FPX, LLC v. Google, Inc. et al

Filing 51

Unopposed MOTION to Withdraw Certain Counsel by AOL, LLC., Turner Broadcasting System, Inc.. (Attachments: # 1 Text of Proposed Order)(Babcock, Charles)

FPX, LLC v. Google, Inc. et al

Doc. 51

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION FPX, LLC d/b/a FIREPOND, Individually and on Behalf of All Others Similarly Situated, Plaintiff, v. GOOGLE INC., YOUTUBE, LLC, AOL, LLC, TURNER BROADCASTING SYSTEM, INC., MYSPACE, INC. AND IAC/INTERACTIVECORP, Defendants. § § § § § § § § § § § § § § § §

Civil Action No. 2:09-cv-00142-TJW

CLASS ACTION COMPLAINT

JURY TRIAL REQUESTED

DEFENDANTS AOL LLC AND TURNER BROADCASTING SYSTEM, INC'S UNOPPOSED MOTION TO WITHDRAW CERTAIN COUNSEL COME NOW Defendants AOL LLC and Turner Broadcasting System, Inc. and respectfully request permission to withdraw Donald C. Templin of the law firm of Haynes and Boone LLC, 2323 Victory Avenue, Suite 700, Dallas, TX 75219, as their counsel of record in the above-styled case. The following named attorneys and firm will continue as lead counsel and co-counsel for Defendants AOL LLC and Turner Broadcasting System, Inc. in the above-styled case as previously indicated by their respective notices of appearance: Charles L. "Chip" Babcock, Lead Counsel David T. Moran, Counsel Carl C. Butzer, Counsel JACKSON WALKER L.L.P. 901 Main Street, Suite 6000 Dallas, Texas 75202 Plaint iff's counsel is not opposed to this motion. This withdrawal of counsel is not sought for purposes of delay, but so that justice may be done. Defendants AOL LLC and Turner Broadcasting System, Inc.'s Unopposed Motion to Withdraw Certain Counsel ­ Page 1
Dockets.Justia.com

WHEREFORE, PREMISES CONSIDERED, Defendants AOL LLC and Turner Broadcasting System, Inc. respectfully request that the Court grant their Unopposed Motion to Withdraw Certain Counsel, and sign and enter an Order permitting the withdrawal of counsel as requested herein. Respect fully submitted, /s/ Charles L. Babcock Charles L. "Chip" Babcock Texas State Bar No. 01479500 JACKSON WALKER L.L.P. 901 Main Street, Suite 6000 Dallas, Texas 75202 [phone] [phone]- Fax Email: [e-mail] David T. Moran Texas State Bar No. 14419400 JACKSON WALKER L.L.P. 901 Main Street, Suite 6000 Dallas, Texas 75202 [phone] [phone] - Fax Email: [e-mail] Carl C. Butzer Texas State Bar No. 03545900 JACKSON WALKER L.L.P. 901 Main Street, Suite 6000 Dallas, Texas 75202 [phone] [phone] - Fax Email: [e-mail] ATTORNEYS FOR DEFENDANTS GOOGLE INC., YOUTUBE, LLC, AOL LLC, TURNER BROADCASTING SYSTEM, INC., MYSPACE, INC., AND IAC/INTERACTIVECORP

Defendants AOL LLC and Turner Broadcasting System, Inc.'s Unopposed Motion to Withdraw Certain Counsel ­ Page 2

CERTIFICATE OF CONFERENCE The undersigned hereby certifies that counsel for Defendants AOL LLC and Turner Broadcasting System, Inc. have conferred with Plaintiff's counsel regarding the merits of the foregoing Motion pursuant to the requirement in Local Rule CV-7(h) and Plaintiff's counsel do not oppose the relief therein requested. Certified this 15th day of December, 2009. /s/ Charles L. Babcock Charles L. "Chip" Babcock

CERTIFICATE OF SERVICE The undersigned hereby certifies that on December 15, 2009 the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this notice was served on all counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date. /s/ Charles L. Babcock Charles L. "Chip" Babcock

Defendants AOL LLC and Turner Broadcasting System, Inc.'s Unopposed Motion to Withdraw Certain Counsel ­ Page 3