19.       When the court denies the motion to join, the Plaintiff will enter a motion seeking to file a supplemental complaint supported by Federal Rules of CP Rule 15(d) and made mandatory by Federal Rules of CP Rule 19(a)(2)(A). The Plaintiff will not appeal anything but refusal to allow adding the FCC until the final order but asks the Court to deny the Defendant Motion to Certify that the Plaintiff is proceeding in bad-faith or at least not do it as another sanction. The Plaintiff would like a simple common language explanation of the claims remaining since the Supreme Court ruling of May 24, 2010 of Lewis v Chicago, (08-974) overruled the previous limitations rulings.  It is difficult to litigate when there is no precise list of claims to prosecute.  The Proposed Supplemental Complaint is, in fact, the listing of claims and parties the Plaintiff feels are still warranted.  These are the claims the Plaintiff will present to the JURY next year. The Plaintiff will not enter a reply to the objection filed in Docket 200. A reply would be a reply to a reply and would be a surreply that is not permitted. This supplemental brief in opposition to a motion contains the relevant information and Plaintiff will file motions only when necessary as described herein.

20.       Plaintiff asks Honorable Jimm Larry Hendren now to recognize that Microsoft Corporation, Yahoo Inc, and IAC/InterActiveCorp have already ceased returning nudes as a result of searches for “Curtis Neeley” image searches and Google Inc ceased displaying Michael Peven’s erect penis for searches for “Curtis Neeley” on October 2, 2010 but has numerous nudes in the strict safe search shown to kids while in school; including the Plaintiff’s children.  Results are beginning to occur as a result of this litigation while Honorable  Erin L Setser has been asked to contemplate ordering Google Inc to do what the other three search engine parties have done before being ordered. The other search engines already realize that ceasing to show nudes as a result of searches for only the Plaintiffs personal name was simply mitigating damages. Only the FCC can force everyone immediately and therefore must be added per Federal Rules of CP Rule 19(a)(2)(A) using the common meanings of language.  Refusal to add them will only be appealed if the alternative request of beginning another trial is not granted.  The Eighth Circuit will grant IFP status regardless of malicious certification due to the certification being on its face improper.

 

Respectfully submitted by hand,

 

Curtis J. Neeley Jr., MFA