Getty Images (US), Inc. v. Stability AI, Inc.

Filing 34

MOTION for Pro Hac Vice Appearance of Attorney Joseph C. Gratz, Allyson R. Bennett, Timothy Chen Saulsbury, Aditya V. Kamdar and Laura Gilbert Remus - filed by Stability AI, Inc., Stability AI, Ltd.. (Flynn, Michael)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
GETTY IMAGES (US), INC.,
Plaintiff,
v.
STABILITY AI, LTD.
and STABILITY AI, INC.,
Defendants.

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C.A. No. 23-135 (JLH)

MOTION AND ORDER FOR ADMISSION PRO HAC VICE
Pursuant to Local Rule 83.5 and the attached certifications, counsel moves the admission
pro hac vice of Joseph C. Gratz, Allyson R. Bennett, Timothy Chen Saulsbury, Aditya V. Kamdar
and Laura Gilbert Remus of MORRISON & FOERSTER LLP to represent Defendants Stability
AI, Ltd. and Stability AI, Inc. in this matter.
MORRIS, NICHOLS, ARSHT & TUNNELL LLP

/s/ Michael J. Flynn
Jack B. Blumenfeld (#1014)
Michael J. Flynn (#5333)
1201 North Market Street
P.O. Box 1347
Wilmington, DE 19899
[phone]
[e-mail]
[e-mail]
Attorneys for Defendants
January 26, 2024

ORDER GRANTING MOTION
IT IS HEREBY ORDERED that counsel’s motion for admission pro hac vice is granted.
Dated:

United States District Judge

CERTIFICATION BY COUNSEL TO BE ADMITTED PRO HAC VICE
Pursuant to Local Rule 83.5, I certify that I am eligible for admission to this Court, am
admitted, practicing and in good standing as a member of the Bar of the State of California, and
pursuant to Local Rule 83.6 submit to the disciplinary jurisdiction of this Court for any alleged
misconduct which occurs in the preparation or course of this action. I also certify that I am
generally familiar with this Court’s Local Rules. In accordance with Standing Order for Attorney
Registration and Pro Hac Vice Fees effective 1/1/2024, I further certify that the filing fee of $50.00
will be submitted to the Clerk’s Office upon the filing of this motion.

Dated: January 26, 2024

/s/ Joseph C. Gratz
Joseph C. Gratz
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, CA 94105-2482
[phone]
[e-mail]

CERTIFICATION BY COUNSEL TO BE ADMITTED PRO HAC VICE
Pursuant to Local Rule 83.5, I certify that I am eligible for admission to this Court, am
admitted, practicing and in good standing as a member of the Bar of the State of California, and
pursuant to Local Rule 83.6 submit to the disciplinary jurisdiction of this Court for any alleged
misconduct which occurs in the preparation or course of this action. I also certify that I am
generally familiar with this Court’s Local Rules. In accordance with Standing Order for Attorney
Registration and Pro Hac Vice Fees effective 1/1/2024, I further certify that the filing fee of $50.00
will be submitted to the Clerk’s Office upon the filing of this motion.

Dated: January 26, 2024

/s/ Allyson R. Bennett
Allyson R. Bennett
MORRISON & FOERSTER LLP
707 Wilshire Boulevard
Los Angeles, CA, 90017-3543
[phone]
[e-mail]

CERTIFICATION BY COUNSEL TO BE ADMITTED PRO HAC VICE
Pursuant to Local Rule 83.5, I certify that I am eligible for admission to this Court, am
admitted, practicing and in good standing as a member of the Bar of the State of California, and
pursuant to Local Rule 83.6 submit to the disciplinary jurisdiction of this Court for any alleged
misconduct which occurs in the preparation or course of this action. I also certify that I am
generally familiar with this Court’s Local Rules. In accordance with Standing Order for Attorney
Registration and Pro Hac Vice Fees effective 1/1/2024, I further certify that the filing fee of $50.00
will be submitted to the Clerk’s Office upon the filing of this motion.

Dated: January 26, 2024

/s/ Timothy Chen Saulsbury
Timothy Chen Saulsbury
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, CA 94105-2482
[phone]
[e-mail]

CERTIFICATION BY COUNSEL TO BE ADMITTED PRO HAC VICE
Pursuant to Local Rule 83.5, I certify that I am eligible for admission to this Court, am
admitted, practicing and in good standing as a member of the Bars for the State of California and
District of Columbia, and pursuant to Local Rule 83.6 submit to the disciplinary jurisdiction of
this Court for any alleged misconduct which occurs in the preparation or course of this action. I
also certify that I am generally familiar with this Court’s Local Rules. In accordance with Standing
Order for Attorney Registration and Pro Hac Vice Fees effective 1/1/2024, I further certify that
the filing fee of $50.00 will be submitted to the Clerk’s Office upon the filing of this motion.

Dated: January 26, 2024

/s/ Aditya V. Kamdar
Aditya V. Kamdar
MORRISON & FOERSTER LLP
2100 L Street, NW, Suite 900
Washington, D.C., 20037
[phone]
[e-mail]

CERTIFICATION BY COUNSEL TO BE ADMITTED PRO HAC VICE
Pursuant to Local Rule 83.5, I certify that I am eligible for admission to this Court, am
admitted, practicing and in good standing as a member of the Bar for the State of California and
pursuant to Local Rule 83.6 submit to the disciplinary jurisdiction of this Court for any alleged
misconduct which occurs in the preparation or course of this action. I also certify that I am
generally familiar with this Court’s Local Rules. In accordance with Standing Order for Attorney
Registration and Pro Hac Vice Fees effective 1/1/2024, I further certify that the filing fee of $50.00
will be submitted to the Clerk’s Office upon the filing of this motion.

Dated: January 26, 2024

/s/ Laura Gilbert Remus
Laura Gilbert Remus
MORRISON & FOERSTER LLP
707 Wilshire Boulevard
Los Angeles, CA 90017-3543
[phone]
[e-mail]

CERTIFICATE OF SERVICE
I hereby certify that on January 26, 2024, I caused the foregoing to be electronically filed
with the Clerk of the Court using CM/ECF, which will send notification of such filing to all
registered participants.
I further certify that I caused copies of the foregoing document to be served on January 26,
2024, upon the following in the manner indicated:
Tammy L. Mercer, Esquire
Robert M. Vrana, Esquire
YOUNG CONAWAY STARGATT & TAYLOR, LLP
1000 North King Street
Wilmington, DE 19801
Attorneys for Plaintiff

VIA ELECTRONIC MAIL

Benjamin E. Marks, Esquire
Jared R. Friedmann, Esquire
WEIL, GOTSHAL & MANGES LLP
767 Fifth Avenue
New York, NY 10153
Attorneys for Plaintiff

VIA ELECTRONIC MAIL

/s/ Michael J. Flynn
Michael J. Flynn (#5333)