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Filing # 195789112 E-Filed 04/09/2024 12:43:17 PM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR
HILLSBOROUGH COUNTY, FLORIDA
EDWARD WILSON,
Plaintiff,
v.
BOEHRINGER INGELHEIM
PHARMACEUTICALS, INC.; Case No.: 22-CA-284
BOEHRINGER INGELHEIM
CORPORATION; BOEHRINGER
INGELHEIM USA CORPORATION;
PFIZER INC.; SANOFI-AVENTIS U.S.
LLC; SANOFI US SERVICES INC.;
GLAXOSMITHKLINE LLC;
GLAXOSMITHKLINE HOLDINGS
(AMERICAS) INC.; DOLGENCORP,
LLC; PUBLIX SUPER MARKETS, INC.,
and WALGREEN CO.
Defendants
UNOPPOSED VERIFIED MOTION FOR ADMISSION TO APPEAR
PRO HAC VICE PURSUANT TO FLORIDA RULE OF
GENERAL PRACTICE AND JUDICIAL ADMINISTRATION 2.510
COMES NOW Kimberly S. Penner, Movant herein, and respectfully represents the
following:
1. Movant is not a resident of the State of Florida and does not maintain a regular
practice of law within the State. Movant resides in Brooklyn, New York.
2. Movant is an attorney and a member of the law firm of Shook, Hardy Bacon L.L.P
with offices at 1 Rockefeller Plaza, Suite 2801, New York, NY 10020, Tel. (212) 989-8844, email:
kpenner@shb.com.
4/9/2024 12:43 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
Case No.: 22-CA-284
3. Movant has been retained as a member of the above-named law firm by
GlaxoSmithKline LLC and GlaxoSmithKline Holdings (Americas) Inc., to provide legal
representation in connection with the above-styled matter now pending before this Court.
4. Movant is an active member in good standing of the bar of New York (Bar No.
2085819) and is currently eligible to practice law in the United States District Court for the
Western District of New York, United States District Court for the Eastern District of New York,
United States District Court for the Southern District of New York, United States District Court
for the Northern District of New York, United States Court of Appeals, Tenth Circuit, and United
States Court of Appeals, District of Columbia Circuit.
5. There have been no disciplinary, suspension, disbarment, or contempt proceedings
initiated against Movant.
6. Movant, either by resignation, withdrawal, or otherwise, never has terminated or
attempted to terminate Movant’s office as an attorney in order to avoid administrative, disciplinary,
disbarment, or suspension proceedings.
7. Movant is not an inactive member of The Florida Bar.
8. Movant is not now a member of The Florida Bar.
9. Movant is not a suspended member of The Florida Bar.
10. Movant is not a disbarred member of The Florida Bar nor has Movant received a
disciplinary resignation from The Florida Bar.
11. Movant has not previously been disciplined or held in contempt by reason of
misconduct committed while engaged in representation pursuant to Florida Rule of General
Practice and Judicial Administration 2.510.
12. Movant has not filed a motion to appear as counsel in Florida state courts during the
past five (5) years.
2
4/9/2024 12:43 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
Case No.: 22-CA-284
13. Local counsel of record associated with Movant in this matter is Mark F. Raymond,
Florida Bar No. 373397, who is an active member in good standing of The Florida Bar and has
offices at Nelson Mullins, 2 S. Biscayne Boulevard, Ste. 2100, Miami, Florida 33131, telephone
(305) 373-9425.
14. Movant has read the applicable provisions of Florida Rule of General Practice and
Judicial Administration 2.510 and Rule 1-3.10 of the Rules Regulating The Florida Bar and
certifies that this verified motion complies with those rules.
15. Movant agrees to comply with the provisions of the Florida Rules of Professional
Conduct and consents to the jurisdiction of the courts and the Bar of the State of Florida.
16. Justin Parafinczuk, counsel for Plaintiff, has been contacted and has no objection to
this motion.
