Music Licensing Inc (SONG)

[lucky, mydog]

IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA

CASE NO. 11-2024-CA-000814-0001-XX
JAKE P. NOCH, and
MUSIC LICENSING INC.

Plaintiffs,

v.

JOHN DOE, et al.

Defendants.
__________________________________/

PLAINTIFFS’ MOTION TO COMPEL DEFENDANT’S COMPLIANCE WITH
SUBPOENA & MOTION FOR SANCTIONS
Plaintiffs, JAKE P. NOCH and MUSIC LICENSING INC. (hereinafter collectively “Mr.
Noch”) by and through their undersigned counsel, submit this Motion to Compel Defendant’s
Compliance with Subpoena to INVESTORSHUB.COM INC. (hereinafter referred to as “iHub”)
to obtain the identity of the Defendants. As such, identities of Defendant are unknow, thus iHub
are required to submit users’ account’s state drivers’ licenses, identification cards, e-mail
addresses, home addresses, phone numbers, and any other relevant information to the user
individuals included on the issued Subpoena. The following in support thereof:
Discovery Requests
1. Mr. Noch received several defamatory and threatening remarks made against them from
multiple user accounts on iHub.
2. Some of these statements were targeted towards Mr. Noch and his family.
Filing # 199895979 E-Filed 06/05/2024 01:11:04 PM
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 06/05/2024 01:11:04 PM
3. Defendants are hiding behind these iHub accounts and have repeatedly harassed Mr. Noch
by spreading false information and continuing to act threateningly.
4. Due to the non-stopping false and threatening statements, Mr. Noch hired the undersigned
counsel to commence an action to obtain the information of the owners of these accounts.
5. On May 10, 2024, the Plaintiffs issued to the Defendant their Subpoena. (Hereinafter
referred to as “Subpoena”).
6. On May 17th, 2024, Defendants’ Counsel contacted the opposing Plaintiff’s Counsel via
email and U.S. mail to object to Plaintiff's Subpoena, alleging that the users are protected
under their First Amendment. However, the First Amendment does not protect users from
illegal conduct.
WHEREFORE, the Plaintiffs respectfully request this Court to enter an Order to
compel the Defendant to respond to the Plaintiffs’ request to produce, to sanction the
Defendant with any alternative or additional relief the Court deems appropriate under the
circumstances, including attorneys’ fees and cost.

Respectfully submitted,
Transnational Matters, PLLC
BY: /s/ Davy Karkason, Esq.
Davy Karkason, Esq.
Florida Bar No.: 1031867
Attorney for Defendant
2121 Biscayne Blvd., # 1878
Miami, FL 33137
Office: [phone]
E-mail: [e-mail]
[e-mail]
[certificate of service on next page]
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 5th day of June, 2024, this Motion was
electronically transmitted to the Clerk of Court and all parties of record via the
Florida Courts E-Filing Portal (“FCEP”), and a true and correct copy of the foregoing
has been furnished by electronic mail to all counsel of record.
Respectfully submitted by,
Transnational Matters, PLLC
BY: /s/ Davy Karkason, Esq.
Davy Karkason, Esq.
Florida Bar No.: 1031867
Attorney for Defendant
2121 Biscayne Blvd., # 1878
Miami, FL 331

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