Google Voice Closed My Account. I sued them. I won.

Small Claims – General statement of claim and notice

(#1DC06) _ In the Small Claims Division of the _ Electronically Filed : District Court of the First Circuit FIRST CIRCUIT | Honolulu Division 1DSC-26-0000370 ee ‘StateofHawaii 14-APR-2026 Please read these instructions before you start the form 12:36 PM a — Dkt. 1 SCN

| How to use this form |

| " " ‘. * " Use this form to file a small claims case if you believe someone owes you $5,000 or less.

| When you file this form, you are called the Plaintiff. The person you a

want a judgment against is called the Defendant. i Ay, _ ar. _ — ! This form is 3 pages and has 2 parts: Case number: AGC Lo 5H

‘ Part The Statement of Claim, including your sworn statement about your situation (called a Declaration). i Fill out Part I to give the Court the details about your case and to tell the Court what you would like to happen. Part I: A Notice of Hearing. The Court Clerk will use this part of the form to schedule a hearing for your case. At the hearing, you will be able to present evidence and tell the Judge why you should win this case. The Defendant will have the same opportunity. , When you have finished the form and the Court has scheduled a hearing, you must deliver a copy of the full form to the Defendant. | You can find more information on the Service of Process Information Sheet.

Part!

STATEMENT OF CLAIM

Give the Court your contact information and as much of the Defendant's contact information as you can. If you have an attorney, give the Court your attorney's contact information.

Craig W. Walsh | Google LLC

| Yeuie name Marjorie J. Walsh | Defendant's | address, i name, | c/o Corporation Service Company telephone 350 Ward Avenue 106-8 | address, | 4003 Bishop Street, Suite 1600 number, and | Honolulu, Hawaii 96814 | mee ons | Honolulu, Hawaii 96813

email: RAG @ HMPP. CoM | email: Tel 802-359-2718 i

Your attorney's Pro Se name, attorney number, firm name, address, telephone number, and email: Attorney signature

On the next page, you will give the Judge more information about your case and what you would like to happen. You will then sign a Declaration, swearing that the information in this form is true.

RG-AC-508 (11/2023) 1D-P-1038

Rev. 7/2023, seinem :

Poepy of the office wou record of

eo tiak acd vawaiit *

2 | Give the Court information about the money that the Defendant owes you.

The Defendant . Month Day Year owes me this | $ 5,000.00 The Defendant has owed me this

much money: money since this date: 2 10 2026

This is why the Defendant owes me money:

(Attach another sheet if you need more room.)

Please see attached Statement of Claim

3 > | Read the information below and then sign the Declaration.

I would like the Court to order the Defendant to pay me the amount listed above. I would also like the Court to order the Defendant to pay me interest, costs, and fees that the Court believes are just and reasonable.

PLAINTIFF'S DECLARATION

The information in this claim is true and correct. I understand that I may be prosecuted for perjury if I have stated anything in this form ghat I know is not true.

agnature a yy Y/L~ Today's date: $/l4/rb

¥ Part I

NOTICE OF HEARING

Fill in the Defendant’s name below and then take or mail the form to the Court. Court staff will schedule a hearing and will fill out the rest of Part II then return it to you to serve.

To:|GoogleLtc %y CORPORATION SERVICE C oMVANY

(Defendant's name)

The Plaintiff has filed this Statement of Claim. A Judge will hear arguments from both the Plaintiff and the Defendant at the place and time stated here:

Place: C Honolulu Division. Kauikeaouli Hale – 1111 Alakea Street, Honolulu — 10" Floor Ewa Division 870 Fourth Street, Pearl City, Honolulu, Hawai‘i, 96782

Ko‘olaupoko/Ko‘olauloa 45-939 Po‘okela Street, Kane‘ohe, Hawai'i, 96744 Division

Wahiawa or Waialua Division 1034 Kilani Avenue, Wahiawa, Hawai‘i, 96786

Wai‘anae Division 4675 Kapolei Parkway, Kapolei, Hawai‘i, 96707

Date & time: MAY 1 4 2026 WwW \) (SAOY (: S30 eM QOUVAy oomi0B

If you need help with this document, please contact the District Court Service Center at PHONE NO. (808) 538-5629 + VISIT 1111 Alakea Street, Honolulu, Hawai'i 96813 — Third Floor

— Certs |_N-BYRNE (SEAL) Today'sdate:| APR 4 4 2026 NZ,

Rev. 7/2023 2 Clear form 1D-P-1038

Here is more information to help both parties prepare for the hearing.

What if I don’t come to the hearing? If you are the Defendant and you do not come to the hearing on the date and time shown above, the Court may order you to pay the Plaintiff the amount requested in the Statement of Claim. This is called a Default Judgment. If you are the Plaintiff and you do not come to the hearing, the Court may dismiss your case.

May I hire an attorney? Yes. You may come to the hearing with or without an attorney.

May I bring witnesses and documents to support my case to the hearing? Yes. If you plan to question witnesses, they must come to the hearing at the date and time shown above. You may also ask the Judge to look at documents that support your case. You must bring those documents, with at least 2 copies, to the hearing.

How can I make sure my witnesses show up for the hearing? The Court can help you make sure a witness comes to the hearing by issuing a subpoena. If you wish to subpoena witnesses, contact the Court Clerk as soon as possible before the hearing.

How can I get the case moved to a different court?

A small claims case can only be transferred to the Court's Regular Claims Division if the Plaintiff agrees to the transfer. If the Plaintiff agrees to the transfer, you must pay the regular claims filing fee to this Court.

Defendant, if you file a counterclaim for more than $5,000, then either you or the Plaintiff may ask for a jury trial. Once the jury fee is paid, the Court will decide if the case should be transferred to the Circuit Court.

If I lose the case, may I appeal it?

No. In a small claims action, the Judge's decision is final. You MAY NOT appeal a judgment of the Small Claims Division.

Instructions to the Plaintiff about delivering this form to the Defendant

You must deliver a full copy of this form to the Defendant, either by registered or certified mail, with restricted delivery, or by personal service. Please read the Instructions on the Service of Process Information Sheet carefully before you try to serve the Defendant.

Restriction on personal service: This claim may not be personally delivered between 10:00 p.m. and 6:00 a.m. unless it is served at a location that is open to the public, or unless a Judge of this Court, by written order, permits personal delivery during those hours.

If you need help with this document, please contact the District Court Service Center at PHONE NO. (808) 538-5629 + VISIT 1111 Alakea Street, Third Floor.

C) Americans with Disabilities Act Notice If you need an accommodation for a disability when participating in a court program, service or activity, please contact the ADA Coordinator as soon as possible to allow the court time to provide an accommodation:

. Call (808) 538-5121; or . Send an e-mail to [email protected]

The court will try to provide, but cannot guarantee, your requested auxiliary aid, service or accommodation.

Rev. 7/2023 3 1D-P-1038

PLAINTIFFS’ STATEMENT OF CLAIM

PRELIMINARY NOTE REGARDING JURISDICTION

Google LLC requires disputes to be resolved by arbitration under its Terms of Service. However, Google explicitly preserves the right of customers to bring claims in Small Claims Court. Google’s Terms of Service state: “You and Google may still bring an individual action in small claims court.” Plaintiffs are invoking that right. This claim is for $5,000, which is within the $5,000

jurisdictional limit of this Court.

THE PARTIES

1. Plaintiffs Craig W. Walsh and Marjorie J. Walsh are husband and wife, whose mailing address is 350 Ward Avenue, Suite 106-8, Honolulu, Hawaii 96814. They bring this action jointly because both have suffered direct financial and commercial harm from the acts and omissions of

Defendant described below.

2. Defendant Google LLC is a Delaware limited liability company registered to do business in Hawaii since October 27, 2017. Its registered agent for service of process in Hawaii is Corporation Service Company, 1003 Bishop Street, Suite 1600, Pauahi Tower, Honolulu, Hawaii 96813. Google LLC is a wholly-owned subsidiary of Alphabet Inc., one of the largest corporations in the world, with a market capitalization exceeding two trillion dollars. Despite this extraordinary

wealth and the technological sophistication it implies, Google has proven entirely unable — or

unwilling — to provide a single human being with whom a customer of seventeen years could

resolve a straightforward dispute.

BACKGROUND: SEVENTEEN YEARS OF FAITHFUL SERVICE

3. On July 28, 2009 — nearly seventeen years ago — Plaintiff Craig Walsh received an invitation from Google to open a Google Voice account. The invitation was sent to his Gmail address, [email protected]. At that time, Mr. Walsh was living in the United Kingdom, where he and Marjorie Walsh had resided for many years. The account was therefore linked to a UK payments profile from its inception. Mr. and Mrs. Walsh relocated from the United Kingdom to Vermont in October 2010, and subsequently to Honolulu, Hawaii in 2016, where they have

resided since.

4. The very next day — July 29, 2009 — Mr. Walsh accepted the invitation, opened the account, and paid Google $10.00 for international calling credit via Google Checkout. Both the invitation email and the payment receipt are attached as Exhibit A, retrieved from Plaintiffs’ email archive. That $10.00 remains in the account to this day. Google has suspended the account, seized the data, allowed the number to lapse toward cancellation — and has not refunded so much as a

single cent of the $10.00 Mr. Walsh paid them in 2009.

5. Google Voice is a telephone service offered by Google LLC that provides users with a dedicated phone number capable of sending and receiving calls and text messages, and that stores all call and message history in a searchable database maintained by Google. Mr. Walsh’s Google

Voice number was 415-915-4708. He used this number continuously, without interruption, from

July 2009 until Google unilaterally suspended his access in early February 2026. That is a period of nearly seventeen years — longer than some of Google’s own employees have worked for the

company.

6. During those seventeen years, Mr. Walsh logged into his Google Voice account every single day. He built a searchable archive of calls, text messages, contact information, and communications history. He shared the number with clients, colleagues, and contacts. He imported a client database from a colleague who had previously used a different Google Voice number, including a list of blocked contacts that allowed him to protect Marjorie Walsh from unwanted communications. The number 415-915-4708 was not merely a convenience. It was a professional identity, a communications infrastructure, and an irreplaceable archive — all of which Google has

now seized without explanation, without warning, and without offering any meaningful remedy.

7. Beginning in late 2024, Plaintiff Marjorie J. Walsh began providing personal professional services to clients in Honolulu. Clients contacted her to make appointments by calling or texting the 415-915-4708 number, which Mr. Walsh managed. The number was listed on Marjorie Walsh’s professional profile on | the primary platform she uses to connect with clients. It also appeared across numerous other websites — some created by Plaintiffs, many created automatically by third-party internet services that scrape and republish professional listings. The number 415-915-4708 had become, over time, inseparable from Marjorie Walsh’s professional identity in the Honolulu market. Marjorie Walsh’s minimum rate for personal professional services is BJ per hour. The commercial value of that number is therefore not theoretical — it is

quantifiable, ongoing, and accruing.

WHAT GOOGLE DID — AND FAILED TO DO

8. On or about February 10, 2026, Mr. Walsh attempted to log into his Google Voice account, as he had done every day for nearly seventeen years. Instead of his account, he was shown a message stating that his access to a Google product had been suspended due to a “perceived violation” of Google’s Terms of Service or product-specific Terms of Service. The suspension

notice is attached as Exhibit B.

9. Google provided no further explanation. Not a sentence. Not a word. Not a category of violation. Not a date or description of the offending conduct. After nearly seventeen years of continuous service, Google terminated Mr. Walsh’s access with the same automated indifference it might apply to an account opened last Tuesday. The suspension notice contained a link purporting to allow Mr. Walsh to review his service restrictions and file an appeal. Mr. Walsh clicked that link. It took him to a page at myaccount.google.com/restrictions which displayed the following message: “Access to your Google Account isn’t restricted.” He was suspended by one Google system and cleared by another. No path forward was offered by either. A screenshot of

that page is attached as Exhibit C.

10. Mr. Walsh did not fail to pursue his remedies. Google’s own systems made pursuit of those remedies impossible. This is not a metaphor. It is a precise description of what happened: the appeal link led to a dead end, the account remained suspended, and no human being at Google was reachable to explain, review, or correct the situation. Verizon Wireless — itself a corporation of considerable size — noted in the course of attempting to assist Plaintiffs that there are, in their

experience, “no humans at Google” to contact regarding such matters. Plaintiffs can only concur.

11. On February 11, 2026, Mr. Walsh submitted a formal Data Subject Access Request to Google under Article 15 of the UK General Data Protection Regulation and the UK Data Protection Act 2018. The account was created while Mr. Walsh was resident in the United Kingdom and was linked to a UK payments profile, making Google UK the relevant data controller. The request asked Google to confirm whether personal data relating to the Google Voice account continued to be processed, and if so, to provide a copy of all such data in a structured, machine-readable format. It also asked for the categories of data held, the recipients of that data, the applicable retention periods, and the lawful basis for any processing or deletion. A copy of that request is attached as

Exhibit D.

12. Article 12(3) of the UK GDPR requires a response within one calendar month. On March 30, 2026 — forty-seven days after submission, already in breach of the statutory deadline — Google responded with a single paragraph. That paragraph directed Mr. Walsh to the Google Voice Help Center. It did not address a single one of the six specific questions raised in the request. It did not confirm whether data was being processed. It did not provide any data. It did not address retention periods, recipients, or the lawful basis for anything. And it directed Mr. Walsh to a Help Center he could not access because his account was suspended. A copy of Google’s response is

attached as Exhibit D. It is, in practical terms, the written equivalent of a shrug.

GOOGLE’S EXTRAORDINARY INTERNAL CONTRADICTIONS

13. If the foregoing were not sufficient, what follows removes any doubt about the dysfunction

at the heart of Google’s handling of this matter. While one Google system was refusing to reinstate

Mr. Walsh’s account on the grounds of a Terms of Service violation, other Google systems were simultaneously sending him routine account maintenance communications that could only make

sense if the account were active and in good standing.

14. | On March 20, 2026 — six weeks after suspending the account — Google Voice sent Mr. Walsh a routine administrative email asking him to verify that he still owned his forwarding phone number, (802) 359-2718, and to re-verify it by April 19, 2026. The email then stated, in Google’s own words: “Even if you don’t re-verify your phone, your Google Voice account will still stay

active.” A copy of that email is attached as Exhibit E.

15. | On April 9, 2026 — two months after suspending the account — Google Voice sent Mr. Walsh another email: “Your Google Voice number (415) 915-4708 will expire in 30 days.” The email advised that to keep the number, Mr. Walsh would need to make calls or send text messages by May 9, 2026, by “logging in” to his account. The email is attached as Exhibit F. Google’s systems were advising Mr. Walsh to log in to an account that Google’s other systems had suspended. On April 10, 2026, a further reminder arrived: verify your forwarding phone within 10

days. A copy is attached as Exhibit G.

16. Also on April 9, 2026, at 1:54 AM, Google’s Voice Support Team sent a separate email in response to Mr. Walsh’s porting inquiry, stating: “We have reviewed your request and cannot reinstate your Google Voice service. Your Google Voice service has been suspended for violations of our Google Voice Policies.” No policy was identified. No violation was described. No appeal

was offered. A copy of that email is attached as Exhibit H.

17. To summarize the state of affairs as of April 10, 2026: Google’s Voice Support Team said the account was suspended for policy violations and would not be reinstated. Google’s Voice automated system said the account would “still stay active.” Google’s Voice automated system said the number would expire in 30 days and advised Mr. Walsh to log in. Google’s Voice automated system said to verify the forwarding number within 10 days. These communications cannot all be true simultaneously. They were all sent by Google. Not one of them was sent by a human being who had actually reviewed the account. This is the customer service experience that a seventeen-year customer of Google Voice received upon losing access to his account: a suspended service, an incoherent collection of automated emails, and a $10.00 calling credit frozen

in an account he cannot open.

THE FAILED PORT AND THE TICKING CLOCK

18. Because the 415-915-4708 number was deeply embedded in Marjorie Walsh’s professional identity, Plaintiffs acted immediately upon discovering the suspension to preserve the number. On February 10, 2026 — the same day the suspension was discovered — Plaintiffs arranged for Verizon Wireless to port the number from Google Voice to Mr. Walsh’s existing Verizon account. Verizon completed the port, activated the number on Mr. Walsh’s iPhone, and began billing for it

on February 10. The relevant page of Plaintiffs’ Verizon bill is attached as Exhibit I.

19. | The number functioned normally on Verizon from February 10 through March 22, 2026. On March 22, without any notification to Mr. Walsh, Verizon’s systems reassigned the number. Upon investigation, it emerged that the original port had not fully completed because Google’s

systems showed the number as “cancelled.” Verizon attempted a second port. Google’s systems

again showed the number as cancelled. Verizon’s Executive Relations team — which engaged with Plaintiffs promptly following a complaint to the Federal Communications Commission — confirmed these facts in writing in an email dated April 9, 2026, attached as Exhibit J. That email states: “We were unable to port the number because it showed cancelled. In order to port a number, it needs to be active. We recommend contacting Google Voice to determine why the number was

cancelled.”

20. Plaintiffs cannot contact Google Voice to determine why the number was cancelled. There is no human being at Google Voice to contact. The account is suspended. The appeal link leads to a page that says the account is not restricted. The Help Center cannot be accessed. The DSAR produced a shrug. The FCC complaint — filed by Plaintiffs in April 2026 and served on Google — has produced no response from Google as of the date of this complaint. The complaint has also been referred to the UK Information Commissioner’s Office, which received it by post from

Plaintiffs’ UK address.

21. | Meanwhile, Google’s April 9 email warns that the number 415-915-4708 will be permanently reclaimed on May 9, 2026 — unless Mr. Walsh logs in and uses it. Mr. Walsh cannot log in. The account is suspended. Google has constructed a situation in which the only person who could save the number is the one person Google has locked out of the system. If the number is reclaimed on May 9, it will be assigned to a new user, and the commercial harm to Plaintiffs —

already substantial — will become permanent and irreversible.

DAMAGES

22. Marjorie Walsh’s minimum rate for personal professional services is J per hour. Her HE profile analytics for the 30-day period ending April 3, 2026 show 21,544 impressions, 1,878 profile views, and — most significantly — 52 separate instances of prospective clients actively seeking her phone number, either by clicking to reveal the number or by clicking to dial it directly. A screenshot of the J analytics dashboard and daily profile views chart are attached as Exhibit K. Profile views have remained consistently between 47 and 91 per day throughout the period. Demand for Marjorie Walsh’s services has not diminished. It is the dead phone number — killed by Google’s suspension and Google’s refusal to release it — that is turning

prospective clients away.

23. A person who clicks to reveal or dial a phone number on a professional services platform has one clear purpose: they wish to make contact. Since February 10, 2026, every one of those contact attempts has hit a dead number. At Marjorie Walsh’s minimum rate of J per engagement, even a small fraction of those 52 monthly contacts converting to appointments represents thousands of dollars in lost revenue. Damages are continuing to accrue every day that

the number remains dead.

24. Plaintiffs cannot simply update Marjorie Walsh’s listings with a new phone number. Many of the platforms displaying the 415-915-4708 number are third-party aggregator and scraper sites over which Plaintiffs have no control. The number is embedded across the internet in ways that cannot be quickly or easily corrected. A Google search for the number 415-915-4708 returns

results across multiple platforms, all associating that number with Marjorie Walsh’s professional

identity in Honolulu. The commercial harm from the dead number will persist long after any new

number is established.

25. In addition to the ongoing commercial harm, Plaintiffs have lost access to an irreplaceable database of nearly seventeen years of communications history — call records, text message content, contact information, voicemail transcriptions, and an imported client database with commercial value independent of the 415-915-4708 number itself. This data cannot be reconstructed. Google continues to hold it. Google has refused to provide it despite a formal legal request. And Google has not refunded the $10.00 calling credit that Mr. Walsh paid in 2009 and

that remains frozen in the suspended account.

26. Plaintiffs claim damages of $5,000, representing a conservative estimate of the commercial harm already sustained and continuing to accrue as a result of Google’s unilateral suspension of a seventeen-year account without notice, warning, explanation, or any functional means of human review or appeal — and Google’s subsequent refusal to release the number, provide the data, respond meaningfully to a formal legal request, or return so much as the $10.00 that Mr. Walsh

paid them on July 29, 2009.

RELIEF REQUESTED

Plaintiffs respectfully request that this Court enter judgment in their favor and against Defendant Google LLC in the amount of $5,000

plus the filing fee of $35 and any other costs the Court deems appropriate.

CERTIFICATION Plaintiffs certify that the facts stated in this complaint are true and correct to the best of their

knowledge and belief.

Respectfully submitted,

Craig W. Walsh-

Marjorie J. Walsh

Plaintiffs, Pro Se 350 Ward Avenue, Suite 106 Honolulu, Hawaii 96814

April__, 2026

EXHIBIT LIST

Exhibit A: Google Voice invitation email (July 28, 2009) and Google Checkout receipt (July 29, 2009), retrieved from Plaintiffs’ email archive

Exhibit B: Google account suspension notice (“Unable to access a Google product”)

Exhibit C: Screenshot of Google’s appeal system displaying “Access to your Google Account isn’t restricted” (April 3, 2026)

Exhibit D: Plaintiffs’ UK GDPR Data Subject Access Request (February 11, 2026) and Google’s response (March 30, 2026)

Exhibit E: Google Voice email of March 20, 2026 stating “your Google Voice account will still stay active”

Exhibit F: Google Voice email of April 9, 2026 stating number 415-915-4708 will expire in 30 days (by May 9, 2026)

Exhibit G: Google Voice reminder email of April 10, 2026 to verify forwarding phone within 10 days

Exhibit H: Google Voice Support Team email of April 9, 2026 refusing reinstatement of account

Exhibit I: Relevant page of Verizon bill showing February 10, 2026 activation and billing of 415-915-4708

Exhibit J: Verizon Executive Relations email of April 9, 2026 confirming two failed port attempts and Google’s system showing number as cancelled

Exhibit K: [Jenalytics dashboard and daily profile views chart (30-day period ending April 3, 2026)

EXHIBIT A

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAII

CRAIG W. WALSH and MARJORIE J. WALSH, Plaintiffs, Vv. GOOGLE LLC, Defendant.

