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Case 3:23-cv-04984-JSC
Holland & Knight LLP
524 Grand Regency Boulevard Brandon, FL 33510 Tel: 813.901.4200 Fax: 813.901.4201
Document 61
Christina T. Tellado (SBN 298597) ttellado@polsinelli.com Mary Vu (SBN 323088) mvu@polsinelli.com POLSINELLI LLP 2049 Century Park East, Suite 2900 Los Angeles, California 90067 Telephone: (310) 556-1801 Facsimile: (310) 556-1802 Attorneys for Defendant TESLA, INC.
(Additional counsel listed on next page) UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION,
Plaintiff,
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Thomas E. Hill (SBN 100861) thomas.hill@hklaw.com HOLLAND & KNIGHT LLP 400 South Hope Street, 8th Floor Los Angeles, California 90071 Telephone: (213) 896-2400 Facsimile: (213) 896-2450
Filed 08/12/24
v.
TESLA, INC.,
Defendant.
Case No. 3:23-cv-4984-JSC NOTICE OF MOTION AND UNOPPOSED MOTION TO WITHDRAW AS COUNSEL OF RECORD FOR DEFENDANT TESLA, INC.; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT [Civ. L.R. 11-5]
Hearing Date: September 26, 2024 Time: 10:00 AM Judge: Hon. Jacqueline S. Corley Courtroom: 8
Complaint Filed: September 28, 2023
[Declaration of Thomas E. Hill; and Proposed Order filed concurrently herewith]
NOTICE OF MOT. AND UNOPPOSED MOT. TO WITHDRAW AS COUNSEL OF RECORD FOR DEF. TESLA, INC.; MEMO. PTS. AND AUTH. IN SUPP.
Case No.: 3:23-CV-4984-JSC
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Case 3:23-cv-04984-JSC
Holland & Knight LLP
400 South Hope Street, 8th Floor Los Angeles, CA 90071 Tel: 213.896.2400 Fax: 213.896.2450
Document 61
Filed 08/12/24
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Samuel J. Stone (SBN 317013) sam.stone@hklaw.com HOLLAND & KNIGHT LLP 400 South Hope Street, 8th Floor Los Angeles, California 90071 Telephone: (213) 896-2400 Facsimile: (213) 896-2450 Paul W. Matthias-Bennetch (SBN 318545) HOLLAND & KNIGHT LLP 601 SW Second Avenue, Suite 1800 Portland, Oregon 97204 Telephone: (503) 243-2300 Facsimile: (503) 241-8014 Sara A. Begley (admitted pro hac vice) sbegley@polsinelli.com POLSINELLI PC Three Logan Square 1717 Arch St, Suite 2800 Philadelphia, PA 19103 Telephone: (215) 267-3001 Facsimile: (215) 267-3002 Raymond A. Cardozo (SBN 173263) rcardozo@reedsmith.com REED SMITH LLP 101 Second Street, Suite 1800 San Francisco, California 94105 Telephone: (415) 543-8700 Facsimile: (415) 391-8269 Tyree P. Jones Jr. (SBN 127631) tpjones@reedsmith.com REED SMITH LLP 1301 K Street, N.W., Suite 1000 Washington, DC 20005 Telephone: (202) 414-9200 Facsimile: (202) 414-9299 Attorneys for Defendant TESLA, INC.
NOTICE OF MOT. AND UNOPPOSED MOT. TO WITHDRAW AS COUNSEL OF RECORD FOR DEF. TESLA, INC.; MEMO. PTS. AND AUTH. IN SUPP.
Case No.: 3:23-CV-4984-JSC
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Case 3:23-cv-04984-JSC
Holland & Knight LLP
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TO PLAINTIFF U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION AND ITS
400 South Hope Street, 8th Floor Los Angeles, CA 90071 Tel: 213.896.2400 Fax: 213.896.2450
Filed 08/12/24
NOTICE OF MOTION AND UNOPPOSED MOTION
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ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that on September 26, 2024, at 10:00 a.m., or as soon as the matter
may be heard before the Honorable Jacqueline Scott Corley in Courtroom 8 of the United States
District Court for the Northern District of California, located at 450 Golden Gate Avenue, San
Francisco, California, Defendant Tesla, Inc. (“Tesla”) will and hereby does move the Court pursuant
to Local Rule 11-5 for an order permitting its counsel of record Thomas E. Hill, Samuel J. Stone,
Paul W. Matthias-Bennetch and Holland & Knight LLP to withdraw as counsel for Tesla in this
action.
