A.R. v. Cardiff Sport Technologies, LLC

District Court, D. Nevada

A.R. v. Cardiff Sport Technologies, LLC

Trial Court Opinion

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1 || ROBERT M. ADAMS, ESQ. 2 Nevada Bar No. 6551 EGLET ADAMS 3 || 400 South 7® Street, 4” Floor Las Vegas, Nevada 89101 4 || E-Mail: [email protected] 5 || Tel: (702) 450-5400 Fax: (702) 450-5451 6 || Attorney for Plaintiff 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 10 A.R., a minor, by and through his Guardian Ad | Case No.: 3:18-CV-00240-LRH-CBC Litem, Michael Ries, uM Plaintiff, 12 COUNSEL’S MOTION TO WITHDRAW 0 vs. AS COUNSEL OF RECORD < 3 CARDIFF SPORT TECHNOLOGIES, LLC, 14 || dba CARDIFF SKATE COMPANY, a Delaware _limited _liability | company; 15 || BROOKSTONE STORES, INC., a foreign corporation dba BROOKSTONE; DOES ! 16]] through 300, inclusive; © ROE 7 CORPORATIONS | through 300, inclusive, UO 18 Defendants.

19 COMES NOW, ROBERT M. ADAMS, ESQ of the law firm EGLET ADAMS, ani 20 pursuant to Local Rule 11-6 of the U.S. District Court Rules, District of Nevada, hereby move 21 |) to withdraw as attorney of record for Plaintiff, A.R., a minor. 22 23 24 25 26 27 | 28 eee

1 The Motion is made based upon the Points and Authorities and the Affidavit of counse 2 || attached hereto as Exhibit “1.” 4 DATED this 19th day of July, 2019. 5 EGLET ADAMS 8 By: 9 ROBERT M. ADAMS, ESQ. Nevada Bar No. 6551 10

400 South 7

Street, 4" Floor Las Vegas, Nevada 89101 1 E-Mail: [email protected] 2 Tel.: (702) 450-5400 Fax: (702) 450-5451 13 Attorney for Plaintiff 14 > 1. IS MEMORANDUM OF POINTS AND AUTHORITIES 16 A. Plaintiff's Counsel’s Motion to Withdraw: 17 An attorney may file an application to withdraw from representation of a client “by leav 18 of the court after notice has been served on the affected client and opposing counsel,” Local Rul 19 11-6. Further, “except for good cause shown, no withdrawal or substitution shall be approved i 2 it will result in delay of discovery, the trial, or any hearing in the case. Where delay would 21 result, the papers seeking leave of court for the withdrawal or substitution must request specific 22 relief from the scheduled discovery, trial, or hearing.” Local Rule 11-6. 23 Plaintiff is represented by DENNIS M. PRINCE, ESQ. and ROBERT M. ADAMS, ESC 24 Until recently, both Mr. PRINCE and Mr. ADAMS worked for the law firm EGLET PRINCE'. 25 Mr. PRINCE departed the firm. Plaintiff's case was overseen by Mr. PRINCE while he worked 26 at EGLET PRINCE, and Mr. PRINCE will remain as lead counsel for Plaintiff. 27 28 ' Now doing business as EGLET ADAMS.

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1 ||Mr. PRINCE departed the firm. Plaintiff's case was overseen by Mr. PRINCE while he worked 2 || at EGLET PRINCE, and Mr. PRINCE will remain as lead counsel for Plaintiff. 3 Il. 4 CONCLUSION 5 Based on the foregoing, ROBERT M. ADAMS, ESQ. of the law firm EGLET ADAMS 6 || respectfully requests this Honorable Court to grant this Motion to Withdraw as Counsel of 7 || Record. 8 DATED this 19th day of July, 2019. 9 EGLET ADAMS 10

11 12 By: Q ROBERT M. ADAMS, ESQ. < 13 Nevada Bar No. 6551 14

400 South 7

" Street, 4° Floor Las Vegas, Nevada 8910! 15 E-Mail: [email protected] 6 Tel.: (702) 450-5400 i Fax: (702) 450-5451 = 17 Attorney for Plaintiff O i

19 20 RED iQ I <j S SO ORDE 21 22 DS.) AGISTRAZE JUDGE 23 paTep:.0] I4[ZOlF 24 25 26 27 28

l CERTIFICATE OF SERVICE 2 I HEREBY CERTIFY that on the 1A day of July, 2019, service of the foregoing 3 || COUNSEL’S MOTION TO WITHDRAW AS COUNSEL OF RECORD was made this dat 4 || be depositing a true copy of the same for mailing, first class mail at the addressed as follows: 6 Stephen G. Castronova, Esq. CASTRONOVA LAW OFFICES, P.C. 7 605 Forest Street 8 Reno, NV 89509 E-Mail: [email protected] 9 Attorneys for Defendant Cardiff Sport Technologies, LLC 10

11 Joel D. Odou, Esq. Christina M. Mamer, Esq. 12 WOOD, SMITH, HENNING & BERMAN, LLP 33 7674 W. Lake Mead Boulevard, Suite 150 < Las Vegas, NV 89128 14 E-Mail: [email protected] E-Mail: [email protected] 15 Attorneys for Defendant Brookstone Stores, Inc. 16 Joba] 17 Michael Ries 18 10291 Copper Cloud Dr. Reno, Nevada 19 89511 20 21 22 8 AK Du 24 An employte of Eglet Adams 25 26 27 28

EXHIBIT 1

‘EXHIBIT 1

| AFFIDAVIT OF ROBERT M. ADAMS, ESO, IN SUPPORT OF MOTION TO 2 WITHDRAW AS COUNSEL OF RECORD 4 || UNITED STATES DISTRICT COURT ) DISTRICT OF NEVADA

7 ROBERT M. ADAMS, being first duly sworn, deposes and says: 8 1. Iam an attomey licensed to practice law in the State of Nevada and in the U.S. District Court for the District of Nevada, and am an attorney at the law firm of Eglet Adams; WY 10 2. That Plaintiff is represented by DENNIS M. PRINCE, ESQ. and ROBERT M. ADAMS, 3 uN ESQ. both of whom worked for the law firm EGLET PRINCE’; 2 3. That Mr. PRINCE departed EGLET PRINCE; < 4. That Plaintiff's case was overseen by Mr. PRINCE while he worked at EGLET PRINCE 5. That Mr. PRINCE will remain as Plaintiff's counsel of record; ? 15 6. That a copy of this Motion to Withdraw was sent to Plaintiff via certified mail; 16 7. That Plaintiff's last known good address is as follows: M7 Michael Ries O is 10291 Copper Cloud Dr. fala} Reno, Nevada 19 89511 20 8. That there has been in the past, regular communication with Plaintiff at the al aforementioned address; . 9. That a copy of this Motion to Withdraw was sent to Defendants’ Counsel; AND

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© 2 Now doing business as EGLET ADAMS.

1 10. That this motion is made in good faith and not for purpose of delay. 2 AFFIANT FURTHER SAYETH NAUGHT. 6 ROBERT M. ADAMS, ESQ. . 8 SIGNED and SWORN to before me This 19th day of July, 2019 by 9 > _-PATRICIAREGALADO ee XQEF Mv Commission Expires: FA —_— ALS = 3 “4 ARY PUBLIC < 13 14 15 16

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Reference

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