Miguel Angel Garcia v. Top Rank Inc et al

Filing 102

ORDER Granting 101 Motion to Withdraw as Attorney. Adam L. Bloom withdrawn from the case as counsel for Defendant Top Rank, Inc. Signed by Magistrate Judge Peggy A. Leen on 8/26/15. (Copies have been distributed pursuant to the NEF - MMM)

1

2
3
4

5

6
7
8
9
10
11
12
13
14
15

DANIEL M. PETROCELLI
CA Bar No. 97802
Admitted Pro Hae Vice
[e-mail]
DAVID MARROSO
CA Bar No. 211655
Admitted Pro Hae Vice
[e-mail]
DREW E. BREUDER
CABarNo.198466
Admitted Pro Hae Vice
[e-mail]
ADAM L. BLOOM
CA Bar No. 267007
Admitted Pro Hae Vice
[e-mail]
O'MELVENY & MYERS LLP
1999 A venue of the Stars, Seventh Floor
Los Angeles, California 90067-6035
Telephone: [phone]
Facsimile: [phone]
J. COLBY WILLIAMS
NV Bar No. 5549
j [e-mail]
CAMPBELL & WILLIAMS
700 South Seventh Street
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: [phone]

16
17

Attorneys for Defendant
Top Rank, Inc.

18

UNITED STATES DISTRICT COURT

19

DISTRICT OF NEVADA

20

MIGUEL ANGEL GARCIA a.k.a. MIKEY
GARCIA, an individual,

21

Hon. Richard F. Boulware, II
Plaintiff,

22
23
24
25

Case No. 2:14-cv-01456-RFB-PAL

v.

TOP RANK, INC., a Nevada corporation;
and DOES 1-10, inclusive,

UNOPPOSED MOTION AND PROPOSED
ORDER FOR ADAM L. BLOOM TO
WITHDRAW AS COUNSEL FOR
DEFENDANT TOP RANK, INC.

Defendants.

26
27

28
MOTION FOR ADAM L. BLOOM TO
WITHDRAW
CASE NO. 2:14-CV-01456

1

Adam L. Bloom respectfully moves the Court for an order permitting Adam L. Bloom to

2

withdraw as counsel for Defendant Top Rank, Inc., in the above captioned matter, pursuant to

3

Local Rule IA 10-6.

4

5

This Motion is made and based upon the Memorandum of Points and Authorities
submitted herein and the Declaration of Adam L. Bloom attached hereto.

6
7
8

Dated: August 24, 2015

DANIEL M. PETROCELLI
DAVID MARRO SO
DREW E. BREUDER
ADAM L. BLOOM
O'MELVENY & MYERS LLP

9

10
11

J. COLBY WILLIAMS
CAMPBELL & WILLIAMS

12
13
14

AdamL. Boom
Attorneys for Defendant
Top Rank, Inc.

15
16
17
18
19
20
21
22
23
24

25

26
27

28
1

MOTION FOR ADAM L. BLOOM TO
WITHDRAW
CASE NO. 2:14-CV-01456

1

MEMORANDUM OF POINTS AND AUTHORITIES

2

Adam L. Bloom ("Mr. Bloom") respectfully moves the Court pursuant to Local Rule IA

3

10-6 for leave to withdraw the appearance of Adam L. Bloom as counsel in this matter. This

4

Motion is precipitated by Mr. Bloom's pending departure from the law firm of O'Melveny &

5

Myers LLP.

6

Local Rule IA 10-6(b) provides that "No attorney may withdraw after appearing in a case

7

except by leave of Court after notice has been served on the affected client and opposing

8

counsel." Defendant Top Rank has been informed of Mr. Bloom's intent to withdraw and does

9

not oppose. Additionally, counsel for Plaintiff Miguel Angel Garcia has been informed of Mr.

10

Bloom's intent to withdraw and does not oppose.

11

Local Rule IA 10-6(e) provides that "no withdrawal ... shall be approved if delay of

12

discovery, the trial or any hearing would result." Here, no delay will result from Mr. Bloom's

13

withdrawal, as O'Melveny & Myers LLP attorneys Daniel M. Petrocelli, David Marroso, and

14

Drew E. Breuder will continue to appear on behalf of Defendant Top Rank, Inc. Mr. Bloom's

15

withdrawal will not prejudice either party or delay any proceeding in this matter.

16

///

17

///

18

///

19

20
21

22
23
24

25

26
27

28
1

MOTION FOR ADAM L. BLOOM TO
WITHDRAW
CASE NO. 2:14-CV-01456

1

2

CONCLUSION
For the reasons set forth above, Mr. Bloom respectfully moves this Court to enter an order

3

approving the withdrawal of Mr. Bloom as a representing attorney for Defendant Top Rank, Inc.

4

in the instant matter.

5
6

Dated: August 24, 2015

DANIEL M. PETROCELLI
DAVID MARRO SO
DREW E. BREUDER
ADAM L. BLOOM
O'MELVENY &MYERS LLP

7
8

J. COLBY WILLIAMS

9

CAMPBELL & WILLIAMS

10

11
Adam L. Bloom
Attorneys for Defendant
Top Rank, Inc.

12
13
14
15

IT IS SO ORDERED:

16

17
18

UNITED STATES MAGISTRAGE JUDGE
UNITED STATES DISTRICT JUDGE

19

August 26, 2015

20
21

22
23
24

25

26

27
28
2

MOTION FOR ADAM L. BLOOM TO
WITHDRAW
CASE NO. 2:14-CV-01456