Unites States v. Pokerstars, et al

Filing 100

MOTION for Ian J. Imrich to Appear Pro Hac Vice. Document filed by Christopher Ferguson.(bwa) (pgu).

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~ UNITED STATES DISTRICT COURT
,_. SOUTHERN DISTRICT OF NEW YORK

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UNITED STATES OF AMERICA
Plaintiff,
MOTION TO ADMIT COUNSEL
PRO HAC VICE

-against11-CV-2564 (LBS)
POKERSTARS, ET AL.
Defendants.
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PURSUANT TO RULE 1.3(c) ofthe Local Rules of the United States District cgvrts..fgr

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the Southern and Eastern Districts ofNew York, I, Jonathan Harris, a member in good sUindi~
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of the bar of this Court, hereby more for an Order allowing the admission pro hac vice of the

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following applicant, in order to represent the Defendant and Claimant, Christopher Ferguson:

Ian J. Imrich
Law Offices oflan J. Imrich, Esq.
A Professional Corporation
10866 Wilshire Boulevard, Suite 1240
Los Angeles, California 90024
310.481.2258 (Voice)
310.481.4475 (Fax)
ian@i j ilaw. com
As set forth in the annexed declaration, Mr. Imrich is a member in good standing of the
Bar of the State of California, and there are no pending disciplinary proceeding against him any

State or Federal court. Further, he has been retained to represent Defendant/Claimant
Christopher Ferguson in this proceeding.

Dated: November 1, 2011
NewYork, NY
Respectfully submitted,

,.......-~A~#~
a athan Harris
arris, Cutler & Houghteling LLP
Ill Broadway, Suite 402
New York, NY 10006
Ph: 212-397-3700
Email: j on@harriscutler. com

CERTIFICATE OF SERVICE

I hereby certify that on November 1, 2011, I caused the foregoing (1) Motion to Admit
Ian J. Imrich, Pro Hac Vice, (2) Affidavit of Jonathan Harris in support thereof, and (3) Proposed
Order to be served upon the following counsel First Class U.S. Mail:
Assistant United States Attorney Jason Harris Cowley
Office ofthe United States Attorney, S.D.N.Y.
One St. Andrew's Plaza
New York, NY 10007
Attorneys for the Plaintiff United States ofAmerica

JONATHAN HARRIS

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA
Plaintiff,

-against-

DECLARATION OF
JONATHAN HARRIS
IN SUPPORT OF MOTION
TO ADMIT COUNSEL

PRO HAC VICE
11-CV -2564 (LBS)
PO KERST ARS, ET AL.
Defendants.

Jonathan Harris declares under penalty of perjury:
1.

I am a member of Harris, Cutler & Houghteling LLP, counsel for Defendant and

Claimant Christopher Ferguson in the above captioned case. I am familiar with the proceedings
in this case. I make this statement based on my personal knowledge of the facts set forth herein
and in support of Mr. Ian J. Imrich as counsel pro hac vice to represent Mr. Christopher
Ferguson in this matter.
2.

I am a member in good standing of the bar ofthe State ofNew York and was admitted to

practice law in 1990. I am also admitted to the bar of the United States District Court for the
Southern District ofNew York, and am in good standing with this Court.
3.

I have known Mr. Imrich since 2011. Mr. Imrich is a member of the Law Offices oflan

J. Imrich, Esq. and a member in good standing of the Bar of California, as evidence by the
attached Certificate of Good Standing, annexed hereto as Exhibit A.

4.

I have found Mr. Imrich to be a skilled attorney and a person of integrity. He is

experienced in federal practice and familiar with the Federal Rules of Procedure.
5.

Accordingly, I am pleased to move the admission oflan J. Imrich,pro hac vice.

6.

I respectfully submit a proposed order granting the admission of Ian J. Imrich pro hac

vice, which is annexed hereto as Exhibit B.

Dated: November 1, 2011
New York, NY

an Harris
is, Cutler & Houghteling LLP
111 Broadway, Suite 402
New York, NY 10006
Ph: 212-397-3700
Email: [e-mail]

THE STATE BAR
OF CALIFORNIA

MEMBJ;lR SERVICES CENTER

180 HOWARD STREET, SAN FRANCISCO, CALIFORNIA 94105-1617

TELEPHONE: [phone]

CERTIFICATE OF STANDING
October 14, 2011

TO WHOM IT MAY CONCERN:
This is to certify that according to the records of the State Bar, IAN JOSHUA
IMRICH, #147010 was admitted to the practice of law in this state by the
Supreme Court of California on June 11, 1990; and has been since that date,
and is at date hereof, an ACTIVE member of the State Bar of California; and
that no recommendation for discipline for professional or other misconduct
has ever been made by the Board of Governors or a Disciplinary Board to
the Supreme Court of the State of California.

THE STATE BAR OF CALIFORNIA

Kath Lambert
Custodian of Membership Records

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA
Plaintiff,
-against-

POKERSTARS, ET AL.

[PROPOSED) ORDER

11-CV-2564 (LBS)

Defendants.

Upon the motion of Jonathan Harris, counsel for Defendant and Claimant Christopher
Ferguson, and his declaration in support;
IT IS HEREBY ORDERED that
Ian J. Imrich
Law Offices of Ian J. Imrich, Esq.
A Professional Corporation
10866 Wilshire Boulevard, Suite 1240
Los Angeles, California 90024
310.481.2258 (Voice)
310.481.4475 (Fax)
[e-mail]
is admitted to practice pro hac vice as counsel for Mr. Ferguson in the above captioned case in
the United States District Court for the Southern District of New York. All attorneys appearing
before this Court are subject to the Local Rules of this Court, including the rules governing
discipline of attorneys. Counsel shall immediately apply for an ECF password at
nysd. uscourts.gov. Counsel shall forward the pro hac vice fee to the Clerk of Court.

Dated: - - - - - -

The Honorable Leonard B. Sand
United States District Judge
Southern District ofNew York