Righthaven LLC v. Newman

Filing 27

MOTION to Extend Time regarding dispositive matter (First Request) re 25 MOTION to Dismiss for Lack of Jurisdiction Subject Matter and Personal First Amended Complaint by Plaintiff Righthaven LLC. Motion ripe 8/16/2011. (Mangano, Shawn)

1
2
3
4
5
6

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]
Attorneys for Plaintiff Righthaven LLC

7

UNITED STATES DISTRICT COURT

8

DISTRICT OF NEVADA

9
10
11

RIGHTHAVEN LLC, a Nevada limitedliability company,

12
13
14
15
16

Case No.: 2:10-cv-01762-JCM-PAL
PLAINTIFF RIGHTHAVEN LLC’S
MOTION FOR EXTENSION OF TIME
TO RESPOND TO DEFENDANT GARRY
NEWMAN’S MOTION TO DISMISS THE
FIRST AMENDED COMPLAINT FOR
LACK OF SUBJECT MATTER
JURISDICTION AND LACK OF
PERSONAL JURISDICTION

Plaintiff,
v.
GARRY NEWMAN, an individual; and
FACEPUNCH STUDIOS LTD., a limited
company formed under the laws of Great
Britain,
Defendants.

17

(FIRST REQUEST)

18
19
20
21
22
23
24
25
26

Righthaven LLC (“Righthaven”) hereby moves the Court for an extension of time to
respond to Defendant Garry Newman’s (“Defendant”) Motion to Dismiss the First Amended
Complaint for Lack of Subject Matter Jurisdiction and Lack of Jurisdiction (Doc. # 25, the
“Motion”).
Righthaven requests an extension of time until Friday, August 19, 2011 to file a response
to Defendant’s Motion. This is Righthaven’s first requested extension of time related to its
response to the Motion. Righthaven’s counsel requests this extension of time because of the

27
28

1

1

unexpected hospitalization of a close friend and client yesterday afternoon at Valley Hospital.

2

This individual was admitted to the emergency room for treatment while his wife and two young

3

children were out of town. Due to the individual’s hospitalization, Righthaven’s counsel was

4

away from the office until late in the evening and then required to return to the hospital for a

5

large portion of the day today. These unexpected events have prevented counsel from preparing

6

a response to the Motion. Moreover, these unexpected events have prevented counsel from

7

attempting to secure a stipulation for the requested extension of time. Righthaven consents to

8

Defendant being give a three (3) day extension of time to file a reply to the response should this

9

requested continuance be granted. This requested extension of time is sought in good faith and

10
11

not for the purposes of delay.
Dated this 16th day of August, 2011.
SHAWN A. MANGANO, LTD.

12

By: /s/ Shawn A. Mangano, Esq.
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]

13
14
15
16
17

Attorney for Plaintiff Righthaven LLC

18
19
20
21

IT IS SO ORDERED:

22
23

UNITED STATES DISTRICT JUDGE
DATED:____________

24
25
26
27
28

2

CERTIFICATE OF SERVICE

1
2

Pursuant to Federal Rule of Civil Procedure 5(b), I hereby certify that on this 16th day of

3

August, 2011, I caused PLAINTIFF RIGHTHAVEN LLC’S MOTION FOR EXTENSION

4

OF TIME TO RESPOND TO DEFENDANT GARRY NEWMAN’S MOTION TO

5

DISMISS THE FIRST AMENDED COMPLAINT FOR LACK OF SUBJECT MATTER

6

JURISDICTION AND LACK OF PERSONAL JURISDICTION to be served by the Court’s

7

CM/ECF system.

8

By:

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

3

/s/ Shawn A. Mangano
Shawn A. Mangano, Esq.
SHAWN A. MANGANO, LTD.