Huon v. Breaking Media et al

Filing 59

MOTION by Plaintiff Meanith Huon to clarify (Huon, Meanith)

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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PLAINTIFF’S MOTION TO PRESENT
THE JEZEBEL.COM DEFENDANTS’ MOTION TO DIMISS AND
FOR CLARIFICATION
Plaintiff, Meanith Huon, states as follows:
1.

Defendants, Irin Carmon, Gabby Darbyshire, Nick Denton, Gawker Media,
Jezebel.com (collectively referred to as “The Jezebel.com Defendants”) filed a
motion for leave to file a brief in excess of 15 pages, without filing the actual brief
with its motion. The Jezebel.com Defendants never noticed up their motion.

2.

The Jezebel.com Defendants have now filed a Motion to Dismiss and Supporting
Memorandum totaling 31 pages and with exhibits. The Jezebel.com Defendants
again have not filed a Notice of its Motion to Dismiss.

3.

This Court previously entered a briefing schedule with respect only to the Motion
to Dismiss of Breaking Media, LLC, Breaking Media, Breakingmedia.com, David
Lat, John Lerner, Abovethelaw.com, Elie Mystal, (“The Above the Law”
Defendants”). The Above the Law Defendants filed a Motion to Dismiss and a 22page Memorandum of Law with Exhibits in Excess of 170 pages.

4.

No briefing schedule has been entered with respect to the Jezebel.com
Defendants’ Motion to Dismiss, since at the time of the briefing schedule, the
Jezebel.com Defendants had not filed a motion and supporting memorandum.

5.

Mr. Huon is pro se and needs the next 35 days or so to respond to The Above the
Law Defendants’ motion to dismiss. He is not represented by an attorney or a law
firm.

6.

On information and belief, the Jezebel.com Defendants have had more than 60
days to file its 27 page Memorandum of Law and Motion to Dismiss and exhibits.

7.

The Court’s ruling on The Above the Law Defendants’ motion to dismiss may
impact Mr. Huon’s responsive pleading to the Jezebel.com Defendants’ pending
Motion to Dismiss or Mr. Huon’s decision to amend his complaint.

8.

Entering and continuing the Jezebel.com Defendants’ Motion to Dismiss
generally until the Court rules on The Above the Law Defendants’ Motion to Dismiss
does not prejudice the Jezebel.com Defendants, since the defamatory content
regarding Mr. Huon continues to be published and re-published every day worldwide
via the Internet by the Jezebel.com Defendants. Only Mr. Huon is prejudiced.

9.

The next Court status date is on December 22, 2011.

10.

Mr. Huon has other professional obligations in state and federal court. He is
assistant general counsel to Aidan Monahan and Monahan Properties, LLC; he is
assistant general counsel to Flava Works, Inc.. Mr. Huon maintains his own law
practice. Mr. Huon has a full time attorney position with a law firm with cases that
require court attendance in Cook County and downstate Illinois, including court calls
in Champaign County and Livingston County in October of 2011.

11.

On September 30, 2011, Mr. Huon emailed counsel for the Jezebel.com
Defendants regarding this issue of not filing a Notice of motion but has not received a
response.
WHEREFORE, Plaintiff, Meanith Huon, requests that this Honorable Court:

1.

Enter and continue the Motion to Dismiss of the Jezebel.com generally, pending
the Court’s ruling on The Above the Law Defendants’ Motion to Dismiss and excuse
Plaintiff from having to respond until further order of Court.

2.

In the alternative, Plaintiff requests that this Court grant him leave to file a
Response Brief to the Jezebel.com Defendants’ Motion and 27-page Memorandum in
excess of 15 pages (but no more than 27 pages) and to give Plaintiff 60 days, until,
November 30, 2011 to file a Response Brief to the Jezebel.com’s Motion to Dismiss.

Respectfully Submitted,
By: /s/ Meanith Huon
Meanith Huon
Meanith Huon
ARDC No.: 6230996
PO Box 441
Chicago, IL 60690
312-405-2789
[e-mail]

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 on September 30, 2011:

PLAINTIFF’S MOTION TO PRESENT
THE JEZEBEL.COM DEFENDANTS’ MOTION TO DIMISS AND
FOR CLARIFICATION

Respectfully submitted,
/s/ Meanith Huon
Meanith Huon
PO Box 441
Chicago, Illinois 60690
Phone: [phone]
E-mail: [e-mail]
IL ARDC. No.: 6230996