Disclaimer

This pleading is offered as a sample for educational purposes only. References to law and rules may not be current or accurate. Counsel must evaluate whether the pleading has utility in a given case. I am always happy to try to answer general questions of fellow counsel about law and practice and can be reached via the information below.

Ralph F. Holmes

McLane Middleton

(603) 628-1409 (office)

(857) 278-0019 (cell)

THE STATE OF NEW HAMPSHIRE

HILLSBOROUGHCOUNTY, SS

SOUTHERN DISTRICTSUPERIOR COURT

Cerissa L. Doe

v.

AAA, N.A.

Docket No. ______

ASSENTED-TO MOTION TO ADMIT COUNSEL PRO HAC VICE

NOW COMESCheryl C. Deshaies, as counsel for Respondent, AAA, N.A., by and through its attorneys, McLane, Graf, Raulerson and Middleton, Professional Association, and respectfully requests pursuant to Superior Court Rule 19, with the assent of opposing counsel, that the Court admit, Christi R. BBB, Esq. pro hac vice, of the firm of CCC, as co-counsel in this case, and in support therefore, states as follows:

  1. Ms. BBB is an attorney with the firm of CCC, Florida (407) xxx-xxxx is principal counsel for Respondent, which has retained undersigned counsel to act as local counsel.
  2. CCChas an existing attorney-client relationship with Respondent, which desires to have Ms. BBBassociated with its New Hampshire counsel.
  3. With this Motion, Ms. BBBhas submitted an affidavit in support of her admission pro hac vice, which satisfies all of the requirements of Superior Court Rule 19. See Affidavit of Christie R. BBB, Esq., attached hereto as Exhibit A.
  4. If admitted pro hac vice, Ms. BBBwill abide by all rules of this Court and will remain associated in this case with undersigned counsel.
  5. Counsel for Petitioner has been contacted and has given his assent to the filing of this Motion.

WHEREFORE, Respondent AAA, N.A. respectfully requests that the Court:

A.Admit Christi R. BBB, Esq., as counsel pro hac vice; and

B.Grant such other relief as this Court deems just and equitable.

Respectfully submitted,

MCLANE, GRAF, RAULERSON & MIDDLETON, PROFESSIONAL ASSOCIATION

Dated:February 18, 2009By:______

Ralph F. Holmes, Esq. NH BAR #1185

Cheryl C. Deshaies, Esq. NH BAR#12848

900 Elm Street, P.O. Box 326

Manchester, NH03105-0326

(603) 625-6464

Certificate of Service

I hereby certify that I have this ____ day of ______, 2009, served by First-Class Mail, postage prepaid, a copy of this Assented-To Motion to Admit Counsel Pro Hac Vice to ______counsel of record for Petitioner.

______

Cheryl C. Deshaies, Esq.

I have contributed this pleading to NHAJ’s online form file in the hope that members might find it of use. I am happy to try to be of assistance if you have questions. I can be reached at 628-1409 and . I encourage you to please donate your pleadings to our online form file. To maximize the value of this important benefit, all of us need to participate.

/s/ Ralph

Ralph F. Holmes

McLane, Graf, Raulerson & Middleton, PA

Box 326

Manchester, NH 03105-0326

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