Jane Doe v. Match.com

Filing 14

REQUEST for Leave to Court's Permission for Plaintiffs to Call Witnesses at Preliminary Injunction Hearing filed by Plaintiff Jane Doe. Request set for hearing on 5/23/2011 at 01:30 PM before Judge Stephen V. Wilson. (Webb, Mark)

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1 2 3 4 5 6 7 MARK L. WEBB (STATE BAR NO. 67959) LAW OFFICE OF MARK L. WEBB 333 PINE STREET, 5TH FLOOR SAN FRANCISCO, CA 94104 TEL: (415) 434-0500 Attorney for Plaintiffs JANE DOE, individually, and on behalf of all others similarly situated 8 9 UNITED STATES DISTRICT COURT 10 FOR THE 11 CENTRAL DISTRICT OF CALIFORNIA 12 13 14 15 JANE DOE, individually and on behalf Of all others similarly situated, 16 Plaintiffs, 17 18 19 v. MATCH.COM, 20 Defendants. 21 22 Case No.: 2:11-cv-03795-SVW-JEM PLAINTIFFS’ REQUEST TO ALLOW WITNESSES AT MAY 23, 2011 PRELIMINARY INJUNCTION HEARING Hearing Date: May 23, 2011 Time and Location: 1:30 pm, Courtroom 6 Hon. Stephen V. Wilson 23 24 25 26 27 28 Plaintiffs hereby request this Honorable Court to allow the calling of witnesses as follows: PLAINTIFFS’ REQUEST TO ALLOW WITNESSES  AT MAY 23, 2011 PRELIMINARY INJUNCTION HEARING  Case No. 2:11‐cv‐03795‐SVW‐JEM  Page 1  1 2 1. Carole Markin, also known as Jane Doe and the Class representative in this matter, as to her declaration filed in support of the Motion for Preliminary 3 4 5 6 7 8 9 Injunction (direct testimony - 15 minutes). 2. Russell Mallette, an expert in security background checks, as to his declaration filed in support of the Motion for Preliminary Injunction (direct testimony – 15). Plaintiffs also intend to call one Match.com executive who is being noticed to 10 11 12 13 14 15 16 appear, as follows: 3. Mandy Ginsburg, President of Match.com, as to the number of prior rapes and/or sexual assaults that have occurred on Match.com dates reported to Defendant. She also will be asked about the size of Match.com and its expansion into China and other global regions (direct exam - 10 minutes). 17 18 19 20 Plaintiffs also, with this Court’s permission, intend to call one more witness for five minutes on direct. DATED: May 16, 2011 Respectfully submitted, 21 22 THE LAW OFFICE OF MARK L. WEBB 23 BY: /s/ 24 25 _______________________________ Mark L. Webb 26 27 28 PLAINTIFFS’ REQUEST TO ALLOW WITNESSES  AT MAY 23, 2011 PRELIMINARY INJUNCTION HEARING  Case No. 2:11‐cv‐03795‐SVW‐JEM  Page 2 

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