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Message: PACER

05/12/2010

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Unopposed MOTION to Withdraw as Attorney and for Substitution by Defendant VTech Electronics North America, LLC. (Attachments: # 1 Proposed Order (PDF Only))(Nuttall, James) (Entered: 05/12/2010)

VTech Electronics North America, LLC (“VTech”) hereby moves to substitute Richard
E. Dick, James R. Nuttall and Daniel S. Stringfield of the law firm McAndrews, Held &
Malloy, Ltd. and Bruce A. Featherstone and Matthew D. Collins of the law firm Featherstone Petrie DeSisto LLP as its counsel in this litigation. Richard D. Harris, Howard E. Silverman, Kevin J. O’Shea, Eric J. Maiers, and Srecko Vidmar of Greenberg Traurig, LLP, hereby move to withdraw as counsel for VTech.

The relief requested herein is unopposed.

Certificate of Compliance with D.C.COLO.LCivR. 7.1(A)
Counsel for VTech conferred in good faith with counsel for plaintiff e.Digital
Corporation regarding the relief requested in this Motion. Plaintiff does not oppose the relief requested.

GROUNDS FOR MOTION
1. VTech respectfully moves the Court to substitute Richard E. Dick, James R.
Nuttall and Daniel S. Stringfield of the law firm McAndrews, Held & Malloy, Ltd. and Bruce A. Featherstone and Matthew D. Collins of the law firm Featherstone Petrie DeSisto LLP as its counsel in this litigation. VTech seeks this substitution of counsel as part of its consolidation of various legal matters.


2. Pursuant to D.C.COLO.LCivR 83.3(D), and at the request of VTech, the
undersigned counsel from the law firm Greenberg Traurig, LLP, hereby notifies all counsel of record and VTech of its withdrawal, and respectfully moves the Court for leave to withdraw, as counsel for VTech. Pursuant to Local Rule 83.3(D), such counsel hereby advises VTech that it is responsible for complying with all court orders and time limitations established by any applicable rules; that it cannot appear without counsel admitted to practice before this Court; and that absent prompt appearance of substitute counsel, pleadings, motions, and other papers may be stricken, and default judgment or other sanctions entered against it. VTech has arranged to comply with these requirements and all other court requirements and case deadlines through its
retention and substitution of counsel from McAndrews, Held & Malloy, Ltd. and Featherstone Petrie DeSisto LLP, to represent and defend it in this litigation.

3. The relief requested in this Motion will not delay or otherwise prejudice this
proceeding. VTech has been an active participant in these proceedings and is in compliance with all court requirements and deadlines. Counsel from Featherstone Petrie DeSisto LLP is actively serving as local counsel for other defendants in this litigation and is fully aware of and will comply with all court deadlines, settings and requirements. Counsel from McAndrews, Held & Malloy, Ltd. likewise is fully aware of and intends to comply with such deadlines, settings and requirements. Mr. Nuttall of the McAndrews, Held & Malloy firm and Matthew Collins of the Featherstone Petrie DeSisto firm will appear in person on behalf of VTech at the status conference set in this matter for May 13, 2010 at 1:30 p.m.


4. VTech is aware of this Motion and specifically has authorized its filing. Counsel
has served a copy of this Motion on the designated client representative for VTech.


5. A proposed form of order granting the stipulated relief requested herein is
attached hereto for review and entry.


WHEREFORE, VTech and the undersigned counsel respectfully move for entry of the
relief requested herein.

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