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Thursday, May 3rd, 2012 James Alan Bush 3311 Princeton Way #5 Santa Clara, California 95051 (408)

791-4866 United States District Court, Northern District of California, San Francisco Division ATTN: Judge Richard Seeborg 450 Golden Gate Avenue, 16th Floor San Francisco, California 94102 (415) 522-2000 In re Petition for Rehearing on Motion to Withdrawal as Counsel by Kaye Scholer LLC in C 09-01024 RS [Bush v. Flores] To the Honorable Richard Seeborg, Judge of United States District Court for the Northern District of California: I am hereby requesting reconsideration of the order granting the motion to withdrawal as counsel brought by Kaye Scholer LLC, former counsel in the above-referenced matter, and am further requesting that opposition to this motion be heard. These requests are made on the ground that the motion was granted without an adequate opportunity to present an opposition, even though I explicitly stated my intention to oppose this motion to Peter Root, a principal at Kaye Scholer, at the time he first advised me of his intent to move for withdrawal as counsel. The fact that Kaye Scholer LLC was aware of my request for a hearing is evidenced by the two attempts of Marissa Armanino Williams, attorney for the aforementioned law firm, to obtain a stipulated agreement to a shortening of time for a hearing on the motion. Due to prior court committments in the San Jose Division, which were placed on a publicly available calendar, and made readily available to any attorney, I rejected the two proposed dates, and reiterated my request for a hearing, and that suc hearing be scheduled no sooner than the requisite 35-day period after noticing, as prescribed by Civil Local Rule 7-2(a): 7-2. Notice and Supporting Papers (a) Time. Except as otherwise ordered or permitted by the assigned Judge or these Local Rules, and except for motions made during the course of a trial or hearing, all motions must be filed, served and noticed in writing on the motion calendar of the assigned Judge for hearing not less than 35 days after service of the motion. Instead, it appears that a shortening of time was granted in the absence of a stipulation, and without any notice of such having been received; and, as a consequence, the motion was subsequently granted without any opposition having been heard. As the Court is undoubtedly aware, any order granted on a motion considered prior to the expiration of the 35-day time period in which the opposing party may file an opposition must be revoked. Therefore, I am requesting that the Court revoke its order granting the motion to withdrawal Kaye Scholer as counsel, and that it allow adequate time to file an opposition to said motion, and that a hearing be scheduled for such opposition to be heard before the Court.


James Alan Bush (Plaintiff in pro per)

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