GSI Technology, Inc. v. United Memories, Inc.

Filing 1114

NOTICE OF INTENT TO WITHDRAW AND MOTION TO WITHDRAW AS COUNSEL OF RECORD FOR DEFENDANT UNITED MEMORIES, INC.; ORDER GRANTING MOTION TO WITHDRAW, signed by Judge Paul S. Grewal on March 10, 2016, re 1113 . (psglc1S, COURT STAFF) (Filed on 3/10/2016)

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CONSTANCE F. RAMOS (Bar No. 203637)
[e-mail]
THOMAS J. KEARNEY (Bar No. 267087)
[e-mail]
WINSTON & STRAWN LLP
101 California Street
San Francisco, CA 94111
Telephone:
[phone]
Facsimile:
[phone]
KORULA T. CHERIAN (Bar No. 133967)
[e-mail]
ROBERT F. RUYAK (pro hac vice)
[e-mail]
RUYAKCHERIAN LLP
1776 Eye Street, NW, Suite 750
Washington, DC 20006
Telephone: [phone]

101 California Street
San Francisco, CA 94111-5802

Winston & Strawn LLP

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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GSI TECHNOLOGY, INC., a Delaware
Corporation,
Plaintiff,

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v.
UNITED MEMORIES, INC., a Colorado
Corporation, and INTEGRATED SILICON
SOLUTION, Inc., a Delaware Corporation,
Defendants.

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Case No. 13-CV-1081-PSG
NOTICE OF INTENT TO WITHDRAW
AND MOTION TO WITHDRAW AS
COUNSEL OF RECORD FOR
DEFENDANT UNITED MEMORIES, INC.;
[PROPOSED] ORDER GRANTING
MOTION TO WITHDRAW
Complaint: Filed March 8, 2013
Judge: Hon. Paul S. Grewal

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UNITED MEMORIES, INC., a Colorado
Corporation,
Counterclaim-Plaintiff,

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v.
GSI TECHNOLOGY, INC., a Delaware
Corporation,

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Counterclaim-Defendant.
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NOTICE OF INTENT TO WITHDRAW AND MOTION TO WITHDRAW AS COUNSEL OF RECORD FOR
DEFENDANT UNITED MEMORIES, INC.; [PROPOSED] ORDER GRANTING MOTION TO WITHDRAW
CASE NO. 13-CV-1081-PSG

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TO THE COURT, ALL PARTIES AND THEIR COUNSEL OF RECORD:
PLEASE TAKE NOTICE that Constance F. Ramos, Thomas J. Kearney, and the law

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firm of Winston & Strawn LLP hereby seek permission from the Court to withdraw as counsel

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of record for Defendant United Memories, Inc. (“United Memories”), pursuant to Civil Local

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Rule 11-5. United Memories understands and consents to this withdrawal.

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Attorneys K.T. Cherian, Robert F. Ruyak, and others of the law firm RuyakCherian

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LLP, continue to represent United Memories in this matter before the Court. Mr. Cherian has

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been lead counsel for United Memories since the filing of this action against it in 2013.

101 California Street
San Francisco, CA 94111-5802

Having alternative counsel, United Memories respectfully moves the Court for an order

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Winston & Strawn LLP

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granting Constance F. Ramos, Thomas J. Kearney, and the law firm of Winston & Strawn LLP

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permission to withdraw as counsel of record in this action. This motion to withdraw is

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permitted under the California Code of Professional Conduct Rule 3-700(C).

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Dated: March 10, 2016

Respectfully submitted,

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WINSTON & STRAWN LLP

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By: _/s/ Constance F. Ramos_____
Constance F. Ramos
Attorneys for Defendant
United Memories, Inc.

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[PROPOSED] ORDER
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The Court hereby GRANTS the above motion to permit the withdrawal of Constance F.
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Ramos, Thomas J. Kearney, and the law firm Winston & Strawn LLP as counsel of record for
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Defendant United Memories, Inc. United Memories, Inc.’s counsel of record otherwise
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remains unchanged.
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IT IS SO ORDERED.
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March 10
Dated: __________, 2016
Honorable Paul S. Grewal
United States District Court Judge
Magistrate

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NOTICE OF INTENT TO WITHDRAW AND MOTION TO WITHDRAW AS COUNSEL OF RECORD FOR
DEFENDANT UNITED MEMORIES, INC.; [PROPOSED] ORDER GRANTING MOTION TO WITHDRAW
CASE NO. 13-CV-1081-PSG