Jones Motion For Extension

FBT-CV18-6076475-S : SUPERIOR COURT
:
William Sherlach, et al : J.D. OF FAIRFIELD
:
v. : AT BRIDGEPORT
:
Alex Emric Jones, et al : MARCH 6, 2019
DEFENDANTS JONES; INFOWARS, LLC; FREE SPEECH SYSTEMS, LLC;

INFOWARS HEALTH, LLC; and PRISON PLANET TV, LLC, MOTION FOR
EXTENSION OF TIME TO COMPLY WITH DISOVERY ORDER
The undersigned requests an additional two weeks to comply with discovery
orders requiring the production of certain documents and/or a privilege log on or before
March 6, 2019. In support hereof, the undersigned represents as follows:
1. The undersigned was contacted during the week of February 25, 2019, and
asked whether he would serve as local counsel to represent the following
parties: Alex Jones; Infowars, LLC; Free Speech Systems, LLC; Infowars
Health, LLC; and, Prison Planet, LLC, in the captioned matter. The
undersigned agreed to do so and promptly filed his appearance on March 1,
2019.
2. The plaintiffs intend to seek the admission of Attorney Robert Barnes as pro
hac vice counsel. Attorney Barnes will also be seeking to appear in a related
matter pending in Texas.
3. The change is counsel was occasioned in part by this court’s denial of
admission pro hoc vice to the plaintiffs’s primary counsel of choice, Marc
Randazza. The court cited certain disciplinary matters against Attorney

Randazza as the reason for denying him the privilege of appearing pro hoc
vice.
4. Upon information and belief, the plaintiffs were unaware of certain allegations
involving Attorney Randazza’s professional ethics until they learned that he
had been denied permission to appear in Connecticut courts on their behalf.
5. Prior counsel is affiliated with Attorney Randazza.
6. The plaintiffs sought to choose new counsel untainted by the claims of
misconduct involving Mr. Randazza.
7. Upon filing his appearance, the undersigned contacted counsel for the
plaintiffs to determine the status of the various motions pending before the
court, and learned that there were significant discovery obligations pending.
8. The undersigned has spoken with prior counsel, Attorney Randazza and
Attorney Barnes about the discovery compliance in this matter.
9. Significant review of documents has already taken place, and claims of
privilege and privacy will be asserted as to many documents.
10. The undersigned does not yet have the file, and is in the process of working
with counsel to produce either documents or a privileged log.
11. The undersigned started proceedings on March 5, 2019, in a criminal case
pending in the Judicial District of Middletown, State v. Cusson, and will be
picking a jury for the balance of this week.
12. The undersigned has been given Thursday, March 7, 2019, off so that he can
attend the status conference in the captioned case.
13. Counsel for the plaintiffs opposes this motion.

14. The plaintiffs’ change of counsel is unfortunate, but understandable given the
unique facts of this case.
15. The undersigned requests until March 20, 2019, to tender compliance with
existing discovery orders.
The Defendants,
Alex Jones;
Infowars, LLC;
Free Speech Systems, LLC;
Infowars Health, LLC; and,
Prison Planet, LLC
BY:/s/ Norman A. Pattis/s/
Norman A. Pattis, Their Attorney
PATTIS & SMITH, LLC
Juris No. 423934
383 Orange Street,
New Haven, Ct 06511
V: 203-393-3017,F: 203-393-9745
npattis@pattisandsmith.com
ORDER
The foregoing Motion having been heard, it is hereby ORDERED:
GRANTED / DENIED
__________________________, J
CERTIFICATION
This is to certify and a copy of the foregoing has been emailed and/or mailed, this 6th
day of March, 2019 to:
Wolfgang Halbig-TO BE MAILED

25526 Haws Run Lane
Sorrento, FL 32776
wolfgang.halbig@comcast.net
Lawrence L. Connelli, Esq.

Regnier Taylor Curran & Eddy
100 Pearl Street, 4th Floor
Hartford, CT 06103
LConnelli@rtcelaw.com
Stephen P. Brown, Esq.

Wilson Elser Moskowitz Edelman & Dicker
1010 Washington Blvd, 8th Floor
Stamford, Ct 06901
stephen.brown@wilsonelser.com
Genesis Communications Network, Inc.

c/o Ted Anderson
190 Cobblestone Lane
Burnsville, MN 55337
t.anderson@gcnlive.com
Koskoff Koskoff & Bieder, PC

330 Fairfield Ave.
Bridgeport, CT 06604
asterling@koskoff.com
cmattei@koskoff.com
mblumenthal@koskoff.com
/s/Norman A. Pattis /s/

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FBT-CV18-6076475-S : SUPERIOR COURT

DEFENDANTS JONES; INFOWARS, LLC; FREE SPEECH SYSTEMS, LLC;

The undersigned requests an additional two weeks to comply with discovery

March 6, 2019. In support hereof, the undersigned represents as follows:

asked whether he would serve as local counsel to represent the following

undersigned agreed to do so and promptly filed his appearance on March 1,

matter pending in Texas.

3. The change is counsel was occasioned in part by this court’s denial of

Randazza. The court cited certain disciplinary matters against Attorney

involving Attorney Randazza’s professional ethics until they learned that he

had been denied permission to appear in Connecticut courts on their behalf.

5. Prior counsel is affiliated with Attorney Randazza.

6. The plaintiffs sought to choose new counsel untainted by the claims of

misconduct involving Mr. Randazza.

Attorney Barnes about the discovery compliance in this matter.

9. Significant review of documents has already taken place, and claims of

privilege and privacy will be asserted as to many documents.

with counsel to produce either documents or a privileged log.

11. The undersigned started proceedings on March 5, 2019, in a criminal case

pending in the Judicial District of Middletown, State v. Cusson, and will be

picking a jury for the balance of this week.

attend the status conference in the captioned case.

13. Counsel for the plaintiffs opposes this motion.

unique facts of this case.

existing discovery orders.

The foregoing Motion having been heard, it is hereby ORDERED:

Wolfgang Halbig-TO BE MAILED

Lawrence L. Connelli, Esq.

Stephen P. Brown, Esq.

Genesis Communications Network, Inc.

Koskoff Koskoff & Bieder, PC

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