ase 2:12-cv-08333-ODW-JC Document 29 Filed 12/21/12 Page1of2 Page ID #:33

Morgan E. Pietz (SBN 260629)
THE PIETZ LAW FIRM

3770 Highland Ave., Ste. 206
Manhattan Beach, CA 90266
mpietz@pietzlawfirm.com
Telephone: (310) 424-5557
Facsimile: (310) 546-5301

Attorney for Putative John Doe in 2:12-cv-08333-ODW-JCx
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA

INGENUITY 13, LLC, a Limited Liability

Company Organized Under the Laws of the

Federation of Saint Kitts and Nevis,
Plaintiff,
V.
JOHN DOE,

Defendant.

ic

Case Number(s): 2:12-cv-08333-ODW-JCx

Assigned to: Judge Otis D Wright, II
Referred to: Magistrate Judge Jacqueline
Chooljian

PUTATIVE JOHN DOE’S REQUEST
FOR LEAVE TO FILE A REPLY

PUTATIVE JOHN DOE’S REQUEST FOR LEAVE TO FILE A REPLY

ase 2:12-cv-08333-ODW-JC Document 29 Filed 12/21/12 Page2of2 Page ID #:33

REQUEST FOR LEAVE TO FILE A REPLY
TO THE HONORABLE COURT, ALL PARTIES, AND THEIR COUNSEL

PLEASE TAKE NOTICE that the putative Putative John Doe in 2:12-cv-08333-
ODW-JCx (“Movant”), by and through counsel, hereby requests leave of Court to file a
reply in support of Putative John Doe’s Ex Parte Application for Leave to Take Early
Discovery and for a Further Stay of the Subpoena Return Date (ECF No. 23) (the
“Application’’).

The issue which necessitated the filing of the Application on an ex parte basis
(namely obtaining a further stay of the ISP subpoena response deadline, which had been set
for December 28, 2012) has been mooted by Judge Wright’s minute order, issued earlier
today, (ECF No. 28) quashing the outstanding ISP subpoena.

The remaining issue in the Application, which has not been mooted by Judge
Wright’s minute order, is whether Movant should be allowed to conduct certain limited
written discovery, prior to a 26(f) conference, relating to Alan Cooper. Since there is now
no exigent circumstance requiring an immediate answer on the Application, and in order to
address a number of points raised in plaintiff’s opposition to the Application (ECF No. 27),
Movant now respectfully requests leave to file a reply in support of the Application, by
Friday January 4, 2012, or such other date as the Court may order.

Respectfully submitted,
DATED: December 21, 2012 THE PIETZ LAW FIRM

/s/ Morgan E. Pietz

Morgan E. Pietz

THE PIETZ LAW FIRM
Attorney for Putative John Doe(s)
Appearing on Caption

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PUTATIVE JOHN DOE’S REQUEST FOR LEAVE TO FILE A REPLY