DEFENDANTS PHILADELPHIA METAL TRADES COUNCIL, RON AULT AND PHILIP ROWAN'S MOTION FOR THE LIMITED ADMISSION (PRO HAC VICE) OF ROBERT MATISOFF, ESQ. AND KEITH R. BOLEK, ESQ., DECLARATION, CERTIFICATE OF SERVICE. (fdc) Additional attachment(s) added on 6/21/2002 (fdc, ).
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Case 2:02-cv-03710-WY Document5 ~ Filed 06/20/2002 Page 1 of 7
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
ener nn ee neem een ee ee eee eee nnn nnn ee enn nnn enn nnn nn nee eennnnn ee en enn nnn I I ES
KVAERNER PHILADELPHIA SHIPYARD, INC.,
Plaintiff,
Vv. No. 02-CV-3710
PHILADELPHIA METAL TRADES COUNCIL, et al.,
Defendants.
Nw New Nee ee ee ee ee ee ee ee ee”
MOTION FOR ADMISSION PRO HAC VICE
COMES NOW, Robert Curley and David D. Capuano, duly admitted to practice and a
member in good standing of the Supreme Court of Pennsylvania and this Court and counsel for
Defendant Philadelphia Metal Trades Council, Ron Ault and Philip Rowan, and hereby move
this Honorable Court to permit Robert Matisoff and Keith R. Bolek to appear pro hac vice on
behalf of the Defendant in this cause. We will act as local counsel for the Defendants in this
matter. The grounds for this motion are set forth in the attached Joint Declaration in Support of
Motion for Admission Pro Hac Vice.
Dated: June 20, 2002
Robert Curley (Bar No. 55760)
David D. Capuano (Bar No. 70238)
O’ DONOGHUE & O’ DONOGHUE
Constitution Place, Suite 515
325 Chestnut Street
Philadelphia, PA 19106
(215) 629-4970
Attorney for Defendant
93840_1.DOCPage 2 ‘ PHILADELPHIA METAL TRADES COUNCIL, et al.,
Case 2:02-cv-03710-WY Document5 ~ Filed 06/20/2002 Page 2of7
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
KVAERNER PHILADELPHIA SHIPYARD, INC.,
Plaintiff,
Vv. No. 02-CV-3710
Defendants.
Nee Ne Ne Ne ee ee ee ee ee ee”
JOINT DECLARATION OF ROBERT MATISOFF AND
- KEITH R. BOLEK IN SUPPORT OF
MOTION FOR ADMISSION PRO HAC VICE
Co-counsel for the Defendant, in support of their admission pro hac vice, declare as
follows:
1, Robert Matisoff is a partner and Keith R. Bolek is an associate with the law firm
of O’Donoghue & O’Donoghue, 4748 Wisconsin Avenue, N.W., Washington, D.C. 20016,
telephone 202-362-0041, facsimile 202-237-1200.
2. The Defendants in this action, Philadelphia Metal Trades Council (““PMTC”), Ron
Ault and Philip Rowan, desires to have Mr. Matisoff and Mr. Bolek of the firm of O’ Donoghue
& O’Donoghue and the attorneys identified above represent them in this matter.
3. Robert Matisoff and Keith R. Bolek are members in good standing of the Bar of
the District of Columbia and the Bar of the State of Maryland. In addition, Robert Matisoff is a
member of the Bar of the Commonwealth of Virginia.Page 3 ses
Case 2:02-cv-03710-WY Document5 ~ Filed 06/20/2002 Page 3 of 7
4. Robert Matisoff has been admitted to practice before, and is presently a member
in good standing of, the bars of the United States District Court for the District of Columbia and
the United States Court of Appeal for the District of Columbia Circuit.
5. Keith R. Bolek has been admitted to practice before, and is presently a member in
good standing of, the bars of the United States District Court for the District of Columbia as well
as the United States Court of Appeals for the Third and D.C. Circuits.
