Chang et al v. United States of America et al

MOTION for Leave to Appear on behalf of Terrence D. Ryan

D.D.C.August 12, 2010

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ____________________________________ : RAYMING CHANG, et al., : : Plaintiffs, : : v. : Civ. Action No. 02-2010 (EGS/JMF) : UNITED STATES OF AMERICA, et al., : : Defendants. : : MOTION OF TERRENCE D. RYAN TO BE REPRESENTED BY COUNSEL AT AUGUST 16, 2010 STATUS HEARING Terrence D. Ryan, by and through his counsel, Monique D. Pressley of the Office of the Attorney General for the District of Columbia, in response to this Court’s Order of July 29, 2010, respectfully requests that the Court excuse Mr. Ryan’s appearance at the August 16, 2010 hearing and allow him to be represented by counsel. In support of this position, he states the following: 1. Mr. Ryan is now represented by undersigned counsel for the purposes of the Special Master’s investigation. 2. Undersigned counsel for Mr. Ryan, a former criminal defense attorney and currently a Senior Assistant Attorney General in the Civil Division of the Office of the Attorney General, is experienced in all facets of civil and criminal law and procedure involved in these proceedings. 3. Mr. Ryan, an attorney for over thirty years, is aware of his constitutional rights. Case 1:02-cv-02010-EGS -JMF Document 673 Filed 08/12/10 Page 1 of 4 4. Undersigned counsel has advised Mr. Ryan of his rights and will continue to advise him regarding any and all issues which may arise during proceedings before the Special Master. For the foregoing reasons, Mr. Ryan moves that he be represented by counsel at the August 16, 2010 status hearing, without personal attendance. Respectfully submitted, PETER J. NICKLES Attorney General for the District of Columbia /S/ George C. Valentine_________________ GEORGE C. VALENTINE Deputy Attorney General Civil Litigation Division /s/ Monique A. Pressley_________________ MONIQUE A. PRESSLEY [464432] Senior Assistant Attorney General Equity Section I 441 4th Street, NW, 6th Floor South Washington, DC 20001 (202) 724-6610 Fax: (202) 741-0424 monique.pressley@dc.gov Attorneys for Terrence D. Ryan Case 1:02-cv-02010-EGS -JMF Document 673 Filed 08/12/10 Page 2 of 4 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ____________________________________ : RAYMING CHANG, et al., : : Plaintiffs, : : v. : Civ. Action No. 02-2010 (EGS/JMF) : UNITED STATES OF AMERICA, et al., : : Defendants. : : MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION OF TERRENCE D. RYAN TO BE REPRESENTED BY COUNSEL AT AUGUST 16, 2010 STATUS HEARING In their joint motion to stay, the parties rely upon the following authorities: 1. Inherent Power of the Court. 2. Fed. R. Civ. P. 7(b). 3. Fed. R. Civ. P. 53. 4. The record herein. Respectfully submitted, PETER J. NICKLES Attorney General for the District of Columbia /S/ George C. Valentine_________________ GEORGE C. VALENTINE Deputy Attorney General Civil Litigation Division /s/ Monique A. Pressley_________________ MONIQUE A. PRESSLEY [464432] Senior Assistant Attorney General Case 1:02-cv-02010-EGS -JMF Document 673 Filed 08/12/10 Page 3 of 4 Equity Section I 441 4th Street, NW, 6th Floor South Washington, DC 20001 (202) 724-6610 Fax: (202) 741-0424 monique.pressley@dc.gov Attorneys for Terrence D. Ryan Case 1:02-cv-02010-EGS -JMF Document 673 Filed 08/12/10 Page 4 of 4