Bear Omnimedia LLC v. Mania Media LLC et al

Filing 84

ORDER granting ECF No. 83 Motion to Extend Time : Mania Media LLC's answer to ECF No. 58 Third Amended Complaint due by 1/10/2018. Signed by Magistrate Judge Carl W. Hoffman on 1/4/2018. (Copies have been distributed pursuant to the NEF - DRM)

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Chad Anderson
Nevada State Bar 014468
3280 E Maule Ave
Las Vegas, NV 89120
602-904-5485
[e-mail]
Attorney for Defendant Mania Media LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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BEAR OMNIMEDIA LLC,

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Case No.: 2:17-cv-1478-MMD-CWH

Plaintiff,
vs.
MANIA MEDIA LLC dba “BEAR FILMS”
and BEARFILMS.com; CM
PUBLICATIONS LIMITED aka “The
magazine ALL BEAR,” “ALL BEAR
Special Edition,” “ALL BEAR EXTRA,”
The “ALL BEAR Newsletter”, BEAR
WORLD MEDIA LTD,
BEARworldMAGAZINE.com; WEBID
CONSULTING LTD. Dba BEARworld.COM
And BEAR411.COM; and STEVEN TILOTTA
dba playBEARMAGAZINE.COM AND dba
playBEAR.COM; INSTAGRAM INC., a
Delaware corporation; INSTAGRAM LLC,
A Delaware corporation; DOES I-X, ROE
COMPANIES I-X
Defendant

(FIRST) MOTION FOR EXTENSION OF
TIME FOR DEFENDANT MANIA MEDIA
TO RESPOND TO THIRD AMENDED
COMPLAINT

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(FIRST) MOTION FOR EXTENSION OF TIME FOR DEFENDANT MANIA MEDIA TO RESPOND TO THIRD
AMENDED COMPLAINT - 1

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Defendant Mania Media LLC, by and through its counsel of record, Chad Anderson,

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Attorney at Law, hereby move this Honorable Court to extend by 7 days the time for it to file its

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response to Plaintiff’s Third Amended Complaint. In support of the motion, counsel states:

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1. On December 14, 2017, this Court entered an Order granting Mania Media’s motion to

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set aside clerk’s entry of default (ECF No. 79);
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2. Within its motion to set aside clerk’s entry of default, Mania Media requested that it

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be permitted to respond to Plaintiff’s Third Amended Complaint (by way of either a Motion to

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Dismiss Pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure, a Motion to Dismiss

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under Nevada’s anti-SLAPP statute, or an Answer)within 20 days of entry of an order granting

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its motion (ECF No. 66);
3. As the Court granted the motion to set aside clerk’s entry of default on December 14,
2017, Mania Media’s response is currently due January 3, 2018;

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4. While counsel has endeavored to finalize a response by the current due date, an
extension is necessary and warranted to allow counsel to finalize a full and appropriate response
that will assist the Court in addressing this matter;
5. Good cause exists to allow a brief extension of 7 days for Mania Media to finalize its
response, specifically, the intervening holidays between December 21 and January 3 reduced the
amount of time counsel could devote to preparing a response;
6. Additionally, this brief extension will not delay this matter, as Defendant Instagram

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has until January 31, 2018, to respond to the complaint (see ECF No. 80), and thus there is no
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prejudice to any party in granting Mania Media a brief extension;
7. Finally, counsel has made no prior request to extend the time to respond to the

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complaint.

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(FIRST) MOTION FOR EXTENSION OF TIME FOR DEFENDANT MANIA MEDIA TO RESPOND TO THIRD
AMENDED COMPLAINT - 2

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In light of the foregoing, Mania Media respectfully request a 7-day extension to file
its response to Plaintiff’s Third Amended Complaint.

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Respectfully submitted this 3rd day of January, 2018
/s/ Chad Anderson
Chad Anderson, Attorney at Law
3280 E Maule Ave
Las Vegas, NV 89120
[phone]
[e-mail]
January 4, 2018
Attorney for Mania Media LLC

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CERTIFICATE OF SERVICE

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I hereby certify that a copy of the foregoing was electronically filed with the
Court’s Electronic Filing System and served on the attorneys of record for all parties in the above

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cause in accordance with the Federal Rules of Civil Procedure on January 3, 2018.
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/s/ Chad Anderson

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(FIRST) MOTION FOR EXTENSION OF TIME FOR DEFENDANT MANIA MEDIA TO RESPOND TO THIRD
AMENDED COMPLAINT - 3