Sanders et al v. Hyundai Motor America et al

Filing 41

ORDER Granting 40 Motion to Withdraw as Attorney. Signed by Magistrate Judge Brenda Weksler on 2/16/2021. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:20-cv-01861-GMN-BNW Document 40 Filed 02/11/21 Page 1 of 5
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James L. Edwards, Esq. (#4256)
H. Stan Johnson, Esq. (#00265)
COHEN-JOHNSON PARKER EDWARD
375 E. Warm Springs Rd., Ste. 104
Las Vegas, Nevada 89119
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff

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KEMP JONES, LLP

3800 Howard Hughes Parkway
Seventeenth Floor
Las Vegas, Nevada 89169
[phone] • Fax [phone]
[e-mail]

J. Randall Jones, Esq. (#1927)
Eric M. Pepperman, Esq. (#11679)
Joshua D. Carlson, Esq. (#11781)
KEMP JONES, LLP
3800 Howard Hughes Parkway
Seventeenth Floor
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Case No.: 2:20-cv-01861-GMN-BNW

M.S., a minor individual, by Guardian
VALERIE SANDERS,
Plaintiff,

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MOTION FOR LEAVE TO WITHDRAW
AS COUNSEL

vs.
HYUNDAI MOTOR AMERICA, a
California business entity; HYUNDAI
MOTOR COMPANY, a Korean corporation;
TAKATA CORPORATION, a Japanese
corporation; ZF TRW AUTOMOTIVE
HOLDINGS CORP., a Delaware
Corporation; ZF FRIEDRICHSHAFEN AG,
a German Corporation; ROE AIRBAG
MANUFACTURING COMPANY; DOE
INDIVIDUALS I through XXX and ROE
CORPORATIONS XXXI through LX,
Defendants.

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Case 2:20-cv-01861-GMN-BNW Document 40 Filed 02/11/21 Page 2 of 5
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COMES NOW, the law firm of Kemp Jones, LLP, co-counsel for Plaintiffs, hereby moves

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for leave to withdraw as counsel for Plaintiffs.
This Motion is based on the Affidavit of J. Randall Jones, the memorandum of points and

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authorities, and any argument of counsel deemed necessary by this Court.
DATED this

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11th

day of February, 2021.

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KEMP JONES, LLP

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By: _/s/ J. Randall Jones_______________
J. RANDALL JONES, ESQ. (# 1927)
ERIC M. PEPPERMAN, ESQ. (#11679)
JOSHUA D. CARLSON, ESQ. (#11781)
3800 Howard Hughes Parkway
Seventeenth Floor
Las Vegas, Nevada 89169
Co-Counsel for Plaintiff

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KEMP JONES, LLP

3800 Howard Hughes Parkway
Seventeenth Floor
Las Vegas, Nevada 89169
[phone] • Fax [phone]
[e-mail]

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AFFIDAVIT OF J. RANDALL JONES

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STATE OF NEVADA
COUNTY OF CLARK

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J. Randall Jones, being duly sworn, deposes and says:

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the State of Nevada. I am personally familiar with this litigation and competent to testify

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to the matters set forth herein.

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2.

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instant action.

I am a partner with the law firm Kemp Jones, LLP, and license to practice law in

My firm Kemp Jones, LLP, is one of the law firms representing Plaintiffs in the

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Case 2:20-cv-01861-GMN-BNW Document 40 Filed 02/11/21 Page 3 of 5
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Case 2:20-cv-01861-GMN-BNW Document 40 Filed 02/11/21 Page 4 of 5
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MEMORANDUM OF POINTS AND AUTHORITIES

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As indicated in the Affidavit of J. Randall Jones attached hereto and incorporated herein

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by this reference, two law firms are presently counsel of record in this action, Kemp Jones, LLP

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and COHEN-JOHNSON, LLC. Because COHEN-JOHNSON, LLC will continue on as counsel

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in this case, withdrawal of Kemp Jones, LLP should cause no disruption or delay in the continued

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prosecution of this action.

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LR IA 11-6 provides in pertinent part:

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(b) If an attorney seeks to withdraw after appearing in a case, the attorney must file
a motion or stipulation and serve it on the affected client and opposing counsel.
…

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KEMP JONES, LLP

3800 Howard Hughes Parkway
Seventeenth Floor
Las Vegas, Nevada 89169
[phone] • Fax [phone]
[e-mail]

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(e) Except for good cause shown, no withdrawal or substitution will be approved if
it will result in delay of discovery, the trial, or any hearing in the case. Where delay
would result, the papers seeking leave of the court for the withdrawal or substitution
must request specific relief from the scheduled discovery, trial, or hearing. If a trial
setting has been made, an additional copy of the moving papers must be provided
to the clerk for immediate delivery to the assigned district judge, bankruptcy judge,
or magistrate judge.

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As indicated above, withdrawal of Kemp Jones, LLP would be in compliance with the

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Local Rules of this District as it would result in no delay of discovery, the trial, or any hearing in

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this case.

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Based on the foregoing and the Affidavit of J. Randall Jones, Kemp Jones, LLP
respectfully requests this Court approve the withdrawal of Kemp Jones, LLP from this action.
DATED this 11th

day of February, 2021.

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KEMP JONES, LLP
ORDER
IT IS SO ORDERED

/s/ J. Randall Jones
J. Randall Jones, Esq. (# 1927)
Eric M. Pepperman, Esq. (#11679)
Joshua D. Carlson, Esq. (#11781)
3800 Howard Hughes Parkway
BRENDA WEKSLER
Seventeenth Floor
UNITED STATES MAGISTRATE JUDGE Vegas, Nevada 89169
Las
Co-Counsel for Plaintiff
DATED: 12:51 pm, February 16, 2021

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