Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 1 of 19
`
`Exhibit B
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674 Filed 05/12/21 Page 1 of 3Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 2 of 19
`
`MICHAEL A. SHERMAN (SBN 94783)
`masherman@stubbsalderton.com
`JEFFREY F. GERSH (SBN 87124)
`jgersh@stubbsalderton.com
`WESLEY W. MONROE (SBN 149211)
`wmonroe@stubbsalderton.com
`VIVIANA BOERO HEDRICK (SBN 239359)
`vhedrick@stubbsalderton.com
`STUBBS ALDERTON & MARKILES, LLP
`15260 Ventura Blvd., 20th Floor
`Sherman Oaks, CA 91403
`Telephone:
`(818) 444-4500
`Facsimile:
`(818) 444-4520
`Attorneys for PERSONALWEB
`TECHNOLOGIES, LLC
`(Excluding Post Judgment Debtor
`Collection Proceedings)
`
`AMAZON.COM, INC. and AMAZON WEB
`SERVICE, INC.,
` Plaintiffs,
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`CASE NO.: 5:18-md-02834-BLF
`IN RE PERSONAL WEB TECHNOLOGIES,
`LLC, ET., AL., PATENT LITIGATION
`Case No.: 5:18-cv-00767-BLF
`Case No.: 5:18-cv-05619-BLF
`NOTICE OF MOTION AND MOTION OF
`STUBBS ALDERTON & MARKILES TO
`WITHDRAW AS COUNSEL FOR
`PERSONALWEB TECHNOLOGIES, LLC
`DECLARATION OF JEFFREY F. GERSH
`FILED IN SUPPORT; [PROPOSED]
`ORDER
`Hearing: June 17, 2021
`Time: 9:00 a.m.
`Judge:
`Hon. Beth Labson Freeman
`
`v.
`PERSONALWEB TECHNOLOGIES, LLC, et
`al.,
`
` Defendants.
`PERSONALWEB TECHNOLOGIES, LLC, et
`al.,
`
`Plaintiffs,
`
`v.
`TWITCH INTERACTIVE, INC.,
`
`Defendant.
`
`1
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`20
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`27
`28
`
`MOTION TO WITHDRAW
`AS COUNSEL OF RECORD
`
`4838-3604-8523, V. 2
`
`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-00767-BLF
`CASE NO.: 5:18-cv-05619-BLF
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674 Filed 05/12/21 Page 2 of 3Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 3 of 19
`
`
`
`1
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`
`
`4838-3604-8523, V. 2
`
`I.
`
`NOTICE OF MOTION
`TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
`PLEASE TAKE NOTICE that on June 17, 2021 at 9:00 a.m., or as soon thereafter as the matter
`may be heard before the Honorable Beth Labson Freeman, Courtroom 3, 5th Floor, of the United
`States District Court for the Northern District of California, San Jose Division, 280 South First Street,
`San Jose, California 95113, Stubbs Alderton & Markiles, LLP (“SAM”), will and hereby does move
`the Court, pursuant to Civil Local Rule 11-5(a) and in compliance with California Rule of Professional
`Conduct 1.16, to withdraw as counsel for PersonalWeb Technologies, LLC (“PersonalWeb”).
`
`
`MOTION TO WITHDRAW AS COUNSEL FOR PERSONALWEB
`INTRODUCTION
`Pursuant to Civil Local Rule 11-5, SAM seeks to withdraw as counsel for PersonalWeb. SAM
`has not been retained to represent PersonalWeb in any post judgment collection proceedings and to
`SAM’s knowledge PersonalWeb has engaged other counsel for that purpose. Based on the foregoing,
`SAM respectfully requests that the Court issue an order granting withdrawal.
`LEGAL ARGUMENT
`II.
`Civil Local Rule 11-5(a) permits withdrawal of counsel by “order of Court after written notice
`has been given reasonably in advance to the client and to all other parties who have appeared in the
`case.” Pursuant to the California Rules of Professional Conduct, Rule 1.16(b)(6), an attorney may
`withdraw from representing a client if “the client knowingly and freely assents to termination of the
`representation.” Prior to the receipt of the legal authorities cited by Amazon/Twitch in their filing on
`Monday, May 10, 2021, SAM reasonably believed that the entry of judgment, conclusion of the
`disposition of the motion on attorneys’ fees, and administrative closing of this case resulted in the
`termination of SAM’s counsel of record status for PersonalWeb in the District Court.
