Free Motion to Substitute Attorney (Consented) - District Court of Federal Claims - federal

Case 1:05-cv-01020-MMS

Document 11

Filed 12/20/2005

Page 1 of 6

IN THE UNITED STATES COURT OF FEDERAL CLAIMS AMERICAN INTERNATIONAL SPECIALTY LINES INSURANCE COMPANY, Plaintiff, v. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-1020C Judge Robert H. Hodges, Jr.

PLAINTIFF'S UNOPPOSED MOTION FOR LEAVE TO SUBSTITUTE COUNSEL Plaintiff American International Specialty Lines Insurance Company ("AISLIC"), by counsel, pursuant to Rule 83.1(c)(4) of the Rules of the United States Court of Federal Claims ("RCFC"), hereby moves for leave to substitute T. Michael Guiffré as attorney of record for Plaintiff in the above-referenced matter. A declaration of appointment supporting Plaintiff's motion is attached hereto as Exhibit A. Peter A. Lynch, Esq., and Peter J. Fontaine, Esq., Plaintiff's previous counsel, consent to substitution and have authorized us to represent such fact to the Court on their behalf. Service of all papers by opposing parties should be addressed as follows: T. Michael Guiffré Patton Boggs LLP 2550 M Street, NW Washington, DC 20037 For the foregoing reasons, Plaintiff respectfully requests that the Court grant this unopposed motion to substitute counsel.

Case 1:05-cv-01020-MMS

Document 11

Filed 12/20/2005

Page 2 of 6

Respectfully submitted, s/T. Michael Guiffré T. Michael Guiffré Benjamin G. Chew (pending admission pro hac vice) J. Gordon Arbuckle Daniel R. Addison (pending admission pro hac vice) PATTON BOGGS LLP 2550 M Street, N.W. Washington, D.C. 20037 Telephone: (202) 457-6000 Facsimile: (202) 457-6315 Attorneys for Plaintiff American International Specialty Lines Insurance Company December 20, 2005

-2-

Case 1:05-cv-01020-MMS

Document 11

Filed 12/20/2005

Page 3 of 6

EXHIBIT A

Case 1:05-cv-01020-MMS

Document 11

Filed 12/20/2005

Page 4 of 6

IN THE UNITED STATES COURT OF FEDERAL CLAIMS AMERICAN INTERNATIONAL SPECIALTY LINES INSURANCE COMPANY, Plaintiff, v. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-1020C Judge Robert H. Hodges, Jr.

DECLARATION OF APPOINTMENT I, T. Michael Guiffré, for my declaration pursuant to 28 U.S.C. § 1746, hereby depose and state as follows: 1. My name is T. Michael Guiffré, and I have personal knowledge of the matters attested to herein. 2. I am an attorney at the law firm of Patton Boggs LLP, 2550 M Street, NW, Washington, DC 20037. 3. Plaintiff American International Specialty Lines Insurance Company ("AISLIC") has retained me as attorney of record and the firm Patton Boggs LLP to serve as its substitute counsel in the above-referenced matter. 4. AISLIC has authorized me to file on its behalf a motion for leave to substitute counsel. I declare under penalty of perjury that the foregoing is true and correct. Executed on December 20, 2005. s/T. Michael Guiffré T. Michael Guiffré

3910798v1

Case 1:05-cv-01020-MMS

Document 11

Filed 12/20/2005

Page 5 of 6

IN THE UNITED STATES COURT OF FEDERAL CLAIMS AMERICAN INTERNATIONAL SPECIALTY LINES INSURANCE COMPANY, Plaintiff, v. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-1020C Judge Robert H. Hodges, Jr.

[PROPOSED] ORDER This matter having come before the Court on Plaintiff's Unopposed Motion for Leave to Substitute Counsel, this court finds just cause to GRANT same and rule as follows. Wherefore, it is hereby: ORDERED, that the attorney of record in this matter is T. Michael Guiffré. Attorneys assisting the attorney of record are designated "of counsel." So Ordered this _____ day of ____________, 20__.

Judge, U.S. Court of Federal Claims

Case 1:05-cv-01020-MMS

Document 11

Filed 12/20/2005

Page 6 of 6

CERTIFICATE OF FILING I certify that on December 20, 2005, the foregoing motion was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. s/T. Michael Guiffré T. Michael Guiffré

3910797v1