?Iebpsac? o. INTHE FOR DAVIDSON PH LI. 23: KNIGHT, an individaal; CLERK AND 1293 LLC, A i Plaintiffs, v. Ca?seNo. FACEBOOK, 1N0, AND JANE DOES or individua?s) who eetiss administrato?s) of the Faeebixikpage ?Families Against MikeliKnight and felseia?n?d defamatory statements were made?and whose identity is-unknown?xte the'Plainti?? at this-time biit Who Will be added by amendmentwhea ascertained. -) Defendants. PETITION FOR FREE-LITIGATION DISCOVERY Thisis an actien for pie-litigatien?discevery arising under the inherent powers of this Court and concerns peteritial Claims?fer.Ilibel and false light invasion ?of privacy against Defendant Doe(s). PARTIES 1. Pleiniiffleson Cross ?a/kfa Mikel Knight is a citizen and.resident of Mt. Juliet, WiisoiiK'Coniityg'fennessec, Plaintiff 1203 Entertainment, LLC is a limited liability under'the laws of the Statexof' Tennessee with of business ?at 14:19 Lebanon Road; Snite B, Old Hickory, Davidson County; Tennessee. Plaintiff?1203 Entertainment, LLC is in the business of managing and promoting, various artists including Plaintiff Cioss. Copy Uponinformation and belief, DefendantFacebook, lite. (hereinafter ?Fh'aeebookij is a corporation formed under the laws of the.State of Delaware with aprieeiple place of btisi?ne?s?sat l60?l Wi110w_Road,_ Mateo County, California. Upon information and belief, Facebook?sregistered agent is Corporation Services Company, which can be found at 2110 Gateway Oaks Drive, Suite 95833. 5. Upon infermation and belief Defendants .lcihn and/er Jane Doe 1-10 (hereafter ?fDefendant are one or more?unkno?wn individuals, organizations, biasin'ess, and/or entities of unkno'wn.f0nn that created, author, organize, Operate, and/or. managethe Faeebook page ?Families Against Mikel Knight and the (herea?er ?the Faeebookpage?). The identities and'residencesof Defendant are unknown to Plaintiffs. JURISDICTION 6. Venne and. jurisdiction are proper pursuant to 204-101(3) and 2042-1223(3) as the Defendants are causing ?tortions injury to the {Plaintiffs by pt?rblishinglibelous statements for view inTennesseethereby giving rise toga cause ofaetion for, libel and orfalse light invasion of privacy. '-if"1 iCopy STATEMENT OF FACT 7 Defendant Doe(s) manage aed operate the Facet)er page. Defendant Dee(s) have organized theFacebeek page'sea's 10 ensm?e their perseii?al infeme?iee is; hidd?ee through the we ef?Feceboek and/er privacy (eels; Defendant identities and other yelevam personal information is not viewable to individuals or entities that are netxa partief the Faceboek?page, Defendant Dee(s) have posted and matinee te?post falseenii defemaiery statements against Plaintiffs. Thezfalse'and defamatery statements made by Defendant include, beiiarezriet limited t0, the following: a. ?Don?t be caughi in his scAm [sic] and surely don?t suppogt this member Mikel Knight?- (June 2, 2015) b. ?Don?t'weny about his YouTube Views. People like?te see what the devil looks likeand heican havelefbillion viewsand no one will eve: hey a?ticket for his fake shows er?his muSie eartheifgom?flune 2015?) e. ?The devil and his: organize?ee?is only worried: about his bleed? money music video premier. #Seten? d. ?Mikel Knight is such a eewas?d he we??t even ?put himself in?the .??ent "anymofe. He is scared. A good video to Show his illegal ,aet?ivity'w?h Resales tam: permit sales.? (May 30, 2015) e. ?Rebemm? helping Mikel Knighi' with his EhhMaee slaveeperatien?? (May '27, 20,15.) Copy 10.. ll 13. ?If?yeu some acrossa Mikel KhighiVan eaveyour money. Buy yourself or family something don?t;supportthiserookt? (May 23, 2015) g. ?leeks like he was gieing SafeLI-faVen pennies to save faceand pocketing. the rest ef the money. He?says he?sgotng to?nd anether charity tense for his SLAVE LABORSCAM {May 15,2015) .. Plaintiffs expect to be parties to an aeticin against Defendant? D0e(s') as Soon as their residenciesefe?discovemd; Presently, ciaims {31' among against Defendant 006(5) because Plaintiffs are unable to Heten?nine the {me identities and/er?reSidencieS of Defendant Doe(s) without the dEscoyery {equested in this?actien; DefendanijDee?fszfalse and?defmatory statements have, and" will Continue, to cause ?i'rre'parahle ham touthe reputation and business of?Plaintiffs until removed from the .Plaintiffs havemade attempts to dimmer-the name(s) "and'other?relevant personal information {if Defendant Doe("s) by leaking at the Facebook page) online and searching varieusjnternet sources for infomatien regarding Defendant f?taintiffs attemptedte eliminate the need to makea? claim 0r action by Sending a? Cease and de'sisfletter to. Faeebeok on June 5, 201 5 asking ,VFaeebook to remove the Facebeok page (cepy 0f cease to hereto and ineorpOratednherein 335 Exhibit ?0 weave a?res?ponse from Faeebpok in regard to thercease and desist lettert Copy 14. 15 16. .aCCurately :identifying and/or serving Defendant D0e(s). On information and belief, Faeebodk Acdllects and maintains information abeut asersfadministrators of pages on the website and has identifying information about usersinc'luding names, e-mailvaddress?esi Internet Protoeol addresses, and dates and times of access to the Faeebook page. Facebook,'therefore, likely has suf?cient information in its records to identify and provide other relevant personal informationregardingDefendant Doe(s) based Upon their Facebdok . Plaintiffs expect to?obtain, information from Faeebookgwhich Will assist in more Plaintiffs request ?penniSSiOn to initiate disCOvei?y; including, but not'limited to, issuing a 'snb?poena to? Faeebook forthe information needed?to identify and-provide other?relevant personal, information regarding Plaintiffs intend to amend their Complaint upon" receiving the alimelmentiened informationregarding Defendant D0e(s). PRAYER FOR RELIEF WHEREFOREyPlaintiffs respectfully request as-JUdgment against Defendants: I. An order allowing Plaintiffs to take allsuch action?as is entain?the relevant personal inforniation of Defendant Doe(S)' including, bUt not limited to, issuing a subpoena?to Defendant Facebook; A temporary andpermanent injunction enjoining Defendant acebookfreni further repnnlie?ation of DefEndant Duets) libelous statements via the Facebonk'page at issue; Copy 3, Cami asyallowed by lamand a?omey?g?fees; grid 4, EFQr?aray and all such?thher relief that this Honorable Court deems RespecthIIy--submitted,, TODD G. COLE, BPR NO. 31078 Plaint?c? ColexxLaw Group 750 Old Hi?ckofy Boulevard Building Suite: 202 Brentwood, Tennesscre 37027 Phone: (615) 4906020 Fax: (615) 942?59l4