`Here, SAM should be permitted to withdraw because PersonalWeb assents to termination of
`SAM’s representation since PersonalWeb never retained SAM to represent it in any post judgment
`collection proceedings. (Gersh Decl., ¶ 2.) SAM’s engagement as counsel for PersonalWeb has been
`(1) limited to proceedings pending in this court up through entry of judgment and proceedings relating
`
`
`
`MOTION TO WITHDRAW
`AS COUNSEL OF RECORD
`
`
`1
`
`
`
`
`
`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-00767-BLF
`CASE NO.: 5:18-cv-05619-BLF
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674 Filed 05/12/21 Page 3 of 3Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 4 of 19
`
`
`
`to Amazon/Twitch’s motion for attorneys’ fees and costs, and (2) the appeals relating thereto pending
`in the United States Court of Appeals for the Federal Circuit, Case Nos. 19-1918, 20-1566, 21-1858,
`and the Petition for a Writ of Certiorari pending in the United States Supreme Court, Case No. 20-
`1394. (Gersh Decl., ¶¶ 2, 3.) PersonalWeb has engaged Ronald Richards of the Law Offices of Ronald
`Richards and Associates, APC to represent it in all post judgment collection proceedings. (Gersh Decl.,
`¶ 4, Ex. A.) Indeed, Mr. Richards sent an email communication to SAM attorneys expressly informing
`them that SAM is “not authorized to do anything post judgment” and that SAM “is only engaged for
`the appeal.” (Id., Ex. B.)
`III. CONCLUSION
`Based on the foregoing, SAM respectfully requests the Court grant this Motion and permit it
`
`to withdraw from this case.
`
`
`
`Respectfully submitted,
`
`Dated: May 12, 2021
`
`
`
`
`STUBBS, ALDERTON & MARKILES, LLP
`
`
`
`By: /s/ Michael A. Sherman
`Michael A. Sherman
`Jeffrey F. Gersh
`Wesley W. Monroe
`Viviana Boero Hedrick
`
`Attorneys for PERSONALWEB
`TECHNOLOGIES, LLC
`(Excluding Post Judgment Debtor
`Collection Proceedings)
`
`
`
`
`MOTION TO WITHDRAW
`AS COUNSEL OF RECORD
`
`
`2
`
`
`
`
`
`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-00767-BLF
`CASE NO.: 5:18-cv-05619-BLF
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`4838-3604-8523, V. 2
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-1 Filed 05/12/21 Page 1 of 3Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 5 of 19
`
`
`
`MICHAEL A. SHERMAN (SBN 94783)
`masherman@stubbsalderton.com
`JEFFREY F. GERSH (SBN 87124)
`jgersh@stubbsalderton.com
`WESLEY W. MONROE (SBN 149211)
`wmonroe@stubbsalderton.com
`VIVIANA BOERO HEDRICK (SBN 239359)
`vhedrick@stubbsalderton.com
`STUBBS ALDERTON & MARKILES, LLP
`15260 Ventura Blvd., 20th Floor
`Sherman Oaks, CA 91403
`Telephone:
`(818) 444-4500
`Facsimile:
`(818) 444-4520
`
`Attorneys for PERSONALWEB
`TECHNOLOGIES, LLC
`(Excluding Post Judgment Debtor
`Collection Proceedings)
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`CASE NO.: 5:18-md-02834-BLF
`IN RE PERSONAL WEB TECHNOLOGIES,
`LLC, ET., AL., PATENT LITIGATION
`Case No.: 5:18-cv-00767-BLF
`
`Case No.: 5:18-cv-05619-BLF
`DECLARATION OF JEFFREY F. GERSH
`IN SUPPORT OF NOTICE OF MOTION
`AND MOTION OF STUBBS ALDERTON
`& MARKILES, LLP TO WITHDRAW AS
`COUNSEL FOR PERSONALWEB
`TECHNOLOGIES, LLC
`
`
`AMAZON.COM, INC. and AMAZON WEB
`SERVICE, INC.,
`
` Plaintiffs,
`v.
