Martin v. Washington Post Company et al

Filing 5

MOTION for Leave to Appear Pro Hac Vice for David P. Sanders and Wade R. Thomson by Defendant Daniel Morse. Responses due by 1/4/2010 (Craven, Donald)

Martin v. Washington Post Company et al

Doc. 5

3:09-cv-03295-JES-BGC # 5

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Friday, 18 December, 2009 03:48:22 PM Clerk, U.S. District Court, ILCD UNITED STATES DISTRICT COURT - CENTRAL DISTRICT OF ILLINOIS SPRINGFIELD DIVISION ANDY MARTIN, Plaintiff, v. WASHINGTON POST COMPANY, DANIEL MORSE, SCOTT SHIRLEY, d/b/a ADD PRODUCTION, GOOGLE, INC., JOHN GILCHRIST, a/k/a JOHN BORLAZA, JIM BROSEMER, MONTGOMERY COUNTY, ) MARYLAND, JOHN J. McCARTHY, JOHN DOE AGENT OF MARK KIRK and/or BARACK HUSSEIN OBAMA, WILLIAM G. SIMMONS, EUGENE WOLFE, CHERYL McCALLY, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

E-FILED

No. 3:09-cv-03295-JES-BGC Magistrate Judge Byron G. Cudmore

MOTION OF DEFENDANT DANIEL MORSE FOR ORDER GRANTING LEAVE TO DAVID P. SANDERS AND WADE R. THOMSON TO APPEAR PRO HAC VICE Defendant Daniel Morse ("Morse"), by his attorneys, moves this Court, pursuant to CDILLR 83.05(F), for entry of an order granting leave to David R. Sanders and Wade A. Thomson to appear as his counsel in this action pro hac vice. In support of this motion, Morse states as follows: 1. Morse is one of the defendants in this action. He currently is employed by the Washington Post newspaper. 2. Morse has retained David P. Sanders and Wade A. Thomson of the Chicago law firm of Jenner & Block LLP to serve as his lead counsel in this action. 3. Mr. Sanders is a partner with Jenner & Block, where he has practiced since 1974. He is a member in good standing of the bar of the State of Illinois, of the United States Court of

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Dockets.Justia.com

3:09-cv-03295-JES-BGC # 5

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Appeals for the Seventh Circuit, and of the Trial Bar of the United States District Court for the Northern District of Illinois. 4. Mr. Thomson is an associate with Jenner & Block, where he has practiced since 2004. He is a member in good standing of the bar of the State of Illinois, and of the United States District Court for the Northern District of Illinois. 5. Donald M. Craven of Springfield, Illinois will also be representing Morse as local counsel in this action. WHEREFORE, Daniel Morse respectfully requests that this Court grant leave to David P. Sanders and Wade A. Thomson to appear pro hac vice in this action. DANIEL MORSE, Defendant

By:

/s/ Donald M. Craven Donald M. Craven (ARDC #6180492) Attorney for Defendant Donald M. Craven, P. C. 1005 North Seventh Street Springfield, IL 62704 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail] David P. Sanders (#2452359) Wade R. Thomson (#6282174) JENNER & BLOCK LLP 353 North Clark Street Chicago, IL 60654-3456 Telephone: [phone]

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PROOF OF SERVICE

I hereby certify that on December 18, 2009 I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following: NONE and I hereby certify that I have mailed by United States Postal Service the document to the following non CM/ECF participants: Andy Martin 30 East Huron St., Suite 4400 Chicago, IL 60611-4723 and other named Defendants. Andy Martin P. O. Box 1851 New York, NY 10150

/s/ Donald M. Craven Donald M. Craven ARDC #6180492 Donald M. Craven, P.C. 1005 North Seventh Street Springfield, IL 62702 Phone: [phone] Facsimile: 217/544-0713 E-Mail: [e-mail] David P. Sanders (#2452359) Wade R. Thomson (#6282174) JENNER & BLOCK LLP 353 North Clark Street Chicago, IL 60654-3456 Telephone: [phone]

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