik is coming to Cody until a week 

or less before he arrives. Id.

On April 23, 2019, our process server again attempted service at the Cody, 

Wyoming address. Id. This time, no one responded to the server’s knocks at the door. The 

server then returned about an hour later, but again no one answered the door. Id. The 

server placed her business card on the front door of the house. Id.

On April 26, 2019, our process server made a second attempt at the Scottsdale 

address. Id. This time, the server noticed a dumpster in the back of the building “labeled 

with the names of Danzik Applied Sciences and Inductance Energy Corp.” Id. Ex. H.

Thus, we are confident that—as Wyo Tech’s counsel told us—this is Mr. Danzik’s 

business address. The server then buzzed the intercom bell again and asked for Mr. 

Danzik. Id. The woman who answered asked whether the server had an appointment with 

him, and when the server said he did not and that he had a subpoena for Mr. Danzik, the 

woman again claimed that he “did not office” out of this building. Id. The woman refused 

to provide any contact information for Mr. Danzik. Id. The server then left a note with his 

own contact at the door of the building and asked the woman to pass it along to Mr. 

Danzik. Id.

On April 27, 2019, our process server again attempted service at the Cody, 

Wyoming address. Id. Ex. I. The server’s business card—which she left on April 23—had 

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been removed from the front door. Id. But there was no answer at the door again. Id.

On April 29, 2019, Mr. Danzik called our Arizona process server’s cell phone—

presumably in response to the note our server left at his office on April 26. Id. Id. Ex. H. 

In response to Mr. Danzik’s call, our server told Mr. Danzik that he had a subpoena for 

him—to which Mr. Danzik responded that he was traveling in Nevada and that we should 

serve him at his home at 1334 Sunset Boulevard, South Cody, Wyoming 82414. Id. Mr. 

Danzik further stated that he may be at his home in Cody around May 13, 2019, and that 

we should call him at that time. Id.

Later on April 29, our process server attempted service at Mr. Danzik’s office in 

Scottsdale. Id. Ex. H. But this time, there was no answer at the buzzer. Id.

On May 10, 2019—in response to Mr. Danzik’s phone call with our Arizona 

process server—our Wyoming process again attempted service at the Cody, Wyoming 

home, but no one was there. Id. Ex. I.

On May 11, 2019, our process server again attempted service at the Cody, 

Wyoming home. Id. No one was there again, and the server left a note on the door for Mr. 

Danzik to call her. Id. The server then called the phone number from which Mr. Danzik 

called our Arizona server, but Mr. Danzik did not answer and the voicemail was not set 

up. Id.

On May 12, 2019, our process server again returned to the Cody, Wyoming home. 

Id. This time, the caretaker was there, and he said that he had sent Mr. Danzik our 

Wyoming server’s business card but had no further indication that Mr. Danzik was 

coming into town. Id.

On May 13, 2019, our process server again made two separate service attempts at 

the Cody, Wyoming home. Id. The server also called Mr. Danzik’s phone, but again he 

did not answer and there was no voicemail set up. Id.

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On May 13 and 15, 2019, our Wyoming process server sent text messages to Mr. 

Danzik at the phone number from which he called our Arizona server. Id. But Mr. Danzik 

did not respond. Id.

Later on May 15, our process server made another service attempt at the Cody, 

Wyoming home, but no one was there. Id.

Mr. Danzik never reached out to our Wyoming process server in response to her 

numerous calls and text messages. Id. Thus, when Mr. Danzik called our Arizona server, 

he likely had no intent of cooperating to accept service, and instead was attempting to 

cause us delay and additional expense in trying to serve him. 

On May 15, 2019, the Wyoming bankruptcy court held an evidentiary hearing on 

our motion to dismiss Mr. Danzik’s bankruptcy case. Hunsicker Decl. ¶ 2. Mr. Danzik 

appeared for and testified at this hearing in Cheyenne, Wyoming (six hours from Cody, 

Wyoming)—which was the first time he physically attended a hearing in Wyoming 

bankruptcy court in the three bankruptcies that he filed since 2016. Id. ¶ 3. At the end of 

that hearing, while he was still in the courtroom, our Wyoming bankruptcy counsel 

handed Mr. Danzik a copy of the subpoenas for documents and testimony that we had 

been trying to serve on Mr. Danzik since April. Id. ¶ 4. This subpoena required Mr. 