6. There arc no disbarment proceedings presently pending against either Robert
Matisoff or Keith Bolek, nor have any disbarment proceedings ever been instituted against either
of them. No certificate of any privilege to appear and practice before any regulatory or
administrative body has ever been suspended or revoked for either of them.
VERIFICATION
I am the applicant in this matter. I have read the above Declaration, and the matters
stated in it are true of my own knowledge. I declare under penalty of perjury that the above is
true and correct.
Dated: June 19, 2002 By: his Af if
fl Matisoff Zi
vl.
*Kéith K. Bolek
District of Columbia Court of Appeals
Committee om Admissions
500 Indima Avenue, N.W. — Room 4200
Washingt, OB. C. 20001
202/879-2710
I, GARLAND PINKSTON, JR., Clerk of the District of Columbia
Court of Appeals, do hereby certify that
KEITH R. BOLEK
was on the 4th day of June 1999
duly qualified and admitted as an attorney and counselor and
entitled to practice before this Court and is, on the date
indicated below, an active member in good standing of this Bar.
In Testimony Whereof, I have
hereunto subscribed my name and
affixed the seal of this Court
at the City of Washington, D.C.
this 18th day of
June , 2002
GARLAND PINKSTON, JR., CLERK
wy: Hid CL.
—Deputy ClerkPage 5 Case 2:02-cv-03710-WY Document5 ~ Filed 06/20/2002 Page5of7
istrict of Columbia Court of Appeals
Comunitter on Admissions
500 Indiana Avenue, N.Y. — Room 4200
Washingt, H.C. 20001
202/879-2710
I, GARLAND PINKSTON, JR., Clerk of the District of Columbia
Court of Appeals, do hereby certify that
ROBERT MATISOFF
was on the Ist day of January ' 1974
duly qualified and admitted as an attorney and counselor and
entitled to practice before this Court and is, on the date
indicated below, an active member in good standing of this Bar.
In Testimony Whereof, I have
hereunto subscribed my name and
affixed the seal of this Court
at the City of Washington, D.C.
18th
this day of
June 200
f
GARLAND PINKSTON, JR., CLERK
Deputy ClerkPage 6 Case 2:02-cv-03710-WY Document5 ~ Filed 06/20/2002 Page6of7
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
KVAERNER PHILADELPHIA SHIPYARD, INC.,
Plaintiff,
Vv. No. 02-CV-3710
PHILADELPHIA METAL TRADES COUNCIL, ef al.,
Defendants.
Nee ee eee eee ee ee
ORDER GRANTING MOTION
FOR ADMISSION PRO HAC VICE
The Court having considered the papers submitted in support of and in opposition to the
Motion of David D. Capuano for an Order granting permission for Robert Matisoff and Keith R.
Bolek to appear as counsel pro hac vice for Defendants Philadelphia Metal Trades Council, Ron
Ault and Philip Rowan, in association with Robert Curley and David D. Capuano, attorneys of
record in the above-entitled matter, and good cause appearing, THEREFORE,
IT IS ORDERED that the Motion for Admission Pro Hac Vice is GRANTED.
Dated:
HONORABLE WILLIAM H. YOHN, JR.
UNITED STATES DISTRICT COURT JUDGE
93840_1,.DOCPage 7 een e eee ee ee ee ee
Case 2:02-cv-03710-WY Document5 ~ Filed 06/20/2002 Page/7 of 7
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
KVAERNER PHILADELPHIA SHIPYARD, INC.,
Plaintiff,
V. No. 02-CV-3710
PHILADELPHIA METAL TRADES COUNCIL, et al.,
Defendants.
)
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Motion for Admission Pro Hac Vice, Joint
Declaration of Robert Matisoff and Keith R. Bolek in Support thereof, and proposed Order have
been served by hand, this 20" day of June, 2002, upon the following:
Kelly A. Wallenda, Esq.
BALLARD SPAHR ANDREWS & INGERSOLL, LLP
1735 Market Street, 51*' Floor
Philadelphia, PA 19103-7599
Michael N. Katz, Esq.
