JOHN DOE 85’S OMNIBUS MOTION – FL Case 4:11-cv-00570, Third Degree Films Inc., v. Does 1-259

Another thanks to Raul for passing this to me.  Sorry I couldn’t get it out sooner. 

This is “JOHN DOE 85’S OMNIBUS MOTION TO SEVER AND/OR QUASH THE SUBPOENA AND/OR ISSUE A PROTECTIVE ORDER AND INCORPORATED MEMORANDUM OF LAW,” (OmnibusMotion_FL_00570) for case 4:11-cv-00570, Third Degree Films Inc., v. Does 1-259, Northern District of FL.  The Troll is Terik Hasmi, TRANSNATIONAL LAW GROUP LLC, 429 Lenox Avenue; Suite 5c13, Miami Beach, Floirda 33139.  The motion was filed by David Tamaroff, TAMAROFF & TAMAROFF, P.A.
The Alfred I. DuPont Building, 169 East Flagler Street, Suite 1633, Miami, Florida 33131.

This is a well written motion that Does can use an an example/template.  Please don’t just do a cut/paste and fire it off to the court.  Take a little time and adapt it to your case and situation. 

I really liked exhibits B & C, concerning CEG’s “monetization” service they provide.  Clearly this is not copyright protection service, just a revenue generating effort – a sleazy one. 

I did find it funny that CEG cites an “Envisional” report (Web address is at the bottom of Exhibit B).  I cited this report (in my declarations) to show that for the overwhelming majority of BitTorrent swarms, there are only 0-9 public IP addresses downloading/sharing at any one time.  Having 259 Does downloading/sharing all at once is a load of crap –  CEG and the Trolls know this. 

DirTrollDie 🙂

About DieTrollDie

I'm one of the many 'John Does' (200,000+ & growing in the US) who Copyright Trolls have threatened with a civil law suit unless they are paid off. What is a Copyright Troll? Check out the Electronic Frontier Foundation link -
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4 Responses to JOHN DOE 85’S OMNIBUS MOTION – FL Case 4:11-cv-00570, Third Degree Films Inc., v. Does 1-259

  1. Thanks for the compliment! We’re holding these copyright trolls’ feet to the fire down here in Florida. If you’ve been targeted by copyright trolls, you don’t have to go it alone. Give us a call at (305) 403-2020 to find out how we can help you protect your identity and defeat copyright trolls.

  2. Raul says:

    This case is like watching an arms race with the Does catching up and now surpassing the Trolls. First there was Daniel J. Simon’s Motion To Quash which is also some excellent legal writing. Next there was the motion that DTD did a nice job reporting about yesterday which was also Daniel J. Simon serving up a Notice Regarding the Unauthorized Practice of Law and/or Motion to Strike Pleadings and Dismiss Suit and now we Does are the beneficiaries of David Tamaroff’s excellent effort! Just goes to show what a good lawyer can do to these junk lawsuits.
    I wonder if Prenda Law, Inc., and International Law Group, LLC are having discussions about these most recent developments?

  3. Raul says:

    P.S. I am also quite pleased to see that Mr. Tamaroff is requesting oral argument on his client’s motion Unless Prenda substitutes for plaintiffs present counsel, I doubt Mr. Hashmi will show up for fear of the Judge’s wrath and, possibly, arrest.

  4. John says:

    Just realized David Tamaroff has joined the dark side.

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