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`ESTTA1307900
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`Filing date:
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`09/05/2023
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
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`Proceeding no.
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`91286736
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`Party
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`Correspondence
`address
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`Submission
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`Filer's name
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`Filer's email
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`Signature
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`Date
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`Defendant
`Stephen Norris
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`JENNIFER APPELMAN RACKLEY
`LZ LEGAL SERVICES, LLC
`101 N. BRAND BLVD, 11TH FLOOR
`GLENDALE, CA 91203
`UNITED STATES
`Primary email: tm@lzlegalservices.com
`512-535-7819
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`Request to Withdraw as Attorney
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`Jennifer Appelman Rackley
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`tm@lzlegalservices.com
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`/Jennifer Appelman Rackley/
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`09/05/2023
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`Attachments
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`230905 MTW - FLY LYT.pdf(116078 bytes )
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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE
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`TRADEMARK TRIAL AND APPEAL BOARD
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`Opposition No. 91286736
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`
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`IFLY HOLDINGS, LLC
` Petitioner,
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`v.
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`STEPHEN NORRIS
` Applicant
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`MOTION TO WITHDRAW AS COUNSEL
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`LZ Legal Services, LLC, counsel for Stephen Norris (“Applicant”) and Application No.
`97611029 (for the mark “IFLY LYT”), hereby requests permission to withdraw as counsel
`pursuant to 37 C.F.R. § 2.19(b), 37 C.F.R. § 11.116(b), and the Trademark Trial and Appeal
`Board Manual of Procedure (“TBMP”) § 513.01.
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`As grounds for withdrawal, LZ Legal Services submits that (i) Applicant agreed and
`consented to LZ Legal Services’s withdrawal; and (ii) said withdrawal can be accomplished
`without material adverse effect on Applicant’s interests.
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`Additionally, in accordance with C.F.R. §11.116(d), LZ Legal Services has taken
`reasonable steps to protect Applicant’s interests, which includes: (i) providing reasonable notice
`of withdrawal to Applicant; (ii) providing ample time for employment of other counsel; (iii)
`providing papers and property that relate to the proceeding and to which Applicant is entitled.
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`LZ Legal Services further confirms that (i) there are no unearned fees that would need to
`be refunded to Applicant and (ii) this withdrawal request has been served upon Applicant and
`upon every other party to the proceeding.
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`The email address for Applicant in this proceeding should be updated to
`norris.transfer@gmail.com, and Applicant’s mailing address is: 25565 Corte Zorita, Murrieta,
`CA 92563
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`Wherefore, the undersigned law firm requests to be permitted to withdraw from
`representation in the above-captioned proceeding and the underlying Appl. No. 97611029.
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`Dated: 9/5/2023
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`/Jennifer Appelman Rackley/
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`Jennifer Appelman Rackley
`Senior Trademark Attorney
`LZ Legal Services, LLC
`101 N. Brand Blvd, 11th Floor
`Glendale, CA 91203
`ph: (512) 535-7819
`email: tm@lzlegalservices.com
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`CERTIFICATE OF SERVICE
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`
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`I hereby certify that a true and complete copy of the foregoing MOTION TO
`WITHDRAW AS COUNSEL has been served on Applicant by forwarding said copy on
`September 5, 2023, via email to: Stephen Norris at the following e-mail address:
`norris.transfer@gmail.com.
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` I
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` further certify that a true and complete copy of the foregoing MOTION TO
`WITHDRAW AS COUNSEL has been served on Opposer by forwarding said copy on
`September 5, 2023, via email to: Christopher Sylvain at the following e-mail address:
`mail@polsoniplaw.com and csylvain@polsoniplaw.com.
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`Dated: 9/5/2023
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`/Jennifer Appelman Rackley/
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`Jennifer Appelman Rackley
`Senior Trademark Attorney
`LZ Legal Services, LLC
`101 N. Brand Blvd, 11th Floor
`Glendale, CA 91203
`ph: (512) 535 7819
`email: tm@lzlegalservices.com
`
`
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