Free Motion for Miscellaneous Relief - District Court of Delaware - Delaware

Case 1:06-cv-00068-JJF

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Filed 07/26/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ALVIA LACY, Plaintiff, v. NATIONAL RAILROAD PASSENGER CORPORATION ("AMTRAK"), Defendant. * * * * * * * * * * * * * * * * Civil Action No.: 1:06-cv-00068-JJF

MOTION TO PERMIT OUT-OF-STATE COUNSEL TO FILE ELECTRONICALLY Defendant, National Railroad Passenger Corporation ("Amtrak"), by counsel, moves for the Court to permit its Maryland-based counsel to file documents in the abovereferenced case through its electronic case filing (ECF) system. The pertinent circumstances concerning this request are as follows: 1. Amtrak has engaged the services of Darrell R. VanDeusen, Clifton R.

Gray and the law firm of Kollman & Saucier, P.A., located in Baltimore, Maryland, to represent it in the matter concerning pro se Plaintiff Alvia Lacy. Messrs. VanDeusen and Gray have applied to this Court to be admitted pro hac vice to the Bar of this Court in order to represent Amtrak in this matter, and have read and will act in accordance with the Local Rules of this Court. 2. Virginia A. Zrake, a member of the Delaware Bar and admitted to practice

in the United States District Court for the District of Delaware, has been retained to serve as local counsel for Amtrak in this matter and, as such, will act in accordance with the Local Rules of this Court, particularly that concerning local counsel in Local Rule 83.5.

Case 1:06-cv-00068-JJF

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3.

Although Virginia A. Zrake is admitted to practice before the United

States District Court for the District of Delaware, her practice before it has been infrequent and she has not as of the date of this motion been registered to use the ECF system of the Court. 4. Amtrak's Maryland-based counsel is both registered and has experience

using the federal ECF system in a number of federal district courts, and seeks, with the association of Virginia Zrake as local counsel, to file documents involved in the matter concerning pro se Plaintiff Alvia Lacy through that system. WHEREFORE, Amtrak asks that the Court GRANT its motion to permit its outof-state counsel, with the association of its local counsel, to file electronically on the ECF system. Respectfully submitted, -sVirginia A. Zrake, DE Bar No. 4054 Law Office of Virginia A. Zrake, LLC 34382 Carpenters Way P.O. Box 247 Lewes, DE 19958 (302) 644-6770 [email protected] -sDarrell R. VanDeusen, #08231 MD Clifton R. Gray, #27895 MD Kollman & Saucier, P.A. Sun Life Building, 8th Floor 20 South Charles Street Baltimore, MD 21201 (410) 727-4300 [email protected] Counsel for National Railroad -2-

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Passenger Corporation

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CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 25th day of July, 2006 a copy of Amtrak's Motion to Permit Out-of-State Counsel to File Electronically, was mailed first class, postage prepaid to Ms. Alvia Lacy, 1306 Jervis Square, Belcamp, Maryland 21017, Plaintiff pro se.

-sVirginia A. Zrake

-4-

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Filed 07/26/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ALVIA LACY, Plaintiff, v. NATIONAL RAILROAD PASSENGER CORPORATION ("AMTRAK"), Defendant. * * * * * * * * * * * * * * * * Civil Action No.: 1:06-cv-00068-JJF

ORDER Upon consideration of Amtrak's Motion to Permit Out-Of-State Counsel to File Electronically, it is this Amtrak's Motion is GRANTED. day of , 2006, hereby ORDERED that

____________________________________ Joseph J. Farnan, Jr. United States District Court Judge