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1 RECEIVED IN THE SUPREME COURT STATE OF ARIZONA APR 1 9 Z007 CLERK SUPREME COURI RICHARD GRAND and MARCIA GRAND, co-trustees of the R. M. Grand Revocable Living Trust, dated January 25, 1991, Plaintiffs -Respondents, JOSEPH P. NACCHIO, a New Jersey resident; JOHN A. McMASTER, a New Jersey resident; QWEST COMMUNICATIONS INTERNATIONAL INC., a Delaware corporation; and QWEST B.V., a foreign organization, Defendants-Petitioners. No. CV PR Court of Appeals No. 2 CA-CV Pima County Superior Court No. C MOTION AND CONSENT OF LOCAL COUNSEL FOR PRO HAC VICE ADMISSION OF ROBIN S. CONRAD Thomas L. Hudson, pursuant to Rule 33 and 38 of the Supreme Court, moves the court to admit Robin S. Conrad of National Chamber Litigation Center as counsel pro hac vice in this action. Pursuant to Rule 38(a Rules of the Supreme Court, the following exhibits are attached hereto: the original Verified Application; o the original Certificate of Good Standing; and Post-it elabel
2 3. the State Bar of Arizona Notice of Receipt of Complete Application. The filing fee as required by Rule 38(a has been submitted to the State Bar of Arizona. Thomas L. Hudson of Osbom Maledon, P.A. hereby agrees to serve as designated local counsel for the subject case. A proposed order admitting Robin S. Conrad accompanies this motion. RESPECTFULLY SUBMITTED this 19th day of April, OSBORN MALEDON, P.A. q~omas L.t/Hhdsbn Maureen Beyers Sara S. Greene 2929 North Central Avenue, Suite 2100 Phoenix, Arizona Attorneys for Chamber of Commerce of the United States of America 2
3 Original and seven copies filed this 19th day of April, 2007 with: Noel K. Dessaint, Clerk Arizona Supreme Court 1501 West Washington Phoenix, Arizona Copy of the foregoing mailed this 19th day of April, 2007 to: Tom Galbraith Meyer, Hendricks & Bivens, P.A North Central Avenue, Suite 1200 Phoenix, Arizona Attorneys for Plaintiffs-Respondents Michael J. Meehan Munger Chadwick 33 North Wilmot, Suite 300 Tucson, Arizona Attorneys for Plaintiffs-Respondents Timothy Berg A. Bates Butler, III James D. Burgess One South Church Avenue, Suite 1000 Tucson, Arizona Attorneys for Defendant-Petitioner Qwest Communications International Inc. James P. Denvir Jonathan Sherman 5301 Wisconsin Avenue, N.W., Suite 800 Washington, DC Attorneys for Defendant-Petitioner Qwest Communications International Inc. 3
4 John N. Iurino Lewis and Roca LLP One South Church Avenue, Suite 700 Tucson,. Arizona Attorney for Defendant-Petitioner John A. McMaster Joseph E. Mais Brian C. Lake Perkins Coie Brown & Bain P.A North Central Avenue P. O. Box 400 Phoenix, Arizona Attorneys for Defendant-Petitioner Joseph P. Nacchio 4
5 1
6 For OfficiaLLL~e 0[flv~.. I I or ARIZONA NONRESIDENT ATTORNEY PRO HAC VICE APPLICATION Name: Robin S. Conrad Residence Address: 150 Haviland Mill Road, Brookville, MD Office Address: National Chamber Litigation Center, 1615 H Street, NW, Washington, DC Telephone: ( Fax: ( Title of cause or case where applicant seeks to appear: Richard and Marcia Grand v. Nacchio, et al. Docket Number: CV PR Court, Board, or Administrative Agency: Arizona Supreme Court Party on whose behalf applicant seeks to appear: Amicus for the Chamber of Commerce of the USA Courts to Which Applicant Has Been Admitted: District of Columbia Court of Appeals Supreme Court of the United States US Court of Appeals for the D.C. Circuit US Court of Appeals for the First Cimuit US Court of Appeals for the Third Circuit Please see Attachment 1A for continuation Applicant is a member in good standing in such courts. Applicant is not currently disbarred or suspended in any court. Date of Admission: 12/19/80 1/16/84 3/26/84 1/11/06 2/11/86 Bar Number: Applicant [--[ is ~] is not (select one currently subject to any pending disciplinary proceeding or investigation by any court, agency or organization authorized to discipline attorneys at law. Jurisdiction(s Where Nature of Matter Name / Address of Discipline Matter Pending: Under Investigation: Disciplinary Authority: Applicant F-I has [] has not (select one been disciplined by any court, agency or organization authorized to discipline attorneys at law. In the preceding three (3 years, applicant has filed applications to appear as counsel under Rule 33, Arizona Rules of Supreme Court in the following: Title of Matter: Docket #: Court or Agency: Application Granted? (Y/N N/A N/A N/A N/A
