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)

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
Claude M. Stern (Bar No. 96737)
2
[e-mail]
Evette D. Pennypacker (Bar No. 203515)
3
[e-mail]
Thomas R. Watson (Bar No. 227264)
4
[e-mail]
555 Twin Dolphin Dr., 5th floor
5 Redwood Shores, CA 94065
Telephone: [phone]
6 Facsimile: [phone]
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Patrick C. Doolittle (Bar No. 203659)
[e-mail]
Joshua L. Sohn (Bar No. 250105)
[e-mail]
Sam S. Stake (Bar No. 257916)
[e-mail]
50 California Street, 22nd Floor
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]

12
13 Attorneys for Defendant Fusion Garage PTE Ltd.
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15

UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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19 TECHCRUNCH, INC., a Delaware
corporation, and CRUNCHPAD, INC., a
20 Delaware corporation,
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Plaintiffs,
vs.

23 FUSION GARAGE PTE. LTD., a Singapore
company,
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Defendant.
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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

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Case No. C 09-cv-5812 RS (PSG)
REPLY IN SUPPORT OF MOTION TO WITHDRAW AS COUNSEL OF RECORD

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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.
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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.
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16 DATED: December 28, 2011

QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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/s/ Claude M. Stern
Claude M. Stern
Attorneys for Defendant Fusion Garage PTE. Ltd.

By

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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