Righthaven LLC v. Vote For The Worst, LLC et al

Filing 20

DECLARATION of J. Charles Coons, Esq. re 19 Response to Motion ; by Plaintiff Righthaven LLC. (Coons, John)

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J. CHARLES COONS, ESQ. Nevada Bar No. 10553 [e-mail] Assistant General Counsel at Righthaven JOSEPH C. CHU, ESQ. Nevada Bar No. 11082 [e-mail] Staff Attorney at Righthaven Righthaven LLC 9960 West Cheyenne Avenue, Suite 210 Las Vegas, Nevada 89129-7701 [phone] Attorneys for Plaintiff UNITED STATES DISTRICT COURT DISTRICT OF NEVADA

RIGHTHAVEN LLC, a Nevada limitedliability company,

Case No.: 2:10-cv-01045-KJD-RJJ DECLARATION OF J. CHARLES COONS IN SUPPORT OF PLAINTIFF'S OPPOSITION TO STAY RULE 26(f) CONFERENCE

Plaintiff,
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v.
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VOTE FOR THE WORST, LLC, a Utah limited-liability company; NATHAN E. PALMER, an individual; and DAVID J. DELLA TERZA, an individual; Defendants.

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I, J. Charles Coons, declare, under penalty of perjury, that the following is true and correct: 1. I am an attorney-at-law admitted to practice in all courts of the State of Nevada. I

have personal knowledge of the facts set forth below, except for those factual statements expressly made upon information and belief, and as to those facts, I believe them to be true. I am over eighteen years old and I am competent to testify to the matters set forth herein. 2. I represent Plaintiff Righthaven LLC ("Righthaven"), in the capacity of assistant

general counsel, in the above-referenced matter.

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3.

On September 28, 2010, I sent a letter to opposing counsel for the Defendants

requesting participation in the Rule 26(f) conference.

/s/ J. Charles Coons J. CHARLES COONS, ESQ.

CERTIFICATE OF SERVICE Pursuant to Federal Rule of Civil Procedure 5(b), I hereby certify that I am an employee of Righthaven LLC and that on this twelfth day of October, 2010, I caused the DECLARATION OF J. CHARLES COONS IN SUPPORT OF PLAINTIFF'S OPPOSITION TO STAY RULE 26(f) CONFERENCE to be served by the Court's CM/ECF system.

By: /s/ J. Charles Coons J. CHARLES COONS, ESQ. Righthaven LLC 9960 West Cheyenne Avenue, Suite 210 Las Vegas, Nevada 89129-7701

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