Righthaven LLC v. Newman

MOTION to Extend Time regarding dispositive matter

D. Nev.August 16, 2011

1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA RIGHTHAVEN LLC, a Nevada limited- liability company, Plaintiff, v. GARRY NEWMAN, an individual; and FACEPUNCH STUDIOS LTD., a limited company formed under the laws of Great Britain, Defendants. 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 (FIRST REQUEST) 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 Case 2:10-cv-01762-JCM -PAL Document 27 Filed 08/16/11 Page 1 of 3 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 unexpected hospitalization of a close friend and client yesterday afternoon at Valley Hospital. This individual was admitted to the emergency room for treatment while his wife and two young children were out of town. Due to the individual’s hospitalization, Righthaven’s counsel was away from the office until late in the evening and then required to return to the hospital for a large portion of the day today. These unexpected events have prevented counsel from preparing a response to the Motion. Moreover, these unexpected events have prevented counsel from attempting to secure a stipulation for the requested extension of time. Righthaven consents to Defendant being give a three (3) day extension of time to file a reply to the response should this requested continuance be granted. This requested extension of time is sought in good faith and not for the purposes of delay. Dated this 16th day of August, 2011. SHAWN A. MANGANO, LTD. 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 Attorney for Plaintiff Righthaven LLC IT IS SO ORDERED: UNITED STATES DISTRICT JUDGE DATED:____________ Case 2:10-cv-01762-JCM -PAL Document 27 Filed 08/16/11 Page 2 of 3 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CERTIFICATE OF SERVICE Pursuant to Federal Rule of Civil Procedure 5(b), I hereby certify that on this 16th day of August, 2011, I caused 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 to be served by the Court’s CM/ECF system. By: /s/ Shawn A. Mangano Shawn A. Mangano, Esq. SHAWN A. MANGANO, LTD. Case 2:10-cv-01762-JCM -PAL Document 27 Filed 08/16/11 Page 3 of 3