Openmind Solutions, Inc. v. Does 1-2925

Filing 3

Ex Parte MOTION for Discovery by Openmind Solutions, Inc.. (Steele, John)

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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS OPENMIND SOLUTIONS, INC., CASE NO. 3:11-cv-00092-WDS -SCW Plaintiff Judge: Magistrate Judge: v. DOES 1 – 2925, Individually, and as Representatives of a class Defendants PLAINTIFF’S EX PARTE MOTION FOR LEAVE TO TAKE EXPEDITED DISCOVERY Plaintiff, through its undersigned counsel, hereby moves this Court ex parte for an Order granting expedited discovery. This motion is based upon the case record, attached memorandum and authorities cited therein, and the attached Affidavit of David Pfister. 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 until the class is certified: 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, OpenMind Solutions, Inc. DATED: February 2, 2011 By: JoDee Favre # 6203442 Favre Law Office, LLC 110 W. Main St. Belleville, IL 62220 618-604-0024; Fax 618-233-9377 /s/ John Steele_______________ One of its Attorneys John Steele # 6292158 Steele Hansmeier PLLC 161 N. Clark St. Suite 4700 Chicago, IL 60601 312-880-9160; Fax 312-893-5677 Lead Counsel Attorneys for Plaintiff 2

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