Andersen et al v. Stability AI Ltd. et al

Filing 15

MOTION for leave to appear in Pro Hac Vice for Michael Keats ( Filing fee $ 317, receipt number ACANDC-17944633.) filed by Stability AI, Inc.. (Keats, Michael) (Filed on 1/31/2023)

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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Sarah Andersen, an individual;
Kelly McKernan, an individual;
Karla Ortiz, an individual,

Plaintiff(s),

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Case No. 23-cv-00201-JCS

v.
Stability AI, LTD., a UK corporation; Stability AI, Inc.,
a Delaware corporation; MIDJOURNEY, INC., a Delaware,
corporation; DEVIANTART, INC., a Delaware corporation,

APPLICATION FOR ADMISSION OF
ATTORNEY PRO HAC VICE
(CIVIL LOCAL RULE 11-3)

Defendant(s).

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United States District Court
Northern District of California

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I, Michael C. Keats

, an active member in good standing of the bar of

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Southern District of New York , hereby respectfully apply for admission to practice pro hac

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vice in the Northern District of California representing:

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above-entitled action. My local co-counsel in this case is

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attorney who is a member of the bar of this Court in good standing and who maintains an office

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155830
within the State of California. Local co-counsel’s bar number is: _________________.

Defendant Stability AI, Inc.*

Mark A. Lemley

in the
, an

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One New York Plaza, New York, NY 10004

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MY ADDRESS OF RECORD
[phone]

MY TELEPHONE # OF RECORD
[e-mail]

MY EMAIL ADDRESS OF RECORD

745 Fifth Avenue, Ste. 500, New York, NY 10151

LOCAL CO-COUNSEL’S ADDRESS OF RECORD
[phone]

LOCAL CO-COUNSEL’S TELEPHONE # OF RECORD
[e-mail]

LOCAL CO-COUNSEL’S EMAIL ADDRESS OF RECORD

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I am an active member in good standing of a United States Court or of the highest court of
another State or the District of Columbia, as indicated above; my bar number is: MK2342
A true and correct copy of a certificate of good standing or equivalent official document
from said bar is attached to this application.
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I have been granted pro hac vice admission by the Court _______
times in the 12 months

preceding this application.
__________________
* Counsel’s appearance does not constitute consent to this Court’s exercise of personal jurisdiction over Defendant, and is subject to and without
waiver of Defendant’s right to dispute such exercise of jurisdiction and/or to otherwise seek to dismiss or transfer this action.

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I agree to familiarize myself with, and abide by, the Local Rules of this Court, especially

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the Standards of Professional Conduct for attorneys and the Alternative Dispute Resolution Local

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Rules. I declare under penalty of perjury that the foregoing is true and correct.

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Dated:

January 31, 2023

s/ Michael C. Keats

APPLICANT

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ORDER GRANTING APPLICATION

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FOR ADMISSION OF ATTORNEY PRO HAC VICE

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IT IS HEREBY ORDERED THAT the application of Michael C. Keats

United States District Court
Northern District of California

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is

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granted, subject to the terms and conditions of Civil L.R. 11-3. All papers filed by the attorney

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must indicate appearance pro hac vice. Service of papers upon, and communication with, local co-

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counsel designated in the application will constitute notice to the party.

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Dated:

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UNITED STATES DISTRICT/MAGISTRATE JUDGE

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Updated 11/2021

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Certificate of Good Standing

I, Ruby J. Krajick, Clerk of Court, Certify that

MICHAEL

C.

KEATS

, Bar #

MK2342

was duly admitted to practice in the Court on

April 20, 1999
and is in good standing as a member of the Bar of this Court

Dated at

500 Pearl St.
New York, New York

On

Ruby J. Krajick

By

Clerk of Court

January 30, 2023

s/ S. Gonzalez
Deputy Clerk