Danzik to produce documents by May 24, 2019, and to appear for a deposition on June 4, 

2019. Id. Ex. A.

But critically, we inadvertently had our Wyoming bankruptcy counsel hand Mr. 

Danzik only the copies of the subpoenas that were returnable in Wyoming, rather than the 

(substantively-identical) ones returnable in Arizona. Wurtzel Decl. ¶ 14. This is 

significant, because as explained above, we believe that Mr. Danzik no longer lives in 

Wyoming, and instead works primarily in Arizona. Wurtzel Decl. ¶ 14. Thus, while we 

could enforce the subpoena we served on him in Wyoming, those enforcement efforts will 

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likely end up being futile, given that Mr. Danzik no longer lives there and seems to travel 

there only rarely as well. Id. ¶ 14.

On May 17, 2019, Wyo Tech’s counsel asked us to consent to asking this Court to 

adjust the date or time of this Court’s show-cause hearing on our contempt motion against 

Wilenchik & Bartness and Beus Gilbert. Id. Ex. J. We agreed, but noted that one of the 

alternate dates they proposed—June 4, 2019—was the date set for Mr. Danzik’s 

deposition in the subpoena we served on him. Id. After some back and forth, we agreed to 

list June 4 as an alternate date for the show-cause hearing, but only if Wyo Tech’s 

counsel—which, as explained above, previously represented Mr. Danzik (and was then

also representing Mr. Danzik in his Wyoming bankruptcy and in the New York action)—

worked with Mr. Danzik to secure an alternate date for his deposition. Id. Wyo Tech’s 

counsel then said that it would work with Mr. Danzik’s other Wyoming bankruptcy 

counsel to secure an alternate date. Id.

On May 21, 2019, Wyo Tech’s counsel wrote to us that he “checked as a courtesy 

as promised,” and that Mr. Danzik “will be in touch re his deposition date.” Id. Ex. K. But 

Mr. Danzik did not produce any documents in response to our subpoena, nor did he ever 

reach out to us to arrange an alternate deposition date. Id.

Thus, on June 5, 2019, we e-mailed Mr. Danzik—at the e-mail address he uses—

demanding that he produce documents in response to the subpoena by June 7, 2019, and 

also give us some available alternate deposition dates in July and August. Id. We copied 

Wyo Tech’s counsel on this e-mail. Id. But neither Mr. Danzik nor Wyo Tech’s counsel 

responded to this e-mail. Id. ¶ 16. Nor has Mr. Danzik—to date—produced any 

documents in response to this subpoena or reached out to us to arrange an alternate 

deposition date. Id.

As this Court knows, the critical issue in this case is whether Mr. Danzik has an 

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interest in the interpleaded funds that were previously held in Wyo Tech’s account at 

Wells Fargo. Mr. Danzik’s document production and testimony are thus critical. And as 

explained above, while we could seek to enforce these subpoenas against Mr. Danzik in 

Wyoming, those efforts would likely be futile, since Mr. Danzik no longer lives there and 

seems to seldom travel there.

Further, as a practical matter, Wyo Tech could produce Mr. Danzik if it wanted to. 

Indeed, though Wyo Tech claims that Mr. Danzik no longer works for it, we understand 

that Mr. Danzik works for Inductance or other related companies. Id. ¶ 17. We also 

understand that Inductance is merely the purported operating entity that leases technology 

that Danzik purportedly created from Wyo Tech, and that any other related companies are 

similarly related to Wyo Tech and Inductance and are all run by the same people—

specifically, Messrs. Hinz and Danzik. Id. ¶ 17. And critically, Mr. Danzik submitted a 

declaration in support of Wyo Tech’s position when this case began. Id. Ex. L. Thus, 

while—in this motion—we seek only leave to make alternative service of a subpoena 

returnable in Arizona on Mr. Danzik, we reserve the right to seek an order of preclusion 

against Wyo Tech if we cannot secure Mr. Danzik’s document production and testimony.

