Grow Universe Inc. d/b/a Cafe Melo v. Doe

48 Wall Street, Suite 1100 Lance A. Clarke New York, NY 10005 Managing Partner Clarke@hcllplaw.com LLP Tel: 212-729-0952 HAMILTON|CLARKE www.HCLLPLaw.com USDC SDNY DOCUMENT The Honorable Gregory H. Woods ELECTRONICALLY FILED United States District Court DOC #:___ Southern District of New York DATE FILED: 8/19/2025 _ 500 Pearl St. New York, NY 10007 MEMORANDUM ENDORSE August 15, 2025 Re: Grow Universe d/b/a Café Melo v. Doe, 25-CV-1861-GHW Objection to Third-Party Subpoena and Request for Additional Time to File Motion to Quash Dear Judge Woods: My firm was recently retained to represent an individual who was notified by Charter Communications d/b/a Spectrum (“Spectrum”) that Spectrum had received a subpoena and court order directing the release of information associated with this individual’s IP address. Because the subpoena seeks personal information, this individual wishes to remain anonymous at this time. Spectrum has advised that, absent objection, it will produce the requested information on August 15, 2025. We respectfully request Your Honor accept this letter as formal notice of the Individual’s objection to this subpoena. Further, we respectfully request that Your Honor grant the undersigned a brief extension of time, until August 29, 2025, to file a Motion to Quash the subpoena. We submit that such an extension of time is appropriate given the late hour at which the firm was retained. We thank Your Honor for your time and attention to this matter and are available should the Court require anything further. granted. The anticipated motion to quash is due no later than August 29, Any opposition is due no later than September 12, 2025. Any reply is due no later September 19, 2025. Charter Communications d/b/a Spectrum need not provide Respectfully Submitted, information that is the subject of the motion to quash until one week following the of the Court’s resolution of the motion to quash. moving individual who wishes to remain anonymous should understand that are the exception and not the rule.” See United States v. Pilcher, 950 F.3d 39 , /s/Lance Clarke (2d Cir. 2020) (per curiam). Additionally, “[t]he party moving to quash a subpoena Lance A. Clarke Esq have standing.” Swike 3 Holdings, LLC v. Doe, 337 F. Supp. 3d 246, 251 (W.D.N-Y. , ° , The Court expects that the moving individual’s papers will address the issue of tanding. ORDERED. August 19, 2025 J A One { 7 “bank SORY H. WOODS □□□ District Judge