Righthaven LLC v. Allec et al

Filing 12

STIPULATION FOR EXTENSION OF TIME (Second Request) 11 MOTION to Dismiss for Lack of Jurisdiction and Failure to State a Claim; by Plaintiff Righthaven LLC. (Mangano, Shawn) Docket entry relationship modified on 7/7/2011 (SRK).

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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 Plaintiff Righthaven LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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RIGHTHAVEN LLC, a Nevada limitedliability company,

Case No.: 2:11-cv-00532-KJD-PAL
STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR PLAINTIFF
RIGHTHAVEN LLC TO RESPOND TO
DEFENDANT’S MOTION TO DISMISS
UNDER RULES 12(b)(1) AND (6)

Plaintiff,
v.
RICK ALLEC, an individual; and RX
ADVERTISING, INC. LLC, a limited-liability
company of unknown origin,

(FIRST REQUEST)

Defendants.

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IT IS HEREBY STIPULATED BETWEEN Righthaven LLC (“Righthaven”), by and
through its counsel of record, and Defendant Michael Richard (a/k/a “Rick”) Allec
(“Defendant”), by and through his counsel of record, that Righthaven shall have up to and
including Thursday, July 21, 2011 to file its response to Defendant’s Motion to Dismiss Under
Rules 12(b)(1) and (6) (Doc. # 11). Defendant shall an additional fourteen (14) days from the
time period permitted under the standard briefing period set forth in the Local Rules of Civil
Practice to file his reply to Righthaven’s response.

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This stipulation is sought in good faith and not for purposes of delay. It is entered into as

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an accommodation to Righthaven’s counsel’s schedule, which includes the need to file an

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Omnibus Order to Show Cause Response in ten (10) pending actions along with additional

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required filings and hearings during the next two weeks.

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Dated this 6th day of July, 2011.

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RANDAZZA LEGAL GROUP

SHAWN A. MANGANO, LTD.

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By: /s/ J. Malcom DeVoy IV
J. Malcom DeVoy IV, Esq.
Nevada Bar No. 11950
[e-mail]
7001 W. Charleston Blvd., # 1043
Las Vegas, Nevada 89117
Attorneys for Defendant Michael
“Rick” Allec

By: /s/ Shawn A. Mangano__
Shawn A. Mangano, Esq.
Nevada Bar No. 6730
[e-mail]
9960 West Cheyenne Avenue, Suite 170
Las Vegas, Nevada 89129-7701
Attorneys for Plaintiff Righthaven LLC

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IT IS SO ORDERED:

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_____________________________________
UNITED STATES DISTRICT COURT JUDGE

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