First Time Videos, LLC v. Does 1-76

Filing 5

MOTION by Plaintiff First Time Videos, LLC to expedite discovery (Attachments: # 1 Memorandum of Law in Support of Plaintiff's Motion for Leave to take Discovery, # 2 Declaration of Peter Hansmeier)(Steele, John)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

CASE NO. 11-cv-3831

FIRST TIME VIDEOS, LLC,

Judge: Hon. John F. Grady

Plaintiff

Magistrate Judge: Hon. Michael T. Mason

v.
DOES 1 - 76,

Defendants

PLAINTIFF’S EX PARTE MOTION FOR LEAVE
TO TAKE DISCOVERY PRIOR TO THE RULE 26(f) CONFERENCE
Plaintiff, through its undersigned counsel, hereby moves this Court ex parte for an Order
granting limited discovery prior to the Rule 26(f) Conference. This motion is based upon the
case record, attached memorandum and authorities cited therein, and the attached Declaration of
Peter Hansmeier. Plaintiff seeks to issue subpoenas pursuant to Fed. R. Civ. P. 45 limited to the
following categories of entities and information:
From Internet Service Providers (ISPs) identified in the Exhibit A attached to the
Complaint and any other entity identified as a provider of Internet services to one of the
Doe Defendants in response to a subpoena or as a result of ongoing BitTorrent activity
monitoring: information sufficient to identify each Defendant, including name, current
(and permanent) address, telephone number, e-mail address, and Media Access Control
address.
Any information disclosed to the Plaintiff in response to a Rule 45 subpoena will be used
by the Plaintiff solely for the purpose of protecting Plaintiff’s rights as set forth in its Complaint.
1

For all the reasons articulated in the attached memorandum, Plaintiff respectfully asks the
Court to grant this motion and enter an Order substantially in the form of the attached Proposed
Order.
Respectfully submitted,
First Time Videos, LLC
DATED: June 6, 2011
By:

2

/s/ John Steele_______________
John Steele (Bar No. 6292158)
Steele Hansmeier PLLC
161 N. Clark St., Suite 4700
Chicago, IL 60601
312-880-9160; Fax [phone]
[e-mail]
Attorney for Plaintiff