ARGUMENT

Under Rule 45(b)(1), serving a subpoena requires “delivering a copy to the named 

person.” The Ninth Circuit has not yet decided whether a court may authorize alternative 

service under Rule 45(b)(1), but there is a “‘growing—although still minority—trend 

among courts to allow substitute service of a Rule 45 subpoena, such as mail delivery, so 

long as the method of service is reasonably calculated to provide timely, fair notice and an 

opportunity to object or file a motion to quash.’” In re: Ex Parte Application of Pro-Sys 

Consultants & Neil Godfrey, 2016 WL 6025155, at *2 (citation omitted).

Though we did not locate any decision in this District dealing with this issue, as a 

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matter of first impression, this Court should follow this “growing trend” and authorize 

alternative service on Mr. Danzik. Indeed, the Rules of Civil Procedure “should not be 

construed as a shield for a witness who is purposefully attempting to evade service.” Toni 

Brattin & Co. v. Mosaic Int’l, LLC, 2015 WL 1844056, at *4 (N.D. Cal. Apr. 9, 2015). 

And “Rule 45 should be construed as provided in Rule 1 ‘to secure the just, speedy, and 

inexpensive determination of every action,’ which would allow for alternate means of 

service.” Id.

Further, the text of Rule 45(b)(1) “does not unequivocally require delivery by 

hand-to-hand exchange”; instead, “service ‘requires delivering a copy’ of the subpoena to 

the witness.” OceanFirst Bank v. Hartford Fire Ins. Co., 794 F. Supp. 2d 752, 754 (E.D. 

Mich. 2011). Thus, the “method of delivery is not specified,” and “[w]hen hand-to-hand 

delivery is required, the rules generally indicate that requirement by designating 

‘personal’ service.” Id. Rule 45(b)(1) does not require “personal” service on a nonparty.

Moreover, cases holding that service made by alternative methods was improper 

under Rule 45(b)(1) often do not involve a motion for leave to make alternative service—

and instead merely reject a party’s unilateral efforts to serve a nonparty by alternative 

methods. See Casun Invest, A.G. v. Ponder, 2019 WL 2358390, at *3 (D. Nev. June 4, 

2019) (“The safest course of action when a party is unable to effectuate personal service, 

is to file a motion for leave to serve the subpoena by alternative means.”). Here, the CWT 

Parties seek leave to make alternative service.

Further, “‘[c]ourts are more inclined to grant such alternative service where the 

serving party has provided sufficient evidence of its earlier diligence in attempting to 

effectuate personal service.’” Chambers v. Whirlpool Corp., 2016 WL 9451361, at *2 

(C.D. Cal. Aug. 12, 2016) (citation omitted). As explained above, the CWT Parties made 

extensive—and certainly diligent—efforts to serve Mr. Danzik with subpoenas for 

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documents and testimony in this case, and he is undoubtedly aware of these subpoenas.

Finally, though this motion is made on notice to Wyo Tech, we labeled this an ex 

parte motion because Wyo Tech has no standing to oppose this motion. Indeed, “[a] party 

has standing to challenge a subpoena served on another entity only if the party can show it 

has a personal right or privilege regarding the subject matter of the subpoena.” Cheatwood 

v. Christian Bros. Servs., 2018 WL 287389, at *1 (D. Ariz. Jan. 4, 2018). And neither a 

party nor a party’s counsel has standing to “object to the grant of leave to alternative 

service” on a nonparty, especially when that counsel “does not represent” the nonparties. 

UnitedHealth Grp., Inc. v. United Healthcare, Inc., 2014 WL 4635882, at *1 (D. Nev. 

Sept. 16, 2014).