`PERSONALWEB TECHNOLOGIES, LLC, et
`al.,
` Defendants.
`
`PERSONALWEB TECHNOLOGIES, LLC, et
`al.,
`
`
`
`
`v.
`
`TWITCH INTERACTIVE, INC.,
`
`
`
`Plaintiffs,
`
`Defendant.
`
`
`
`GERSH DECL. ISO MOTION TO WITHDRAW
`AS COUNSEL OF RECORD
`
`
`
`
`
`
`
`
`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-00767-BLF
`CASE NO.: 5:18-cv-05619-BLF
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`4838-3604-8523, V. 2
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-1 Filed 05/12/21 Page 2 of 3Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 6 of 19
`
`
`
`I am a member of the bar of the State of California and am admitted to practice
`1.
`before the United States District Court for the Northern District of California. I am a partner at
`Stubbs Alderton & Markiles, LLP (“SAM”). The facts herein are, unless otherwise stated, based
`upon personal knowledge, and if called upon to do so, I could, and would testify to their truth
`under oath. I submit this declaration in support of SAM’s Motion to Withdraw as Counsel for
`PersonalWeb.
`PersonalWeb never retained SAM to represent it in any post judgment collection
`2.
`proceedings. Rather, SAM was engaged by PersonalWeb to represent it in the above-captioned
`actions up through entry of judgment and relating to Amazon and Twitch’s motion for attorneys’
`fees and costs.
`SAM now remains engaged as counsel for PersonalWeb relating only to
`3.
`PersonalWeb’s appeals pending in the United States Court of Appeals for the Federal Circuit,
`Case Nos. 19-1918, 20-1566, 21-1858, and the Petition for a Writ of Certiorari pending in the
`United States Supreme Court, Case No. 20-1394.
` It is my understanding that Personal Web has engaged Ronald Richards of the Law
`4.
`Offices of Ronald Richards and Associates, APC to represent it in all post judgment collection
`proceedings. On April 27, 2021, I received an email from Mr. Richards wherein he advised me,
`other SAM attorneys, and Todd Gregorian, counsel for Amazon and Twitch in this action, that
`his office was engaged to represent PersonalWeb on all post judgment collection proceedings.
`Attached hereto as Exhibit A is a true and correct copy of this email. That same day, I received
`another email from Mr. Richards wherein he notified me that neither myself nor anyone at SAM
`is authorized to do anything post judgment, and that SAM was only engaged by PersonalWeb on
`the pending appeals. Mr. Richards further requested that I confirm receipt and acknowledge the
`limited scope of SAM’s representation of PersonalWeb, which I did. Attached hereto as Exhibit
`B is a true and correct copy of this second email from Mr. Richards, and my response thereto.
`
`///
`
`///
`
`///
`
`///
`
`
`GERSH DECL. ISO MOTION TO WITHDRAW
`AS COUNSEL OF RECORD
`
`
`1
`
`
`
`
`
`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-00767-BLF
`CASE NO.: 5:18-cv-05619-BLF
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
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`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
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`28
`
`
`4838-3604-8523, V. 2
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-1 Filed 05/12/21 Page 3 of 3Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 7 of 19
`
`
`
`5. At the time of the filing of this motion, Mr. Richards had not yet filed a notice of
`appearance with this Court.
`
`Executed this 12th day of May, Paso Robles, California.
`
`
`
`
`
`By: /s/ Jeffrey F. Gersh
`Jeffrey F. Gersh
`
`
`
`
`
`
`
`GERSH DECL. ISO MOTION TO WITHDRAW
`AS COUNSEL OF RECORD
`
`
`2
`
`
`
`
`
`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-00767-BLF
`CASE NO.: 5:18-cv-05619-BLF
`
`1
`2
`3
`4
`5
`6
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`8
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`10
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`14
`15
`16
`17
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`20
`21
`22
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`24
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`26
`27
`28
`
`
`4838-3604-8523, V. 2
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-2 Filed 05/12/21 Page 1 of 5Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 8 of 19
`
`Exhibit A
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-2 Filed 05/12/21 Page 2 of 5Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 9 of 19
`
`From:
`To:
`Cc:
`Subject:
`Date:
`
`Ronald Richards
`Todd Gregorian; Morani Stelmach
`Michael Sherman; Jeffrey Gersh; Viviana Boero Hedrick; Lamken, Jeffrey
`RE: PERSONALWEB TECHONLOGIES INC.
