No IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT DOTCONNECTAFRICA TRUST,

Similar documents
Nos , IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION

IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT. Petitioners, Real Parties in Interest.

Case 3:13-cv SC Document 39 Filed 01/09/14 Page 1 of 5

IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT. No

IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

International Centre for Dispute Resolution. CASE No. Case Between. DOTCONNECTAFRICA TRUST (DCA TRUST), Claimant

Case 2:11-cv JEM Document 89 Entered on FLSD Docket 12/05/2011 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

Nos and IN THE UNITED STATES COURT OF APPEAL FOR THE NINTH CIRCUIT

Case 2:11-cv JEM Document 38 Entered on FLSD Docket 04/18/2011 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT. No TODD S. GLASSEY AND MICHAEL E. MCNEIL,

Nos ; IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

March 11, Re: Realtek Semiconductor Corp. v. LSI Corp. et al., No Panel: Judges Farris, Reinhardt & Tashima

IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

Attorneys for Plaintiff Regina Bozic, the Proposed Classes, and the Appeals Class (See FRAP 3(c)(3))

Case 1:16-md GAO Document 381 Filed 08/17/18 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

Case , Document 219-1, 01/26/2017, , Page1 of 3

Case 1:18-cv LY Document 43 Filed 09/17/18 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION

UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT. No John Teixeira; et al., Plaintiffs/Appellants,

UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

Case 4:09-cv CW Document 579 Filed 06/01/16 Page 1 of 5

CASE NO. EC UNITED STATES BANKRUPTCY APPELLATE PANEL OF THE NINTH CIRCUIT. In re CITY OF STOCKTON, CALIFORNIA, Debtor.

Case: Document: 26-1 Filed: 12/04/2014 Pages: 6 NO IN THE UNITED STATES COURT OF APPEALS FOR THE SEVENTH CIRCUIT ) ) ) )

Case 1:14-cv CMH-TRJ Document 14 Filed 01/23/15 Page 1 of 10 PageID# 83

United States Court of Appeals for the Ninth Circuit

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

No No CV LRS

IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT. Plaintiffs - Appellants, Defendants - Appellees.

Case3:15-cv VC Document25 Filed06/19/15 Page1 of 8

- UNITED STATES DISTRICT COURT,_. SOUTHERN DISTRICT OF NEW YORK

Case 2:14-cv ODW-RZ Document 66 Filed 08/06/15 Page 1 of 7 Page ID #:791

Appeal No IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT. Bradley Berentson, et al. Brian Perryman,

IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT

US District Court for the Northern District of California

UNOPOSSED PLAINTIFF-APPELLANT S AMENDED MOTION FOR COURT S APPROVAL TO ELECTRONIC FILE CASE DOCUMENTS VIA CM/ECF SYSTEM 1

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

PlainSite. Legal Document

Nos and UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

Case: Document: 6 Filed: 11/03/2016 Pages: 6 UNITED STATES COURT OF APPEALS FOR THE SEVENTH CIRCUIT. No ) ) ) ) ) ) ) ) ) )

Case 3:06-cv JSW Document 122 Filed 10/30/2006 Page 1 of 15

In the United States Court of Appeals for the Fifth Circuit

Case 1:12-cv GBL-JFA Document 17 Filed 09/10/12 Page 1 of 4 PageID# 185

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT. Office of the Clerk. After Opening a Case Pro Se Appellants (revised December 2012)

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT

In the United States Court of Appeals for the Third Circuit

Case 3:06-cv JSW Document 136 Filed 12/04/2006 Page 1 of 8

Nos & IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT. ROSALINA CUELLAR DE OSORIO; et al.

Case 8:11-cv FMO-AN Document 193 Filed 10/16/15 Page 1 of 5 Page ID #:4291

IN THE UNITED STATES COURT OF APPEALS FOR THE FEDERAL CIRCUIT IN RE TELES AG,

Case: Document: 37 Page: 1 Filed: 07/25/ , IN THE UNITED STATES COURT OF APPEALS FOR THE FEDERAL CIRCUIT

Case 2:17-cv JLR Document 179 Filed 04/07/17 Page 1 of 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON.

