Posted in: commodities-and-mining
RE: Frontera Archive7 Nov 2019 01:34
Posted by Earsbern on the 5th November :-
TO ALL PARTIES AND THEIR COUNSEL OF RECORD: Please take notice that on December 5, 2019, at 1:30 p.m., or as soon thereafter as counsel may be heard, in the courtroom of the Honorable Richard Seeborg, United States District Judge for the Northern District of California, Courtroom 3, 17th Floor, Phillip Burton Federal Building & United States Courthouse, 450 Golden Gate Avenue, San Francisco, CA 94102 movants, WILLIAM B. DECLERCQ, ERIC S. FISHER, JOHN MILLS and TAYLOR ENGLISH DUMA LLP, current counsel for Plaintiffs Frontera Resources Corporation (“FRC”) and Frontera International Corporation (“FIC”) (collectively, “Plaintiffs”) will and hereby do move to withdraw and seek an order relieving them as counsel for Plaintiffs, pursuant to Local Rules 5-1(c)(2)(C) and 11-5. The full reasons for the motion cannot be disclosed without violating attorney-client privilege, but have been discussed over some months. Undersigned counsel is prepared to inform the Court in camera of the privileged reasons that it is necessary for counsel to withdraw, should that become necessary. Plaintiffs are not opposed to the motion by current counsel and will not be prejudiced by the Motion. Counsel has served this Motion to Plaintiffs immediately after filing it. This Motion follows a series of conferences of counsel, pursuant to Local Rule both in writing and telephonically, which occurred October 11, 24, 29, and 30 regarding Plaintiffs’ request to voluntarily dismiss this case without prejudice, pursuant to Rule 41 of the Federal Rules of Civil Procedure, and then this motion. Defendants Stephen Hope, Outrider Management, LLC, and Outrider Onshore, LP (collectively, “Defendants”) do not oppose this motion, but Defendants request the Court set a status conference to discuss the implications of a withdrawal by current counsel for Plaintiffs.
To support the Motion, Plaintiffs submit the following Memorandum of Points and Authorities, the Declaration of William B. DeClercq and a Proposed Order, and they will rely upon the other pleadings and briefs filed in this action, the proceedings at oral argument, and any other matter that the Court deems appropriate. DATED: November 4, 2019 Respectfully submitted, TAYLOR ENGLISH DUMA LLP /s/ William DeClercq William DeClercq SBN 240538