Case 5:18-cv-07581-LHK Document 44-2 Filed 03/26/19 Page 1 of 3
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`HARMEET K. DHILLON (SBN: 207873)
`harmeet@dhillonlaw.com
`NITOJ P. SINGH (SBN: 265005)
`nsingh@dhillonlaw.com
`DHILLON LAW GROUP INC.
`177 Post Street, Suite 700
`San Francisco, California 94108
`Telephone: (415) 433-1700
`Facsimile: (415) 520-6593
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`Attorneys for Konda Technologies, Inc.
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`SAN JOSE DIVISION
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`Plaintiff,
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`v.
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`KONDA TECHNOLOGIES, INC., a
`California corporation,
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`FLEX LOGIX TECHNOLOGIES, INC., a
`Delaware corporation, et al.,
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`Defendants.
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`Case Number: 5:18-cv-07581-LHK
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`DECLARATION OF NITOJ P. SINGH
`IN SUPPORT OF MOTION TO
`WITHDRAW AS COUNSEL FOR
`PLAINTIFF KONDA TECHNOLOGIES,
`INC.
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`Judge:
`Court:
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`Hon. Lucy H. Koh
`8, 4th Floor
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`Declaration of Nitoj P. Singh
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`Case Number: 5:18-cv-07581-LHK
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`Case 5:18-cv-07581-LHK Document 44-2 Filed 03/26/19 Page 2 of 3
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`I, Nitoj P. Singh, declare:
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`1.
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`I am a Partner with the Dhillon Law Group Inc. (“DLG”), counsel of record for
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`Plaintiff Konda Technologies, Inc. (“Konda Tech”). I have personal knowledge of the facts stated
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`herein. If called upon to testify, I could and would testify competently thereto.
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`2.
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`As this Declaration is in support of DLG’s motion to be relieved as counsel of record
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`for a client, I will disclose what I believe is the minimum information necessary for this motion and
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`the Court’s information while, at the same time, respecting and maintaining the attorney-client
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`confidences shared between DLG and Konda Tech. If this Court wishes more information from our
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`firm, I am happy to provide it for an in camera review by this Court. Nothing set forth in this
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`Declaration is intended to waive, in any way, the attorney-client privilege between DLG and Konda
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`Tech.
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`3.
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`On March 4, 2019, DLG advised Konda Tech in writing that should it not retain new
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`counsel to substitute in as lead counsel by March 22, 2019, DLG would be moving to withdraw as
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`counsel.
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`4.
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`Konda Tech has been, and remains in, material breach of its engagement agreement
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`with DLG, and has not cured that breach after receiving notice of the breach.
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`5.
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`On March 25, 2019, I notified the Court and Defendants’ counsel that DLG intended
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`to move to withdraw as counsel.
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`6.
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`I advised Konda Tech that it needs counsel should it wish to continue to litigate this
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`matter following DLG’s withdrawal.
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`7.
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`Konda Tech consents to this Motion, while disputing it materially breached its
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`engagement agreement with DLG.
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`8.
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`The parties’ differences of opinion on engagement and strategy, including this Motion,
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`has rendered it unreasonably difficult for DLG to carry out its representation effectively. Given these
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`and other issues, there has been an irreconcilable breakdown of the attorney-client relationship.
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`9.
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`A copy of this Motion will be provided to Konda Tech by email upon filing.
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`///
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`///
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`Declaration of Nitoj P. Singh
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`Case Number: 5:18-cv-07581-LHK
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`Case 5:18-cv-07581-LHK Document 44-2 Filed 03/26/19 Page 3 of 3
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct.
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`Date: March 26, 2019
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`By:
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` Nitoj P. Singh
`Nitoj P. Singh
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`Declaration of Nitoj P. Singh
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`Case Number: 5:18-cv-07581-LHK
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