Righthaven LLC v. Pantheon Promotions, Inc. et al

Filing 10

MOTION to Withdraw as Attorney by Plaintiff Righthaven LLC. (Attachments: # 1 Exhibit Notice of Withdrawal of Appearance, # 2 Proposed Order (PDF Only))(Ganim, Steven)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No.: 1:11-cv-00553-JLK
RIGHTHAVEN LLC, a Nevada limited-liability company,
Plaintiff,
v.
PANTHEON PROMOTIONS, INC., a Texas corporation; and
NATHANIEL BACON, an individual,
Defendant.

MOTION TO WITHDRAW AS COUNSEL

STEVEN G. GANIM, Esq. respectfully moves this Court for an Order permitting Steven
G. Ganim (“Mr. Ganim”), who has appeared in these proceedings, to withdraw as counsel for
Righthaven LLC (“Righthaven”), in the above-styled matter, pursuant to D.C.COLO.LCivR 83.3
(D) and Rule 1.16 of the Colorado Rules of Professional Conduct. In support thereof, the
undersigned states as follows:
1.

Mr. Ganim is no longer employed by Righthaven, due to recently being laid off.

2.

Pursuant to Rule 1.16(a)(3) of the Colorado Rules of Professional Conduct, a

lawyer is required to withdraw from the representation of a client if the lawyer is discharged.
3.

Mr. Ganim has complied with the notification requirements of D.C.COLO.LCivR

83.3 (D). Please see the Notice of Withdraw of Appearance, attached hereto as Exhibit “1”.
Service of the Notice of Withdraw was not effectuated upon the defendants in the matter, as the
defendants have not been served or otherwise appeared, and the undersigned does not have any
means of communicating with defendants.

4.

No party will be prejudiced or otherwise affected by Mr. Ganim’s withdrawal, as

Righthaven is currently represented by other counsel.
5.

The relief requested in this Motion is sought in good faith and not for the

purposes of delay.

RULE 7.1(A) CERTIFICATION
Mr. Ganim has been unable to confer with any of the defendant in this matter, as none of
the defendants have been served or otherwise appeared, and the undersigned does not have any
means of communicating the defendants.
WHEREFORE, the undersigned counsel respectfully requests to withdraw from
representing Righthaven in the instant matter.

Dated this 8th day of September, 2011.
By: /s/ Steven G. Ganim
STEVEN G. GANIM, ESQ.
Post Office Box 230812
Las Vegas, Nevada 89105
Tel: [phone]
[e-mail]

CERTIFICATE OF SERVICE
Pursuant to Federal Rule of Civil Procedure 5(b), I hereby certify that on this 8th day of
September, 2011, I caused a copy of the MOTION TO WITHDRAW AS COUNSEL to be
served via the Court’s CM/ECF system, as well as depositing a copy of the foregoing in the
United States Mail to the following persons:
Righthaven LLC
4475 South Pecos Road
Las Vegas, Nevada 89121

/s/ Steven G. Ganim