Google Voice Invitation and Payment Receipt (July 28-29, 2009)

Email invitation to open Google Voice account (July 28, 2009) and Google Checkout payment receipt for $10.00 international calling credit (July 29, 2009), retrieved from Plaintiffs’ Global Relay compliance email archive.

sh v. Google LLC — Exhibit A

Serial #: 322826 printed by [email protected] on 2026-04-04 00:18:55

(=| =| Audit Trail [EDT] Username Event Comment Jul 28 2009 07:03:38PM Global Relay Archive @ Imported Message #322826: Received from Mail Server

Subject : You've been invited to Google Voice

From: Google Voice <[email protected]> Date: 16 years ago Tue, 28 Jul 2009 17:41:32 -0400 To: “[email protected]" <[email protected]>

Bcc/DL: [email protected], [email protected] ty F \@{Google Voice

You are invited to open a free Google Voice account. To accept this invitation and create your account, visit https://www.google.com/voice/inv/ZZVgWk-rLQcwTrmgFJbq5zbfHIballad4ac4ad2b25

If you haven't already heard about it, Google Voice is a service that makes using your current phones much better! Here's what it offers: « A personal phone number that rings all of your existing phones when people call e All of your voicemail in one inbox with unlimited online storage and free voicemail transcripts sent to your phone and

email e Low-priced international calling to over 200 countries and free SMS

* Other powerful features like the first phone spam filter to protect you from unwanted callers, the ability to ListenIn™ on your voicemail messages while they are being left, conference calling and more To learn more about Google Voice before registering, visit: http://www.google.com/voice/about Please note that Google Voice is only available for sign up in the US. We hope you enjoy Google Voice,

The Google Voice Team

Serial #: 322956 printed by [email protected] on 2026-04-04 00:19:52

(=| =| Audit Trail [EDT] Username Event Comment Jul 29 2009 05:09:38AM Global Relay Archive @ Imported Message #322956: Received from Mail Server

Subject : Order receipt from Google Services (USD10.00) From: Google Checkout <[email protected]> Date: 16 years ago Wed, 29 Jul 2009 04:48:58 -0400

To: “[email protected]" <[email protected]>

Bcc/DL: [email protected], [email protected]

\»,Google Checkout

Hello MiG Walsh Buy again in seconds Thanks for buying from Google Services using Google Checkout! Google Services will charge your order soon. every time you shop. Just look for the

Google Checkout button on Google How do I check on this order? Services or on Google Product Get up-to-date information about order no.425006819141868 Search.

Problems with this order? Contact Google Services

Order Details – 29 Jul 2009 04:48 GMT-04:00 Google Order #425006819141868

Delivery Status Qty Item Price Digital delivery 1 $10 Google Voice calling credit – Allows you to make international calls using Google Voice. USD10.00 Tax : USDO.00

Total: USD10.00

Paid with: VISA xxx-4744

Need help? Visit the Google Checkout help centre. Please do not reply to this message.

©2009 Google

EXHIBIT B

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAII

CRAIG W. WALSH and MARJORIE J. WALSH, Plaintiffs, v. GOOGLE LLC, Defendant.

Google Account Suspension Notice

Screenshot of Google account suspension notice stating access has been suspended due to ‘perceived violation’ of Google's Terms of Service. No explanation, warning, or opportunity to respond was provided.

Walsh v. Google LLC — Exhibit B

Unable to access a Google product

If you've been redirected to this page from a particular product, it means that your access to this product has been suspended. Read on for more information.

Your access to this Google product has been suspended because of a perceived violation of either the Google Terms of Service _ or product-specific Terms of Service. For specific product guidelines, please visit the homepage of each Google product you're interested in for a link to its Terms of Service.

Google reserves the right to:

* Disable an account for investigation.

+ Suspend a Google Account user from accessing a particular product or the entire Google Accounts system, if the Terms of Service or product-specific policies are violated. + Terminate an account at any time, for any reason, with or without notice.

Next steps for suspended accounts: If you believe your access to this product was suspended in error, contact us.

Tip: If you are not redirected to this page from a product, review your service restrictions to file an appeal.

Need more help?

Post to the help community Get answers from community members

EXHIBIT C

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAII

CRAIG W. WALSH and MARJORIE J. WALSH, Plaintiffs, v. GOOGLE LLC, Defendant.

Google Appeal System Displaying ‘Access to Your Google Account Isn't Restricted’ (April 3, 2026)

Screenshot showing that when Plaintiff clicked the appeal link in the suspension notice, Google's own system displayed the message ‘Access to your Google Account isn't restricted’ — making appeal impossible.

Walsh v. Google LLC — Exhibit C

Co tS tren uiimnpacrount qooge comvrestesct

Google Account

€ Review service restrictions

your Googie Account int t restricted

EXHIBIT D

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAII

CRAIG W. WALSH and MARJORIE J. WALSH, Plaintiffs, v. GOOGLE LLC, Defendant.

UK GDPR Data Subject Access Request (February 11, 2026) and Google's Response (March 30, 2026)

Plaintiffs formal Data Subject Access Request submitted under Article 15 UK GDPR on February 11, 2026, and Google's response dated March 30, 2026 — 47 days after submission, in breach of the statutory one-month deadline — directing Plaintiff to a Help Center he cannot access.

Walsh v. Google LLC — Exhibit D

Craig Walsh

From: Craig Walsh <[email protected]>

Sent: Friday, April 3, 2026 12:23 PM

To: Craig Walsh

Subject: Fwd: Port out request on your Google Voice number: 415-915-4708

Forwarded message From: Google Voice <[email protected]>

Date: Tue, Feb 10, 2026 at 12:53 PM

Subject: Port out request on your Google Voice number: 415-915-4708 To: <crai lsh i >

Hello Craig Watsh, We've received a request to port your Google Voice number 415-915-4708 to another service provider. To

protect your number from unauthorized porting, your Google Voice number must be unlocked before we can authorize the porting request.

To unlock your number, visit www.google.com/voice/unlock and log in to your Google Voice account. lf you did not request to port your number, please ignore this email.

Thanks, The Google Voice Team

Craig Walsh

From: Craig Walsh <[email protected]> Sent: Friday, April 3, 2026 12:24 PM

To: Craig Walsh

Subject: Fwd: [3-5814000039773]

Forwarded message From: <data-ac' \> Date: Mon, Mar 30, 2026 at 7:48 AM

Subject: Re: [3-5814000039773]

To: <[email protected]>

Hello, Thank you for contacting us.

If you are unable to access Google Voice, please visit the Google Voice Help Center for more information.

Regards,

Google

Wed, Feb 11, 2026 at 05:32 UTC Data Access Request Form

Email address [email protected]

Please select your country of residence United Kingdom

About which Google product are you inquiring? Other Google product(s)

What personal data are you seeking? lam making a formal request under Article 15 UK GDPR and the Data Protection Act 2018. The Google account

([email protected]) was created while | was resident in the United Kingdom and was linked to a UK payments profile. The Google Voice service associated with this account has recently been suspended and is no longer 1

accessible via Google Takeout. | am not requesting reinstatement. The Google Voice service was active on this account from 2009 to its termination in 2026.

| request confirmation of:

(1) Whether personal data relating to my Google Voice service continues to be processed.

(2) If so, a copy of ALL such data in a structured, commonly used, machine-readable format.

(3) If any such data has been erased, the date of erasure, the retention policy relied upon, and the lawful basis for processing and deletion.

(4) Categories of personal data held.

(5) Recipients or categories of recipients.

(6) Applicable retention periods.

Please treat this as a formal statutory request.

EXHIBIT E

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAII

CRAIG W. WALSH and MARJORIE J. WALSH, Plaintiffs, v. GOOGLE LLC, Defendant.

Google Voice Email of March 20, 2026: 'Your Google Voice Account Will Still Stay Active’

Email from Google Voice dated March 20, 2026 — six weeks after suspending Plaintiff's account — asking Plaintiff to verify his forwarding phone number and stating 'Even if you don't re-verify your phone, your Google Voice account will still stay active.’ This directly contradicts the account suspension.

Walsh v. Google LLC — Exhibit E

Craig Walsh

From: Craig Walsh <[email protected]>

Sent: Friday, April 3, 2026 12:26 PM

To: Craig Walsh

Subject: Fwd: Notice: Verify your Google Voice forwarding phone (802) 359-2718 in the next 30 days

Forwarded message From: Google Voice <[email protected]>

Date: Fri, Mar 20, 2026 at 8:05 AM

Subject: Notice: Verify your Google Voice forwarding phone (802) 359-2718 in the next 30 days To: <crai i >

R® Voice

Hello,

We'd like to make sure that the information on your Google Voice account [email protected] is accurate and that you still own the forwarding phone number (802) 359-2718.

If you want Google Voice to continue forwarding calls and texts to this phone, please verify it by April 19, 2026. To re-verify or remove this phone, please visit your Google Voice Settings.

Even if you don't re-verify your phone, your Googte Voice account will still stay active. You won't get calls forwarded to this specific phone, but you can use it again at any time by re-verifying it. If you have other forwarding phones turned on, calls will still be forwarded to them.

Please note that this is a no-reply email. If you have additional questions, please visit our Help Center.

– The Googie Voice Team

YOUR ACCOUNT HELP CENTER HELP FORUM

You received this mandatory email to update you about important changes to your service.

Google

Google LLC 1600 Amphitheatre Pkwy Mountain View CA 94043 USA

EXHIBIT F

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAII

CRAIG W. WALSH and MARJORIE J. WALSH, Plaintiffs, Vv. GOOGLE LLC, Defendant.

Google Voice Email of April 9, 2026: Number 415-915-4708 Will Expire in 30 Days

Email from Google Voice dated April 9, 2026 warning that number 415-915-4708 will be permanently reclaimed on May 9, 2026 unless Plaintiff logs in and uses it — which he cannot do because the account is suspended.

Walsh v. Google LLC — Exhibit F

Serial #: 5933778 printed by [email protected] on 2026-04-12 09:14:52

(=| =| Audit Trail [EDT] Username Event Comment Apr 10 2026 10:48:19PM Global Relay Archive @ Imported Message #5933778: Received from Mail Server

Subject: Fwd: Your Google Voice number (415) 915-4708 will expire in 30 days From: Craig Walsh <[email protected]> Date: 1 day ago Fri, 10 Apr 2026 20:41:49 -0400 To: "Craig W. Walsh" <[email protected]>

— Forwarded message — From: Google Voice <[email protected]>

Date: Thu, Apr 9, 2026 at 3:50PM

Subject: Your Google Voice number (415) 915-4708 will expire in 30 days To: <[email protected]>

Hello,

We noticed that you haven’t used your Google Voice number in a while. Because phone numbers are a limited resource, it is our policy to reclaim unused numbers so they can be made available to new users.

If you’d like to keep your Google Voice number (415) 915-4708, you will need to make calls or send text messages by May 9, 2026 by logging in to your account or using the Google Voice app on Android or iOS.

Please remember that your current number will be reclaimed in 30 days unless you start using it. If the number is reclaimed, your existing messages will remain available in your account, but you will no longer be able to receive calls or text messages.

The Google Voice Team

EXHIBIT G

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAII

CRAIG W. WALSH and MARJORIE J. WALSH, Plaintiffs, Vv. GOOGLE LLC, Defendant.

Google Voice Reminder Email of April 10, 2026: Verify Forwarding Phone Within 10 Days

Follow-up email from Google Voice dated April 10, 2026 reminding Plaintiff to verify his forwarding phone number (802) 359-2718 within 10 days — treating the account as active while it remains suspended.

Walsh v. Google LLC — Exhibit G

Serial #: 5933779 printed by [email protected] on 2026-04-12 09:15:45

(=| =| Audit Trail [EDT] Username Event Comment Apr 10 2026 10:48:36PM Global Relay Archive @ Imported Message #5933779: Received from Mail Server

Subject : Fwd: Reminder: Verify your Google Voice forwarding phone (802) 359-2718 in the next 10 days

From: Craig Walsh <[email protected]> Date : 1 day ago Fri, 10 Apr 2026 20:41:08 -0400 To: "Craig W. Walsh" <[email protected]>

From: Google Voice <voice- nerenl@doodle: com>

Date: Fri, Apr 10, 2026 at 11:49AM

Subject: ‘Reminder: Verify your Google Voice forwarding phone (802) 359-2718 in the next 10 days To: <[email protected]>

\» {Google Voice

Hello,

We'd like to make sure that the information on your Google Voice account [email protected] is accurate and that you still own the forwarding phone number (802) 359-2718.

If you want Google Voice to continue forwarding calls and texts to this phone, please verify it by April 20, 2026. To re-verify or remove this phone, please visit your Google Voice Settings.

Even if you don't re-verify your phone, your Google Voice account will still stay active. You won't get calls forwarded to this specific phone, but you can use it again at any time by re-verifying it. If you have other forwarding phones turned on, calls will still be forwarded to them.

Please note that this is a no-reply email. If you have additional questions, please visit our Help Center.

– The Google Voice Team

YOUR HELP HELP ACCOUNT CENTER FORUM

You received this mandatory email to update you about important changes to your service. lo Google

Google LLC 1600 Amphitheatre Pkwy Mountain View CA 94043 USA

EXHIBIT H

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAII

CRAIG W. WALSH and MARJORIE J. WALSH, Plaintiffs, v. GOOGLE LLC, Defendant.

Google Voice Support Team Email of April 9, 2026: Refusing Reinstatement

Email from Google Voice Support Team dated April 9, 2026 stating 'We have reviewed your request and cannot reinstate your Google Voice service. Your Google Voice service has been suspended for violations of our Google Voice Policies.’ No policy is identified. No violation is described. No appeal is offered.

Walsh v. Google LLC — Exhibit H

Serial #: 5933780 printed by [email protected] on 2026-04-12 09:16:14

(=| =| Audit Trail [EDT] Username Event Comment Apr 10 2026 10:49:39PM Global Relay Archive @ Imported Message #5933780: Received from Mail Server

Subject : Fwd: [1-1953000040723] From: Craig Walsh <[email protected]> Date: 1 day ago Fri, 10 Apr 2026 20:40:47 -0400 To: "Craig W. Walsh" <[email protected]>

From: <[email protected]> Date: Fri, Apr 10, 2026 at 1:54AM Subject: Re: [1-1953000040723] To: <[email protected]>

Hello,

We have reviewed your request and cannot reinstate your Google Voice service. Your Google Voice service has been suspended for violations of our Google Voice Policies.

If you have any further questions, please consult the Google Voice Help Center. Thanks,

Google Voice Support Team

Google inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043 USA

EXHIBIT |

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAII

CRAIG W. WALSH and MARJORIE J. WALSH, Plaintiffs, v. GOOGLE LLC,

Defendant.

Verizon Wireless Bill Showing February 10, 2026 Activation of Number 415-915-4708

Page from Verizon Wireless Invoice 8963852090 (billing period February 5 – March 4, 2026) showing activation and billing of telephone number 415-915-4708 as a Second Number beginning February 10, 2026, confirming Verizon treated the port as complete and the number as Plaintiffs from that date.

Walsh v. Google LLC — Exhibit |

verizon At

Invoice: 8963852090 Billing period: Feb 5 – Mar 4, 2026

Your March bill is $314.16

Due Mar 27 Questions about your bill?

verizon.com/support 800-922-0204

| Since your last bill

| &@B You paid $330.34.

| €@ You received $54.10 in one-time credits. | | | An itemized bill breakdown of all

Your bill decreased by $16.18. | charges and credits is available on \ J) the My Verizon app and online.

Review your bill online

Scan the QR code ®

with your camera Ls AO) app or go to boa ae

go.vzw.com/bill. Bt ahr @tre o ote ats Bill summary by line Account-wide charges & credits -$8.95 Surcharges, taxes and gov fees ; The total amount due for this month Craig Walsh $120.47 includes surcharges of $32.80 and Apple iPhone 17 Pro Max (802-359-2718) taxes and gov fees of $3.96. For an itemized list of taxes, fees and © Service removed © Perk added surcharges visit go.vzw.com/bill Craig Walsh $10.64

Apple iPhone 17 Pro Max-2 (415-915-4708) (Second Number) Save up to $40.00/month when you

© Service added enroll in Auto Pay & paperfree billing using your bank account or Verizon Marjorie J. Walsh $35.67 Visa card. Enroll using the My Verizon

Apple iPhone 16 Pro Max-2 (808-518-5889) Ber chai vzW com my verizon

The discount will be effective beginning

Ka LA Phone $71.78 your next billing cycle after the Apple iPhone 13 128GB IN Midni (808-723-1911) enrollment Craig Walsh $84.55

Apple iPhone 16 Pro Max (808-859-1102)

Total: $314.16

EXHIBIT J

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAII

CRAIG W. WALSH and MARJORIE J. WALSH, Plaintiffs, Vv. GOOGLE LLC, Defendant.

Verizon Executive Relations Email of April 9, 2026: Confirming Two Failed Port Attempts

Email from Emma, Verizon Wireless Executive Relations, dated April 9, 2026, confirming that Verizon attempted to re-port number 415-915-4708 but was unable to do so because Google's systems showed the number as cancelled. States: 'We were unable to port the number because it showed cancelled. In order to port a number, it needs to be active. We recommend contacting Google Voice to determine why the number was cancelled.’

Walsh v. Google LLC — Exhibit J

Serial #: 5933391 printed by [email protected] on 2026-04-12 09:17:53

(=| =| Audit Trail [EDT] Username Event Comment Apr 09 2026 07:15:16PM Global Relay Archive ‘@ Imported Message #5933391: Received from Mail Server Subject: Verizon Executive Relations Case 3383082 (CASE3383082) From: Verizon Wireless Executive Relations <[email protected]>

Date: 2 days ago Thu, 9 Apr 2026 19:14:58 -0400 To: [email protected]

Dear Craig Walsh,

This is Emma with the Executive Office. We were able to research your account regarding the Port of the Google Voice phone number 4159154708 into Verizon and the reason the ported phone number was cancelled, We were unable to port the number because it showed cancelled. In order to port a number, it needs to be active. We recommend contacting Google Voice to determine why the number was canceled.

Your Mobile Number and Porting

You may be able to transfer, or "port," your wireless phone number to another carrier. If you port a number from us, we'll treat it as though you asked us to cancel your Service for that number.

If you're a Prepaid customer, you won't be entitled to a refund of any balance on your account. If you port a number to us, please be aware that we may not be able to provide some services right away, such as 911 location services. You don't have any rights to your Mobile

Telephone Number (MTN), except for any right you may have to port it. After a line of service is disconnected, for any reason, the disconnected MTN may not be suspended or otherwise reserved and may not be able to be recovered.

If you have any further concerns, please reply to this email. Best Regards,

Emma

Executive Relations

Verizon Executive Relations

EXHIBIT K

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAII

CRAIG W. WALSH and MARJORIE J. WALSH, Plaintiffs, v. GOOGLE LLC, Defendant.

HE Analytics Dashboard and Daily Profile Views Chart (30-Day Period Ending April 3, 2026)

Screenshots from Plaintiff Marjorie Walsh's JE professional profile analytics showing: 21,544 impressions, 1,878 profile views, and 52 instances of prospective clients actively seeking her phone number

(Contact: Mobile Click + Contact: Reveal Mobile). Daily profile views chart shows consistent demand of 47-91 views per day throughout the period.

Walsh v. Google LLC — Exhibit K

Analytics

@ Ai data shown beter a for

impressions Checks Click-throwgh rate Profile views

Photo views:

Contact

Coract

Comact

Contact:

Contact:

Contact:

Email Chick Mobée Click Reweal Emax Reweal Mobile

voit

Visit Twitter

Profile Views

Oe, Oe a er ae

FIRST CIRCUIT

STATE OF HAWATT HONOLULU DIVISION RECEIPT

Case No:1DSC-26-0000370 RECEIPT NO:4114480 RECEIVED FROM: Walsh, Craig W. 14-APR-2026 THE SUM OF: $35.00 12:47PM DESCRIPTION: Payment by Debit Card 1. Statement of Claim (General; Security Deposit)

V721- Statement of Claim $35.00

$35.00

TOTAL

vlSibicd oi dot CERCur 1111 ALAKEA ST HONOLULU, Hi i681 OF rt 2ura

/s/Court Document Clerk

DEBLE CAKD DEBLT SALE Cai filet ik Chk aie Ali

Bai 452 Thy AE 3

Apt oval cade. widlo2

Eri sietiod

Se AMOUNT

Cun] GiitK LUFT

NON-HEARING MOTION FOR CONTINUANCE; DECLARATION; Form 1DC11 NOTICE OF MOTION; CERTIFICATE OF SERVICE; ORDER

IN THE DISTRICT COURT OF THE FIRST CIRCUIT Honolulu DIVISION

STATE OF HAWAII RECEIVED Plaintiff 006 Craig W. Walsh may 122 Marjorie J. Walsh C+M WALSH HONOLULU Reserved for Court Use Civil No. 1DSC-26-0000370 Defendant Filing Party/Attorney Name, Attorney Number, Firm Name (if Google LLC applicable), Address, Telephone and Fax Number or Email

Leslie Altherr on behalf of Google LLC 1600 Amphitheatre Parkway

Mountain View, CA 94043 [email protected]

NON-HEARING MOTION FOR CONTINUANCE O, Answer [1 Returnable (Summary Possession cases) of Hearing-Type of Motion: Status Hearing © Trial O Pre-Trial O Other-Specify: The Filing Party requests that this Motion be granted for the reasons stated in the Declaration below.

