Doe 1 et al v. Ciolli et al
MOTION to Expedite Plaintiffs' Motion for Expedited Discovery by Doe 1, Doe 2. (Attachments: # 1 Memorandum in Support Plaintiffs' Memorandum of Law in Support of Motion for Expedited Discovery, # 2 Affidavit Declaration of Doe I, # 3 Affidavit Declaration of Doe II, # 4 Affidavit Declaration of Doe II (Part 2 of 2), # 5 Affidavit Declaration of Steve Mitra. (Additional attachment(s) added on 4/11/2008: # 1 Memorandum in Support Plaintiffs' Memorandum in Support of Motion for Expedited Discovery, # 2 Affidavit Declaration of Doe I, # 3 Affidavit Declaration of Doe II, # 4 Affidavit Declaration of Doe II (Part 2 of 2), # 5 Affidavit Declaration of Steve Mitra, # 7 Affidavit of Steve Mitra Part 1, # 8 Affidavit of Steve Mitra Part 2) (Kunofsky, L.). Modified on 4/11/2008 (Kunofsky, L.). (Additional attachment(s) added on 4/11/2008: # 9 Proposed Order) (Kunofsky, L.). Modified on 10/6/2008 to correct text (S-D'Onofrio, B.).
Doe 1 et al v. Ciolli et al
UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT
DOE I, and DOE II, Plaintiffs, v. Individuals, whose true names are unknown, using the following pseudonyms: pauliewalnuts; neoprag; STANFORDtroll; :D; lkjhgf; yalelaw; Spanky; ylsdooder; HI; David Carr; vincimus; Cheese Eating Surrender Monkey; A horse walks into a bar; The Ayatollah of Rock-n-Rollah; DRACULA; Sleazy Z; Whamo; Ari Gold; Ugly Women; playboytroll; Dean_Harold_Koh; kr0nz; reminderdood; r@ygold; who is; Joel Schellhammer; Prof. Brian Leiter; hitlerhitlerhitler; lonelyvirgin; Patrick Zeke ; Patrick Bateman ; [DOE I] got a 157 LSAT; azn, azn, azn; Dirty Nigger; leaf; t14 gunner; kibitzer; yalels2009; AK47, Defendants.
Case No. 3:07CV00909(CFD)
Date: January 24, 2008
EMERGENCY RELIEF REQUESTED
PLAINTIFFS' MOTION FOR EXPEDITED DISCOVERY Plaintiffs DOE I and DOE II move this Court, under Federal Rule of Civil Procedure 26(d), to permit limited, expedited discovery in advance of the Rule 26(f) conference. Plaintiffs need this discovery to unearth the identities of the pseudonymous defendants and serve them with process, conduct a meet and confer, and proceed with this action. If this motion is not granted, plaintiffs will not be able to hold a Rule 26(f) conference, and, indeed, will not be able seek redress of their injuries through the courts. Plaintiffs further request that the Court consider the merits of this motion on an expedited basis since the information sought by plaintiffs is
subject to the threat of deletion. In support of this motion, plaintiffs submit herewith a Memorandum of Law, Declarations by Plaintiffs DOE I and DOE II,1 a Declaration by Plaintiffs' Counsel, and a Proposed Order.
Dated: January 24, 2008
PLAINTIFFS DOE I AND DOE II By: /s/_Steve Mitra__________ __________ Mark Lemley (pro hac vice) Ashok Ramani (pro hac vice) Steve Mitra (pro hac vice) KEKER & VAN NEST, LLP 710 Sansome Street San Francisco, CA 94111 Telephone: (415) 391-5400 Facsimile: (415) 397-7188 Email: MLemley@kvn.com ARamani@kvn.com SMitra@kvn.com David N. Rosen David Rosen & Associates PC 400 Orange Street New Haven, CT 06511 Telephone: (203) 787-3513 Facsimile: (203) 789-1605 Email: firstname.lastname@example.org
On June 8, 2007, the plaintiffs moved the Court to allow them to proceed anonymously in this case in light of the defendants' egregious actions. The Court granted the motion on June 18, 2007. Plaintiffs' names have therefore been redacted and replaced with DOE I and DOE II in the motion, memorandum, declarations, and exhibits.
CERTIFICATION OF SERVICE The addresses of all the defendants are unknown. This is to certify that a copy of this motion has been sent to the following by first class mail, postage prepaid on January 24, 2008, to: Marc Randazza, Esq. Weston, Garrou, DeWitt & Walters 781 Douglas Ave. Altamonte Springs, FL 32714 Leighton Cohen, Esq. 465 West Linden Street Allentown, PA 18102 Attorney for Anthony Ciolli
Attorney for Jarret Cohen
/s/ Steve Mitra STEVE MITRA
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