Code Revision Commission et al v. Public.Resource.Org, Inc.

Filing 45

Joint MOTION for Order Entering Proposed Permanent Injunction by Code Revision Commission. (Attachments: # 1 Text of Proposed Order)(Askew, Anthony)

Case 1:15-cv-02594-RWS Document 45 Filed 04/06/17 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
CODE REVISION COMMISSION on
behalf of and for the benefit of THE
GENERAL ASSEMBLY OF
GEORGIA, and THE STATE OF
GEORGIA,
Plaintiff,

CIVIL ACTION NO.

v.

1:15-CV-2594-RWS

PUBLIC.RESOURCE.ORG, INC.
Defendant.

JOINT MOTION FOR ENTRY OF
PROPOSED PERMANENT INJUNCTION ORDER

Plaintiff and Counterclaim-Defendant the Code Revision Commission, on
behalf of and for the benefit of the General Assembly of Georgia, and the State of
Georgia (“Commission”), and Defendant and Counterclaim-Plaintiff
Public.Resource.Org, Inc. (“Public Resource”) jointly move for the Court to enter
the below Proposed Permanent Injunction Order following this Court’s Order on
March 23, 2017 (Dkt. No. 44) granting Commission’s Motion for Partial Summary
Judgment. On March 23, 2017, upon learning of the Court’s Order, Public
Resource took down all versions of the O.C.G.A. from its website and any other
website within its possession, custody, or control. Public Resource has also
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Case 1:15-cv-02594-RWS Document 45 Filed 04/06/17 Page 2 of 4

removed all fundraising solicitations for its use of the O.C.G.A. from its website
and any other website within its possession, custody, or control and from its web
server.
The Parties submit this Joint Motion in lieu of a proposed briefing schedule
to address the injunctive relief to which Commission is entitled.
Respectfully submitted, this 6th day of April, 2017.
/s/Elizabeth H. Rader (w/express
permission)

/s/Anthony B. Askew
Anthony B. Askew (G.A. Bar: 025300)
Lisa C. Pavento (G.A. Bar: 246698)
Warren Thomas (G.A. Bar: 164714)
Meunier Carlin & Curfman LLC
999 Peachtree Street, NE, Suite 1300
Atlanta, Georgia 30309
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]

Elizabeth H. Rader (pro hac vice)
ALSTON & BIRD LLP
950 F Street, NW
Washington, DC 20004
Telephone: [phone]
Fax: [phone]
[e-mail]

Counsel for the Plaintiff, Code Revision
Commission on behalf of and for the
benefit of the General Assembly of
Georgia, and the State of Georgia

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Jason D. Rosenberg
Georgia Bar No. 510855
Sarah Parker LaFantano
ALSTON & BIRD LLP
One Atlantic Center
1201 West Peachtree Street
Atlanta, GA 30309-3424
Telephone [phone]
Fax [phone]
[e-mail]
[e-mail]
Counsel for the Defendant,
Public.Resource.Org

Case 1:15-cv-02594-RWS Document 45 Filed 04/06/17 Page 3 of 4

CERTIFICATE OF COMPLIANCE
I hereby certify that, pursuant to L.R. 5.1C and 7.1D of the Northern District
of Georgia, the foregoing JOINT MOTION FOR ENTRY OF PROPOSED
PERMANENT INJUCTION ORDER complies with the font and point
selections approved by the Court in L.R. 5.1C. The foregoing pleading was
prepared on a computer using 14-point Times New Roman font.

/s/Anthony B. Askew
Anthony B. Askew (G.A. Bar: 025300)
Meunier Carlin & Curfman LLC
999 Peachtree Street NE, Suite 1300
Atlanta, Georgia 30309
Telephone: [phone]
Email: [e-mail]

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Case 1:15-cv-02594-RWS Document 45 Filed 04/06/17 Page 4 of 4

CERTIFICATE OF SERVICE
I certify that on April 6, 2017, I electronically filed the foregoing JOINT
MOTION FOR ENTRY OF PROPOSED PERMANENT INJUCTION
ORDER with the Clerk of Court using the CM/ECF system, which constitutes
service of the filed document on all counsel of record in this proceeding under LR
5.1(A)(3), N.D. Ga.

By:

/s/Anthony B. Askew
Anthony B. Askew (G.A. Bar: 025300)

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