Interserve, Inc. et al v. Fusion Garage PTE. LTD

Filing 235

REPLY (re 230 MOTION to Withdraw as Attorney Quinn Emanuel's Motion to Withdraw as Counsel for Fusion Garage PTE. LTD. ) filed byFusion Garage PTE. LTD. (Stern, Claude) (Filed on 12/28/2011)

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1 QUINN EMANUEL URQUHART & SULLIVAN, LLP Claude M. Stern (Bar No. 96737) 2 Evette D. Pennypacker (Bar No. 203515) 3 Thomas R. Watson (Bar No. 227264) 4 555 Twin Dolphin Dr., 5th floor 5 Redwood Shores, CA 94065 Telephone: (650) 801-5000 6 Facsimile: (650) 801-5100 7 8 9 10 11 Patrick C. Doolittle (Bar No. 203659) Joshua L. Sohn (Bar No. 250105) Sam S. Stake (Bar No. 257916) 50 California Street, 22nd Floor San Francisco, California 94111 Telephone: (415) 875-6600 Facsimile: (415) 875-6700 12 13 Attorneys for Defendant Fusion Garage PTE Ltd. 14 15 UNITED STATES DISTRICT COURT 16 NORTHERN DISTRICT OF CALIFORNIA 17 SAN FRANCISCO DIVISION 18 19 TECHCRUNCH, INC., a Delaware corporation, and CRUNCHPAD, INC., a 20 Delaware corporation, 21 22 Plaintiffs, vs. 23 FUSION GARAGE PTE. LTD., a Singapore company, 24 Defendant. 25 CASE NO. C 09-cv-5812 RS (PSG) REPLY IN SUPPORT OF QUINN EMANUEL URQUHART & SULLIVAN LLP’S MOTION TO WITHDRAW AS COUNSEL OF RECORD FOR DEFENDANT FUSION GARAGE PTE. LTD. Date: January 19, 2012 Time: 1:30 p.m. Judge: Hon. Richard Seeborg Location: San Francisco, Courtroom 3 - 17th Floor 26 27 28 Case No. C 09-cv-5812 RS (PSG) REPLY IN SUPPORT OF MOTION TO WITHDRAW AS COUNSEL OF RECORD 1 Plaintiffs submitted a statement of non-opposition to Quinn Emanuel Urquhart & Sullivan 2 LLP’s (“Quinn Emanuel”) motion to withdraw as counsel of record for Defendant Fusion Garage 3 PTE. Ltd. See Dkt. 234. Accordingly, Quinn Emanuel respectfully requests that the Court grant 4 its motion to withdraw. 5 Plaintiffs’ statement of non-opposition included several requests for further relief from the 6 Court regarding Defendant Fusion Garage. Specifically, Plaintiffs have requested (1) the Court 7 issue an Order to Show Cause Why Default Should Not be Entered, set for hearing no more than 8 21 days after Quinn Emanuel’s motion is granted; (2) a referral to Magistrate Judge Laporte for 9 additional ADR; and (3) that the discovery previously due on December 16, 2011 be served within 10 14 days of the date Quinn Emanuel’s motion is granted.1 See Dkt. 234 and 234-1. 11 Fusion Garage respectfully requests that the Court give it thirty days to find new counsel. 12 Once new counsel is retained, the parties can meet and confer and discuss the case schedule and 13 ADR with the benefit of new counsel’s participation in the case. Trial will not commence until 14 early 2013. Thus, Plaintiffs will face little to no prejudice by Fusion Garage’s reasonable request. 15 16 DATED: December 28, 2011 QUINN EMANUEL URQUHART & SULLIVAN, LLP 17 18 /s/ Claude M. Stern Claude M. Stern Attorneys for Defendant Fusion Garage PTE. Ltd. By 19 20 21 22 23 24 25 26 27 28 1 Fusion Garage notes that Plaintiffs’ request of 14 days to exchange discovery is 7 days before the date Plaintiffs requested that Fusion Garage must retain new counsel or face default. Case No. C 09-cv-5812 RS (PSG) -1REPLY IN SUPPORT OF MOTION TO WITHDRAW AS COUNSEL OF RECORD

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