Huong Hoang, the actress suing the Internet Movie Database for revealing her age, is scheduled to bring her claims before a jury in a federal courtroom in Seattle beginning April 8.
According to her pretrial statement, she won't be alone in attempting to hold the Amazon.com affiliate liable for costing her jobs in Hollywood. Hoang's lawyers want to bring nine other actors and actresses onto the witness stand to testify about their own efforts to get IMDb to remove birth dates.
In total, Hoang plans 19 witnesses and 400 trial exhibits, which has caused Amazon's lawyers to strongly object to a "straightforward" one-to-two day trial potentially getting out of hand.
The actors on Hoang's witness list are Jason Cermak, Camille Solari, Stacey Newsome, Joan McCall, Jill Virnig, Mark Anthony Nacarato, Mitchell Fink, Micah Ballinger and Scott Cohen.
Hoang will also testify and among the things she will likely talk about is how she was initially cast in the film, Consequences, before the casting director rejected her as being too old. She says that IMDb's revelation of her age has caused her to see a therapist and that she suffers from anxiety and sleep loss.
The lawsuit also seeks to present the picture of IMDb getting actors to submit certain credit information and then using the website PrivateEye.com for the purposes of adding or correcting to its database. Hoang's documents also assert that IMDb has been involved in 10 to 15 legal disputes in the last few years relating to it displaying performers' ages.
Among the other planned witnesses are Joe Kolkowitz at Player's Talent Agency, a records custodian at SAG-AFTRA, and various employees at IMDB/Amazon.
The defendant thinks this is all too much, saying that Hoang has "not provided any justification to extend the length of trial which is a virtual certainty if she is permitted to call 19 witnesses and offer over 400 trial exhibits."
Amazon/IMDb also says that in the interest of fairness, if Hoang is permitted to call that many witnesses, next month's trial date should be stricken and discovery reopened. "Hoang's last minute effort to expand the scope and length of the trial is neither harmless nor substantially justified," the company's lawyers told the judge on Thursday.
Hoang's pretrial statement is presented, which also lays out the issues that the actress believes should be determined at trial.
Among them: Is IMDb's Subscriber Agreement legally binding contract between IMDb and Hoang? Is the Privacy Notice incorporated into the Subscriber Agreement? Is a limitation of liability clause so unconscionable and one-sided to be rendered unenforceable? Should the Court require IMDb to remove Hoang's birth date as well as the birth dates of other individuals at their request? Should treble damages be awarded to her under Washington's Consumer Protection Act?
IMDb has its own defenses, including that Hoang bears responsibility over alleged deceptions she made about her age.
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