DECLARATION I have read this Motion, know the contents and verify that the statements are true to my personal knowledge and belief. I DECLARE UNDER PENALTY OF PERJURY THAT THE FOLLOWING IS TRUE AND CORRECT: that Filing Party wishes to continue this proceeding to the date and for the reason stated below. 1 I have contacted the Opposing Party or their attorney and they will not agree to the continuance, or (1 I have tried several times to contact them by telephone and/or mail and they have not returned my calls or answered my letters. Explain why you will not be available and want this continuance: (Attach continuation page, if necessary).

Please see attached Defendant's Request to Postpone Trial.

May 14, 2026 . On or after June 8, 2026 . . Old Date/Time: _at 13:30:00 New Date/Time: at 13:30:00 No. of Prior Continuances: 0

NOTICE OF MOTION

TO: Craig W. Walsh and Marjorie J. Walsh : NOTICE IS GIVEN that the undersigned has filed this Motion. Any response to this Motion must be in writing on the reverse side and filed with the Court no later than 5 days from the date shown on the Certificate of Service when the Motion is hand-delivered or 7 days excluding Saturday, Sunday, and legal holidays when the Motion is mailed. Your written response can be delivered or mailed to the Court at 1111 Alakea Street, Civil Division, Third Floor, Honolulu, Hawai‘i 96813. IF NO RESPONSE IS RECEIVED BY THE COURT BY THE DATES SPECIFIED IN THIS NOTICE, THIS MOTION MAY BE GRANTED.

Signature of Declarant/Attorney: / gy Zz Lei

May 5, 2026 . Date: Print/Type Name: Leslie Altherr on behalf of Google LLC SEE AND USE REVERSE SIDE TO RESPOND TO MOTION I certify that this is a full, true, and correct copy of the original on filed in this office. Clerk, District Court of the above Circuit, State of Hawai‘i 1D-P-789 Common Look® Reprographics (09/11) 1D

(Rev. 08/03/2011) 5°8<ertified Page 1 of 2 Form 1DC11

CERTIFICATE OF SERVICE I certify that I served a copy of this Motion to the Opposing Party or Opposing Party’s attorney on (date) May 5, 2026 by © Hand-delivery or vA Mail, addressed as follows:

350 Ward Avenue, 106-B Honolulu, Hawaii 96814

Signature of Filing Party/Attorney: Laskhe kihunr May 5, 2026 rgnature of Sting BaryiAtomey cad

Date: Print/Type Name: Leslie Altherr on behalf of Google LLC

RESPONSE TO MOTION/CERTIFICATE OF SERVICE CO IDONOT OBJECT to this Motion.

O I DISAGREE with this Motion for the following reasons: (Attach continuation page, if necessary).

Reserved for Court Use

T have read this Response, know the contents and verify that the statements are true to my personal knowledge and belief. I DECLARE UNDER PENALTY OF PERJURY THAT WHAT I HAVE STATED IS TRUE AND CORRECT.

CERTIFICATE OF SERVICE I certify that I served a copy of this Response to the Filing Party or Filing Party’s attorney on (date) by © Hand-delivery or O Mail, addressed as follows:

Signature of Opposing Party/Attorney:

Date: Print/Type Name:

Reserved for Court Use COURT ORDER

1 This Motion is granted and you must appear at the new date and time stated in the Declaration on the reverse side.

(0 This Motion is denied and you must appear at the old date and time stated in the Declaration on the reverse side.

0 This Motion is partially granted and you must appear at ___.m.on for O ANSWER HEARING ON MOTION

O RETURNABLE O PRE-TRIAL

O TRIAL O OTHER-

Date: Judge

Inaccordance with the Americans with Disabilities Act and other applicable state and federal laws, if you require an accommodation t for a disability when working with a court program, service, or activity, please contact the District Court Administration Office at © PHONE NO. (808) 538-5121, FAX (808) 538-5233, or TTY (808) 539-4853 at least ten (10) working days before your proceeding, hearing, or appointment date. For all Civil related matters, please call (808) 538-5151 or visit the District Court Service

Center, 1111 Alakea Street, Third (3") Floor.

1D-P-789 CommonLook® (Rev. 08/03/2011) 28 Certified Page 2 of 2 Form |DC11

Google

1600 Amphitheatre Parkway Tel: 650.253.0000 Mountain View, California 94043 Fax: 650.253.0001 www.google.com

May 5, 2026

Kauikeaouli Hale

Honolulu Division : 1111 Alakea Street, 10th floor, RE C E IVE D

Honolulu, Hawaii 96813 MAY 12 7026 RE: Craig W Walsh, PLT, et al v. Google LLC, DFT. C+M WALSH Case Number: 1DSC-26-0000370 HONOLULU

Hearing Date: May 14, 2026 at 1:30 PM GMT DEFENDANT’S REQUEST TO POSTPONE TRIAL

To The Court:

Google LLC (“Google”) writes in regards to the above-referenced Small Claims suit. Google would prefer to appear remotely at the hearing time as scheduled. If this is not possible, Google seeks a continuance to acquire counsel to appear on its behalf. Google respectfully requests that the Courts postpone the hearing currently scheduled for May 14, 2026 to on or after June 8, 2026.

Please note that Google’s principal place of business is Santa Clara County California, and due to scheduling conflicts and limited staffing, a Google representative is unable to appear physically at the hearing currently scheduled. In absence of a granted postponement or remote request, Google’s defense will rest on their filed Motion to Dismiss. Should you wish to follow up on this matter, you may contact us at

[email protected]. Thank you for your attention and consideration to this matter.

Respectfully submitted,

Google LLC

[email protected]

Google

1600 Amphitheatre Parkway Tel: 650.253.0000 Mountain View, California 94043 Fax: 650.253.0001

www.google.com

CERTIFICATE OF SERVICE

Google certifies that a copy hereof has been furnished to the following parties on May 5, 2026. The names and address of the parties are as follows:

Craig W. Walsh

Marjorie J. Walsh

350 Ward Avenue 106-B

Honolulu, Hawaii 96814

Via USPS: 9405 5362 0830 3312 6643 34

Kauikeaouli Hale

Honolulu Division

1111] Alakea Street, 10th floor, Honolulu, Hawaii 96813

Via efile

Sincerely,

Google LLC [email protected]

MOTION TO DISMISS; DECLARATION; NOTICE OF MOTION; CERTIFICATE OF SERVICE

IN THE DISTRICT COURT OF THE FIRST CIRCUIT Honolulu DIVISION STATE OF HAWAI‘I

Plaintiff

Craig W. Walsh Marjorie J. Walsh

Reserved for Court Use

Civil No. 1DSC-26-0000370

Defendant Filing Party/Attorney Name, Attorney Number, Firm Name

(if applicable), Address, Telephone Number and Email Google LLC

Leslie Altherr on behalf of Google LLC 1600 Amphitheatre Parkway

Mountain View, CA 94043 [email protected]

MOTION TO DISMISS

Filing party requests that this Motion be set for hearing. This Motion is based on the District Court Rules of Civil Procedure, Rule 41 (6) , and the Declaration below.

DECLARATION

1.lam the Movant or {4 associated with the Movant as 4" employee of the corporation

2. The following are facts why the Motion should be granted (Attach additional page(s), if necessary):

See attached Defendant's Motion to Dismiss Letter Brief

I DECLARE UNDER PENALTY OF LAW THAT WHAT I HAVE STATED IS TRUE AND CORRECT.

May 12, 2026 Signature of Declarant: / Ly Dbtunr

Date: Print/Type Name: _ Leslie Altherr on behalf of Google LLC

SEE PAGE 2 FOR NOTICE AND TO RESPOND TO MOTION

(Rev. 01/01/2026) Page | of 2 Motion to Dismiss RG-AC-508 (01/2026) WF Form# 1DC36

NOTICE OF MOTION

TO Craig W. Walsh and Marjorie J. Walsh, and to whom it may concen : Please take notice that this Motion will be heard by the District Judge of this Court, in the Courtroom, at the address below on (Day): Thursday , (Date): May 14, 2026 at (Time): 1:30 »P om. or as soon thereafter as parties may be heard.

COURT ADDRESSES

W Honolulu Division, 1111 Alakea Street, 10th Floor, Honolulu, Hawai‘i

O ‘Ewa Division, 870 Fourth Street, Pearl City, Hawai‘i

O Ko‘olaupoko OR Ko‘olauloa Division 45-939 Po‘okela Street, Kane‘ohe, Hawai‘i

O Wahiawa OR Waialua Division 1034 Kilani Avenue, Hawai‘i

O Wai‘anae Division 4675 Kapolei Parkway, Hawai‘i

CERTIFICATE OF SERVICE I certify that on (date): May 12, 2026 I served a copy of this Motion on all parties or their attorneys by 0 Hand-delivery or {4 Mail, addressed as follows: Craig W. Walsh USPS Tracking Number: 9405 5362 0830 3313 4338 30

Marjorie J. Walsh . 350 Ward Avenue 106-B Honolulu, Hawaii 96814

Signature of Filing Party/Attorney: / gv ha a Gharr

Date: May 12, 2026 Print/Type Name: _Leslie Altherr on behalf of Google LLC

RESPONSE TO THE MOTION/CERTIFICATE OF SERVICE 0 1DO NOT OBJECT to this Motion.

O IDISAGREE with this Motion for the following reasons (Attach additional page(s), if necessary):

Reserved for Court Use

I DECLARE UNDER PENALTY OF LAW THAT WHAT I HAVE STATED IS TRUE AND CORRECT.

CERTIFICATE OF SERVICE I certify that on (date): I served a copy of this Response to the Motion on all parties or their

attorneys by 1] Hand-delivery or [J Mail, addressed as follows:

Signature of Responding Party/Attorney:

Date: Print/Type Name:

Americans with Disabilities Act Notice

If you need an accommodation for a disability when participating in a court program, service or activity, please contact the ADA

Coordinator as soon as possible to allow the court time to provide an accommodation: « e Call (808) 538-5121; or e Send an email to [email protected]

The court will try to provide, but cannot guarantee, your requested auxiliary aid, service or accommodation. For Civil related matters, please call (808) 538-5629 or visit the District Court Service Center at 1111 Alakea Street, Third (34) Floor, Honolulu, Hawai‘i 96813.

(Rev. 1/1/2026) Page 2 of 2 Motion to Dismiss Form #1DC36

Google

1600 Amphitheatre Parkway Tel: 650.253.0000 Mountain View, California 94043 Fax: 650.253.0001 www.google.com

May 12, 2026

Kauikeaouli Hale

Honolulu Division

1111 Alakea Street, 10th floor, Honolulu, Hawaii 96813

Re: Craig W Walsh, PLT, et al v. Google LLC, DFT Case No.: 1DSC-26-0000370

Hearing Date: May 14, 2026 at 1:30 PM HST

DEFENDANT’S MOTION TO DISMISS LETTER BRIEF To the Court: I. INTRODUCTION

Google LLC (“Google”), on behalf of its parent company Alphabet Inc., writes in response to the April 14, 2026, Complaint filed by Plaintiffs Craig W. Walsh and Marjorie J. Walsh (“Plaintiff’) regarding the above-referenced small claims matter. Plaintiff alleges that their Google Voice number was suspended, and that despite their attempts to reinstate the number, Google has allegedly denied their appeal and kept the deposit used to open the account. Plaintiff is seeking $5,000.00 USD in compensatory damages.

Google requests that the court dismiss this case because: A. This is not the parties’ agreed-upon forum; B. Google reserves the right to suspend or terminate access to its services. C. Google’s Terms of Service limit the company’s liability.

For the reasons stated above, we therefore respectfully ask that this Court dismiss Plaintiff’s claims in its entirety and with prejudice.

I. BACKGROUND

Plaintiff brings this suit in Honolulu County, Hawaii, seeking $5,000.00 USD in compensatory damages. Plaintiff alleges that Google suspended their Google Voice account

without warning or explanation. When Plaintiff tried to appeal these suspensions, Google denied their appeals. Plaintiff claims that because their phone number was suspended, they have lost potential business, as a result of a loss of contact with potential clients. See Complaint.

The use of Google services and products is subject to the Google Terms of Service which can be found at https://policies.google.com/terms (Exhibit A, Pages 1-20). Google Voice is a service that enhances the existing capabilities of users’ phones by providing a central phone number that can be used over the internet from any phone. Google provides a comprehensive help center for Google Voice-related information, which can be found by visiting,

https://support.google.com/voice.

In using Google Voice, users agree to the Google Voice Additional Terms of Service https://support.google.com/voice/answer/9231816 (Exhibit A, Pages 21-22), the Voice Acceptable Use Policy https://support.google.com/voice/answer/9230450 (Exhibit A, Pages 23-24) and the Google Privacy Policy https://policies.google.com/privacy. Consistent with the Voice Acceptable Use Policy, if Google identifies a potential policy violation, Google may review and take action, including limiting or terminating a user’s access to Google Voice.

In their complaint, Plaintiff makes reference to an allegedly “failed” port out of their Google Voice number to Verizon. Google Voice numbers are locked by default for all consumers, and any attempt to port out a Google Voice number will fail while it is locked. More information about the port out process, including how to unlock a Google Voice number, can be found at

https://support.google.com/voice/answer/1065667. Please note, a Google Voice number may not

be unlocked while the Google Voice account is suspended. Google’s record reflects the following:

e On July 29, 2009, Plaintiff created a Google Voice account using the gmail account, cra***|[email protected], and thereby agreed to the Google Terms of Service, the Google Voice Additional Terms of Service, and the Voice Acceptable Use Policy.

e On August 5, 2023, Plaintiff acquired their Google Voice number ending in 4708. Please note that while Plaintiff has received and utilized multiple Google Voice numbers throughout their use of Google Voice services, the number ending in 4708 was only issued in August of 2023.

e@ On February 6, 2026, Plaintiff’s Google Voice account was suspended for violating the Voice Acceptable Use policy. Later that same day, Plaintiff contacted the Google Voice Support team to submit an appeal for their suspended Google Voice account. (Exhibit B, Page 1)

e@ On February 7, 2026, The Google Voice Support team reviewed the appeal and determined Plaintiff’s use of Google Voice violated the Voice Acceptable Use Policy. Plaintiffs Google Voice service was denied reinstatement. (Exhibit B, Page 2)

e On April 10, 2026, Plaintiff contacted the Google Voice Support team to submit a second appeal for their suspended Google Voice account. The Google Voice Support team reviewed the appeal and determined Plaintiff’s use of Google Voice violated the Voice

Acceptable Use Policy. Plaintiff’s Google Voice service was again denied reinstatement. (Exhibit B, Page 3)

e On May 6, 2026, Google conducted another investigation into Plaintiff's Google Voice suspension. Plaintiffs usage of Google Voice was once again determined to be in violation of the Voice Acceptable Use Policy, and their account remained ineligible for reinstatement.

Il. LEGAL ARGUMENTS A. This is not the parties’ agreed-upon forum.

The use of Google products and services is governed by the Google Terms of Service, which state that:

“California law will govern all disputes arising out of or relating to these terms, service-specific additional terms, or any related services, regardless of conflict of laws rules. These disputes will be resolved exclusively in the federal or state courts of Santa Clara County, California, USA, and you and Google consent to personal jurisdiction in those courts” (Exhibit A, Page 16).

Plaintiff’s claim was filed in Honolulu County, Hawaii, which is in direct contradiction to the Governing Law section of the Google Terms of Service that the Plaintiff agreed to through their use of Google services. Therefore, the Court should dismiss this case for improper jurisdiction.

B. Google reserves the right to suspend or terminate access to its services. In pertinent part, the Google Terms of Service state that:

“Without limiting any of our other rights, Google may suspend or terminate your access to the services or delete your Google Account if any of these things happen:

e you materially or repeatedly breach these terms, service-specific additional terms or policies

@ we’re required to do so to comply with a legal requirement or a court order

e your conduct causes harm or liability to a user, third party, or Google — for example, by hacking, phishing, harassing, spamming, misleading others, or scraping content that doesn’t belong to you” (Exhibit A, Page 15).

Plaintiff's Google Voice account was initially suspended on February 6, 2026, due to being used in a way that violated the Google Voice Acceptable Use policy. Following the account’s suspension, Plaintiff followed the account appeals process and submitted several

appeals. For each appeal request, Google completed an additional review of the account and confirmed that it was, in fact, used in a way that violated Google’s policies. As a result of violating the Google Voice Acceptable Use Policy, Plaintiff's access to Google Voice accounts and services were suspended.

As of the date of this motion, Google has conducted three additional investigations into Plaintiff’s account following its initial suspension. In each case, a human reviewer has affirmed that the account had been appropriately suspended due to violations of the Voice Acceptable Use Policy. Google asserts it acted in accordance with its Terms of Service to suspend Plaintiff’s access to their Google Voice account. As such, Google respectfully requests that the court dismiss Plaintiff’s claim in its entirety with prejudice.

C. Google’s Terms of Service limit the company’s liability.

Notwithstanding the above, the Google Terms of Service state that: “To the extent allowed by applicable law:

e@ Google is liable only for its breaches of these terms or applicable service-specific additional terms

e Google isn’t liable for:

e loss of profits, revenues, business opportunities, goodwill, or anticipated savings

e indirect or consequential losses e@ punitive damages

III. | Google’s total liability arising out of or relating to these terms is limited to the greater of (1) $200 or (2) the fees paid to use the relevant services in the 12 months before the dispute.” (Exhibit A, Page 14)

To the extent Plaintiff brings these claims for their use of Google Voice, Plaintiff is subject to the Google Terms of Service. Accordingly, Plaintiff’s recoverable damages in this case are limited to $200.00 USD or “the fees paid to use the relevant services in the 12 months before the dispute.” Plaintiff has not alleged that they paid for any Google services. Thus, even if Plaintiff’s claim were substantiated, their damages would be limited to $200.00 USD per the Google Terms of Service.

IV. INCLUSION

For the aforementioned reasons set forth in this letter, Google moves to dismiss Plaintiff's claim with prejudice. Thank you for your attention.

Sincerely, Google LLC [email protected]

Cc: Craig W. Walsh and Marjorie J. Walsh

Exhibit A

GOOGLE TERMS OF SERVICE

Effective May 22, 2024 | Archived versions

What's covered in these terms

We know it’s tempting to skip these Terms of Service, but it’s important to establish what you can expect from us as you use Google services, and what we expect from you.

These Terms of Service reflect the way Google's business works, the laws that apply to our company, and certain things weve always believed to be true. As a result, these Terms of Service help define Google's relationship with you as you interact with our services. For example, these terms include the following topic headings:

* What you can expect from us, which describes how we provide and develop our

services « What we expect from you, which establishes certain rules for using our services

° Content in Google services, which describes the intellectual property rights to the content you find in our services — whether that content belongs to you, Google, or others

° In case of problems or disagreements, which describes other legal rights you have, and what to expect in case someone violates these terms

Understanding these terms is important because, by accessing or using our services (whether you’re signed in to a Google account or not), you're agreeing to these terms.

Besides these terms, we also publish a Privacy Policy. We encourage you to read it to better understand how you can update, manage, export, and delete your information.

Terms

Service provider

Google services are provided by, and you're contracting with:

Google LLC organized under the laws of the State of Delaware, USA, and operating under the laws of the USA

1600 Amphitheatre Parkway Mountain View, California 94043 USA

Age requirements

If you're under the age required to manage your own Google Account, you must have your parent or legal guardian's permission to use a Google Account. Please have your

parent or legal guardian read these terms with you.

If you're a parent or legal guardian, and you allow your child to use the services, then these terms apply to you and you're responsible for your child’s activity on the services.

Some Google services have additional age requirements as described in their service-

specific additional terms and policies.

Your relationship with Google

These terms help define the relationship between you and Google. When we speak of “Google,” “we,” “us,” and “our,” we mean Google LLC and its affiliates. Broadly speaking, we give you permission to access and use our services if you agree to follow these terms,

which reflect how Google's business works and how we earn money.

What you can expect from us

Provide a broad range of useful services

We provide a broad range of services that are subject to these terms, including: * apps and sites (like Search and Maps)

° platforms (like Google Shopping)

¢ integrated services (like Maps embedded in other companies’ apps or sites)

¢ devices (like Google Nest and Pixel) Many of these services also include content that you can stream or interact with.

Our services are designed to work together, making it easier for you to move from one activity to the next. For example, if your Calendar event includes an address, you can click on that address and Maps can show you how to get there.

Develop, improve, and update Google services

Were constantly developing new technologies and features to improve our services. For example, we use artificial intelligence and machine learning to provide you with simultaneous translations, and to better detect and block spam and malware. As part of this continual improvement, we sometimes add or remove features and functionalities, increase or decrease limits to our services, and start offering new services or stop offering old ones. When a service requires or includes downloadable or preloaded software, that software sometimes updates automatically on your device once a new version or feature

is available. Some services let you adjust your automatic update settings.

If we make material changes that negatively impact your use of our services or if we stop offering a service, we'll provide you with reasonable advance notice, except in urgent situations such as preventing abuse, responding to legal requirements, or addressing security and operability issues. We'll also provide you with an opportunity to export your content from your Google Account using Google Takeout, subject to applicable law and policies.

What we expect from you

Follow these terms and service-specific additional terms The permission we give you to access and use our services continues as long as you comply with:

e these terms

° service-specific additional terms, which could, for example, include things like additional age requirements

You also agree that our Privacy Policy applies to your use of our services. We also provide resources like the Copyright Help Center, Safety Center, Transparency Center, and descriptions of our technologies from our policies site to answer common questions and to set expectations about using our services. Finally, we may provide specific instructions and warnings within our services — such as dialog boxes that alert you to important information.

Although we give you permission to use our services, we retain any intellectual property rights we have in the services.

