`
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
`
`
`B.E. TECHNOLOGY, L.L.C.,
`
`
`Civil Action No. 2:12-cv-02833-JPM-tmp
`
`
`
`))))))))))
`
`
`
`
`
`
`
`
`
` v.
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`Plaintiff,
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`Defendant.
`
`
`PEOPLE MEDIA, INC.,
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`
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`MOTION TO WITHDRAW AS COUNSEL
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`Comes now Jonathan D. Rose, pursuant to LR83.5, and respectfully moves for
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`permission to withdraw as counsel for People Media, Inc. As grounds for this motion, the
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`undersigned states that he is departing the law firm Bradley Arant Boult Cummings, LLP, to
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`serve as in-house counsel for an unrelated entity. No party will be prejudiced by the granting of
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`this motion because this case is in its early stages and because People Media, Inc. will continue
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`to be represented by Steven G. Schortgen, Jennifer Klein Ayers, Sanjay K. Murthy, and
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`Christopher E. Hanba of K&L Gates LLP. Additionally, H. Frederick Humbracht, Jr. of Bradley
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`Arant Boult Cummings, LLP and a member of the bar of this Court, has entered has appearance
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`as additional counsel for People Media, Inc.
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`
`
`WHEREFORE, Jonathan D. Rose respectfully request that he be deemed withdrawn as
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`counsel for People Media, Inc. in this action.
`
`
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`1
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`
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`Case 2:12-cv-02833-JPM-tmp Document 58 Filed 08/16/13 Page 2 of 4 PageID 526
`
`
`CERTIFICATION OF CONSULTATION
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`Pursuant to LR 7.2(a)(1)(B), the undersigned certifies that he spoke with counsel for B.E.
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`Technologies, Richard Carter, by telephone on August 16, 2013, and was authorized by Mr.
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`Carter to state that the Plaintiff consents to the relief sought herein.
`
`
`
`
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`
`
`
`
`
`
`
`
`
`
`
`
`
`
` s/ Jonathan D. Rose
`Jonathan D. Rose
`
`
`
`2
`
`
`
`Case 2:12-cv-02833-JPM-tmp Document 58 Filed 08/16/13 Page 3 of 4 PageID 527
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
` s/ Jonathan D. Rose
`H. Frederick Humbracht, Jr. (No. 2993)
`rhumbracht@babc.com
`Jonathan D. Rose (No. 20967)
`jrose@babc.com
`BRADLEY ARANT BOULT CUMMINGS LLP
`1600 Division Street, Suite 700
`Nashville, Tennessee 37203
`(615) 252-2371
`(615) 252-6371 Facsimile
`
`Steven G. Schortgen, pro hac vice
`Texas Bar No. 00794603
`steve.schortgen@klgates.com
`Jennifer Klein Ayers, pro hac vice
`Texas Bar No. 24069322
`jennifer.ayers@klgates.com
`K&L GATES LLP
`1717 Main Street, Suite 2800
`Dallas, TX 75201
`(214) 939-5500
`(214) 939-5849 Facsimile
`
`Sanjay K. Murthy, pro hac vice
`Illinois Bar No. 6279314
`sanjay.murthy@klgates.com
`Christopher E. Hanba, pro hac vice
`Illinois Bar No. 6298424
`christopher.hanba@klgates.com
`K&L GATES LLP
`70 W. Madison Street
`Suite 3100
`Chicago, Illinois 60602-4207
`(312) 372-1121
`(312) 827-8000 Facsimile
`
`Attorneys for Defendant
`
`
`
`
`
`3
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`
`
`Case 2:12-cv-02833-JPM-tmp Document 58 Filed 08/16/13 Page 4 of 4 PageID 528
`
`
`CERIFICATE OF SERVICE
`
`
`
`I hereby certify that on August 16, 2013, the foregoing is being served the foregoing via
`the Court’s Electronic Filing System, upon the following:
`
`Craig Robert Kaufman
`Robert Edward Freitas
`Hsiang Hong Lin
`Qudas B. Olaniran
`FREITAS TSENG & KAUFMAN, LLP
`100 Marine Parkway, Suite 200
`Redwood Shores, CA 94065
`
`Richard M. Carter
`Adam Calhoun Simpson
`MARTIN TATE MORROW & MARSTON
`International Place, Tower II
`6410 Poplar Ave., Ste. 1000
`Memphis, TN 38119
`
`
`
`
`
`
`
`
`
`
`
`
`
` s/ Jonathan D. Rose
`Jonathan D. Rose
`
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`
`4
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