Michael Ferguson
34322 Hourglass Street
Temecula, CA 92592
MICHAEL FERGUSON, IN PRO PER
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN DIEGO- CENTRAL COURTHOUSE
COUNTY OF SAN DIEGO,
Petitioner
vs.
MICHAEL FERGUSON,
Respondent
vs.
RANDI BAKER,
Other Parent
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Case No.: DF282267
EX PARTE APPLICATION FOR
REQUEST FOR A THREE DAY
HEARING
Date: 9/28/23
Time: 1:45 p.m.
Dept: 603
Judge: Honorable Laura H. Miller
Respondent MICHAEL FERGUSON hereby applies for a Three-Day Hearing. The
application is made on the ground(s) that Respondent needs to challenge and counter all of Randi
Baker’s documents filed as Exhibits, and averments therein. Respondent could not make this request
by noticed motion because the Order requested herein needs to be expedited so that all the parties in
this action get sufficient notice of the three-day hearing. Proceeding via a noticed motion would
possibly subject the instant application to unnecessary objection from either Randi Baker or the
County of San Diego, as Petitioner.
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EX PARTE REQUEST FOR A THREE-DAY HEARING
This application is based on the declaration of Respondent, Michael Ferguson, and supporting
memorandum served and filed herewith, on the papers and records on file herein, and on such oral
and documentary evidence as may be presented at the hearing, if any, on the application.
Dated: ________
_________________________________
Signature
Michael Ferguson, In Pro Per
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EX PARTE REQUEST FOR A THREE-DAY HEARING
DECLARATION IN SUPPORT OF APPLICATION AND RE NOTICE
I, MICHAEL FERGUSON, Respondent, declare:
1. I am the Respondent in this action, and I have personal knowledge of each fact stated
in this declaration.
2. The name, address and telephone number of the Other Party, Randi Baker, as known
to me, is 3559 Andrews Street, San Diego, California 92103, Tel: (619) 346-5003.
3. I have not given notice of this application for ex parte orders because giving notice
would frustrate the purpose of the order.
4. On September 1, 2023, Randi Baker, the Other Parent in this action, filed a “Notice of
Intent to Lodge Documents by Other Parent, Randi Baker, In Support of Request for Order Regarding
1) Move Away to Arizona with Minor Child, and 2) Minor Child Name Change Request No Longer
Be Legally Valid.”
5. In said application, Randi provided a list of documents, for the up-coming hearing.
Randi also filed a Declaration in Support of her application. The documents and the declaration are
already in the Court’s record (Other Parent’s Exhibits A to FF).
6. In the Declaration, Randi has made averments against me, which necessitate a three-
day hearing to canvass, counter, and rebut.
7. First, Randi falsely attributes her drinking problem to frustrations allegedly caused by
me. She even states that I need counselling and anger management. Randi then states that I lied about
many issues, which are stated in her Declaration (See pages 4-11, Randi Baker’s Declaration).
8. Randi also made an outrageous statement that this case is “about [me] ‘winning’ and
trying to remain having ‘control’ in a time when [I feel] out of control.” Randi went ahead to aver
that I am determined to cause her pain and suffering because she got pregnant and served me with
child support (See Lines 17-20, Randi’s Declaration). Randi’s statements are outrageous because
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EX PARTE REQUEST FOR A THREE-DAY HEARING
they are baseless. Notably, as the Respondent in the case, I am only responding to allegations made,
to which I need to assert my position.
9. Randi also avers that I gaslight and manipulate. She then went ahead to cite various
specific instances, which allegedly demonstrate my blameworthy conduct.
10. Randi’s Declaration, and all of the documents she filed for the hearing, clearly show
her determined efforts to taint my character before the Court.
11. In that regard, I need a three-day hearing to rebut, counter, and/or challenge her
averments.
12. I intent to present pertinent evidence in support of my opposition to her averments. I
have submitted a Witness List for the requested three-day hearing.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true
and correct.
Dated: ___________.
_________________________________
Signature
Michael Ferguson, In Pro Per
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EX PARTE REQUEST FOR A THREE-DAY HEARING
MEMORANDUM OF POINTS AND AUTHORITIES
BACKGROUND
On September 1, 2023, Randi Baker, the Other Parent in this action, filed a “Notice of Intent
to Lodge Documents by Other Parent, Randi Baker, In Support of Request for Order Regarding 1)
Move Away to Arizona with Minor Child, and 2) Minor Child Name Change Request No Longer Be
Legally Valid.”
