The Football Association Premi v. Youtube, Inc.

Filing 320

MOTION, to be relieved as attorney, on behalf of Appellant Alley Music Corporation, Edward B. Marks Music Company, Freddy Bienstock Music Company, National Music Publishers' Association and The Rodgers & Hammerstein Organization, FILED. Service date 04/18/2011 by CM/ECF. [266143] [10-3342]

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT
Thurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: [phone]
MOTION INFORMATION STATEMENT
Docket Number(s):
Motion for:

10-3342

Caption ruse short title .]

Football Association Premier League Ltd., et al. v.
YouTube, et al.

Leave to withdraw as counsel

Set forth below precise, complete statement of relief sought:

Jacqueline C. Charlesworth seeks to withdraw as counsel
for Alley Music Corp., Edward B. Marks Music Corp.,
Freddy Bienstock Music Co., NMPA, Rodgers &
Hammerstein Org. and Stage Three Music (US) Inc.
MOVING PARTY: Alley Music Corp, et al. (listed above)
0 Defendant
151 Plaintiff
0 Appellee/Respondent
ig Appellant/Petitioner
MOVING ATTORNEY:

OPPOSING PARTY:

YouTube, et al.

OPPOSING ATTORNEY: Andrew Schapiro, Esq.
[name of attorney, with firm, address, phone number and e-mail]

Jacqueline C. Charlesworth, Esq.

Pryor Cashman LLP
7 Times Square
New York, NY 10036
[phone] / icharlesworth(pryorcashman.com
Court-Judge/Agency appealed from:

Mayer Brown LLP
1675 Broadway
New York, NY 10019
[phone] / aschapiromayerbrown.com

U.S. District Court, S.D.N.Y., Hon. Louis L. Stanton

Please check appropriate boxes:
Has movant notified opposing counsel (required by Local Rule 27.1):
No (explain):
Yes

0

FOR EMERGENCY MOTIONS, MOTIONS FOR STAYS AND
INJUNCTIONS PENDING APPEAL:
Has request for relief been made below?
0 Yes 0 No
Has this relief been previously sought in this Court?
0 Yes 0 No
Requested return date and explanation of emergency:

Opposing counsel's position on motion:
Unopposed 0Opposed 0Don't Know
Does opposing counsel intend to file a response:
0 Yes F4 No ['Don't Know
Is oral argument on motion requested?

Yes

No (requests for oral argument will not necessarily be granted)

Has argument date of appeal been set?

Yes

No If yes, enter date:

Simmture of Moyin2 Attorney:
/5/Jacqueline Lnanetworm

Date:

April 18, 2011

Has service been effected?

Yes 9 No [Attach proof of service]

ORDER
IT IS HEREBY ORDERED THAT the motion is GRANTED DENIED.
FOR THE COURT:
CATHERINE O'HAGAN WOLFE, Clerk of Court

By:

Date:

Form T 1080
-

UNITED STATES COURT OF APPEALS
FOR THE SECOND CIRCUIT
THE FOOTBALL ASSOCIATION
PREMIER LEAGUE LIMITED, et al.,
Plaintiffs-Appellants,

No. 10-3342

V.
YOUTUBE, INC., et al.,
Defendants-Appellees.

DECLARATION OF
JACQUELINE C. CHARLESWORTH
IN SUPPORT OF MOTION TO WITHDRAW
1

I, JACQUELINE C. CHARLESWORTH, pursuant to 28 U.S.C.

§1746, hereby declare as follows:
2.

I am a partner with the law firm Pryor Cashman LLP. I submit this

declaration in support of my motion to withdraw as counsel of record for PlaintiffsAppellants Alley Music Corporation, Edward B. Marks Music Corporation, Freddy
Bienstock Music Company, National Music Publishers' Association, Rodgers &
Hammerstein Organization and Stage Three Music (US), Inc.
3.

The above-referenced Plaintiffs-Appellants will continue to be

represented in this appeal by the law firms Proskauer Rose LLP, Lieff Cabraser

Heimann & Bernstein LLP and Bernstein Litowitz Berger & Grossmann LLP.
Accordingly, my withdrawal will not cause or result in any delay or prejudice.
4.

I declare under penalty of perjury that the foregoing is true and

correct.
Executed this 18 th day of April, 2011.

By: /s/ Jacqueline C. Charlesworth
Jacqueline C. Charlesworth
PRYOR CASHMAN LLP
7 Times Square
New York, NY 10036-6569
[phone]
Attorneys for Plaintiffs-Appellants
Alley Music Corporation, Edward B. Marks
Music Corporation, Freddy Bienstock Music
Company, National Music Publishers'
Association, Rodgers & Hammerstein
Organization and Stage Three Music (US),
Inc.

CERTIFICATE OF SERVICE
I hereby certify that on this 18 th day of April, 2011, I caused true and correct
copies of the foregoing Motion for Leave to Withdraw as Counsel and Declaration
of Jacqueline C. Charlesworth in Support of Motion to Withdraw to be served on
all counsel of record in this appeal via CM/ECF, pursuant to Local Rule 25.1 (h)(1)
& (2).
By:

/s/ Jacqueline C. Charlesworth
Jacqueline C. Charlesworth