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.