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Act 32: I Appeal the Injunction

One of the main reasons I created this website was in the hope that people might contact me to offer advice, which has happened beyond my wildest expectations. One of my correspondents (an inventor/activist by the name of Ronald J. Riley) suggested that I get in touch with an attorney named Paul Levy, who specializes in Internet-related free-speech issues for the Litigation Group of Public Citizen, which describes itself as a "National Non-Profit Public Interest Organization." Paul appears to be very interested in the case – and although he hasn't offered to represent me, he has offered me some timely and greatly appreciated advice.

One thing that Paul noticed was that the 30-day limit on appealing the preliminary injunction against my ShopsAtWillowBend.com website was about to expire. He suggested that I file a notice of appeal, just to keep my options open. So I did a little research on the Court of Appeals website and found that they had a form online, all I had to do was fill in the blanks and mail it to the court (with a check for $100). Since there didn't seem to be any downside to it (other than the $100, that is), I went ahead and submitted the following notice on November 9, 2001.


United States District Court for the
Eastern District of Michigan

THE TAUBMAN COMPANY LIMITED  
PARTNERSHIP, a Delaware limited partnership,  
 
Plaintiff,  
vs. CASE NO. 01-72987
 
WEBFEATS, a Texas company,  
and HENRY MISHKOFF, an individual,  
 
Defendants.  

NOTICE OF APPEAL

Notice is hereby given that WEBFEATS and HENRY MISHKOFF hereby appeal to the United States Court of Appeals for the Sixth Circuit from the "Order Granting Preliminary Injunction" entered in this action on the 11th day of October, 2001.

Henry Mishkoff
2661 Midway Road, #224-225
Carrollton, TX 75006

Dated: November 9, 2001


Note: A few days after I filed the notice of appeal, Paul Levy agreed to represent me, pro bono (for free) – but only on the appeal. He's been very helpful in offering advice on the "main" portion of the case (in the District Court), in an unofficial, "behind-the-scenes" capacity. But in the appeals process, Paul will be my official legal representative. From what I understand, as you get into higher courts, the process gets increasingly technical, and the patience of the judges gets increasingly short, so it'll be nice having someone on my side who actually knows what he's doing. And since Paul has argued cases before the U.S. Supreme Court, I don't think that he'll have any problem figuring out how to shepherd the process through the Court of Appeals.

Next: I Challenge the Court's Jurisdiction

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©2001 Hank Mishkoff
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