Huon v. Breaking Media et al
Filing
198
MOTION by Defendants Breaking Media, Breaking Media, Inc., Breaking Media, LLC, Irin Carmon, Gabby Darbyshire, Nick Denton, Gawker Media, David Lat, John Lerner, David Minkin, Elie Mystal to strike response in opposition to motion, 195 , response in opposition to motion,, 194 - Joint (Attachments: # 1 Exhibit A)(Mandell, Steven)
Exhibit A
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IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
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MEANITH HUON,
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Plaintiff,
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vs.
BREAKING MEDIA, et al.,
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Defendants.
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Chicago, Illinois
January 10, 2013
9:00 o'clock a.m.
APPEARANCES:
For the Plaintiff:
HUON LAW FIRM
BY: MR. MEANITH HUON
P.O. Box 441
Chicago, IL 60690
(312) 405-2789
For the Defendants
Breaking Media, Inc.,
David Lat, Elie
Mystal, John Lerner,
And David Minkin:
MANDELL MENKES LLC
BY: MR. STEVEN P. MANDELL
One North Franklin, Suite 3600
Chicago, IL 60606
(312) 251-1000
Court Reporter:
MS. CAROLYN R. COX, CSR, RPR, CRR, FCRR
Official Court Reporter
219 S. Dearborn Street, Suite 1420
Chicago, Illinois 60604
(312) 435-5639
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09:08:27
Docket No. 11 C 3054
TRANSCRIPT OF PROCEEDINGS - STATUS
BEFORE THE HONORABLE JOHN J. THARP, JR.
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For Defendants
Gawker Media,
Jezebel.com,
Elizabeth Denton,
Irin Carmon, and
Gabby Darbyshire:
LYNCH & STERN LLP
BY: MS. AMANDA SZUCH MLINARCIK
150 South Wacker Drive
Suite 2600
Chicago, IL 60606
(312) 346-1600
AND
GISKAN, SOLOTARTOFF ANDERSON & STEWART
BY: MR. DAVID L. FEIGE
11 Broadway, Suite 2150
New York, NY 10004
(212) 847-8315
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THE CLERK: 11 C 3054, Huon v. Breaking Media.
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MR. HUON: Good morning, your Honor. Meanith,
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THE COURT: Good morning.
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Counsel in court, could you enter your appearances,
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Mandell on behalf of Breaking Media, Inc., David Lat, Elie
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Mystal, John Lerner, and David Minkin.
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behalf of Gawker Media, Gawker Media, Inc., Entertainment
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Technologies, Elizabeth Denton, Irin Carmon, and Gabby
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Darbyshire.
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THE COURT: Okay. And, Mr. Huon, you already...
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MR. HUON: I have seen their motion, Judge. There is
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a couple, two items, housekeeping items. One is attached to
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their motion to dismiss is a truncated trial transcript and
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it's part of their exhibit. I had brought a prior motion
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before a magistrate judge to redact the name of the
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complaining witness and their home town. That motion was
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granted. As part of that motion, I also asked for them to
(The following proceedings were had in open court:)
M-e-a-n-i-t-h, Huon, H-u-o-n, for the plaintiff.
please.
MS. MLINARCIK: Amanda Mlinarcik on behalf of Gawker
Media, Jezebel.com, Nick Denton, Irin Carmon, and Gabby
Darbyshire, local counsel.
MR. MANDELL: Good morning, your Honor. Steve
MR. FEIGE: And by telephone, Judge, David Feige on
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produce the entire transcript. The reason being -- and they
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have the entire trial transcript. The reason being is if they
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are going to assert the reporter privilege, the reporter
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privilege only applies -- it doesn't apply if they don't fully
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disclose everything that took place in the original
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proceedings. The other thing is most of these articles were
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about the consent defense. The consent defense never went to
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the jury. That's in the trial transcript.
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issue discovery to get that. Now, since you have denied my
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motion to conduct limited discovery and since I can't get the
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parties to do a 26(f) conference, I have an issue with
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discovery. I need that trial transcript in order to respond
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to the motion to dismiss. That's one of the first issues.
