UNITED STATES OF AMERICA v. 8 GILCREASE LANE, QUINCY, FLORIDA 32351 et al

Filing 12

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- D. Jack Smith, :Firm- Law Offices of D. Jack Smith, :Address- 4620 Shady Grove Road, Memphis, TN 39117. Phone No. - 901-685-1586. Fax No. - 901-763-2976 by GOLDEN PANDA AD BUILDER, CLARENCE BUSBY, JR (Attachments: # 1 Affidavit)(Emord, Jonathan)

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, c/o United States Attorney's Office 555 Fourth St., N.W., Washington, D.C. 20530, Plaintiff, v. 8 GILCREASE LANE, QUINCY FLORIDA 32351, and, ONE CONDO LOCATED ON NORTH OCEAN BOULEVARD IN MYRTLE BEACH, SOUTH CAROLINA, and, ALL FUNDS, INCLUDING APPROXIMATELY $53 MILLION, HELD ON DEPOSIT AT BANK OF AMERICA ACCOUNTS IN THE NAMES (1) THOMAS A. BOWDOIN, JR., SOLE PROPRIETOR, DBA ADSURFDAILY, (2) CLARENCE BUSBY JR. AND DAWN STOWERS, DBA GOLDEN PANDA AD BUILDER, AND (3) GOLDEN PANDA AD BUILDER, Defendants, and GOLDEN PANDA AD BUILDER, AND CLARENCE BUSBY, JR. Claimants. Civil Action No: 1:08-cv-01345 Hon. Rosemary M. Collyer MOTION FOR ADMISSION PRO HAC VICE

MOTION FOR ADMISSION PRO HAC VICE The above-referenced Claimants ("Claimants"), by counsel and pursuant to D.C. District Rule 83.2(d), hereby move this Honorable Court to permit D. Jack Smith, Esq., an attorney not admitted to practice before this Court, to do so for the limited purpose of representing Clarence Busby Jr., d/b/a Golden Panda Ad Builder. In support, Claimants' counsel states as follows: 1. 2. D. Jack Smith is an attorney licensed to practice in the states of Tennessee. Mr. Smith is in good standing in each jurisdiction where he is licensed and has never been disciplined by any bar or by any court for wrongful, unethical, or unlawful conduct except for a fee dispute matter that occurred approximately 20 years ago. 3. Mr. Smith is familiar with, and agrees to be bound by, the rules of this Court and agrees to submit to this Court's power. 4. Mr. Smith has not applied for pro hac vice admission before this Court within the last two years. 5. Mr. Smith's office address and phone number is as follows: D. Jack Smith, Esq. Law Offices of D. Jack Smith 4620 Shady Grove Road Memphis, TN 39117 Based on the foregoing and on the attached affidavit of Mr. D. Jack Smith, counsel for Claimants respectfully requests that this motion be granted and that Mr. D. Jack Smith be permitted to appear before this Honorable Court pro hac vice.

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Respectfully submitted,

________/s/________________ Jonathan W. Emord, Esq. D.C. Bar. No. 407414 Emord & Associates, P.C. 11808 Wolf Run Lane Clifton, VA 20124 Ph: [phone] Fx: [phone] [e-mail]

Dated: August 25, 2008

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