On 7 May 13, Attorney Paul Ticen responded to Troll Goodhue/Prenda Law’s response to his motion to stay discovery on 71 Cox Communication IP addresses. Doc49_02144(AZ) Cox_Ltrs_Does_02144(AZ) Post on the Prenda Law response.
Attorney Ticen clearly points out that his six clients have standing to file the motion to stay. Previously this was pointed out to the court and Plaintiff on 25 Mar 13, in Document 44-1 (Motion to stay exhibit). Ticen goes on to show the court each of the ISP subpoena notices sent to his clients, informing them that their personal information would be released to Plaintiff.
But to demonstrate that undersigned counsel is not representing little green people harboring anti-copyright sentiments, but instead real individuals seeking Court protection to avoid being identified and harassed for settlement dollars, the remainder of the redacted letters from Cox Communication are submitted herewith.
Ticen also points out that troll Goodhue’s response should be striken for the simple reason it was filed nearly three weeks after the deadline to file expired. Sounds like classic Prenda style (my opinion) – Too Little Too Late.
Ticen tell the court that if it decides not to strike Plaintiff’s response, that it should be made aware of recent sanctions against Prenda Law (and its members) in Ingenuity 13, LLC v. John Doe, C.D. Cal., 2:12-cv-08333. Order can be found here.
Included in the order are findings of deceptive and fraudulent conduct involving Plaintiff and a referral to the United States Attorneys’ Office for the Central District of California and the IRS – Criminal Investigation Division. This order only reinforces the need for a stay at a minimum, if not an outright dismissal (sua sponte) with prejudice. Because of the findings contained in this order, the sanctions, namely, referrals to commence additional investigation/proceedings that will ultimately bear on Plaintiff and Prenda Law’s right and ability to continue prosecuting copyright infringement claims and carrying on with its coercive settlement business model, the requested remedies are well founded at this juncture. And the Movants respectfully request leave to bring a Motion for Sanctions against Plaintiff and Prenda Law for attorneys fees they have been forced to take protective measures to fight a subpoena requesting their contact information that is based on a facially implausible conspiracy theory.
Yes, he also asks permission to file sanctions against plaintiff from the court. This should be fun to watch. Please take a read and tell me what you think. *** Speaking of possible sanctions, please see the following order from another Arizona Judge directing Prenda Law to file the required corporate disclosure statement or face sanctions. Judge Bolton Order
Star Trek II: The Wrath of Khan: “Ah, Kirk, my old friend. Do you know of the old Klingon proverb that revenge is a dish best served cold? It is very cold in space.”