Righthaven LLC v. BuzzFeed, Inc. et al

Filing 19

MOTION to Withdraw as Attorney by Plaintiff Righthaven LLC, Counter Defendant 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-00811-JLK
RIGHTHAVEN LLC, a Nevada limited-liability company,
Plaintiff,
v.
BUZZFEED, INC., a Delaware corporation;
JONAH PERETTI, an individual; and
GAVON LAESSIG, an individual,
Defendants.

UNOPPOSED 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”.
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 conferred with Kathryn Barrett, Esq., counsel for defendants in this matter,
concerning the relief requested herein. Defendants do not oppose this Motion.
WHEREFORE, the undersigned counsel respectfully requests to withdraw from
representing Righthaven in the instant matter.

Dated this 11th 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 11th 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:
Kathryn Reed Debord, Esq.
Peter John Korneffel, Jr., Esq.
Kathryn Barrett, Esq.
Brownstein Hyatt Farber Schreck LLP
410 17th Street, #2200
Denver, Colorado 80202-4432
Righthaven LLC
4475 South Pecos Road
Las Vegas, Nevada 89121
/s/ Steven G. Ganim