WHEREFORE, it is respectfully requested that the Court enter the attached order admitting
Kimberly S. Penner pro hac vice in this matter on behalf of Defendants GlaxoSmithKline LLC
and GlaxoSmithKline Holdings (Americas) Inc.
DATED: April 9, 2024
/s/ Kimberly S. Penner
Movant
Shook, Hardy & Bacon, L.L.P
1 Rockefeller Plaza
Suite 2801
New York, NY 10020
Telephone: (212) 989-8844
Facsimile: (929) 501-5455
Email: kpenner@shb.com
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4/9/2024 12:43 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
Case No.: 22-CA-284
STATE OF: NEW YORK
COUNTY OF: NEW YORK COUNTY
I, Kimberly S. Penner, do hereby swear or affirm under penalty of perjury that I am the
Movant in the above-styled matter, that I have read the foregoing Motion and know the contents
thereof, and the contents are true of my own knowledge and belief.
/s/ Kimberly S. Penner
Movant
Shook, Hardy & Bacon, L.L.P
1 Rockefeller Plaza
Suite 2801
New York, NY 10020
Telephone: (212) 989-8844
Facsimile: (929) 501-5455
Email: kpenner@shb.com
I hereby consent to be associated as local counsel of record in this cause pursuant to
Florida Rule of General Practice and Judicial Administration 2.510.
DATED: April 9, 2024
/s/ Mark F. Raymond
Mark F. Raymond
Florida Bar No.: 373397
NELSON MULLINS
2 S. Biscayne Boulevard, Suite 2100
Miami, Florida 33131
Tel: (305) 373-9425
Fax: (305) 995-6384
Email: mark.raymond@nelsonmullins.com
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4/9/2024 12:43 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served through the
Florida Courts E-Filing Portal on all counsel of record this 9th day of April, 2024.
I FURTHER HEREBY CERTIFY that a true and correct copy of the foregoing was
furnished electronically to PHV Admissions, The Florida Bar, 651 East Jefferson St., Tallahassee,
FL 32399-2333, accompanied by payment of the $250.00 filing fee made payable to The Florida
Bar on this 9th day of April, 2024.
/s/ Mark F. Raymond
GlaxoSmithKline LLC and
GlaxoSmithKline Holdings (Americas)
Inc.
4/9/2024 12:43 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 5
Appellate Division of the Supreme Court
of the State of New York
Second Judicial Department
I, Darrell M. Joseph, Clerk of the Appellate Division of the
Supreme Court of the State of New York, Second Judicial
Department, do hereby certify that
Kimberly S. Penner
was duly licensed and admitted to practice as an Attorney and
Counselor at Law in all the courts of this State on ,
has duly taken and subscribed the oath of office prescribed by law,
has been enrolled in the Roll of Attorneys and Counselors at Law
on file in this office, is duly registered with the Office of Court
Administration, and according to the records of this Court is
currently in good standing as an Attorney and Counselor-at
at-Law.
In Witness Whereof, I have hereunto set
my hand in the City of Brooklyn on
April 5, 2024.
Clerk of the Court
CertID-00168676
4/9/2024 12:43 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 6
Appellate Division
Supreme Court of the State of New York
Second Judicial Department
45 Monroe Place
Brooklyn, N.Y. 11201
(718) 875-1300
HECTOR D. LASALLE KENNETH BAND
PRESIDING JUSTICE DEPUTY CLERKS
MELISSA KRAKOWSKI
DARRELL M. JOSEPH
CLERK OF THE COURT WENDY STYNES
LAUREN G. DOME
BRIAN E. KENNEDY
January 7, 2005
ASSOCIATE DEPUTY CLERKS
To Whom It May Concern
An attorney admitted to practice by this Court may request a certificate of
good standing, which is the only official document this Court issues certifying to an
attorney's admission and good standing.
An attorney's registration status, date of admission and disciplinary history
may be viewed through the attorney search feature on the website of the Unified
Court System.
New York State does not register attorneys as active or inactive.
An attorney may request a disciplinary history letter from the Attorney
Grievance Committee of the Second Judicial Department.
Bar examination history is available from the New York State Board of Law
Examiners.
