Righthaven LLC v. No Quarter et al

Filing 32

ORDER GRANTING 31 Stipulation to Extend Deadlines. Responses due by 4/8/2011 and, Replies due by 4/29/2011iled re 18 MOTION to Dismiss filed by Larry C. Johnson and 16 MOTION to Set Aside Default and Motion to Dismiss filed by Larry C. Johnson. Signed by Judge James C. Mahan on 3/25/11. (Copies have been distributed pursuant to the NEF - ECS)

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-GWF Righthaven LLC v. No Quarter et al Doc. 32 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SHAWN A. MANGANO, ESQ. Nevada Bar No. 6730 shawn@manganolaw.com SHAWN A. MANGANO, LTD. 9960 West Cheyenne Avenue, Suite 170 Las Vegas, Nevada 89129-7701 Tel: (702) 304-0432 Fax: (702) 922-3851 ANNE E. PIERONI, ESQ. Nevada Bar No. 9650 apieroni@righthaven.com Counsel at Righthaven LLC IKENNA K. ODUNZE, ESQ. Nevada Bar No. 9885 iodunze@righthaven.com Counsel at Righthaven LLC RIGHTHAVEN LLC 9960 West Cheyenne Avenue, Suite 210 Las Vegas, Nevada 89129-7701 Tel.: (702) 527-5900 Fax: (702) 527-5909 Attorneys for Plaintiff Righthaven LLC UNITED STATES DISTRICT COURT DISTRICT OF NEVADA RIGHTHAVEN LLC, a Nevada limitedliability company, Plaintiff, v. NO QUARTER, an entity of unknown origin and nature; and LARRY C. JOHNSON, an individual, Defendants. Case No.: 2:10-cv-01022-JCM-GWF STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT LARRY C. JOHNSON'S MOTION TO DISMISS AND CONSENT TO SET ASIDE DEFAULT (FOURTH REQUEST) 1 Dockets.Justia.com Case 2:10-cv-01022-JCM -GWF Document 31 Filed 03/22/11 Page 2 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 IT IS HEREBY STIPULATED BETWEEN Righthaven LLC ("Righthaven"), by and through its counsel of record, and Defendant Larry C. Johnson ("Defendant"), by and through his counsel of record, that Righthaven's Response to Defendant's Motion to Dismiss (Doc. # 16, 18), which was due on March 18, 2011 and Defendant's reply to Righthaven's response to same was due on March 28, 2011 based on a stipulation and order entered by the Court on March 16, 2011 (Doc. # 29), shall now be due as follows: (1) Righthaven's response to Defendant's Motion Dismiss is to be filed on or before April, 8, 2011; and Defendant's reply to Righthaven's response shall be filed on or before April 29, 2011. This stipulation and order is entered into between Righthaven and Defendant because the parties have reached agreement in various material terms to settle these proceedings but have not yet reduced their understanding to writing via a formal settlement agreement. The parties wish to relieve the Court of the burden associated with unnecessary filings in this action in view of the fact that Righthaven's response and Defendant's reply submissions would appear to be rendered moot given the nature of the settlement discussions between them. The time periods requested by this stipulation should provide the parties with sufficient time to negotiate and execute a written settlement agreement or, should for some unforeseen and unlikely reason a settlement is not formally reduced to writing, adequate time is provided for appropriate responses to be filed in connection with Defendant's Motion to Dismiss. This stipulation is sought in good faith and not for purposes of delay. /// /// /// /// /// /// /// /// 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated this 22nd day of March, 2011. WOODS ERICKSON WHITAKER & MAURICE LLP By: /s/ Jason M. Wiley JASON M. WILEY, ESQ. Nevada Bar No. 9274 jwiley@woodserickson.com 1349 W. Galleria Drive, #200 Henderson, Nevada 89014 Attorneys for Defendant SHAWN A. MANGANO, LTD. By: /s/ Shawn A. Mangano__ SHAWN A. MANGANO, ESQ. Nevada Bar No. 6730 shawn@manganolaw.com 9960 West Cheyenne Avenue, Suite 170 Las Vegas, Nevada 89129-7701 ANNE E. PERONI, ESQ. Nevada Bar No. 9630 aperoni@righthaven.com Counsel at Righthaven LLC Righthaven LLC 9960 West Cheyenne Avenue, Suite 210 Las Vegas, Nevada 89129-7701 Attorneys for Plaintiff Righthaven LLC IT IS SO ORDERED: ________________________________________ UNITED STATES DISTRICT COURT JUDGE March 25, 2011 DATED: _____________________________ 3

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