{Converted to html by JM. I have indicated where there are errors in the original PDF document so you won’t think I made them.}
Case 3:11-cv-00645-RCJ -VPC Document 20 Filed 02/22/12 Page 1 of 4
McMahon LAW OFFICES, LTD.
BRIAN M. McMahon Nevada State Bar No. 00927
Telephone: (775) 348-2701
Facsimile: (775) 348-2702
Email: brian@mamahonlaw.org
Fred Hopengarten (pro hac vice pending)
Telephone: (781) 259-0088
Facsimile: (419) 858-2421
Email: hopengarten@post.harvard.edu
D.C. Bar No. 114124
Attorneys for Plaintiffs
IN THE UNITED STATES DISTRICT COURT
STATE {sic} OF NEVADA
Case No.: 3:11-CV-00645-RCJ-VPC
THOMAS
S. TAORMINA and MIDGE A.
Plaintiffs,
vs.
Defendants.
REPLY IN SUPPORT OF MOTION TO WAIVE LR IA 10-2, PERMITTING COUNSEL TO CONTINUE REPRESENTATION AND NOTICE OF NON-OPPOSITION
Plaintiffs, THOMAS S. TAORMINA, and MIDGE A, TAORMINA, by and through their attorneys, Brian M. McMahon, Esq., of McMahon Law Offices, Ltd., and Fred Hopengarten, Esq., of the District of Columbia Bar, PRO HAV {sic} VICE PENDING, hereby replies in support of the request that this court waive Local Rule IA 10-2 for this lawsuit and this lawsuit only, so that Fred Hopengarten, Esq., may continue to represent them without further documentation and expense. The original Motion was filed on November 16, 2011. No opposition to this motion has been filed to
Case 3:11-cv-00645-RCJ-VPC Document 20 Filed 02/22/12 Page 2 of 4
date. The parties have met with the Magistrate and this issue came before the Magistrate. It is respectfully requested that this Court enter its order granting this motion to waive LR IA 10-2 permitting counsel, Fred Hopengarten, Esq., to continue representation of the TAORMINAS without further documentation and expense.
As set forth in the original Motion to waive, attorney Hopengarten has already been admitted as pro hac vice in Case Number 3:09-cv-00021-LRH-VPC, on January 29, 2009. See approved Verified Petition for Permission to Practice in This Case Only by Attorney Not Admitted to the Bar of this Court and Designation of Local Counsel, attached hereto as Exhibit 1.
Respectfully submitted,
Dated: February 22, 2012.
MCMAHON LAW OFFICES, LTD.
By _________________
Brian M. McMahon
Attorneys for Plaintiff's
Thomas S. Taormina and
Midge A. Taormina
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Case 3:11-cv-00645-RCJ -VPC Document 20 Filed 02/22/12 Page 3 of 4
CERTIFICATE OF SERVICE
Pursuant to NRCP 5(b) I hereby certify that I am an employee of McMahon Law Offices, Ltd., and that on the 22 day of February, 2012, I served a true and correct copy of the attached foregoing document by:
X
Depositing for mailing, in a sealed enveloped, U.S. Postage prepaid, at
__ Personal Delivery
__ Facsimile
__ Federal Express/Airborne Express/Other Overnight Delivery
__ Reno-Carson Messenger Service
addressed as follows:
Brent T. Kolvet, Esq.
Thorndal Armstrong Delk Balkenbush & Eisinger
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Case 3:11-cv-00645-RCJ -VPC Document 20 Filed 02/22/12 Page 4 of 4
Index to Exhibits
Exhibit 1 Verified Petition for Permission to Practice in this Case Only 7 Pages
By Attorney Not Admitted to the Bar of this Court and Designation
Of Local Counsel
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