Brave New Films 501 (C)(4) v. Weiner et al

Filing 78

NOTICE of JOINDER by Michael Weiner re 63 MOTION for Protective Order (Supplemental) Notice of Joinder (Shapiro, Benjamin) (Filed on 5/8/2009) Modified on 5/11/2009 (ys, COURT STAFF).

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Benjamin Aaron Shapiro (SBN 254456) 12330 Magnolia Blvd., #114 Valley Village, CA 91607 Telephone: [phone] Attorney for Defendant MICHAEL WEINER aka MICHAEL SAVAGE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

BRAVE NEW FILMS 501(c)(4), Plaintiff, vs. MICHAEL WEINER aka MICHAEL SAVAGE and ORIGINAL TALK RADIO NETWORK, INC., Defendants

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Case No.: CV 08-4703 SI NOTICE OF JOINDER OF DEFENDANT MICHAEL WEINER aka MICHAEL SAVAGE IN DEFENDANT THE ORIGINAL TALK RADIO NETWORK, INC.'S MOTION FOR SUPPLEMENTAL PROTECTIVE ORDER AND POINTS AND AUTHORITIES IN SUPPORT THEREOF Date: May 22, 2009 Time: 9:00 a.m. Location: Courtroom 10 The Honorable Susan Illston

1 SAVAGE'S NOTICE OF JOINDER IN MOTION FOR SUPPLEMENTAL PROTECTIVE ORDER Case No. CV 08-4703 SI

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PLEASE TAKE NOTICE that defendant MICHAEL WEINER aka MICHAEL SAVAGE ("Savage") will, and hereby does, join in defendant THE ORIGINAL TALK RADIO NETWORK, INC.'s Motion for Supplemental Protective Order and Points and Authorities in Support Thereof in the above captioned action (the "Motion"), as was anticipated in the Stipulation and [Proposed] Order to Continue Hearing filed in the above-captioned action (this "Action") by Savage, defendant THE ORIGINAL TALK RADIO NETWORK, INC. ("OTRN"), and plaintiff BRAVE NEW FILMS 501(c)(4) as of April 30, 2009, and, in such regard, requests that such protective order apply, as requested by OTRN, to any and all discovery propounded to Savage which raises the same issues as the discovery propounded to OTRN which is the subject of the Motion. Federal courts have long recognized the right to join in motions filed by other parties, particularly parties on the same side in a case; and such joinder is in fact encouraged when "the grounds stated in the motion are applicable to the joining party as well as the moving party." Willis v. Pacific Maritime Ass'n, 1997 WL 488581, at p. *2 (N.D. Cal 1997).

Dated: May 8, 2009 By /s/ Benjamin Aaron Shapiro

Attorney for Defendant MICHAEL WEINER aka MICHAEL SAVAGE

2 SAVAGE'S NOTICE OF JOINDER IN MOTION FOR SUPPLEMENTAL PROTECTIVE ORDER Case No. CV 08-4703 SI

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PROOF OF SERVICE BY E-MAIL I am employed in the County of Los Angeles, California. I am over the age of eighteen years and not a party to the within case. My business address is 12330 Magnolia Boulevard Suite 114, Los Angeles, CA, 91607. On May 8, 2009, I served the attached NOTICE OF JOINDER OF DEFENDANT MICHAEL WEINER aka MICHAEL SAVAGE IN DEFENDANT THE ORIGINAL TALK RADIO NETWORK, INC.'S MOTION FOR SUPPLEMENTAL PROTECTIVE ORDER AND POINTS AND AUTHORITIES IN SUPPORT THEREOF on the interested parties in the above captioned action by E-mail as follows:

Tony Falzone [e-mail] William Abrams [e-mail] Ronald H. Severaid [e-mail] Carter Glahn [e-mail] I declare under penalty of perjury that the foregoing is true and correct, and that this declaration was executed on May 8, 2009 at Los Angeles, California.

/s/ Benjamin Shapiro Benjamin Shapiro 12330 Magnolia Blvd., #114 Valley Village, CA 91607 [phone] [e-mail] Attorney for Defendant MICHAEL WEINER aka MICHAEL SAVAGE

3 SAVAGE'S NOTICE OF JOINDER IN MOTION FOR SUPPLEMENTAL PROTECTIVE ORDER Case No. CV 08-4703 SI