Defendant’s Application for Order Scheduling Judgment Debtor Examination | Judgment (Law) | Deposition (Law)

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Randazza
Legal Group
7001 W Charleston Blvd
#1043
Las Vegas, NV 89117
(888) 667-1113


Marc J. Randazza (Admitted Pro Hac Vice)
J. Malcolm DeVoy IV (Nevada Bar No. 11950)
RANDAZZA LEGAL GROUP
mjr@Randazza.com
jmd@Randazza.com
7001 W. Charleston Boulevard, # 1043
Las Vegas, NV 89117
Telephone: 888-667-1113
Facsimile: 305-437-7662
www.Randazza.com

Attorneys for Defendant,
Wayne Hoehn


UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA

RIGHTHAVEN, LLC, a Nevada limited liability
company,

Plaintiff,

vs.

WAYNE HOEHN, an individual,

Defendant.
Case No. 2:11-cv-00050

DEFENDANT’S APPLICATION FOR
ORDER SCHEDULING JUDGMENT
DEBTOR EXAMINATION


DEFENDANT’S APPLICATION FOR ORDER SCHEDULING JUDGMENT DEBTOR
EXAMINATION
Defendant Wayne Hoehn (“Hoehn”), through his attorneys, brings this motion seeking
this Court, in light of its writ of execution entered against Plaintiff Righthaven LLC
(“Righthaven”) (Doc. # 59) on November 1, 2011, to Order limited discovery as set forth below
pursuant to Rule 69 and Local Rule IB 1-9(k). In order to fully recover Righthaven’s assets,
Hoehn must first apprehend where they have gone, as Righthaven’s counsel has stated that
Righthaven is nearing bankruptcy (Doc. # 52-1). As such, Hoehn requests a copy of
Righthaven’s financial records, and a debtor’s examination of two Righthaven officers – Steven
Gibson, Righthaven’s Chief Executive Officer, and Raisha Y. Gibson - also known as “Drizzle”
Gibson - Righthaven’s Chief Administrative Officer, to ascertain the location of Righthaven’s
Case 2:11-cv-00050-PMP -RJJ Document 60 Filed 11/06/11 Page 1 of 6

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Randazza
Legal Group
7001 W Charleston Blvd
#1043
Las Vegas, NV 89117
(888) 667-1113

assets. Pursuant to Local Rule IB 1-9(k), this examination shall be conducted under the authority
of a Magistrate Judge.
On November 1, 2011, this Court entered a writ of execution to Hoehn, against
Righthaven, in the sum of $63,720.80. (Doc. # 59.) Hoehn has filed writs of execution with the
U.S. Marshals to begin seizing Righthaven’s financial assets. To date, Hoehn has not recovered
any portion of his judgment. To aid in his discovery and acquisition of assets, however, Hoehn
seeks to receive information from Righthaven and depose two of its officers in order to satisfy
his judgment. (DeVoy Decl. ¶¶ 3-8.) Federal Rule of Civil Procedure 69(a)(2) contemplates this
procedure and states as follows:

In aid of the judgment or execution, the judgment creditor […] may obtain
discovery from any person — including the judgment debtor — as provided in
these rules or by the procedure of the state where the court is located.
Steven Gibson, as the Chief Executive Officer of Righthaven, signatory of the company’s
Operating Agreement,
1
and signer of the Strategic Alliance Agreement with Stephens Media
LLC, has knowledge of the company’s financial and other assets, and their whereabouts. (DeVoy
Decl. ¶¶ 3-4.) Similarly, Raisha Gibson is likely to know about Righthaven’s financial accounts
based on her position and responsibilities as Righthaven’s Chief Administrative Officer. (Exh. A;
DeVoy Decl. ¶¶ 5-9.) Raisha Gibson had, and likely still has, power to act on Righthaven’s
behalf as its Chief Administrative Officer, representing Righthaven in transactions with the U.S.
Patent and Trademark Office and very likely in many other business dealings. (Exh. B at 2)
Both Raisha and Steven Gibson will likely have direct knowledge of information regarding
suspected fraudulent transfers of funds from Righthaven to third parties, including themselves,
effected in order to evade payment of the lawful judgment rendered by this Honorable Court.
(DeVoy Decl. ¶¶ 13-14.)
Righthaven’s prior conduct before this district, and the conduct of its executive
individually in other matters, reveals a manifest need for any debtors exam to be refereed by a