Respect others We want to maintain a respectful environment for everyone, which means you must follow these basic rules of conduct:

. comply with applicable laws, including export control, sanctions, and human

trafficking laws

. respect the rights of others, including privacy and intellectual property rights

. don't abuse or harm others or yourself (or threaten or encourage such abuse or harm) — for example, by misleading, defrauding, illegally impersonating, defaming, bullying, harassing, or stalking others

Our service-specific additional terms and policies, such as our Generative Al Prohibited Use Policy, provide additional details about appropriate conduct that everyone using those services must follow. If you find that others aren't following these rules, many of our services allow you to report abuse. If we act on a report of abuse, we also provide the process described in the Taking action in case of problems section.

Don’t abuse our services

Most people who access or use our services understand the general rules that keep the internet safe and open. Unfortunately, a small number of people don't respect those rules, so were describing them here to protect our services and users from abuse. In that spirit:

You must not abuse, harm, interfere with, or disrupt our services or systems — for example, by:

° introducing malware . spamming, hacking, or bypassing our systems or protective measures

¢ jailbreaking, adversarial prompting, or prompt injection, except as part of our safety and bug testing programs

. accessing or using our services or content in fraudulent or deceptive ways, such as: ° phishing . creating fake accounts or content, including fake reviews

* misleading others into thinking that generative Al content was created by a

human

* providing services that appear to originate from you (or someone else) when

they actually originate from us . providing services that appear to originate from us when they do not

° using our services (including the content they provide) to violate anyones legal tights, such as intellectual property or privacy rights

. reverse engineering our services or underlying technology, such as our machine learning models, to extract trade secrets or other proprietary information, except as allowed by applicable law

* using automated means to access content from any of our services in violation of the machine-readable instructions on our web pages (for example, robots.txt files that disallow crawling, training, or other activities)

. using Al-generated content from our services to develop machine learning models or related Al technology

. hiding or misrepresenting who you are in order to violate these terms

¢ providing services that encourage others to violate these terms

Permission to use your content

Some of our services are designed to let you upload, submit, store, send, receive, or share your content. You have no obligation to provide any content to our services and you're free to choose the content that you want to provide. If you choose to upload or share content, please make sure you have the necessary rights to do so and that the content is

lawful.

License

Your content remains yours, which means that you retain any intellectual property rights that you have in your content. For

example, you have intellectual property rights in the creative content you make, such as reviews you write. Or you may have the right to share someone elses creative content if they've given you their permission.

We need your permission if your intellectual property rights restrict our use of your content. You provide Google with that permission through this license.

What's covered

This license covers your content if that content is protected by intellectual property rights.

What's not covered

e — This license doesn't affect your privacy rights — it’s only about your intellectual property rights

° This license doesn’t cover these types of content:

° publicly-available factual information that you provide, such as corrections to the address of a local business. That information doesn't require a license because it’s considered common knowledge that everyone's free to use.

e — feedback that you offer, such as suggestions to improve our services. Feedback is covered in the Service-related communications section below.

Scope This license is: ° worldwide, which means it’s valid anywhere in the world

* non-exclusive, which means you can license your content to others

* royalty-free, which means there are no monetary fees for this license

Rights

This license allows Google to:

e host, reproduce, distribute, communicate, and use your content — for example, to save your content on our systems and make it accessible from anywhere you go

. publish, publicly perform, or publicly display your content, if you've made it visible to others

. modify and create derivative works based on your content, such as reformatting or translating it

e sublicense these rights to:

. other users to allow the services to work as designed, such as enabling you to share photos with people you choose

* our contractors who've signed agreements with us that are consistent with these terms, only for the limited purposes described in the Purpose section below

Purpose

This license is for the limited purpose of:

. operating and improving the services, which means allowing the services to work as designed and creating new features and functionalities. This includes using automated systems and algorithms to analyze your content:

. for spam, malware, and illegal content

« torecognize patterns in data, such as determining when to suggest a new album in Google Photos to keep related photos together

° to customize our services for you, such as providing recommendations and personalized search results, content, and ads (which you can change or turn off in Ads Settings)

This analysis occurs as the content is sent, received, and when

it is stored.

¢ using content you've shared publicly to promote the services. For example, to promote a Google app, we might quote a review you wrote. Or to promote Google Play, we might show a screenshot of the app you offer in the Play Store.

¢ developing new technologies and services for Google consistent with these terms

Duration

This license lasts for as long as your content is protected by intellectual property rights.

If you remove from our services any content that’s covered by this license, then our systems will stop making that content publicly available in a reasonable amount of time. There are two exceptions:

¢ If you already shared your content with others before removing it. For example, if you shared a photo with a friend who then made a copy of it, or shared it again, then that photo may continue to appear in your friend's Google Account even after you remove it from your Google Account.

.e If you make your content available through other companies’ services, it’s possible that search engines, including Google Search, will continue to find and display your content as part of their search results.

Using Google services

Your Google Account

If you meet these age requirements you can create a Google Account for your convenience. Some services require that you have a Google Account in order to work — for example, to use Gmail, you need a Google Account so that you have a place to send and receive your email.

You're responsible for what you do with your Google Account, including taking reasonable steps to keep your Google Account secure, and we encourage you to regularly use the Security Checkup.

Using Google services on behalf of an organization or business

Many organizations, such as businesses, non-profits, and schools, take advantage of our

services. To use our services on behalf of an organization: * an authorized representative of that organization must agree to these terms

oy your organization's administrator may assign a Google Account to you. That administrator might require you to follow additional rules and may be able to access or disable your Google Account.

Service-related communications

To provide you with our services, we sometimes send you service announcements and other information. To learn more about how we communicate with you, see Google's Privacy Policy.

If you choose to give us feedback, such as suggestions to improve our services, we may act on your feedback without obligation to you.

Content in Google services

Your content

Some of our services allow you to generate original content. Google won't claim

ownership over that content.

Some of our services give you the opportunity to make your content publicly available — for example, you might post a product or restaurant review that you wrote, or you might upload a blog post that you created.

. See the Permission to use your content section for more about your rights in your content, and how your content is used in our services

° See the Removing your content section to learn why and how we might remove user- generated content from our services

If you think someone is infringing your intellectual property rights, you can send us notice

of the infringement and we'll take appropriate action. For example, we suspend or close the Google Accounts of repeat copyright infringers as described in our Copyright Help Center.

Google content

Some of our services include content that belongs to Google — for example, many of the visual illustrations you see in Google Maps. You may use Google's content as allowed by these terms and any service-specific additional terms, but we retain any intellectual property rights that we have in our content. Don’t remove, obscure, or alter any of our branding, logos, or legal notices. If you want to use our branding or logos, please see the Google Brand Permissions page.

Other content

Finally, some of our services give you access to content that belongs to other people or organizations — for example, a store owner's description of their own business, or a newspaper article displayed in Google News. You may not use this content without that person or organization’s permission, or as otherwise allowed by law. The views expressed in other people or organizations’ content are theirs, and don't necessarily reflect Google's

views.

Software in Google services

Some of our services include downloadable or preloaded software. We give you permission to use that software as part of the services.

The license we give you is:

« — worldwide, which means it’s valid anywhere in the world

. non-exclusive, which means that we can license the software to others ° royalty-free, which means there are no monetary fees for this license

° personal, which means it doesn't extend to anyone else

. non-assignable, which means you're not allowed to assign the license to anyone else

Some of our services include software that’s offered under open source license terms that we make available to you. Sometimes there are provisions in the open source license that explicitly override parts of these terms, so please be sure to read those licenses.

You may not copy, modify, distribute, sell, or lease any part of our services or software.

In case of problems or disagreements

Warranty disclaimer

We built our reputation on providing useful, reliable services like Google Search and Maps, and were continuously improving our services to meet your needs. However, for legal purposes, we offer our services without warranties unless explicitly stated in our service-

specific additional terms. The law requires that we explain this using specific legal language and that we use capital letters to help make sure you see it, as follows:

TO THE EXTENT ALLOWED BY APPLICABLE LAW, WE PROVIDE OUR SERVICES "AS 1S” WITHOUT ANY EXPRESS OR IMPLIED WARRANTIES, INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. FOR EXAMPLE, WE DON’T MAKE ANY WARRANTIES ABOUT THE CONTENT OR FEATURES OF THE SERVICES, INCLUDING THEIR ACCURACY, RELIABILITY, AVAILABILITY, OR ABILITY TO MEET YOUR NEEDS.

DON’T RELY ON THE SERVICES FOR MEDICAL, LEGAL, FINANCIAL, OR OTHER PROFESSIONAL ADVICE. ANY CONTENT REGARDING THOSE TOPICS IS PROVIDED FOR INFORMATIONAL PURPOSES ONLY AND IS NOT A SUBSTITUTE FOR ADVICE FROMA QUALIFIED PROFESSIONAL.

Liabilities

For all users

Both the law and these terms try to strike a balance as to what you or Google can claim from the other in case of problems. That's why the law requires everyone to be responsible for certain liabilities — but not others — under these terms.

These terms only limit our responsibilities as allowed by applicable law. These terms don't limit liability for gross negligence or willful misconduct.

To the extent allowed by applicable law:

. Google is liable only for its breaches of these terms or applicable service-specific additional terms

. Google isn't liable for:

+ loss of profits, revenues, business opportunities, goodwill, or anticipated savings

° indirect or consequential losses ° punitive damages

. Google's total liability arising out of or relating to these terms is limited to the greater of (1) $200 or (2) the fees paid to use the relevant services in the 12 months before the dispute

For business users and organizations only

If you're a business user or organization:

¢ To the extent allowed by applicable law, you'll indemnify Google and its directors, officers, employees, and contractors for any third-party legal proceedings (including actions by government authorities) arising out of or relating to your unlawful use of the services or violation of these terms or service-specific additional terms. This indemnity covers any liability or expense arising from claims, losses, damages,

judgments, fines, litigation costs, and legal fees.

° If you're legally exempt from certain responsibilities, including indemnification, then those responsibilities don't apply to you under these terms. For example, the United Nations enjoys certain immunities from legal obligations and these terms don't override those immunities.

Taking action in case of problems

Before taking action as described below, we'll provide you with advance notice when reasonably possible, describe the reason for our action, and give you an opportunity to clarify the issue and address it, unless doing so would:

. cause harm or liability to a user, third party, or Google e violate the law or a legal enforcement authority's order . compromise an investigation

. compromise the operation, integrity, or security of our services

Removing your content

If any of your content (1) breaches these terms, service-specific additional terms or policies, (2) violates applicable law, or (3) could harm our users, third parties, or Google, then we reserve the right to take down some or all of that content in accordance with applicable law. Examples include child pornography, content that facilitates human trafficking or harassment, terrorist content, and content that infringes someone else's intellectual property rights.

Suspending or terminating your access to Google services

Without limiting any of our other rights, Google may suspend or terminate your access to the services or delete your Google Account if any of these things happen:

. you materially or repeatedly breach these terms, service-specific additional terms or

policies ° we're required to do so to comply with a legal requirement or a court order

. your conduct causes harm or liability to a user, third party, or Google — for example, by hacking, phishing, harassing, spamming, misleading others, or scraping content that doesn't belong to you

For more information about why we disable accounts and what happens when we do, see this Help Center page. If you believe your Google Account has been suspended or terminated in error, you can appeal.

Of course, you're always free to stop using our services at any time. If you do stop using a service, we'd appreciate knowing why so that we can continue improving our services.

Settling disputes, governing law, and courts

For information about how to contact Google, please visit our contact page.

California law will govern all disputes arising out of or relating to these terms, service- specific additional terms, or any related services, regardless of conflict of laws rules. These disputes will be resolved exclusively in the federal or state courts of Santa Clara County, California, USA, and you and Google consent to personal jurisdiction in those courts.

About these terms

By law, you have certain rights that can't be limited by a contract like these terms of service. These terms are in no way intended to restrict those rights.

These terms describe the relationship between you and Google. They don't create any legal rights for other people or organizations, even if others benefit from that relationship under these terms.

We want to make these terms easy to understand, so weve used examples from our services. But not all services mentioned may be available in your country.

If these terms conflict with the service-specific additional terms, the additional terms will

govern for that service.

If it turns out that a particular term is not valid or enforceable, this will not affect any other terms.

If you don't follow these terms or the service-specific additional terms, and we don't take action right away, that doesn’t mean were giving up any rights that we may have, such as taking action in the future.

We may update these terms and service-specific additional terms (1) to reflect changes in our services or how we do business — for example, when we add new services, features, technologies, pricing, or benefits (or remove old ones), (2) for legal, regulatory, or security reasons, or (3) to prevent abuse or harm.

If we materially change these terms or service-specific additional terms, we'll provide you with reasonable advance notice and the opportunity to review the changes, except (1) when we launch a new service or feature, or (2) in urgent situations, such as preventing ongoing abuse or responding to legal requirements. If you don't agree to the new terms, you should remove your content and stop using the services. You can also end your relationship with us at any time by closing your Google Account. If you close your Google Account and then access or use our services without an account, that access and use will be subject to the most current version of these terms.

DEFINITIONS

affiliate

An entity that belongs to the Google group of companies, which means Google LLC and its subsidiaries, including the following companies that provide consumer services in the EU: Google Iretand Limited, Google Commerce Limited, and Google Dialer Inc.

business user

An individual or entity who is not a consumer (see consumer).

consumer

An individual who uses Google services for personal, non-commercial purposes outside of their trade, business, craft, or profession. (See business user)

copyright

A legal right that allows the creator of an original work (such as a blog post, photo, or video) to decide if and how that original work may be used by others, subject to certain limitations and exceptions (such as “fair use” and “fair dealing”).

disclaimer

A statement that limits someone's legal responsibilities.

indemnify or indemnity

An individual or organization's contractual obligation to compensate the losses suffered by another individual or organization from legal proceedings such as lawsuits.

intellectual property rights (IP rights)

Rights over the creations of a person's mind, such as inventions (patent rights); literary and artistic works (copyright); designs (design rights); and symbols, names, and images used in commerce (trademarks). IP rights may belong to you, another individual, or an

organization.

liability

Losses from any type of legal claim, whether the claim is based on a contract, tort (including negligence), or other reason, and whether or not those losses could have been

reasonably anticipated or foreseen.

organization

A legal entity (such as a corporation, non-profit, or school) and not an individual person.

services

The Google services that are subject to these terms are the products and services listed at https://policies.google.com/terms/service-specific, including:

* apps and sites (like Search and Maps) « platforms (like Google Shopping) * integrated services (like Maps embedded in other companies’ apps or sites)

« devices and other goods (like Google Nest)

Many of these services also include content that you can stream or interact with.

trademark

Symbols, names, and images used in commerce that are capable of distinguishing the goods or services of one individual or organization from those of another.

warranty

An assurance that a product or service will perform to a certain standard.

your content

Things that you create, upload, submit, store, send, receive, or share using our services,

such as:

° Docs, Sheets, and Slides you create

blog posts you upload through Blogger

reviews you submit through Maps

videos you store in Drive

emails you send and receive through Gmail

pictures you share with friends through Photos

travel itineraries that you share with Google

Additional Terms of Service

Thank you for using Google Voice! By using Google Voice (the "Service"), you accept and agree to be bound by the Google Terms of Service, the Google Voice Acceptable Use Policy, the Google Privacy Policy, as well as these additional terms and conditions (collectively the "Terms of Service"). It's important for you to read each of these documents, as they form a legal agreement between you and Google regarding your use of the Service.

Caller ID

If you have a Google Voice number, it will appear on the recipient's caller ID. If you haven't set up a Google Voice number, a generic number or the word "unknown" will appear to the person you're calling.

Emergency calls

You understand and agree that Google Voice is an enhanced call management application and that Google Voice isn't capable of placing or receiving emergency services calls. In addition, if you haven't set up a Google Voice number but you're using Google Voice to call a public-safety answering point (PSAP), then the PSAP gets a generic number or the word "unknown" on your caller ID and might not be able to call you back.

Google's proprietary rights

Google has the right not to provide calling or connections to any telephone numbers in its sole discretion. Unserved numbers may include but are not limited to certain geographic locations, special services numbers, satellite telephony services, and other call forwarding services.

Recording conversations

Google Voice provides a function that allows you to record individual telephone conversations. The laws regarding the notice and notification requirements of such recorded conversations vary by state to state. You're responsible for applying the local laws in the relevant jurisdiction when using this feature.

Bill payment

Depending on the Google Voice service you sign up to, you may be required to pay fees in connection with the Services, as stated by Google. There may be additional fees if you request a change in any Services. Depending on the level of Services selected by you, there may be charges for calls to or from certain locations, including without limitation payphones and areas within extended calling zones. There may also be applicable charges for any special or enhanced

services you use. 21

You may purchase prepaid credits to be used for Google Voice services. Google is under no obligation to offer any refunds or reimbursements for the purchase price of such prepayments. Usage of minutes is billed in one-minute increments. Prepaid credits are billed at the time of purchase.

Unless prohibited by law, any outbound calling credit that you've purchased expires 6 months from the most recent date of use, and may not be transferred.

Calling credit may be used for calls made using the Service.

Taxes

You are responsible for any taxes, and will pay any fees for the Service without reduction for taxes. lf Google is obligated to collect or pay any taxes, Google will invoice the taxes to you and you are responsible to pay such taxes to Google, unless you provide Google with a timely and valid tax exemption certificate for such taxes.

You will provide Google with any applicable tax identification information that Google may require under applicable law to ensure its compliance with applicable tax regulations and authorities in applicable jurisdictions. You will be responsible to pay (or reimburse Google for) any taxes, interest, penalties, or fines arising out of any mis-declaration you have made.

General

Calls placed to and received from phone numbers in the United States and other countries/regions are routed through and provided by various regulated and licensed partners.

The Google Voice service is provided by Google Voice, Inc., a subsidiary of Google LLC.

Voice Acceptable Use Policy

Our policies play an important role in maintaining a positive experience for our users. Please follow these policies when using Google Voice. When we identify a potential policy violation, we may review and take action, including limiting or terminating a user’s access to Google Voice.

Spam and Commercial Use Do not send or facilitate the transmission of spam, large numbers of commercial messages, or automated messages. Such activity includes, but is not limited to: sending commercial or promotional messages to a large number of users, or sending messages in bulk; sending messages via an automated process, such as a script; sending unwanted or mass solicitation; placing calls in violation of laws prohibiting unsolicited marketing calls (e.g., "do-not-call laws"); data mining any web property (including Google) to find phone numbers;

selling, exchanging, or distributing to a third party the phone numbers of any person without such person’s consent to such disclosure;

inflating call traffic (e.g., traffic pumping, international revenue share fraud).

Harassment and Bullying

Do not use the Google Voice service to threaten, bully, or harass.

Violence

Do not distribute depictions of graphic or gratuitous violence.

Child Safety

Do not distribute content that may be harmful to minors. Do not distribute content that exploits children, such as child sexual abuse imagery or content that presents children in a sexual manner.

Impersonation

Do not impersonate another person (via the use of a telephone number or otherwise) or otherwise misrepresent yourself or the source of any phone call.

Intellectual Property

Do not infringe on the intellectual property of others (including patent, trademark, trade secret, copyright, and other proprietary rights), and do not encourage or induce infringement of intellectual property rights.

Privacy 23

Do not distribute other people’s personal and confidential information, such as credit card numbers, confidential national ID numbers, or account passwords, without their permission.

IHegal Activities

Do not use Google Voice to engage in or promote illegal activities.

Malicious Products

Do not transmit viruses, malware, or any other malicious or destructive code. Do not use Google Voice in a way that harms or interferes with the operation of the networks, servers, or other infrastructure of Google or others.

System Interference and Abuse

Do not abuse the Google Voice Service, and do not interfere with other Google Voice users’ enjoyment of the Google Voice Service. For example:

Do not use Google Voice to data mine phone numbers or other information. Do not automate our system to place phone calls or send messages automatically. Do not forward to phone numbers that aren’t your own or under your control.

Do not create multiple user accounts, and do not create user accounts by automated means or under false or fraudulent pretenses.

Do not sell, trade, resell or otherwise exploit for any unauthorized commercial purpose or transfer any Google Voice account or the Google Voice Service.

Do not modify, adapt, translate, or reverse engineer any portion of the Google Voice Service.

Do not remove any copyright, trademark, or other proprietary rights notices contained in or on the Google Voice Service.

Do not reformat or frame any portion of the web pages that are part of the Google Voice Service.

Account Inactivity

Google may reclaim your Google Voice number (if you have one) if you do not appear to be making use of the service as it was intended, such as placing calls or sending text messages for a period of 3 months. We advise checking your email for notifications regarding any such number reclamation based on account inactivity.

Exhibit B

5/12/26, 10:28 AM Connect Cases

Case 3-4476000040343: Unable to access a Google product

Item types: Customer communicatio: ~ crash @gmail.com Fri, Feb 6, 8:25PM

Source Submitted via Help Center Direct to Form

Symptom (help category) Not available

Contact form

Email address we can use to contact you [email protected]

Please briefly explain why you think your access was suspended in error. Please include any relevant information that you believe could have caused the suspension.

| have not violated any of Google's terms and conditions. | have been a Google customer for 25+ years.

Data collected when case was created

Username

cra '[email protected]

View Contact Us Form 4

"FORWARD REPLY

From: [email protected] Fri, Feb 6, 8:25PM To: — [email protected]

[3-4476000040343]

Google Accounts

Thank you for contacting us about restoring access to your Google Account.

Google will review your appeal as soon as possible. Most requests take 2 business days to review, but some might take longer.

You may be able to download your data from some Google services. To get started, sign in to your account. If your account is eligible, you'll see a link to download your data.

Thanks for your patience.

https://cases.connect.corp.google.com/#/case/3 4476000040343/print case log

5/12/26, 10:28 AM Connect Cases

You received this message because someone provided this as the contact email address for an appeal. If you didn't submit an appeal, you may disregard this message.

© 2025 Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

N From: [email protected] Sat, Feb 7, 5:14AM 3

To: — [email protected]

Re: [3-4476000040343]

Hello,

We have reviewed your request and cannot reinstate your Google Voice service. Your Google Voice service has been suspended for violations of our Google Voice Policies.

