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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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`MOTION FOR ADMISSION PRO HAC VICE
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`Pursuant to Local Rule 83.5.3, Ruben J. Rodrigues, attorney for Plaintiff Philips North
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`America LLC, (“Philips”), hereby moves this Court for an order granting leave for Michelle A.
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`Moran to appear and practice in this Court for the purpose of representing Philips in this action.
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`In support of this Motion, Plaintiff states as follows:
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`1.
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`Philips is represented in this action by Ruben J. Rodrigues, Lucas I. Silva and
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`John W. Custer of the law firm Foley & Lardner LLP, who are members of good standing of the
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`Bar of this Court.
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`2.
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`The appearance and active participation of Michelle A. Moran on behalf of
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`Philips will facilitate the representation of Philips in this Court.
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`3.
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`Michelle A. Moran is also an attorney with Foley & Lardner LLP, who practices
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`out of the firm’s office located at 777 E. Wisconsin Avenue, Milwaukee, Wisconsin 53202.
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`4.
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`Michelle A. Moran is a member of good standing of the Bar of the State of
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`Wisconsin (Bar No. 1073953) and is a member in good standing of the Bar in every jurisdiction
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`Case 1:19-cv-11586-IT Document 89 Filed 08/18/20 Page 2 of 4
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`in which she has been admitted to practice. There are no disciplinary proceedings pending
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`against Michelle A. Moran as a member of the Bar in any jurisdiction.
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`5.
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`Michelle A. Moran is familiar with, and will follow, the Court’s rules, procedures,
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`timetables, and all Massachusetts laws.
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`Dated: August 17, 2020
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`Respectfully Submitted,
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` /s/ Ruben J. Rodrigues
`Lucas I. Silva (BBO 673,935)
`Ruben J. Rodrigues (BBO 676,573)
`John W. Custer (BBO 705,258)
`FOLEY & LARDNER LLP
`111 Huntington Avenue
`Suite 2500
`Boston, MA 02199-7610
`Phone: (617) 342-4000
`Fax: (617) 342-4001
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`lsilva@foley.com
`rrodrigues@foley.com
`jcuster@foley.com
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`2
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`Case 1:19-cv-11586-IT Document 89 Filed 08/18/20 Page 3 of 4
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`Eley O. Thompson (pro hac vice to be filed)
`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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`Case 1:19-cv-11586-IT Document 89 Filed 08/18/20 Page 4 of 4
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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 August 17, 2020 on counsel for Defendant via electronic mail.
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`/s/ Ruben J. Rodrigues
`Ruben J. Rodrigues
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`4
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