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The fact is that after Mr. Mangano and his client lost the exact same argument eighttimes, Mangano still persisted in forcing this defendant to litigate the same issue a ninth time. Itis the Defendants’ position that
the first time that Mangano signed pleadings in directcontravention with the 9th Circuit’s holding in
, it could have been a forgivable attempt.The same may have been true for the second and third times, with declining defensibility. Whenit came to being told eight times that he brought an unsupportable claim before the court, Mr.Mangano under a clear obligation to exercise some degree of client control; to refuse to bring theexact same arguments; or to dismiss a case with an inescapable outcome, such as this one, rather than to force a defendant to litigate the same exact issue a
on grounds identical to the previous eight defeats. Forcing this issue nine times had no effect except to punitively imposelitigation expenses on this Defendant. This Defendant deserves to be made whole for theexpenses incurred due to that misconduct.In the Opposition, Mangano strenuously attempts to obfuscate the issues before theCourt.
Mangano argues that since he was given multiple warnings about his conduct before theinstant motion was filed, then the motion is not proper. To the contrary, such warnings indicate just how much restraint was shown before bringing this motion, and they indicate the degree of warning afforded to Mr. Mangano - giving him ample opportunity to change course. Finally,after Mr. Mangano forced a defendant to fully litigate Righthaven’s lack of standing for the
, enough was enough, and a motion for sanctions finally was unleashed. The instantmotion came as no surprise to Mangano. He was warned, and he remained arrogant in the faceof such warnings. The instant motion is long overdue.//////
It is understandable that Righthaven’s counsel would vigorously oppose a motion for sanctions. Therefore, NewsBlaze asks the Court to forgive Mr. Mangano’s unnecessarily vituperative invective in the Opposition.However, while doing so, this Court should not fall victim to Mangano’s attempt to muddy the waters. For example,Mr. Mangano introduces numerous statements that were made in Rule 408 privileged discussions. However, noneof it is relevant to the issue at hand.
Case 2:11-cv-00720-RCJ -GWF Document 30 Filed 11/14/11 Page 2 of 12