Doe v. SexSearch.com et al

Filing 47

Motion to continue Plaintiff's Motion for Preliminary Injunction and for Other Related Relief filed by Manic Media, Stallion.com FSC Limited, DNR. Related document(s) 26 . (Kravitz, Max)

Doe v. SexSearch.com et al

Doc. 47

Case 3:07-cv-00604-JZ

Document 47

Filed 03/19/2007

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 STALLION. COM FSC LIMITED, DNR, AND MANIC MEDIA'S MOTION FOR AN ORDER CONTINUING PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION AND FOR OTHER RELATED RELIEF Max Kravitz (0023765) Kravitz, Brown & Dortch, LLC 145 E. Rich St. Columbus, Ohio 43215 Telephone: [phone] Fax: [phone] Counsel for Specially Appearing Defendants Stallion.Com FSC Limited, DNR, and Manic Media

Dockets.Justia.com

Case 3:07-cv-00604-JZ

Document 47

Filed 03/19/2007

Page 2 of 3

Specially appearing defendants Stallion.com FSC Limited ("Stallion"), DNR, 1 and Manic Media (aka Manic Media, Inc.) seek a continuance of the hearing on Plaintiff's preliminary injunction motion and related relief. Stallion owns the web site sexsearch.com and DNR owns orgasm.com. The domains are corporate assets, and therefore lack the capacity to defend this lawsuit. Specifically, these specially appearing defendants request an order: (1) unsealing the papers Plaintiff filed in support of his ex parte application for a temporary restraining order ("TRO") and motion for a preliminary injunction; (2) ordering Plaintiff's counsel to serve those unsealed moving papers on these Defendants' counsel via email; (3) allowing these Defendants to file papers in opposition to the preliminary injunction motion at least 10 days after the moving papers are served; (4) continuing the hearing on Plaintiff's preliminary injunction motion to a date convenient to the Court and after these Defendants have had an opportunity to file its papers in opposition; and (5) extending the TRO currently in effect until the Court holds the hearing on the preliminary injunction motion. As the reasons in support of these Defendants' motion are exactly the same as the reasons put forth by Defendant Experienced Internet.com, Inc. in its motion for the same relief we respectfully, with the permission of counsel for Experienced Internet.com, Inc., incorporate herein the arguments and declarations made in their motion as if stated anew herein.

Stallion and DNR have not been properly served. Both reserve the right to challenge service, but are specially appearing here because of the extraordinary nature of status of the proceedings at this juncture.
1

Case 3:07-cv-00604-JZ

Document 47

Filed 03/19/2007

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Respectfully submitted, /s/ Max Kravitz Max Kravitz (0023765) Counsel for Stallion.com FSC Limited, DNR, and Manic Media

CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing has been electronically filed this 19th day of March, 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/ Max Kravitz