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Act 47: I Move for a Stay

Paul Levy, the Public Citizen attorney who's representing me on my appeals, suggested that I should move for a stay of the new injunction pending its appeal (which means that I'm asking Judge Zatkoff to "suspend" his injunction while my appeal is in progress). Although I get the feeling that the judge is unlikely to grant this motion, it seems to be a formality to submit the request to the judge who issued the injunction before submitting the same request to the Court of Appeals.

I was on vacation at the time, so Paul submitted this motion in my name on December 12, 2001.

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

THE TAUBMAN COMPANY )

LIMITED PARTNERSHIP, )

)

Plaintiff, )

) Civil Action No. 01-72987

v. )

) District Judge Zatkoff

WEBFEATS AND ) Magistrate Judge Komives

HENRY MISHKOFF, )

)

Defendants. )

MOTION FOR STAY PENDING APPEAL

Defendants move the Court to issue a stay pending appeal of its preliminary injunction, barring the defendants "from using the websites on the Internet with the following domain names" and ordering them "to remove the websites with the following domain names," on the ground that the injunction constitutes a prior restraint issued without personal jurisdiction.

On December 10, 2001, defendant Mishkoff telephoned plaintiff's counsel Julie Greenberg to request her consent to this motion; when she was unavailable to take the call, Mishkoff left her a voicemail message. This telephone call has not been returned. Given the urgency and the fact that a stay is being sought from a prior restraint, this motion is being filed immediately rather than waiting longer for a returned telephone call.

Respectfully submitted,

Henry Mishkoff
WebFeats
2661 Midway Road, #224-225
Carrollton, Texas 75006
(972)931-5421
Pro se

December 12, 2001