AdvanceMe Inc v. RapidPay LLC

Filing 18

MOTION to Withdraw as Attorney of Record by RapidPay LLC. (Attachments: # 1 Exhibit A# 2 Text of Proposed Order)(Harrison, Guy)

AdvanceMe Inc v. RapidPay LLC

Doc. 18

Case 6:05-cv-00424-LED

Document 18

Filed 02/17/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION ADVANCEME, INC. Plaintiff § § § § § § § § § §

CASE NO.. 6:05CV 424 LED

vs. RAPID PAY, LLCSM Defendant.

MOTION TO WITHDRAW AS ATTORNEY OF RECORD FOR RAPIDPAY, LLC TO THE HONORABLE JUDGE OF SAID COURT: Guy N. Harrison ("Counsel") files this Motion to Withdraw as Attorney of Record for Defendant, Rapidpay, LLC. Defendant, Rapidpay, LLC has advised by phone call from the President of said company, Stephanie Nimberg, that they have no objection to Counsel's withdrawal as its attorney of record. Counsel represents that his withdrawal will not materially affect the interest of Rapidpay, LLC or interfere or delay these proceedings as this matter is in the beginning stages of litigation. I. Defendant, Rapidpay, LLC has been advised of this filing by letter attached to this filing as exhibit "A" in addition to the phone contact reference above. Counsel further advises that defendant Rapidpay, has been advised and is further advised by this pleading of the following deadlines:

Dockets.Justia.com

Case 6:05-cv-00424-LED

Document 18

Filed 02/17/2006

Page 2 of 3

Event Initial disclosures of theories, identities of parties and witnesses, insurance agreements, etc. Additional disclosure relating to claims or defenses other than those addressed in the local patent rules Defendant's Preliminary Invalidity Contentions (prior art, etc.) and document production Parties exchange Proposed Terms and Claim Elements for Construction Mediation before Harry McKee Claim Construction Hearing (Markman) before Magistrate Love II. The contact information of Rapidpay to the knowledge of counsel is as follows: Stephanie Nimberg President of Rapidpay, LLC 17 Battery Place, Suite 1330 New York, New York 10004 Phone [phone] Fax [phone] Lawrence Morrison General Counsel of Rapidpay 17 Battery Place, Suite 1330 New York, New York 10004 Phone [phone] ext 225 Fax [phone]

Date Mar 3, 2006

Mar 20, 2006

Mar 28, 2006

Apr 7, 2006

by Aug 15, 06 Sep 20, 2006

Case 6:05-cv-00424-LED

Document 18

Filed 02/17/2006

Page 3 of 3

WHEREFORE PREMISES CONSIDERED, Counsel respectfully requests that the Court permit his withdrawal as counsel of record for Rapidpay, LLC. Dated: February 1, 2006. Respectfully submitted, /s/ Guy N. Harrison Guy N. Harrison Attorney at Law State Bar No. 00000077 217 N. Center Street P.O. Box 2845 Longview, Texas 75606 Tel: [phone] Fax: [phone] E-Mail: [e-mail]

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument has been forwarded via the Court's CM/ECF Filing System or via first class mail to each attorney/party of record on this 17th day of February, 2006. /s/ Guy N. Harrison Guy N. Harrison

CERTIFICATE OF CONFERENCE Counsel for Defendant Rapidpay, LLC contacted counsel for Plaintiff on this 16th day of February, 2006 and Plaintiff does not oppose this motion. /s/ Guy N. Harrison Guy N. Harrison