If you have any further questions, please consult the Google Voice Help Center. Thanks,

Google Voice Support Team

Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043 USA Google

Y FORWARD REPLY

https://cases.connect.corp.google.com/#/case/3 4476000040343 /print case log

5/12/26, 10:20 AM Connect Cases

Case 1-1953000040723: Unable to access a Google product

Item types: Customer communicatio: v

Apr 10, 4:58AM

[email protected]

Contact Us Form Email address we can use to contact you [email protected] Please briefly explain why you think your

Apr 10, 4:59AM

N [email protected]

From: [email protected] Fri, Apr 10, 7:54AM

To: — [email protected]

Re: [1-1953000040723]

Hello,

We have reviewed your request and cannot reinstate your Google Voice service. Your Google Voice service has been suspended for violations of our Google Voice Policies.

If you have any further questions, please consult the Google Voice Help Center. Thanks,

Google Voice Support Team

Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043 USA Google

Yo FORWARD REPLY

https://cases.connect.corp.google.com/#/case/1 1953000040723/print case log

CRAIG W. WALSH MARJORIE J. WALSH

350 Ward Avenue, Suite 106-B Honolulu, Hawai‘i 96814 Telephone: (802) 359-2718 Email: [email protected]

Plaintiffs Pro Se IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAI‘I CRAIG W. WALSH and Civil No. 1DSC-26-0000370 MARJORIE J. WALSH, Plaintiffs, PLAINTIFFS’ OPPOSITION TO vs. DEFENDANT’S MOTION TO GOOGLE LLC, DISMISS; PLAINTIFFS’ MOTION TO Defendant. REQUIRE DEFENDANT TO APPEAR

THROUGH LICENSED HAWAI‘I COUNSEL; CERTIFICATE OF SERVICE

Hearing: May 14, 2026 at 1:30 PM Judge: Hon. Erika E. Ireland

I. INTRODUCTION

Plaintiffs filed this case in Small Claims Court because the Small Claims Division was designed to provide ordinary Hawai‘i residents with a simple, accessible, and inexpensive forum for resolving modest disputes —- a forum free of the formal motion practice and procedural complexity that characterizes regular civil litigation. Plaintiffs had hoped that this case would

proceed in that spirit: through a short hearing, perhaps mediation, and a decision on the merits.

Defendant Google LLC has chosen a different course. On May 12, 2026 — two days before this Court’s scheduled hearing —- Defendant filed a thirty-six page Motion to Dismiss with prejudice (Dkt. 12), and approximately twenty-six minutes later re-filed the motion with a

corrected certificate of service (Dkt. 17). Both filings cite case law, quote contract clauses, and ask

Page | of 11

this Court to terminate Plaintiffs’ claim before any evidence is presented. Both were signed by Ms. Leslie Altherr, identified on the face of the filings only as “an employee of the corporation.” No Hawai‘i-licensed attorney has entered an appearance for Defendant. No attorney name, bar number, or firm name appears on any of Defendant’s filings. A search of the California State Bar’s licensee database conducted by Plaintiffs on May 13, 2026 returned no results for “Leslie Altherr,”

indicating that she is not admitted to practice law even in California, where she is located.

Plaintiffs file this Opposition and Motion reluctantly. They do not wish to engage in the kind of formal motion practice that the Small Claims Division was created to avoid. They file now only because Defendant has done so, and because the issues raised by Defendant’s filings cannot be left unanswered. The relief Plaintiffs seek is straightforward: that this Court (1) deny Defendant’s Motion to Dismiss; (2) require Defendant to appear through licensed Hawai‘i counsel before any further motion practice in this case; and (3) return this case to the simple, informal process the Small Claims Division is designed to provide — mediation through the Mediation

Center of the Pacific, and, if necessary, a hearing on the merits.

Il. BACKGROUND

Plaintiffs filed their Statement of Claim on April 14, 2026, seeking $5,000 in damages arising from Defendant’s suspension of a Google Voice account that Plaintiff Craig Walsh has held continuously since July 2009 — nearly seventeen years. The account telephone number, 415- 915-4708, has acquired substantial commercial value through its long association with Plaintiff Marjorie Walsh’s professional services in Honolulu. Defendant suspended the account in February 2026 without notice, has refused over four separate appeals to identify any specific policy violation, has refused to release the number, has refused to return seventeen years of communications data, and has not refunded a $10.00 calling credit Plaintiff paid in 2009. The full facts are set forth in the Statement of Claim and supporting exhibits.

On May 5, 2026, Defendant filed a Non-Hearing Motion for Continuance (Dkt. 10) in which Defendant candidly stated, in a sentence signed by Ms. Altherr: “Google seeks a continuance to acquire counsel to appear on its behalf.” That motion was partially granted on May 7, 2026 by Judge Erika E. Ireland; the trial date was reset to on or after June 8, 2026, and the May

14 hearing was preserved.

Page 2 of 11

On May 12, 2026 — having not yet retained Hawai‘i counsel — Defendant filed the Motion to Dismiss now before this Court (Dkt. 12, time-stamped 6:48 AM). Approximately twenty-six minutes later, at 7:14 AM, Defendant re-filed the motion together with a corrected certificate of service (Dkt. 17). Defendant’s own description of the re-filing, entered on the JEFS docket, states: “Re-filing the Motion to Dismiss form, as the former version did not correctly reflect both Tracking numbers. The FEDEX label is meant to arrive overnight, while the USPS is standard mail.” Both

filings were made by Ms. Altherr, identified again as “an employee of the corporation.”

As of the time this Opposition was prepared, Plaintiffs have not received Defendant’s Motion to Dismiss — either Dkt. 12 or Dkt. 17 — by mail or by any other physical means. Plaintiffs received Dkt. 10 (the May 5 Motion for Continuance) by mail on May 12, but in a form that did not include the Court’s May 7 disposition. Plaintiffs are aware of the existence of the Motion to Dismiss only because Plaintiff Craig W. Walsh contacted Hawai‘i Judiciary staff on the morning of May 12, 2026 to request that this Small Claims action be added to his JEFS account, so that he could electronically file the Certificate of Service of Plaintiffs’ Statement of Claim on Defendant. Plaintiffs’ awareness of Defendant’s motion practice is therefore the product of their own diligence in monitoring the electronic docket — a diligence not contemplated by, and not required of, Small Claims Division litigants under any rule of court. Plaintiff Marjorie J. Walsh, who is not a JEFS registered filer, remains on the Court’s list of parties requiring conventional service (see Dkt. 19) and has received nothing from Defendant relating to the Motion to Dismiss

by any means.

Ill. THE MOTION TO DISMISS IS NOT PROPERLY BEFORE THIS COURT

Before the Court reaches the merits of Defendant’s Motion, two threshold questions must be addressed: whether Defendant’s filings were made by an authorized representative, and whether the motion has been properly served on Plaintiffs. Plaintiffs respectfully submit that the answer to both is no.

A. Hawai‘ law requires corporations to appear through licensed attorneys.

Under Hawai‘i Revised Statutes § 605-2, no person may practice in any court of this State unless duly licensed by the Hawai‘i Supreme Court. In Oahu Plumbing & Sheet Metal v. Kona

Page 3 of 11

Construction, Inc., 60 Haw. 372, 590 P.2d 570 (1979), the Hawai‘i Supreme Court held that, under § 605-2, “a corporation cannot appear and represent itself either in proper person or by its officers, but can do so only by an attorney admitted to practice law.” 60 Haw. at 374, 590 P.2d at 572. The reason is fundamental: corporations are legal fictions that can act only through agents, and the agents authorized to act for them in court must be persons subject to the discipline of the courts. As the Hawai‘i Supreme Court explained, “Unlike lay agents of corporations, attorneys are subject to professional rules of conduct and are amenable to disciplinary action by the courts for violations of ethical standards. Therefore, attorneys, being fully accountable to the courts, are properly designated to act as the representatives of corporations.” Id. at 378, 590 P.2d at 574 (citation omitted).

B. The narrow small claims exception in HRS § 633-28(b) does not authorize Defendant’s

appearance here.

The Hawai‘i Legislature has created one carefully bounded exception to the rule that

corporations must appear through counsel. HRS § 633-28(b) provides:

Notwithstanding any provision of law requiring the licensing of practitioners, any person, with the approval of the court, may appear on behalf of the person or another person in the small claims division of the district court . . . . The services of an unlicensed person appearing under this subsection shall be without compensation, either by way of direct fee, contingent fee, or otherwise. In the event representation services are rendered for compensation, this subsection is inapplicable and the rendering of the services constitutes the unlawful practice of

law….

The Hawai‘i Supreme Court has explained the rationale for this exception in language that

directly governs this case:

Although we recognize that corporations may be represented by non-attorney agents in Small Claims court, such representation is provided for by statute, see HRS § 633-28(b), and is consistent with the established purpose of providing quick, impartial and inexpensive settlement of disputes in the Small Claims courts. . . .

Moreover, unlike proceedings in the circuit courts, virtually no rules of evidence

Page 4 of 11

and far fewer rules of procedure apply in the Small Claims courts. . . . Therefore, problems which may otherwise occur when lay persons are permitted to act as representatives of corporations are greatly minimized in the more informal setting

of the Small Claims courts. Oahu Plumbing, 60 Haw. at 378-79, 590 P.2d at 575 (emphasis added).

Two conditions in HRS § 633-28(b) limit the exception, and Defendant has satisfied

neither.

First, the exception applies only “with the approval of the court.” The exception is not self- executing. It requires the affirmative permission of the presiding judge. Ms. Altherr has filed three substantive papers in this action — the May 5 Motion for Continuance, the May 12 Motion to Dismiss, and the May 12 corrected re-filing — without ever seeking such approval. This Court has not been asked to authorize Ms. Altherr’s appearance, and the record reflects no such authorization. Ms. Altherr is also a registered filer in the Hawai‘i Judiciary Electronic Filing System (JEFS Filer No. 7027909) and has used that registration to electronically file motions in this action on a recurring basis. The narrow informal-hearing exception of HRS § 633-28(b) does not contemplate

this pattern of organized motion practice by a non-attorney corporate employee.

Second, the statute requires that the services of an unlicensed representative “shall be without compensation, either by way of direct fee, contingent fee, or otherwise.” HRS § 633-28(b) (emphasis added). Ms. Altherr is Defendant’s salaried employee. According to her publicly available LinkedIn profile, she is “Senior Manager, Legal Specialist” at Google LLC; her ZoomInfo profile describes her career as “Manager, Litigation & Support Paralegal” at Google, “Senior Litigation Paralegal” at Fenwick & West LLP, and “Litigation Paralegal” at Morrison & Foerster and Hancock Rothert and Bunshoft. No law degree is listed in any of these sources. A search of the California State Bar’s licensee database conducted by Plaintiffs on May 13, 2026 returned no results for “Leslie Altherr,” indicating that Ms. Altherr is not admitted to practice law in California. Appearing for Google in small claims actions across the United States is part of Ms. Altherr’s paid employment. She is therefore compensated for that representation, in salary if not in per-case fee. The Legislature’s choice of the word “otherwise” was deliberate and capacious; it

forecloses precisely this kind of routinized in-house representation. By the terms of the statute,

Page 5 of 11

where representation services are rendered for compensation, “this subsection is inapplicable and

the rendering of the services constitutes the unlawful practice of law.”

The small claims exception was designed for the genuine pro se small business owner — the local sole proprietor, the family-run LLC, the contractor who cannot afford counsel for a $5,000 claim. It was not designed to permit a $2 trillion corporation to staff its nationwide consumer litigation through in-house paralegals while avoiding the cost of retaining local counsel. The Hawai‘i Supreme Court’s rationale for the exception in Oahu Plumbing was that the informality of small claims practice “greatly minimize[s]” the problems associated with lay representation. That rationale does not extend to a defendant that files a thirty-six page dispositive motion citing

case law and seeking dismissal with prejudice.

C. Defendant’s filings are made on a form not designated for Small Claims Division use.

Defendant’s Motions to Dismiss were filed on District Court Form 1DC36 — the standard motion form used for regular civil practice in the District Court, not the Small Claims Division. The form contains designated fields for “Attorney Number” and “Firm Name.” In each of Defendant’s filings, those fields are blank. The form itself documents that no attorney is appearing on behalf of Defendant. The form also designates the “Honolulu” Division of the District Court rather than the Small Claims Division — a further indication that Defendant is treating this case

as regular civil practice rather than as the small claims action Plaintiffs filed.

D. Defendant has not properly served Plaintiffs with the Motion to Dismiss.

As of the preparation of this Opposition, Plaintiffs have not received Defendant’s Motion to Dismiss —— either Dkt. 12 or the corrected Dkt. 17 — by mail or by any other physical means. Defendant’s own description of the re-filing acknowledges that the initial mailed service used incorrect tracking labels (Dkt. 17 description: “the former version did not correctly reflect both Tracking numbers. The FEDEX label is meant to arrive overnight, while the USPS is standard mail”). Defendant’s only previously successful mailed service —- the May 5 Motion for Continuance — arrived seven days after dispatch. Mail dispatched on May 12 from Mountain View, California is unlikely to arrive in Honolulu before the May 14 hearing at 1:30 PM. The Court’s own Notice of Court Date (Dkt. 19) expressly confirms that Plaintiffs must be

“conventionally served,” and that conventional service has not been accomplished. Plaintiff

Page 6 of 11

Marjorie J. Walsh, who is not a JEFS registered filer, has received nothing from Defendant relating to the Motion to Dismiss by any means — yet Defendant’s motion expressly seeks dismissal of this action with prejudice as to both Plaintiffs. Plaintiffs respectfully submit that a dispositive motion seeking dismissal with prejudice as to two Plaintiffs should not be heard on two days’

notice and without effective service on either.

E. Defendant itself acknowledged on May 5 that it needs to retain Hawai‘ counsel.

Defendant’s May 5, 2026 letter to this Court, filed as part of its Motion for Continuance (Dkt. 10), candidly states: “Google seeks a continuance to acquire counsel to appear on its behalf.” That is an admission, in a filing signed by Ms. Altherr, that as of May 5 Defendant had not retained Hawai‘i counsel and recognized that it needed to do so. One week later, having failed to do so, Defendant nonetheless filed a thirty-six page Motion to Dismiss with prejudice. Plaintiffs respectfully submit that Defendant should not be permitted to proceed by dispositive motion practice without first satisfying the very precondition Defendant itself identified.

IV. EVEN IF THE COURT REACHES THE MERITS, THE MOTION SHOULD BE DENIED

Should the Court conclude that Defendant’s filings are properly before it notwithstanding the foregoing, Plaintiffs respectfully submit that the Motion to Dismiss should be denied on the

merits.

A. The forum-selection clause does not bar Plaintiffs’ claim in this Court.

Defendant’s primary argument for dismissal is that the Google Terms of Service require disputes to be litigated “exclusively in the federal or state courts of Santa Clara County, California.” Defendant asks this Court to send a Honolulu consumer across the Pacific Ocean to

litigate a $5,000 dispute.

The seminal authority on forum-selection clauses, The Bremen v. Zapata Off-Shore Co., 407 U.S. 1 (1972), held that such clauses are presumptively valid but unenforceable where their

enforcement would be “unreasonable and unjust.” 407 U.S. at 15. The Supreme Court explained:

Page 7 of 11

[I]t should be incumbent on the party seeking to escape his contract to show that trial in the contractual forum will be so gravely difficult and inconvenient that he

will for all practical purposes be deprived of his day in court.

Id. at 18. The Court was careful, however, to distinguish the freely negotiated international

commercial agreement before it from a different category of case:

We are not here dealing with an agreement between two Americans to resolve their essentially local disputes in a remote alien forum. In such a case, the serious inconvenience of the contractual forum to one or both of the parties might carry

greater weight in determining the reasonableness of the forum clause.

Id. at 17. This case falls squarely within the category the Bremen Court reserved for greater scrutiny. Plaintiffs are Hawai‘i residents. Their dispute concerns harm to a Hawai‘i resident’s business in Honolulu, caused by suspension of a telephone number used in Hawai‘i. The contractual forum, Santa Clara County, has no connection to the parties or the dispute other than the unilateral designation in Defendant’s adhesion contract. The cost of litigating a $5,000 consumer claim in California — airfare, lodging, time — exceeds the amount in controversy. The forum-selection clause, as applied here, does not merely relocate the dispute; it eliminates it. Under Bremen’s own standard, that is the very definition of being “for all practical purposes . . . deprived of his day in court.”

The Supreme Court reaffirmed that forum-selection clauses in consumer contracts are “subject to judicial scrutiny for fundamental fairness” in Carnival Cruise Lines, Inc. v. Shute, 499 U.S. 585, 595 (1991). While Carnival Cruise enforced the clause before it, the Court emphasized that the enforcement was appropriate because the chosen forum (Florida) was the defendant’s principal place of business, with substantial connection to the dispute, and because there was “no indication that petitioner set Florida as the forum . . . as a means of discouraging cruise passengers from pursuing legitimate claims.” Jd. None of those conditions is satisfied here: Santa Clara County has no connection to this dispute, and requiring Hawai‘i consumers to travel to California

to recover modest sums functions precisely as a means of discouraging legitimate claims.

Plaintiffs acknowledge that a federal court in this District recently enforced a forum- selection clause against a Hawai‘i plaintiff in Morris v. Biotronik, Inc., 2022 U.S. Dist. LEXIS

Page 8 of 11

32086 (D. Haw. Feb. 23, 2022). That case is distinguishable in three material respects. First, Morris was a federal diversity case governed by the federal transfer statute, 28 U.S.C. § 1404(a), and by the Supreme Court’s decision in Atlantic Marine Construction Co. v. U.S. District Court, 571 U.S. 49 (2013). This case is in Hawai‘i state Small Claims Court, which is not subject to either authority. Second, Morris involved an arm’s-length commercial agreement between a businessman and a corporation, not a consumer adhesion contract. Third, the Morris court did not consider the interaction between a forum-selection clause and Hawai‘i’s small claims statutory scheme — a scheme expressly designed to provide Hawai‘i consumers with a local forum for modest disputes.

Morris therefore does not control this case.

B. Defendant has separately consented to Hawai ‘i jurisdiction by registering to do

business in Hawai‘.

Defendant cannot reconcile its position with its own conduct in Hawai‘i. Google LLC has voluntarily registered as a foreign limited liability company in Hawai‘i, and has designated Corporation Service Company at 1003 Bishop Street, Honolulu, as its agent for service of process. Plaintiffs served Defendant at that Honolulu address, and Defendant does not contest the validity of that service. By registering and appointing a Hawai‘i agent, Defendant has invoked the benefits of doing business in Hawai‘i and accepted the corresponding burden: that Hawai‘i residents may bring claims against it in Hawai‘i courts arising out of its Hawai‘i business. That separate consent to Hawai‘i jurisdiction cannot be retracted through boilerplate in a consumer adhesion contract that Plaintiffs never negotiated. A corporation cannot accept the revenues of Hawai‘i commerce

while denying Hawai‘i residents the forum to vindicate claims arising from that commerce.

C. Defendant’s remaining grounds are merits defenses, not bases for dismissal.

Defendant’s remaining arguments — that its Terms of Service authorize suspension of accounts for policy violations, and that its contractual liability is capped at $200 — are affirmative defenses to be addressed at trial on the merits, not grounds for dismissal under District Court Rules of Civil Procedure Rule 41(b) or otherwise. Plaintiffs’ Statement of Claim specifically alleges, and Defendant has never refuted, that Defendant has refused over four separate appeals to identify what policy Plaintiffs allegedly violated. On a motion to dismiss, the Court must take Plaintiffs’

well-pleaded allegations as true. Defendant’s unilateral assertion of a violation is not evidence.

Page 9 of 11

The asserted liability cap is, by its terms, a damages limitation, not a basis to dismiss a complaint “in its entirety with prejudice.” Whether the cap is enforceable, and whether it applies to claims for conversion of frozen account credits and seventeen years of communications data, are

questions for trial.

V. PLAINTIFFS RESPECTFULLY REQUEST THAT THIS CASE BE RETURNED TO THE ORDINARY SMALL CLAIMS PROCESS

Plaintiffs filed in the Small Claims Division because, as the Hawai‘i Supreme Court has explained, this Division was created to provide “quick, impartial and inexpensive settlement of disputes” in “the more informal setting of the Smal! Claims courts.” Oahu Plumbing, 60 Haw. at 378-79, 590 P.2d at 575. The Division’s defining characteristic is that “virtually no rules of evidence and far fewer rules of procedure apply” than in regular civil practice. Id. Mediation is encouraged. Hearings are short. Pro se litigants present their case in their own words, the judge

hears the other side, the judge decides.

That is the system Plaintiffs invoked when they filed this case. It is the system to which they are entitled. And it is the system to which they ask this Court to return them.

Plaintiffs do not file this Opposition and Motion because they wish to engage in formal motion practice. They file it because Defendant’s thirty-six page Motion to Dismiss with prejudice has made some response necessary. The relief Plaintiffs seek is not further motion practice. It is the opposite: that this Court require Defendant to retain Hawai‘i counsel (as Defendant itself acknowledged on May 5 it needed to do), deny the procedurally improper Motion to Dismiss, and direct the parties toward mediation through the Mediation Center of the Pacific, which provides

this service to Small Claims Division litigants at no cost.

