GEORGE HOTZ’S MOTION FOR PROTECTIVE ORDER
Now Comes Defendant George Hotz, by and through counsel, and moves this Court for Protective Order pursuant to Federal Rules of Civil Procedure Rule 26(c) and FRCP 26(b)(2)(c), seeking to protect Defendant George Hotz from Plaintiff Sony Computer Entertainment LLC‟s (“SCEA”) overbroad jurisdictional discovery requests, which are for the purpose of annoyance, embarrassment, oppression, and are an undue burden and undue expense on Defendant. Please note that this Motion is in addition to the Joint Protective Order, which is currently being drafted with Plaintiff’s counsel.

PRELIMINARY STATEMENT
Mr. Hotz is a 21-year-old individual, who resides in New Jersey and who has not consented to the jurisdiction of this Court. Despite the fact that SCEA has filed this action and represented that this matter belongs in the Northern District of California, SCEA now attempts to engage in a jurisdictional fishing expedition as a means to utilize jurisdictional discovery to achieve other ends. Although the Court has limited discovery to jurisdictional issues, SCEA has demanded overly burdensome and expensive discovery from Plaintiffs that bears little, if any, relevance to the issues at hand.
The Defendant has shown good cause for the protective order sought herein, as the discovery SCEA seeks is harassing, irrelevant, burdensome, expensive, and intrusive. In addition, the confidential information sought to be protected could cause Defendant irreparable harm if mishandled or exposed.
Mr. Hotz is not seeking to withhold information from Plaintiff. Instead, Mr. Hotz seeks only to (1) protect the information he is willingly providing by directing that the copy of his hard drive be created as-is and unaltered, and (2) relieve the undue burden and expense of appearing in this forum for a deposition where Mr. Hotz will gladly offer the same information through written deposition. Mr. Hotzhas been extremely accommodating to SCEA’s demanding requests– being responsive to questions and inquiries at all hours of the day and night, providing his personal hard drive with commercial, confidential, and valuable information so that SCEA can determine that nothing pertaining to jurisdiction resides on such drive, turning over his Playstation Computer, and remaining accessible despite the fact that he is not in the forum.
Mr. Hotz files this Motion for a Protective Order to limit the issues at hand to the matters of jurisdiction, and to limit such discovery to less burdensome means. The protection Defendant seeks would prevent irreparable harm and undue burden on Defendant, while still granting SCEA the information it seeks to discover, without any burden.

ps3hax psscene nextgenupdate... everyone should be helping this kid out... this court case means everything right now....

if sony wins this nothing can be hacked...

This case and the Blizzard vs mdy case are the 2 everyone should be watching

Blizzard is basically saying you subscribe to the game anything on your computer that has to do with it is theirs and you cant touch it or look at it......if you do we are coming after you.... its a very long court case catch up on the details i could be wrong
Basically the point of bringing it up is if blizzard wins the same thing will happen
all software vendors are going to use it to their advantage

Same thing with this... if sony wins say goodbye to hacking hardware because this case will be a weapon for others in the future

good luck geohotz

Yeah we need charlie sheen and the bear jew on the PS3 scene. The need to knock sony on their asses.

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:bro:

ps3hax psscene nextgenupdate... everyone should be helping this kid out... this court case means everything right now....

if sony wins this nothing can be hacked...

This case and the Blizzard vs mdy case are the 2 everyone should be watching

Blizzard is basically saying you subscribe to the game anything on your computer that has to do with it is theirs and you cant touch it or look at it......if you do we are coming after you.... its a very long court case catch up on the details i could be wrong
Basically the point of bringing it up is if blizzard wins the same thing will happen
all software vendors are going to use it to their advantage

Same thing with this... if sony wins say goodbye to hacking hardware because this case will be a weapon for others in the future

good luck geohotz

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its a lot to read with a lot of links to the official paperwork but its some Sony is doing some salty stuff to the courts and should be PUNISHED!!!! ... my vote is old skool witchcraft house burning (only their HQ gets burned along with their high up counselmen)

The battle continues between SCEA and GeoHot, with George Hotz petitioning the court for a protective order and accusing SCEA of false representations, here is a quote from the motion for protective order:


At the same time SkyLayer Technologies, the host’s of PSX-Scene have filed for motion to quash the subpoena, here is a quote from the court document:
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Geohot = Winning =D (<<<<Hopefully)