UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
CAREFIRST, INC., et al.,
Plaintiffs,
v.
THE HON. STEPHEN C. TAYLOR, IN
HIS OFFICIAL CAPACITY AS THE
COMMISSIONER, DISTRICT OF
COLUMBIA DEPARTMENT OF
INSURANCE, SECURITIES AND
BANKING, et al.,
Defendants.
Civil Action No. 16-2656 (CCB)
DEFENDANT STEPHEN C. TAYLOR’S MOTION TO EXCUSE
LEAD COUNSEL ELIZABETH SARAH GERE FROM APPEARING AT THE
JUNE 27, 2017 HEARING ON PLAINTIFFS’ MOTION FOR TEMPORARY
RESTRAINING ORDER AND/OR PRELIMINARY INJUNCTION
Defendant Stephen C. Taylor files this Motion to request that lead counsel,
Deputy Attorney General Elizabeth Sarah Gere, be excused from appearing at the
hearing on plaintiffs’ Motion for Temporary Restraining Order and/or Preliminary
Injunction, which is scheduled for June 27, 2017. (ECF No. 78.)
This Court’s Local Civil Rule 101.1(b) requires that any party that is
represented by attorneys admitted pro hac vice also be represented by counsel who
is an active member of the bar of this Court, and that the formally-admitted counsel
be present at all proceedings unless “excused by the presiding judge.” Ms. Gere has
been appointed as a member of the Judicial Conference for the District of Columbia
Circuit, which is scheduled from June 27 to June 30, 2017 in Lancaster,
Pennsylvania.
Case 1:16-cv-02656-CCB Document 80 Filed 06/23/17 Page 1 of 4
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Defendant Taylor therefore requests that Ms. Gere, lead counsel formally
admitted to the bar of this Court, be excused from appearing at the June 27, 2017
hearing, and that Assistant Attorneys General Fernando Amarillas and Gregory
Cumming, both of whom are admitted pro hac vice in this matter, be permitted to
appear without Ms. Gere.
A memorandum of points and authorities in support of this Motion and a
proposed order, are attached. Defendant Taylor respectfully requests that the Court
grant the Motion and enter the proposed order.
Dated: June 23, 2017. Respectfully submitted,
KARL A. RACINE
Attorney General for the District of Columbia
/s/ Elizabeth Sarah Gere
ELIZABETH SARAH GERE, Bar No. 14172
Deputy Attorney General
FERNANDO AMARILLAS, Bar No. 805629*
GREGORY M. CUMMING, Bar No. 805621*
Assistant Attorneys General
Public Interest Division
441 Fourth Street, N.W., Suite 630 South
Washington, D.C. 20001
(202) 724-7272
(202) 741-0578 (fax)
sally.gere@dc.gov
Counsel for Defendant
Commissioner Stephen C. Taylor
*Admitted pro hac vice
Case 1:16-cv-02656-CCB Document 80 Filed 06/23/17 Page 2 of 4
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
CAREFIRST, INC., et al.,
Plaintiffs,
v.
THE HON. STEPHEN C. TAYLOR, IN
HIS OFFICIAL CAPACITY AS THE
COMMISSIONER, DISTRICT OF
COLUMBIA DEPARTMENT OF
INSURANCE, SECURITIES AND
BANKING, et al.,
Defendants.
Civil Action No. 16-2656 (CCB)
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
DEFENDANT STEPHEN C. TAYLOR’S MOTION TO EXCUSE
LEAD COUNSEL ELIZABETH SARAH GERE FROM APPEARING AT THE
JUNE 27, 2017 HEARING ON PLAINTIFFS’ MOTION FOR TEMPORARY
RESTRAINING ORDER AND/OR PRELIMINARY INJUNCTION
Defendant Stephen C. Taylor submits the following points and authorities in
support of his Motion to request that lead counsel, Deputy Attorney General
Elizabeth Sarah Gere, be excused from appearing at the June 27, 2017 hearing
scheduled in the above-captioned matter:
1. The Court’s Local Civil Rule 101.1(b);
2. Defendant’s showing of good cause in support of the Motion; and
3. The inherent power of the Court.
Accordingly, Defendant Taylor requests that the Court grant the Motion and
enter the proposed order.
Case 1:16-cv-02656-CCB Document 80 Filed 06/23/17 Page 3 of 4
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Dated: June 23, 2017. Respectfully submitted,
KARL A. RACINE
Attorney General for the District of Columbia
/s/ Elizabeth Sarah Gere
ELIZABETH SARAH GERE, Bar No. 14172
Deputy Attorney General
FERNANDO AMARILLAS, Bar No. 805629*
GREGORY M. CUMMING, Bar No. 805621*
Assistant Attorneys General
Public Interest Division
441 Fourth Street, N.W., Suite 630 South
Washington, D.C. 20001
(202) 724-7272
(202) 741-0578 (fax)
sally.gere@dc.gov
Counsel for Defendant
Commissioner Stephen C. Taylor
*Admitted pro hac vice
Case 1:16-cv-02656-CCB Document 80 Filed 06/23/17 Page 4 of 4
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
CAREFIRST, INC., et al.,
Plaintiffs,
v.
THE HON. STEPHEN C. TAYLOR, IN
HIS OFFICIAL CAPACITY AS THE
COMMISSIONER, DISTRICT OF
COLUMBIA DEPARTMENT OF
INSURANCE, SECURITIES AND
BANKING, et al.,
Defendants.
Civil Action No. 16-2656 (CCB)
ORDER
Upon consideration of Defendant Stephen C. Taylor’s Motion to Excuse Lead
Counsel Elizabeth Sarah Gere from Appearing at the June 27, 2017 Hearing on
Plaintiffs’ Motion for Temporary Restraining Order and/or Preliminary Injunction,
and the entire record, it is this ______ day of _____________, 2017, ORDERED that:
1) The Motion is GRANTED; and
2) Elizabeth Sarah Gere is excused from appearing at the June 27, 2017
hearing.
_____________________________________________
THE HONORABLE CATHERINE C. BLAKE
Chief Judge
United States District Court for the District of Maryland
Case 1:16-cv-02656-CCB Document 80-1 Filed 06/23/17 Page 1 of 1