`Tuesday, April 27, 2021 2:10:23 PM
`
`[EXTERNAL EMAIL] This email is from an external sender, and not from Stubbs
`Alderton & Markiles.
`Do not click on links or attachments unless you are sure of the sender.
`
`Hi Todd,
`
`Your confused. That is an order that has to be served per California procedure.
`
`You applied for an ORAP. You now have your order.
`
`The order is pursuant to your application where you represented you were taking an ORAP. Once
`your serve it, we will deal with it. We are engaged to represent the entity upon service any valid
`post judgment order that complies with California law.
`
`If you are taking the position you do not need to serve this order per the CCP which applies to the
`federal court per the federal rules, I will immediately take further action to protect our client or do
`nothing depending on your position.
`
`We are now engaged FYI but you haven’t done anything yet that requires our representation.
`
`
`
`
`
`Sincerely,
`
`Ronald Richards, Esq.
`Law Offices of Ronald Richards & Associates, A.P.C.
`310-556-1001 Office
`310-277-3325 Fax
`www.ronaldrichards.com
`
`Mailing Address:
`P.O. Box 11480
`Beverly Hills, CA 90213
` ®
`
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-2 Filed 05/12/21 Page 3 of 5Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 10 of 19
`
` **A multi jurisdictional practice with bar admissions on the East and West Coast**
` ***CONFIDENTIALITY NOTICE*** This electronic mail transmission has been sent by an
`attorney. This message and any files or text attached to it are intended only for the
`recipients named above, and contain information that may be confidential or privileged.
`If you are not an intended recipient, you must not read, copy, use or disclose this
`communication. Please also notify the sender by replying to this message, and then
`delete all copies of it from your system. Thank you.
`________________________________
`THINK GREEN. PLEASE CONSIDER THE ENVIRONMENT BEFORE YOU PRINT THIS
`MESSAGE. THANK YOU.
`
`
`
`
`
`
`
`From: Todd Gregorian <TGregorian@fenwick.com>
`Sent: Tuesday, April 27, 2021 2:03 PM
`To: Ronald Richards <ron@ronaldrichards.com>; Morani Stelmach <morani@ronaldrichards.com>
`Cc: Michael Sherman <masherman@stubbsalderton.com>; Jeffrey Gersh
`<jgersh@stubbsalderton.com>; Viviana Boero Hedrick <vhedrick@stubbsalderton.com>; Lamken,
`Jeffrey <jlamken@mololamken.com>
`Subject: RE: PERSONALWEB TECHONLOGIES INC.
`
`Ron,
`
`Please let me know when you are retained. Until then we will continue to deal with PersonalWeb’s
`counsel of record (the Stubbs Alderton attorneys cc’ed), who have not withdrawn from the case.
`The Court has ordered that PersonalWeb produce its bank and financial account information by May
`7 and its remaining financial records within 30 days.
`
`
`Todd Gregorian
`Fenwick | Partner | 415-875-2402 | tgregorian@fenwick.com
`
`
`
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-2 Filed 05/12/21 Page 4 of 5Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 11 of 19
`
`From: Ronald Richards <ron@ronaldrichards.com>
`Sent: Monday, April 26, 2021 3:39 PM
`To: Todd Gregorian <TGregorian@fenwick.com>
`Cc: Morani Stelmach <morani@ronaldrichards.com>
`Subject: PERSONALWEB TECHONLOGIES INC.
`
`** EXTERNAL EMAIL **
`
`Dear Mr. Gregorian,
`
`Our firm is going to be retained in the next day or two to handle any post judgment matters you
`bring. This is not my only file but we will respond as quickly as possible to any demands upon legal
`service.
`
`As you know, post judgment matters are handled by the magistrate and we are not going to appear
`in the underlying case except for post judgment motions if for some reason we need to involve the
`Court.
`
`Hopefully that won’t be necessary.
`
`Presently the case is on appeal and the divestiture rule applies.
`
`There is no rush to do anything pending the outcome of that appeal.
