Sexual Minorities Uganda v. Lively

MOTION for Leave to Appear Pro Hac Vice for admission of Horatio Mihet Filing fee: $ 100, receipt number 0101-3896460

D. Mass.April 11, 2012

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS SPRINGFIELD DIVISION SEXUAL MINORITIES UGANDA, : CIVIL ACTION : Plaintiff, : 3:12-CV-30051-KPN : v. : MAGISTRATE JUDGE : KENNETH P. NEIMAN SCOTT LIVELY, : : Defendant. : MOTION FOR ADMISSION PRO HAC VICE OF HORATIO G. MIHET Pursuant to L.R. D. Mass. 83.5.3(b), Philip D. Moran, Esq., a member in good standing of the Bar of the Commonwealth of Massachusetts and the United States District Court for the District of Massachusetts, who has filed an appearance in this case on behalf of Defendant, Scott Lively, respectfully moves this Court to admit attorney Horatio G. Mihet to appear and practice in this Court in the above-styled case. As set forth in his Declaration, attached hereto as Exhibit A: (1) Mr. Mihet is a member of the bar in good standing in every jurisdiction where he has been admitted to practice; (2) there are no disciplinary proceedings pending against Mr. Mihet as a member of the bar in any jurisdiction; and (3) Mr. Mihet is familiar with the Local Rules of the United States District Court for the District of Massachusetts. WHEREFORE, having satisfied each of the requirements of L.R. D. Mass. 83.5.3(b), and for good cause shown, the undersigned counsel respectfully requests that this motion be granted, Case 3:12-cv-30051-KPN Document 11 Filed 04/11/12 Page 1 of 5 2 and that Horatio G. Mihet be permitted to appear and practice in this Court as co-counsel for Defendant Scott Lively in the above-styled case. Respectfully submitted, /s/ Philip D. Moran________________ Philip D. Moran (MA Bar # 353920) 265 Essex Street, Suite 202 Salem, Massachusetts 01970 Tel: (978) 745-6085 Fax: (978) 741-2572 Email: philipmoranesq@aol.com Attorney for Defendant Scott Lively CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was filed electronically with the Court on April 11, 2012. Service will be effectuated by the Court’s electronic notification system upon all counsel or parties of record. /s/ Philip D. Moran________________ Philip D. Moran Attorney for Defendant Scott Lively Case 3:12-cv-30051-KPN Document 11 Filed 04/11/12 Page 2 of 5 EXHIBIT A Case 3:12-cv-30051-KPN Document 11 Filed 04/11/12 Page 3 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS SPRINGFIELD DIVISION SEXUAL MINORITIES UGANDA, : CIVIL ACTION : Plaintiff, : 3:12-CV-30051-KPN : v. : MAGISTRATE JUDGE : KENNETH P. NEIMAN SCOTT LIVELY, : : Defendant. : DECLARATION OF HORATIO G. MIHET IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE I, HORATIO G. MIHET, declare as follows: 1) I am Senior Litigation Counsel at Liberty Counsel, P.O. Box 540774, Orlando, Florida, 32854. My office telephone number is 800-671-1776, and fax number is 407-875-0770. 2) I am a member of the bar of the State of Florida (Bar No. 26581), where I was admitted to practice in 2006. I am also a member of the bar of the State of Ohio (Bar No. 75518), where I was admitted to practice in 2002. I am also admitted to practice in several federal courts, including the Northern, Middle and Southern Districts of Florida, the Northern and Southern Districts of Ohio, the Sixth Circuit Court of Appeals and the Eleventh Circuit Court of Appeals. 3) I am a member in good standing of the bar in every jurisdiction where I have been admitted to practice. 4) There are no disciplinary proceedings pending against me as a member of the bar in any jurisdiction. 5) I am familiar with the Local Rules of the United States District Court for the District of Massachusetts. Case 3:12-cv-30051-KPN Document 11 Filed 04/11/12 Page 4 of 5 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on April 10, 2012. /s/ Horatio G. Mihet___________ HORATIO G. MIHET Case 3:12-cv-30051-KPN Document 11 Filed 04/11/12 Page 5 of 5