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/