1
See Righthaven v. DiBiase, Case No. 2:10-cv-01343 (Doc. # 51) (D. Nev. Apr. 17, 2011). (containing a redacted
version of Righthaven’s operating agreement).
Case 2:11-cv-00050-PMP -RJJ Document 60 Filed 11/06/11 Page 2 of 6

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Randazza
Legal Group
7001 W Charleston Blvd
#1043
Las Vegas, NV 89117
(888) 667-1113

magistrate judge. In Righthaven v. Democratic Underground, the defendants had considerable
difficulty obtaining discovery from Righthaven and its counsel. Case No. 2:10-cv-01356 (Doc.
96 ¶¶ 19-29) (D. Nev. Apr. 28, 2011) The experience of defense counsel in that case – trying to
get answers out of an unresponsive plaintiff – closely resembles the experience Hoehn had when
attempting to negotiate Righthaven’s fee liability in good faith. (Doc. # 32-2 ¶¶ 14-18), and the
difficulties incurred by counsel in Righthaven v. Leon et al., Case No. 2:10-cv-01672 (Doc. # 42-
2 ¶¶ 18-23) (D. Nev. May 3, 2011).
This conduct is not isolated to Righthaven, but appears endemic to the litigation strategy
of Steven Gibson, its CEO. In March of 2011, Gibson was held jointly and severally liable
within this District for sanctions in excess of $6,000, stemming from misconduct during a
deposition, including “numerous inappropriate objections,” which was not “substantially
justified.” Kabins Family LLC v. Chain Consortium, Inc., Case No. 2:09-cv-01125 (Doc. # 333
at 1-2) (D. Nev. Mar. 29, 2011). The court, in disbelief, characterized one of Gibson’s
explanations for his voluminous objections as “amazing.” Kabins Family LLC, (Doc. # 275 at
15:19-21) (D. Nev. Apr. 27, 2010) (addressing Mr. Gibson: “Amazing. Did that end up on the
record, my comment, amazing, ‘cause that’s my comment to that whole discussion. Why don’t
you be seated”). Ultimately, Judge Navarro admonished Mr. Gibson’s conduct, further ordering
that the magistrate judge would oversee further depositions of Mr. Gibson’s client. Kabins
Family LLC, (Doc. # 314 at 22-25) (D. Nev. July 28, 2010) (“From the beginning, it was clear
that Mr. Gibson was prepared to be combative”). It is no idle speculation that such conduct,
between Gibson and his wife (DeVoy Decl. ¶ 3), would be guaranteed in a wasteful private
deposition where sensitive financial information about the company for which they both worked
was at stake, culminating in a seizure of its assets.
These risks need not be taken where Local Rule IB 1-9(k) allows magistrate judge
participation. Having the Court’s immediate sanction powers available will compel candid,
immediate answers, rather than more dilatory conduct requiring further motion practice –
seeking sanctions for Righthaven’s misconduct during these depositions – to curtail. Conducting
Case 2:11-cv-00050-PMP -RJJ Document 60 Filed 11/06/11 Page 3 of 6

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Randazza
Legal Group
7001 W Charleston Blvd
#1043
Las Vegas, NV 89117
(888) 667-1113

the examination before a magistrate will create a clear public record of Righthaven’s financial
condition for Hoehn to act upon in seizing assets through the U.S. Marshals.
Moreover, the media attention Righthaven’s litigation campaign has received makes the
Plaintiff’s precarious financial condition (see Doc. # 52-1) a matter of public interest, as the
technology and media communities have great interest in knowing what became of settlement
funds earned by the “Nation’s Pre-Eminent Copyright Enforcer.”
2
Righthaven has established a
pattern of delaying not only discovery, but the payment of fees as well. (Docs. # 52, 57). Further
stalling is intolerable when Hoehn is entitled to begin collecting his judgment, and must
determine how to best focus his search.
Pursuant to Rule 27, the last known addresses of the debtor representatives to be
examined are as follows:

Steven A. Gibson
c/o Dickinson Wright PLLC
7201 W. Lake Mead Boulevard, Suite 503
Las Vegas, NV 89128

Raisha “Drizzle” Y. Gibson
7278 Silver Charm Court
Las Vegas, NV 89131
3

In addition to seeking examinations of the above-named representatives, Hoehn seeks the
production of all documents and information identifying, related to, and/or comprising the
following:
1. Any and all information and documentation identifying real property, vehicles,
bank accounts, bank deposits, company securities, intangible intellectual property
and all other assets that may be available for execution to satisfy this Court’s
judgment and writ of execution, including money owed to Judgment Debtor by
others, etc.

