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

Case 1:08-mc-00008-UNA Document2 Filed O1/23/2008 Page1 of3
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IN THE UNITED ST°ATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
IN RE: SUBPOENA SERVED ON MISC. CASE NUMBER
PHARMIDUR, INC.
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misc me at G Li
Medical Card System, Inc., MCS Life ° W _ _ I I
Insurance, Inc., and L?
MCS Advantage, Inc.
Petitioners
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MO'I'ION FOR ADMISSION PRO HAC VICE ji
TO THE HONORABLE COURT:
Pursuant to Rule 83.5 of the Local Rules of the United States District
Court for the District of Delaware (the "Local Rules”), request is hereby made that
Carmen Edith Torres be permitted to appear and participate in this action as
counsel for the named petitioners, Medical Card System, Inc., MCS Life
Insurance, Inc., and MCS Advantage, Inc. ln support of this application the
undersigned counsel states as follows:
1. That Carmen Edith Torres is a member in good standing ofthe U.S.
District Court for the District of Puerto Rico (admitted on January 28, 2005,
Bar No. 222313); U.S. Court of Appeals for the First Circuit (admitted on
March 9, 2006, Bar No. 111116); and the Puerto Rico Supreme Court
(admitted on January 30, 2002, Bar No. 15,339).
2. The proposed admittee is not a member of the Delaware bar and does not
maintain any law office in Delaware.

Case 1:08-mc-00008-UNA Document 2 Filed 01/23/2008 Page 2 of 3
3. That Ms. Torres is a partner in the LAW OFFICES OF PEDRO ORTIZ "
ALVAREZ, PSC, "with offices located at G-8 O’NeiIl Street, San Juan, .
Puerto Rico 00931.
4. This is the first time the proposed admitte has requested admission in a
Pro l—lac Vice basis before this Court, and the sole purpose of this request
is to file a petition to quash or modify a subpoena duces tecum ancillary in
a case pending before the U.S. District Court for the District of Puerto
Rico.
5. The proposed admittee has never been disbarred, suspended, or denied
l admission to practice law in any jurisdiction, and does not have any
complaints for unethical misconduct, disciplinary proceedings or criminal
charges that are currently pending before any court of jurisdiction.
6. The proposed admittee is familiar with the `Code of Professional
Responsibility, the Federal Rules of Civil and Criminal Procedure, the
Federal Rules of Evidence, the Federal Rules of Appellate Procedure and
the Local Rules of this Court, and understands she shall be subject to the
disciplinary jurisdiction of this Court.
7. The proposed admittee understands admission pro hac vice is for this
case only and does not constitute formal admission to the bar of this
Coun.
8. That currently the undersigned is seeking the assistance of a counsel
admitted to practice before this Court that could act as designee on behalf
of the applicant. Hence, is requested that pursuant to Local Rule 83.5 (d),

Case 1:08-mc-00008-UNA Document 2 Filed O1/23/2008 Page 3 of 3
a 30-day period from the time of the filing ofthe instant motion, be granted
to obtain a local counsel. .
WHEREFORE, the undersigned attorney, Carmen Edith Torres, Esq.,
respectfully requests this Honorable Court to allow her admission pro hac vice to
appear in these proceedings pursuant to the Local Rules.
RESPECTFULLY SUBMITTED.
ln San Juan, Puerto Rico on this 215* day of January, 2008.
LAW OFFICES OF PEDRO ORTIZ ALVAREZ, PSC
P.O. Box 9009
Ponce, Puerto Rico 00732
Tel (787) 841~7575
Fax (787) 841-0000

CARM N EDITH TORRE R RIGUEZ
USDC—PR Number 222313 _
e~mai1: cto1·[email protected]

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