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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
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`Case No. 1:21-cv-00027-LY
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`Plaintiff,
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`MEDIA CHAIN, LLC,
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`v.
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`ROKU, INC.,
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`Defendant.
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`UNOPPOSED MOTION TO WITHDRAW AS ATTORNEY FOR PLAINTIFF
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`Movant, David F. Tamaroff, attorney for Plaintiff, Media Chain, LLC, pursuant to Local
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`Rule AT-3, files this motion to withdraw and states as follows:
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`1.
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`Movant will no longer be able to continue his representation of Plaintiff in this case,
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`and therefore requests the Court grant this motion to withdraw.
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`2.
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`Good cause for Movant’s withdrawal exists pursuant to Rules 4-1.16(b)(1) and (5)
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`of the Rules Regulating the Florida Bar and Rules 1.15(b)(1) and (7) of the Texas Disciplinary
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`Rules of Professional Conduct.
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`3.
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`4.
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`Movant recently disassociated from his previous law firm, Morgan & Morgan, P.A.
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`Plaintiff will continue to be represented in this action by other attorneys from
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`Morgan & Morgan, P.A., including Phillip Sanov, William Lewis (pending admission pro hac
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`vice), and Arletys Hernandez (pending admission pro hac vice). (See D.E. 36-38.)
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`5.
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`6.
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`Plaintiff has been notified of and consents to Movant’s withdrawal.
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`Defendant does not oppose this motion.
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`1
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`Case 1:21-cv-00027-LY Document 41 Filed 08/10/21 Page 2 of 2
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`7.
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`This motion is not filed for purpose of, and the relief sought will not result in, undue
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`delay or prejudice to any party.
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`WHEREFORE, Movant respectfully requests that the Court enter an order discharging
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`David F. Tamaroff as attorney of record for Plaintiff, Media Chain, LLC.
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`CERTIFICATION OF LOCAL RULE CV-7(G) CONFERENCE
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`
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`Movant has conferred with Defendant’s counsel about the relief requested herein.
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`Defendant’s counsel informed that Defendant does not oppose this motion.
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`Dated: August 10, 2021.
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`
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`Respectfully submitted,
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`
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`/s/ David Tamaroff
`David F. Tamaroff
`Florida Bar No. 92084
`TAMAROFF LAW, PLLC
`5727 NW 7th Street #264
`Miami, Florida 33126
`Tel: (305) 350-7440
`Fax: (305) 350-7441
`david@tamarofflaw.com
`Counsel for Plaintiff
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that, on August 10, 2021, I filed the foregoing document with the
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`Clerk of the Court for the Austin Division using the CM/ECF system, which sends notifications
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`of such filings to all counsel of record who have consented to accept service by electronic means.
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`/s/ David Tamaroff
`David F. Tamaroff
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`2
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