The Motion is unopposed and based on this Notice of Motion and Motion, the Memorandum
of Points and Authorities in Support of the Motion, and the Declaration of Thomas E. Hill in support
thereof. Reasonable notice has been provided Tesla and counsel of record for Plaintiff U.S. Equal
Employment Opportunity Commission of counsel’s intent to withdraw from this case, and Tesla
consents to the withdrawal and Plaintiff does not oppose the withdrawal. Counsel from Polsinelli
LLP, Polsinelli PC, and Reed Smith LLP will continue to represent Tesla in this matter.
NOTICE OF MOT. AND UNOPPOSED MOT. TO WITHDRAW AS COUNSEL
OF RECORD FOR DEF. TESLA, INC.; MEMO. PTS. AND AUTH. IN SUPP.
Case No.: 3:23-CV-4984-JSC
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Case 3:23-cv-04984-JSC
Holland & Knight LLP
Filed 08/12/24
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MEMORANDUM OF POINTS AND AUTHORITIES
400 South Hope Street, 8th Floor Los Angeles, CA 90071 Tel: 213.896.2400 Fax: 213.896.2450
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I.
INTRODUCTION
Pursuant to Rule 11-5 of the Local Rules for the United States District Court for the
Northern District of California, Defendant Tesla, Inc. (“Tesla”) and its counsel of record Thomas
E. Hill, Samuel J. Stone, Paul W. Matthias-Bennetch and Holland & Knight LLP hereby request a
Court order permitting Messrs. Hill, Stone and Matthias-Bennetch and Holland & Knight LLP
(together, “Withdrawing Counsel”) to withdraw as counsel for Tesla in this action. Reasonable
notice has been provided Tesla and counsel of record for Plaintiff U.S. Equal Employment
Opportunity Commission of Withdrawing Counsel’s intent to withdraw from this case, and Tesla
consents to the withdrawal and Plaintiff does not oppose the withdrawal. See Declaration of
Thomas E. Hill, par. 5–6 (hereinafter “Hill Decl.).
II.
ARGUMENT
This Motion to Withdraw is made on the following grounds:
1) In addition to Withdrawing Counsel, Tesla’s counsel of record in this case have included Sara
A. Begley, Christina T. Tellado, and Mary T. Vu (all formerly of Holland & Knight LLP, and, as
of August 5, 2024, all now with Polsinelli LLP; hereinafter together referred to as “Polsinelli
Counsel”), and Raymond A. Cardozo and Tyree P. Jones, Jr. of Reed Smith LLP; hereinafter
together referred to as “Reed Smith Counsel”). On August 9, 2024, Polsinelli Counsel made
appearances as defense counsel for Tesla in this case. (ECF No. 60) Reed Smith Counsel have
continued as counsel of record for Tesla without interruption since the inception of this case.
2) Tesla has been notified and consented to the withdrawal of Withdrawing Counsel from
this action, and counsel of record for Plaintiff EEOC have received reasonable notice of
Withdrawing Counsel’s intent to withdraw and expressed no opposition, all in compliance with
Local Rule 11-5. See Hill Decl., par. 5–6.
3) No prejudice or inconvenience to any party will result from the Court’s granting this
Motion because substantial continuity exists in Tesla’s counsel of record given the recent
appearances of Polsinelli Counsel and the ongoing representation of Reed Smith Counsel. See id.
NOTICE OF MOT. AND UNOPPOSED MOT. TO WITHDRAW AS COUNSEL
OF RECORD FOR DEF. TESLA, INC.; MEMO. PTS. AND AUTH. IN SUPP.
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III.
CONCLUSION
For all the foregoing reasons, Withdrawing Counsel therefore request that the Court issue
an order granting this Motion to Withdraw and remove Withdrawing Counsel from the Court’s
service list in this action.
Respectfully submitted,
Dated: August 12, 2024
HOLLAND & KNIGHT LLP
Thomas E. Hill Samuel J. Stone Paul W. Matthias-Bennetch
Holland & Knight LLP
400 South Hope Street, 8th Floor Los Angeles, CA 90071 Tel: 213.896.2400 Fax: 213.896.2450
By: /s/ Thomas E. Hill Thomas E. Hill Attorneys for Defendant TESLA, INC.
NOTICE OF MOT. AND UNOPPOSED MOT. TO WITHDRAW AS COUNSEL OF RECORD FOR DEF. TESLA, INC.; MEMO. PTS. AND AUTH. IN SUPP.
Case No.: 3:23-CV-4984-JSC
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