The mere fact that Hotz resides in New Jersey does not make his burden of litigating in California unfairly high. While Hotzs preference to litigate in New Jersey, does not make the exercise of jurisdiction here unreasonable. As the Ninth Circuit has noted, with the advances in transportation and telecommunications and the increasing interstate practice of law, any burden is substantially less than in days past. Menken, 503 F.3d at 1060 (quoting CE Distrib., LLC, 308 F.3d at 1112).
This statement is particularly applicable to Hotz, who formerly lived and worked in California, and has traveled to California at least four times in the past two years. Bricker Decl., ¶4, Exh. C. Recently, in fact, Hotz conveniently traveled to South America in the midst of jurisdictional discovery, including his court-ordered deposition. Accordingly, the burden on Hotz of litigating in California will be minimal at most, and hardly dispositive.