SANDLER v. CALCAGNI et al

Filing 79

NOTICE of Appearance Pro Hac Vice of Kari L. Vander Stoep filed by STEVEN P. WRIGHT on behalf of BOOKSURGE LLC (Attachments: # 1 Affidavit of Kari L. Vander Stoep Pro Hac Vice)(WRIGHT, STEVEN)

SANDLER v. CALCAGNI et al Doc. 79 UNITED STATES DISTRICT COURT DISTRICT OF MAINE AT BANGOR SHANA SANDLER, Plaintiff, v. MIA CALCAGNI, RALPH CALCAGNI, MAUREEN CALCAGNI, PETER MARS, and BOOKSURGE, LLC, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 07-CV-00029-DBH MOTION TO ADMIT KARI L. VANDER STOEP AS A VISITING ATTORNEY PURSUANT TO LOCAL RULE 83.1 I, Steven P. Wright, a member in good standing of the Bar of this Court, and as an attorney with the law firm of Kirkpatrick & Lockhart, Preston Gates Ellis LLP, which is counsel of record for the Defendant Booksurge, LLC ( Booksurge ), hereby respectfully moves this Court that Kari L. Vander Stoep be admitted to appear and practice as visiting lawyer pursuant to Local Rule 83.1(c). In support of this motion, I state as follows: 1. Kari L. Vander Stoep is a member in good standing of the bars of the State of Washington and the United States Court of Appeals for the Ninth Circuit. 2. Ms. Vander Stoep is an associate in the law firm of Kirkpatrick & Lockhart, Preston Gates Ellis LLP, 925 Fourth Avenue, Suite 2900, Seattle, Washington, 98104-1158. 3. There are no disciplinary proceedings pending (nor have any ever been brought) against Ms. Vander Stoep. Dockets.Justia.com 4. Ms. Vander Stoep is familiar with the Local Rules of the Federal District Court for the District of Maine. 5. As reflected in the Affidavit of Ms. Vander Stoep, which is submitted herewith, Ms. Vander Stoep meets all of the requirements to be admitted as a visiting attorney pursuant to Local Rule 83.1(c) and has knowledge of the underlying facts that will materially aid Booksurge in the defense of this action. 6. Ms. Vander Stoep is currently counsel for Booksurge and, as a visiting attorney, will be associated with Steven P. Wright, who is a member of good standing in this court. 7. WHEREFORE, Booksurge respectfully requests that this Court admit Kari L. Vander Stoep as a visiting attorney pursuant to Local Rule 83.1(c). December 19, 2007 BOOKSURGE, LLC By its attorney, /s/ Steven P. Wright Steven P. Wright (ME BBO# 009473) steven.wright@klgates.com Kirkpatrick & Lockhart Preston Gates Ellis LLP State Street Financial Center One Lincoln Street Boston, MA 02111-2950 Stephen A. Smith (Pro Hac Vice) steve.smith@klgates.com Matthew J. Segal (Pro Hac Vice) matthew.segal@klgates.com Kirkpatrick & Lockhart Preston Gates Ellis LLP 925 Fourth Avenue, Suite 2900 Seattle, Washington 98104-1158 -2- CERTIFICATE OF SERVICE I hereby certify that on December 19, 2007, I served a copy of the foregoing: 1. MOTION TO ADMIT KARI VANDER STOEP AS A VISITING ATTORNEY PURSUANT TO LOCAL RULE 83.1 2. AFFIDAVIT OF KARI VANDER STOEP IN SUPPORT OF MOTION TO ADMIT KARI VANDER STOEP AS A VISITING ATTORNEY PURSUANT TO LOCAL RULE 83.1 by US Mail and electronic mail to the following counsel of record: Bernard J. Kubetz, Esq. Eaton Peabody 80 Exchange Street P.O. Box 1210 Bangor, ME 04401-1210 Bruce Mallonee, Esq. Rudman & Winchell, LLC 84 Harlow Street P.O. Box 1401 Bangor, ME 04402-1401 J. William Druary, Jr., Esq. Marden, Dubord, Bernier & Stevens 44 Elm Street P.O. Box 708 Waterville, ME 04903 /s/ Steven P. Wright Steven P. Wright -3-