Doe v. SexSearch.com et al

Filing 125

Objection to evidence submitted by Plainitff in support his motion for a preliminary injunction filed by Experienced Internet.com, Inc.. (Milmeister, Dana)

Doe v. SexSearch.com et al

Doc. 125

Case 3:07-cv-00604-JZ

Document 125

Filed 04/15/2007

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION John Doe, Plaintiff, v. SexSearch.com, et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 3:07CV604 Hon. Jack Zouhary DEFENDANTS EXPERIENCED INTERNET.COM, INC.'S AND MAURICIO BEDOYA'S OBJECTIONS TO EVIDENCE SUBMITTED IN SUPPORT OF PLAINTIFF'S MOTION FOR A PRELIMINARY INJUNCTION Richard M. Kerger (0015864) KERGER & ASSOCIATES 33 S. Michigan Street, Suite 100 Toledo, Ohio 43604 Telephone: [phone] Fax: [phone] Gary Jay Kaufman (Pro hac vice) Dana Milmeister (Pro hac vice) The Kaufman Law Group 1925 Century Park East Suite 2350 Los Angeles, California 90067 Telephone: [phone] Fax: [phone] Counsel for Specially Appearing Defendants Experienced Internet.com, Inc., Mauricio Bedoya and Patricia Quesada

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Dockets.Justia.com

Case 3:07-cv-00604-JZ

Document 125

Filed 04/15/2007

Page 2 of 3

Specially appearing defendants Experienced Internet.com, Inc. and Mauricio Bedoya ("Defendants") hereby object to the exhibits Plaintiff submitted in support of his motion for a preliminary injunction, identified as Exhibits Exhibits 2, 6A, 6B, 8-29, 31-48, 51-58, 60-69 ("TRO Exhibits") submitted in support of Plaintiff's ex parte request for a temporary restraining order and the entire appendix of exhibits submitted in support of Plaintiff's preliminary injunction motion ("PI Exhibits"). Most of the exhibits consist of irrelevant and /or hearsay information that is inadmissible pursuant to Rules 401 et seq. and 801 et seq. of the Federal Rules of Evidence. Defendants respectfully request that the Court refuse to consider the following exhibits for the reasons listed below: TRO Exhibits 6A, 6B, 8-29, 31-48 and PI Exhibits 1-8, 10-91: Defendants object to these exhibits on the grounds that these exhibits are irrelevant to the issues to be determined at this hearing and in this lawsuit, or that, if relevant, they are confusing, prejudicial and a waste of time. Fed. R. Evid. 401, et seq. Separately, Defendants additional object on the grounds that these exhibits contain inadmissible hearsay. Fed. R. Evid. 801, et seq. Defendants reserve their rights to assert other objections at the hearings in addition to those set forth herein. Respectfully submitted, /s/ Richard M. Kerger RICHARD M. KERGER (0015864) /s/ Dana Milmeister Dana Milmeister (pro hac vice) Counsel for Specially Appearing Defendants Experienced Internet.com, Inc., Mauricio Bedoya and Patricia Quesada

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Case 3:07-cv-00604-JZ

Document 125

Filed 04/15/2007

Page 3 of 3

CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing has been electronically filed this 15t h day of April, 2007. Notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's System. /s/ Dana Milmeister

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