6:14-cv-00812-MC 

Page 1 

Unopposed Motion to Correct Pro Hac Admission of Morgan PIETZ 

David H. Madden 

Mersenne Law LLP

9600 S.W. Oak Street 

Suite 500 

Tigard, Oregon 97223 

(503)679-1671 

dhm@mersenne.com 

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

EUGENE DIVISION

VOLTAGE PICTURES LLC, a California 

limited-liability company, 

Plaintiff, 

v.

DOEs 1–50, 

Defendants 

Civil Action No.: ............ 6:14-cv-00812-MC

 .......................... related 6:14-cv-00816-MC

UNOPPOSED MOTION TO CORRECT 

PRO HAC ADMISSION OF MORGAN 

PIETZ 

ON 21 May 2014, the undersigned moved to admit California attorney Morgan PIETZ 

pro hac vice in this matter to represent “certain DOEs 1-50.” The proposed order also 

referenced “certain anonymous John Does in the above-captioned matter.” However, 

an entry on the Court’s Application for Special Admission form stated that Mr. PIETZ 

would represent “DOES 1-50.” This statement was in error. 

 Mr. PIETZ and the undersigned represent a total of seven (7) unnamed, 

unidentified and unserved DOE defendants in the present action and related action 

Case 6:14-cv-00812-MC Document 11 Filed 05/29/14 Page 1 of 3 Page ID#: 212
6:14-cv-00812-MC 

Page 2 

Unopposed Motion to Correct Pro Hac Admission of Morgan PIETZ 

6:14-cv-00816-MC. In prior filings, and for reasons explained in the Motions to Quash 

submitted in the Oregon state court cases (copies included in the PACER docket at doc. 

#1, Exhibit #2), counsel have referred to the DOEs they represent by the initials A–G, 

rather than by Plaintiff’s DOE numbers or IP addresses. These defendants were 

dismissed via the Court’s Order on 21 May 2014. 

 This Motion is submitted to notify the Court that neither Mr. PIETZ nor the 

undersigned represent DOE #1 in either action. Any understanding to the contrary is 

incorrect, and counsel regret that their filings may have allowed this mistake to enter 

the record. 

 Counsel are prepared to identify their clients for the Court by filing, under seal, 

the DOE defendants’ names, addresses, and copies of the Internet Service Provider 

letters by which these individuals became aware of these proceedings. However, for 

reasons previously described, and as will be argued in further detail in planned 

oppositions to Plaintiff’s Motion to Remand (doc. #9)1, the DOEs identities should not 

be made public at the present stage of these proceedings. 

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1

 Although PIETZ and MADDEN’s clients were dismissed by the Court’s May 21st Order, Plaintiff’s Motion 

to Remand also has the practical effect of a motion to reconsider the dismissal. If, as Plaintiff argues in its 

Motion to Remand, this Court lacks jurisdiction over Plaintiff’s claims, then a grant of remand would call 

into question the propriety of the May 21st dismissal of DOEs beyond DOE #1. Thus, the “dismissed” 

DOEs would once again be placed in jeopardy in the state court action, and would have been deprived of 

their opportunity to argue here in favor of Federal jurisdiction of the action and preemption of Plaintiff’s 

claims by the Copyright Act. 

Case 6:14-cv-00812-MC Document 11 Filed 05/29/14 Page 2 of 3 Page ID#: 213
6:14-cv-00812-MC 

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Unopposed Motion to Correct Pro Hac Admission of Morgan PIETZ 

Respectfully submitted, 

29 May 2014 

Date David H. Madden, SBN OR080396 

Attorney for DOEs A–G (not DOE #1)

Mersenne Law LLP

9600 S.W. Oak Street 

Suite 500 

Tigard, Oregon 97223 

dhm@mersenne.com 

(503)679-1671

Case 6:14-cv-00812-MC Document 11 Filed 05/29/14 Page 3 of 3 Page ID#: 214