Dunstan et al v. comScore, Inc.

Filing 90

MOTION by counsel for Defendant comScore, Inc. to withdraw as attorney - David Z. Smith (Reed Smith LLP) (Hudson, Leonard)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
MIKE HARRIS and JEFF DUNSTAN,
Individually and on behalf of a class of
similarly situated individuals,
Plaintiffs,
v.
COMSCORE, INC., a Delaware corporation,
Defendant.

)
)
)
)
) Case No. 1:11-5807
)
) Hon. James F. Holderman
)
)
)
)
)

MOTION TO WITHDRAW AS LOCAL COUNSEL
Attorney David Z. Smith (“Movant”) respectfully moves this court for leave to withdraw
as local counsel for the Defendant in the above-captioned matter. In support of this motion,
Movant states as follows:
1.

When Movant was retained by the Defendant to act as local counsel in this matter,

Defendant’s lead counsel were located in California. Accordingly, Movant filed an appearance
as local counsel only.
2.

Defendant has recently retained Chicago-based attorneys to act as lead counsel in

this matter and those attorneys have filed appearances.
3.

Defendant’s original lead counsel have moved to withdraw in this matter.

4.

Defendant has been informed of, and consents to, Movant’s request to withdraw.

5.

Accordingly, Movant respectfully requests that he be granted leave to withdraw as

local counsel in this matter.

WHEREFORE, Movant requests that this Court enter an order granting him leave to
withdraw as local counsel for Defendant and granting such other and further relief that the Court
deems just and appropriate.
Dated: March 9, 2012

Respectfully submitted,

By: s/ David Z. Smith______
David Z. Smith
Leonard E. Hudson
REED SMITH LLP
10 South Wacker Drive, 40th Floor
Chicago, IL 60606-7507
Telephone: [phone]
Local Counsel for Defendant comScore, Inc.

-2-

CERTIFICATE OF SERVICE
I, Leonard E. Hudson, state that on March 9, 2012, I caused the foregoing Notice of
Motion for Motion for Leave to Withdraw as Local Counsel to be filed with the Clerk of the
Court using the ECF system which will send notification of such filing to the following:
Jay Edelson
William Charles Gray
Steven W. Teppler
Ari Jonathan Scharg
EDELSON McGUIRE, LLC
350 North LaSalle, Suite 1300
Chicago, Illinois 60654
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Andrew H. Schapiro
Amanda S. Williamson
Stephen A. Swedlow

Mark William Wallin
Paul F. Stack

Michael G. Rhodes
Ray A. Sardo
Whitty Somvichian

STACK & O'CONNOR CHARTERED

140 South Dearborn Street, Ste. 411
Chicago, IL 60603
[e-mail]
[e-mail]

QUINN EMANUEL URQUHART &
SULLIVAN, LLP

500 W Madison St., Suite 2450
Chicago, IL 60606
[e-mail]
[e-mail]
[e-mail]

COOLEY LLP

101 California Street, 5th Floor
San Francisco, CA 94111
[e-mail]
[e-mail]
s/ Leonard E. Hudson
David Z. Smith (ARDC #6256687)
Leonard E. Hudson (ARDC # 6293044)
REED SMITH LLP
10 South Wacker Drive
Chicago, IL 60606-7507
Telephone: [phone]
Local Counsel for Defendant comScore, Inc.