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the defendants to answer -- to disclose under 7.1 or what
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their affiliates are which is the reason we are back here
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because I had to identify the issues of citizenship. Breaking
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Media, I acknowledge when they were served or in the suit,
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they appeared correctly as Breaking Media, L.L.C. Now they
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appear as Breaking Media, Inc.
The magistrate judge at the time recommended that I
THE COURT: All right. We will get to that in just a
second.
With respect to the motion -- let me -- just
preliminarily, where do we stand on service?
MR. HUON: That's the second issue. You had ordered
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have appeared as Gawker Media. It's very difficult -- we know
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that there are several Gawker entities. There's Gawker Media,
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Inc., Gawker Technologies, Gawker, L.L.C. It's very difficult
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to tell who they are responding for and they have not answered
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the 7.1 disclosure. Breaking Media has.
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THE COURT: Hold on. Hold on.
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MR. FEIGE: Sure. Sorry, Judge.
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MR. HUON: I think that they should be ordered to
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state who they're responding for because that would allow me
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to move forward as to whether I am going to default the ones
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who I think that they have already appeared for by appearing
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as Gawker, and that would also allow me to identify who I need
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to serve. I have sent waiver of service of summons to Gawker.
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But by appearing as Gawker Media, it's difficult to tell who
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they're here for.
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THE COURT: All right. Mr. Feige.
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MR. FEIGE: Yes, if I could just respond. The 7.1
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disclosures, I'm sorry, that should be filed within the hour.
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They're done and should be being filed now. I can just answer
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those fairly simply.
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which has one member, that being Gawker Media Group, Inc.
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Gawker Media, L.L.C., is the sole member of Gawker
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Entertainment, L.L.C., Gawker Sales, L.L.C., and Gawker
Gawker has waived service as Gawker Media, and they
Gawker Media Group, Inc., owns Gawker Media, L.L.C.,
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Technology, L.L.C. I am appearing for all of them and, of
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course, the individual defendants.
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THE COURT: All right.
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MR. FEIGE: I think that's sufficiently clear. I
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THE COURT: I think it is. Mr. Huon.
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MR. HUON: I didn't have time to catch all of that,
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Judge. If he could put it in a letter and send it to us.
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Last time the magistrate judge ordered him to put something in
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THE COURT: You will get the disclosure. If you have
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any further questions, it doesn't sound like there's any issue
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there that we should have a problem cooperating identifying
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exactly who is represented.
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MR. FEIGE: No, I don't expect so.
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THE COURT: All right. Now, with respect to the
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trial transcript, do either of the defendants have or groups
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of defendants have a response?
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talking about that happened in front of the magistrate.
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Obviously, he was the defendant in the proceeding. We have
know there's a lot of Gawkers in there.
a letter.
THE COURT: Will your disclosure that's going to be
filed -MR. FEIGE: It will contain all of that, yes, and it
should be there within the hour.
MR. MANDELL: I don't frankly recall what counsel is
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spent money to obtain the transcript. You know, I am not
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opposed to sharing the transcript with him. It would be nice
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if he shared the cost of the transcript.
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MR. HUON: Well, when I called the court reporter,
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the entire trial transcript is $5,000. The other thing is,
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you know, I am pro se. They're relying on this, so as
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officers of the court, they have a duty to disclose the whole
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have not provided something they are required to provide, you
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have to raise that point, but they certainly are entitled to
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support their motion to dismiss with whatever it is that they
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think is relevant. If you think there's some other portion of
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a trial transcript that is relevant, the fact that they have
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introduced it might give you an opening to include that in
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your response, but it's not their responsibility to do that
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for you.
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out what his costs are. In the worst case scenario, he can
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perhaps produce one page where the Court makes it clear that
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the consent defense never went to the jury, and that one page
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might be a dollar for the copy.
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THE COURT: Is there any reason, Mr. Huon, you can't
obtain the transcript yourself?
facts. They can't just disclose selective things.
THE COURT: Sure, they can. If you think that they
MR. HUON: I could propose talking to counsel to find
THE COURT: Why don't you all have a discussion about
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that because I am not clear exactly what you're talking about.
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See if you can work it out. I will tell you what I tell all
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counsel. I expect counsel to cooperate and be reasonable so
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we can get things done efficiently, and efficiency includes
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economically, but having said that, the defendants don't have
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any right to pay for your lawsuit here.
