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Civil Procedure – Frivolous Complaints – Pre-Filing Inquiry

By Deborah Elkins
Published: June 29, 2009

A pro se plaintiff who has sued 31 entities as defendants, alleging a variety of employment discrimination, tort and contract claims arising from defendant media and entertainment companies’ alleged theft of plaintiff’s ideas for movie plots, popular songs, magazine layouts and events surrounding the inauguration of President Barack Obama, is ordered subject to a pre-filing injunction now in the Alexandria U.S. District Court, as he faces in other federal district courts.

It is apparent that the imposition of other sanctions, such as monetary sanctions, will not provide adequate relief, given plaintiff’s history of litigation. The court concludes that a pre-filing injunction appears to be the only means to adequately protect this court’s ability to function.

Whitehead v. Paramount Pictures Corp. (Trenga, J.) No. 1:08cv792, May 26, 2009; USDC at Alexandria, Va. VLW 009-3-308, 7 pp.

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