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  • Fuller, John et al vs. R.J. Reynolds Tobacco Company et al Products Liability document preview
  • Fuller, John et al vs. R.J. Reynolds Tobacco Company et al Products Liability document preview
  • Fuller, John et al vs. R.J. Reynolds Tobacco Company et al Products Liability document preview
  • Fuller, John et al vs. R.J. Reynolds Tobacco Company et al Products Liability document preview
  • Fuller, John et al vs. R.J. Reynolds Tobacco Company et al Products Liability document preview
  • Fuller, John et al vs. R.J. Reynolds Tobacco Company et al Products Liability document preview
  • Fuller, John et al vs. R.J. Reynolds Tobacco Company et al Products Liability document preview
  • Fuller, John et al vs. R.J. Reynolds Tobacco Company et al Products Liability document preview
						
                                

Preview

“4 gACHU R cour / SUPE ¥ ALTHO PE 2 ae PARR ef # = . yur at & \0 Filed nee BARNS KetanSA \otk ui) ARY PULLER, 672-CV" olloe mrs heh FULLER ani JOHN Plaintiffs, .REYN ROS. RJARBER C.., an opacco COMP ANY (L B) ‘Dp FARMS, CUM! Defendants 4s FOR ADMISSION oF 9 MOTION See PROC SY ASSENTED Garbet ds To ba cc o Company, RJ Reynol defendants of the law t to GL . ¢. 221 § 46. A. ey Pe te r 3 Biersteker Pursua nt that ato! mn reby move s, iinc., he Bros., Inc., an d Cumb er la nd Fa rm for the purposes of this case only: be for ¢ this Court firm Jon es Day be ad mitted to practice state bars of the District 0 f Colunbi, Florida, Attomey Biersteker is a member of the and Pennsylvania. He is also a member of the federal bars of the United States District Court for e the District of Columbia, the United Stat es Court of Appeals foy the Four Chey i id United States Cour t of Appeals for the D istrict oF C bar of the Di strict of C omb Clip Pennsylv olum! bia in] 9 81, the S ult tate ‘tly ania in 2013. Hi bar ofp Districg oF Co, * 8S admittey Fo, 1a in 198 Ni, Weuit 4 FCO, him a 3 ern) a bop Trey it egg Sear tt by iy 4 | Up Uk ‘, Sag ‘ % 4 , \, "4 ? es BAH? Filed JUL 37 28{@COMMONWEALTH OF MASSACHUSETTS BARN a SUPERIOR COURT Hrdaider lark JOHN FULLER and MARY FULLER, Fog AUouH*!, byte Cun Plaintiffs, Case No. 1672-CV-00154 Nokeaeh (f ltUe Vv, R.J. REYNOLDS TOBACCO COMPANY, GARBER BROS., INC., and (Vap-vengishith CUMBERLAND FARMS, INC., 4 Defendants. we ASSENTED-TO MOTION OF DEFENDANTS FOR ADMISSION OF PETER J. BIERSTEKER PRO HAC VICE Pursuant to G.L. c. 221, § 46A, defendants R.J. Reynolds Tobacco Company, Garber Bros., Inc., and Cumberland Farms, Inc., hereby move that attorney Peter J. Biersteker of the law firm Jones Day be admitted to practice before this Court for the purposes of this case only. Attorney Biersteker is a member of the state bars of the District of Columbia, Florida, and Pennsylvania. He is also a member of the federal bars of the United States District Court for a the District of Columbia, the United States Court of Appeals for the Fourth Circuit, and the United States Court of Appeals for the District of Columbia Circuit. He was admitted to the state bar of the District of Columbia in 1981, the state bar of Florida in 2011, and the state bar of aa Pennsylvania in 2013. He was admitted to the federal bar of the United States District Court for, : the District of Columbia in 1982, the federal bar of the United States Court of Appeals for the Fourth Circuit in 1988, and the federal bar of the United States Court of Appeals for the District of Columbia Circuit in 2000. ~ R.J. REYNOLDS TOBACCO COMPANY, GARBER BROS., INC., and CUMBERLAND FARMS, INC., By their attorneys, Dated: July 26, 2016 Thémas E. Peisch (BB) (0. 393 ‘in K. Higgins (BBO No. 559510) ohanna L. Matloff (BBO No. 655178) CONN KAVANAUGH ROSENTHAL PEISCH & FORD, LLP Ten Post Office Square Boston, MA 02109 Telephone: (617) 482-8200 tpeisch@connkavanaugh.com ehiggins@connkavanaugh.com jmatloff@connkavanaugh.com ASSENTED -TO BY: JOHN FULLER and MARY FULLER, By their attorneys, Rebeca ae Saleh The Public Heaith Advocacy Institute 360 Huntington Avenue #117CU RVICE Boston, MA 02115 (617) 373-2026 ERTIFICATE OF SEabove ‘wort document a true that y certifyeb Uher for sock other 1367898.1 06746-106 wees served Upt pastyby le Attorney Biersteker has submitted an affidavit, attached hereto at Tab A, in support of this Motion. As his affidavit attests: (1) He is a member in good standing of the Bar in every jurisdiction in which he has been admitted to practice; (2) There are no disciplinary proceedings pending against him as a member of the Bar in any jurisdiction; (3) He is familiar with the Massachusetts Rules of Civil Procedure and the Rules of the Superior Court; (4) The District of Columbia, Florida, and Pennsylvania bars grant like pro hac vice privileges to members of the Bar of the Commonwealth of Massachusetts; 6) He has paid to the Board of Bar Overseers the registration fees required by Supreme Judicial Court Rule 3:15; (6) He is a partner with the law firm of Jones Day; and ) He has represented R.J. Reynolds Tobacco Company, a long-standing client of Jones Day, in tobacco- related litigation for a number of years and, as a result, is very familiar with the issues presented in the instant litigation. In addition, Attorney Biersteker has associated, as co-counsel, the undersigned members in good standing of the Massachusetts Bar, who serve as counsel for Reynolds, Garber Bros., Inc., and Cumberland Farms, Inc. The defendants have conferred with counsel for John Fuller and Mary Fuller and they have assented to the allowance of this motion. WHEREFORE, the defendants respectfully request that the Court grant its motion to admit Peter J. Biersteker pro hac vice for purposes of this case.