Instructions, forms and links are available on this Court's website.
Darrell M. Joseph
Clerk of the Court
Revised March 2024
4/9/2024 12:43 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 7
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Filing # 195789112 E-Filed 04/09/2024 12:43:17 PM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA EDWARD WILSON, Plaintiff, v. BOEHRINGER INGELHEIM PHARMACEUTICALS, INC.; Case No.: 22-CA-284 BOEHRINGER INGELHEIM CORPORATION; BOEHRINGER INGELHEIM USA CORPORATION; PFIZER INC.; SANOFI-AVENTIS U.S. LLC; SANOFI US SERVICES INC.; GLAXOSMITHKLINE LLC; GLAXOSMITHKLINE HOLDINGS (AMERICAS) INC.; DOLGENCORP, LLC; PUBLIX SUPER MARKETS, INC., and WALGREEN CO. Defendants UNOPPOSED VERIFIED MOTION FOR ADMISSION TO APPEAR PRO HAC VICE PURSUANT TO FLORIDA RULE OF GENERAL PRACTICE AND JUDICIAL ADMINISTRATION 2.510 COMES NOW Kimberly S. Penner, Movant herein, and respectfully represents the following: 1. Movant is not a resident of the State of Florida and does not maintain a regular practice of law within the State. Movant resides in Brooklyn, New York. 2. Movant is an attorney and a member of the law firm of Shook, Hardy Bacon L.L.P with offices at 1 Rockefeller Plaza, Suite 2801, New York, NY 10020, Tel. (212) 989-8844, email: kpenner@shb.com. 4/9/2024 12:43 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 Case No.: 22-CA-284 3. Movant has been retained as a member of the above-named law firm by GlaxoSmithKline LLC and GlaxoSmithKline Holdings (Americas) Inc., to provide legal representation in connection with the above-styled matter now pending before this Court. 4. Movant is an active member in good standing of the bar of New York (Bar No. 2085819) and is currently eligible to practice law in the United States District Court for the Western District of New York, United States District Court for the Eastern District of New York, United States District Court for the Southern District of New York, United States District Court for the Northern District of New York, United States Court of Appeals, Tenth Circuit, and United States Court of Appeals, District of Columbia Circuit. 5. There have been no disciplinary, suspension, disbarment, or contempt proceedings initiated against Movant. 6. Movant, either by resignation, withdrawal, or otherwise, never has terminated or attempted to terminate Movant’s office as an attorney in order to avoid administrative, disciplinary, disbarment, or suspension proceedings. 7. Movant is not an inactive member of The Florida Bar. 8. Movant is not now a member of The Florida Bar. 9. Movant is not a suspended member of The Florida Bar. 10. Movant is not a disbarred member of The Florida Bar nor has Movant received a disciplinary resignation from The Florida Bar. 11. Movant has not previously been disciplined or held in contempt by reason of misconduct committed while engaged in representation pursuant to Florida Rule of General Practice and Judicial Administration 2.510. 12. Movant has not filed a motion to appear as counsel in Florida state courts during the past five (5) years. 2 4/9/2024 12:43 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 Case No.: 22-CA-284 13. Local counsel of record associated with Movant in this matter is Mark F. Raymond, Florida Bar No. 373397, who is an active member in good standing of The Florida Bar and has offices at Nelson Mullins, 2 S. Biscayne Boulevard, Ste. 2100, Miami, Florida 33131, telephone (305) 373-9425. 14. Movant has read the applicable provisions of Florida Rule of General Practice and Judicial Administration 2.510 and Rule 1-3.10 of the Rules Regulating The Florida Bar and certifies that this verified motion complies with those rules. 15. Movant agrees to comply with the provisions of the Florida Rules of Professional Conduct and consents to the jurisdiction of the courts and the Bar of the State of Florida. 