Righthaven LLC v. Newman

Filing 30

MOTION to Extend Time regarding dispositive matter (Second Request) re 25 MOTION to Dismiss for Lack of Jurisdiction Subject Matter and Personal First Amended Complaint, 29 Order on Motion to Extend Time/Shorten Time regarding Dispositive matter, by Plaintiff Righthaven LLC. Motion ripe 8/19/2011. (Mangano, Shawn)

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1 2 3 4 5 6 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 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 (SECOND REQUEST) 18 19 20 21 22 23 24 25 26 Righthaven LLC (“Righthaven”) hereby moves the Court for a second 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 previously requested an extension of time until Friday, August 19, 2011 to file a response to Defendant’s Motion, which was requested by counsel because of the unexpected hospitalization of a close friend and client at Valley Hospital. (Doc. # 27.) As noted 27 28 1 1 in the previous submission, due to the close friend and client’s hospitalization, Righthaven’s 2 counsel has been required to be away from his office until late in the evening and then required 3 to return to the hospital for a large portion of the following day. (Doc. # 27 at 2.) Defendant’s 4 counsel did not oppose the request for an extension of time. (Doc. # 28.) The Court 5 subsequently granted the request for extension of time. (Doc. # 29.) Unfortunately, counsel’s friend and client remained hospitalized and under emergency 6 7 room care until late yesterday evening. Counsel then was asked to help assist with medical and 8 other in-home transitional needs for this individual for the remaining portion of Thursday 9 evening and until late Friday evening. In view of these events, which were unexpected, counsel 10 has diligently attempted to meet the ECF deadline for Righthaven’s response pursuant to the 11 extension of time previously granted, but simply cannot do so. What actions counsel has been 12 able to perform for Righthaven and for other clients have been done late into the evening given 13 his need to help his friend and client and his family. Righthaven’s counsel anticipates having a 14 response to the Motion on file likely before the Court has a chance to consider this second 15 requested extension of time, but said filing should be made no later than Monday, August 29, 16 2011. 17 As with the prior requested extension, the foregoing unexpected events have prevented 18 counsel from preparing a response to the Motion by the time set forth in the extension of time 19 entered by the Court. Moreover, these unexpected events have prevented counsel from 20 attempting to secure a stipulation for the requested extension of time because counsel has been 21 away from his office and working as best possible on a remote basis. Righthaven consents to 22 Defendant being given an additional extension of time to file a reply to the response should this 23 24 25 26 27 28 2 1 requested continuance be granted. This requested extension of time is sought in good faith and 2 not for the purposes of delay. 3 Dated this 19th day of August, 2011. SHAWN A. MANGANO, LTD. 4 By: /s/ Shawn A. Mangano, Esq. SHAWN A. MANGANO, ESQ. Nevada Bar No. 6730 shawn@manganolaw.com 9960 West Cheyenne Avenue, Suite 170 Las Vegas, Nevada 89129-7701 Tel.: (702) 304-0432 Fax: (702) 922-3851 5 6 7 8 9 Attorney for Plaintiff Righthaven LLC 10 11 12 13 IT IS SO ORDERED: 14 15 UNITED STATES DISTRICT JUDGE DATED:____________ 16 17 18 19 20 21 22 23 24 25 26 27 28 3 1 CERTIFICATE OF SERVICE 2 Pursuant to Federal Rule of Civil Procedure 5(b), I hereby certify that on this 19th 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 (Second Request) to be 7 served by the Court’s 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 4 /s/ Shawn A. Mangano Shawn A. Mangano, Esq. SHAWN A. MANGANO, LTD.

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