2
See Righthaven.com.
3
This address is the last known address of Ms. Gibson, as Righthaven does not appear to actively use its S. Pecos
Road address any longer. Disclosure of this last known address is compelled by Rule 27.
Case 2:11-cv-00050-PMP -RJJ Document 60 Filed 11/06/11 Page 4 of 6

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Randazza
Legal Group
7001 W Charleston Blvd
#1043
Las Vegas, NV 89117
(888) 667-1113

2. Any and all information and documentation identifying purchases, transfers of
funds, or other dissipation of assets from Righthaven to yourselves or any other
third parties commencing on or about April 15, 2011, when Righthaven’s SAA
was unsealed in the Democratic Underground case.
Hoehn requests the discovered specified above in order to satisfy his judgment as allowed
by Rule 69, and for no other purpose. In this case, magistrate participation in the debtor exam is
necessary and proper, and will promote judicial economy by obviating the need for any sanctions
motion arising from a deposition of Righthaven’s officers.

Dated November 6, 2011 Respectfully Submitted,
RANDAZZA LEGAL GROUP













Marc J. Randazza
J. Malcolm DeVoy IV

Attorneys for Defendant,
Wayne Hoehn
Case 2:11-cv-00050-PMP -RJJ Document 60 Filed 11/06/11 Page 5 of 6

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Randazza
Legal Group
7001 W Charleston Blvd
#1043
Las Vegas, NV 89117
(888) 667-1113


CERTIFICATE OF SERVICE
Pursuant to Federal Rule of Civil Procedure 5(b), I hereby certify that I am a
representative of Randazza Legal Group and that on this 6th day of November, 2011, I caused
the document(s) entitled:

DEFENDANT’S APPLICATION FOR ORDER SCHEDULING JUDGMENT DEBTOR
EXAMINATION


and all attachments to be served as follows:

[ ] Pursuant to Fed. R. Civ. P. 5(b)(2)(D), to be sent via facsimile as indicated; and/or

[ X ] by the Court’s CM/ECF system.

/s/ J. Malcolm DeVoy
J. Malcolm DeVoy

Case 2:11-cv-00050-PMP -RJJ Document 60 Filed 11/06/11 Page 6 of 6

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Randazza
Legal Group
7001 W Charleston Blvd
#1043
Las Vegas, NV 89117
(888) 667-1113


Marc J. Randazza (Admitted Pro Hac Vice)
J. Malcolm DeVoy IV (Nevada Bar No. 11950)
RANDAZZA LEGAL GROUP
mjr@Randazza.com
jmd@Randazza.com
7001 W. Charleston Boulevard, # 1043
Las Vegas, NV 89117
Telephone: 888-667-1113
Facsimile: 305-437-7662
www.Randazza.com

Attorneys for Defendant,
Wayne Hoehn


UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA

RIGHTHAVEN, LLC, a Nevada limited liability
company,

Plaintiff,

vs.

WAYNE HOEHN, an individual,

Defendant.
Case No. 2:11-cv-00050

DECLARATION OF J. MALCOLM
DEVOY IN SUPPORT OF
DEFENDANT’S APPLICATION FOR
ORDER SCHEDULING JUDGMENT
DEBTOR EXAMINATION


DECLARATION OF J. MALCOLM DEVOY IN SUPPORT OF DEFENDANT’S
APPLICATION FOR ORDER SCHEDULING JUDGMENT DEBTOR EXAMINATION
I, J. Malcolm DeVoy, having personal knowledge of the matters set forth below, state as follows:
1. I am counsel of record for Wayne Hoehn in this matter, an attorney for Randazza
Legal Group and a duly licensed attorney in the state of Nevada, in good standing with its bar.
2. I have undertaken research and investigation of Righthaven’s assets in order to
satisfy Wayne Hoehn’s judgment and writ of execution in this case.
3. My research indicates that the Chief Executive Officer (“CEO”) of Righthaven
LLC (“Righthaven”) is married to Raisha Y. Gibson, also known as Drizzle Gibson,
1

Righthaven’s Chief Administrative Officer.

