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HOW TO PLAY MUSICAL CHAIRS ---- ERM, ATTORNEYS When it comes to Federal Courts, attorneys cannot just jump

from Federal District Court to Federal District Court even within the same State. Formal procedures must be followed. I will try to explain my understanding of the current proceedings to everyone providing cites to the corresponding documents which, if I have done things correctly will follow this writing. Throughout, I am going to use the State of Georgia as an example, but this basically applies to all the Federal District Courts in all the States of America. Local Federal Rules of Civil Procedure can differ slightly. When an attorney passes the Georgia Bar, they apply for and become a member of the Georgia Bar thus admitting to them to practice in Superior (State) Courts. Most attorneys who are going to practice in the field of civil litigation will also apply to his/her local Federal District Court. In this instance, the Southern District Court, Savannah Division. An attorney must apply in writing, be approved and then be admitted to practice by sworn oath before a judge. If an attorney lives in Washington D.C. (Federal District of Columbia) and is an admitted member of that Federal District, but is not a member of the Federal Southern District Court of Georgia, then they can apply as pro hac vice counsel or one time counsel. In order to do this, they must prove in writing that they are a member in good standing in the Federal District of Columbia. They must also designate a local attorney in the Southern Federal District Court who is already admitted and practicing. This attorney acts as local counsel and is expected to receive copies of all documents, pleadings, etc., and to promise to appear if the pro hac vice attorney fails to do so. So, the first step is to file a Notice of Appearance of Counsel or a Notice of Substitution of Counsel. This has all ready been done by Deen's new counsel. SEE: Docket #246: Second step, each of Deen's new attorneys have filed an Application (Motion) for Admission Pro Hac Vice. They have designated Deen's new Georgia attorney, Harvey Weitz, Esquire, as their local counsel or hook up, if you will. I am providing a link to one of the Applications so everyone can see what it looks like. SEE: Docket #249 Next, the old or current attorneys of record must file a Motion of Withdrawal as Counsel and set forth the reason they are withdrawing. Deen's old legal team has done this and stated the reason .... is at the request of the Deen Defendants and per Notice of Substitution on Counsel, Doc #246. (And now we can guess why the press said Deen fired her attorneys.) SEE: Docket #252. The above link also contains a proposed Order for The Honorable William T. Moore, Jr. to sign if he agrees. If Judge Moore does sign the Order it will be entered separately as a new document on the Court's Docket. Abra-Caadabra Change-A-Rooney! Normally, this would be the end of things and the case would move forward without a hitch. But not in the Deen Case.

Jackson and her attorneys have filed a Notice of Intention to File Response to Motions for Leave to Appear Pro Hac Vice and they are asking the Court for time to respond until July 15, 2013. See Docket #253: I do not know why Jackson and her attorneys would want to respond to the (Motions) Applications to Appear Pro Hac Vice, but I guess we will find out Monday. Again, for the record, my opinion is that I am unsure if this change of attorneys is such a good thing win, loose or draw. First, for those of you who think it will save money I can tell you hands down that tens of thousands of dollars have already been spent by Deen because there are over 60,000 documents which have been reviewed to date, not counting depositions and pleadings filed as they appear on the Court Docket. That is a lot of man hours and a lot of attorney's fees and costs. Deen's new legal team will have to re-review all these documents, read all the depositions, become familiar with each pleading on the docket and all those pleadings which have not yet been filed such as Requests for Admissions; Answers to Interrogatories, etc. Since they are presumably a higher priced law firm, their bill for just coming up to speed would send most of us screaming under the covers. It is my understanding that no further discovery can be conducted as the discovery deadline was originally sometime in early June, so there is nothing new they can do insofar as depositions, etc. Changing attorneys in the 11th hour before trial simply does not sit well with me, unless there is some legal strategy and there are only two of which I can wrap my tiny brain around. I'm not completely buying that the case was too in-depth for her current attorneys, because if that was completely true, new attorneys would have come on the scene way before now. If it is a PR move well, I have no comment on that subject matter which I currently wish to share. Once again, I ask everyone to be kind to each other in responding and to respect each others' opinions. DISCLAIMER: This writing is meant to demonstrate my own personal opinion based on my own limited understanding. It is by no means meant to be a legal authority or advisory. Nor it is meant to be inflammatory or to defame.

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