The alternative method of service must be “reasonably calculated under the 

circumstances to provide” Mr. Danzik with both “notice and an opportunity to present 

objections.” Toni Brattin & Co., 2015 WL 1844056, at *4. Thus, this Court should grant 

the CWT Parties leave to serve Mr. Danzik by: (1) overnight FedEx to his purported home 

at 1334 Sunset Boulevard, Cody, Wyoming 82414; (2) overnight FedEx to his office at 

7543 East Tierra Buena Lane, Scottsdale, Arizona 85260; (3) e-mail to his e-mail address 

at dmdanzik@gmail.com; and (4) e-mail to his Wyoming bankruptcy counsel, Ken 

McCartney; his New York counsel, Jacques Catafago and Tom M. Fini; and Wyo Tech’s 

counsel (who was and is Mr. Danzik’s counsel in other matters), Dennis M. Wilenchik. 

Given that Mr. Danzik is already aware of the subpoenas we have been trying to serve on 

him, and given that these attorneys are all regularly in touch with Mr. Danzik, these 

methods are “sufficient to ensure that [Mr. Danzik] has knowledge of and actually 

receive[s] the subpoena[].” Chambers, 2016 WL 9451361, at *3; see also In re: Ex Parte 

Application of Pro-Sys Consultants & Neil Godfrey, 2016 WL 6025155, at *2 (granting 

leave to serve subpoena by “overnight courier” to deponent’s residence when deponent 

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refused to accept service and was “attempting to evade personal service”).

CONCLUSION

This Court should grant the CWT Parties leave to serve Mr. Danzik with subpoenas 

for documents and testimony in this action, returnable in Phoenix, Arizona, by 

(1) overnight FedEx to his purported home at 1334 Sunset Boulevard, Cody, Wyoming 

82414; (2) overnight FedEx to his office at 7543 East Tierra Buena Lane, Scottsdale, 

Arizona 85260; (3) e-mail to his e-mail address at dmdanzik@gmail.com; and (4) e-mail 

to his Wyoming bankruptcy counsel, Ken McCartney; his New York counsel, Jacques 

Catafago and Tom M. Fini; and Wyo Tech’s counsel (who was and is Mr. Danzik’s 

counsel in other matters), Dennis M. Wilenchik.

Case 2:17-cv-04140-DWL Document 173 Filed 07/08/19 Page 14 of 16
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Dated:July 8, 2019

Phoenix, Arizona

Respectfully submitted,

RYAN RAPP & UNDERWOOD, P.L.C.

By: /s/ Henk Taylor (016321)

J. Henk Taylor (016321)

3200 N. Central Ave., Suite 1600

Phoenix, Arizona 85012

Telephone: (602) 280-1000

Facsimile: (602) 265-1495

E-Mail: htaylor@rrulaw.com

SCHLAM STONE & DOLAN LLP

Jeffrey M. Eilender (admitted pro hac 

 vice)

Bradley J. Nash (admitted pro hac vice)

Joshua Wurtzel (admitted pro hac vice)

26 Broadway

New York, New York 10004

Telephone: (212) 344-5400

Facsimile: (212) 34407677

E-Mail: jeilender@schlamstone.com

E-Mail: bnash@schlamstone.com

E-Mail: jwurtzel@schlamstone.com 

Attorneys for Defendants CWT Canada II 

Limited Partnership, Resource Recovery 

Corporation, and Jean Noelting

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ORIGINAL e-filed and COPIES

e-mailed this 8th day of July

2019 as follows:

Dennis I. Wilenchik

Tyler Swenson

Chris Meyers

WILENCHIK & BARTNESS P.C.

2810 North Third Street

Phoenix, AZ 85004

E-Mail: diw@wb-law.com

E-Mail: tylers@wb-law.com

E-Mail: chrism@wb-law.com

Leo R. Beus

BEUS GILBERT PLLC

701 North 44th Street

Phoenix, AZ 85008

E-Mail: lbeus@beusgilbert.com

Attorneys for Wyo Tech Investment 

Group, LLC

/s/ Henk Taylor 

J. Henk Taylor

Case 2:17-cv-04140-DWL Document 173 Filed 07/08/19 Page 16 of 16