MERANZE & KATZ
225 S. 15" Street, 12" Floor
Philadelphia, PA 19102-3977
Robert Curley
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PlainSite Cover Page
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Case 2:02-cv-03710-WY Document5 ~ Filed 06/20/2002 Page 1 of 7
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
ener nn ee neem een ee ee eee eee nnn nnn ee enn nnn enn nnn nn nee eennnnn ee en enn nnn I I ES
KVAERNER PHILADELPHIA SHIPYARD, INC.,
Plaintiff,
Vv. No. 02-CV-3710
PHILADELPHIA METAL TRADES COUNCIL, et al.,
Defendants.
Nw New Nee ee ee ee ee ee ee ee ee”
MOTION FOR ADMISSION PRO HAC VICE
COMES NOW, Robert Curley and David D. Capuano, duly admitted to practice and a
member in good standing of the Supreme Court of Pennsylvania and this Court and counsel for
Defendant Philadelphia Metal Trades Council, Ron Ault and Philip Rowan, and hereby move
this Honorable Court to permit Robert Matisoff and Keith R. Bolek to appear pro hac vice on
behalf of the Defendant in this cause. We will act as local counsel for the Defendants in this
matter. The grounds for this motion are set forth in the attached Joint Declaration in Support of
Motion for Admission Pro Hac Vice.
Dated: June 20, 2002
Robert Curley (Bar No. 55760)
David D. Capuano (Bar No. 70238)
O’ DONOGHUE & O’ DONOGHUE
Constitution Place, Suite 515
325 Chestnut Street
Philadelphia, PA 19106
(215) 629-4970
Attorney for Defendant
93840_1.DOC
PDF Page 3
‘ PHILADELPHIA METAL TRADES COUNCIL, et al.,
Case 2:02-cv-03710-WY Document5 ~ Filed 06/20/2002 Page 2of7
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
KVAERNER PHILADELPHIA SHIPYARD, INC.,
Plaintiff,
Vv. No. 02-CV-3710
Defendants.
Nee Ne Ne Ne ee ee ee ee ee ee”
JOINT DECLARATION OF ROBERT MATISOFF AND
- KEITH R. BOLEK IN SUPPORT OF
MOTION FOR ADMISSION PRO HAC VICE
Co-counsel for the Defendant, in support of their admission pro hac vice, declare as
follows:
1, Robert Matisoff is a partner and Keith R. Bolek is an associate with the law firm
of O’Donoghue & O’Donoghue, 4748 Wisconsin Avenue, N.W., Washington, D.C. 20016,
telephone 202-362-0041, facsimile 202-237-1200.
2. The Defendants in this action, Philadelphia Metal Trades Council (““PMTC”), Ron
Ault and Philip Rowan, desires to have Mr. Matisoff and Mr. Bolek of the firm of O’ Donoghue
& O’Donoghue and the attorneys identified above represent them in this matter.
3. Robert Matisoff and Keith R. Bolek are members in good standing of the Bar of
the District of Columbia and the Bar of the State of Maryland. In addition, Robert Matisoff is a
member of the Bar of the Commonwealth of Virginia.
PDF Page 4
ses
Case 2:02-cv-03710-WY Document5 ~ Filed 06/20/2002 Page 3 of 7
4. Robert Matisoff has been admitted to practice before, and is presently a member
in good standing of, the bars of the United States District Court for the District of Columbia and
the United States Court of Appeal for the District of Columbia Circuit.
5. Keith R. Bolek has been admitted to practice before, and is presently a member in
good standing of, the bars of the United States District Court for the District of Columbia as well
as the United States Court of Appeals for the Third and D.C. Circuits.
6. There arc no disbarment proceedings presently pending against either Robert
Matisoff or Keith Bolek, nor have any disbarment proceedings ever been instituted against either
of them. No certificate of any privilege to appear and practice before any regulatory or
administrative body has ever been suspended or revoked for either of them.
VERIFICATION
I am the applicant in this matter. I have read the above Declaration, and the matters
stated in it are true of my own knowledge. I declare under penalty of perjury that the above is
true and correct.
Dated: June 19, 2002 By: his Af if
fl Matisoff Zi
4 vl.
