UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

RICCARDO SILVA,

Plaintiff,

vs. 

MOBILE BILLBOARDS, INC., et al.

Defendants.

Case No.: 22-cv-24262-Altman/Reid

 

PLAINTIFF RICCARDO SILVA’S UNOPPOSED MOTION TO RE-OPEN CASE

Plaintiff Riccardo Silva (“Plaintiff”) hereby respectfully moves the Court for an Order reopening the case, and in support thereof, states as follows: 

1. Plaintiff filed this lawsuit on December 30, 2022. [ECF No. 1]. 

2. In the Complaint, [ECF No. 7-1], Plaintiff names five defendants: Mobile 

Billboards, Inc. (“Mobile Billboards”) and four John Doe Defendants (the “John Does”).

3. In particular, Plaintiff alleges in his Complaint that the four John Does have 

anonymously defamed him, through forums such as Twitter, Reddit, a website (the “Website”), 

and a mobile billboard. 

4. Since filing his lawsuit, Plaintiff has been working diligently to identify the 

anonymous John Does, including for purposes of service of process. See Joint Sched. Rpt. [ECF 

No. 18] (Plaintiff informing the Court that his efforts to identify the John Does are underway). As 

part of those efforts, Plaintiff has done the following to date: 

A. Subpoenaed Reddit for the identities of the owner(s) of the Reddit 

username, the publisher(s) of the Reddit posts, and the moderator(s) of the 

Reddit forum at issue in the Complaint;

B. Subpoenaed Twitter for the identity of the owner(s) of the Twitter account 

at issue in the Complaint;

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C. Subpoenaed Wix for the identity of the purchaser of the Wix-domain 

associated with the Website at issue in the Complaint;

D. Subpoenaed Verizon, which is the cell-phone service provider for at least 

one individual believed to be at the helm of the defamation campaign

against Plaintiff and the network provider for the IP address associated with 

the Website;

E. Subpoenaed several individuals believed to be involved in the defamation 

campaign against Plaintiff based on records produced by Verizon and Wix;

F. Subpoenaed a restaurant in New York City to identify the owner(s) of a 

phone number used by the individual(s) who Plaintiff believes is involved 

in the defamation campaign against him; and

G. Subpoenaed Chase Bank, N.A. to identify the owner(s) of a certain debit or 

credit card used to purchase the Wix domain name for the Website at issue 

in the Complaint.

H. Engaged a private investigator to assist in identifying the John Does.

5. In addition, Plaintiff is in the process of preparing and issuing subpoenas to several 

other individuals and companies he has learned have been in contact with the anonymous 

individuals believed to be involved in the defamation campaign against him. Those individuals 

and companies include the following:

A. Several aerial banner companies, which provide aerial billboard services, 

akin to the mobile billboard services offered by Defendant Mobile 

Billboards;

B. Another mobile-billboard company, which offers mobile-billboard services 

akin to those offered by Defendant Mobile Billboards; and

C. At least three other cell-phone service providers, who Plaintiff has learned 

are the providers for cell-phone numbers believed to be involved in the 

defamation campaign against him.

6. In short, Plaintiff is working diligently on unraveling the anonymous network out 

to falsely attack him.

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7. Indeed, Plaintiff’s efforts have thus far revealed the identities of at least two 

individuals known to be involved in—and believed to be spearheading—the defamation campaign 

against Plaintiff.

8. Plaintiff intends to name those two individuals (and possibly other individuals, 

depending on the results of his efforts described supra), and at least one company, in an amended 

complaint, which is due to the Court on or before March 29, 2023, per the Court’s Scheduling 

Order. See [ECF No. 19].

9. However, upon Defendant Mobile Billboards’ unopposed motion for extension of 

time to respond to the Complaint, the Court entered an Order administratively closing this case. 

See Paperless Order [ECF No. 22]. 

10. In the Order, the Court stated the basis for its administrative closure: “In their

Motion, the Defendants told us they have ‘been in communication with counsel for [Plaintiff] in 

an attempt to reach an agreement which would resolve the dispute without exhausting the Court’s 

valuable time and without the need for costly litigation.’” 

11. To be clear, only one Defendant—Mobile Billboards—moved for an extension of 

time to respond to the Complaint. Mobile Billboards is just one piece to what appears to be a 

much-larger puzzle in the defamation campaign waged against Plaintiff. Even if Plaintiff and 

Defendant Mobile Billboards were to resolve the claims against Defendant Mobile Billboards, “the 

dispute” continues as to the four John Doe Defendants.

12. Given the extraordinary lengths at which the John Does have attempted to 

anonymously and falsely accuse Plaintiff of criminal conduct, Plaintiff has yet been unable to serve 

the John Does with process, as explained supra, despite his diligent efforts to date.

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13. And, thus, the Court’s administrative closure of this case is prejudicial to Plaintiff’s 

efforts to identify the John Does. Indeed, on February 27, 2023, in-house counsel for Reddit wrote 

to Attorney Adam Stolz, co-counsel for Plaintiff, that it would not comply with Plaintiff’s 

subpoena, in part, because of the Court’s administrative closure. In particular, Reddit’s counsel 

stated that Reddit would not comply with the subpoena “particularly now that the case is stayed,” 

and that before it were to comply with the subpoena, “Plaintiff will need to get the S.D. Fla. Court 

to lift the stay.” 

14. Accordingly, Plaintiff respectfully requests that the Court re-open the case so that 

Plaintiff can proceed with his case against the Defendants, including the John Doe Defendants, 

pursuant to the Court’s Scheduling Order. 

15. Plaintiff has conferred with Defendant Mobile Billboards, which does not oppose

the relief sought through this Motion and asks that it have, as it requested, until April 14, 2023 to 

file its answer to Plaintiff’s complaint. 

WHEREFORE, Plaintiff Riccardo Silva respectfully requests that this Court enter an Order 

re-opening the case, setting the April 14, 2023 deadline for Defendant Mobile Billboards to answer 

Plaintiff’s Complaint, and for such further relief as this Court deems equitable, just, and proper.

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Dated: February 28, 2023 Respectfully submitted,

By: /s/ Joshua M. Mandel 

GREENBERG TRAURIG, P.A.

333 S.E. 2nd Avenue, Suite 4400 

Miami, Florida 33131 

Telephone: (305) 579-0570 

Facsimile: (305) 961-5702 

THOMAS R. HEISLER

Florida Bar No. 1029852 

heislert@gtlaw.com 

BENJAMIN GREENBERG

Florida Bar No. 192732 

greenbergb@gtlaw.com 

JOSHUA M. MANDEL

Florida Bar No. 1031396 

mandelj@gtlaw.com

cruzm@gtlaw.com

fernandezf@gtlaw.com

FLService@gtlaw.com 

Counsel for Plaintiff Riccardo Silva

LASH GOLDBERG LLP

100 SE 2nd Street, Ste. 1200 

Miami, Florida 33131 

Telephone: (305) 347-4040 

Facsimile: (305) 347-4050 

ADAM J. STOLZ

Florida Bar No. 1011946 

astolz@lashgoldberg.com 

Co-Counsel for Plaintiff Riccardo Silva

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CERTIFICATE OF SERVICE

I hereby certify that on this 28th day of February, 2023, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document 

is being served this day on all counsel of record via transmission of Notices of Electronic Filing 

generated by CM/ECF. 

/s/ Joshua M. Mandel 

 JOSHUA M. MANDEL

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