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`Case 1:19-cv-11586-IT Document 124-1 Filed 11/17/20 Page 1 of 3
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`UNITED STATES DISTRICT COURT
`DISTRICT OF MASSACHUSETTS
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`Plaintiff,
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`v.
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`PHILIPS NORTH AMERICA LLC,
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`FITBIT, INC.
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`Defendant.
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`C.A. No. 1:19-cv-11586-IT
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`JURY TRIAL DEMANDED
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`AFFIDAVIT OF RUBEN J. RODRIGUES IN SUPPORT OF
`MOTION FOR ADMISSION OF COUNSEL PRO HAC VICE
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`I, Ruben J. Rodrigues, do hereby depose and state under oath as follows:
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`1.
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`I am a resident of the State of Massachusetts and am a member in good standing
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`of the Bar of this Court.
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`2.
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`I am a member of the law firm Foley & Lardner LLP, at 111 Huntington Avenue,
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`Boston, Massachusetts 02199.
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`3.
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`I represent Philips North America LLC, (“Philips”) in connection with the above-
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`captioned litigation.
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`4.
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`The appearance and active participation of Andrew M. Gross on behalf of Philips
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`will facilitate the representation of Philips in this Court.
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`5.
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`Andrew M. Gross is also an associate with Foley & Lardner LLP, who practices
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`out of the firm’s office located at 321 N. Clark Street, Suite 3000, Chicago, Illinois 60654.
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`Andrew M. Gross is a member of good standing of the Bar of the State of Illinois (Bar No.
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`6299917) and there are no disciplinary proceedings pending against Andrew M. Gross as a
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`member of the Bar in any jurisdiction. Andrew M. Gross is familiar with the Local Rules of the
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`4826-7396-3986.1
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`Case 1:19-cv-11586-IT Document 124-1 Filed 11/17/20 Page 2 of 3
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`United States District Court of Massachusetts.
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`WHEREFORE, the undersigned respectfully requests that this Court enter an Order
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`admitting Andrew M. Gross, pro hac vice, as counsel of record for the Plaintiff Philips for all
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`purposes relating to the proceedings in the above-styled matter.
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`Respectfully submitted,
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`/s/ Ruben J. Rodrigues
`Lucas I. Silva (BBO# 673935)
`Ruben J. Rodrigues (BBO 676,573)
`John W. Custer (BBO 705,258)
`FOLEY & LARDNER LLP
`111 Huntington Avenue, Suite 2600
`Boston, Massachusetts 02199
`T: 617.342.4000
`F: 617.342.4001
`lsilva@foley.com
`rrodrigues@foley.com
`jcuster@foley.com
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`Eley O. Thompson (pro hac vice)
`FOLEY & LARDNER LLP
`321 N. Clark Street
`Suite 2800
`Chicago, IL 60654-5313
`Phone: (312) 832-4359
`Fax: (312) 832-4700
`ethompson@foley.com
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`Counsel for Plaintiff
`Philips North America LLC
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`Dated: November 17, 2020
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`4826-7396-3986.1
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`Case 1:19-cv-11586-IT Document 124-1 Filed 11/17/20 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the above document was
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`served on November 17, 2020 on counsel for Defendant via electronic mail.
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`/s/ Ruben J. Rodrigues
`Ruben J. Rodrigues
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`4826-7396-3986.1
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