Global Touch Solutions, LLC v. Apple Inc.

MOTION to Withdraw as Counsel for Plaintiff

N.D. Cal.October 4, 2016

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 MOTION FOR LEAVE TO WITHDRAW AS COUNSEL FOR PLAINTIFF 1 Case Nos. 3:15cv2746, -2747, -2748, -2749, -2750-JD Wilson W. Lin (Bar No. 302228) wlin@park-law.com H. C. PARK & ASSOCIATES, PLC 1894 Preston White Drive Reston, VA 20191 Telephone: (703) 544-9230 Facsimile: (703) 288-5139 Attorney for Plaintiff GLOBAL TOUCH SOLUTIONS, LLC UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION GLOBAL TOUCH SOLUTIONS, LLC, Plaintiff, v. TOSHIBA CORPORATION, et al., Defendants. Case Nos. 3:15cv2746-JD 3:15cv2747-JD 3:15cv2748-JD 3:15cv2749-JD 3:15cv2750-JD NOTICE OF MOTION AND MOTION FOR LEAVE TO WITHDRAW AS COUNSEL FOR PLAINTIFF; [PROPOSED] ORDER GRANTING MITON TO WITHDRAW Date: November 9, 2016 Time: 10:00 a.m. Courtroom: 11, 19th Floor, San Francisco Judge: Hon. James Donato GLOBAL TOUCH SOLUTIONS, LLC, Plaintiff, v. VIZIO, INC., Defendant. GLOBAL TOUCH SOLUTIONS, LLC, Plaintiff, v. APPLE INC., Defendant. Case 3:15-cv-02748-JD Document 74 Filed 10/04/16 Page 1 of 4 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 [PROPOSED] ORDER GRANTING MOTION TO WITHDRAW AS COUNSEL FOR PLAINTIFF 2 CASE NOS. 3:15cv2746, -2747, -2748, -2749, -2750-JD GLOBAL TOUCH SOLUTIONS, LLC, Plaintiff, v. MOTOROLA MOBILITY LLC, Defendant. GLOBAL TOUCH SOLUTIONS, LLC, Plaintiff, v. MICROSOFT CORPORATION, et al., Defendants. NOTICE OF MOTION AND MOTION TO THE PARTIES AND THEIR COUNSEL OF RECORD: PLEASE TAKE NOTICE that, on Wednesday, November 9, 2016, at 10:00 am, or as soon thereafter as the matter may be heard before the Honorable James Donato, United States District Judge, Courtroom 11, 19th Floor, of the United States District Court for the Northern District of California, San Francisco Division, 450 Golden Gate Avenue, San Francisco, California 94102, Wilson W. Lin of H.C. Park & Associates, PLC, 1894 Preston White Drive, Reston, Virginia 20191, shall and hereby does respectfully seek leave of this Court, pursuant to Civil Local Rule 11-5(a) and (b) and in compliance with California Rules of Professional Conduct 3-700, to withdraw as counsel for Plaintiff Global Touch Solutions, LLC (“Plaintiff”). MOTION TO WITHDRAW AS COUNSEL FOR PLAINTIFF Pusuant to Local Rule 11-5, Wilson W. Lin (“Movant”) hereby notifies the parties and the Court of its intent to withdraw as counsel for Plaintiff. Movant states the following grounds for this notice and motion: 1. On June 30, 2015, Movant entered his appearance on behalf of Plaintiff in the above matters. Case 3:15-cv-02748-JD Document 74 Filed 10/04/16 Page 2 of 4 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 [PROPOSED] ORDER GRANTING MOTION TO WITHDRAW AS COUNSEL FOR PLAINTIFF 3 CASE NOS. 3:15cv2746, -2747, -2748, -2749, -2750-JD 2. On April 7, 2016, Order Staying and Administratively Closing Cases was issued ordering the above cases to be administratively closed. 3. On May 9, 2016, Movant provided Plaintiff with notice of his intent to withdraw. 4. Movant respectfully submits that withdrawal is permissible because continued representation will result in an unreasonable financial burden on Movant. 5. The granting of this Motion imposes no delay and will not affect any deadlines in the cases. 6. In compliance with Civil Local Rule 11-5(b), Movant has notified counsel for defendants in the above-captioned matters that this Motion is not accompanied by simultaneous appearance of substitute counsel and is subject to the condition that papers may continue to be served on Movant for forwarding purposes, unless and until plaintiff appears by other counsel. 7. Counsel for defendants in the above-captioned matters has confirmed that they do not oppose this Motion. THEREFORE, the undersigned Movant respectfully requests that the Court grant his Motion to Withdraw as Counsel for Plaintiff in the above-captioned matters and enter an Order. Dated: October 4, 2016 Respectfully submitted, /s/ Wilson W. Lin Wilson W. Lin (Bar No. 302228) wlin@park-law.com H.C. PARK & ASSOCIATES, PLC 1894 Preston White Drive Reston, VA 20191 T: (703) 544-9230; F: (703) 288-5139 Counsel for Plaintiff Global Touch Solutions, LLC Case 3:15-cv-02748-JD Document 74 Filed 10/04/16 Page 3 of 4 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 [PROPOSED] ORDER GRANTING MOTION TO WITHDRAW AS COUNSEL FOR PLAINTIFF 4 CASE NOS. 3:15cv2746, -2747, -2748, -2749, -2750-JD CERTIFICATE OF SERVICE The undersigned certifies that, on October 4, 2016, he caused this document to be electronically filed with the Clerk of Court using the CM/ECF system, which will send notification of filing to counsel of record for each party. /s/ Wilson W. Lin Wilson W. Lin Case 3:15-cv-02748-JD Document 74 Filed 10/04/16 Page 4 of 4