16. Justin Parafinczuk, counsel for Plaintiff, has been contacted and has no objection to this motion. WHEREFORE, it is respectfully requested that the Court enter the attached order admitting Kimberly S. Penner pro hac vice in this matter on behalf of Defendants GlaxoSmithKline LLC and GlaxoSmithKline Holdings (Americas) Inc. DATED: April 9, 2024 /s/ Kimberly S. Penner Movant Shook, Hardy & Bacon, L.L.P 1 Rockefeller Plaza Suite 2801 New York, NY 10020 Telephone: (212) 989-8844 Facsimile: (929) 501-5455 Email: kpenner@shb.com 3 4/9/2024 12:43 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3 Case No.: 22-CA-284 STATE OF: NEW YORK COUNTY OF: NEW YORK COUNTY I, Kimberly S. Penner, do hereby swear or affirm under penalty of perjury that I am the Movant in the above-styled matter, that I have read the foregoing Motion and know the contents thereof, and the contents are true of my own knowledge and belief. /s/ Kimberly S. Penner Movant Shook, Hardy & Bacon, L.L.P 1 Rockefeller Plaza Suite 2801 New York, NY 10020 Telephone: (212) 989-8844 Facsimile: (929) 501-5455 Email: kpenner@shb.com I hereby consent to be associated as local counsel of record in this cause pursuant to Florida Rule of General Practice and Judicial Administration 2.510. DATED: April 9, 2024 /s/ Mark F. Raymond Mark F. Raymond Florida Bar No.: 373397 NELSON MULLINS 2 S. Biscayne Boulevard, Suite 2100 Miami, Florida 33131 Tel: (305) 373-9425 Fax: (305) 995-6384 Email: mark.raymond@nelsonmullins.com 4 4/9/2024 12:43 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served through the Florida Courts E-Filing Portal on all counsel of record this 9th day of April, 2024. I FURTHER HEREBY CERTIFY that a true and correct copy of the foregoing was furnished electronically to PHV Admissions, The Florida Bar, 651 East Jefferson St., Tallahassee, FL 32399-2333, accompanied by payment of the $250.00 filing fee made payable to The Florida Bar on this 9th day of April, 2024. /s/ Mark F. Raymond GlaxoSmithKline LLC and GlaxoSmithKline Holdings (Americas) Inc. 4/9/2024 12:43 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 5 Appellate Division of the Supreme Court of the State of New York Second Judicial Department I, Darrell M. Joseph, Clerk of the Appellate Division of the Supreme Court of the State of New York, Second Judicial Department, do hereby certify that Kimberly S. Penner was duly licensed and admitted to practice as an Attorney and Counselor at Law in all the courts of this State on , has duly taken and subscribed the oath of office prescribed by law, has been enrolled in the Roll of Attorneys and Counselors at Law on file in this office, is duly registered with the Office of Court Administration, and according to the records of this Court is currently in good standing as an Attorney and Counselor-at at-Law. In Witness Whereof, I have hereunto set my hand in the City of Brooklyn on April 5, 2024. Clerk of the Court CertID-00168676 4/9/2024 12:43 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 6 Appellate Division Supreme Court of the State of New York Second Judicial Department 45 Monroe Place Brooklyn, N.Y. 11201 (718) 875-1300 HECTOR D. LASALLE KENNETH BAND PRESIDING JUSTICE DEPUTY CLERKS MELISSA KRAKOWSKI DARRELL M. JOSEPH CLERK OF THE COURT WENDY STYNES LAUREN G. DOME BRIAN E. KENNEDY January 7, 2005 ASSOCIATE DEPUTY CLERKS To Whom It May Concern An attorney admitted to practice by this Court may request a certificate of good standing, which is the only official document this Court issues certifying to an attorney's admission and good standing. An attorney's registration status, date of admission and disciplinary history may be viewed through the attorney search feature on the website of the Unified Court System. New York State does not register attorneys as active or inactive. An attorney may request a disciplinary history letter from the Attorney Grievance Committee of the Second Judicial Department. Bar examination history is available from the New York State Board of Law Examiners. Instructions, forms and links are available on this Court's website. Darrell M. Joseph Clerk of the Court Revised March 2024 4/9/2024 12:43 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 7