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Case 1:10-cv-10216-NMG Document 82

Filed 10/29/11 Page 1 of 3

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
BOSTON DIVISION
JAGEX LIMITED,
PLAINTIFF,
v.
IMPULSE SOFTWARE,
ERIC SNELLMAN, and
MARK SNELLMAN
DEFENDANTS.
__________________________________

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Case No. 1:10-cv-10216

DEFENDANTS’ EMERGENCY MOTION FOR LEAVE
TO FILE AN EMERGENCY MOTION FOR SANCTIONS IN EXCESS OF TWENTY PAGES
Defendants, IMPULSE SOFTWARE, ERIC SNELLMAN and MARK SNELLMAN (hereinafter
“Defendants”), by and through their undersigned attorneys hereby submit their Emergency Motion for Leave to
File an EMERGENCY Motion in Excess of Twenty (20) Pages. The EMERGENCY motion which is in excess of
20 pages is for Sanctions Pursuant to Federal Rule of Civil Procedure 37(b), (c) and 45(c) for Plaintiff and its
attorneys’ blatant disregard of this Court’s Protective Order [Dkt. No. 60] through the filing of a sham
proceeding in the Central District of California for the sole purpose of issuing a third subpoena to PayPal under
false pretenses to obtain Defendants’ confidential documents that were previously produced in the instant
case with the designation of CONFIDENTIAL-OUTSIDE ATTORNEY’S EYES ONLY so that Plaintiff’s attorneys
could provide such confidential information to their client.
Defendants are bringing this matter to the attention of this Court as an EMERGENCY Motion because
Jagex is using the improperly obtained confidential documents to threaten Defendants’ customers, which is
resulting in immediate and irreparable harm to Defendants’ business. Plaintiff is unyielding and refuses to
cease its inappropriate actions. If Plaintiff’s conduct is allowed to continue much longer, Defendants’ business
will be completely destroyed.