Brown et al v. Young

Filing 17

Notice of Unopposed Motion and Motion for an Order Permitting Owens Tarabichi LLP to Withdraw as Counsel for defendant; Memorandum of Points and Authorities in Support Thereof filed by Yvonne Young. Motion Hearing set for 8/30/2011 10:00 AM in Courtroom 2, 5th Floor, San Jose before Magistrate Judge Howard R. Lloyd. Responses due by 8/4/2011. Replies due by 8/11/2011. (Attachments: # 1 (Proposed) Order) (Tarabichi, Bruno) (Filed on 7/21/2011) Modified on 7/22/2011 (bw, COURT STAFF).

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1 2 3 4 5 6 DAVID R. OWENS, State Bar No. 180829 dowens@owenstarabichi.com BRUNO W. TARABICHI, State Bar No. 215129 btarabichi@owenstarabichi.com OWENS TARABICHI LLP 111 N. Market St., Suite 730 San Jose, California 95113 Telephone: 408.298.8200 Facsimile: 408.521.2203 Attorneys for Defendant Yvonne Young 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 SAN JOSE DIVISION 11 12 BRIDGET BROWN and BELLA BRIDESMAID, LLC, Case No. 5:11-cv-02517-HRL 13 Plaintiffs, 14 vs. 15 YVONNE YOUNG, 16 Defendant. NOTICE OF UNOPPOSED MOTION AND MOTION FOR AN ORDER PERMITTING OWENS TARABICHI LLP TO WITHDRAW AS COUNSEL FOR DEFENDANT YVONNE YOUNG; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF 17 18 19 20 REQUEST FOR ORDER WITHOUT HEARING Date: August 30, 2011 Time: 10am Judge: Hon. Howard R. Lloyd 21 22 23 24 25 26 27 28 owens tarabichi llp Co u ns el or s A t La w MOTION TO WITHDRAW (5:11-cv-02517-HRL) 1 P PLEASE TAKE NOTICE THAT on August 30, 2011 at 10:00 a.m., or as soon 2 thereafter as counsel may be heard by the Court, Defendant Yvonne Young and her counsel, 3 Owens Tarabichi LLP, jointly move the Court, pursuant to Local Rule 11-5(a), for an order 4 permitting Owens Tarabichi LLP to withdraw as counsel for Ms. Young. To the extent the Court 5 is agreeable to deciding the matter on the papers, such action is requested because opposing 6 counsel has stated that Plaintiffs will not oppose the instant Motion and because Ms. Young 7 consents to the withdrawal of his counsel. 8 9 This Motion is made on the grounds that Ms. Young wishes to represent herself moving forward. 10 This Motion is based on this Notice of Motion and Motion and the accompanying 11 Memorandum of Points and Authorities, as well as the pleadings and papers on file in this action 12 and such other argument, evidence, or matters as may be presented to the Court at the time of 13 hearing. 14 15 MEMORANDUM OF POINTS AND AUTHORITIES Good cause exists to permit David R. Owens, Bruno W. Tarabichi, and the law firm of 16 Owens Tarabichi LLP to withdraw as counsel for Defendant Yvonne Young. In this regard, Ms. 17 Young has requested that Owens Tarabichi no longer represent her in this action and has 18 indicated that she wishes to represent herself. As such, Ms. Young not only consents to Owens 19 Tarabichi LLP’s withdrawal, but the withdrawal is being filed at her request. Ms. Young’s 20 consent is evidenced by his signature below. 21 Furthermore, Owens Tarabichi LLP’s withdrawal from this case will not disrupt or 22 otherwise delay this case. Specifically, this case is still in the early stages of the case—the initial 23 case management conference has not yet been held and the parties have not engaged in formal 24 discovery to date. 25 Finally, pursuant to Local Rule 11-5(a), Owens Tarabichi LLP has provided prior written 26 notice to both the client, Ms. Young, and to opposing counsel. Ms. Young consents to, and has 27 requested, the withdrawal. In addition, opposing counsel indicated that Plaintiffs will not oppose 28 the instant motion. Accordingly, Owens Tarabichi LLP and Ms. Young respectfully request that owens tarabichi llp Co u ns el or s A t La w 1 MOTION TO WITHDRAW (5:11-cv-02517-HRL)

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