Free Motion for Leave to Appear - District Court of Connecticut - Connecticut

Case 3:02-cv-02200-CFD

Document 52

Filed 06/21/2004

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT CARLOS A. ARREDONDO, in his capacity as Trustee of The 2000 Trust for the Grandchildren of Carlos A. Arredondo and Mari V. Arredondo, General Partner of Arredondo Properties Limited Partnership, : : : : : : Plaintiff, : : v. : : CAESAR A. ARREDONDO, individually and in : his capacity as Trustee of The 2000 Trust for the : Grandchildren of Caesar A. Arredondo and Carolyn : Abad Arredondo; THE 2000 TRUST FOR THE : GRANDCHILDREN OF CAESAR A. : ARREDONDO AND CAROLYN ABAD : ARREDONDO, in its capacity as General Partner : of Arredondo Properties Limited Partnership; and : ARREDONDO & CO., LLC, : : Defendants. :

CIVIL ACTION NO.: 3:02 CV 02200 (CFD)

June 21, 2004

MOTION FOR ADMISSION PRO HAC VICE
Pursuant to D. Conn L. Civ. R. 83.1(d), the undersigned counsel hereby moves for the admission pro hac vice of David M. Kelly, Esq. to represent the defendants, Caesar A. Arredondo, individually and in his capacity as Trustee of The 2000 Trust for the Grandchildren of Caesar A. Arredondo and Carolyn Abad Arredondo; The 2000 Trust for the Grandchildren of Caesar A. Arredondo and Carolyn Abad Arredondo, in its capacity as General Partner of Arredondo Properties Limited Partnership; and Arredondo & Co., LLC. In support of this motion, the undersigned represents as follows:

HART1-1187697-1

Case 3:02-cv-02200-CFD

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Filed 06/21/2004

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1.

Mr. Kelly is an attorney with Finnegan Henderson, 1300 I Street, NW,

Washington, DC 20005-3315, telephone number (202) 408-4000, fax number (202) 4084400. Mr. Kelly's email address is [email protected]. 2. As demonstrated in the affidavit of David M. Kelly dated June 18, 2004

(attached hereto as Exhibit A), Mr. Kelly is a member in good standing of the bar of the District of Columbia, the bar of the State of Pennsylvania, the bar of the state of Louisiana and is admitted to practice before several federal courts, including the Supreme Court of the United States. 3. Mr. Kelly has never been denied admission or disciplined by this Court or

any other court. 4. The granting of this motion will not require modification of a scheduling

order or other deadlines. 5. This motion is accompanied by payment to the Clerk of this Court the fee

of twenty-five dollars ($25.00).

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WHEREFORE, the undersigned respectfully requests that this Court enter an Order granting permission for David M. Kelly, Esq. to appear pro hac vice in the abovereferenced action.

DEFENDANTS, CAESAR A. ARREDONDO, et al. By /s/ Edward J. Heath Craig A. Raabe ct 04116 Email: [email protected] Edward J. Heath (ct20992) Email: [email protected] Robin P. Keller (ct23564) Email : [email protected] Robinson & Cole LLP 280 Trumbull Street Hartford, CT 06103 Tel.: (860) 275-8200 Fax: (860) 275-8299

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CERTIFICATION This is to certify that a copy of the foregoing was mailed via facsimile and first class mail on the 21st day of June, 2004, to: ROBERT P. DOLIAN, ESQ. CUMMINGS & LOCKWOOD LLC 107 Elm Street Stamford, Connecticut 06902 MARTIN J. ELGISON, ESQ. DAVID J. STEWART, ESQ. DANA MARTY HAAS, ESQ. ALSTON & BIRD LLP One Atlantic Center 1201 West Peachtree Street Atlanta, Georgia 30309-3424 /s/ Edward J. Heath Edward J. Heath

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