VI. PRAYER FOR RELIEF For the foregoing reasons, Plaintiffs respectfully request that this Court:

1. Deny Defendant’s Motion to Dismiss (Dkt. 12 and Dkt. 17) in its entirety, or in the alternative defer ruling and reset the motion on a proper briefing schedule with adequate

notice;

Page 10 of 11

2. Order that Defendant must appear through licensed Hawai‘i counsel before filing any

further motion or other substantive paper in this action;

3. Direct the parties to participate in mediation through the Mediation Center of the Pacific, or such other mediation as the Court deems appropriate, before any further hearing on the

merits; and 4. Grant such other and further relief as this Court deems just and proper. Respectfully submitted,

Craig W. Walsh, Pjaintiff Pro Se

Marjorie J. Walsh, Plaintiff Pro Se

Dated: Honolulu, Hawaii – May 13, 2026

Page 11 of 11

CRAIG W. WALSH MARJORIE J. WALSH

350 Ward Avenue, Suite 106-B Honolulu, Hawai‘i 96814 Telephone: (802) 359-2718 Email: [email protected]

Plaintiffs Pro Se IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAI'I CRAIG W. WALSH and Civil No. 1DSC-26-0000370 MARJORIE J. WALSH, Plaintiffs, CERTIFICATE OF SERVICE vs. GOOGLE LLC, Hearing: May 14, 2026 at 1:30 PM Defendant. Judge: Hon. Erika E. Ireland

CERTIFICATE OF SERVICE

1, CRAIG W. WALSH, hereby certify that on the date set forth below, a true and correct copy of PLAINTIFFS’ OPPOSITION TO DEFENDANT’S MOTION TO DISMISS; PLAINTIFFS’ MOTION TO REQUIRE DEFENDANT TO APPEAR THROUGH LICENSED HAWAI‘I COUNSEL was duly served on Defendant Google LLC through the Hawai‘i Judiciary Electronic Filing System (JEFS), at which Defendant is a registered filer (EFS Filer No. 7027909). The JEFS system automatically generates and transmits a Notice of Electronic Filing to

all registered filers in an action, with a link to the filed document.

DATED: Honolulu, Hawai‘i, May 13, 2026

Page 1 of 2

CRAIG W. WALSH Plaintiff Pro Se

Page 2 of 2

Go: gle

1600 Amphitheatre Parkway Tel: 650.253.0000

Mountain View, California 94043 Fax: 650.253.0001_— Elestrenigally Filed

May 13, 2026 FIRST CIRCUIT 1DSC-26-0000370

Kauikeaouli Hale lone ake

Small Claims Division Dkt. 23 OT

1111 Alakea Street, 10th floor, Honolulu, Hawaii 96813

RE: Craig W Walsh, PLT, et al v. Google LLC, DFT. Case Number: 1DSC-26-0000370

To the Court,

I, Ian Drakeford, am a Litigation Legal Specialist Support Team Manager and contractor supporting Google LLC (“Google”). I have been authorized by Leslie Altherr, Senior Manager, Legal Specialist, to act on Google’s behalf regarding matters related to the above mentioned

small claims action.

Thank you for your attention to this matter.

Sincerely, Acknowledged by:

Ian Drakeford ~ Leslie Altherr

Litigation Legal Specialist Support Team Senior Manager, Legal Specialist Manager

RECEIVED MAY 13 2026

C+M WALSH CERTIFICATE OF SERVICE HONOLULU

Go. gle

1600 Amphitheatre Parkway Tel: 650.253.0000 Mountain View, California 94043 Fax: 650.253.0001 www.google.com

Google certifies that a copy hereof has been furnished to the following parties on May 13, 2026. The names and address of the parties are as follows:

Craig W. Walsh

Marjorie J. Walsh

350 Ward Avenue 106-B

Honolulu, Hawaii 96814

Via USPS: 9405 5362 0830 3313 6515 86

Kauikeaouli Hale

Honolulu Division

1111 Alakea Street, 10th floor, Honolulu, Hawaii 96813

Via efile

Sincerely,

Google LLC [email protected]

Craig Walsh

From: Craig Walsh

Sent: Saturday, June 20, 2026 10:17 PM

To: ‘[email protected]’

Subject: Walsh v. Google LLC, Civil No. 1DSC-26-0000370 Attachments: Walsh_Settlement_Agreement_Draft.docx Importance: High

Mr. lan Drakeford

clo Google LLC, Small Claims Team 1600 Amphitheatre Parkway Mountain View, California 94043 Via email: [email protected]

Re: Walsh v. Google LLC, Civil No. |DSC-26-0000370 Settlement Communication — Pursuant to HRE 408 and FRE 408

This communication is made pursuant to Hawai‘i Rules of Evidence Rule 408 and Federal Rule of Evidence 408 for purposes of settlement discussion. It is not admissible to prove or disprove the validity or amount of any disputed claim, or for any other purpose, except as permitted by those rules. Nothing in this letter is intended as, or shall be construed as, an admission of liability.

Dear Mr. Drakeford:

As you know, the above-captioned action was the subject of a hearing before the Honorable Andrew Pepper on May 14, 2026. The Court continued Defendant’s Motion to Dismiss to the next status hearing on August 4, 2026, and referred the parties to mediation through the Mediation Center of the Pacific in the interim. Plaintiffs write now, in advance of that mediation, to set out a settlement framework that Plaintiffs believe would resolve this matter cleanly and on terms that Defendant should find acceptable.

Plaintiffs’ priorities in this case have always been operational rather than financial. The underlying harm is not measured by a check; it is measured by Plaintiff Marjorie J. Walsh’s loss of access to a telephone number she has relied upon for her professional services in Honolulu, and by Plaintiffs’ loss of access to nearly seventeen years of communications data stored in Plaintiff Craig W. Walsh’s Google Voice account. With those priorities in mind, Plaintiffs propose the following framework for resolution:

I. Monetary payment. Defendant shall pay Plaintiffs the sum of $275.00, consisting of $200.00 (which corresponds to the contractual liability limit identified in Defendant’s Motion to Dismiss at Dkt. 12) plus $75.00 for court costs incurred by Plaintiffs ($35.00 filing fee and $40.00 service of process). Payment shall be by check payable to Craig W. Walsh and Marjorie J. Walsh, or by other electronic means (ACH, Zelle, PayPal, etc.).

2 Release of telephone number. Defendant shall release telephone number 415-915-4708 from any hold, quarantine, or non-portable status in Defendant’s numbering inventory, and shall cooperate in good faith with the port-in request that Plaintiffs will initiate through Verizon Wireless. Defendant shall complete its obligations under this paragraph within fourteen (14) calendar days of execution of the settlement agreement.

3. Data return. Defendant shall make available to Plaintiff Craig W. Walsh a complete export of the communications data associated with the Google Voice account at issue in this case, including call records, voicemail recordings and transcriptions, text messages sent and received through the Service, and Google Voice contacts. The data shall be provided in the formats ordinarily produced by Google Takeout for Voice exports and shall be made available for download within fourteen (14) calendar days of execution of the settlement agreement.

4. Mutual general release and dismissal. Upon Defendant's performance of the obligations in paragraphs | through 3, Plaintiffs will execute a mutual general release of claims arising out of or relating to the Google Voice account at issue and will file a stipulation dismissing this action with prejudice.

Plaintiffs believe this framework is reasonable for both parties. The monetary component matches the position Defendant has already taken in this litigation regarding its maximum contractual exposure, plus the $75 in court costs Plaintiffs have already incurred. The operational components — release of the telephone number and return of Google Voice account data — require no incremental expenditure by Defendant beyond the routine administrative work involved in releasing a number from inventory and producing data through Google Takeout. Plaintiffs are not seeking damages beyond the figure Defendant itself identified and are not seeking any admission of fault. The framework provides Defendant with a clean exit and Plaintiffs with the operational relief that has been their objective from the beginning of this dispute.

One housekeeping point bears on the mediation. Under Hawai'i Revised Statutes § 605-2 and Oahu Plumbing & Sheet Metal v. Kona Construction, Inc., 60 Haw. 372 (1979), corporations appearing in Hawai'i courts must generally be represented by attorneys admitted to practice in Hawai'i. HRS § 633-28(b) provides a narrow Small Claims Court exception, but only with court approval and only for uncompensated representation. Mr. Drakeford’s identification on the record as a “contractor supporting Google LLC” places his representation outside that exception, as the statute by its terms excludes compensated representation. Plaintiffs also note that the Court’s minutes from the May 14, 2026 hearing identify Mr. Drakeford as “ATTY IAN DRAKEFORD,” and the record reflects no correction of that designation by Defendant. Plaintiffs raise these points not to relitigate Defendant's prior filings, but to assist Defendant in considering its options. Defendant should consider retaining Hawai‘i-licensed counsel for purposes of the mediation and any further proceedings in this matter.

Plaintiffs request a response to this framework by the close of business on Friday, June 26, 2026.

Accepting this framework now would spare both sides the time and expense of preparing for and attending the mediation, which is likely to take an hour or two of session time plus preparation on Defendant's side. If Defendant accepts the framework by that date, the parties can move directly to executing the settlement agreement and filing the stipulation of dismissal in advance of the August 4, 2026 status hearing. To facilitate that path, Plaintiffs have enclosed a proposed draft Settlement Agreement and Mutual Release reflecting the framework above. If Defendant wishes to use a different form of agreement or to propose modifications, Plaintiffs are open to a good-faith conversation, provided that the operational components (paragraphs 2 and 3) are substantially preserved. If the framework is not acceptable, Plaintiffs will proceed to mediation and, if necessary, to the continued hearing on August 4, 2026 and to trial on the merits thereafter.

Plaintiffs ask that this letter be reviewed by a person within Defendant's organization who has settlement authority over both monetary and operational terms. The Mediation Center of the Pacific will require confirmation of Defendant’s settlement authority before the mediation proceeds; resolving any questions on this point in advance will assist the productive use of the mediation.

Plaintiffs look forward to a constructive process.

Sincerely, Marjorie and Craig Walsh

350 Ward Avenue, Suite 106-8 Honolulu, Hawaii 96814-4004 Tel (802) 359-2718

SETTLEMENT AGREEMENT AND MUTUAL RELEASE

This Settlement Agreement and Mutual Release (“Agreement”) is entered into as of the last date of signature below (the “Effective Date”) by and between Craig W. Walsh and Marjorie J. Walsh (collectively, “Plaintiffs”) and Google LLC (“Defendant”). Plaintiffs and Defendant are referred to collectively as the “Parties.”

RECITALS

A. On April 14, 2026, Plaintiffs commenced an action agains’ t in the District Court of

No. 1DSC-26-0000370 (the “Action”).

B. The Action arises from Defendant’s suspensi i ociated with telephone number 415-915-4708 (the “Acco i i i A sh has held continuously since July 2009.

C. The Parties wish to resolve the Acti 3 on the terms set forth in this

Defendant sha portable status i port-in request in Plaintiffs’ choice.

dant’s numbering inventory, and shall cooperate in good faith with the ated by Plaintiffs through Verizon Wireless or any other carrier of

3. Data Return. Within fourteen (14) calendar days after the Effective Date, Defendant shall make available to Plaintiff Craig W. Walsh a complete export of the communications data associated with the Account, including call records, voicemail recordings and transcriptions, text messages sent and received through the Service, and Google Voice contacts. The data shall

Settlement Agreement — Walsh v. Google LLC, 1DSC-26-0000370 — Page | of 3

be provided in the formats ordinarily produced by Google Takeout for Voice exports and shall be made available for download by Plaintiff Craig W. Walsh from his Google account.

4. Mutual General Release. Upon Defendant’s performance of the obligations in Sections 1 through 3, the Parties mutually release and forever discharge one another, and their respective affiliates, officers, directors, employees, agents, successors, and assigns, from any and all claims, demands, causes of action, damages, costs, and expenses of any kind, whether known or unknown, that arise out of or relate to the Account or to the Action. This release does not waive any obligation arising under this Agreement.

5. Dismissal of Action. Within seven (7) calendar days aft it’s performance of the obligations in Sections 1 through 3, Plaintiffs shall file a s issing the Action with prejudice, each Party to bear its own costs and atto: erwise provided in this Agreement.

Settlement Agreement — Walsh v. Google LLC, 1DSC-26-0000370 — Page 2 of 3

IN WITNESS WHEREOF, the Parties have executed this Agreement as of the dates set forth below.

PLAINTIFFS:

Craig W. Walsh Date:

Marjorie J. Walsh Date:

DEFENDANT:

GOOGLE LLC

By: Name: Title: Date:

Settlement Agreement — Walsh v. Google LLC, 1DSC-26-0000370 — Page 3 of 3

Craig Walsh

From: Microsoft Outlook <MicrosoftExchange329e7 1ec88ae461 [email protected]> To: [email protected] Sent: Saturday, June 20, 2026 10:17 PM Subject: Relayed: Walsh v. Google LLC, Civil No. 1DSC-26-0000370

Delivery to these recipients or groups is complete, but no delivery notification was sent by the destination server:

small-claim le.com (small-claims le.com

Subject: Walsh v. Google LLC, Civil No. 1DSC-26-0000370

P.O. Box 10 Newark, NJ 07101-0010

April 15, 2026

Federal Communications Commission Consumer Inquiries & Complaints Division

Consumer & Governmental Affairs Bureau RE Cc EIV ED

45 L Street NE – 5 2026 Re: Name and address: MAY

Washington, DC 20554 Craig Walsh LSH 350 Ward Ave Ste 106 CMO LU Honolulu, Hl 96814 HO Serve ticket#: 8572353 Serve date: 04/07/2026

Dear FCC,

This letter is in response to the above-referenced complaint. Thank you for referring it to our office for review. In her /his complaint, Mr. Craig Walsh has expressed concern regarding his line being ineligible to port-in to Verizon.

Mr. Craig Walsh has requested that either line ending in-4708 be ported in to Verizon, or that once confirmed why the mobile number is not port eligible, that he be provided an explanation.

Upon review of this concern, we contacted Mr. Craig Walsh on 04/07/26 , to further discuss his porting issue. Mr. Craig Walsh stated that Google Voice had cancelled his phone number, around 03/19/26 to inquire about establishing service. While attempting to port in his service, the Verizon store associate stated that his existing device was eligible for Verizon service, but that mobile number ending in -4708 was not portable.

Verizon strives to provide a premier experience for all our customers. However, we have confirmed that Mr. Craig Walsh's telephone number is associated with a geographic area where Verizon does not maintain the wireless

facilities that would be necessary to port her number from her current carrier to Verizon. As a result, the porting system that all wireless carriers use to port numbers to and from one another cannot port Mr. Craig Walsh's number to Verizon.

Verizon appreciates the opportunity to respond to Mr. Craig Walsh's concerns and apologizes for any inconvenience this matter may have caused. Please be advised that as the mobile number ending in -4708 is not portable due to the limits of the industry's number porting system no further action will be taken by the Executive Office at this time. Should the Federal Communications Commission have any questions, please contact Finis M. using the contact

information you have on file. Should Craig Walsh have any questions or concerns, | may be reached at 800-779-2067 ext. 2221075 between 11:00 AM — 4:00 PM ET, Monday — Friday.

Sincerely,

Emma Verizon Executive Relations

cc: Craig Walsh

verizon

Search our support Search

Request #8571951

Problem porting number from Google Voice to Verizon

ee sean . terse amie eater te

Craigwalsh April 6, 2026 at 3:55 PM

Google Voice closed my account for no known reason. | ported my number to my Verizon account, effective February 10, 2026. This was then undone by Verizon (and/or Google) without any notice to me on March 22, 2026. am unable to log into Google Voice to authorize or re-authorize the porting of the number — which is what | want to do. | have had this number for 17 years.

o % Walsh v Google Verizon Statement of Claim Lpdf (100 KB)

© = — ECC Complaint Verizon {1).pdf (100 KB)

FCC Consumer Help Center May 8, 2026 at 1:05 AM

The FCC's Consumer Inquiries and Complaints Center is contacting you about the complaint you filed recently, which was assigned Ticket No. 8571951.

Thank you again for contacting the FCC. The FCC’s role in this process is to facilitate a conversation between you and your provider. We received a response from your provider.

Here is what happens next:

© Your provider is required to send you a written copy of its response. If the carrier sends the response by postal mail, it could take up to 10 days for you to receive the response.

© You should review your provider's response. If the issues you raised in your complaint remain unresolved, you can reply directly to this email with a short description of the problem. Keep in mind that billing adjustments or other actions by your provider could take time to implement.

© If we do not hear from you within 30 days, your ticket will be closed.

© If you have new issues with your provider, you can file a new complaint by going to: consumercomplaints.fec.gov.

This request is closed for comments. You can create a follow-up.

Craigwaish submitted this request

Assigned to FCC Consumer Help Center

Phone Issues Number Portability (keeping your number if you change providers)

Unwanted Calis/Texts Sub Issue

State for Slamming Issue

Phone Availabitity Sub Issue

Emergency Alert System Phone Sub Issue

Phone Billing Sub Issue

Phone Equipment Sub Issue

CRAIG W. WALSH MARJORIE J. WALSH

350 Ward Avenue, Suite 106-B Honolulu, Hawai‘i 96814 Telephone: (802) 359-2718 Email: [email protected]

Plaintiffs Pro Se

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAI'I

CRAIG W. WALSH and Civil No. 1DSC-26-0000370 MARJORIE J. WALSH, PLAINTIFFS’ SUPPLEMENTAL Plaintiffs, MEMORANDUM (1) IN FURTHER

OPPOSITION TO DEFENDANT’S MOTION TO DISMISS AND (2) IN GOOGLE LLC, FURTHER SUPPORT OF PLAINTIFFS’ Defendant. MOTION TO REQUIRE DEFENDANT TO APPEAR THROUGH LICENSED HAWAII COUNSEL; CERTIFICATE OF SERVICE

vs.

Hearing: August 4, 2026, 1:30 p.m. Courtroom 10B

PLAINTIFFS’ SUPPLEMENTAL MEMORANDUM

I. INTRODUCTION

Plaintiffs respectfully submit this short supplemental memorandum to update the Court on developments since the parties’ May 2026 briefing, and to assist the Court in preparing for the August 4, 2026 hearing. Because this matter may be heard by a judge encountering the file for the first time, this memorandum is written to be self-contained: Section II summarizes the procedural developments since May 13; Section III addresses Defendant’s May 13 designation of a second non-attorney representative (Dkt. 23), which bears directly on Plaintiffs’ pending Motion to

Require Defendant to Appear Through Licensed Hawai‘i Counsel (Dkt. 20); Section IV shows,

Page 1 of 14

using only Defendant’s own exhibits, why the Motion to Dismiss should be denied; and Section V sets out a brief factual chronology drawn from the record.

One point of framing may assist the Court above all others. Plaintiffs do not seek reinstatement of the Google Voice service, and they do not contest Defendant’s right to decide whom it will serve. Nor do Plaintiffs ask this Division for relief beyond its jurisdiction: Plaintiffs understand that the Small Claims Division awards money damages, and money damages are what Plaintiffs seek — $5,000, measured by the value of the property Defendant continues to retain following the suspension: seventeen years of Plaintiffs’ communications data and the telephone number on which Plaintiffs built a professional identity. Defendant remains free, at any time, to reduce or eliminate its damages exposure by the simple expedient of returning what it holds.

Plaintiffs file this memorandum in the same spirit as their May 13 Opposition: reluctantly, and only because Defendant has elected to proceed by formal dispositive motion practice in a forum designed to function without it. Plaintiffs’ aim throughout has been — and remains — a prompt,

simple resolution on the merits.

II. PROCEDURAL DEVELOPMENTS SINCE MAY 13, 2026

On May 13, 2026, Plaintiffs filed their Opposition to Defendant’s Motion to Dismiss together with their Motion to Require Defendant to Appear Through Licensed Hawai‘i Counsel (Dkt. 20) and Certificate of Service (Dkt. 21). Later that same morning, at 10:28 a.m., Defendant filed a one- page letter (Dkt. 23) in which Ian Drakeford identified himself as follows:

“I, Jan Drakeford, am a Litigation Legal Specialist Support Team Manager and contractor supporting Google LLC (‘Google’). I have been authorized by Leslie Altherr, Senior Manager, Legal Specialist, to act on Google’s behalf regarding matters related to the above mentioned small claims action.”

Page 2 of 14

The letter is signed by Mr. Drakeford and countersigned “Acknowledged by” Ms. Altherr. It does not request the Court’s approval for Mr. Drakeford’s appearance, and no order approving any non- attorney appearance for Defendant appears anywhere on the docket.

At the May 14, 2026 hearing, Mr. Drakeford appeared by Zoom for Defendant. The Court continued Defendant’s Motion to Dismiss and the status hearing to August 4, 2026 at 1:30 p.m. in Courtroom 10B, and ordered the parties to mediation at the Mediation Center of the Pacific. (Dkt. 25.) On July 9, 2026, the parties participated in mediation as ordered. The mediation did not result

in a resolution. Plaintiffs remain ready to proceed to a hearing on the merits.

Ill. DEFENDANT’S MAY 13 LETTER (DKT. 23) DOES NOT SATISFY HRS § 633-28(b)

As set forth in Plaintiffs’ pending motion (Dkt. 20 at 3-6), Hawai‘i law requires a corporation to appear in court through licensed counsel. HRS § 605-2; Oahu Plumbing & Sheet Metal, Ltd. v. Kona Construction, Inc., 60 Haw. 372, 374, 590 P.2d 570, 572 (1979) (a corporation “cannot appear and represent itself either in proper person or by its officers, but can do so only by an attorney admitted to practice law”). The single, narrow exception for the Small Claims Division, HRS § 633-28(b), imposes two conditions. Defendant’s May 13 letter satisfies neither, and in one

respect makes Defendant’s position weaker than before.

A. The exception operates only “with the approval of the court” — and no approval has

ever been sought or given.

HRS § 633-28(b) permits a non-attorney to appear only “with the approval of the court.” The exception is not self-executing; it requires the affirmative permission of the presiding judge. Dkt. 23 requests nothing of the Court. It is a notification, not a motion. Defendant has now conducted

this litigation through two successive non-attorneys —- Ms. Altherr, who filed a continuance

Page 3 of 14

motion (Dkt. 10) and two versions of a dispositive Motion to Dismiss (Dkts. 12, 17), and Mr. Drakeford, who appeared at the May 14 hearing — without once asking this Court for the approval

the statute makes a precondition. The record contains no such request and no such order.

