Huon v. Breaking Media et al

Filing 94

OBJECTIONS by Meanith Huon to MOTION by Defendants Irin Carmon, Gabby Darbyshire, Nick Denton, Gawker Media, Jezebel.com for extension of time 92 , notice of motion 93 (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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PLAINTIFF’S OBJECTION TO THE JEZEBEL DEFENDANTS’ MOTION FOR
EXTENSION OF TIME
Plaintiff, Meanith Huon, states as follows:
1.

The Magistrate Judge gave Mr. Huon until November 30, 2011 to file a 22 page

Response Brief to the Above the Law Motion to Dismiss and a 27 page Response Brief to the
Jezebel Defendants’ Motion to Dismiss, since the Jezebel Defendants filed a 27 page
Memorandum, including 55 pages of exhibits. (Mr. Huon is unable to locate the Docket No. for
this order but recalls asking the Magistrate Judge to file the same number of pages as the 27 page
Jezebel Defendants’ memorandum).
2.

On November 30, 2011, Mr. Huon filed a Motion for Leave to File a 33 page

Response Brief to the Above The Law Defendants’ Motion to Dismiss and for an extension of
time until December 12, 2011 to file his 27-page Response Brief to the Jezebel Defendants’
Motion to Dismiss. Mr. Huon stated that if the Court granted his Motion, he had no objection to
an extension for the Jezebel Defendants’ Reply Brief.
3.

However, the Jezebel Defendants opposed Mr. Huon’s request as it has done so

for every request for extension of time by Mr. Huon.
4.

On December 5, 2011, the Court entered the following order:
Plaintiff is granted leave to file a responsive brief of no more than 23 pages to the
Above The Law Defendants Motion to Dismiss on or before December 12, 2011 2.
As to all Memoranda relating to Above The Law Defendants Motion to Dismiss
heretofore filed or scheduled to be filed, all parties shall file on or before December
12, 2011, a summary of no more than 15 pages of their respective Memoranda and a
summary of no more than 15 pages of any exhibits to said Memoranda. (For further
details, see Order in separate docket entry). The motion hearing set for 12/6/11 is
stricken. Judicial staff mailed notice (gl, )

5.

With less than a week to file a 23 page Response Brief and a 27 page Response

Brief, Mr. Huon called the Courtroom Deputy and asked for clarification as to what the Court
meant by “Summary”. Did the Court want Mr. Huon to file Response Briefs plus two 15-page
Summaries?

Mr. Huon was advised that Mr. Huon and the Jezebel Defendants were to file

their Memorandum or Response Briefs by December 12, 2011 not to exceed 15 pages. He was
advised that the Court was NOT ordering him in a week’s time to file 23 page and 27 page
Response briefs and two 15 pages Summaries.
6.

Mr. Huon has been endeavoring to convert his Response Briefs to both Motions to

Dismiss into 15 pages.
7.

Mr. Huon was finally able to review the Jezebel Defendants’ Motion to Dismiss

and Memorandum and read several pages of personal attacks against Mr. Huon that had no
bearing on this lawsuit. Defendant accused him of having pending criminal charges and being a
sex offender. Mr. Huon has no pending criminal charges and has never been convicted of a
felony or misdemeanor.
8.

Mr. Huon endeavored to respond to the Jezebel Defendants 82-page Motion to

Dismiss, Memorandum, Exhibits and personal attacks by limiting his Response Brief to 15

pages, going over a few pages. As of the time this Objection is being filed, Mr. Huon
continues to attempt to revise his briefs meet the Court’s Order.
9.

The Jezebel Defendants have now filed a Motion for Extension of Time. The

Motion misstates that Mr. Huon has no objection. Counsel for the Jezebel Defendants never
called or contacted Mr. Huon. The fact that Mr. Huon was willing to modify the briefing
schedule (in a prior motion) is moot after the Jezebel Defendants opposed his request and the
Court entered the December 5, 2011 order. Why would Mr. Huon agree to an extension of time
to Defendants’ attorneys who called him a sex offender, after the Court limited Mr. Huon’s brief
from 33 pages to 15 pages?
10.

It would be patently unfair for the Jezebel Defendants to be given leave to file an

82 page Motion to Dismiss, Memorandum, Exhibits, to be given leave to file a 15 page
Summary, to be given leave to file a Reply brief, and to be given more time—after the
Defendants’ objection to each and every request to extension from Mr Huon resulted in the Court
limiting Mr. Huon’s Response Brief from 27 pages to 15 pages.
11.

Mr. Huon did not file hi Response Brief at the “eleventh hour”. On December 5,

2011, the Court ordered any Memorandum relating to the Motions to Dismiss to be filed by
December 5, 2011.
12.

At the eleventh hour, as Mr. Huon is trying to convert his Response Briefs into

briefs complying with the Court’s page limitations, the Jezebel Defendants files another motion
for Mr. Huon to respond to.
WHEREFORE, Plaintiff, Meanith Huon, requests that this Honorable Court:
1.

Deny the Jezebel Defendants’ Motion for Extension of time.

2.

Grant Mr. Huon until December 13, 2011 to comply with the December 5, 2011
order limiting the pages of the briefs by amending his Response Briefs.

3.

Alternatively, Mr. Huon asks that the Court modify the entire briefing schedule to
allow Mr. Huon to file amended Response Briefs not to exceed the 82 same number
of pages that the Jezebel Defendants have filed—82 pages to date.

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 December 12, 2011:

PLAINTIFF’S OBJECTION TO THE
THE JEZEBEL.COM DEFENDANTS’ MOTION FOR EXTENSION OF TIME

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