1
In my observations, Ms. Gibson uses the alias “Drizzle.” No other aliases are known for her at this time.
Case 2:11-cv-00050-PMP -RJJ Document 60-1 Filed 11/06/11 Page 1 of 4

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Randazza
Legal Group
7001 W Charleston Blvd
#1043
Las Vegas, NV 89117
(888) 667-1113

4. As CEO of Righthaven, Mr. Gibson is likely to be aware of Righthaven’s
financial relationships with banks, individuals with whom Righthaven has settled, or by whom
Righthaven is otherwise owed money, the location of Righthaven’s financial assets, and/or
whom to contact for that information.
5. On March 29, 2011, I received an e-mail from Ms. Gibson related to a Righthaven
matter. A true and correct redacted version of this e-mail is attached hereto as Exhibit A.
6. Moreover, Ms. Gibson identified herself as the Chief Administrative Officer of
Righthaven in an attorney revocation/appointment order filed with the U.S. Patent and
Trademark Office on February 2, 2011.
7. This revocation/appointment order is a public document, and a true and correct
copy is attached hereto as Exhibit B.
8. As the Chief Administrative Officer, Ms. Gibson’s signature has appeared on at
least one of Righthaven’s checks, which I have personally seen, for the amount of $3,815.00 and
dated July 20, 2011.
9. As the Chief Administrative Officer, Ms. Gibson is likely to have more detailed
information about Righthaven’s assets, day-to-day function, and other information important for
the execution of the judgment in this case.
10. My research indicates that Righthaven employees are infrequently, if ever, at the
company’s 4475 S. Pecos Road address.
11. Background and research I performed leads me to believe that the best addresses
for contacting Mr. and Ms. Gibson are as follows:

Steven A. Gibson
c/o Dickinson Wright PLLC
7201 W. Lake Mead Boulevard, Suite 503
Las Vegas, NV 89128

Raisha Y. Gibson (a/k/a Drizzle Gibson)
7278 Silver Charm Court
Las Vegas, NV 89131
Case 2:11-cv-00050-PMP -RJJ Document 60-1 Filed 11/06/11 Page 2 of 4

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Randazza
Legal Group
7001 W Charleston Blvd
#1043
Las Vegas, NV 89117
(888) 667-1113

12. Examination of both Righthaven officers is reasonably necessary to find all assets
that may be seized in satisfaction of Hoehn’s judgment and writ of execution.
13. As Mr. and Ms. Gibson are the sole remaining known officers of Righthaven, and
as such have knowledge of Righthaven’s financial transfers to third parties and other insiders,
including themselves.
14. As the Righthaven Operating Agreement indicates, though in redacted form, that
Mr. Gibson receives a salary from Righthaven
2
– but the offices have been rarely used for a
significant period of time – these salary payments likely constitute fraudulent transfers to
frustrate judgment recovery by Hoehn and other prevailing defendants.
15. Based on the conduct of Righthaven in this litigation and related cases, and the
conduct of CEO Steven Gibson in other matters, particularly Kabins Family LLC v. Chain
Consortium, Inc., Case No. 2:09-cv-01125 (Doc. # 333 at 1-2) (D. Nev. Mar. 29, 2011), I believe
any examination undertaken outside the jurisdiction of a magistrate judge will be uneconomical,
a waste of Hoehn’s resources.
16. I further believe, based on the above-referenced conduct, that Righthaven’s
conduct would result in further wasting of judicial resources, as Hoehn would be forced to seek
sanctions against Righthaven for its abusive conduct, then re-depose the debtor’s representatives.
17. I believe that conducting a debtor’s examination in the presence of a magistrate
judge under Local Rule IB 1-9(k) will ultimately conserve judicial resources and assist Hoehn –
and the Court – in efficiently discerning the whereabouts of Righthaven’s assets, so they may be
seized in satisfaction of the judgment and writ of execution.
18. Based on Righthaven’s prior conduct in this litigation, I certify that the parties
will not be able to resolve this dispute without Court action, and have taken good faith efforts to

2
See Righthaven v. DiBiase, Case No. 2:10-cv-01343 (Doc. # 51) (D. Nev. Apr. 17, 2011) (containing a redacted
copy of Righthaven’s operating agreement).
Case 2:11-cv-00050-PMP -RJJ Document 60-1 Filed 11/06/11 Page 3 of 4