PLAINTIFFS-APPELLANTS:

Case 4:16-cv CW Document 75-4 Filed 08/14/18 Page 1 of 7

NOS , UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT UNDER SEAL, PETITIONER-APPELLANT,

Case4:13-cv JSW Document122 Filed10/31/14 Page1 of 4

) ) ) ) ) ) ) ) ) ) ) )

IN THE UNITED STATES COURT OF APPEALS FOR THE SEVENTH CIRCUIT ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

UNITED STATE COURT OF APPEALS NINTH CIRCUIT

Case 3:14-cv L-NLS Document 60 Filed 11/18/15 Page 1 of 3

Case 3:15-cv HEH Document 64 Filed 09/18/15 Page 1 of 4 PageID# 445

UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA SAN DIEGO DIVISION

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case 2:13-cv JAK-AGR Document 457 Filed 12/07/15 Page 1 of 12 Page ID #:13889

INDEPENDENT REVIEW PROCESS INTERNATIONAL CENTRE FOR DISPUTE RESOLUTION

NOT FOR PUBLICATION FOR THE NINTH CIRCUIT

PlainSite. Legal Document

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

Synchronoss Technologies, Inc. v. Funambol, Inc. Doc. 52

Case: , 11/17/2017, ID: , DktEntry: 36, Page 1 of 12 No IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

Defendants. Judge: Hon. Manuel L. Real

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION

Case3:11-cv WHA Document33 Filed01/06/12 Page1 of 11 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA. Plaintiff, Plaintiffs,

JOINT STIPULATION OF DISMISSAL OF DEFENDANT AIR FRANCE-KLM WITHOUT PREJUDICE [F.R.C.P. 4141(a)(1)(A)(ii)]

Case 2:17-ap BB Doc 24 Filed 03/21/17 Entered 03/21/17 10:59:09 Desc Main Document Page 1 of 6

IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT Case No ) ) ) ) ) ) ) ) ) ) ) ) ) ) APPELLANT S OPENING BRIEF

Case4:10-cv CW Document205 Filed11/02/12 Page1 of 6

UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION, LOS ANGELES

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA CRUZ ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case 3:16-md VC Document 419 Filed 08/03/17 Page 1 of 5 UNITED STATES DISTRICT COURT

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

NO IN THE SUPREME COURT OF THE STATE OF HAWAII

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

Case 5:11-cv LHK Document 3322 Filed 12/03/15 Page 1 of 7

Case 2:12-cv SVW-PLA Document 21 Filed 05/24/12 Page 1 of 10 Page ID #:204

No IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT. MICHELLE FLANAGAN, ET AL., Plaintiffs-Appellants,

Case 3:13-cv WHO Document 90 Filed 09/20/17 Page 1 of 5

No UNITED STATES COURT OF APPEALS FOR THE TENTH CIRCUIT SECURITIES AND EXCHANGE COMMISSION, Plaintiff-Appellee, CHARLES D.

Case 2:17-cv RAJ Document 36 Filed 07/21/17 Page 1 of 5

U.S. District Court District of Columbia (Washington, DC) CIVIL DOCKET FOR CASE #: 1:14 cv JDB

Cooper & Kirk, PLLC 1523 New Hampshire Avenue, NW Washington, DC Hon. William M. Skretny, Western District of New York

Attorneys for Plaintiff JANE DOE, a pseudonym UNITED STATES DISTRICT COURT

UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

Office of the Clerk United States Court of Appeals for the Ninth Circuit Post Office Box San Francisco, California

Transcription:

Case: 16-55693, 05/18/2016, ID: 9981617, DktEntry: 5, Page 1 of 6 No. 16-55693 IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT DOTCONNECTAFRICA TRUST, v. Plaintiff-Appellee, INTERNET CORPORATION FOR ASSIGNED NAMES AND NUMBERS, ET AL., Defendants-Appellant. On Appeal From the United States District Court For the Central District of California Case No. CV 16-00862-RGK The Honorable R. Gary Klausner APPELLANT S UNOPPOSED MOTION FOR AN EXTENSION OF TIME TO FILE OPENING BRIEF Craig Stewart JONES DAY 555 California Street, 26th Floor San Francisco, CA 94104 Telephone: (415) 626-3939 Facsimile: (415) 875-5700 Jeffrey A. LeVee Kate Wallace Rachel Gezerseh Charlotte Wasserstein JONES DAY 555 South Flower Street Fiftieth Floor Los Angeles, CA 90071-2300 Telephone: (213) 489-3939 Facsimile: (213) 243-2539 Attorneys for Defendant-Appellant INTERNET CORPORATION FOR ASSIGNED NAMES AND NUMBERS

