Tyntec Inc. et al v. Syniverse Technologies, LLC

Middle District of Florida, flmd-8:2017-cv-00591

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PageID 27828 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION TYNTEC, INC. and TYNTEC GROUP, LTD. f/k/a Phoenix Spring, Ltd., Case No.: 8:17-cv-591-SDM-SPF Plaintiffs, v. SYNIVERSE TECHNOLOGIES, LLC., Defendant. UNOPPOSED MOTION TO WITHDRAW AS COUNSEL OF RECORD OF JASON C. BERTOLDI Pursuant to Local Rule 2.03(b), Local Rules for the Middle District of Florida, Plaintiffs tyntec Inc. and tyntec Group, LTD. (together, "tyntec"), respectfully request entry of an order allowing the withdrawal of Jason C. Bertoldi as counsel for tyntec, and in support of this motion, state as follows: 1. On October 2nd, 2018, this Court granted leave to Jason C. Bertoldi of the law firm of Susman Godfrey, LLP to appear pro hac vice on behalf of tyntec. 2. Undersigned counsel is no longer employed by the law firm of Susman Godfrey, LLP and has no further action in this matter. The law firm of Susman Godfrey, LLP continues to represent tyntec in the above-mentioned matter. 3. The relief sought herein will not prejudice any of the parties to this action. 4. Pursuant to Local Rule 2.03(b), this Motion is made after providing the required ten (10) days' notice to tyntec and opposing counsel. PageID 27829 Local Rule 3.01(g) Certificate Pursuant to Local Rule 3.01(g), counsel for tyntec certify that they have conferred with opposing counsel and confirmed that there is no opposition to the relief requested herein. WHEREFORE, based on the foregoing, tyntec respectfully request the entry of an Order allowing Jason C. Bertoldi to withdraw his pro hac vice appearance as counsel for tyntec in this action. Dated: October 14, 2019 SUSMAN GODFREY L.L.P. By: /s/ Shawn J. Rabin William Christopher Carmody Shawn J. Rabin Jason C. Bertoldi 1301 Avenue of the Americas, 32nd Floor New York, NY 10019 (212) 336-8330 bcarmody@susmangodfrey.com srabin@susmangodfrey.com jbertoldi@susmangodfrey.com Vineet Bhatia 1000 Louisiana, Suite 5100 Houston, TX 77002 (713) 651-9366 vbhatia@susmangodfrey.com Amanda Bonn Meng Xi 1900 Avenue of the Stars, Suite 1400 Los Angeles, CA 90067 (310) 789-3100 abonn@susmangodfrey.com mxi@susmangodfrey.com GUNSTER, YOAKLEY & STEWART, P.A. Daniel P. Dietrich Florida Bar No. 934461 401 East Jackson Street, Suite 2500 Tampa, FL 33602 (813) 739-6970 ddietrich@gunster.com 2 PageID 27830 MAYER BROWN LLP Stephen M. Medlock 1999 K Street, N.W. Washington, D.C. 20006 (202) 263-3000 smedlock@mayerbrown.com Attorneys for Plaintiffs 3 PageID 27831 CERTIFICATE OF SERVICE I hereby certify this 14th day of October 2019, I caused a true and correct copy of the foregoing to be electronically filed with the Clerk of the court using the CM/ECF system which will send notification to the attorneys of record and is available for viewing and downloading. /s/ Shawn J. Rabin Shawn J. Rabin 4