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Bradley J. Reeves (TX Bar No. 24068266)

Reeves Law, PLLC

702 Rio Grande Street, Suite 306

Austin, TX 78701

Telephone: 512-827-2246

brad@brtx.law

Marc J. Randazza (pro hac vice)

Jay M. Wolman (pro hac vice)

RANDAZZA LEGAL GROUP, PLLC

2764 Lake Sahara Drive, Suite 109

Las Vegas, NV 89117

Telephone: 702-420-2001

ecf@randazza.com

Attorneys for Defendants

Infowars, LLC, Free Speech Systems, LLC, 

Alex E. Jones, and Owen Shroyer

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

AUSTIN DIVISION

DR. JEROME CORSI and 

LARRY KLAYMAN,

Plaintiffs,

vs.

INFOWARS, LLC, FREE SPEECH SYSTEMS, 

LLC, ALEX E. JONES, DAVID JONES, and

OWEN SHROYER,

Defendants.

CIVIL ACTION NO. 1:20-CV-00298-LY

REQUEST FOR TELEPHONIC 

STATUS CONFERENCE

Defendants Infowars, LLC, Free Speech Systems, LLC, Alex E. Jones, and 

Owen Shroyer (“Defendants”), hereby request the Court hold a status conference

in this matter. In support hereof, Defendants state as follows:

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BACKGROUND

A. The Rule 12(b)(6) Portion of the Motion to Dismiss Remains Undecided

1. On April 8, 2019, Defendants moved to dismiss this action, originally 

filed in the U.S. District Court for the District of Columbia, Case No. 1:19-cv-00656-

TJK, pursuant to Fed. R. Civ. P. 12(b)(2), (3) & (6). That motion was fully briefed. 

See Dkt. Nos. 10, 11 & 12.

2. On March 10, 2020, the D.C. Court found that the District of Columbia 

was an improper venue and transferred the matter to this Court. See Dkt. No. 21.

3. The March 10 Order disposed of the motion pursuant to Rule 12(b)(3) 

and rendered the motion pursuant to Rule 12(b)(2) moot. However, that portion 

of the motion brought under Rule 12(b)(6), for failure to state a claim, was neither 

discussed nor adjudicated. 

B. Plaintiffs have not Entered their Appearances

4. On March 20, 2020, the case was officially transferred and the Court 

ordered counsel for the parties to move to appear pro hac vice within fourteen 

days thereof. See Dkt. Nos. 23 & 24. Thereupon, all Defendants appeared by 

local counsel and their counsel otherwise moved for and were admitted pro hac 

vice. See Dkt. Nos. 25-32.

5. To date, counsel for Plaintiffs has not appeared by local counsel or 

moved for admission pro hac vice.

C. Mr. Klayman Filed and Dismissed an Overlapping Action in the Face of 

Judicial Scrutiny

6. Separately, Plaintiff Larry Klayman, allegedly on his own behalf, but 

nonetheless referring to Dr. Corsi as a plaintiff therein, on April 8, 2020, filed a new 

suit in the U.S. District Court for the Southern District of Florida, Case No. 9:20-cv80614-RKA (“SDFL Action”), raising substantially similar claims (oft verbatim) in that 

action as in this one. See Exhibit 1, Complaint in SDFL Action.

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7. On April 14, 2020, Hon. Roy K. Altman sua sponte issued an “Order 

Requiring More Definite Statement” finding that the complaint in the SDFL Action

was “a shotgun pleading” with “problematic” and “deficient” allegations, with 

significant attention brought to the implausible Lanham Act claim. Exhibit 2, 

Order of April 14, 2020. Judge Altman invited Mr. Klayman to file an amended 

complaint to avoid dismissal.

8. Rather than amend the complaint, Mr. Klayman filed a notice of 

voluntary dismissal the following day, which was so ordered. See Exhibits 3 & 4.

ANALYSIS

Because the D.C. court did not adjudicate that portion of the motion to 

dismiss brought under Rule 12(b)(6), if this Court is so inclined, it would appear 

proper to consider it to be a live motion that could be decided on the existing 

12(b)(6) briefing. Accordingly, the defendants would appreciate a status 

conference in which to discuss this with the Court, prior to expending significant 

party and judicial resources . 

Further, Plaintiffs have not taken steps to appear in this action and at least 

Mr. Klayman filed and dismissed overlapping claims in the Florida Action, so it is 

unclear if they intend to prosecute their claims in this matter, or if it would even 

be proper to do so. Thus, it would be helpful for the parties to discuss the status of 

this case with the Court.1 

/ / /

/ / /

/ / /

1 Counsel for Defendants attempted to confer with Mr. Klayman, but the 

one-hour Mr. Klayman offered his time, Defendants’ counsel was unavailable. 

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WHEREFORE, Defendants respectfully request that the Court set this matter 

for a telephonic status conference.

Dated: May 1, 2020. Respectfully submitted,

/s/ Marc J. Randazza

Marc J. Randazza (pro hac vice)

Jay M. Wolman (pro hac vice)

RANDAZZA LEGAL GROUP, PLLC

2764 Lake Sahara Drive, Suite 109

Las Vegas, NV 89117

Bradley J. Reeves (TX Bar No. 24068266)

REEVES LAW, PLLC

702 Rio Grande Street, Suite 306

Austin, TX 78701

Attorneys for Defendants

Infowars, LLC, Free Speech Systems, LLC, 

Alex E. Jones, and Owen Shroyer

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Civil Action No.: 1:20-CV-00298-LY

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 1st day of May, 2020, a true and correct copy 

of the foregoing document is being served via Notice of Electronic Filing through 

the Court’s the CM/ECF system as well as via electronic and first-class mail, 

postage pre-paid to:

Larry E. Klayman, Esq.

Klayman Law Group, P.A.

2020 Pennsylvania Avenue, NW

Washington, DC 20006

<leklayman@gmail.com>

Respectfully Submitted,

/s/Marc J. Randazza

Marc J. Randazza

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