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MR. HUON: I understand.
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THE COURT: Now, with respect to the briefing on the
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Judge, I am just asking for 60. I got War and Peace and Anna
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Karenina to respond to here. They are massive briefs. I am
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asking for 60 days. I don't have three law firms working on
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the file, and the original briefing schedule before the case
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was transferred, I think we have similar times as well.
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THE CLERK: March 12th.
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MR. HUON: Is there a way that you can move it by a
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week so I can try to work out the trial transcript issue, just
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give us a week to work out the trial transcript issue, 60 days
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from a week from now?
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THE COURT: No, 60 days. That's plenty of time.
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On that score, the motions by both groups of
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motions, what do you need to respond?
MR. HUON: Since they had 53 days to put it together,
THE COURT: All right. It's your case. You are the
plaintiff. 60 days to respond.
defendants for leave to file memoranda in excess of 15 pages
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are granted. That's docket entries 176 and 181. Mr. Huon, I
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will give you leave to file a consolidated response memoranda
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to both motions of up to 35 pages. That's I think equal,
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approximately, to the total number of pages in the two
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motions, and then reply briefs will not exceed 15 pages.
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transferred to you. Breaking Media filed an 18-page brief and
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then they filed a 17-page chart. I think that circumvents the
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page requirements because I am responding to a 17-page chart.
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of pages they are talking about facts and allegations that are
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very inflammatory that's not relevant. The Seventh Circuit
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has said there is no such thing as a defamation outlaw. It
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takes one sentence to cry fire in the theater; it takes pages
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to explain that there is no fire. They have done that before.
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What happened before the case was transferred to you, I had
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responded to them separately. I have no problems responding
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to them separately, but the Court actually gave me 30 pages.
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I am not saying I am going to use 30 pages, but if he's got a
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17-page chart plus an 18-page brief and Gawker Media has a
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22-page response brief and two pages are devoted to name
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calling where they are moving from lawyers' advocate --
MR. HUON: That's the last issue I wanted to address,
if I can have your indulgence.
The issue with the briefing schedule, this came up
with the original briefing schedule as well before it was
Now, with respect to Gawker Media, the first couple
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THE COURT: How many pages do you think you need?
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MR. HUON: I wanted to have the option of a 30-page
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two ways. I will give you up to 50 pages in a combined brief
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or 30 pages individually.
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MR. HUON: Thank you, Judge.
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THE COURT: That should be more than adequate. You
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MR. HUON: That is, Judge.
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THE COURT: In light of the expanded pages, I will
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give each of the defense groups 20 pages for reply.
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Anything else we need to address?
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MR. HUON: Do you want us to hold off on a 26(f)
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are going to get at issue before we start talking about moving
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ahead with discovery.
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is 10 pages, and it really is just for the benefit of the
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Court because he has allegations against Breaking Media alone
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of over 50 alleged defamatory statements.
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MR. HUON: Sorry. I misspoke.
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THE COURT: That's fine. I will give you -- both
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response for each side.
THE COURT: I will give you -- you can do it one of
have 60 days. That should be more than adequate.
conference?
THE COURT: Yes. We are going to get straight -- we
MR. MANDELL: I don't want to quibble, but our chart
sides should have ample pages to make your points, and we will
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take them under advisement. We will try to address things
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expeditiously, so if the case is able to move forward, we can
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get started on that.
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MR. FEIGE: I don't believe so.
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THE COURT: I don't think we set a schedule. We
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should definitely do that. How long -- well, we gave Mr. Huon
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60 days. How long do you need for the reply?
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give you 28 days on the reply in light of the extended period
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for the plaintiff's response.
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MR. FEIGE: Great. That's great.
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MR. MANDELL: Thank you.
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THE COURT: Thank you all very much.
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MR. MANDELL: One more thing, your Honor. I may have
missed it, but did we set a deadline for the reply briefs?
MR. MANDELL: I will say subject to what Mr. Feige
says, 21 days.
MR. FEIGE: I was going to say 30, but I am fine -- I
am okay with either.
THE COURT: Well, to avoid coming back in, I will
(Which were all the proceedings had in the above-entitled
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cause on the day and date aforesaid.)
