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  • xxxx, xxxxxx V xxxxxx, xxxx 3 document preview
  • xxxx, xxxxxx V xxxxxx, xxxx 3 document preview
  • xxxx, xxxxxx V xxxxxx, xxxx 3 document preview
  • xxxx, xxxxxx V xxxxxx, xxxx 3 document preview
  • xxxx, xxxxxx V xxxxxx, xxxx 3 document preview
  • xxxx, xxxxxx V xxxxxx, xxxx 3 document preview
  • xxxx, xxxxxx V xxxxxx, xxxx 3 document preview
  • xxxx, xxxxxx V xxxxxx, xxxx 3 document preview
						
                                

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Filing # 196769723 E-Filed 04/23/2024 10:33:53 AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA GENERAL CIVIL DIVISION xxxxxx xxxx and TRISTAN xxxx, Plaintiffs/Petitioners, Case #: 502023CA011904XXXXMB VS. xxxx xxxxxx, xxxx xxxxxxx xxxxxx, xxxxxxx xxxxxx, et al., Defendants/Respondents. / VERIFIED MOTION FOR ADMISSION TO APPEAR PRO HAC VICE PURSUANT TO FLORIDA RULE OF GENERAL PRACTICE AND JUDICIAL ADMINISTRATION 2.510 COMES NOW Benjamin W. Bull, Movant herein, and respectfully represents the following: 1 Movant resides in Scottsdale, Arizona and Movant is not a resident of the State of Florida. Movant is the General Counsel of the National Center on Sexual Exploitation, 1201 F Street NW, Suite 200, Washington, DC 20004; phone: (202) 393-7245. Movant has been retained as co-counsel on behalf of Defendants/Respondents to provide legal representation in connection with the above-styled matter now pending before the above-named court of the State of Florida. Movant is an active member in good standing in the District of Columbia Bar (Bar #388206); the United States District Court for the District of Columbia, and the Arizona State Bar (Bar #009940). A judicial officer or the entity responsible for attorney regulation has neither initiated disciplinary, suspension, disbarment or contempt proceedings or disciplined, suspended, disbarred or held Movant in contempt in the preceding 5 years. FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 04/23/2024 10:33:53 AM 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. Movant is not an inactive member of The Florida Bar. Movant is not now a member of The Florida Bar. 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 or disciplinary revocation 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 any motion(s) to appear as counsel in Florida state courts during the past 5 years. 13 Local counsel of record associated with Movant in this matter is: Danielle Bianculli Pinter, who is an active member in good standing of The Florida Bar, with Florida Bar Number 120441; and office address: National Center on Sexual Exploitation, 1201 F Street, NW, Suite 200, Washington, DC 20004. 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 Regarding The Florida Bar and certified 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 ofthe courts and the Bar of the State of Florida. WHEREFORE, Movant respectfully requests permission to appear in this court for this cause only. DATED this 12" day of April, 2024. /s/ Benjamin W. Bull Benjamin W. Bull, Movant National Center on Sexual Exploitation 1201 F Street NW, Suite 200 Washington, DC 20004 Telephone: (202) 393-7245 Email: bbull@ncose.com STATE OF ARIZONA ) ) ss. COUNTY OF MARICOPA) I, Benjamin W. Bull, 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/ Benjamin W. Bull Benjamin W. Bull, Movant 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 this 12" day of April, 2024. /s/ Danielle Bianculli Pinter Danielle Bianculli Pinter FBN 120441 National Center on Sexual Exploitation 1201 F Street NW, Suite 200 Washington, DC 20004 Telephone: (202) 393-7245 Email: dpinter@ncoselaw.org CERTIFICATE OF SERVICE I HEREBY CERTIFY that on April 12, 2024, the foregoing was electronically submitted to PHV Admissions, The Florida Bar, and upon Plaintiffs’ attorneys via e-mail at Thomas Maniotis, Equity Legal, PLLC, 5201 Blue Lagoon Dr., Flr. 8, Miami, FL 33126; amaniots@equitylegal.net, and Joseph D. McBride, The McBride Law Firm, PLLC 99 Park Avenue, 6th Flr., New York, NY 10016; jmcbride@mcbridelawnyc.com; and that the movant has paid the fees described in the Rules Regulating The Florida Bar concerning non-Florida lawyer appearances in a Florida court or has notified The Florida Bar of movant’s request for a judicial waiver of said fees. DATED this 12" day of April, 2024. /s/ Benjamin W. Bull Benjamin W. Bull, Movant