In said application, Randi provided a list of documents, for the up-coming hearing. Randi also
filed a Declaration in Support of her application. In the Declaration, while making reference to the
said documents, Randi has made outrageous averments against Respondent,
Respondent therefore files this application to request an ex parte Order for a three-day hearing
to canvass, counter, and rebut Randi’s averments.
RESPONDENT IS ENTITLED TO THE REQUESTED EX PARTE ORDER
The rules governing ex parte applications in civil cases require that “[a]n applicant . . . make
an affirmative factual showing . . . of irreparable harm, immediate danger, or any other statutory basis
for granting relief ex parte.” Cal. R. 3.1202.
In the Declaration, Respondent has made a factual showing, while making reference to
Randi’s filings, of the grave allegations made against him by Randi. In the event this Court denies
Respondent’s ex parte application, Respondent will suffer irreparable harm because the Respondent
would not have the three-day hearing to rebut and/or challenge Randi’s voluminous documents filed
in preparation of the hearing. As already stated above, the Declaration and documents filed by Randi
contain outrageous allegations against Respondent. This necessitates a thorough response from
Respondent. Respondent is therefore organizing evidence and witnesses in support of his position.
WHEREFORE, Respondent prays this Honorable Court grant Respondent’s ex parte
application for a three-day hearing.
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EX PARTE REQUEST FOR A THREE-DAY HEARING
Respectfully submitted,
Dated:______________.
_________________________________
Signature
Michael Ferguson, In Pro Per
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LIST OF WITNESSES
Michael Ferguson
34322 Hourglass Street
Temecula, CA 92592
MICHAEL FERGUSON, IN PRO PER
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN DIEGO- CENTRAL COURTHOUSE
COUNTY OF SAN DIEGO,
Petitioner
vs.
MICHAEL FERGUSON,
Respondent
vs.
RANDI BAKER,
Other Parent
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Case No.: DF282267
RESPONDENT’S LIST OF WITNESSES
Date: 9/28/23
Time: 1:45 p.m.
Dept: 603
Judge: Honorable Laura H. Miller
Respondent MICHAEL FERGUSON hereby files this List of Witness for the requested three-
day hearing.
Witness Name and
Address
Description of
Testimony Subject
Estimated Time of
Direct Examination
Date of
Testimony
Troy Petty
292 Stephens Mill Drive
Dallas, GA 30157
(619) 488-7460
Will testify via MS
Teams as to the facts that
related to the history.
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LIST OF WITNESSES
Angela Petty
292 Stephens Mill Drive
Dallas, GA 30157
(619) 488-7460.
Will testify via MS
Teams as to the facts that
relate to the history.
Teodros Medhim
2557 Marathon Dr. San
Diego, CA 92123
(858)289-7134.
Will testify via MS
Teams as to the facts that
related to the history.
Nicole Charles
100 S. Reynolds St Unit
610, Alexandria, VA
22304
(202) 910-2379.
Will testify via MS
Teams as to the facts that
relate to the history.
Pat Hutasevee
32322 Hourglass St,
Temecula, CA 92592
(619) 657-6344.
Will testify via MS
Teams as to the facts that
related to the history.
Marcus Young
137 West Stonehaven
Circle, Pelham, Alabama
35124
(619) 227-9771.
Will testify via MS
Teams as to the facts that
related to the history.
Celia Young Will testify via MS
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LIST OF WITNESSES
137 West Stonehaven
Circle, Pelham,
Alabama, 35124
(619) 227-9758.
Teams as to the facts that
related to the history.
Ekaterina Kliveva
5335 Repecho Drive,
San Diego, CA 92124
(619) 866-8517.
Will testify in court as to
the facts that related to
the history.
Gregory Waters, 925
Centinela Ave,
Inglewood, CA 90302
Will testify via MS
Teams as to the facts that
related to the history.
Respectfully submitted,
Dated: ______________.
_________________________________
Signature
Michael Ferguson, In Pro Per
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ORDER
Michael Ferguson
34322 Hourglass Street
Temecula, CA 92592
MICHAEL FERGUSON, IN PRO PER
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN DIEGO- CENTRAL COURTHOUSE
COUNTY OF SAN DIEGO,
Petitioner
vs.
MICHAEL FERGUSON,
Respondent
vs.
RANDI BAKER,
Other Parent
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Case No.: DF282267
EX PARTE APPLICATION FOR
REQUEST FOR A THREE DAY
HEARING
Date: 9/28/23
Time: 1:45 p.m.
Dept: 603
Judge: Honorable Laura H. Miller
Application having been made by Respondent, Michael Ferguson, and good cause appearing
therefor,
IT IS ORDERED that this matter is set for a three-day hearing on _____________.
Dated: .
_________________________________
Judge of the Superior Court
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