Free Motion for Leave to Appear Pro Hac Vice - District Court of Delaware - Delaware


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Date: January 10, 2006
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Case 1:O6—mc-OOOO7—KAJ Document 3 Filed O1/10/2006 Page1 of 3
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
FORTUNET, INC., a Nevada corporation,
and MILLENNIUM, INC., a Nevada _
corporation, U.S. District Court for the
District of Delaware
Piai11tifi`s!Cou1iter—Defendants, Misc. Case No.
v.
U.S. District Court for the
MELANGE COMPUTER SERVICES, District of Nevada
INC., a Michigan corporation, and Case No. CV—S~04-i448 PMP (PAL)
PLANET BINGO, LLC.,
a California iimited iiabiiity company,
Defendants!Counter—Plaintiffs .
MOTION FOR ADMISSION PRO HAC VICE
NOW COMES, Mark R. Fox, and pursuant to D. Del. LR. 85.3(c), hereby moves this
Honorable Court to admit him, an out—of-state attorney, who is a member in good standing of
the Bars of Michigan, Florida, and the District of Columbia, for the limited purpose of
appearing and participating in the above—captioned miscellaneous case for the purpose of
representing Melange Computer Services, inc. in connection with a rnotion to quash a
subpoena duces tecum issued under the auspices of this Court. In support hereof, Movaut
FRASER _
TREBILCOCK States :
DAv1s&
Dumas,
$5,,, 1. I have not previously been admitted pro imc vice, or sought to be admitted pro
§:{i`£“§§§§‘i
48933 imc vice, by the United States District Court for the District of Delaware.

Case 1:O6—mc-OOOO7—KAJ Document 3 Filed O1/10/2006 Page 2 of 3
2. I am a shareholder in the law firm of Fraser Trebilcock Davis &. Dunlap, P.C.,
with ofiices located at 124 West Allegan Street, Suite 1000, Lansing, Michigan 48933, (517)
4826800, and One Woodward Avenue, Suite 1550, Detroit, Michigan 48226, (313) 237-
7300, where i have nearly twenty years of experience as a trial attorney, with an emphasis
in the area of commercial litigation. Currently, I serve as Vice—President of my law firm and
as Chair of its Litigation Department.
3. l am a member in good standing of the following bars as of the dates indicated:
• State of Michigan, May 12, 1987, Bar No. P-39902
• State of Florida, October 17, 1987, Bar No. 712612
• District of Columbia, July 9, 1990, Bar No. 423769
‘ • UCS. Supreme Court, August 28, 1992
• U.S. Court of Appeals for the Sixth Circuit, August 28, 1987
¤ U.S. Court of Appeals for the Eight Circuit, November 13, 1991
• U.S. Court of Appeals for the Eleventh Circuit, January 13, 1997
• U.S. District Court for the Eastern District of Michigan, June 8, 1987
• U.S. District Court for the Western District of Michigan, lune 1, 1987
• U.S. District Court for the Southern District of Florida, August 10, 1990
• U.S. District Court for the Middle District of Florida, December 13, 1991
• U.S. District Court for the District of Colorado, May 28, 1997
4. I have also previously been admitted pro hoc vice by U.S. District Courts in
Alabama, Connecticut, iowa, Indiana, Kentucky, Massachusetts, Minnesota, Missouri,
Nevada, New York, North Carolina, Ohio, Pennsylvania, Virginia, and West Virginia, and by
the state courts in Illinois, Maryland, Minnesota, Tennessee, Ohio, and Washington. I have
tried cases to verdict in both the state and federal courts.
Suisse
T‘§f§;§‘·_};“ 5. 1 have never been denied admission or disciplined by any court or bar association.
Dunbar,
;,§,,,, 6. I agree to submit to and comply with all provisions and requirements of the
inmsnao,
Miiiigm rules of conduct applicable to attorneys admitted to practice before the bar of this Court in
connection with my pro hoc vice representation in this case.
2

Case 1:O6—mc-OOOO7—KAJ Document 3 Filed 01/10/2006 Page 3 of 3
7. I will comply with the associate counsel requirements of D. Del. LR. 85.3(d)
and (e) by associating within thirty days with an attorney who is a member of the Bar of this
Court and who maintains an office in the District of Delaware for the regular transaction of
business.
8. E can be contacted at the following location: Fraser Trebiicock Davis & Dunlap,
P.C., 124 West Allegan Street, Suite 1000, Lansing, Michigan 48933, (517) 482-5800 ~»-
telephone, (5 l 7) 482-08 87 ——— facsimile, and n1t`ox@i*raserlavvii1in.com — email.
Res e 1 submitted,
Xanuary 9, 2006 By: ’
Mark R. F
Fraser Trebilcock; Davis & Dunlap, P.C.
1000 Michigan National Tower
124 West Allegan Street »- Suite 1000
Lansing, Michigan 48933
(517) 482-5800 — Telephone
(517) 482-0887 — Facsimile ·
rrn°ox@fraserlaw‘£inn.com
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