Judge Carter had nothing to do with this. It appears that case law requires DOJ’s motion to limit discovery regarding a motion to dismiss (MTD) must include language that allows limited discovery by Orly's plaintiffs that is only in direct support of establishing “standing” needed by plaintiffs to defeat the MTD.
Leo claims that DOJ screwed up when they specifically referenced the congressional vote to certify the electoral college vote in their motion, and mere mention of this event in support of Obama’s de facto current status as president has opened an opportunity for Orly to do discovery on whether objections were properly allowed before that vote was certified.
Leo repeatedly states in the comments that Orly's case has no hope of even surviving the MTD on Oct 5, and that it won't survive an appeal even if Carter rules for Orly's plaintiff(s). Leo only suggests that prior to that MTD hearing there is an opportunity for Orly to request Magistrate Nakazato to order limited discovery.
I think it is fairly obvious that if such a discovery request was granted by Nakazato, it would be appealed and at the least, the Oct. 5 MDT hearing would be delayed. October 5 is also the day that broad discovery for the whole trial will be ordered if the MTD is denied, and I doubt Orly will want to risk that to go on Leo's wild goose chase, intellectually stimulating though that might be.
But hey, I'm not a lawyer so your mileage may vary...