Beneficial Innovations, Inc. v. Careerbuilder, LLC et al

Filing 14

MOTION to Withdraw as Attorney by Beneficial Innovations, Inc.. (Attachments: # 1 Text of Proposed Order)(Bunt, Robert)

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BENEFICIAL INNOVATIONS, INC. Plaintiff, V. CAREERBUILDER, LLC., et al Defendants. Case No. 2:09-CV-175 (TJW) JURY TRIAL DEMANDED MOTION FOR WITHDRAWAL OF COUNSEL Come now Chris Bunt, Charles Ainsworth and the law firm of Parker, Bunt & Ainsworth, PC and file this Motion for Withdrawal of Counsel, and would respectfully show the Court the following: 1. Chris Bunt, Charles Ainsworth and the law firm of Parker, Bunt & Ainsworth, PC were hired as local counsel in this matter on behalf of Plaintiff Beneficial Innovations, Inc. Chris Bunt and Charles Ainsworth have since determined that a potential conflict exists and must withdraw. 2. Chris Bunt and Charles Ainsworth further request the termination of receiving electronic filing notices. 3. 4. Plaintiff Beneficial Innovations, Inc. approves the withdrawal. This withdrawal will not delay these proceedings. WHEREFORE, PREMISES CONSIDERED, Chris Bunt, Charles Ainsworth and Parker, Bunt & Ainsworth, P.C. respectfully request that this Motion be granted and that Chris Bunt, Charles Ainsworth and the law firm of Parker, Bunt & Ainsworth, PC be allowed to withdraw as local counsel on behalf of Beneficial Innovations, Inc. 1 Respectfully submitted, /s/ Robert Christopher Bunt Robert Christopher Bunt State Bar No. 00787165 Charles Ainsworth State Bar No. 00783521 PARKER, BUNT & AINSWORTH, P.C. 100 E. Ferguson, Suite 1114 Tyler, TX 75702 Telephone: 903/531-3535 Facsimile: 903/533-9687 E-mail: rcbunt@pbatyler.com ATTORNEYS FOR PLAINTIFF BENEFICIAL INNOVATIONS, INC. CERTIFICATE OF SERVICE I hereby certify that the following counsel of record, who are deemed to have consented to electronic service are being served this 8th day of September, 2009, with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3). Any other counsel of record will be served by electronic mail, facsimile transmission and/or first class mail on this same date. /s/ Robert Christopher Bunt ROBERT CHRISTOPHER BUNT CERTIFICATE OF CONFERENCE I hereby certify that none of the Defendants have filed an answer in this case. Accordingly, Plaintiff's counsel has been unable to determine whether anyone opposes this motion. /s/ Robert Christopher Bunt ROBERT CHRISTOPHER BUNT 2

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