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Randazza
Legal Group
7001 W Charleston Blvd
#1043
Las Vegas, NV 89117
(888) 667-1113

resolve this dispute prior to it reaching this point. Further efforts to engage Righthaven will
waste time and be futile.
19. On November 4, I left a voice mail with Righthaven’s counsel seeking to discuss
Hoehn’s writ of execution and how the U.S. Marshals would enforce it.
20. On November 4, I also sent Mr. Mangano a letter regarding this motion, seeking
to enter a stipulation for a debtors examination before the magistrate judge without motion
practice.
21. I have regularly had e-mail exchanges and phone calls with Righthaven’s counsel
at late hours and outside of the normal business week, and determined based on prior filings and
correspondence from Righthaven’s counsel, that this correspondence would not be unfair, nor
prejudicial.
22. On November 5, I once again contacted Righthaven’s counsel, seeking to resolve
this issue informally, obviating the need for motion practice, but received no response.

I declare under penalty of perjury that the foregoing is true and correct to the best of my
knowledge.

Dated November 6, 2011
/s/ J. Malcolm DeVoy
J. Malcolm DeVoy

Case 2:11-cv-00050-PMP -RJJ Document 60-1 Filed 11/06/11 Page 4 of 4

EXHIBIT A
Case 2:11-cv-00050-PMP -RJJ Document 60-2 Filed 11/06/11 Page 1 of 3
From: Raisha Gibson <RGibson@righthaven.com>
Subject: Timothy Daniel
Date: March 29, 2011 4:41:37 PM PDT
To: "J. Malcolm DeVoy Esq. (jmd@randazza.com)" <jmd@randazza.com>
Cc: Steve Gibson <SGibson@righthaven.com>, Steven Ganim <SGanim@righthaven.com>
4 Attachments, 1.2 MB
uear Mr. uevoy:

ln connecLlon wlLh Lhe above-referenced maLLer, please flnd correspondence from me along wlLh a correspondlng enclosure.

Þlease conLacL me lf you have any quesLlons. 1hank you.

8esL regards,

Raisha Y. ("Drizzle") Gibson
Chief Administrative Officer

Conquistador Business Park
9960 West Cheyenne Avenue, Suite 210
Las Vegas, Nevada 89129
Direct: (702) 541-6400
Cell: (702) 308-7007
Main: (702) 527-5900
Fax: (702) 527-5909
E-mail: rgibson@righthaven.com

!
!
!"#$%$&'()!**+,
CONQLI$TADOR BL$INE$$ PARK
9960 WE$T CHEYENNE AVENLE, $LITE 210
LA$ VEOA$, NEVADA 89129
TELEPHONE 702.527.5900 FAC$IMILE 702.527.5909
!
Writer's Electronic Mail. Writer's Direct Dial.
r¸ibson©ri¸hthaven.com (702) 5+1·6+00

March 29, 2011

Via E-mail & U.S. Mail

J. Michael DeVoy, Esq.
Randazza Legal Group
1027 South Rainbow Boulevard, Suite 306
Las Vegas, Nevada 89145

Re: Timothy Daniel

Dear Mr. DeVoy:

In connection with the above-referenced matter, please find transmitted herewith a fully-
executed original Settlement Agreement for your files.

If you have any questions regarding the foregoing, please do not hesitate to contact me.

Best regards,

!"#$%$&'()!!**+,


/s/
Raisha Y. (“Drizzle”) Gibson
Chief Administrative Officer

RYG/hs

Enclosure

cc: Mr. Steven A. Gibson
Steven A. Ganim, Esq.
Case 2:11-cv-00050-PMP -RJJ Document 60-2 Filed 11/06/11 Page 2 of 3
!
!
!"#$%$&'()!**+,
CONQLI$TADOR BL$INE$$ PARK
9960 WE$T CHEYENNE AVENLE, $LITE 210
LA$ VEOA$, NEVADA 89129
TELEPHONE 702.527.5900 FAC$IMILE 702.527.5909
!
Writer's Electronic Mail. Writer's Direct Dial.
r¸ibson©ri¸hthaven.com (702) 5+1·6+00

March 29, 2011

Via E-mail & U.S. Mail

J. Michael DeVoy, Esq.
Randazza Legal Group
1027 South Rainbow Boulevard, Suite 306
Las Vegas, Nevada 89145

Re: Timothy Daniel

Dear Mr. DeVoy:

In connection with the above-referenced matter, please find transmitted herewith a fully-
executed original Settlement Agreement for your files.

If you have any questions regarding the foregoing, please do not hesitate to contact me.

