WILSON v. MENU FOODS INCOME FUND et al

Filing 8

Attachment 2
MOTION for Leave to Appear Pro Hac Vice MARK J. TAMBLYN and STUART C. TALLEY by LARRY WILSON. (Attachments: # 1 Statement As to Why No Brief is Necessary# 2 Certification of Joseph J. DePalma in Support of Motion# 3 Certification of Mark J. Tamblyn in Support of Motion# 4 Certification of Stuart C. Talley# 5 Text of Proposed Order # 6 Certificate of Service)(DEPALMA, JOSEPH)

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WILSON v. MENU FOODS INCOME FUND et al Doc. 8 Att. 2 Case 1:07-cv-01456-NLH-AMD Document 8-3 Filed 05/21/2007 Page 1 of 3 LITE DEPALMA GREENBERG & RIVAS, LLC Joseph J. DePalma Two Gateway Center, 12th Floor Newark, NJ 07102-5003 Telephone: 973-623-3000 Facsimile: 973-968-3845 Attorneys for Plaintiff UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY DOCUMENT ELECTRONICALLY FILED LARRY WILSON, on behalf of himself and all others similarly situated, Plaintiff, v. MENU FOODS INCOME FUND, MENU FOODS, INC., a New Jersey corporation, MENU FOODS HOLDINGS, INC., and MENU FOODS MIDWEST CORPORATION, a Delaware corporation Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Civil Action No. 07-1456 (NLH) CERTIFICATION OF JOSEPH J. DEPALMA IN SUPPORT OF MOTION TO ADMIT MARK J. TAMBLYN AND STUART C. TALLEY TO APPEAR AND PARTICIPATE PRO HAC VICE Joseph J. DePalma hereby certifies and says: 1. I am an attorney at law of the State of New Jersey, and a member of the law firm of Lite DePalma Greenberg & Rivas, LLC, located at Two Gateway Center, 12th Floor, Newark, New Jersey 07102, counsel for Plaintiff in this matter. As such, I have personal knowledge of the facts herein. 2. I have been asked by the law firms of Wexler Toriseva Wallace, LLP and Kershaw, Cutter & Ratinoff, LLP to participate with them as co-counsel in connection with the abovecaptioned matter on behalf of Plaintiff. 143564 v1 -1Dockets.Justia.com Case 1:07-cv-01456-NLH-AMD Document 8-3 Filed 05/21/2007 Page 2 of 3 3. I make this certification in support of an application to admit Mark J. Tamblyn and Stuart C. Talley pro hac vice as attorney for Plaintiff before this Court. 4. Mark J. Tamblyn is a partner with the firm Wexler Toriseva Wallace, LLP located at 1610 Arden Way, Suite 290, Sacramento, California. Mr. Tamblyn has advised me that he is a member in good standing of the Bar of the State of California and is admitted to practice in the courts of the Eastern, Northern, Southern, and Central Districts of California. Mr. Tamblyn has further advised me that he has never been disbarred or suspended. 5. Stuart C. Talley is a partner with the firm Kershaw, Cutter & Ratinoff, LLP located at 980 9th Street, Suite 1900, Sacramento, California 95814. Mr. Talley has advised me that he is a member in good standing of the Bar of the State of California and is admitted to practice in the courts of the Eastern, Northern, Southern, and Central Districts of California. Mr. Talley has further advised me that he has never been disbarred or suspended. 6. I understand and have informed Mr. Tamblyn and Mr. Talley that, in the event that the Court grants this application, all notices, orders and pleadings shall be served upon me as liaison counsel, and I shall promptly notify counsel of their receipt, and that only an attorney at law of this Court may file papers, enter appearances for parties, sign stipulations, or sign and receive payments on judgments, decrees or orders. 7. There is good cause for the pro hac vice admission of Mark J. Tamblyn and Stuart C. Talley as they are familiar with the facts, issues and pleadings in this action and no delay in the conduct of the proceedings would be occasioned by them acting as attorneys for Plaintiff in this matter. 8. I was admitted to the bar of the State of New Jersey in 1982. I am a member of the Bars of the State of New Jersey; U.S. District Court, District of New Jersey; U.S. Court of Appeals, Third Circuit and the United States Supreme Court. 143564 v1 -2- Case 1:07-cv-01456-NLH-AMD Document 8-3 Filed 05/21/2007 Page 3 of 3 9. 10. I am not under suspension or disbarment of any court. Accordingly, I respectfully request that this Court enter the proposed Order admitting Mark J. Tamblyn and Stuart C. Talley to appear pro hac vice in this action. 11. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are wilfully false, I am subject to punishment. Dated: May 21, 2007 /s/ Joseph J. DePalma Joseph J. DePalma 143564 v1 -3-

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