15. The Federal Communications Commission
(FCC) is the only party able to make it illegal to use indecent wire
communications and the FCC is extremely aware of this action and has the
proposed supplemental complaint already. Without the FCC, the wire frauds permitted done would continue exactly
like they do now.
16. The Plaintiff will appeal if the FCC is
not allowed added as a party. This
supplemental brief should help the Court in realizing the bad-faith argument
was nothing but a waste of billable time and that denial of the Joinder will be
appealed the day that it is denied, in spite of this brief The motion to certify that the Plaintiff is
acting in bad-faith is asking the court to “super-deny” the motion that was
already denied or denial of the order leaving no recourse for the plaintiff but
to await the final rulings. The
Plaintiff will reserve appealing until the case is before the JURY or after the
JURY ruling. The May 20, 2010 order
stated as follows.
The only
ambiguity in the statute at issue here arises from the fact that it lists only
two applicable disabilities, but contains a provision for "when two or
more disabilities exist." The Court specifically addressed this ambiguity
in its Order dated March 1, 2010, and found it did not inure to Neeley's
benefit. Neeley offers neither factual nor legal argument that persuades the
Court now to the contrary, and reconsideration on this basis will be denied.
18. The claims Honorable Jimm Larry Hendren
dismissed due to limitations were overruled by the Supreme Court already and
were addressed as still existing in the orders on October 27, 2010 wherein
NAMEMEDIA INC and Google Inc are each mentioned facing the claim of
‘cybersquatting’ together.
|