Case: 16-55693, 05/18/2016, ID: 9981617, DktEntry: 5, Page 2 of 6 Appellant Internet Corporation For Assigned Names And Numbers ( ICANN ) respectfully moves for an extension of time, from June 8, 2016 to June 29, 2016, within which to file its opening brief in this preliminary injunction appeal. ICANN makes this request because, on June 6, 2016, the district court will hear defendant ZA Central Registry s ( ZACR s ) motion to reconsider the preliminary injunction order from which this appeal is taken. The requested extension of time will give the district court an opportunity to rule on the motion to reconsider and, to the extent that ruling does not moot this appeal, will allow ICANN the opportunity to address the district court s ruling in its opening brief. This Court may grant the requested extension under Rule 26(b) of the Federal Rules of Appellate Procedure and Ninth Circuit Rule 31-2.2(b). Plaintiffappellee DotConnectAfrica Trust ( Plaintiff ) does not oppose the requested extension on the condition that its Appellee s Brief shall be due on August 5, 2016, which request ICANN does not oppose. ZACR does not oppose the requested extension. The grounds for this motion are as follows, and are explained in the accompanying Declaration of Jeffrey A. LeVee. This appeal is from the district court s preliminary injunction entered against ICANN on April 12, 2016. ECF No. 75. 1 Although ZACR was named in the complaint as a defendant along with ICANN, Plaintiff did not serve ZACR until 1 ECF references are to the docket in the court below, No. CV 16-00862- RGK (C.D. Cal.).

Case: 16-55693, 05/18/2016, ID: 9981617, DktEntry: 5, Page 3 of 6 March 22, 2016, the day after briefing on Plaintiff s preliminary injunction motion was completed. See ECF No. 85 at 4. As such, ZACR did not have an opportunity to participate in the briefing on Plaintiff s preliminary injunction motion. ZACR filed its motion to reconsider on May, 6, 2016. ECF No. 85. ICANN joined in that motion on May 10, 2016. ECF No. 86. The motion to reconsider is currently scheduled to be heard on June 6, 2016. As a result, ICANN requests an extension of time to file its opening brief, through June 29, 2016, to permit ICANN to address the district court s ruling on the motion to reconsider, to the extent that the district court s ruling does not moot this appeal. Dated: May 18, 2016 Respectfully submitted, JONES DAY By: /s/ Jeffrey A. LeVee Jeffrey A. LeVee Jones Day 555 South Flower Street, Fiftieth Floor Los Angeles, CA 90071.2300 Telephone: (213) 489-3939 Facsimile: (213) 243-2539 Attorneys for Defendant-Appellant INTERNET CORPORATION FOR ASSIGNED NAMES AND NUMBERS 2

Case: 16-55693, 05/18/2016, ID: 9981617, DktEntry: 5, Page 4 of 6 DECLARATION OF JEFFREY A. LEVEE IN SUPPORT OF APPELLANT S UNOPPOSED MOTION FOR AN EXTENSION OF TIME TO FILE OPENING BRIEF I, Jeffrey A. LeVee, declare: 1. I am a Partner with Jones Day, in its Los Angeles, California office, counsel of record for appellant Internet Corporation for Assigned Names and Numbers ( ICANN ) in this preliminary injunction appeal. I have personal knowledge of the matters set forth below and if called to testify to them, could do so competently. 2. ICANN is seeking an extension of time, until June 29, 2016, within which to file its opening brief. ICANN s opening brief is currently due on June 8, 2016. No previous extensions for this brief have been sought or granted. 3. The grounds for this extension are as follows: On June 6, 2016, the district court will hear defendant ZA Central Registry s motion for reconsideration of the preliminary injunction order from which this appeal is taken. The requested extension of time will afford the district court an opportunity to rule on the pending motion and, to the extent that the district court s ruling does not moot the appeal, will allow ICANN the opportunity to address that ruling in its opening brief. 4. I have exercised diligence regarding this matter, and will file ICANN s opening brief within the time requested, unless subsequent events render 3

Case: 16-55693, 05/18/2016, ID: 9981617, DktEntry: 5, Page 5 of 6 4

Case: 16-55693, 05/18/2016, ID: 9981617, DktEntry: 5, Page 6 of 6 CERTIFICATE OF SERVICE I, Jeffrey A. LeVee, counsel for Appellant ICANN, certify that I electronically filed the foregoing documents with the Clerk of the Court for the United States Court of Appeals for the Ninth Circuit by using the appellate CM/ECF system on May 18, 2016. I certify that the following participants in this case are registered CM/ECF users and will be served by the appellate CM/ECF system. Plaintiff-Appellee DotConnectAfrica Trust Ethan J. Brown ethan@bnslawgroup.com Sara C. Colón sara@bnslawgroup.com BROWN NERI & SMITH LLP 11766 Wilshire Boulevard, Suite 1670 Los Angeles, California 90025 Telephone: (310) 593-9890 Facsimile: (310) 593-9980 I further certify that the following participant in this case is not registered with the CM/ECF system and will be served by e-mail by mutual agreement. Defendant ZA Central Registry David W. Kesselman, Esq. dkesselman@kbslaw.com Kesselman Brantly Stockinger LLP 1230 Rosecrans Ave, Suite 690 Manhattan Beach, CA 90266 Telephone: (310) 307-4556 Facsimile: (310) 307-4570 NAI-1501037556 /s Jeffrey A. LeVee Jeffrey A. LeVee