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