Puda Doc 71
description
Transcript of Puda Doc 71
-
quinn emanuel trial lawyers | new york 51 Madison Avenue, 22nd Floor, New York, New York 10010-1601 | TEL (212) 849-7000 | FAX (212) 849-7100
WRITER'S DIRECT DIAL NO.
(212) 849-7134
WRITER'S INTERNET ADDRESS
[email protected] March 25, 2015
Hon. Denise L. Cote
United States District Judge
Southern District of New York
Daniel Patrick Moynihan Courthouse
500 Pearl St., Courtroom 15B
New York, NY 10007-1312
Re: SEC. v. Ming Zhao (Case No. 1:12-CV-01316 (DLC))
Dear Judge Cote:
I write in response to (1) the Courts March 13, 2015 order to provide a status update with respect to the
issues discussed during the February 24, 2015 telephonic hearing in connection with the motion filed by
Quinn Emanuel Urquhart & Sullivan, LLP (Quinn Emanuel) to withdraw as counsel to Ming Zhao in
the above-referenced action; and (2) the letter submitted to the Court by the Securities and Exchange
Commission (the Commission) today.
In its letter, the Commission among other things reiterated its prior request that Quinn Emanuel be
required to accept on behalf of Mr. Zhao any default motion papers and default judgment that the Court
might enter against Mr. Zhao. Quinn Emanuel continues to oppose this request. The relief requested by
the Commission is simply not necessary to protect the interests of the Commission. Mr. Zhao
understands the consequences of his decision not to litigate these cases and, as observed by the Court
during the February 24, 2015 hearing and in the letter submitted by the Commission today, Mr. Zhao is
clearly on notice that a default judgment will be entered by the Court. Therefore, there is no need for
Quinn Emanuel to remain in the action for the Commission to obtain a default judgment.
Moreover, on February 27, 2015, pursuant to Your Honors on the record directive, Quinn Emanuel
provided to the Commission and Class Plaintiffs the most current email addresses and physical mailing
address Quinn Emanuel has on file for Mr. Zhao. Therefore, the Commission can transmit any
documents it wishes to Mr. Zhao as easily as Quinn Emanuel can.
Finally, Quinn Emanuel was advised by Mr. Zhao on March 6, 2015 that he no longer considers Quinn
Emanuel as his counsel and does not consent to Quinn Emanuel accepting any legal papers on his
behalf.
Accordingly, Quinn Emanuel respectfully requests that the Court grant its motion to withdraw as
counsel without imposing the condition being sought by the Commission.
Case 1:12-cv-01316-DLC-HBP Document 71 Filed 03/25/15 Page 1 of 2
-
2
Respectfully submitted,
/s/ Minyao Wang
Minyao Wang
Case 1:12-cv-01316-DLC-HBP Document 71 Filed 03/25/15 Page 2 of 2