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I certify that the foregoing is a correct transcript from
the record of proceedings in the above-entitled matter.
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Carolyn R. Cox
Official Court Reporter
Northern District of Illinois
Date
1
$
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disclosures [1] - 5:19
2
discovery [4] - 4:10, 4:11, 4:13, 10:18
discussion [1] - 7:25
dismiss [3] - 3:21, 4:14, 7:14
District [1] - 11:25
docket [1] - 9:1
dollar [1] - 7:24
done [3] - 5:20, 8:4, 9:18
Drive [1] - 2:2
duty [1] - 7:9
E
economically [1] - 8:5
efficiency [1] - 8:4
efficiently [1] - 8:4
either [2] - 6:21, 11:13
Elie [1] - 3:12
Elizabeth [2] - 2:2, 3:16
enter [1] - 3:6
Entertainment [2] - 3:15, 5:25
entire [3] - 4:1, 4:2, 7:7
entities [1] - 5:3
entitled [3] - 7:13, 11:20, 11:22
entries [1] - 9:1
equal [1] - 9:3
exactly [2] - 6:18, 8:1
exceed [1] - 9:5
excess [1] - 8:25
exhibit [1] - 3:22
expanded [1] - 10:11
expect [2] - 6:19, 8:3
expeditiously [1] - 11:2
explain [1] - 9:18
extended [1] - 11:15
F
fact [1] - 7:16
facts [2] - 7:10, 9:14
fairly [1] - 5:21
FEIGE [10] - 2:7, 3:14, 5:8, 5:18, 6:4,
6:13, 6:19, 11:6, 11:12, 11:17
Feige [3] - 3:14, 5:17, 11:10
file [3] - 8:14, 8:25, 9:2
filed [5] - 5:19, 5:20, 6:12, 9:10, 9:11
fine [2] - 10:24, 11:12
fire [2] - 9:17, 9:18
firms [1] - 8:13
first [2] - 4:14, 9:13
following [1] - 3:1
foregoing [1] - 11:22
forward [2] - 5:11, 11:2
frankly [1] - 6:23
front [1] - 6:24
fully [1] - 4:4
G
Gabby [3] - 2:3, 3:9, 3:16
Gawker [23] - 2:1, 3:8, 3:15, 5:1, 5:2,
5:3, 5:4, 5:13, 5:14, 5:15, 5:22, 5:23,
5:24, 5:25, 9:13, 9:23
Gawkers [1] - 6:5
gISKAN [1] - 2:6
granted [2] - 3:25, 9:1
great [2] - 11:17
Group [2] - 5:22, 5:23
groups [3] - 6:21, 8:24, 10:12
H
hold [3] - 5:7, 10:14
home [1] - 3:24
Honor [3] - 3:3, 3:11, 11:4
hour [2] - 5:19, 6:14
housekeeping [1] - 3:20
Huon [7] - 3:2, 3:4, 3:18, 6:6, 7:4, 9:1,
11:8
HUON [17] - 3:3, 3:4, 3:19, 4:19, 5:9,
6:7, 7:6, 7:20, 8:7, 8:10, 8:19, 9:6, 10:2,
10:7, 10:10, 10:14, 10:23
I
identify [2] - 4:22, 5:13
identifying [1] - 6:17
IL [1] - 2:3
Illinois [1] - 11:25
Inc [6] - 3:12, 3:15, 4:25, 5:4, 5:22,
5:23
include [1] - 7:17
includes [1] - 8:4
individual [1] - 6:2
individually [1] - 10:6
indulgence [1] - 9:7
inflammatory [1] - 9:15
introduced [1] - 7:17
Irin [3] - 2:3, 3:9, 3:16
issue [9] - 4:10, 4:12, 4:19, 6:16, 8:20,
8:21, 9:6, 9:8, 10:17
issues [2] - 4:14, 4:22
items [2] - 3:20
J
Jezebel.com [2] - 2:2, 3:9
John [1] - 3:13
