Free Motion for Leave to Appear - District Court of Connecticut - Connecticut

{I _ _ Case 3:03-cv—OO940—RNC Document 27 Filed O4/30/2004 Page 1 of 2 d (9/9/
I P
I UNITED STATES DISTRICT COURT
> FOR THE DISTRICT OF CONNECTICUT
MARIA DEGENNARO : FH IF
I I Plaintiff; : i"'” M Q
I ZHUIII APH 30 D [ .
I I Z g;;;[._..I___!_ UL!
IINLC6 C.A. NO. 3:03—CV—940 (RNC) Ja fm,
I If7k/a EXPANETS OF NORTH AMERICA, I J I°
5 LLC and AVAYA LLC, :
I Defendants. : ‘
I MOTION FOR ADMISSION PRO HAC VICE
Pursuant to Local Rule 83.1(d), the undersigned hereby moves the Court to admit Daniel A.
I Rizzi, Esq. jg hey ge for the purpose of representing Defendant AVAYA LLC ("Def`endant") in addition to
counsel of record in the instant lawsuit. In support of this Motion, the tmdersigned represents that:
I 1. The undersigned, Stacie Boeniger Collier, is an attorney with the firm of Nixon Peabody
. ILLP, City Place, 185 Asylum Street, Hartford, Connecticut, 06105. Stacie Boeniger Collier has been a member
I good standing of the Bars of the United States District Court for the District of Connecticut and of the State
I of Connecticut since 1998 and 1997, respectively. I
I 2. Daniel A. Rizzi is a partner with the firm of Nixon Peabody LLP, 990 Stewart Avenue, I
Garden City, New York 11590; 516-832-7594; [email protected]. Mr. Rizzi joined the firm in July I
1995, and has been a member in good standing of the Bar ofthe State of` New York since June 1982. I
3. Mr. Rizzi is also admitted to practice in the United States District Courts for Southern
and Eastern Districts of New York.
4. Mr. Rizzi has expertise in the field of management labor and employment law, and I
regularly represents Avaya Inc. in connection with such matters. This case involves claims of employment g
discrimination and retaliation, as well as Avaya LLC purported liability as a "successor" to the other named
defendants. Mr. Rizzi’s admission to the bar in connection with this action would be of significant benefit to
Defendant Avaya LLC.
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" “ ·• Case 3:03-cv—OO940—FlNC Document 27 Filed O4/30/2004 Page 2 of 2
[ 5. The undersigned believes Mr. Rizzi to be of good character and knows of no reason why
1
I ithis Court should not grant this Motion.
p A 6. Mr. Rizzi has not been denied admission or disciplined in accordance with Rule 83.2 of
x The Local Rules nor has Mr. Rizzi been denied admission or disciplined by any other Court.
[ WHEREFORE, based upon the representations stated above, and the attached aftidavit, the
. imdersigned requests that Daniel A. Rizzi be admitted Ig by jg before this Court as co-counsel for
i befendant Avaya LLC.
i S DEFENDANT AVAYA LLC,
I N
BY:
T Stacie Boeniger Co ier( t 1 95)
, Nixon Peabody LLP
City Place — 185 Asylum Street
. Hartford, CT 06105
l (860) 275-6820 -
e 1 (860) 275-6821 (fax)
[email protected]
CERTIFICATE OF SERVICE
I hereby certify that on thi ay of April 2004, I sent a true copy of this Motion For Admission Pro
ac Vice, via first-class mail, postage prepaid, to James E. Miller, Esq., Shepherd Finkleman Miller & Shah, I
LC, Attorneys for Plaintiff; and to Christopher L. Brigham, Esq., Updike, Kelly & Spellacy, P.C., Attorneys
for Defendants NETEXIT, INC. Uk/a EXPANETS, INC. and NETEXIT OF NORTH AMERICA, LLC f/k/a
EXPANETS OF NORTH AMERICA. ’
. ‘ i i
i Stacie Boeniger Collier, Esq. l
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