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MOTION TO WITHDRAW AS COUNSEL
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Stephen M. Doniger, Esq. (SBN 179314)Scott A. Burroughs, Esq. (SBN 235718)DONIGER / BURROUGHS APC300 Corporate Pointe, Suite 355Culver City, California 90230Telephone: (310) 590-1820Facsimile: (310) 417-3538E-mail: stephen@donigerlawfirm.comE-mail: scott@donigerlawfirm.comAttorneys for Plaintiff DANIEL JURIN
UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIA
DANIEL JURINPlaintiff,vs.GOOGLE, INC., et al.Defendants.Case No.: CV 09-3934 GHK (Ex)
Honorable George H. King Presiding
NOTICE OF MOTION AND MOTIONTO WITHDRAW AS COUNSEL;DECLARATION OF SCOTT A.BURROUGHS, ESQ.
DATE: August 10, 2009TIME: 9:30 a.m.COURTROOM: 650TO THE HONORABLE COURT, ALL PARTIES, AND THEIR COUNSEL:PLEASE TAKE NOTICE that on August 10, 2009 at 9:30 a.m. or as soonthereafter as the matter may be heard in the above-entitled Court, located at 255 EastTemple Street, Los Angeles, California, in the Courtroom 780, DONIGER / BURROUGHS, APC will and hereby does move the Court to be relieved as counselof record for Plaintiff DANIEL JURIN in this action.
Case 2:09-cv-03934-GHK-E Document 7 Filed 07/15/2009 Page 1 of 7
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MOTION TO WITHDRAW AS COUNSEL
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DANIEL JURIN IS FURTHER NOTIFIED that in order to preserve his legalrights, he should act immediately to retain new counsel in this action.The basis for this Motion is that Doniger / Burroughs APC has been unable tocommunicate effectively with its client, has a difference of opinion with its client inregard to the prosecution of this case, and has been informed that the client does notintend to comply with the terms of the retainer agreement.This motion is made pursuant to Local Rules 83-2.9 of the United StatesDistrict Court for the Central District of California, relevant case authority and theinherent powers of the Court to control its proceedings. This Motion is based on thisNotice of Motion, the attached Memorandum of Points and Authorities theDeclaration of Scott A. Burroughs, Esq., the pleadings and papers on file in theaction, and such further evidence and argument as may be received by the Court at orprior to the hearing of this motion.DATED: July 15, 2009 DONIGER / BURROUGHSBy: /S/ Scott A. BurroughsScott A. Burroughs, Esq.Attorneys for Plaintiff
Case 2:09-cv-03934-GHK-E Document 7 Filed 07/15/2009 Page 2 of 7
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MOTION TO WITHDRAW AS COUNSEL
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MEMORANDUM OF POINTS AND AUTHORITIESI.
INTRODUCTION
As set forth in the Declaration of Scott A. Burroughs, Esq., in May, 2009,DONIGER / BURROUGHS APC (hereinafter “the Firm”) agreed to represent DanielJurin in connection with his claims against Google, Inc. The parties executed aretainer agreement that included the terms under which the Firm would represent Mr.Jurin, which included certain terms relating to the bearing of costs associated withthis matter.On July 10, 2009, our office had an extended teleconference with Mr. Jurinregarding the litigation strategy going forward. This discussion included certainelements of the discovery plan, elements that we believed to be crucial to the successof Mr. Jurin’s claims. There was general disagreement in this regard; and, onespecific element of the discovery plan, which our office considers particularlyintegral, was objected to by Mr. Jurin. Further discussion revealed that he would notsupport the approach advocated by our office in the manner called for in the retaineragreement.Additional communication transpired after this conference, and it becameapparent that our office and Mr. Jurin had irreconcilable differences in the way weviewed the case, and its handling. As such, we informed Mr. Jurin that we would nolonger be able to represent his company in these proceedings, and advised him toimmediately seek new counsel. Give the foregoing, our office respectfully requeststhat this Court grant this request and allow our withdrawal as counsel.
II.
LEGAL ARGUMENTA.
GOOD CAUSE EXISTS TO PERMIT THE WITHDRAWAL
This request to withdraw is within the ambit of the applicable rules. Rule 4-100(c)(1)(d) of the California Rules of Professional Conduct permits an attorney toseek withdrawal from representation of a client when the client “by other conduct
Case 2:09-cv-03934-GHK-E Document 7 Filed 07/15/2009 Page 3 of 7
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