GUNVALSON et al v. PTC THERAPEUTICS, INC.

Filing 6

MOTION for Leave to Appear Pro Hac Vice on behalf of Michael A. Hatch by JACOB GUNVALSON, CHERI AND JOHN GUNVALSON(AS GUARDIANS FOR JACOB GUNVALSON), CHERI AND JOHN GUNVALSON(INDIVIDUALLY). (Attachments: # 1 Certification of Marc E. Wolin, # 2 Declaration of Michael A. Hatch, # 3 Text of Proposed Order, # 4 Certificate of Service)(WOLIN, MARC)

GUNVALSON et al v. PTC THERAPEUTICS, INC.

Doc. 6

Marc E. Wolin ([e-mail]) Jakob B. Halpern ([e-mail]) SAIBER LLC One Gateway Center Newark, N.J. 07102 Telephone: [phone] Facsimile: [phone] Michael A. Hatch ([e-mail]) BLACKWELL BURKE P.A. 431 South Seventh Street, Suite 2500 Minneapolis, MN 55402 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiffs UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY JACOB GUNVALSON, CHERI AND JOHN GUNVALSON, AS GUARDIANS FOR JACOB GUNVALSON, AND CHERI AND JOHN GUNVALSON, INDIVIDUALLY, Plaintiffs, v. PTC THERAPEUTICS, INC., Defendant. TO: PTC Therapeutics, Inc. 100 Corporate Court South Plainfield, N.J. 07080 ) ) ) ) ) ) ) ) ) ) ) ) ) ) Civil Action No. 08-3559 (WJM) (MF) NOTICE OF PLAINTIFFS' MOTION FOR PRO HAC VICE ADMISSION OF CO-COUNSEL DOCUMENT FILED ELECTRONICALLY RETURN DATE: Date to be Set by the Court

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PLEASE TAKE NOTICE that on a date and time to be set by the Court, plaintiffs Jacob Gunvalson, Cheri and John Gunvalson, as guardians for Jacob Gunvalson, and Cheri and John Gunvalson, individually (collectively, "Plaintiffs") shall appear before the Honorable William J. Martini, U.S.D.J., King Federal Building & U.S. Courthouse, 50 Walnut Street, Newark, New Jersey 07101, and shall move this Court for entry of an Order pursuant to Local Civil Rule 101.1(c) admitting Michael A. Hatch, Esq., member in good standing of the bar of the state of Minnesota, as counsel pro hac vice in this matter. PLEASE TAKE FURTHER NOTICE that in support of their Motion, Plaintiffs shall rely upon the Application and Certification of Marc E. Wolin, Esq., and the Declaration of Michael A. Hatch, Esq. A proposed form of Order is also submitted for the Court's consideration. PLEASE TAKE FURTHER NOTICE that Plaintiffs hereby request that their application be considered for a ruling on the papers only, unless opposition is timely

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filed.

Plaintiffs request oral argument on the return date of the within motion if

opposition to said motion is filed. Respectfully submitted, SAIBER LLC Attorneys for Plaintiffs _/s/ Marc. E. Wolin____________ Marc E. Wolin ([e-mail]) Jakob B. Halpern ([e-mail]) One Gateway Center, 13th Floor Newark, NJ 07102 Tel: [phone] Michael A. Hatch ([e-mail]) BLACKWELL BURKE P.A. 431 South Seventh Street, Suite 2500 Minneapolis, MN 55402 Tel: [phone] Dated: July 28, 2008

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STATEMENT IN LIEU OF BRIEF PURSUANT TO L.CIV.R. 7.1(c)(1) Pursuant to Local Civil Rule 7.1(c)(1), Plaintiffs submit this Statement in lieu of the submission of a formal brief in support of their application for the admission pro hac vice of co-counsel. Inasmuch as the admission of counsel pro hac vice under the terms of Local Civil Rule 101.1(c) is a matter within the sound discretion of the Court, and until any opposition to the within motion is filed with the Court by defendant herein, it is respectfully submitted that no brief in support of the within motion is necessary at this time. SAIBER LLC Attorneys for Plaintiffs _/s/ Marc. E. Wolin____________ Marc E. Wolin ([e-mail]) Jakob B. Halpern ([e-mail]) One Gateway Center, 13th Floor Newark, NJ 07102 Tel: [phone] Michael A. Hatch ([e-mail]) BLACKWELL BURKE P.A. 431 South Seventh Street, Suite 2500 Minneapolis, MN 55402 Tel: [phone] Dated: July 28, 2008

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