Taubman Sucks!

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TheShopsAtWillowBendSucks.com
GiffordKrassGrohSprinkleSucks.com

Act 65: We Move to Supplement the Record

Two of my websites were forced off the web by injunctions – so how is the Court of Appeals going to review those injunctions if they can't access the sites?

To address that problem, I've created a CD-ROM version of the sites, which we'd like to submit to the Appeals Court so they can familiarize themselves with the sites on which they'll be ruling. But it turns out that we can't simply mail a copy of the CD to the Court of Appeals (that would be much too easy), instead we have to go through the process of submitting a motion to the District Court asking them to allow us to "supplement the record."

And there's an additional reason that we'd like to supplement the record: In several of his decisions, Judge Zatkoff mentioned that he's reviewed the websites – and in one decision, he mentioned that he even used a search engine to judge (so to speak) for himself the extent to which my sites might be confused with Taubman's sites. But although the Judge's activities figured into his decisions, those activities have not been introduced into evidence, an omission that we'd like to correct.

(By the way, now that I'm represented by an attorney, I probably won't comment on these proceedings quite as extensively as I've done in the past. There's even a chance that I might entirely omit some of the minor legal wrangling that takes place from time to time. But I do plan to try to maintain this site and to keep it as current as I can, if for no other reason than that I have so much time invested in it that it's important to me that it continue to be useful.)

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 HENRY MISHKOFF, Magistrate Judge Komives

Defendants.

MOTION TO SUPPLEMENT RECORD ON APPEAL

Defendants hereby move the Court to supplement the record on appeal by adding the attached electronic files and by adding the printed record of the Court's own electronic search of the Internet, for the reasons explained in the accompanying memorandum.

Respectfully submitted,

Barbara Harvey (P25478)
Suite 3060
Penobscot Building
645 Griswold
Detroit, Michigan 48226
(313) 963-3570

Paul Alan Levy (DC Bar 946400)
Public Citizen Litigation Group
1600 - 20th Street, N.W.
Washington, D.C. 20009
(202) 588-1000

Attorneys for Defendants

February 8, 2002