NOTICE OF REQUEST AND REQUEST FOR LEAVE TO WITHDRAW AS COUNSEL FOR PLAINTIFF; DECLARATION OF EDWIN K. PRATHER IN SUPPORT; ORDER

HAYWOOD S. GILLIAM JR,, District Judge.

NOTICE TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that the law firm of Prather Law Offices and attorney Edwin Prather request leave to withdrawal as co-counsel of record for Plaintiff TSI USA, LLC, in accordance with Northern District Local Civil Rule 11-5.

MOTION OF PRATHER LAW OFFICES FOR LEAVE TO WITHDRAW AS COUNSEL FOR PLAINTIFF

Prather Law Offices and attorney Edwin Prather request leave to withdrawal as co-counsel of record for Plaintiff TSI USA, LLC, pursuant to Northern District Local Civil Rule 11-5.

Withdrawal will neither prejudice Plaintiff nor delay trial, as Plaintiff has been and will continue to be represented by co-counsel Steven Shebar. Mr. Shebar filed all of the pleadings in this case and handled all of the communications with defense counsel and the Court. Mr. Shebar is familiar with the issues presented and need only identify and hire new local co-counsel to assist him in this matter.

Prather Law Offices and Edwin Prather have informed Plaintiff of their intent to sever ties with Plaintiff. Plaintiff has consented to termination of representation. Plaintiff is aware of the requirement that Plaintiff must identify and hire new local co-counsel in this matter.

As such, this Court should grant Prather Law Offices and Edwin Prather's request leave to withdrawal as co-counsel of record for Plaintiff TSI USA, LLC.

DECLARATION OF EDWIN K. PRATHER IN SUPPORT OF REQUEST FOR LEAVE TO WITHDRAW AS COUNSEL FOR PLAINTIFF

I, Edwin K. Prather, am not a party am not a party in the above-titled action. I am over the age of 18, have personal knowledge of the facts and events referred to in this Declaration, and am competent to testify to the matters stated below

[1] I and my law firm, Prather Law Offices, are co-counsel of record for TSI USA, LLC. We serve as local counsel. This Declaration is made in support of our request seeking the Court's leave to withdraw as co-counsel of record for Plaintiff TSI USA, LLC, in accordance with Civil Local Rule 11-5.

[2] On May 19, 2019, I sent an email to co-counsel, Steven Shebar, and provided him with copies of the instant Notice of Request and Request for Leave to Withdraw as Counsel for Plaintiff. As I have never had direct contact with a representative of the client other than Mr. Shebar, I sought to give notice of my request to withdraw to the client through Mr. Shebar. In my May 19, 2019 email, I informed Mr. Shebar that my firm and I sought to withdraw from further representing Plaintiff and asked Mr. Shebar to communicate our withdrawal to the client. I also informed Mr. Shebar that the client needed to retain new local counsel in this matter. Mr. Shebar responded on May 30, 2019, that the client agreed with our withdrawal.

[3] In conformance with the attached proof of service, a copy of this request is being served on the parties through counsel.

I declare under penalty of perjury that the foregoing is true and correct. Executed on May 30, 2019, in San Francisco, California.

ORDER

GOOD CAUSE APPEARING, IT IS HEREBY ORDERED THAT Edwin Prather and Prather Law Offices have withdrawn as counsel of record for Plaintiff TSI USA, LLC. The Clerk of Court is ordered to enter their withdrawal in the case docket.

Plaintiff TSI USA, LLC must retain new local co-counsel within 30 days to comply with Local Civil Rule 11-3 (a)(3), regarding Pro Hac Vice requirements.