Doe 1 et al v. Government of the United States Virgin Islands et al

Filing 99

MEMO ENDORSEMENT granting 93 Motion for Leave to Appear. ENDORSEMENT Application GRANTED. The Clerk of Court is directed to terminate the motion at ECF No. 93. SO ORDERED. (Signed by Judge Arun Subramanian on 5/9/2024) (jca)

Case 1:23-cv-10301-AS Document 93 Filed 04/29/24 Page 2 of 5

and for such other and further relief as this Court deems just and proper.
Dated: South Salem, New York
April 29, 2024
Respectfully submitted,

________________________________________
Annette G. Hasapidis, Esq.
HASAPIDIS LAW OFFICES
38C Grove Street
Ridgefield, CT 06877
Telephone: [phone]
[e-mail]

Case 1:23-cv-10301-AS Document 93 Filed 04/29/24 Page 3 of 5

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-------------------------------------------------------------------X
JANE DOE 1, individually, and on behalf of all
others similarly situated, JANE DOE 2,
individually and on behalf of all others similarly
situated, JANE DOE 3, individually and on behalf
of all others similarly situated, JANE DOE 4,
individually and on behalf of all others similarly
situated JANE DOE 5, individually and on behalf
of all others similarly situated, and JANE DOE 6,
individually and on behalf of all others similarly
situated,
Plaintiffs,
v.

Civil Action No:23-cv-10301-AS
DECLARATION

GOVERNMENT OF THE UNITED STATES VIRGIN
ISLANDS, FIRST LADY CECILE DE JONGH,
GOVERNOR KENNETH MAPP, SENATOR
CELESTINO WHITE, ATTORNEY GENERAL
VICENT FRAZER, GOVERNOR JOHN DE JONGH,
SENATOR CARTLTON DOWE, DELEGATE
STACEY PLASKETT, and JOHN DOES 1-100,
Defendants.
-------------------------------------------------------------------X
ANNETTE G. HASAPIDIS, pursuant to 28 U.S.C. §1746, declares as follows:
1.

I am an attorney duly admitted to practice law before this Court and co-counsel for

Plaintiffs in this action. As such, I submit this Declaration in support of this motion for an order
deeming my admission to this Court, nunc pro tunc, as of November 22, 2023.
2.

I was admitted to practice in New York State on April 29, 1992. Exhibit A. I was

admitted to the United States District Court for the Eastern District of New York as of February 4,
1994. Exhibit B. Thereafter, I was admitted to the United States Court of Appeals for the Second

Case 1:23-cv-10301-AS Document 93 Filed 04/29/24 Page 4 of 5

Circuit on November 2, 1994. Exhibit C. I was admitted to practice in the State of Connecticut
on July 26, 2013. Exhibit D. I remain in good standing in all of the foregoing jurisdictions.
3.

I have an unblemished reputation in the legal community. I have never been

sanctioned in any jurisdiction. Nor have I ever been subject to a complaint by any client in any
jurisdiction.
4.

I have served as appellate counsel to the Merson Law firm since January 2019.

Without waiving privilege or confidentiality, I advise this Court that I have worked with the firm
in prosecuting this action. During the course of my review of a draft of the Complaint initially
filed in this matter on November 22, 2023 (the day before Thanksgiving), I observed that the draft
included my firm’s name and address block. I removed that address block. Simultaneously, I
advised Mr. Merson that I was not yet admitted to practice before this Court, so I could not record
an appearance on the docket nor make any filings. I did, however, intend to seek admission to this
Court in the NewYear.
5.

As the Court may note from the Complaint that was initially filed, my firm’s name

does not appear on the Complaint. However, my name and email address was included in the
signature block on the final page of that pleading.
6.

There was an extreme urgency in finalizing the Complaint before the revival

window (under New York’s Adult Survivors Act) for Plaintiffs’ claims closed on November 24,
2023, the day after Thanksgiving. Unfortunately, I failed to notice that my name and email address
had been added to the Merson Law firm’s signature block.
7.

I became aware that my name was included on the pleading during the Christmas

holiday, due to media articles concerning the lawsuit. After consulting with my ethics counsel,
Deborah A Scalise, of Scalise & Hamilton, PC, I began the process for admission to this Court in

Case 1:23-cv-10301-AS Document 93 Filed 04/29/24 Page 5 of 5

January 2024, seeking to waive in through my admission in the Eastern District. I immediately
secured a sponsor and spent two months, inter alia, completing and filing the application, securing
the certificates of good standing from New York State, Connecticut and the Eastern District Court,
and obtaining the requisite information from my sponsor. My application was accepted on March
13, 2024 and I was admitted on that day. Exhibit E.
WHEREFORE, for the foregoing reasons, the undersigned respectfully requests that this
Court grant the motion and enter an order deeming her admission to this Court, nunc pro tunc, as
of November 22, 2023, together with such other and further relief as this Court deems just and
proper.
Dated: South Salem, New York
April 29, 2024
Respectfully submitted,

________________________________________
Annette G. Hasapidis, Esq.
HASAPIDIS LAW OFFICES
38C Grove Street
Ridgefield, CT 06877
Telephone: [phone]
[e-mail]