Righthaven LLC v. Democratic Underground, LLC et al

Filing 114

REPLY to Response to 95 First MOTION to Compel the Production of Documents By Defendant Democratic Underground, LLC and Memorandum of Points and Authorities In Support Thereof ; filed by Defendants David Allen, Democratic Underground, LLC. (Attachments: # 1 Declaration of Jennifer Johnson, # 2 Exhibit A to Johnson Declaration, # 3 Exhibit B to Johnson Declaration)(Johnson, Jennifer)

EXHIBIT B

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SHAWN A. MANGANO, ESQ.
Nevada Bar No. 6730
[e-mail]
SHAWN A. MANGANO, LTD.
9960 West Cheyenne Avenue, Suite 170
Las Vegas, Nevada 89129-7701
Tel: [phone]
Fax: [phone]
Attorney for Righthaven LLC
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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RIGHTHAVEN LLC, a Nevada limitedliability company,

Case No.: 2:10-cv-01356-RLH-RJJ
PLAINTIFF’S SIXTH SUPPLEMENTAL
DISCLOSURES PURSUANT TO RULE
26(A)(1)(A) OF THE FEDERAL RULES
OF CIVIL PROCEDURE

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Plaintiff,

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v.

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DEMOCRATIC UNDERGROUND, LLC, a
District of Columbia limited-liability
company; and DAVID ALLEN, an individual,

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Defendants.

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DEMOCRATIC UNDERGROUND, LLC, a
District of Columbia limited-liability
company,
Counterclaimant,

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v.
RIGHTHAVEN LLC, a Nevada limitedliability company; and STEPHENS MEDIA
LLC, a Nevada limited-liability company,
Counterdefendants.

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Plaintiff/Counterdefendant Righthaven LLC (“Righthaven”) makes the following sixth

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supplement to its initial disclosures pursuant to the requirements of Rule 26(a)(1)(A) of the

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Federal Rules of Civil Procedure.

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I.

DESCRIPTION BY CATEGORY AND LOCATION OF DOCUMENTS,
ELECTRONICALLY STORED INFORMATION, AND TANGIBLE THINGS IN
RIGHTHAVEN’S POSSESSION, CUSTODY, OR CONTROL THAT
RIGHTHAVEN MAY USE TO SUPPORT RIGHTHAVEN’S CLAIMS
Righthaven supplements its prior initial, either amended or supplemental, disclosures by

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identifying, as required under the Federal Rules of Civil Procedure, the following documents that

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it may use to support the claims and defenses at issue in this action, which are being concurrently

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produced in PDF format as indicated by the exhibit reference associated with same:

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1.

Original assignment of the literary work that is the subject of the instant suit (the
“Work”), pages 2 – 3 (Exhibit 1);

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2.

Subsequent assignment of the Work, pages 5 – 6 (Exhibit 2); and

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3.

Case summary from the United States Copyright Office of the copyright
registration of the Work (the “Work”), page 8 (Exhibit 3);

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Righthaven reserves the right to supplement the foregoing disclosures as discovery
continues.
Dated this 25th day of May, 2011.

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SHAWN A. MANGANO, LTD.

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By: Shawn A. Mangano
SHAWN A. MANGANO, ESQ.
Nevada Bar No. 6730
[e-mail]
9960 West Cheyenne Avenue, Suite 170
Las Vegas, Nevada 89129-7701
Tel: [phone]
Fax: [phone]

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Attorney for Righthaven LLC

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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 25th day of May, 2011, I caused PLAINTIFF’S SIXTH
SUPPLEMENTAL DISCLOSURES PURSUANT TO RULE 26(A)(1)(A) OF THE
FEDERAL RULES OF CIVIL PROCEDURE to be served to be served in PDF format via
electronic mail to following persons:

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Chad A. Bowers, Esq.
[e-mail]
CHAD A. BOWERS LTD.
3202 West Charleston Boulevard
Las Vegas, Nevada 89102
Laurence F. Pulgram, Esq.
[e-mail]
Jennifer Johnson, Esq.
[e-mail]
FENWICK & WEST
555 California Street, 12th Floor
San Francisco, California 94104
Kurt Opsahl, Esq.
[e-mail]
Corynne McSherry, Esq.
ELECTRONIC FRONTIER FOUNDATION
454 Shotwell Street
San Francisco, California 94110

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Attorney for Defendant/Counterclaimant
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By: /s/ Steven G. Ganim
An Employee of Righthaven LLC
9960 West Cheyenne Avenue, Suite 210
Las Vegas, Nevada 89129-7701
Tel: [phone]

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