Filing 66555856 E-Filed 01/16/2018 09:54:03 AM

IN THE CIRCUIT COURT
OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA

DOUGLAS BERGER, et a1. Case No.: 
Division:Al
Plaintiffs, 

v. 

JOHN DOE, et al. 

Defendant. 

NOTICE OF VOLUNTARY DISMISSAL WITHOUT PREJUDICE

Pursuant to Florida Rule of Civil Procedure 1.420, Plaintiffs Douglas Berger and Meguro
Counseling Center (collectively ?P1aintiffs?) voluntarily dismisses all claims against Defendant
John Doe and Nominal/Relief Defendant Reddit Inc. without prejudice, each party bearing its
own costs and fees.

Plaintiffs? dismissal is submitted after preliminary discovery has raised questions about
the proper jurisdiction to litigate the acerbic, irrational, and highly defamatory statements which
have been published about him on the Internet. This dismissal does not re?ect in any way upon
the merits of Plaintiffs? undoubtfully legitimate claims under applicable law, his likelihood of
success upon the merits, or the compensable damages for which he will seek recovery upon his

re-?ling.

FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 01/16/2018 09:54:03 AM

Respectfully submitted,

MEYERS, ROMAN, FRIEDBERG 
LEWIS, LPA

Rick Russell 0 ?Rourke

Rick Russell O?Rourke

Florida Bar No. 0564257

Meyers, Roman, Friedberg Lewis, LPA
Eton Tower

28601 Chagrin Blvd, Suite 600
Cleveland, Ohio 44122

Phone: (216) 831~0042

Fax: (216) 831-0542

Email: Rorourke@meyersreman.com

 

Counsel for Plaintiffs

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 16th day of January 2018, a true and correct copy of

the foregoing is being electronically ?led with the Clerk of the Court using the ?ling

system. I also certify that no counsel of record or pro se parties have entered an appearance in

Rick Russell 0 ?Rourke
RICK RUSSELL