Verified motion for pro hac vice admission in Palm Beach Post records suit, Nov. 2019

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA¶

CA FLORIDA HOLDINGS, LLC, Publisher of THE PALM BEACH POST,¶

Plaintiff,¶

v.¶

DAVE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida,¶

Defendants.¶

CASE NO.: 50-2019-CA-014681-XXXX-MB AG¶

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VERIFIED MOTION FOR ADMISSION TO APPEAR PRO MC VICE PURSUANT TO FLORIDA RULE OF JUDICIAL ADMINISTRATION 2.510¶

COMES NOW Michael Grygiel, Mo t herein, and respectfully represents the following:¶

• 1. Movant resides in Sara , State of New York.
• 2. Movant is an attorney and a Shareholder of the law firm of Greenberg Traurig, LLP, with offices at 54 State Street, 6th Floor, Albany, New York 12207, telephone number (518) 689- 1406.
• 3. vant has been retained personally or as a member of the above-named law firm on or abo t , 2019, by plaintiff CA Florida Holdings, LLC, publisher of the Palm Beach P s egal representation in connection with matters related to the above-styled action now pen ing before the above-named court of the State of Florida.
• 4. Movant is an active member in good standing and currently eligible to practice law in the following jurisdiction(s):

Court	Bar Number	Admitted
State of New York	2291821	8/28/1989
District of Columbia	423070	3/7/1990
State of Vermont	3154	4/8/1996
United States Supreme Court	309705	5/13/2019

5. There have been no disciplinary, suspension, disbarment, or contempt proceedings initiated against Movant in the preceding 5 years.

6. Movant, either by resignation, withdrawal, or otherwise, nev attempted to terminate Movant’s office as an attorney in order to avoid alit disbarment, or suspension proceedings. errainated or e, disciplinary,

7. Movant is not an active member of The Florida

8. Movant is not now {sup}amember of The F

9. Movant is not a suspended mem o {sup}eFlorida Bar.

10. Movant is not adisbarred mt o {sup}eFlorida Bar nor has Movant received {sup}a disciplinary resignation from The Fl

11. Movant has ny been disciplined or held in contempt by reason of misconduct committed while ed in representation pursuant to Florida Rule of Judicial Administration 2.5 0.

12. fo S has not filed amotion to appear as counsel in Florida state courts during the p

Local counsel of record associated with Movant in this matter is Stephen A. Mendelsohn who is an active member in good standing of The Florida Bar and has offices at Greenberg Traurig, P.A., 51 Town Center Circle, Suite 400, Boca Raton, Florida 33486, telephone number (561) 955-7600.¶

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14. Movant has read the applicable provisions of Florida Rule of Judicial Administration 2.510 and Rule 1-3.10 of the Rules Regulating The Florida Bar and certifies that this verified motion complies with those rules.

15. Movant agrees to comply with the provisions of the Florida Rules of Professional Conduct and consents to the jurisdiction of the courts and the Bar of the State of Florida.

WHEREFORE, Movant respectfully requests permission to appear in this court for this cause only.¶

DATED this 12{sup}th day of November, 2019.¶

STATE OF NEW YORK ) ) ss: ) COUNTY OF ALBANY )¶

I, Michael J. Grygiel, do hereby swear or affirm under penalty of perjury that I am the Movant in the above-styled matter; that I have read the foregoing Motion and know the contents thereof, and the contents are true of my own knowledge and belief.¶

Sworn to before me This 12 day of November, 2019.¶

AUTUMN [REDACTED] Notary Public, State of New York Qualified in Santa Cruz County No. 01WH6006258 Commission Expires Nov. 13, 2019¶

CERTIFICATE OF. LOCAL COUNSEL¶

{sup}Ihereby consent to be associated as local counsel of record in this cause pursuant to Florida Rule of Judicial Administration 2.510.¶

DATED November 12, 2019.¶

Stephen 11. Afendelvalm Stephen A. Mendelsohn Florida Bar Number: 849324 Greenberg Traurig, PA. 5100 Town Center Circle, Suite 400 Boca Raton, FL 33486 Telephone: (561) 955-7600 Facsimile: (561-338-7099 o@gtlaw.com¶

CERTIFICATE OF SERVICE¶

I HEREBY CERTIFY that on November 12, 2019, a true and correct copy of the foregoing motion was served by mail to PHV Admissions, The Florida Bar, 651 East Jefferson Street, Tallahassee, Florida 32399-2333 accompanied by payment of the $250.00 filing fee made payable to The Florida Bar. I also certify that the foregoing was electronically filed with the Clerk of the Court using the Florida Courts E-Filing Portal and is being served by e-mail generated by the EPortal system upon:¶

/s/ Sionhisit A. /Vandals() MS¶

Stephen A. Mende °o¶

ACTIVE 47104867v1¶

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SUPREME COURT OF THE STATE OF NEW YORK APPELLATE DIVISION, FOURTH DEPARTMENT ROCHESTER, NEW YORK¶

I, ALAN L. , Deputy Clerk of the Appellate Division of the Supreme Court in the Fourth Judicial Department, State of New York, do hereby certify that¶

Michael J. Grygiel¶

was duly admitted to practice a§,a attorney and counselor at law in all courts of this state by this Court on August 28, 1989, and appears in good standing upon the roll of attorneys and counselors, and other records, in this office and has registered with the administrative office of the Courts as required by Judiciary Law §468-a.¶

IN WITNESS WHEREOF, I have hereunto set my hand and affixed the seal of this Court, at the City of Rochester, November 12, 2019¶

Deputy Clerk of the Court¶