WPIX, Inc. et al v. IVI, Inc. et al

Filing 37

MOTION to Stay re: 35 Order on Motion for Preliminary Injunction,,,. Document filed by IVI, Inc., Todd Weaver.(Handwerker, Gavin)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK WPIX, INC., WNET.ORG, AMERICAN BROADCASTING COMPANIES, INC., DISNEY ENTERPRISES, INC., CBS BROADCASTING INC., CBS STUDIOS INC., THE CW TELEVISION STATIONS INC., NBC UNIVERSAL, INC., NBC STUDIOS, INC., UNIVERSAL NETWORK TELEVISION, LLC, TELEMUNDO NETOWRK GROUP LLC, NBC TELEMUNDO LICENSE COMPANY, OFFICE OF THE COMMISSIONER OF BASEBALL, MLB ADVANCED MEDIA, L.P., COX MEDIA GROUP, INC., FISHER BROADCASTINGSEATTLE TV, L.L.C., TWENTIETH CENTURY FOX FILM CORPORATION, FOX TELEVISION STATIONS, INC., TRIBUNE TELEVISION HOLDINGS, INC., TRIBUNE TELEVISION NORTHWEST, INC., UNIVISION TELEVISION GROUP, INC., THE UNIVISION NETWORK LIMITED PARTNERSHIP, TELEFUTURA NETWORK, WGBH EDUCATIONAL FOUNDATION, THIRTEEN, and PUBLIC BROADCASTING SERVICE, Plaintiffs, - against IVI, INC. and TODD WEAVER, Defendants. PLEASE TAKE NOTICE that upon the declarations of Stephen Graham and Ellen Bierman, Esq. and the exhibits annexed thereto, and the memorandum of law submitted in support of Defendants' motion the Defendants, ivi, Inc. and Todd Weaver, by and through their attorneys, Nissenbaum Law Group, LLC and Black Lowe & Graham, PLLC, will move this Court before the Honorable Naomi Reice Buchwald, United States District Court Judge, at the Docket No.: 10 Civ. 7415 (NRB)

NOTICE OF MOTION STAY PENDING APPEAL

FOR

(Oral Argument Requested)

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United States Courthouse for the Southern District of New York, located at 500 Pearl Street, New York, New York, where counsel may be heard for an Order: 1. Pursuant to Federal Rule of Civil Procedure 62(c), staying enforcement pending

appeal of the Court's preliminary injunction dated February 22, 2011; and, 2. Granting such other, further and different relief as to this Court seems just,

equitable and proper under the circumstances. PLEASE TAKE FURTHER NOTICE that in accordance with Local Rule 6.1(b), answering papers, if any, are to be served within fourteen (14) business days after service of these moving papers. PLEASE TAKE FURTHER NOTICE that Defendants request oral argument. Dated: March 1, 2011 Union, New Jersey NISSENBAUM LAW GROUP, LLC Attorneys for Defendants ivi, Inc. and Todd Weaver /S/ GAVIN I. HANDWERKER By: Gavin Handwerker (GIH 6191) 2400 Morris Avenue, 3rd Floor Union, New Jersey 07083 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] -and-

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Lawrence D. Graham Ellen M. Bierman Black Lowe & Graham, PLLC 701 Fifth Avenue, Suite 4800 Seattle, Washington 98104 [phone] [phone] [e-mail] [e-mail]

To:

Peter Zimroth, Esq. ARNOLD & PORTER, LLP Attorneys for Plaintiffs 399 Park Avenue New York, New York [phone] -andRobert Alan Garrett Hadrian R. Katz C. Scott Morrow ARNOLD & PORTER, LLP 555 Twelfth Street, NW Washington, D.C. 20004 [phone]

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