Huon v. Breaking Media et al
Filing
50
MOTION by Plaintiff Meanith Huon to strike 38 Amended (Attachments: # 1 Exhibit A)(Huon, Meanith) Docket text modified by the Clerk's office on 9/27/2011 (psm, ).
IIN THE UNITED STATES DISTRICT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
MEANITH HUON,
Plaintiff,
v.
ABOVETHELAW.COM,
et. al.
Defendants
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) CIVIL ACTION NO.: 1: 11-cv-3054
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AMENDED MOTION TO STRIKE EXHIBIT B TO DEFENDANTS’ MEMORANDUM
Plaintiff, Meanith Huon, states as follows:
1.
Defendants, Breaking Media, LLC, Breaking Media, Breakingmedia.com, David
Lat, John Lerner, Abovethelaw.com, Elie Mystal, (“The Above the Law”
Defendants”) filed an exhibit B to its Memorandum of Law in Support of its Motion
to Dismiss. Exhibit B to Exhibit 1 of Document No. 36.
2.
Exhibit “B” appears to be an incomplete transcript of the jury trial in the People
of the State of Illinois v. Meanith Huon, 08 CF 1496.
3.
Exhibit “B” is not relevant and serves no other purpose except to harass and
embarrass Mr. Huon.
4.
For example, the Trial Judge in 08 CF 1496 barred the consent defense, but the
incomplete transcript from the first day of trial does not show that. The trial
transcript consisting of opening arguments is not even evidence presented at trial.
5.
Moreover, the Above The Law article was published on or about the day Mr.
Huon was acquitted several days later on May 6, 2010.
6.
Worse, Exhibit identified the complaining witness in 08 CF 1496 and her
hometown. On information and belief, newspapers generally do not identify the
complaining witness.
The trial transcript also identifies the names and addresses of
the witnesses in the case.
7.
On information and belief, there is no evidence that The Above The Law
Defendants even ordered the trial transcript before publishing the defamatory
statements. The trial transcript serves no other purpose but to harass and embarrass
then individuals involved in the underlying criminal case.
8.
Defendants could have filed a transcript redacting the names and addresses of the
complaining witness and witnesses.
9.
Mr. Huon agreed to give Defendants leave to file in excess of the page limitations
allowed, as a matter of professional courtesy.
10.
He never agreed to give Defendants leave to file a trial transcript disclosing the
names and address of the complaining witness and witnesses in the criminal case.
11.
Pursuant to Local Rule 37.2, counsel's attempts to engage in such consultation
were unsuccessful due to no fault of counsel's. On or about September 22, 2011, Mr.
Huon requested in writing that counsel for Defendants produce the entire transcript.
Exhibit A. On or about September 30, 2011, Mr. Huon left a message for counsel for
Defendants,Shari Albrect, asking for her clients’ position on producing the entire trial
transcript Counsel for Defendants have not responded.
WHEREFORE, Plaintiff, Meanith Huon, requests that this Honorable Court:
1.
Strike Exhibit B to Defendants’ Memorandum of Law.
2.
In the alternative, order the Clerk of Court to remove Exhibit B and replace a
redacted version of Exhibit redacting the names and addresses of the complaining
witness and witnesses and any personal information.
Respectfully Submitted,
By: /s/ Meanith Huon /s/
Meanith Huon
Meanith Huon
ARDC No.: 6230996
PO Box 441
Chicago, IL 60690
312-405-2789
huon.meanith@gmail.com
IN THE UNITED STATES DISTRICT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
MEANITH HUON,
Plaintiff,
v.
FORMER MADISON COUNTY STATE'S
ATTORNEY WILLIAM MUDGE, et. al.
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CIVIL ACTION NO. 11-3050
JURY TRIAL DEMANDED
CERTIFICATE OF SERVICE
Under penalties of law, I attest the following documents or items have been or are being
electronically served on all counsel of record for all parties:
AMENDED MOTION TO STRIKE EXHIBIT B TO DEFENDANTS’ MEMORANDUM
Respectfully submitted,
/s/ Meanith Huon
Meanith Huon
PO Box 441
Chicago, Illinois 60690
Phone: (312) 405-2789
E-mail: huon.meanith@gmail.com
IL ARDC. No.: 6230996
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