Gordon v. DreamWorks Animation SKG, Inc. et al

Filing 50

MOTION for Leave to File A REPLY MEMORANDUM OF LAW IN SUPPORT OF HIS EMERGENCY MOTION FOR A PROTECTIVE ORDER AND SANCTIONS by Jayme Gordon. (Attachments: # 1 Memo of Law in support, # 2 Martinez declaration, # 3 Exhibit A-Martinez declaration, # 4 McCallion declaration, # 5 Exhibit A-McCallion declaration, # 6 Exhibit B-McCallion declaration, # 7 Exhibit C-McCallion declaration, # 8 Exhibit D-McCallion declaration, # 9 Exhibit E-McCallion declaration, # 10 Exhibit F-McCallion declaration)(Madera, Gregory)

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
JAYME GORDON,
Plaintiff,
v.

C.A. No. 1:11-cv-10255-JLT

DREAMWORKS ANIMATION SKG, INC.,
DREAMWORKS ANIMATION LLC, and
PARAMOUNT PICTURES, CORP.,
Defendants.

PLAINTIFF JAYME GORDON’S REQUEST PURSUANT TO L.R. 7.1(b)(3) FOR
LEAVE TO FILE A REPLY MEMORANDUM OF LAW IN SUPPORT OF HIS
EMERGENCY MOTION FOR A PROTECTIVE ORDER AND SANCTIONS
Pursuant to Local Rule 7.1(b)(3), Plaintiff Jayme Gordon (“Gordon”) respectfully
requests leave to file a reply brief to Defendants’ DreamWorks Animation SKG, Inc.,
DreamWorks Animation LLC and Paramount Pictures, Corp. (“Defendants”) opposition to
Mr. Gordon’s Emergency Motion for Protective Order and Sanctions. Gordon respectfully seeks
the Court’s leave to file a reply that will address certain misstatements of law and
mischaracterizations of fact made by the Defendants in their opposition papers, and to adequately
respond to all of the Defendants’ arguments. Gordon believes that a reply will aid the court in
resolving the issues central to his emergency motion.
The undersigned certifies that on November 10, 2011, counsel for Gordon and
Defendants conferred via electronic mail in good faith regarding this reply brief. Defendants’
counsel object to such filing and reserve the right to file a sur-reply.

Gordon’s intended reply, and the supporting declarations of Mr. Martinez and
Ms. McCallion, are attached as exhibits hereto. We thank the Court for its attention to this
matter.
Respectfully submitted,
FISH & RICHARDSON P.C.
Dated: November 10, 2011

/s/ Gregory A. Madera
Gregory A. Madera, BBO #313,020
FISH & RICHARDSON P.C.
One Marina Park Drive
Boston, MA 02210-1878
[phone]
[e-mail]; [e-mail];
[e-mail]
Juanita R. Brooks, pro hac vice
FISH & RICHARDSON P.C.
12390 El Camino Real
San Diego, CA 92130
[phone]
[e-mail]
Kristen McCallion, pro hac vice
FISH & RICHARDSON P.C.
601 Lexington Avenue, 52nd Floor
New York, NY 10022
[phone]
[e-mail]
ATTORNEYS FOR PLAINTIFF
JAYME GORDON

CERTIFICATE OF SERVICE
I certify that this document(s) filed through the ECF system will be sent electronically to
the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies
will be sent to those indicated as non-registered participants on this 10th day of November, 2011.
/s/ Gregory A. Madera
Gregory A. Madera
22737880.doc

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