Capitol Records, LLC v. Redigi Inc.
LETTER addressed to Judge Richard J. Sullivan from C. Dennis Loomis dated October 3, 2016 re: Report on the Status of the Automatic Stay. Document filed by John Ossenmacher, Redigi Inc., Larry Rudolph.(Warshavsky, Oren)
11601 Wilshire Boulevard
Los Angeles, CA 90025-0509
October 3, 2016
C. Denni s Loom is
direct dial: 310.442.8865
cdl oomi s@bakerl aw.com
Hon. Richard J. Sullivan, U.S.D.J.
Thurgood Marshall United States Courthouse
40 Foley Square
New York, NY 100007
Capital Records, LLC v. ReDigi Inc., et al.
Case No. 12 cv. 0095 (RJS): Report on Status of Bankruptcy Automatic Stay
Dear Judge Sullivan:
Pursuant to your Order entered on August 8, 2016, on behalf of defendants and appellants
ReDigi, Inc., John Ossenmacher and Larry Rogel, aka Larry Rudolf (collectively, "Appellants")
in the above action, we submit this Report on the status of the automatic stay implemented upon
the filing of the Chapter 11 bankruptcy case filed by ReDigi, Inc. and John Ossenmacher
(collectively, the "Petitioners") on August 3, 2016 in the Southern District of Florida, Case No .
18-20809-PGH (the "Bankruptcy").
Bankruptcy counsel has filed motions in the Bankruptcy on behalf of Petitioners seeking a
turnover order requiring Appellants' predecessor law firms to deliver to Appellants the case files
necessary for Appellants to effectively prosecute the appeal. Those motions are currently
scheduled to be heard on October 18, 2016. Bankruptcy counsel is planning shortly to file a
further motion in the Bankruptcy requesting that the automatic stay be lifted to allow ReDigi to
make a motion in this Court to unseal all documents which were initially filed by ReDigi in the
District Court Action under seal, and ce11ain other documents that were filed in redacted form,
based on the fact that these materials no longer require the confidential, trade secret treatment
which existed at the time that they were initially filed under seal.
The objective of these motions is to enable Appellants to obtain complete, un-redacted copies of
all documents in the record in this case that are material to the appeal, and which are currently
being withheld by Appellants ' predecessor counsel pursuant to their assertion of the attorneys '
retaining lien. If successful, these motions will also provide the many parties who have
Wash ington, DC
October 3, 2016
contacted ReDigi seeking permission to file amicus briefs on the appeal with access to those
documents submitted to the District Court that discuss how ReDigi's patented technology
operates, which may be relevant to the arguments these amici may wish to present to the Second
As soon as the above motions have been adjudicated, and assuming that the outcome of those
motions enables Appellants' counsel to obtain access to the full record below, Petitioners will
prepare and file in the Bankruptcy a motion for relief from the automatic stay to allow the appeal
Baker & Hostetler LLP
C. Dennis Loomis
All Parties Receiving Notice via ECF
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?