Marc J. Randazza, Esq., 

6525 Warm Springs Road, Suite 100

Las Vegas, NV 89118

888-667-1113

305-437-7662 (fax)

ecf@randazza.com

Attorney for Plaintiff,

LIBERTY MEDIA HOLDINGS, LLC

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

LIBERTY MEDIA HOLDINGS, LLC

Plaintiff,

vs.

SHENG GAN f/k/a PROTECTED DOMAIN 

SERVICES CUSTOMER NCR-3356109 

d/b/a SITERIPKING.COM and JOHN DOES 

2-10 

Defendant.

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a.

Case No. 1:11-cv-02754-MSK-KMT

AMENDED NOTICE OF MOTION AND 

MOTION TO WITHDRAW AS ATTORNEY 

OF RECORD

Marc J. Randazza (“Randazza”) respectfully moves this Court for an Order permitting 

him to withdraw as counsel for Liberty Media Holdings, LLC (“Liberty”) in the above-entitled 

matter, pursuant to D.C.COLO.LCivR 83.3(D). In support thereof, the undersigned states as 

follows:

1. Liberty explicitly instructed Randazza to cease action in this case. 

Case 1:11-cv-02754-MSK-KMT Document 37 Filed 12/17/12 USDC Colorado Page 1 of 5
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2. Liberty retained the firm Greenberg Traurig LLP, which took over representation 

on other Liberty matters.

3. Shortly thereafter, Liberty replaced Greenberg Traurig with Brownstein Hyatt for 

all pending matters. 

4. Since the instruction to cease action, Liberty has declined to communicate with 

Randazza about this case. 

5. Randazza advised Liberty’s other counsel on multiple occasions about pending 

deadlines and a need to substitute in on this case, but has received no response. 

6. Without client approval to act, Randazza cannot continue to represent Liberty in 

this case and requests that the Court allow him to withdraw as counsel of record. 

7. Randazza has complied with the notification requirements of D.C.COLOR.LCivR 

83.3(D). Please see the Notice of Withdrawal attached hereto.

8. The relief requested in this Motion is sought in good faith and not for the 

purposes of delay.

9. In order to preserve Liberty’s rights, Liberty should be given at least thirty (30) 

days in which to name substitute counsel in this action.

Dated: December 17, 2012

Respectfully submitted,

s/ Marc J. Randazza___________

Marc J. Randazza, Esq.

6525 Warm Springs Road, Suite 100

Las Vegas, NV 89118

888-667-1113, 305-437-7662 (fax)

ecf@randazza.com

Case 1:11-cv-02754-MSK-KMT Document 37 Filed 12/17/12 USDC Colorado Page 2 of 5
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CERTIFICATE OF SERVICE

Pursuant to Federal Rule of Civil Procedure 5(b), I HEREBY CERTIFY that on 

December 17, 2012, I caused a copy of the foregoing document and all attachments to be served 

via the Court’s CM/ECF system, as well as depositing a copy of the foregoing in the United 

States mail to the following persons:

Liberty Media Holdings, LLC

4262 Blue Diamond Road

Suite 102-377

Las Vegas, NV 89139

__s/ Marc J. Randazza___________

Case 1:11-cv-02754-MSK-KMT Document 37 Filed 12/17/12 USDC Colorado Page 3 of 5
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Marc J. Randazza, Esq., 

6525 Warm Springs Road, Suite 100

Las Vegas, NV 89118

888-667-1113

305-437-7662 (fax)

ecf@randazza.com

Attorney for Plaintiff,

LIBERTY MEDIA HOLDINGS, LLC

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

LIBERTY MEDIA HOLDINGS, LLC

Plaintiff,

vs.

SHENG GAN f/k/a PROTECTED DOMAIN 

SERVICES CUSTOMER NCR-3356109 

d/b/a SITERIPKING.COM and JOHN DOES 

2-10 

Defendant.

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b.

Case No. 1:11-cv-02754-MSK-KMT

NOTICE OF WITHDRAWAL OF 

APPEARANCE

In accordance with D.C.COLO.LCivR 83.3(D), the undersigned states as follows:

1. The undersigned intends to withdraw as attorney of record for Liberty Media 

Holdings, LLC (“Liberty”) in the above-entitled case. 

2. Pursuant to D.C.COLO.LCivR 83.3(D), the undersigned hereby notifies Liberty 

of the following: a) Liberty is personally responsible for complying with all court orders and 

time limitations established by any applicable rules; and b) Liberty cannot appear without 

Case 1:11-cv-02754-MSK-KMT Document 37 Filed 12/17/12 USDC Colorado Page 4 of 5
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counsel admitted to practice before this court, and absent any prompt appearance of substitute 

counsel, pleadings, motions, and other papers may be stricken and default judgment or other 

sanctions may be imposed against the entity. 

Dated: December 17, 2012

Respectfully submitted,

s/ Marc J. Randazza___________

Marc J. Randazza, Esq.

6525 Warm Springs Road, Suite 100

Las Vegas, NV 89118

888-667-1113

305-437-7662 (fax)

ecf@randazza.com

Attorney for Plaintiff

Liberty Media Holdings, LLC

CERTIFICATE OF SERVICE

Pursuant to Federal Rule of Civil Procedure 5(b), I HEREBY CERTIFY that on 

December 17, 2012, I caused a copy of the NOTICE OF WITHDRAWAL OF APPERANCE to 

be served via United States mail to the following persons:

Liberty Media Holdings, LLC

4262 Blue Diamond Road

Suite 102-377

Las Vegas, NV 89139

__s/ Marc J. Randazza___________

Case 1:11-cv-02754-MSK-KMT Document 37 Filed 12/17/12 USDC Colorado Page 5 of 5