i.think inc v. Minekey Inc et al

Filing 15

Unopposed MOTION Dispense With Local Counsel by Internet Unlimited LLC (O'Neil, Dave)

i.think inc v. Minekey Inc et al

Doc. 15

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION i.think.inc. § § Plaintiff § § v. § § MINEKEY, INC., § DELIP ANDRA, and § INTERNET UNLIMITED, LLC § § Defendants §

Case 3-08CV0163-P

JURY TRIAL DEMANDED

DEFENDANT INTERNET UNLIMITED'S UNOPPOSED MOTION FOR LEAVE TO DISPENSE WITH LOCAL COUNSEL REQUIREMNT COMES NOW, INTERNET UNLIMITED, LLC and files this Unopposed Motion For Leave to Dispense with Local Counsel Requirement and respectfully shows: 1. David O'Neil, Attorney-In-Charge for Defendant Internet Unlimited was

first admitted to practice law in the State of Texas on May 21, 1982. Mr. O'Neil was first admitted to the bar of the Southern District of Texas on or before May 30, 1986. He was first admitted to the bar of this court on July 8, 1993. Mr. O'Neil has been constantly licensed to practice law in the State of Texas for over 25 years and no disciplinary or legal malpractice action of any kind has ever been brought against Mr. O'Neil. 2. Mr. O'Neil has familiarized himself with the Local Rules of the Northern

District of Texas. 3. The University of Houston's Bates Law Center conferred an LL.M degree

in Intellectual Property Law upon Mr. O'Neil on August 13, 2005.

Dockets.Justia.com

4.

Mr. O'Neil resides 35 miles north of Houston, approximately 200 miles

from this Honorable Court. Barring conflicts, he can appear in this Court upon one day's notice. 5. Dispensing with the requirement of local counsel would avoid duplication

of effort and spare Internet Unlimited unnecessary expense. PRAYER For the reasons cited, Internet Limited respectfully prays that the Court allow it to proceed without designating local counsel.

Respectfully submitted,

____________________________________ By: David S. O'Neil Attorney-in-Charge O'NEIL & MCCONNELL, PLLC Texas Bar No. 15284715 9001 Forest Crossing Drive, Suite F The Woodlands, Texas 77381 Telephone: [phone] Facsimile: [phone] Email: [e-mail] ATTORNEYS FOR DEFENDANT INTERNET UNLIMITED, LLC

Internet Unlimited's Motion to Dispense With Local Counsel Requirement, page 2

CERTIFICATE OF CONFERENCE I hereby certify that on March 13, 2008 I conferred with Joseph Cox, counsel for Plaintiff, and Barry Bell, counsel for Defendant, and both indicated that they did not oppose this motion.

David S. O'Neil

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been forwarded to the below listed party by ECF on March 13, 2008: Mr. Joseph M. Cox Texas State Bar No. 04950200 Mr. Talcott J. Franklin Texas State Bar No. 24010629 Mr. Lawrence R. Youst Texas State Bar No. 00794898 2001 Ross Avenue Suite 3000 Dallas, Texas 75201 Mr. Craig W. Weinlein Texas State Bar No. 21095500 Mr. Barry R. Bell Texas State Bar No. 02068550 Mr. Omar Kilany Texas State Bar No. 24026974 Carrington, Coleman, Sloman & Blumenthal, LLP 901 Main Street Dallas, Texas 75202

David S. O'Neil

Internet Unlimited's Motion to Dispense With Local Counsel Requirement, page 3