Massachusetts Bay Transportation Authority v. Anderson et al

Filing 42

MOTION for Leave to Appear Pro Hac Vice for admission of Cindy Cohn Filing fee $ 50, receipt number 01010000000002078677. by Zack Anderson, RJ Ryan, Alessandro Chiesa. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Reinstein, John)

Massachusetts Bay Transportation Authority v. Anderson et al

Doc. 42

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS Civil Action No. 08-11364-GAO MASSACHUSETTS BAY TRANSPORTATION AUTHORITY, Plaintiff, v. ZACK ANDERSON, RJ RYAN, ALESSANDRO CHIESA, and the MASSACHUSETTS INSTITUTE OF TECHNOLOGY, Defendants.

MOTION FOR ADMISSION PRO HAC VICE
Pursuant to Massachusetts Local Rule 83.5.3(b), John Reinstein, Esq., a member in good standing of the Bar of the Commonwealth of Massachusetts and the United States District Court for the District of Massachusetts, moves for the admission of Cindy Cohn, a member of the Bar of the State of California, to this Court for the purpose of representing defendants in the above-captioned matter, and states as follows: 1. Cindy Cohn is counsel at the Electronic Frontier Foundation. Her

business address is 454 Shotwell Street, San Francisco, CA 94110. number is [phone]. 2.

Her telephone

Cindy Cohn is a member in good standing of the Bar of the State of

California, as evidenced by the Certificate of Good Standing attached hereto as Exhibit A. There are no disciplinary proceedings pending against her as a member of the bar in any jurisdiction. See Affidavit of Cindy Cohn, attached hereto as Exhibit B. 3. Cindy Cohn is familiar with the applicable provisions of the Local Rules 1

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of the United States District Court for the District of Massachusetts. 4. John Reinstein, a member of the Bar of the Commonwealth of

Massachusetts and the United States District Court for the District of Massachusetts, will continue to represent defendants if this motion is granted. 5. Pursuant to Local Rule 7.1(a), Defendants have conferred with counsel for

the Plaintiff and he has no objection to granting this motion. WHEREFORE, the defendants respectfully request that Cindy Cohn be admitted to practice before this Court pro hac vice for the purpose of appearing as counsel for defendants in the above referenced proceeding in accordance with the Rules of this Court. DEFENDANTS ANDERSON, RYAN AND CHIESA By their attorneys, Dated: August 18, 2008 /s/ John Reinstein_ John Reinstein, BBO #416120 [e-mail] ACLU of Massachusettes 211 Congress Street, 3rd Floor Boston, MA 02110 Tel: [phone] Cindy Cohn, CA Bar No. 145997 [e-mail] Jennifer Stisa Granick Bar No. 168423 [e-mail] Kurt Opsahl, CA Bar No. 191303 [e-mail] Marcia Hofmann, CA Bar No. 250087 [e-mail] ELECTRONIC FRONTIER FOUNDATION 454 Shotwell St. San Francisco, CA 94110 [phone] [phone] (fax)

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CERTIFICATE OF SERVICE
In accordance with Local Rule 5.2(b), I, John Reinstein, hereby certify that this document filed through the ECF system on August 18, 2008 will be sent electronically to the registered participants as identified on the Notice of Electronic Filing.

/s/ John Reinstein John Reinstein, Esq.

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