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# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

# Case No. 0:16-mc-61262-JEM

In re: SUBPOENA TO BRADLEY J. EDWARDS

Underlying case:

VIRGINIA L. GIUFFRE,
Plaintiff,

V.

GHISLAINE MAXWELL
Defendant.

No. 15-cv-07433-RWS (S.D.N.Y.)

## MOTION TO APPEAR PRO HAC VICE, CONSENT TO DESIGNATION, AND REQUEST TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING

In accordance with Local Rules 4(b) of the Special Rules Governing the Admission and Practice of Attorneys of the United States District Court for the Southern District of Florida, the undersigned respectfully moves for the admission pro hac vice of Jeffrey S. Pagliuca of the law firm of Haddon, Morgan and Foreman, P.C., 150 East 10th Avenue, Denver, Colorado 80203, 303-831-7364, for purposes of appearance as co-counsel on behalf of Defendant Ghislaine Maxwell in the above-styled case only, and pursuant to Rule 2B of the CM/ECF Administrative Procedures, to permit Jeffrey S. Pagliuca to receive electronic filings in this case, and in support thereof states as follows:

1. Jeffrey S. Pagliuca is not admitted to practice in the Southern District of Florida and is a member in good standing of the bar of the state of Colorado and United States District Courts of Colorado.

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	2. Movant, Denise D. Riley, Esquire, of the law firm of Riley Law PLLC, 2710 Del Prado Blvd. S., Unit 2-246, Cape Coral, Florida 33904, 303-907-0075, is a member in good standing of the Florida Bar and the United States District Court for the Southern District of Florida and is authorized to file through the Court’s electronic filing system. Movant consents to be designated as a member of the Bar of this Court with whom the Court and opposing counsel may readily communicate regarding the conduct of the case, upon whom filings shall be served, who shall be required to electronically file all documents and things that may be filed electronically, and who shall be responsible for filing documents in compliance with the CM/ECF Administrative Procedures. See Section 2B of the CM/ECF Administrative Procedures.

3. In accordance with the local rules of this Court, Jeffrey S. Pagliuca has made payment of this Court’s $75 admission fee. A certification in accordance with Rule 4(b) is attached hereto.

4. Jeffrey S. Pagliuca, by and through designated counsel and pursuant to Section 2B CM/ECF Administrative Procedures, hereby requests the Court to provide Notice of Electronic Filings to Jeffrey S. Pagliuca at email address: jpagliuca@hmflaw.com with a copy to Nicole Simmons at email address: nsimmons@hmflaw.com.

WHEREFORE, Denise D. Riley, moves this Court to enter an Order Jeffrey S. Pagliuca, to appear before this Court on behalf of Defendant Ghislaine Maxwell for all purposes relating to the proceedings in the above-styled matter and directing the Clerk to provide notice of electronic filings to Jeffrey S. Pagliuca.

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Date: June 29, 2016

Respectfully submitted,

/s Denise D. Riley
Denise D. Riley (Fl. Bar No. 160245)
Email: denise@rileylawpl.com
Riley Law PLLC
2710 Del Prado Blvd. S., Unit 2-246,
Cape Coral, FL 33904
303.907.0075
Attorneys for Defendant Ghislaine Maxwell

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# CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Motion to Appear Pro Hac Vice, Consent to Designation and Request to Electronically Receive Notices of Electronic Filings was served by using the CM/ECF system on June 29, 2016, which will send a notice of electronic filing to the following counsel or parties of record on the service list:

## SERVICE LIST

Jack Scarola
jsx@searcylaw.com
mep@searcylaw.com
Searcy Denney Scarola Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 34409
Phone: 561-686-6300
Fax : 561-383-9451
Attorneys for Plaintiff Bradley J. Edwards

/s Denise D. Riley
Denise D. Riley (Fl. Bar No. 160245)
Email: denise@rileylawpl.com
Riley Law PLLC
2710 Del Prado Blvd. S., Unit 2-246,
Cape Coral, FL 33904
Phone: 303.907.0075
Attorneys for Defendant Ghislaine Maxwell
documents/doj-3be69c989a1eba20.pdf
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