*Kéith K. Bolek
Dated: June 19, 2002
O’ DONOGHUE & O’ DONOGHUE
4748 Wisconsin Avenue, N.W.
Washington, D.C. 20016
(202) 362-0041 — telephone
(202) 237-1200 — facsimile
93840_1.DOC
PDF Page 5
Case 2:02-cv-03710-WY Document5 ~ Filed 06/20/2002 Page4of7
District of Columbia Court of Appeals
Committee om Admissions
500 Indima Avenue, N.W. — Room 4200
Washingt, OB. C. 20001
202/879-2710
I, GARLAND PINKSTON, JR., Clerk of the District of Columbia
Court of Appeals, do hereby certify that
KEITH R. BOLEK
was on the 4th day of June 1999
duly qualified and admitted as an attorney and counselor and
entitled to practice before this Court and is, on the date
indicated below, an active member in good standing of this Bar.
In Testimony Whereof, I have
hereunto subscribed my name and
affixed the seal of this Court
at the City of Washington, D.C.
this 18th day of
June , 2002
GARLAND PINKSTON, JR., CLERK
wy: Hid CL.
—Deputy Clerk
PDF Page 6
Case 2:02-cv-03710-WY Document5 ~ Filed 06/20/2002 Page5of7
istrict of Columbia Court of Appeals
Comunitter on Admissions
500 Indiana Avenue, N.Y. — Room 4200
Washingt, H.C. 20001
202/879-2710
I, GARLAND PINKSTON, JR., Clerk of the District of Columbia
Court of Appeals, do hereby certify that
ROBERT MATISOFF
was on the Ist day of January ' 1974
duly qualified and admitted as an attorney and counselor and
entitled to practice before this Court and is, on the date
indicated below, an active member in good standing of this Bar.
In Testimony Whereof, I have
hereunto subscribed my name and
affixed the seal of this Court
at the City of Washington, D.C.
18th
this day of
June 200
f
GARLAND PINKSTON, JR., CLERK
Deputy Clerk
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Case 2:02-cv-03710-WY Document5 ~ Filed 06/20/2002 Page6of7
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
KVAERNER PHILADELPHIA SHIPYARD, INC.,
Plaintiff,
Vv. No. 02-CV-3710
PHILADELPHIA METAL TRADES COUNCIL, ef al.,
Defendants.
Nee ee eee eee ee ee
ORDER GRANTING MOTION
FOR ADMISSION PRO HAC VICE
The Court having considered the papers submitted in support of and in opposition to the
Motion of David D. Capuano for an Order granting permission for Robert Matisoff and Keith R.
Bolek to appear as counsel pro hac vice for Defendants Philadelphia Metal Trades Council, Ron
Ault and Philip Rowan, in association with Robert Curley and David D. Capuano, attorneys of
record in the above-entitled matter, and good cause appearing, THEREFORE,
IT IS ORDERED that the Motion for Admission Pro Hac Vice is GRANTED.
Dated:
HONORABLE WILLIAM H. YOHN, JR.
UNITED STATES DISTRICT COURT JUDGE
93840_1,.DOC
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Case 2:02-cv-03710-WY Document5 ~ Filed 06/20/2002 Page/7 of 7
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
KVAERNER PHILADELPHIA SHIPYARD, INC.,
Plaintiff,
V. No. 02-CV-3710
PHILADELPHIA METAL TRADES COUNCIL, et al.,
Defendants.
)
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Motion for Admission Pro Hac Vice, Joint
Declaration of Robert Matisoff and Keith R. Bolek in Support thereof, and proposed Order have
been served by hand, this 20" day of June, 2002, upon the following:
Kelly A. Wallenda, Esq.
BALLARD SPAHR ANDREWS & INGERSOLL, LLP
1735 Market Street, 51*' Floor
Philadelphia, PA 19103-7599
Michael N. Katz, Esq.
MERANZE & KATZ
225 S. 15" Street, 12" Floor
Philadelphia, PA 19102-3977
Robert Curley
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