Page 1 UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
AARON GREENSPAN,
Plaintiff,
v.
RANDOM HOUSE, INC., MEZCO, INC.,
BENJAMIN MEZRICH, COLUMBIA
PICTURES INDUSTRIES, INC. a/k/a SONY
PICTURES a/k/a COLUMBIA TRISTAR
MOTION PICTURE GROUP,
Defendants.
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CIVIL ACTION
NO.: 1: 11-CV-12000-RBC
MOTION FOR LEAVE TO FILE REPLY BRIEF
Pursuant to Local Rule 7.1(B)(3), the defendant Columbia Pictures Industries, Inc.
("Columbia") requests leave of the Court to file the attached reply memorandum in further
support of its motion to dismiss the complaint of the plaintiff, Aaron Greenspan ("Greenspan").
As grounds therefore, Columbia states as follows:. As discussed in more detail in the attached proposed reply brief, Greenspan's opposition
all but ignores the movie, The Social Network, that Columbia produced and distributed
and on which any claim that Greenspan could pursue against Columbia must be based.
Indeed, Greenspan's opposition focuses almost exclusively on the book called The
Accidental Billionaires, which was written and published by the other defendants.. None of Greenspan's arguments are supported in the least by any of the factual
allegations of the complaint, nor do those allegations state a claim against Columbia for
copyright infringement, defamation, or under the Lanham Act.
1333165v1/14632-6Page 2 3. The reply brief will assist the Court in deciding the issues relevant to Columbia's motion
to dismiss.. Colombia has attached its proposed reply brief as Exhibit A.
WHEREFORE, Columbia respectfully requests that the Court grant it leave to file the
attached reply brief.
Respectfully submitted,
COLUMBIA PICTURES INDUSTRIES, INC.
By its attorneys,
/s/ Dustin F. Hecker
Dustin F. Hecker, BBO # 549171
POSTERNAK BLANKSTEIN & LUND LLP
The Prudential Tower Boylston Street
Boston, MA 02199
Telephone: (617) 973-6100
Facsimile: (617) 367-2315
Kevin T. Baine (pro hac vice)
Megan A. Hughes (pro hac vice)
WILLIAMS & CONNOLLY LLP 12th Street, N.W.
Washington, D.C. 20005
Telephone: (202) 434-5000
Facsimile: (202) 434-5029
Dated: February 2, 2012
1333165v1/14632-6Page 3 CERTIFICATE OF SERVICE
I, Dustin F. Hecker, hereby certify that this document filed through the ECF system will
be sent electronically to the registered participants as identified on the Notice of Electronic Filing
(NEF) and paper copies will be sent to those indicated as non-registered participants.
/s/ Dustin F. Hecker
Dustin F. Hecker
1333165v1/14632-6
PDF Page 1
PlainSite Cover Page
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Case 1:11-cv-12000-RBC Document 32 Filed 02/02/12 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
AARON GREENSPAN,
Plaintiff,
v.
RANDOM HOUSE, INC., MEZCO, INC.,
BENJAMIN MEZRICH, COLUMBIA
PICTURES INDUSTRIES, INC. a/k/a SONY
PICTURES a/k/a COLUMBIA TRISTAR
MOTION PICTURE GROUP,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
CIVIL ACTION
NO.: 1: 11-CV-12000-RBC
MOTION FOR LEAVE TO FILE REPLY BRIEF
Pursuant to Local Rule 7.1(B)(3), the defendant Columbia Pictures Industries, Inc.
("Columbia") requests leave of the Court to file the attached reply memorandum in further
support of its motion to dismiss the complaint of the plaintiff, Aaron Greenspan ("Greenspan").
As grounds therefore, Columbia states as follows:
1. As discussed in more detail in the attached proposed reply brief, Greenspan's opposition
all but ignores the movie, The Social Network, that Columbia produced and distributed
and on which any claim that Greenspan could pursue against Columbia must be based.
Indeed, Greenspan's opposition focuses almost exclusively on the book called The
Accidental Billionaires, which was written and published by the other defendants.
2. None of Greenspan's arguments are supported in the least by any of the factual
allegations of the complaint, nor do those allegations state a claim against Columbia for
copyright infringement, defamation, or under the Lanham Act.
1
1333165v1/14632-6
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Case 1:11-cv-12000-RBC Document 32 Filed 02/02/12 Page 2 of 3
3. The reply brief will assist the Court in deciding the issues relevant to Columbia's motion
to dismiss.
4. Colombia has attached its proposed reply brief as Exhibit A.
WHEREFORE, Columbia respectfully requests that the Court grant it leave to file the
attached reply brief.
Respectfully submitted,
COLUMBIA PICTURES INDUSTRIES, INC.
By its attorneys,
/s/ Dustin F. Hecker
Dustin F. Hecker, BBO # 549171
POSTERNAK BLANKSTEIN & LUND LLP
The Prudential Tower
800 Boylston Street
Boston, MA 02199
Telephone: (617) 973-6100
Facsimile: (617) 367-2315
Kevin T. Baine (pro hac vice)
Megan A. Hughes (pro hac vice)
WILLIAMS & CONNOLLY LLP
725 12th Street, N.W.
Washington, D.C. 20005
Telephone: (202) 434-5000
Facsimile: (202) 434-5029
Dated: February 2, 2012
2
1333165v1/14632-6
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Case 1:11-cv-12000-RBC Document 32 Filed 02/02/12 Page 3 of 3
CERTIFICATE OF SERVICE
I, Dustin F. Hecker, hereby certify that this document filed through the ECF system will
be sent electronically to the registered participants as identified on the Notice of Electronic Filing
(NEF) and paper copies will be sent to those indicated as non-registered participants.
/s/ Dustin F. Hecker
Dustin F. Hecker
3
1333165v1/14632-6
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