Case 1:11-cv-00830-JLK Document 32 Filed 08/21/11 USDC Colorado Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No.: 1:11-cv-00830-JLK RIGHTHAVEN LLC, a Nevada limited-liability company, v. Plaintiff, LELAND WOLF, an individual; and IT MAKES SENSE BLOG, an entity of unknown origin and nature, Defendants. UNOPPOSED MOTION TO WITHDRAW AS COUNSEL STEVEN G. GANIM, Esq. respectfully moves this Court for an Order permitting Steven G. Ganim ( Mr. Ganim ), who has appeared in these proceedings, to withdraw as counsel for Righthaven LLC ( Righthaven ), in the above-styled matter, pursuant to D.C.COLO.LCivR 83.3 (D) and Rule 1.16 of the Colorado Rules of Professional Conduct. In support thereof, the undersigned states as follows: 1. Mr. Ganim is no longer employed by Righthaven, due to recently being laid off. 2. Pursuant to Rule 1.16(a)(3) of the Colorado Rules of Professional Conduct, a lawyer is required to withdraw from the representation of a client if the lawyer is discharged. 3. Mr. Ganim has complied with the notification requirements of D.C.COLO.LCivR 83.3 (D). Please see the Notice of Withdraw of Appearance, attached hereto as Exhibit 1. 4. No party will be prejudiced or otherwise affected by Mr. Ganim s withdrawal, as Righthaven is currently represented by other counsel. 5. The relief requested in this Motion is sought in good faith and not for the purposes of delay.
Case 1:11-cv-00830-JLK Document 32 Filed 08/21/11 USDC Colorado Page 2 of 3 RULE 7.1(A) CERTIFICATION Mr. Ganim conferred with James Malcolm DeVoy, IV, counsel for defendants in this matter, concerning the relief requested herein. Defendants do not oppose this Motion. WHEREFORE, the undersigned counsel respectfully requests to withdraw from representing Righthaven in the instant matter. Dated this 21 st day of August, 2011. By: /s/ Steven G. Ganim STEVEN G. GANIM, ESQ. Post Office Box 230812 Las Vegas, Nevada 89105 Tel: (702) 324.5347 sgganim@gmail.com
Case 1:11-cv-00830-JLK Document 32 Filed 08/21/11 USDC Colorado Page 3 of 3 CERTIFICATE OF SERVICE Pursuant to Federal Rule of Civil Procedure 5(b), I hereby certify that on this 21 st day of August, 2011, I caused a copy of the MOTION TO WITHDRAW AS COUNSEL to be served via the Court s CM/ECF system, as well as depositing a copy of the foregoing in the United States Mail to the following persons: Andrew John Contiguglia, Esq. Contiguglia & Fazzone, P.C. 400 South Colorado Blvd., Ste. 830 Denver, CO 80246 James Malcom DeVoy, IV, Esq. Marc John Randazza, Esq. Randazza Legal Group 7001 West Charleston Blvd, #1043 Las Vegas, Nevada 89117 Kurt Bradford Opsahl, Esq. Electronic Frontier Foundation 454 Shotwell Street San Francisco, CA 94110-1914 James John Todd Kincannon, Esq. The Kincannon Firm P.O. Box 7901 Columbia, SC 29202 Righthaven LLC 4475 South Pecos Road Las Vegas, Nevada 89121 /s/ Steven G. Ganim
Case 1:11-cv-00830-JLK Document 32-1 Filed 08/21/11 USDC Colorado Page 1 of 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No.: 1:11-cv-00830-JLK RIGHTHAVEN LLC, a Nevada limited-liability company, v. Plaintiff, LELAND WOLF, an individual; and IT MAKES SENSE BLOG, an entity of unknown origin and nature, Defendants. NOTICE OF WITHDRAWAL OF APPEARANCE In accordance with D.C.COLO.LCivR 83.3 (D) and Rule 1.16 of the Colorado Rules of Professional Conduct, the undersigned hereby certifies as follows: 1. The undersigned intends to withdraw as attorney of record for Righthaven LLC ( Righthaven ), in the above-styled matter. 2. Pursuant to D.C.COLO.LCivR 83.3 (D), the undersigned hereby notifies Righthaven of the following: (a) Righthaven is personally responsible for complying with all court orders and time limitations established by any applicable rules; and (b) Righthaven cannot appear without counsel admitted to practice before this court, and absent prompt appearance of substitute counsel, pleadings, motions, and other papers may be stricken, and default judgment or other sanctions may be imposed against the entity. Dated this 21 st day of August, 2011. By: /s/ Steven G. Ganim STEVEN G. GANIM, ESQ. Post Office Box 230812 Las Vegas, Nevada 89105 Tel: (702) 324.5347 sgganim@gmail.com
Case 1:11-cv-00830-JLK Document 32-1 Filed 08/21/11 USDC Colorado Page 2 of 2 CERTIFICATE OF SERVICE Pursuant to Federal Rule of Civil Procedure 5(b), I hereby certify that on this 21 st day of August, 2011, I caused a copy of the NOTICE OF WITHDRAWAL OF APPEARANCE to be served via United States Mail to the following persons: Andrew John Contiguglia, Esq. Contiguglia & Fazzone, P.C. 400 South Colorado Blvd., Ste. 830 Denver, CO 80246 James Malcom DeVoy, IV, Esq. Marc John Randazza, Esq. Randazza Legal Group 7001 West Charleston Blvd, #1043 Las Vegas, Nevada 89117 Kurt Bradford Opsahl, Esq. Electronic Frontier Foundation 454 Shotwell Street San Francisco, CA 94110-1914 James John Todd Kincannon, Esq. The Kincannon Firm P.O. Box 7901 Columbia, SC 29202 Righthaven LLC 4475 South Pecos Road Las Vegas, Nevada 89121 /s/ Steven G. Ganim
Case 1:11-cv-00830-JLK Document 32-2 Filed 08/21/11 USDC Colorado Page 1 of 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No.: 1:11-cv-00830-JLK RIGHTHAVEN LLC, a Nevada limited-liability company, v. Plaintiff, LELAND WOLF, an individual; and IT MAKES SENSE BLOG, an entity of unknown origin and nature, Defendants. ORDER REGARDING UNOPPOSED MOTION TO WITHDRAW AS COUNSEL This matter having come before the Court on the Unopposed Motion to Withdraw as Counsel and the Court having reviewed the pleadings filed herein and being fully advised of the premises contained therein, it hereby GRANTS the Motion and ORDERS that: 1. Steven G. Ganim is hereby withdrawn from representing Righthaven LLC. 2. The Clerk of the Court shall terminate the association of Steven G. Ganim with Righthaven LLC. Dated this day of August, 2011. BY THE COURT: UNITED STATES DISTRICT JUDGE JOHN L. KANE