`
`Once we are retained, I am happy to have a call with you to discuss this matter.
`
`
`Sincerely,
`
`Ronald Richards, Esq.
`Law Offices of Ronald Richards & Associates, A.P.C.
`310-556-1001 Office
`310-277-3325 Fax
`www.ronaldrichards.com
`
`Mailing Address:
`P.O. Box 11480
`Beverly Hills, CA 90213
` ®
`
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-2 Filed 05/12/21 Page 5 of 5Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 12 of 19
`
` **A multi jurisdictional practice with bar admissions on the East and West Coast**
` ***CONFIDENTIALITY NOTICE*** This electronic mail transmission has been sent by an
`attorney. This message and any files or text attached to it are intended only for the
`recipients named above, and contain information that may be confidential or privileged.
`If you are not an intended recipient, you must not read, copy, use or disclose this
`communication. Please also notify the sender by replying to this message, and then
`delete all copies of it from your system. Thank you.
`________________________________
`THINK GREEN. PLEASE CONSIDER THE ENVIRONMENT BEFORE YOU PRINT THIS
`MESSAGE. THANK YOU.
`
`
`
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-3 Filed 05/12/21 Page 1 of 5Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 13 of 19
`
`Exhibit B
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-3 Filed 05/12/21 Page 2 of 5Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 14 of 19
`
`From:
`To:
`Cc:
`Subject:
`Date:
`
`Jeffrey Gersh
`Ronald Richards; Todd Gregorian; Morani Stelmach
`Michael Sherman; Viviana Boero Hedrick; Lamken, Jeffrey
`RE: PERSONALWEB TECHONLOGIES INC.
`Tuesday, April 27, 2021 2:33:31 PM
`
`I understand.
`
`Thank you.
`
`JG
`
`
`Jeffrey F. Gersh
`Partner, Stubbs Alderton & Markiles, LLP
`818.444.9222 (voice/text/fax) | jgersh@stubbsalderton.com
`www.stubbsalderton.com | Attorney Bio
`15260 Ventura Blvd., 20th FL, Sherman Oaks, CA 91403
`
`
`
`The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an
`attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or an agent
`responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination,
`distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the
`original message.
`From: Ronald Richards <ron@ronaldrichards.com>
`Sent: Tuesday, April 27, 2021 2:18 PM
`To: Jeffrey Gersh <jgersh@stubbsalderton.com>; Todd Gregorian <TGregorian@fenwick.com>; Morani Stelmach
`<morani@ronaldrichards.com>
`Cc: Michael Sherman <masherman@stubbsalderton.com>; Viviana Boero Hedrick <vhedrick@stubbsalderton.com>;
`Lamken, Jeffrey <jlamken@mololamken.com>
`Subject: RE: PERSONALWEB TECHONLOGIES INC.
`
`[EXTERNAL EMAIL] This email is from an external sender, and not from Stubbs Alderton & Markiles.
`Do not click on links or attachments unless you are sure of the sender.
`
`Mr. Gersh,
`
`You are not authorized to do anything post judgment. The case is on appeal. There is no jurisdiction with this Court
`pending the appeal except for collateral post judgment matters per Code.
`
`If Mr. Gregorian, who I do not know personally but feels free to call me by my first name and the wrong one at that, does
`not serve my office, please forward any documents.
`
`Your office is only engaged for the appeal. Please confirm receipt and acknowledgment of the above.
`
`
`
`
`
`Sincerely,
`
`Ronald Richards, Esq.
`Law Offices of Ronald Richards & Associates, A.P.C.
`310-556-1001 Office
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-3 Filed 05/12/21 Page 3 of 5Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 15 of 19
`
`310-277-3325 Fax
`www.ronaldrichards.com
`
`Mailing Address:
`P.O. Box 11480
`Beverly Hills, CA 90213
` ®
`
`
` **A multi jurisdictional practice with bar admissions on the East and West Coast**
` ***CONFIDENTIALITY NOTICE*** This electronic mail transmission has been sent by an attorney. This
`message and any files or text attached to it are intended only for the recipients named above, and contain
`information that may be confidential or privileged. If you are not an intended recipient, you must not read,
`copy, use or disclose this communication. Please also notify the sender by replying to this message, and then
`delete all copies of it from your system. Thank you.