B. The statute excludes compensated representatives — and Dkt. 23 identifies Mr.

Drakeford as a retained litigation contractor.

HRS § 633-28(b) provides that the services of an unlicensed representative “shall be without compensation, either by way of direct fee, contingent fee, or otherwise,” and that where representation services are rendered for compensation, “this subsection is inapplicable and the rendering of the services constitutes the unlawful practice of law.” Plaintiffs’ pending motion explains why a salaried in-house employee such as Ms. Altherr falls within the statute’s deliberately capacious “or otherwise” language. (Dkt. 20 at 56.) Mr. Drakeford’s case is more straightforward still: by his own filed description, he is a “contractor” whose occupational title is “Litigation Legal Specialist Support Team Manager.” A contractor retained to perform litigation- support services is compensated for those services by definition. The representation he provides in this action is not an incidental courtesy by a corporate officer; it is the paid service he is engaged

to supply.

C. A non-attorney cannot confer representational authority on another non-attorney.

Dkt. 23 recites that Mr. Drakeford has been “authorized by Leslie Altherr” to act for Defendant. But under Oahu Plumbing, Ms. Altherr herself may not represent Defendant in this Court absent compliance with HRS § 633-28(b) — compliance Plaintiffs’ pending motion demonstrates is

absent. Authority that is derivative cannot exceed its source. A designation of one non-attorney by

Page 4 of 14

another non-attorney, filed without any request for judicial approval, does not cure the defect identified in Dkt. 20; it repeats it.

Plaintiffs therefore respectfully renew their request that, before entertaining Defendant’s Motion to Dismiss or any further motion practice by Defendant, the Court require Defendant to appear through licensed Hawai‘i counsel. Defendant itself recognized this obligation on May 5, when it sought a continuance in a filing stating: “Google seeks a continuance to acquire counsel to appear

on its behalf.” (Dkt. 10.) More than two months later, it has not done so.

IV. DEFENDANT’S OWN EXHIBITS DO NOT SUPPORT ITS MOTION TO DISMISS

Should the Court reach the merits of Defendant’s Motion notwithstanding the foregoing, Plaintiffs respectfully direct the Court to the exhibits Defendant itself filed: Exhibit A (the Google Terms of Service, effective May 22, 2024, together with the Google Voice Additional Terms of Service and the Voice Acceptable Use Policy) and Exhibit B (Defendant’s support-case log). The Court need not master a fifty-page contract to resolve this Motion. The dispositive material occupies a handful

of pages, summarized in the following table and discussed below.

A. Summary table. — What Defendant’s Motion quotes What the same pages of Defendant’s Exhibit A also say — and the Motion omits The suspension clause (Ex. A p. 15): Google The paragraph immediately above it on the same “may suspend or terminate your access to the page (Ex. A p. 15): “Before taking action as services” if the user “materially or repeatedly described below, we’ll provide you with advance breach[es]” the terms or policies. Motion § II.B. notice when reasonably possible, describe the

reason for our action, and give you an opportunity to clarify the issue and address it,” subject to four enumerated exceptions, none of which is alleged here.

Page 5 of 14

What Defendant’s Motion quotes What the same pages of Defendant’s Exhibit A also say — and the Motion omits

The liability cap (Ex. A p. 14): total liability The sentence directly above the quoted passage “limited to the greater of (1) $200 or (2) the fees (Ex. A pp. 13-14): “These terms don’t limit paid to use the relevant services in the 12 months _| liability for gross negligence or willful

before the dispute.” Motion § II.C. misconduct.”

The assertion that Plaintiffs’ use “violated the The Acceptable Use Policy itself (Ex. A pp. 23— Voice Acceptable Use Policy.” Motion §§ I, I.B | 24), which contains no personal-use requirement (no provision cited). and no prohibition on a user’s professional use of

her own number. Its only commercial-use provisions address bulk or automated commercial messaging and the resale or transfer of the account or the Service itself.

B. Defendant’s Exhibit A required pre-suspension notice, a stated reason, and an

opportunity to respond — on the same page as the clause Defendant quotes.

Defendant’s Motion quotes the suspension clause from page 15 of its Exhibit A. The paragraph immediately preceding that clause — on the same page — is captioned “Taking action in case of problems” and states:

“Before taking action as described below, we’ll provide you with advance notice when reasonably possible, describe the reason for our action, and give you an opportunity to clarify the issue and address it, unless doing so would: cause harm or liability to a user, third party, or Google; violate the law or a legal enforcement authority’s order; compromise an investigation; [or] compromise the operation, integrity, or security of our services.” (Ex. Ap. 15.)

The record shows no advance notice, no described reason beyond an unexplained on-screen reference to a “perceived violation,” and no opportunity to clarify or address anything: Defendant’s own appeal system simultaneously reported that “Access to your Google Account isn’t restricted.” (Dkt. 1 | 8-10 & Ex. C.) Defendant has never alleged that any of the four enumerated exceptions applies. Defendant’s Motion thus rests on a suspension carried out in a manner contrary to the

commitments on the very page of the contract it quotes. The suspension clause itself, moreover, is

Page 6 of 14

triggered only where a user “materially or repeatedly breach[es]” the terms or policies (Ex. A p.

15) — a showing Defendant has not attempted to make.

C. The liability cap Defendant quotes expressly does not apply to gross negligence or

willful misconduct.

Defendant’s Motion quotes a $200 liability cap from pages 13-14 of Exhibit A. The sentence directly above the quoted passage states: “These terms don’t limit liability for gross negligence or willful misconduct.” (Ex. A p. 13.) Whether Defendant’s conduct meets that standard is a question of fact for trial, not a basis for dismissal. The record a factfinder would weigh includes: suspension without the notice Defendant’s own terms promised; an appeal mechanism that reported no restriction existed; an email six weeks after suspension stating the “Google Voice account will still stay active” (Dkt. 1, Ex. E); emails warning Plaintiffs the number would expire unless action was taken; and a port of the number to Verizon, completed effective February 10, 2026, that was reversed on or about March 22, 2026 — after which Plaintiffs, locked out of the account, could not authorize any further port (Dkt. 1, Ex. J; Ex. 1 hereto). In all events, as Plaintiffs’ Opposition explains (Dkt. 20 at 10), a damages limitation is an affirmative defense going to the amount of recovery; it is not a ground for dismissal.

The porting sequence deserves particular attention. Defendant’s own emails instructed Plaintiffs to port the number or lose it. Plaintiffs complied: the port to Verizon completed on February 10, 2026 through the industry’s number-portability system; the number rang and functioned on Plaintiffs’ Verizon device; and Verizon billed Plaintiffs for the line. (Ex. 2 hereto (Verizon billing statement).) Six weeks later, the completed port was reversed without notice to Plaintiffs. Defendant’s Motion asserts that Google Voice numbers are “locked by default for all consumers”

and that “any attempt to port out a Google Voice number will fail while it is locked.” (Dkt. 17.)

Page 7 of 14

That assertion cannot be reconciled with a port that completed and remained in service for six weeks — except on the understanding that Defendant’s lock was lifted or failed on February 10, and was restored by the March 22 reversal. On Defendant’s own description of its systems, the reversal of Plaintiffs’ completed, in-service, billed port originated on Defendant’s side of the carrier chain. A company that instructs its customer in writing to port a number, processes the completed port, reverses it six weeks later, and then continues to warn the customer that the number “will expire” is difficult to credit with inadvertence. Whether that sequence constitutes willful misconduct or gross negligence is a question of fact for the hearing; on either finding, the liability

limits Defendant invokes do not apply, by the express terms of Defendant’s own exhibit.

D. The Acceptable Use Policy Defendant filed contains no provision prohibiting the

conduct Defendant appears to allege — and Defendant has never identified one.

Defendant’s Motion asserts, repeatedly but generically, that Plaintiffs’ use of Google Voice “violated the Voice Acceptable Use Policy.” It never identifies which provision, or what conduct. Defendant’s own Exhibit B confirms that this omission is not an oversight of briefing: each written denial of Plaintiffs’ appeals states only that the service “has been suspended for violations of our Google Voice Policies,” without more. (Def. Ex. B pp. 2-3.)

The Acceptable Use Policy itself appears at pages 23-24 of Defendant’s Exhibit A. It contains no requirement that Google Voice be used only for personal purposes and no prohibition on a user’s professional use of her own number. Its only provisions touching commercial activity are: (1) the “Spam and Commercial Use” section, which prohibits bulk, automated, or unsolicited commercial messaging; and (2) a single line in the “System Interference and Abuse” section: “Do not sell, trade, resell or otherwise exploit for any unauthorized commercial purpose or transfer any Google

Voice account or the Google Voice Service.” (Ex. A pp. 23-24.) The first addresses spamming;

Page 8 of 14

the second addresses trafficking in the account or the Service itself. Neither prohibits an individual from receiving calls or messages at her own number in connection with her own work.

Nor could the phrase “unauthorized commercial purpose” supply the missing prohibition. The term “unauthorized” is defined nowhere in the contract, which establishes no scheme by which any commercial purpose is authorized or refused —- though the word itself concedes that some commercial purposes are permitted. And read in the company of “sell, trade, [and] resell,” the phrase “otherwise exploit” addresses commercialization of the account or the Service itself. To the extent any provision is ambiguous, the ambiguity is construed against Defendant as the drafter of this consumer form contract. Defendant’s continued silence as to which provision it relies upon — maintained through four written appeal denials, a thirty-six-page dispositive motion, and a written response to the Federal Communications Commission asserting that “activity violating the Acceptable Use Policy did occur” while naming neither the provision nor the activity (Ex. 1 hereto) — speaks for itself. Defendant’s FCC response is notable in a second respect: submitted in answer to a complaint expressly about number portability, it does not mention porting at all. It addresses

only reinstatement — relief Plaintiffs have never requested.

E. Defendant’s own records show it could mitigate Plaintiffs’ damages at any time —

and has chosen not to.

Plaintiffs’ damages are measured by the value of the property Defendant retains: their communications data and their telephone number. Defendant’s own filed exhibit shows that returning that property is consistent with Defendant’s ordinary practice: Defendant’s February 6, 2026 automated response to Plaintiffs’ first appeal states, “You may be able to download your data from some Google services. To get started, sign in to your account. If your account is eligible,

you'll see a link to download your data.” (Def. Ex. B p. 1.) Exhibit A likewise directs suspended

Page 9 of 14

users to Defendant’s published account-disablement policies for “what happens when we do” disable accounts. (Ex. A p. 15.) Nothing in Exhibit A conditions the return of a user’s own content on the account’s standing, and nothing in it authorizes the permanent retention of seventeen years of a customer’s communications data.

Mitigation remains available today. As of the date of this filing, the number remains provisioned: calls to it are accepted by the network and return a busy signal, and text messages to it are accepted without any delivery failure —- messages Defendant’s systems continue to receive and store in the very account records Defendant declines to release. The number Defendant warned would “expire in 30 days” on April 10 remains, three months later, parked in Defendant’s chain of custody, one administrative action away from return.

More fundamentally, nothing in Defendant’s contract converts suspension into forfeiture. The termination provisions of Exhibit A end the service relationship; no provision anywhere in the document states that Defendant keeps the customer’s belongings when the relationship ends. Exhibit A itself provides: “Your content remains yours, which means that you retain any intellectual property rights that you have in your content.” (Ex. A p. 6.) A landlord who lawfully ends a tenancy does not thereby acquire the tenant’s furniture. Whatever the merits of Defendant’s decision to stop serving Plaintiffs — a decision Plaintiffs do not ask this Court to revisit — that decision supplies no right to retain seventeen years of Plaintiffs’ communications or the telephone number itself.

Nor can Defendant characterize the number as its own property to give or withhold. Under federal law, telephone numbers are a public resource administered under the exclusive jurisdiction of the Federal Communications Commission. 47 U.S.C. § 251(e). The numbering administrator allocates

numbers to licensed carriers of record, which provision them to subscribers; ported numbers are

Page 10 of 14

tracked in the industry’s portability database. Neither subscribers nor providers own them, and the federal number-portability framework, 47 U.S.C. § 251(b)(2); 47 C.F.R. Part 52, exists precisely so that numbers follow customers when they change providers. Verizon is such a carrier of record. Defendant, by its own filed terms, is not: Google Voice calls “are routed through and provided by various regulated and licensed partners.” (Ex. A p. 22.) Defendant thus holds this number, if at all, through intermediary carriers — a step removed from the public resource it declines to release — and its only connection to the number was as a service provider to Plaintiffs, a relationship Defendant itself elected to end. What Defendant retains is custody of a public resource, and seventeen years of Plaintiffs’ own content, for no purpose the contract or the federal framework

recognizes.

V. CHRONOLOGY OF THE RECORD

The following chronology is drawn from the docket and the parties’ filed exhibits.

Date Event (record citation)

Feb. 6, 2026 Google Voice service suspended without prior notice; on-screen message cites an unexplained “perceived violation.” Plaintiffs appeal the same day. Google’s automated reply states Plaintiffs “may be able to download your data.” (Def. Ex. B p. 1.)

Feb. 7, 2026 Appeal denied. No policy provision identified. (Def. Ex. B p. 2.) Feb. 11, 2026 Plaintiffs submit a Data Subject Access Request. (Dkt. 1, Ex. D.)

Mar. 20, 2026 Google Voice emails Plaintiffs that the “Google Voice account will still stay active.” (Dkt. 1, Ex. E.)

Mar. 30, 2026 Google responds to the data request 47 days after submission with a single paragraph directing Plaintiffs to a Help Center inaccessible to a suspended account. None of the six enumerated requests is addressed. (Dkt. 1, Ex. D.)

Apr. 6, 2026 Plaintiffs file an informal complaint with the Federal Communications Commission regarding the failed port and the locked number. (FCC Ticket No. 8571951; Ex. 1 hereto.)

Apr. 9, 2026 Verizon’s Executive Relations team responds to the FCC complaint in writing,

confirming the failed port of the number. (Dkt. 1, Ex. J.)

Apr. 15, 2026 Verizon provides a formal written response to the FCC, copying Plaintiffs.

Page 11 of 14

Date Event (record citation)

Apr. 10, 2026 Google emails Plaintiffs that the number “will expire in 30 days”; a further appeal is denied the same day, again without any provision identified. (Dkt. 1 Exs.; Def. Ex. B p. 3.)

Apr. 14, 2026 Statement of Claim filed. (Dkt. 1.)

May 5, 2026 Defendant moves for a continuance, stating: “Google seeks a continuance to acquire counsel to appear on its behalf.” (Dkt. 10.)

May 7, 2026 Defendant responds to the FCC complaint in a two-paragraph letter asserting that “activity violating the Acceptable Use Policy did occur” — without identifying any provision or any activity — and addressing only reinstatement, relief Plaintiffs have never sought. The letter, marked “cc: Craig Walsh,” did not reach Plaintiffs; it first came to their attention on July 15, 2026, as an attachment to the FCC’s closure of Plaintiffs’ follow-up complaint. (Ex. 1 hereto.)

May 12, 2026 Defendant, not having retained counsel, files its Motion to Dismiss through a non- attorney employee. (Dkts. 12, 17.)

May 13, 2026 Plaintiffs file their Opposition and Motion regarding representation. (Dkts. 20, 21.) The same day, at 10:28 a.m., Defendant files a letter designating a second non- attorney representative. (Dkt. 23.)

May 14, 2026 Hearing held; Defendant appears through Mr. Drakeford; Motion to Dismiss and status hearing continued to August 4, 2026; parties ordered to mediation. (Dkt. 25.)

July 9, 2026 Parties participate in mediation at the Mediation Center of the Pacific pursuant to the Court’s order. The mediation does not result in a resolution.

July 14, 2026 Plaintiffs file a further FCC informal complaint directed to Google LLC (Request No. 8890610), incorporating Ticket No. 8571951. (Ex. 1 hereto.) July 15, 2026 The FCC concludes the informal complaint process, attaching Defendant’s May 7

response. (Ex. 1 hereto.)

Date of filing Defendant has not identified — in four appeal denials, a thirty-six-page dispositive motion, or a written response to the Federal Communications Commission — any policy provision Plaintiffs are alleged to have violated; has not retained Hawai‘i counsel; and no order approving a non-attorney appearance appears on the docket.

VI. CONCLUSION

For the reasons stated above and in Plaintiffs’ May 13 Opposition (Dkt. 20), Plaintiffs respectfully request that the Court: (1) require Defendant to appear through licensed Hawai‘i counsel before

entertaining Defendant’s Motion to Dismiss or any further motion practice by Defendant; (2) deny

Page 12 of 14

Defendant’s Motion to Dismiss; and (3) set this matter for a prompt hearing on Plaintiffs’ claim

for money damages. Dated: Honolulu, Hawai‘i, July IS , 2026.

Respectfully submitted,

CRAIG W. WALSH Plaintiff Pro Se

MARJORIE J. WALSH Plaintiff Pro Se

Page 13 of 14

KC] Consumer inquiries and Complaints Center Pas

Search our support : : Search Request #8571951 Problem Porting number from Google Voice to Verizon

Craigwaish April 6, 2026 at 3:55 PM

Google Voice closed my account for no known reason. | ported my number to my Verizon account, effective February 10, 2026. This was then undone by Verizon (and/or Google) without any notice to me on March 22, 2026. 1 am unable to log into Google Voice to authorize or re-authorize the porting of the number — which is what | want to do. | have had this number for 17 years.

© Walsh y Google Verizon Statement of Claim Lodf (100 KB) © F ECE Complaint Verizon {1).pdf (100 KB)

FCC Consumer Help Center ‘May 6. 2026 at 1:05'4M

The FCC's Consumer Inquiries and Complaints Center is contacting you about the complaint you filed recently, which was assigned Ticket No. 8571951.

Thank you again for contacting the FCC. The FCC's role in this process is to facilitate a conversation between you and your provider. We received a response from your provider.

Here is what happens next:

© Your provider is required to send you a written copy of its response. If the carrier sends the response by posta! mail, it could take up to 10 days for you to receive the response.

© You should review your provider's response. If the issues you raised in your complaint remain unresolved, you can reply directly to this email with a short description of the problem. Keep in mind that billing adjustments or other actions by your provider could take time to implement.

© If we do not hear from you within 30 days, your ticket will be closed.

© If you have new issues with your provider, you can file a new complaint by going to: consumercomplaints. fcc. gov.

This request is closed for comments. You can create a follow-up.

Craigwaish submitted this request

Assigned to FCC Consumer Help Center

Phone Issues. Number Portability (keeping your number if you change providers)

‘Unwanted Caiis/Texts Sub tssue

‘State for Slamming issue

Phone Availability Sub tssue

Emergency Alert System Phone Sub Issue

Phone Biling Sub sue

“~~ EXHIBIT 1.

Search our support Search

Request #8890610 Re: Problem porting number from Google Voice to Verizon

Craigwalsh Yesterday, 12:22 AM

This is a follow-up to your previous request #8571951 "Problem porting number from Google Voice to Verizon"

This complaint is against Google LLC (Google Voice) regarding its refusal to permit porting of my telephone number, 415-915-4708.

| have held a Google Voice account since July 2009. On February 6, 2026, Google suspended my Google Voice service without prior notice and has never identified, despite four written appeals, any specific policy provision it claims was violated.

Both before and after the suspension, Google Voice sent me multiple emails instructing me to port the number or lose it. Following those instructions, | ported the number to Verizon, effective February 10, 2026. On or about March 22, 2026, that completed port was reversed from the Google/carrier side without notice to me. Because Google has locked me out of the account, | cannot authorize or re-authorize any port, to Verizon or to any other provider. Google has refused all requests to unlock the number. Its own emails urging me to port the number contradict any claim that the number is not portable — as does the fact that the port completed and remained in effect for six weeks.

| previously filed Ticket No. 8571951 concerning this matter. Verizon responded promptly in writing. Google LLC has never responded in any forum. A small claims action, Walsh v. Google LLC, Civil No. 1DSC-26-0000370 (District Court of the First Circuit, Hawai'i), is pending, and Google is on notice to preserve all account data.

| request that Google LLC be required to (1) unlock telephone number 415-915-4708 and permit me to port it to the carrier of my choice, and (2) respond to this complaint in writing as FCC procedure requires.

FCC Consumer Help Center Today, 1:30 AM

Thank you for contacting the FCC’s Consumer Inquiries and Complaints Center.

The FCC's informal complaint process provides consumers with an easy and informal way to raise issues with their providers. The role of the FCC in the informal complaint process is to facilitate a conversation between the consumer and their provider to try to address the consumer's issue.

The informal complaint process has now concluded. You will receive no further status updates on your informal complaint from FCC staff.

In some instances, the complaint process concludes, yet the consumer's issue is not resolved to their satisfaction. We regret that you were not satisfied with attempts by FCC staff to facilitate a dialogue between you and your provider to address your issue.

At this point, you may want to consider two options: either contacting your provider directly to see if you and the provider can arrive at a resolution that is acceptable to you, or pursuing formal legal options.

You have the option to file a formal complaint with the FCC if your issue involves a violation of the Communications Act. A formal complaint proceeding is a legal action similar to a court proceeding. Each party must comply with specific procedural rules, appear before the FCC, and file documents that address legal issues. Because the FCC resolves this type of complaint in a manner similar to a court proceeding, we strongly encourage consumers to seek the advice of legal counsel before filing an action.

Complete information on how to file formal complaints can be found in sections 1.720 through 1.735 of the FCC’s rules, located at 47 C.F.R. §§ 1.720 — 1.735, or sections 8.12-8.17, located at 47 C.F.R. §§ 8.12-8.17 (for Open internet complaints).

For more information, see the FCC’s Enforcement Bureau website at www.fcc.gov/eb/tcd/laction.html.

Attached is Google's response.

