Motion To Withdraw As Counsel - Steve Ganim Laid Off

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The motion requests for an order permitting a lawyer named Steven G. Ganim to withdraw as counsel for Righthaven in a civil case between Righthaven and Leland Wolf and It Makes Sense Blog.

The motion requests the court's permission for the lawyer Steven G. Ganim to withdraw as counsel for Righthaven in the civil case.

Three reasons are provided for the lawyer Steven G. Ganim to withdraw as counsel - he is no longer employed by Righthaven due to being laid off, he is required to withdraw if discharged by a client according to rules of professional conduct, and he has complied with notification requirements.

I N T HE UNI T ED ST AT ES DISTRI CT COURT

F OR T HE DISTRI CT OF COL ORADO



Civil Action No.: 1:11-cv-00830-JLK

RIGHTHAVEN LLC, a Nevada limited-liability company,

Plaintiff,
v.

LELAND WOLF, an individual; and
IT MAKES SENSE BLOG, an entity of unknown origin and nature,

Defendants.


UNOPPOSED MOTI ON T O WI T HDRAW AS COUNSE L


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 oI Withdraw oI 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 1 of 3
RUL E 7.1(A) CERTI FI CATI ON
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
[email protected]

























Case 1:11-cv-00830-JLK Document 32 Filed 08/21/11 USDC Colorado Page 2 of 3
CERTI FI CAT E OF SERVI CE

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 oI the Ioregoing 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 Filed 08/21/11 USDC Colorado Page 3 of 3

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