`________________________________
`THINK GREEN. PLEASE CONSIDER THE ENVIRONMENT BEFORE YOU PRINT THIS MESSAGE. THANK YOU.
`
`
`
`
`
`From: Jeffrey Gersh <jgersh@stubbsalderton.com>
`Sent: Tuesday, April 27, 2021 2:16 PM
`To: Todd Gregorian <TGregorian@fenwick.com>; Ronald Richards <ron@ronaldrichards.com>; Morani Stelmach
`<morani@ronaldrichards.com>
`Cc: Michael Sherman <masherman@stubbsalderton.com>; Viviana Boero Hedrick <vhedrick@stubbsalderton.com>;
`Lamken, Jeffrey <jlamken@mololamken.com>
`Subject: RE: PERSONALWEB TECHONLOGIES INC.
`
`Todd
`
`As I told you before and I will tell you again, we are not counsel for Personal Web in any of the
`post judgment collection proceedings, only the appeals. Nothing has changed. We have never
`agreed to accept service for the client, verbally or otherwise.
`
`JG
`
`
`Jeffrey F. Gersh
`Partner, Stubbs Alderton & Markiles, LLP
`818.444.9222 (voice/text/fax) | jgersh@stubbsalderton.com
`www.stubbsalderton.com | Attorney Bio
`15260 Ventura Blvd., 20th FL, Sherman Oaks, CA 91403
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-3 Filed 05/12/21 Page 4 of 5Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 16 of 19
`
`
`
`The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an
`attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or an agent
`responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination,
`distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the
`original message.
`From: Todd Gregorian <TGregorian@fenwick.com>
`Sent: Tuesday, April 27, 2021 2:03 PM
`To: Ronald Richards <ron@ronaldrichards.com>; Morani Stelmach <morani@ronaldrichards.com>
`Cc: Michael Sherman <masherman@stubbsalderton.com>; Jeffrey Gersh <jgersh@stubbsalderton.com>; Viviana Boero
`Hedrick <vhedrick@stubbsalderton.com>; Lamken, Jeffrey <jlamken@mololamken.com>
`Subject: RE: PERSONALWEB TECHONLOGIES INC.
`
`[EXTERNAL EMAIL] This email is from an external sender, and not from Stubbs Alderton & Markiles.
`Do not click on links or attachments unless you are sure of the sender.
`
`Ron,
`
`Please let me know when you are retained. Until then we will continue to deal with PersonalWeb’s counsel of record (the
`Stubbs Alderton attorneys cc’ed), who have not withdrawn from the case. The Court has ordered that PersonalWeb
`produce its bank and financial account information by May 7 and its remaining financial records within 30 days.
`
`
`Todd Gregorian
`Fenwick | Partner | 415-875-2402 | tgregorian@fenwick.com
`
`
`
`From: Ronald Richards <ron@ronaldrichards.com>
`Sent: Monday, April 26, 2021 3:39 PM
`To: Todd Gregorian <TGregorian@fenwick.com>
`Cc: Morani Stelmach <morani@ronaldrichards.com>
`Subject: PERSONALWEB TECHONLOGIES INC.
`
`** EXTERNAL EMAIL **
`
`Dear Mr. Gregorian,
`
`Our firm is going to be retained in the next day or two to handle any post judgment matters you bring. This is not my only
`file but we will respond as quickly as possible to any demands upon legal service.
`
`As you know, post judgment matters are handled by the magistrate and we are not going to appear in the underlying case
`except for post judgment motions if for some reason we need to involve the Court.
`
`Hopefully that won’t be necessary.
`
`Presently the case is on appeal and the divestiture rule applies.
`
`There is no rush to do anything pending the outcome of that appeal.
`
`Once we are retained, I am happy to have a call with you to discuss this matter.
`
`
`Sincerely,
`
`Ronald Richards, Esq.
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-3 Filed 05/12/21 Page 5 of 5Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 17 of 19
`
`Law Offices of Ronald Richards & Associates, A.P.C.