Judge [7] - 3:14, 3:19, 5:8, 6:8, 8:11,
10:7, 10:10
judge [3] - 3:23, 4:9, 6:9
jury [2] - 4:8, 7:23
K
Karenina [1] - 8:12
L
L.L.C [7] - 4:24, 5:4, 5:22, 5:24, 5:25,
6:1
last [2] - 6:9, 9:6
Lat [1] - 3:12
law [1] - 8:13
lawsuit [1] - 8:6
lawyers' [1] - 9:25
leave [2] - 8:25, 9:2
Lerner [1] - 3:13
letter [2] - 6:8, 6:10
light [2] - 10:11, 11:15
limited [1] - 4:11
LLP [1] - 2:1
local [1] - 3:10
LYNCH [1] - 2:1
M
magistrate [4] - 3:23, 4:9, 6:9, 6:24
MANDELL [6] - 3:11, 6:23, 10:19,
11:4, 11:10, 11:18
Mandell [1] - 3:12
March [1] - 8:18
massive [1] - 8:12
matter [1] - 11:22
Meanith [1] - 3:3
MEANITH [1] - 3:4
Media [22] - 2:1, 3:2, 3:9, 3:12, 3:15,
4:23, 4:24, 4:25, 5:1, 5:2, 5:3, 5:6, 5:15,
5:22, 5:23, 5:24, 9:10, 9:13, 9:23, 10:21
member [2] - 5:23, 5:24
memoranda [2] - 8:25, 9:2
might [2] - 7:17, 7:24
Minkin [1] - 3:13
missed [1] - 11:5
misspoke [1] - 10:23
MLINARCIK [2] - 2:1, 3:8
Mlinarcik [1] - 3:8
money [1] - 7:1
morning [3] - 3:3, 3:5, 3:11
most [1] - 4:6
motion [9] - 3:19, 3:21, 3:22, 3:24,
3:25, 4:11, 4:14, 4:17, 7:14
motions [4] - 8:9, 8:24, 9:3, 9:5
move [3] - 5:11, 8:19, 11:2
moving [2] - 9:25, 10:17
MR [32] - 2:7, 3:3, 3:11, 3:14, 3:19,
4:19, 5:8, 5:9, 5:18, 6:4, 6:7, 6:13, 6:19,
6:23, 7:6, 7:20, 8:7, 8:10, 8:19, 9:6,
10:2, 10:7, 10:10, 10:14, 10:19, 10:23,
11:4, 11:6, 11:10, 11:12, 11:17, 11:18
MS [2] - 2:1, 3:8
Mystal [1] - 3:13
N
name [2] - 3:23, 9:24
3
need [6] - 4:13, 5:13, 8:9, 10:1, 10:13,
11:9
never [2] - 4:7, 7:23
New [1] - 2:8
nice [1] - 7:2
Nick [1] - 3:9
Northern [1] - 11:25
number [1] - 9:4
NY [1] - 2:8
O
obtain [2] - 7:1, 7:5
obviously [1] - 6:25
officers [1] - 7:9
Official [1] - 11:24
one [8] - 3:20, 4:14, 5:23, 7:22, 7:23,
9:17, 10:4, 11:4
ones [1] - 5:11
open [1] - 3:1
opening [1] - 7:17
opposed [1] - 7:2
option [1] - 10:2
order [1] - 4:13
ordered [3] - 4:19, 5:9, 6:9
original [3] - 4:5, 8:14, 9:9
outlaw [1] - 9:16
owns [1] - 5:22
P
page [3] - 7:22, 7:23, 9:12
pages [16] - 8:25, 9:3, 9:4, 9:5, 9:14,
9:17, 9:21, 9:22, 9:24, 10:1, 10:5, 10:6,
10:11, 10:12, 10:20, 10:25
part [2] - 3:22, 3:25
parties [1] - 4:12
pay [1] - 8:6
Peace [1] - 8:11
perhaps [1] - 7:22
period [1] - 11:15
place [1] - 4:5
plaintiff [2] - 3:4, 8:17
plaintiff's [1] - 11:16
plenty [1] - 8:23
plus [1] - 9:23
point [1] - 7:13
points [1] - 10:25
portion [1] - 7:15
preliminarily [1] - 4:18
privilege [2] - 4:3, 4:4
pro [1] - 7:8
problem [1] - 6:17
problems [1] - 9:20
proceeding [1] - 6:25
proceedings [4] - 3:1, 4:6, 11:20,
11:22
produce [2] - 4:1, 7:22
propose [1] - 7:20
