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Nicolettiadmission Redacted

Nicolettiadmission Redacted

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Published by J Doe
Nicolettiadmission Redacted
Nicolettiadmission Redacted

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Categories:Types, Business/Law
Published by: J Doe on Jan 04, 2014
Copyright:Attribution Non-commercial

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01/07/2014

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Case 1:13-cv-01525-SEB-MJD Document 24-6 Filed 12/09/13 Page 1 of 2 PageiD : 150
From Sent To Subject
John,
Paul
Nicoletti <pauljnicoletti@gmail.com> Thursday, September 19, 2013
: 9PM
John Bradshaw Malibu Media,
LLC
v
In
light
of
the information that you
h ~d·
my
client would like you
to
stipulate
to
the substitution
of
,
as
the Defendant.
s
you are well aware, at the time this suit was filed
your
client
who was the subscriber assigned the relevant
IP
address on the relevant date/
time
was the only individual that Plaintiff could identify
as
the alleged infringer. Consequently, Plaintiff alleged
that
was the infringer. From the information that you have provided
regarding
, however,
it
appears
as
if.
ma
y not
be
the proper defendant
in
this case and
my
cl
ient
has
no
interest
in
pursuing
an
innocent individual. Accordingly, I d like for you
to
stipulate
to
the substitution. The infringement
in
this case was committed
by
and, Plaintiff has a good faith basis for believing that
is
the most likely person to have used BitTorrent
in
the household from where the infringement emanated.
Consequent ~
is
he most likely person
to
have infringed
my
client s copyrighted works through the use
of
the BitTorrent protocol and substitution
is
therefore warranted. Please advise whether or not you will stipulate to the substitution
o
as
Defendant.
If
not,
we
will prepare
an
appropriate motion
to
amend the
me~aint
to
add
as
a defendant and, once
he
is
added,
we
will then
dismiss ·
Best Regards, Law Offices
of
Nicoletti & Associates, PLLC Paul J. Nicoletti (P-44419)

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