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Assault Libel & Slander | Illinois Central
Order on Motion to Expedite
TEXT ORDER DENYING Plaintiff's 30 Motion to Expedite Consideration of Motion for Preliminary Injunction. Plaintiff seeks this Court enter an order on his 29 Motion Preliminary Injunction within four days of the filing of his Motion. D. 30 at 11. Though 28 U.S.C. Section 1657 requires the Court expedite its consideration of any action for preliminary injunctive relief, it does not authorize movants to unilaterally schedule the resolution of their motions. Defendant Reddit Inc.'s ("Reddit") filed a Motion to Dismiss (D. 31 ) attacking the likelihood of Plaintiff's success on his underlying claim. The Court finds it proper to wait until this Motion is fully briefed to address the 29 Motion for Preliminary Injunction. Thus, Plaintiff's 30 Motion is DENIED. Entered by Judge Michael M. Mihm on 07/23/2026. (SB)
Order on Motion for Leave to File
TEXT ORDER: Plaintiff filed his complaint in May 2026 against Reddit, Inc., alleging that an anonymous Reddit user posted defamatory comments about him. Plaintiff also named as a defendant "Jane Doe"--a placeholder for the anonymous user who posted the comments. He now 28 moves for leave to conduct early discovery to ascertain Doe's true identity. In general, a "party may not seek discovery from any source before the parties have conferred as required by Rule 26(f)." Fed. R. Civ. P. 26(d)(1). A party may do so, however, "when authorized by... court order." Id. In determining whether to issue such an order, "courts generally apply a 'good cause' standard." AF Holdings LLC v. Doe, No. 12-1398, 2012 WL 5928532, at *1 (C.D. Ill. Nov. 26, 2012). And as relevant here, courts have found good cause to allow early discovery to "determine the identities" of individuals involved in the suit. Ibarra v. City of Chicago, 816 F. Supp. 2d 541, 555 (N.D. Ill. 2011). Here, Plaintiff seeks leave to issue a subpoena to "Shreem Capital," who Plaintiff identifies as "the entity to which the defamatory communications were directly sent and which took adverse action based on those communications." (Doc. 28 at 6.) But that characterization is inconsistent with Plaintiff's complaint, which alleges that the defamatory Reddit post--the statement at the core of this lawsuit--was simply "viewed by numerous third parties, including... Shreem Capital dba Marriot Peoria." (Doc. 1 at 4.) It is unclear how Shreem Capital, who allegedly rescinded Plaintiff's job offer based on the Reddit post, (Doc. 28-1 at 4), would possess the identity of the Reddit user who generated the post. Plaintiff's affidavit suggests that Shreem Capital's revocation of his job offer "was based solely on communications received from Shreem Capital employees raising purported concerns about [Plaintiff's] background, professional fitness, and, critically, referencing the defamatory Reddit post." (Doc. 28-1 at 4.) But Plaintiff fails to establish any connection between the Shreem Capital employees who lodged complaints about him and the identity of the anonymous Reddit user who generated the post. Plaintiff has accordingly failed to demonstrate "good cause" for his request to subpoena this entity. His 28 motion is therefore DENIED. Plaintiff may renew his motion for leave to conduct early discovery, so long as he explains--with specificity--why a subpoena to Shreem Capital (as opposed to some other person or entity) is appropriate in light of this Order. Entered by Magistrate Judge Ronald L. Hanna on July 23, 2026. (MJS)
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