Plaintiff’S Unopposed Motion For Michael W. Weaver To

Summary

Plaintiff's Unopposed Motion for Michael W. Weaver to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of Electronic Filing, Document 21 (Case 8:20-cv-01003-MSS-CPT, filed 05/11/20), in 3M Company v. TAC2 Global LLC, U.S. District Court for the Middle District of Florida, Tampa Division. Local counsel Joseph M. Wasserkrug moves under Local Rule 2.02 for admission of Michael W. Weaver of McDermott Will & Emery LLP as co-counsel for Plaintiff 3M Company. The motion also serves as the written designation and consent for Mr. Wasserkrug to act as local counsel. A good faith certificate states that counsel for Defendant does not object, and Weaver's attorney certification is attached.

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IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION

3M COMPANY,

Plaintiff,
v.

Case No.: No. 8:20-cv-01003
TAC2 GLOBAL LLC,

Defendant.
________________________/

PLAINTIFF’S UNOPPOSED MOTION FOR MICHAEL W. WEAVER TO
APPEAR PRO HAC VICE, CONSENT TO DESIGNATION, AND REQUEST
TO ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING

In accordance with Local Rule 2.02 of the United States District Court for the
Middle District of Florida, undersigned local counsel, Joseph M. Wasserkrug, respectfully
moves for admission of Michael W. Weaver of the law firm of MCDERMOTT WILL &
EMERY LLP, 444 West Lake Street, Suite 4000, Chicago, Illinois 60606, for purposes of
appearing as co-counsel on behalf of Plaintiff 3M Company.  Mr. Weaver will pay a
$150.00 upon filing of this Motion with the Court.

As set forth in Mr. Weaver’s certification below, he has studied and is familiar with
the Local Rules of this Court, including Local Rules 2.02 and 2.04.  He is a member in
good standing with the Bar of the State of Illinois (IL Bar No. 6291021; admitted to practice
in 2006) and American Samoa (U.S. Territory); the United States District Court for the
Northern, Central, and Southern Districts of Illinois, the District of Colorado, and the
Eastern District of Michigan; and the United States Court of Appeals for the Third,
Case 8:20-cv-01003-MSS-CPT     Document 21     Filed 05/11/20     Page 1 of 4 PageID 346

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Seventh, and Ninth Circuits.  There are no disciplinary or suspension proceedings pending
against him in any Court of the United States or of any State, Territory, or Possession of
the United States.  Mr. Weaver certifies that he is not a resident of the State of Florida and
does not make frequent or regular appearances in separate cases to such a degree as to
constitute the maintenance of a regular practice of law in the State of Florida.
Mr. Weaver was admitted pro hac vice in Florida in the following cases: (i) Goldoni
v. Polymer Additives Holdings, Inc., No. 1:18-cv-21170-KMW, S.D. Fla. (admitted May
1, 2018); and (ii) 3M Company v. Geftico, LLC, No. 6:20-cv-648-Orl-41GJK, M.D. Fla.
(admitted April 24, 2020).  Otherwise, he has not appeared pro hac vice in any other federal
or state court in Florida within the past five (5) years.

Joseph M. Wasserkrug, an attorney with the law firm of MCDERMOTT WILL &
EMERY LLP, is a member in good standing of The Florida Bar and the Bar of this Court.
Mr. Wasserkrug is a resident of the State of Florida and practices at McDermott Will &
Emery LLP’s office located at 333 S.E. 2nd Avenue, Suite 4500, Miami, Florida 33131,
Telephone 305.347.6501, Facsimile 305.675.8403.

In accordance with Local Rule 2.02(a), this motion also serves as the written
designation and consent for Joseph M. Wasserkrug to act as local counsel.  As designated
hereunder: (a) all notices and papers may be served upon Mr. Wasserkrug, (b) opposing
counsel may readily communicate with Mr. Wasserkrug regarding the case; and (c) Mr.
Wasserkrug will be responsible for the case, including trial in the event of a default of the
non-resident attorneys.

Case 8:20-cv-01003-MSS-CPT     Document 21     Filed 05/11/20     Page 2 of 4 PageID 347

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LOCAL RULE 3.01(g) GOOD FAITH CERTIFICATE

Undersigned counsel certifies that counsel for Plaintiff conferred with counsel for
Defendant on May 11, 2020, who represented that Defendant does not object to the relief
requested herein.

Dated: May 11, 2020

MCDERMOTT WILL & EMERY LLP
By:
 /s/ Joseph M. Wasserkrug
Joseph M. Wasserkrug
Florida Bar No.: 112274
jwasserkrug@mwe.com
333 SE 2nd Avenue, Suite 4500
Miami, FL 33131-4336
T: 305.347.6501 | F: 305.675.8403

Counsel for Plaintiff 3M Company

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that, on May 11, 2020, I served the foregoing document
via email transmission to the parties listed on the service list below.

/s/ Joseph M. Wasserkrug

Joseph M. Wasserkrug (FBN 112274)

SERVICE LIST

Amy E. Stoll, Esq.
Richard C. Alvarez, Esq.
OLDER LUNDY & ALVAREZ
1000 West Cass Street
Tampa, Florida 33606
Tel. 813.254.8998
Fax. 813.839.4411
triallawyers@olalaw.com
astoll@olalaw.com

Counsel for Defendant

Case 8:20-cv-01003-MSS-CPT     Document 21     Filed 05/11/20     Page 3 of 4 PageID 348

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ATTORNEY CERTIFICATION

I, Michael W. Weaver, certify the following:

To my knowledge, there are NO disciplinary or suspension proceedings pending
against me in any Court of the United States or of any State, Territory, or Possession of the
United States.

I am not a resident of the State of Florida and have not made frequent or regular
appearances in separate cases to such a degree as to constitute the maintenance of a regular
practice of law in the State of Florida.  I was admitted pro hac vice in Florida in the
following cases: (i) Goldoni v. Polymer Additives Holdings, Inc., No. 1:18-cv-21170-
KMW, S.D. Fla. (admitted May 1, 2018); and (ii) 3M Company v. Geftico, LLC, No. 6:20-
cv-648-Orl-41GJK, M.D. Fla. (admitted April 24, 2020).  Otherwise, I have not appeared
pro hac vice in any other federal or state court in Florida within the past five (5) years

Within the twelve (12) month period preceding the date of this attorney
certification, I have studied and am familiar with the most current version of the Local
Rules of the United States District Court for the Middle District of Florida, including Local
Rules 2.02 and 2.04.

I declare under the penalty of perjury that the foregoing is true and correct.

 /s/ Michael W. Weaver

Michael W. Weaver
(signed by filing attorney with permission of
non-filing attorney)

/s/ Joseph M. Wasserkrug

Joseph M. Wasserkrug

May 11, 2020

DM_US 168417703-3.099922.0012
Case 8:20-cv-01003-MSS-CPT     Document 21     Filed 05/11/20     Page 4 of 4 PageID 349

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