provide [1] - 7:12
provided [1] - 7:12
put [3] - 6:8, 6:9, 8:10
Q
questions [1] - 6:16
quibble [1] - 10:19
R
raise [1] - 7:13
really [1] - 10:20
reason [4] - 4:1, 4:2, 4:21, 7:4
reasonable [1] - 8:3
recommended [1] - 4:9
record [1] - 11:22
redact [1] - 3:23
relevant [3] - 7:15, 7:16, 9:15
relying [1] - 7:8
reply [5] - 9:5, 10:12, 11:5, 11:9, 11:15
reporter [3] - 4:3, 7:6
Reporter [1] - 11:24
represented [1] - 6:18
required [1] - 7:12
requirements [1] - 9:12
respect [4] - 4:17, 6:20, 8:8, 9:13
respond [5] - 4:13, 5:18, 8:9, 8:12,
8:17
responded [1] - 9:20
responding [4] - 5:5, 5:10, 9:12, 9:20
response [6] - 6:22, 7:18, 9:2, 9:24,
10:3, 11:16
responsibility [1] - 7:18
S
Sales [1] - 5:25
scenario [1] - 7:21
schedule [4] - 8:14, 9:8, 9:9, 11:7
score [1] - 8:24
se [1] - 7:8
second [2] - 4:16, 4:19
see [1] - 8:2
selective [1] - 7:10
send [1] - 6:8
sent [1] - 5:14
sentence [1] - 9:17
separately [2] - 9:20, 9:21
serve [1] - 5:14
served [1] - 4:23
service [3] - 4:18, 5:1, 5:14
set [2] - 11:5, 11:7
Seventh [1] - 9:15
several [1] - 5:3
shared [1] - 7:3
sharing [1] - 7:2
side [1] - 10:3
sides [1] - 10:25
similar [1] - 8:15
simply [1] - 5:21
sole [1] - 5:24
SOLOTARTOFF [1] - 2:6
sorry [3] - 5:8, 5:19, 10:23
sound [1] - 6:16
South [1] - 2:2
spent [1] - 7:1
stand [1] - 4:18
start [1] - 10:17
started [1] - 11:3
state [1] - 5:10
statements [1] - 10:22
STERN [1] - 2:1
Steve [1] - 3:11
STEWART [1] - 2:6
straight [1] - 10:16
subject [1] - 11:10
sufficiently [1] - 6:4
suit [1] - 4:23
Suite [2] - 2:2, 2:7
summons [1] - 5:14
support [1] - 7:14
SZUCH [1] - 2:1
T
Technologies [2] - 3:16, 5:4
Technology [1] - 6:1
telephone [1] - 3:14
THE [27] - 3:2, 3:5, 3:18, 4:15, 5:7,
5:17, 6:3, 6:6, 6:11, 6:15, 6:20, 7:4,
7:11, 7:25, 8:8, 8:16, 8:18, 8:23, 10:1,
10:4, 10:8, 10:11, 10:16, 10:24, 11:7,
11:14, 11:19
theater [1] - 9:17
three [1] - 8:13
together [1] - 8:10
took [1] - 4:5
total [1] - 9:4
town [1] - 3:24
transcript [15] - 3:21, 4:1, 4:2, 4:8,
4:13, 6:21, 7:1, 7:2, 7:3, 7:5, 7:7, 7:16,
8:20, 8:21, 11:22
transferred [3] - 8:15, 9:10, 9:19
trial [9] - 3:21, 4:2, 4:8, 4:13, 6:21, 7:7,
7:16, 8:20, 8:21
truncated [1] - 3:21
try [2] - 8:20, 11:1
two [4] - 3:20, 9:4, 9:24, 10:5
U
under [2] - 4:20, 11:1
up [3] - 9:3, 9:8, 10:5
W
Wacker [1] - 2:2
4
waived [1] - 5:1
waiver [1] - 5:14
War [1] - 8:11
ways [1] - 10:5
week [3] - 8:20, 8:21, 8:22
whole [1] - 7:9
witness [1] - 3:24
worst [1] - 7:21
Y
York [1] - 2:8
yourself [1] - 7:5
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