Original PDF (RECAP archive via CourtListener) · 7 pages · filed April 8, 2026

Summary

Plaintiff’s verified motion to continue the May 18, 2026 trial date in Doe v. Bonnell (1-25-cv-20757). Asserts the case is not trial-ready because Bonnell has not been deposed (his deposition was stayed November 5, 2025 by ECF 167), multiple dispositive and discovery motions remain unresolved, a foreign deposition via letter rogatory is pending, and potential spoliation requires further motion practice. Hearing set for April 21, 2026.

Key Points

  • Trial set: two-week period beginning May 18, 2026 (ECF 23).
  • The bottleneck: Bonnell’s deposition has not occurred. His deposition was stayed November 5, 2025 (ECF 167) pending resolution of his own motion for protective order (ECF 163).
  • Other unresolved motions: Plaintiff’s motion to modify scheduling order (ECF 184), Plaintiff’s Rule 56(d) motion for discovery necessary to oppose summary judgment (ECF 216), Bonnell’s summary judgment motion (ECF 210).
  • Discovery window was short: meaningful discovery didn’t begin until the Protective Order entered September 2, 2025 (ECF 116), leaving ~3.5 months.
  • ★ Foreign deposition via letter rogatory is pending. This is almost certainly directed at Solo in the UK. The motion does not name the witness but references “a foreign deposition (via letter rogatory) remains pending” under discovery still incomplete.
  • Spoliation: “issues concerning potential spoliation require further investigation and motion practice” — ties to Bonnell’s alleged deletion of messages beginning January 21, 2025.
  • Melina Göransson to be deposed: named explicitly in the motion as a non-party witness whose deposition is part of the continuance justification.
  • Rule and standard: Fed. R. Civ. P. 16(b)(4) good-cause standard; Eleventh Circuit four-factor test (diligence, whether continuance cures, inconvenience, prejudice); Local Rule 7.6 “exceptional circumstances.”
  • Procedural: Plaintiff’s counsel conferred with defense April 2, 2026; parties did not agree. Motion verified under penalty of perjury by Joan Schlump Peters.
  • Hearing: set April 21, 2026 at 8:30 a.m., Courtroom 11-4 (ECF 228). Order (ECF 234) grants plaintiff remote telephonic appearance but counsel “will not be permitted to make any arguments” — live-argument-only hearing.

Newsletter Angles

  • The letter rogatory detail is the one that modifies the article’s thesis. “Civil process cannot reach Solo in the UK” was a slight overstatement. The more precise claim: the Hague Convention and letter rogatory process exist, but (a) they are slow enough to miss trial schedules, (b) UK authorities may or may not cooperate on a private civil intimate-image matter, (c) even a completed deposition of an anonymous actor using a false name is evidentiarily thin. The reachability routing is not a binary; it is a gradient where the reachable defendant absorbs all practical weight before the unreachable mechanism finishes running. This is a cleaner and more defensible version of the article’s structural argument.
  • The April 21 hearing is not a trial continuance hearing in dramatic terms. It is an ordinary pretrial motion hearing that happens to be the article’s timeliness hook. The piece should treat it as an anchor, not a spectacle.
  • Bonnell has not been deposed — meaning the factual basis of the case remains largely constructed from plaintiff’s pleadings, the Nov 29 admission quoted in the complaint, the Rose deposition, and Bonnell’s public posts. The article is being written during a discovery stage, not a post-verdict one.

Entities Mentioned

Concepts Mentioned

  • Reachability Routing — the letter rogatory process is the “reachability gradient” this concept page now discusses

Quotes

“This case is not trial-ready, and proceeding to trial under the current posture would be fundamentally unfair.”

“a foreign deposition (via letter rogatory) remains pending” — confirming plaintiff is attempting to reach Solo through international civil process

Notes

  • Cited authorities are standard Eleventh Circuit continuance cases (Sosa, Romero, High Soc’y Exotics, Snook, Jones). No novel legal theory.
  • The motion is procedurally routine but rich in docket-state detail; it’s the single best single document for understanding where the case actually stands as of April 2026.
  • The order granting remote appearance (ECF 234) specifying that remote counsel “will not be permitted to make any arguments” is an unusual hands-on bench posture — suggests Judge Becerra wants live, in-person advocacy at the April 21 hearing.