Mirror Worlds, LLC v. Apple, Inc.
Unopposed MOTION to Withdraw as Attorney, Unopposed MOTION to Substitute Attorney by Apple, Inc.. (Attachments: # 1 Proposed Order)(Randall, Jeffrey)
Mirror Worlds, LLC v. Apple, Inc.
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC, Plaintiff, v. APPLE INC., Defendant. APPLE INC., Counterclaim Plaintiff, v. MIRROR WORLDS, LLC, MIRROR WORLDS TECHNOLOGIES, INC., Counterclaim Defendants. APPLE INC.'S UNOPPOSED MOTION FOR WITHDRAWAL AND SUBSTITUTION OF COUNSEL Apple Inc. ("Apple") hereby moves this Court for withdrawal of counsel, Weil, Gotshal & Manges LLP, and all of the firm's attorneys who are of record in the above-captioned action, namely Matthew D. Powers, Carmen E. Bremer, Sonal N. Mehta, Stefani C. Smith, Steven S. Cherensky, and Sven Raz. The undersigned certify that Apple is in agreement with the withdrawal and substitution being requested. Notice is hereby given that the undersigned attorneys, Jeffery G. Randall and Allan M. Soobert, and their law firm, Paul, Hastings, Janofsky & Walker LLP, are being substituted as counsel and hereby enter their appearance. Mr. Randall will represent Apple as Lead Counsel in this matter. Defendant Apple has met and conferred with Plaintiff Mirror Worlds, LLC, who has no objections to the withdrawal of Weil, Gotshal & Manges LLP as counsel for Apple. Civil Action No. 6:08-cv-88 LED JURY TRIAL DEMANDED
The withdrawal/substitution is being made to accommodate scheduling conflicts between the above-captioned matter and another Apple matter being handled by the same Weil, Gotshal & Manges LLP attorneys. It will not delay these proceedings and no prejudice will result to any party. To provide sufficient time for Apple to implement its request for substitution of counsel and to accommodate the parties' on-going discovery efforts, the parties submit to the court an Unopposed Motion to Amend the Docket Control Order, filed concurrently herewith. The proposed Amended Docket Control Order adjusts the deadlines for the designation of expert witnesses, expert reports, and the discovery deadline. Neither the dispositive motion deadline, nor the trial date will be affected by the proposed Amended Docket Control Order. Accordingly, the Unopposed Motion to Amend the Docket Control Order will not cause a delay in the proceedings or any prejudice to either party. Apple respectfully requests that the Court make Jeffery G. Randall and Allan M. Soobert attorneys of record for Apple in these proceedings. Copies of all communications and other documents filed in the above-referenced proceedings should be emailed to the addresses set forth below. Additionally, Apple also requests that Weil Gotshal & Manges LLP and its attorneys no longer receive CM/ECF notices for this action.
Dated: April 1, 2010
Respectfully submitted, PAUL, HASTINGS, JANOFSKY, AND WALKER LLP /s/ Jeffrey G. Randall Jeffery G. Randall Lead Attorney PAUL, HASTINGS, JANOFSKY, AND WALKER LLP 1117 S. California Avenue Palo Alto, California 94304-1106 Telephone: (650) 320-1850 Facsimile: (650) 320-1950 email@example.com Allan M. Soobert PAUL, HASTINGS, JANOFSKY, AND WALKER LLP 875 15th Street, N.W. Washington, DC 20005 Telephone: (202) 551-1822 Facsimile: (202) 551-0222 firstname.lastname@example.org Eric M. Albritton Texas State Bar No. 00790215 ALBRITTON LAW FIRM P.O. Box 2649 Longview, Texas 75606 Telephone: (903) 757-8449 Facsimile: (903) 758-7397 email@example.com Counsel for Apple Inc.
Weil, Gotshal & Manges LLP hereby consents to this Unopposed Motion to Withdraw and Substitution of Counsel: Dated: April 1, 2010 WEIL, GOTSHAL & MANGES LLP /s/ Matthew D. Powers Matthew D. Powers WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 650-802-3000 (Telephone) 650-802-3100 (Facsimile) firstname.lastname@example.org
CERTIFICATE OF CONFERENCE I hereby certify that counsel for Apple has satisfied the "meet and confer" requirements of Local Rule CV-7(h), and that counsel of record in this matter are not opposed to the relief sought in this Motion. /s/ Jeffery G. Randall Jeffery G. Randall CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was filed electronically in compliance with Local Rule CV-5 on this 1st day of April, 2010. As of this date, all counsel of record have consented to electronic service and are being served with a copy of this document through the Court's CM/ECF system under Local Rule CV-5(a)(3)(A). /s/ Jeffery G. Randall Jeffery G. Randall