Righthaven LLC v. Democratic Underground, LLC et al

Filing 33

STIPULATION to Extend Time for Rule 26 Conference by Defendants David Allen, Democratic Underground, LLC. (Opsahl, Kurt)

Righthaven LLC v. Democratic Underground, LLC et al

Doc. 33

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LAURENCE F. PULGRAM (CSB NO. 115163) (pro hac vice) [e-mail] FENWICK & WEST LLP 555 California Street, 12th Floor San Francisco, California 94104 Telephone: [phone] Facsimile: [phone] KURT OPSAHL (pro hac vice) [e-mail] CORYNNE MCSHERRY (pro hac vice) [e-mail] ELECTRONIC FRONTIER FOUNDATION 454 Shotwell Street San Francisco, CA 94110 Telephone: [phone] Facsimile: [phone] CHAD BOWERS (NV State Bar No. 7283) [e-mail] CHAD A. BOWERS, LTD 3202 West Charleston Boulevard Las Vegas, Nevada 89102 Telephone: [phone] Attorneys for Defendants and Counterclaimant DEMOCRATIC UNDERGROUND, LLC, and Defendant DAVID ALLEN UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA RIGHTHAVEN LLC, a Nevada limited liability company, Plaintiff, v. DEMOCRATIC UNDERGROUND, LLC, a District of Columbia limited-liability company; and DAVID ALLEN, an individual, Defendants. DEMOCRATIC UNDERGROUND, LLC, a District of Columbia limited-liability company, Counterclaimant, v. RIGHTHAVEN LLC, a Nevada limited liability company, and STEPHENS MEDIA LLC, a Nevada limited-liability company, Counterdefendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 2:10-cv-01356-RLH (RJJ)

JOINT STIPULATION AND ORDER TO EXTEND TIME TO COMPLETE RULE 26(f) CONFERENCE (FIRST REQUEST)

JOINT STIPULATION TO EXTEND RULE 26 CONFERENCE

CASE NO. 2:10-CV-01356-RLH (RJJ)

Dockets.Justia.com

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IT IS HERBY STIPULATED BETWEEN Defendants and Counterclaimants, Democratic Underground and David Allen, though their attorneys of record, and Plaintiff and Counterdefendant, Righthaven LLC, and Counterdefendant Stephens Media LLC, though their attorneys of record, as follows: 1. At the Counterdefendants' request, the parties have previously stipulated to extend Counterdefendants' deadline to respond to the counterclaim until November 17, 2010. See Docket No. 29. 2. The time to submit a discovery plan under Federal Rules of Civil Procedure 26 and Local Rule 26-1 is presently due to expire on November 11, 2010, before the time for response to the Counterclaim, which will frame the issues in dispute in this action. 3. The parties agree that it will benefit efficiency in disposition of this action for them to conduct the Rule 26(f) conference and submit their discovery plan to the Court after the pleadings are complete, and therefore respectfully request that their date to conduct the Rule 26(f) conference be extended to December 1, 2010, with a discovery plan to be submitted to the court by December 3, 2010. This is the first request for such an extension. This stipulated extension is sought in good faith and not for the purposes of delay. Dated this 10th day of November, 2010 ELECTRONIC FRONTIER FOUNDATION RIGHTHAVEN LLC

/s/ KURT OPSAHL, ESQ.

By:

/s/ J. CHARLES COONS, ESQ

Kurt Opsahl, Esq. 454 Shotwell Street San Francisco, CA 94110 Attorneys for Defendants and Counterclaimant DEMOCRATIC UNDERGROUND, LLC, and Defendant DAVID ALLEN

J. Charles Coons, Esq. 9960 West Cheyenne Avenue, Suite 210 Las Vegas, Nevada 89129 Attorneys for Plaintiff/Counterdefendant RIGHTHAVEN LLC

JOINT STIPULATION TO EXTEND RULE 26 CONFERENCE

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CASE NO. 2:10-CV-01356-RLH (RJJ)

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JOINT STIPULATION TO EXTEND RULE 26 CONFERENCE

STEPHENS MEDIA LLC

By:

/s/ J. COLBY WILLIAMS, ESQ

J. Colby Williams, Esq. Campbell & Williams 700 South Seventh Street Las Vegas, Nevada 89101 Attorneys for Counterdefendant STEPHENS MEDIA LLC

IT IS SO ORDERED:

_________________________________ UNITED STATES DISTRICT JUDGE

DATED:__________________________

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CASE NO. 2:10-CV-01356-RLH (RJJ)