Openmind Solutions, Inc. v. Does 1-2925

Filing 3

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

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.

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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 [phone]
[e-mail]

/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 [phone]
[e-mail]
Lead Counsel
Attorneys for Plaintiff

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