`310-556-1001 Office
`310-277-3325 Fax
`www.ronaldrichards.com
`
`Mailing Address:
`P.O. Box 11480
`Beverly Hills, CA 90213
` ®
`
`
` **A multi jurisdictional practice with bar admissions on the East and West Coast**
` ***CONFIDENTIALITY NOTICE*** This electronic mail transmission has been sent by an attorney. This
`message and any files or text attached to it are intended only for the recipients named above, and contain
`information that may be confidential or privileged. If you are not an intended recipient, you must not read,
`copy, use or disclose this communication. Please also notify the sender by replying to this message, and then
`delete all copies of it from your system. Thank you.
`________________________________
`THINK GREEN. PLEASE CONSIDER THE ENVIRONMENT BEFORE YOU PRINT THIS MESSAGE. THANK YOU.
`
`
`
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-4 Filed 05/12/21 Page 1 of 2Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 18 of 19
`
`
`
`MICHAEL A. SHERMAN (SBN 94783)
`masherman@stubbsalderton.com
`JEFFREY F. GERSH (SBN 87124)
`jgersh@stubbsalderton.com
`WESLEY W. MONROE (SBN 149211)
`wmonroe@stubbsalderton.com
`VIVIANA BOERO HEDRICK (SBN 239359)
`vhedrick@stubbsalderton.com
`STUBBS, ALDERTON & MARKILES, LLP
`15260 Ventura Blvd., 20th Floor
`Sherman Oaks, CA 91403
`Telephone:
`(818) 444-4500
`Facsimile:
`(818) 444-4520
`
`Attorneys for PERSONALWEB
`TECHNOLOGIES, LLC
`(Excluding Post Judgment Debtor
`Collection Proceedings)
`
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`CASE NO.: 5:18-md-02834-BLF
`IN RE PERSONAL WEB TECHNOLOGIES,
`LLC, ET., AL., PATENT LITIGATION
`Case No.: 5:18-cv-00767-BLF
`
`Case No.: 5:18-cv-05619-BLF
`[PROPOSED] ORDER GRANTING
`MOTION OF STUBBS ALDERTON &
`MARKILES, LLP TO WITHDRAW AS
`COUNSEL FOR PERSONALWEB
`TECHNOLOGIES, LLC
`
`
`AMAZON.COM, INC. and AMAZON WEB
`SERVICE, INC.,
`
` Plaintiffs,
`v.
`PERSONALWEB TECHNOLOGIES, LLC, et
`al.,
` Defendants.
`
`PERSONALWEB TECHNOLOGIES, LLC, et
`al.,
`
`
`
`
`v.
`
`TWITCH INTERACTIVE, INC.,
`
`
`
`Plaintiffs,
`
`Defendant.
`
`
`
`[PROPOSED ORDER GRANTING MOTION
`OF SAM TO WITHDRAW AS COUNSEL
`
`
`
`
`
`
`
`
`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-00767-BLF
`CASE NO.: 5:18-cv-05619-BLF
`
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`
`
`4838-3604-8523, V. 2
`
`

`

`
`
`Case 5:18-md-02834-BLF Document 674-4 Filed 05/12/21 Page 2 of 2Case 5:18-md-02834-BLF Document 683-2 Filed 05/19/21 Page 19 of 19
`
`Stubbs Alderton & Markiles, LLP (“SAM”) has moved to withdraw as counsel for
`PersonalWeb Technologies, LLC (“PersonalWeb”) in the above-captioned litigation pursuant to Civil
`Local Rule 11-5(a) and California Rules of Professional Conduct, Rule 1.16(b)(6). As this Court finds
`that SAM has submitted a satisfactory basis for withdrawal, and that the granting of this Motion will
`not cause substantial prejudice or delay to any party, it is hereby ordered that the motion to withdraw
`as counsel for PersonalWeb is granted, and SAM is hereby terminated as counsel of record for
`PersonalWeb in this proceeding.
`
`IT IS SO ORDERED:
`
`DATED:
`
`
`
`HON. BETH LABSON FREEMAN
`
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`PROPOSED ORDER GRANTING MOTION
`OF SAM TO WITHDRAW AS COUNSEL
`
`1
`
`CASE NO: 5:18-md-02834-BLF
`CASE NO: 5:18-cv-00767-BLF
`CASE NO.: 5:18-cv-05619-BLF
`
`