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Case 1:12-mc-00150-RLW-AK Document 26 Filed 06/14/12 Page 1 of 3

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

MILLENNIUM TGA, INC.,





Plaintiff,



v.


JOHN DOE,


_______________________________________)


Defendant.









) No. 4:11-cv-4501]


)
) Case No.: 1:12-mc-00150-RLW-AK


)





) Judge : Hon. Robert L. Wilkins
)
) Magistrate Judge: Hon. Alan Kay
)
)
)

[Case pending in the U.S. District Court
for the Southern District of Texas,

PLAINTIFF’S MOTION FOR AN IMMEDIATE TELEPHONIC HEARING



Plaintiff’s counsel has just been informed that Comcast’s counsel contacted the Court ex

parte yesterday to advocate on pending matters in this miscellaneous action. Immediately after

the unannounced ex parte advocacy concluded, Comcast’s motion for a stay was granted and

Plaintiff’s motion to strike was denied. Plaintiff’s counsel is gravely troubled by the appearance

of yesterday’s events.

Plaintiff’s counsel respectfully requests an immediate telephonic hearing on all matters

currently pending before the Court so that it may contain the damage caused by Comcast’s ex

parte advocacy and have an equal opportunity to present its case. Plaintiff has the utmost respect

for the Court and does not believe that the Court’s relationship with Mr. Seiver would have any

impact on the Court’s decision-making process. However, as a zealous advocate for its client,

Plaintiff’s counsel can hardly allow this startling development to go unchallenged.

It bears mentioning that Comcast’s grand strategy in this miscellaneous action is to paint

Plaintiff as abusive of the legal process. To be sure, no federal court has ever come close to

ruling that a nonparty, like Comcast, has standing to raise joinder and personal jurisdiction

Case 1:12-mc-00150-RLW-AK Document 26 Filed 06/14/12 Page 2 of 3

defenses on behalf of its subscribers. Yesterday’s developments suggest that Comcast is not well

suited to cast the first stone.



DATED: June 14, 2012


Respectfully submitted,

MILLENNIUM TGA, INC.







By: /s/ Paul A. Duffy
Paul A. Duffy, Esq. (D.C. Bar Number: IL0014)
Prenda Law Inc.
161 N. Clark St., Suite 3200
Chicago, IL 60601
Telephone: (312) 880-9160
Facsimile: (312) 893-5677
E-mail: [email protected]
Counsel for the Plaintiff











2

Case 1:12-mc-00150-RLW-AK Document 26 Filed 06/14/12 Page 3 of 3

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on June 14, 2012, all counsel of record who are
deemed to have consented to electronic service are being served a true and correct copy of the
foregoing document using the Court’s CM/ECF system.



















/s/ Paul A. Duffy
PAUL A. DUFFY





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