Best regards,

!"#$%$&'()!!**+,


/s/
Raisha Y. (“Drizzle”) Gibson
Chief Administrative Officer

RYG/hs

Enclosure

cc: Mr. Steven A. Gibson
Steven A. Ganim, Esq.
Timothy Dan….pdf (1.1 MB)
Case 2:11-cv-00050-PMP -RJJ Document 60-2 Filed 11/06/11 Page 3 of 3

EXHIBIT B
Case 2:11-cv-00050-PMP -RJJ Document 60-3 Filed 11/06/11 Page 1 of 5
PTO Form 2196 (Rev 9/2005)
OMB No. 0651-0056 (Exp 09/30/2011)
Revocation of Attorney/Domestic Representative and/or
Appointment of Attorney/Domestic Representative
The table below presents the data as entered.
Input Field Entered
SERIAL NUMBER 77924076
LAW OFFICE ASSIGNED LAW OFFICE 103
MARK SECTION
MARK
RIGHTHAVEN
ATTORNEY SECTION
ORIGINAL ADDRESS
Steven A. Gibson
Dickinson Wright PLLC
1619-001
1875 Eye Street, NW, Suite 1200
Washington DC 20006
702.541.7888
202.659.1559
Trademark@dickinsonwright.com
NEW ATTORNEY ADDRESS
STATEMENT TEXT
By submission of this request, the undersigned
REVOKES the power of attorney currently of record,
as listed above, and hereby APPOINTS the following
new attorney.
NAME
Anne E. Pieroni, Esq.
FIRM NAME
Righthaven LLC
STREET
9960 West Cheyenne Avenue, Suite 210
CITY
Las Vegas
STATE
Nevada
COUNTRY
United States
POSTAL/ZIP CODE
89129
PHONE
(702) 527-5900
FAX
(702) 527-5909
Case 2:11-cv-00050-PMP -RJJ Document 60-3 Filed 11/06/11 Page 2 of 5
EMAIL
rgibson@righthaven.com
ATTORNEY AUTHORIZED TO
COMMUNICATE VIA E-MAIL
YES
NEW CORRESPONDENCE ADDRESS
NAME
Anne E. Pieroni, Esq.
FIRM NAME
Righthaven LLC
STREET
9960 West Cheyenne Avenue, Suite 210
CITY
Las Vegas
STATE
Nevada
COUNTRY
United States
POSTAL/ZIP CODE
89129
PHONE
(702) 527-5900
FAX
(702) 527-5909
EMAIL
rgibson@righthaven.com
AUTHORIZED TO COMMUNICATE
VIA E-MAIL
YES
SIGNATURE SECTION
SIGNATURE
/Raisha Y. Gibson/
SIGNATORY NAME
Raisha Y. Gibson
SIGNATORY DATE
02/02/2011
SIGNATORY POSITION
Chief Administrative Officer
FILING INFORMATION SECTION
SUBMIT DATE
Wed Feb 02 15:14:58 EST 2011
TEAS STAMP
USPTO/RAA-24.253.69.70-20
110202151458674828-779240
76-4808de988a9326d6a29781
06ba6b74c5cef-N/A-N/A-201
10202150421794295
Case 2:11-cv-00050-PMP -RJJ Document 60-3 Filed 11/06/11 Page 3 of 5
PTO Form 2196 (Rev 9/2005)
OMB No. 0651-0056 (Exp 09/30/2011)
Revocation of Attorney/Domestic Representative and/or
Appointment of Attorney/Domestic Representative
To the Commissioner for Trademarks:
MARK: RIGHTHAVEN
SERIAL NUMBER: 77924076
The original attorney
Steven A. Gibson
Dickinson Wright PLLC
1619-001
1875 Eye Street, NW, Suite 1200
Washington DC 20006
702.541.7888
202.659.1559
Trademark@dickinsonwright.com
Original Correspondence Address :
Steven A. Gibson
Dickinson Wright PLLC
1875 Eye Street, NW, Suite 1200
Washington DC 20006
702.541.7888
202.659.1559
Trademark@dickinsonwright.com
By submission of this request, the undersigned REVOKES the power of attorney currently of record, as
listed above, and hereby APPOINTS the following new attorney.
Newly Appointed Attorney:
Anne E. Pieroni, Esq.
Righthaven LLC
9960 West Cheyenne Avenue, Suite 210
Las Vegas, Nevada 89129
United States
(702) 527-5900
(702) 527-5909
rgibson@righthaven.com
The following is to be used as the correspondence address:
Anne E. Pieroni, Esq.
Righthaven LLC
9960 West Cheyenne Avenue, Suite 210
Las Vegas, Nevada 89129
Case 2:11-cv-00050-PMP -RJJ Document 60-3 Filed 11/06/11 Page 4 of 5
United States
(702) 527-5900
(702) 527-5909
rgibson@righthaven.com
Signature: /Raisha Y. Gibson/ Date: 02/02/2011
Signatory's Name: Raisha Y. Gibson
Signatory's Position: Chief Administrative Officer
Serial Number: 77924076
Internet Transmission Date: Wed Feb 02 15:14:58 EST 2011
TEAS Stamp: USPTO/RAA-24.253.69.70-20110202151458674
828-77924076-4808de988a9326d6a2978106ba6
b74c5cef-N/A-N/A-20110202150421794295
Case 2:11-cv-00050-PMP -RJJ Document 60-3 Filed 11/06/11 Page 5 of 5

