Parallel Networks, LLC v. Adidas America, Inc. et al

Filing 354

Unopposed MOTION to Withdraw as Counsel and Request for Termination of Electronic Notices by American Girl LLC, Mattel, Inc.. (Attachments: #1 Text of Proposed Order)(Johnson, Jeffrey)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION PARALLEL NETWORKS, LLC, Plaintiff, v. ADIDAS AMERICA, INC., et al., Defendants. § § § § § § § §

C.A. No. 6:10-cv-491-LED JURY TRIAL DEMANDED

UNOPPOSED MOTION TO WITHDRAW AS COUNSEL AND REQUEST FOR TERMINATION OF ELECTRONIC NOTICES Jeffrey L. Johnson of Pillsbury Winthrop Shaw Pittman LLP, counsel for Defendants American Girl LLC and Mattel, Inc., moves to withdraw his appearance pursuant to Local Rule CV-11(d) and requests the Clerk of this Court remove his name from the list of persons authorized to receive electronic notices pursuant to Local Rule CV-11(f), and in support states the following: 1. American Girl LLC and Mattel, Inc., have retained the law firm of Morgan Lewis

& Bockius to represent them in connection with the above-captioned case. 2. Clay Erik Hawes of Morgan Lewis & Bockius filed a notice of appearance in this

matter on November 22, 2010. 3. American Girl LLC and Mattel, Inc., do not wish to retain Pillsbury Winthrop

Shaw Pittman LLP in relation to this case. 4. this case. WHEREFORE, Jeffrey L. Johnson of Pillsbury Winthrop Shaw Pittman LLP respectfully requests that (1) this Court grant him leave to withdraw as counsel for American Girl LLC and Granting this motion will not create inequity or unduly prejudice the parties in

Mattel, Inc., (2) the Clerk of this Court remove his name from the list of persons authorized to receive electronic notices, and (3) grant such further relief as it deems just and necessary. Dated: November 30, 2010 Respectfully submitted, /s/ Jeffrey L. Johnson Jeffrey L. Johnson State Bar No. 24029638 909 Fannin, Suite 2000 Houston, TX 77010 [phone] [phone] FAX [e-mail] ATTORNEY FOR DEFENDANTS, AMERICAN GIRL LLC and MATTEL, INC.

CERTIFICATE OF CONFERENCE I hereby certify that on November 30, 2010, I conferred with Craig Tadlock, one of the attorneys for Parallel Networks, LLC, who confirmed that Parallel Networks, LLC, is unopposed to this Motion. /s/ Jeffrey L. Johnson Jeffrey L. Johnson

CERTIFICATE OF SERVICE I hereby certify that on November 30, 2010, a true and correct copy of the foregoing Motion to Withdraw as Counsel and Request for Termination of Electronic Notices has been served on counsel of record whom is deemed to have consented to electronic service via the Court's CM/ECF system pursuant to Local Rule CV-5. Any other counsel of record will be served by First Class U.S. mail on this same date. /s/ Jeffrey L. Johnson Jeffrey L. Johnson

2