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Message: Nelson Bumgardner P.C., Albritton Law Firm, Hoge Law Firm and Silicon Valley Law Group's Notice of Motion and Motion to Withdraw as Counsel of Record

Nelson Bumgardner P.C., Albritton Law Firm, Hoge Law Firm and Silicon Valley Law Group's Notice of Motion and Motion to Withdraw as Counsel of Record

posted on Jul 17, 2017 01:23AM

I couldn't get the actual Pacer to save.. but here is the gist...

PLEASE TAKE NOTICE that on Thursday, August 17, 2017, at 10:00 A.M., or as soon thereafter (or before) as the matter may be heard before the Honorable Vince Chhabria, United States District Judge, of the United States District Court for the Northern District of California, San Francisco Division, 450 Golden Gate Avenue, Courtroom 4 – 17th Floor, San Francisco, CA 94102, Nelson Bumgardner P.C. and its attorneys (including Edward R. Nelson, III, Brent Nelson Bumgardner, Barry J. Bumgardner, Thomas Christopher Cecil, and John Murphy), of Nelson Bumgardner P.C., 3131 West 7th St., Fort Worth, Texas 76107; Albritton Law Firm and its attorneys (including Eric M. Albritton), of Albritton Law Firm, P.O. Box 2649, Longview, TX 75606; Hoge Law Firm and its attorneys (including Charles T. Hoge), of Hoge Law Firm, 888 Prospect Street, Suite 200, La Jolla, CA 92037; and Silicon Valley Law Group and its attorneys (including William L. Bretschneider), of Silicon Valley Law Group, 50 W. San Fernando Street, Case 3:12-cv-03865-VC Document 127 Filed 07/13/17 Page 2 of 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NOTICE OF MOTION AND MOTION TO 3 CASE NOS. 12-cv-03865-VC, -03876-VC, WITHDRAW AS COUNSEL FOR PLAINTIFFS -03877-VC, -03880-VC, -03881-VC Suite 750 San Jose, California 95113 shall and hereby do respectfully seek leave of this Court pursuant to Northern District Local Rule 11-5(a) and in compliance with California Rules of Professional Conduct 3-700, to withdraw as attorneys of record for plaintiffs, Phoenix Digital Solutions LLC, Patriot Scientific Corporation, and Technology Properties Limited LLC, respectively.

Plaintiffs filed the complaints in the above-captioned suits on July 24, 2012. There is no trial set in this matter, no discovery is outstanding, and there are no other motions currently pending. Defendants are scheduled to file a summary judgment motion on August 1, 2017 (but this motion has not been filed at this time). Plaintiffs do not oppose Movants’ Motion. Johnson PDL Decl. at 2; Johnson PSC Decl. at 2; Brown TPL Decl. at 2. Movants have provided written notice to both Plaintiffs and Defendants. Bumgardner Decl. at 2. Plaintiffs are in the process of retaining new counsel. Johnson PDL Decl. at 3; Johnson PSC Decl. at 3; Brown TPL Decl. at 3. Plaintiffs have been notified of the requirement that papers may continue to be served on counsel for forwarding purposes until Plaintiffs retain new counsel. Bumgardner Decl. at 3. Defendants, with whom Movants have conferred, do not oppose this motion. Id. at 4. Moreover, as to prejudice, Movants/Plaintiffs have conferred with counsel for Defendants, and Defendants have agreed to not oppose Plaintiffs’ motion for a sixty day stay of the litigation

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