© 2 Ticket # 8571951 Response (11.pdf (200 KB)

Add file or drop files here

Craigwalsh submitted this request

Assigned to FCC Consumer Help Center

Phone Issues Number Portability (keeping your number if you change providers)

Unwanted Calls/Texts Sub Issue

State for Slamming Issue

Phone Availability Sub Issue

Emergency Alert System Phone Sub Issue

Phone Billing Sub Issue

Phone Equipment Sub Issue

Phone Interference Sub Issue

Has your personal information been tained of used by an ized p

Did you receive written notice from your provider about the data breach?

Did the call/message that you are reporting advertise any type of property, goods, or services?

Type of Property, Goods, or Services

‘Type of Property, Goods, or Services

Have you or anyone else in your household done any business with the caller/company within the past 18 months immediately before you received the call/message?

Have you or anyone else in your household made any inquiry or application to the caller/company within the 3 months immediately before you received the call/message?

Do you or anyone in your Id have a personal ip with the that made the call?

Your Phone Method Wireless (cell phone/other mobile device)

Te Subject of Cc 415-915-4708

Your Phone Type/Location

RECEIVED

May 7, 2026

JUL 15 2026 Federal Communications Commission + 45 L Street NE honongon Washington, DC 20554 Consumer Name: Craig Walsh Ticket Number: 8571951

To Whom It May Concern:

We have received the informal complaint filed with the Commission by Craig Walsh, in which they expressed concern regarding the status of their Google Voice account.

Google’s Voice Acceptable Use Policy available at https://support.google.com/voice/answer/9230450, is critical in maintaining a positive experience for our users. When a policy violation is identified, Google may review and take action, including limiting or terminating a user’s access to Google Voice. Google Voice account associated with +14159154708 has violated Google Voice Acceptable use policy, and is not able to be reinstated. was flagged for a violation and disabled. Following a thorough review of the concerns presented by Walsh, Google has concluded that activity violating the Acceptable Use Policy did occur; therefore, the account suspension will be upheld.

Based on the foregoing, we request that this informal complaint be closed with respect to Google.

Respectfully submitted,

Maryann Ferrer

ce: Craig Walsh

verizon

Account: Invoice: secs Charges by line details (continued) Billing period: Feb 5 – Mar 4, 2026

Craig Walsh $10.64 Apple iPhone 17 Pro Max-2

415-915-4708 (Second Number)

© Service added

One-time charges & credits $0.00 One-time charges & credits This bill includes adjustments from Second number (added) $12.32 account changes made during the last Partial charge for 23 days: Feb 10 – Mar 4 $16.00 billing cycle. Second number discount (Feb 10 – Mar 4) -$12.32 Activation fee Activation fee $40.00 We charge a one-time $40.00 fee per vation fee -$40.00 device activated on the Verizon

network.For more information about this fee, visit https://go.vzw.com/activation-fee.

Plan $0.00

Second number $15.00 Plan shared with 8028692718 Plans are billed a month in advance. Mar 5 – Apr 4

Second number discount -$15.00

Mar 5 – Apr 4

Surcharges $9.32

Fed Universal Service Charge $0.90

Regulatory Charge $0.42

Admin & Telco Recovery Charge $7.56

Ht Public Srvc CO Surcharge $0.33

HI Gen Excise Surchg-telecom $0.11

Taxes & gov fees $1.32

Hi State 911 Surcharge $1.32

Marjorie J. Walsh $35.67

Apple iPhone 16 Pro Max-2

60:

Plan $30.00 Plan Plans are billed a month in advance. Unlimited Weicome $40.00 Mar 5 – Apr 4 Save $10.00 on your UNLIMITED WELCOME plan each month when you Loyalty discount $10 for 12 MO -$10.00 enroll in Auto Pay and paper-free billing Mar 5 – Apr 4 using your bank account or Verizon Visa (Expires Jul 12, 2026) card. Enroll using the My Verizon app, or at

vzw.com/myverizon.,

XHIBIT 2.

CRAIG W. WALSH MARJORIE J. WALSH

350 Ward Avenue, Suite 106-B Honolulu, Hawai‘i 96814 Telephone: (802) 359-2718 Email: [email protected]

Plaintiffs Pro Se

CRAIG W. WALSH and Civil No. IDSC-26-0000370 MARJORIE J. WALSH, CERTIFICATE OF SERVICE Plaintiffs, vs. GOOGLE LLC, Defendant.

CERTIFICATE OF SERVICE The undersigned certifies that on the date of filing, a true and correct copy of the foregoing PLAINTIFFS’ SUPPLEMENTAL MEMORANDUM was served upon Defendant GOOGLE LLC through the Hawai‘i Judiciary Electronic Filing System (JEFS), which effects electronic service on all registered filers in this action, including Defendant’s registered filer (JEFS Filer No. 7027909), and by email to [email protected], the email address designated on

Defendant’s filings.

Dated: Honolulu, Hawai‘i, July [5 , 2026. CRAIG W. WALSH

Plaintiff Pro Se

Page 14 of 14

Google

1600 Amphitheatre Parkway Tel: 650.253.0000

Mountain View, California 94043 Fax: 650.253.0001__ Electrenigally,Filed

July 30, 2026 FIRST CIRCUIT 1DSC-26-0000370

Kauikeaouli Hale hay AM

Small Claims Division Dkt. 34 OT

1111 Alakea Street, 10th floor, Honolulu, Hawaii 96813

RE: Craig W Walsh, PLT, et al v. Google LLC, DFT. Case Number: 1DSC-26-0000370

To the Court,

I, Ian Drakeford, am a Litigation Legal Specialist Support Team Manager and contractor supporting Google LLC (“Google”). I have been authorized by Leslie Altherr, Senior Manager, Legal Specialist, to act on Google’s behalf regarding matters related to the above mentioned small claims action. I am not being compensated either by way of direct fee, contingent fee, or otherwise, for my appearance and I am not a licensed attorney.

Thank you for your attention to this matter.

Sincerely, Acknowledged by:

Islan DrakelerL js) Leche bhornr Ian Drakeford v Leslie Altherr

Litigation Legal Specialist Support Team Senior Manager, Legal Specialist Manager

Google

1600 Amphitheatre Parkway Tel: 650.253.0000 Mountain View, California 94043 Fax: 650.253.0001 www.google.com

CERTIFICATE OF SERVICE

Google certifies that a copy hereof has been furnished to the following parties on July 30, 2026. The names and address of the parties are as follows:

Craig W. Walsh

Marjorie J. Walsh

350 Ward Avenue 106-B

Honolulu, Hawaii 96814

Via USPS: 9405 5362 0830 3320 2046 21 Via USPS: 9405 5362 0830 3320 2047 68

Kauikeaouli Hale

Honolulu Division

1111 Alakea Street, 10th floor, Honolulu, Hawaii 96813

Via efile

Sincerely,

Google LLC [email protected]

CRAIG W. WALSH MARJORIE J. WALSH

350 Ward Avenue, Suite 106-8 Honolulu, Hawai‘i 96814 Telephone: (802) 359-2718 Email: [email protected]

Plaintiffs Pro Se

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAI‘I

GRATE W. WALAH AND Civil No. 1DSC-26-0000370

MARJORIE J. WALSH, PLAINTIFFS’ RESPONSE TO Plaintiffs, DEFENDANT'S JULY 30, 2026 FILINGS (DKTS. 32 AND 34)

vs. Hearing: August 4, 2026, 1:30 p.m.

Courtroom 10B GOOGLE LLC,

Defendant.

PLAINTIFFS’ RESPONSE TO DEFENDANT’S JULY 30, 2026 FILINGS (DKTS. 32 AND 34) I. INTRODUCTION Five days before the hearing on its own Motion to Dismiss and on Plaintiffs’ pending Motion to Require Defendant to Appear Through Licensed Hawai‘i Counsel, Defendant made two filings thirty-four minutes apart: a refiled

Motion to Dismiss with exhibits (Dkt. 32, 11:03 a.m.) and a second representat-

ive-designation letter (Dkt. 34, 11:37 a.m.). Neither is signed by an attorney. Plaintiffs respond briefly to both.

Il. THE REFILED MOTION TO DISMISS (DKT. 32)

The refiled motion is identical in substance to the motion Plaintiffs have already answered in full (Dkts. 20, 30), and Plaintiffs rest on that briefing. Three features of the refiled package nonetheless warrant the Court’s attention.

First, the motion invokes the wrong rule. The Form 1DC36 states that the Motion “is based on the District Court Rules of Civil Procedure, Rule 41(b).” Rule 41(b) governs involuntary dismissal of an action for a plaintiffs failure to prosecute or failure to comply with the rules or an order of the court. It is not a vehicle for forum-selection arguments, contractual defenses, or liability limitations, and it has no application to this case—unless one observes that fail- ure to comply with the rules of court is the one subject the cited rule does address, and that on this docket the party with that difficulty is the movant.

Second, the declaration deepens the representation problem. The form’s declaration is executed under penalty of law by Ms. Altherr as “an employee of the corporation.” Defendant’s designation letters (Dkts. 23, 34) describe Mr. Drakeford as a “contractor.” Every substantive factual assertion in the letter brief—the account history, the asserted investigations, the assertion that Voice numbers are “locked by default’—thus rests on the declaration of a non-attorney whose authority to conduct this litigation is precisely the question pending before the Court. The brief’s first sentence, moreover, states that Google LLC writes “on behalf of its parent company Alphabet Inc.”—an entity that is

not a party to this action.

Third, the motion’s own records confirm the seventeen-year account. Defendant’s motion recites that “[o]n July 29, 2009, Plaintiff created a Google Voice account” and asserts that the number ending in 4708 was issued in August 2023, Plaintiffs having held earlier Voice numbers over the years. Noth- ing in Plaintiffs’ claim turns on the issuance date of the number. The account— and the seventeen years of communications data stored in it, including many years of text messages—dates to July 2009, as Defendant’s own records confirm. The number, whenever issued, is the professional contact number on which Plaintiff Marjorie J. Walsh’s practice relies. The property Defendant retains— seventeen years of Plaintiffs’ own data, and the number Defendant’s own emails instructed Plaintiffs to port—is the same property, whatever its vintage.

Ill. THE SECOND DESIGNATION LETTER (DET. 34)

Dkt. 34 is the same letter Defendant filed on May 18 (Dkt. 23), from the same two non-attorneys, with one sentence added: “I am not being compensated either by way of direct fee, contingent fee, or otherwise, for my appearance and I am not a licensed attorney.” The added sentence tracks, word for word, the stat- utory language Plaintiffs quoted in their briefing. It changes nothing, for the following reasons—though its one concession usefully narrows what the Court must decide.

A. The recital is unsworn.

Dkt. 34 is a letter bearing “/s/’ signatures. It is not a declaration under penalty of perjury, is supported by no facts, and identifies no terms of Mr. Drake- ford’s engagement: who retains him, what his engagement encompasses, or whether his time on this matter is compensated. As a basis for the Court to find

that a statutory precondition is satisfied, it is a recital, not a record.

B. The qualifier “for my appearance” does not address what the statute actually requires.

HRS § 633-28(b) does not ask whether a separate fee attaches to a court appearance. It provides that the services of an unlicensed representative “shall be without compensation, either by way of direct fee, contingent fee, or other- wise,” and that where “representation services are rendered for compensation, this subsection is inapplicable and the rendering of the services constitutes the unlawful practice of law.” The question is whether the representation services are compensated—not whether Defendant has itemized a line for the hearing.

The letter answers that question against itself. Two sentences before the new recital, Mr. Drakeford repeats—verbatim from Dkt. 23—that he is “a Litiga- tion Legal Specialist Support Team Manager and contractor supporting Google LLC.” A contractor retained to perform litigation-support services is com- pensated for those services by definition; they are not an incidental courtesy but the paid occupation his own title describes. The recital that no compensation attaches “for my appearance” is a conclusion contradicted by the sentence that precedes it.

The recital also asks a great deal of credulity. Defendant’s parent com- pany, Alphabet Inc., reported revenues of approximately $402.8 billion for its most recent fiscal year, and its public disclosures describe legal matters on a scale that includes a $3.5 billion European Commission fine in a single year; in one publicly reported 2025 settlement with the State of Texas, Defendant agreed to pay approximately $190 million toward opposing counsel’s fees alone. Defend- ant is among the largest purchasers of legal services in the world. The Court is

nonetheless asked to accept, on an unsworn letter, that the “Litigation Legal

Specialist Support Team Manager and contractor” Defendant has designated to conduct this litigation renders those services for free. If that is so, it can be established in two minutes of examination. Plaintiffs respectfully request that, before Mr. Drakeford is permitted to be heard on August 4, the Court examine him regarding the terms of his engagement: who engages him, whether his engagement encompasses this litigation, and whether his time on this matter is compensated. If the answers establish compensation, HRS § 633-28(b) by its own terms makes the rendering of the services “the unlawful practice of law.”

C. The letter still does not seek—and Defendant still does not have —the approval of the Court.

The § 633-28(b) exception operates only “with the approval of the court.” Twice now—on May 13 and again on July 30—Defendant has responded to Plaintiffs’ pending motion by filing letters that request nothing of the Court. No motion for approval has been made; no order granting approval appears on the docket. And the letter’s authorization chain is unchanged: Mr. Drakeford is “authorized by Leslie Altherr,” a non-attorney whose own authority to act for Defendant in this Court is the subject of Plaintiffs’ pending motion. Authority that is derivative cannot exceed its source.

D. The letter’s concession narrows the hearing.

One sentence in Dkt. 34 does advance matters: “I am not a licensed attor- ney” is now an express admission on the docket. It is therefore undisputed that Defendant—a corporation, which under Oahu Plumbing & Sheet Metal, Ltd. v. Kona Construction, Inc., 60 Haw. 372, 590 P.2d 570 (1979), cannot appear except through counsel—proposes to appear on August 4 through a person who may

appear, if at all, only within the narrow exception of HRS § 633-28(b). The hear-

ing’s threshold question is thus squarely framed by Defendant’s own filing: has the Court approved the appearance, and is the no-compensation condition genuinely satisfied? On this record, the answer to both is no.

IV. NONE OF THIS BELONGS IN THE SMALL CLAIMS DIVISION —AND LICENSED COUNSEL WOULD HAVE SAID SO

The Small Claims Division exists to resolve modest disputes promptly and informally, without the apparatus of motion practice. Plaintiffs did not choose that apparatus. Every motion on this docket is Defendant’s; every non-conform- ing letter on corporate letterhead is Defendant’s; Plaintiffs’ filings have been responsive, conforming, and reluctant. Defendant is a corporation registered to do business in the State of Hawai‘i, with a registered agent on Bishop Street in Honolulu. (Dkt. 20.) Had Defendant simply followed the law of this State and retained licensed Hawai‘i counsel—as it told this Court on May 5, 2026 it inten- ded to do (Dkt. 10: “Google seeks a continuance to acquire counsel to appear on its behalf”)—its counsel would have advised it of everything set out above: that a corporation cannot appear through unlicensed personnel; that the Small Claims exception requires the Court’s approval and genuinely uncompensated service; that filings in this Court conform to its format rules; and that the swiftest way through the Small Claims Division has always been a prompt hearing on the merits. Defendant’s six months in this action without counsel was not inability. It was a choice—and the consequences of that choice are Defendant’s to bear, not Plaintiffs’ and not this Court’s.

V. DEFENDANT’S CONDUCT HAS ANSWERED ITS OWN FORUM MOTION

Finally, Defendant’s Motion to Dismiss contends that this dispute belongs in California. Defendant’s conduct has answered that contention. On May 14, 2026, the Court stated its inclination to continue the Motion and refer the parties to mediation; the Court’s minutes reflect that no party—including Defendant—objected. (Dkt. 25.) Defendant thereafter scheduled mediation through the Mediation Center of the Pacific and, on July 9, 2026, participated in mediation of this dispute in this State. In the same period, Defendant registered and used a Hawai‘ Judiciary electronic filing account, designated two successive representatives to appear in this Court, and filed successive letters and motions here. A party that genuinely contends a forum is improper seeks a ruling and preserves its objection; it does not spend three months litigating and mediating in the forum it disputes. Whatever the formal contours of waiver in this Division, Defendant’s course of conduct is acquiescence in this forum in every practical sense, and it sits poorly beside a request—renewed five days before the hearing— that two Honolulu residents pursue their $5,000 claim in Santa Clara County, California.

VI. CONCLUSION

For these reasons and those stated in Plaintiffs’ prior briefing (Dkts. 20, 30), Plaintiffs respectfully request that the Court: (1) decline to accept Dkt. 34 as satisfying HRS § 633-28(b), and examine Mr. Drakeford regarding the terms of his engagement before permitting him to be heard; (2) require Defendant to appear through licensed Hawai‘i counsel; (3) deny Defendant’s Motion to Dismiss (Dkts. 12, 17, 32)—which, in its refiled form, rests on a rule that does not author- ize the relief it seeks; and (4) proceed to a prompt hearing on Plaintiffs’ claim for

money damages.

Dated: Honolulu, Hawai‘, July 22 2026. Respectfully submitte

CRAIG W. WALSH Plaintiff Pro Se

MARJORIE J. WALSH Plaintiff Pro Se

CRAIG W. WALSH MARJORIE J. WALSH

350 Ward Avenue, Suite 106-8 Honolulu, Hawai‘i 96814 Telephone: (802) 359-2718 Email: [email protected]

Plaintiffs Pro Se

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAI'I

CRAIG W. WALSH AND Civil No. 1DSC-26-0000370 MARJORIE J. WALSH, CERTIFICATE OF SERVICE Plaintiffs, Hearing: August 4, 2026, 1:30 p.m. vs. Courtroom 10B

GOOGLE LLC, Defendant.

CERTIFICATE OF SERVICE

The undersigned certifies that on the date of filing, a true and correct copy of the foregoing PLAINTIFFS’ RESPONSE TO DEFENDANT'S JULY 30, 2026 FILINGS (DKTS. 32 AND 34) was served upon Defendant GOOGLE LLC through the Hawai‘i Judiciary Electronic Filing System (JEFS), which effects

electronic service on all registered filers in this action, including Defendant’s

registered filer (JEFS Filer No. 7027909), and by email to small- [email protected], the email address designated on Defendant’s filings.

Dated: Honolulu, Hawai‘, July 30 2026.

CRAIG W. oft

Plaintiff Pro Se

CRAIG W. WALSH MARJORIE J. WALSH

350 Ward Avenue, Suite 106-8 Electronically Filed

ax FIRST CIRCUIT Honolulu, Hawai‘ 96814 Telephone: (802) 359-2718 1DSC-26-0000370 Email: [email protected] 05-AUG-2026 04:55 PM

Plaintiffs Pro Se Dkt. 40 PJDG

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAI'I

CRAIG W. WALSH AND Civil No. 1DSC-26-0000370

MARJORIE J. WALSH, PLAINTIFFS’ SUBMISSION OF Plaintiffs, PROPOSED JUDGMENT

vs.

GOOGLE LLC, Defendant.

PLAINTIFFS’ MISSION OF PROP: D GME

Pursuant to the Court’s direction at the conclusion of the August 4, 2026 trial, Plaintiffs respectfully submit the attached proposed Judgment, conforming to

the Court’s rulings, for the Court’s review and signature.

Dated: Honolulu, Hawai‘, August 5th, 2026.

Respectfully submitted, ’

CRAIG W. WALSH

Plaintiff Pro Se

MARJORIE J. WALSH

Plaintiff Pro Se

CRAIG W. WALSH MARJORIE J. WALSH

350 Ward Avenue, Suite 106-8 Honolulu, Hawai‘i 96814 Telephone: (802) 359-2718 Email: [email protected]

Plaintiffs Pro Se

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAI‘T

CRAIG W. WALSH AND Civil No. 1DSC-26-0000370 MARJORIE J. WALSH, [PROPOSED] JUDGMENT Plaintiffs, vs. GOOGLE LLC, Defendant. JUDGMENT

This matter came on for trial on August 4, 2026, at 1:30 p.m. in Courtroom 10B of the above-entitled Court. Plaintiff Craig W. Walsh appeared via Zoom;

Plaintiff Marjorie J. Walsh was excused. Defendant Google LLC appeared via

Zoom through its designated representative, Ian Drakeford. Trial was had; both

parties gave testimony and were examined by the Court.

At the conclusion of the trial, and by order of the Court, Defendant’s Motion to Dismiss was DENIED, and the Court ordered judgment in favor of

Plaintiffs.

Accordingly, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that Judgment is entered in favor of Plaintiffs CRAIG W. WALSH and MARJORIE J. WALSH and against Defendant GOOGLE LLC in the principal amount of $200.00, together with costs of $35.00 (filing fee), for a total judgment of $235.00, with post-judgment interest thereon at the rate of ten percent (10%) per annum pursuant to HRS § 478-3 from the date of entry of this

Judgment until satisfied.

DATED: Honolulu, Hawai'i, , 2026.

JUDGE OF THE ABOVE-ENTITLED COURT

CRAIG W. WALSH MARJORIE J. WALSH

350 Ward Avenue, Suite 106-8 Honolulu, Hawai‘i 96814 Telephone: (802) 359-2718 Email: [email protected]

Plaintiffs Pro Se

IN THE DISTRICT COURT OF THE FIRST CIRCUIT SMALL CLAIMS DIVISION — STATE OF HAWAI‘T

CRAIG W. WALSH AND Civil No. 1DSC-26-0000370 MERE te wale, CERTIFICATE OF SERVICE Plaintiffs, vs. GOOGLE LLC, Defendant. CERTIFICATE OF SERVICE

The undersigned hereby certifies that on the date set forth below, true and correct copies of the following documents were duly served upon Defendant

GOOGLE LLC:

e Plaintiffs’ Submission of Proposed Judgment; and

e Proposed Judgment.

Service was effected through the Hawai‘i Judiciary Electronic Filing System

(JEFS) and by electronic mail to [email protected].

Dated: Honolulu, Hawai'i, August 5th, 2026. /W— \

CRAIG W. WALSH

Plaintiff Pro Se