7 Name of local counsel: Thomas L. Hudson, Osborn Maledon, PA State Bar of Arizona Number: Address: 2929 North Central Avenue, Suite 2100, Phoenix, Arizona Telephone: ( Fax: ( Name(s of each party in this cause and name and address of all counsel of record: Party: Counsel of Record: Address: Please see Attachment 1B Applicant is including with this application a nonrefundable application fee, payable to the State Bar of Arizona, in the amount of $ This case or causel- l is ~] is not (select one a related or consolidated matter for which applicant has previously applied to appear pro hac vice in Arizona. If this matter is a related or consolidated with any previous application, applicant certifies the following: Applicant certifies the following:. ".. 1. Applicant shall be subject to the jurisdiction of the courts and agencies of the State of Arizona and to the State Bar of Arizona with respect to the law 0fthis state governing the conduct of attorneys to the same extent as an active member of the State Bar of Arizona, as provided in Rule 46(b Rules of the Supreme Court. 2. Applicant will review and comply with appropriate rules of procedure as required in the underlying cause. 3. Applicant understands and shall comply with the standards of conduct required of members of the State Bar of Arizona. Verification I, the Applicant, swear that all statements in the application are true, correct and complete to the best of my knowledge and belief. Dated: ~-o? -c9 ~ Applicant s signature ~ ~ b~ %. ~ ~ ~I~13~C~PdBED~.AND SWORN TO before me this Name of Applicant day of ~r-;i,20 ~_~, by Notary Public Nolaey, Publie, District of Columbia My CommissiOn Expires May 31,
8 NOTE - As the application requires original signatures of the applicant and notary, this application cannot be filed electronically. Please submit all documents and fees by mail to: State Bar of Arizona Pro Hac Vice 4201 N. 24th Street, Suite 200 Phoenix, AZ For further information, please contact our Membership Records Department at
9 ATTACHMENT 1 NONRESIDENT ATTORNEY PRO HAC VICE APPLICATION For Robin S. Conrad Richardand Marcia Grand v. Nacchio, et al. Docket No. CV PR A. Courts to Which Applicant Has Been Admitted - Continuation Court US Court of Appeals for the Fourth Circuit US Court of Appeals for the Fifth Circuit US Court of Appeals for the Seventh Circuit US Court of Appeals for the Eighth Circuit US Court of Appeals for the Ninth. Circuit US Court of Appeals for the Tenth Circuit US Court of Appeals for the Eleventh Circuit US Court of Appeals for the Federal Circuit US District Court for the District of Columbia Date of Admission 2/3/86 1/14/86 1/24/86 1/21/86 10/17/86 1/21/86 12/16/85 11/9/92 1/3/84 B. Name(s of each party in this cause and name and address of all counsel of record: Tom Galbraith Meyer, Hendricks & Bivens, P.A North Central Avenue, Suite 1200 Phoenix, Arizona Attorneys for Plaintiffs-Respondents Richard and Marcia Grand Michael J. Meehan Munger Chadwick 33 North Wilmot, Suite 300 Tucson, Arizona Attorneys for Plaintiffs-Respondents Richard and Marcia Grand Timothy Berg A. Bates Butler, III James D. Burgess One South Church Avenue, Suite 1000 Tucson, Arizona Attorneys for Defendant-Petitioner Qwest Communications International Inc.
10 James P. Denvir Jonathan Sherman 5301 Wisconsin Avenue, N.W., Suite 800 Washington, DC Attorneys for Defendant-Petitioner Qwest Communications International Inc. John N. Iurino Lewis and Roca LLP One South Church Avenue, Suite 700 Tucson, Arizona Attorney for Defendant-Petitioner John A. McMaster Joseph E. Mais Brian C. Lake Perkins Coie Brown & Bain P.A North Central Avenue P. O. Box 400 Phoenix, Arizona Attorneys for Defendant-Petitioner Joseph P. Nacchio
11 2
12 I, GARLAND PINKSTON, JR., Clerk of the District of Columbia Court of Appeals, do hereby certify that ROBIN S. CONRAD was on the 19 TH day of DECEMBER, 1980 duly qualified and admitted as an attorney and counselor and entitled to practice before this Court and is, on the daze indicated below, an active member in good standing of this Bar. In Testimony Whereof, I have hereunto subscribed my name and affixed the seal of this Court at the City of Washington, D.C., on April 2, GARLAND PINKSTON, JR., CLERK Depu~er ~
13 3
14 Arizona Supreme Court Richard and Marcia Grand Plaintiff, v. Nacchio, et al. Defendant. CASE # CV PR SBA App # NOTICE OF RECEIPT OF COMPLETE APPLICATION 9 i0 Ii NOTICE IS HEREBY given by THE STATE BAR OF ARIZONA that it has received the verified application and fee from Robin S Conrad. In addition to this application, applicant has made the following applications to appear pro hac vice, pursuant to Rule38 (a, within the previous three (3 years: Title of Matter Court/Agency Date Granted? [--]Yes []Yes [] No [] No Exhibit A, the original verified application and Exhibit B, the original Certificate(s of Good Standing are attached hereto. DATED this 16 m day of April Original Mailed on this 16 th day of April 2007 to: Thomas L Hudson 2929 N Central Ave Ste 2100 Phoenix, AZ Resource Center State Bar of Arizona 25
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