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Randazza
Legal Group
7001 W Charleston Blvd
#1043
Las Vegas, NV 89117
(888) 667-1113


Marc J. Randazza (Admitted Pro Hac Vice)
J. Malcolm DeVoy IV (Nevada Bar No. 11950)
RANDAZZA LEGAL GROUP
mjr@Randazza.com
jmd@Randazza.com
7001 W. Charleston Boulevard, # 1043
Las Vegas, NV 89117
Telephone: 888-667-1113
Facsimile: 305-437-7662
www.Randazza.com

Attorneys for Defendant,
Wayne Hoehn


UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA

RIGHTHAVEN, LLC, a Nevada limited liability
company,

Plaintiff,

vs.

WAYNE HOEHN, an individual,

Defendant.
Case No. 2:11-cv-00050

PROPOSED ORDER GRANTING
DEFENDANT’S APPLICATION FOR
ORDER SCHEDULING JUDGMENT
DEBTOR EXAMINATION AND TO
PRODUCE DOCUMENTS


PROPOSED ORDER GRANTING DEFENDANT’S APPLICATION FOR ORDER
SCHEDULING JUDGMENT DEBTOR EXAMINATION AND TO PRODUCE
DOCUMENTS
Pursuant to the Application of Wayne Hoehn for issuance of this Court’s Order
Scheduling Judgment Debtor Examination before the magistrate judge under LR IB 1-9, and
production of documents, and good cause shown, it is hereby ORDERED that Steven A. Gibson
and Raisha “Drizzle” Y. Gibson shall personally appear before this Court on , 2011,
at .m., and provide testimony under oath concerning the location of Righthaven’s
assets. Both representatives of Righthaven shall be examined with regard to the extent and
location of Righthaven’s assets that may be available to Hoehn for the purpose of satisfying this
Court’s Judgment (Doc. # 44) and Writ of Execution (Doc. # 59).
Case 2:11-cv-00050-PMP -RJJ Document 60-4 Filed 11/06/11 Page 1 of 2

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Randazza
Legal Group
7001 W Charleston Blvd
#1043
Las Vegas, NV 89117
(888) 667-1113

At least one (1) calendar week before the above-scheduled examination, Righthaven shall
produce the following documents to Hoehn through his counsel:
Any and all information and documentation identifying real property, vehicles, bank
accounts, bank deposits, company securities, intangible intellectual property and all other
assets that may be available for execution to satisfy this Court’s judgment and writ of
execution, including money owed to Judgment Debtor by others, and other information of
the like;
And
Any and all information and documentation identifying purchases, transfers of funds, or
other dissipation of assets from Righthaven to yourselves or any other third parties
commencing on or about April 15, 2011.
Should Righthaven fail or refuse to cause Steven Gibson and/or Raisha Gibson to appear
at the examination herein scheduled, or to produce documents referred to above, this Court may
adjudicate Righthaven guilty of civil contempt of its orders. The Court may issue warrants or
seizure orders to compel compliance with this Order. In the event that either deponent fails to
attend, this Court will issue writs of bodily attachment and instruct the U.S. Marshalls to use
reasonable force to compel their attendance.

IT IS SO ORDERED





U.S. DISTRICT COURT JUDGE

DATE:
Case 2:11-cv-00050-PMP -RJJ Document 60-4 Filed 11/06/11 Page 2 of 2

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