Hubbard v. MySpace, Inc.

Filing 16

MOTION for Sanctions Under Rule 11. Document filed by MySpace, Inc..(Mukasey, Michael)

Hubbard v. MySpace, Inc.

Doc. 16

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญx CORY HUBBARD, ) ) Plaintiff, ) ) vs. ) ) MYSPACE, INC., ) ) Defendant. ) ) ญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญญx

11-cv-00433 (LAK) ECF Case

NOTICE OF MOTION FOR SANCTIONS UNDER RULE 11 PLEASE TAKE NOTICE that, upon the accompanying memorandum of law dated March 28, 2011, and upon all prior pleadings and proceedings herein, the undersigned, attorneys for MySpace, Inc., hereby move this Court for sanctions and MySpace's attorney's fees and costs under Federal Rule of Civil Procedure 11, and for such other and further relief as the Court may deem just and proper. MySpace advised Plaintiff Cory Hubbard's counsel in writing on February 11, 2011, of its intent to seek Rule 11 sanctions if Hubbard's counsel did not withdraw Hubbard's complaint, and MySpace served its memorandum of law in draft form on Hubbard's counsel on March 4, 2011. In a memorandum of law Hubbard's counsel filed on March 17, Hubbard's counsel acknowledged MySpace's intent to seek sanctions but declined to withdraw Hubbard's amended complaint.

Dockets.Justia.com

Dated: New York, New York March 28, 2011 DEBEVOISE & PLIMPTON LLP By: /s/ Michael B. Mukasey Michael B. Mukasey [e-mail] 919 Third Avenue New York, New York 10022 [phone] Attorneys for Defendant MySpace, Inc.

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