UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

ALEXIA PREDDY, individually and on 

behalf of all others similarly situated, 

Plaintiff, 

v. 

ADT, LLC d/b/a ADT SECURITY 

SERVICES, a Delaware limited liability 

company, 

Defendant. 

 Case No. 0:20-cv-60971-AHS 

MOTION TO APPEAR PRO HAC VICE, 

CONSENT TO DESIGNATION, AND REQUEST TO 

ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING 

In accordance with Rule 4(b) of the Rules Governing the Admission, Practice, Peer 

Review, and Discipline of Attorneys of the United States District Court for the Southern District 

of Florida, the undersigned respectfully moves for the admission pro hac vice of Charles C. Eblen 

of the law firm of Shook, Hardy & Bacon L.L.P., 2555 Grand Blvd., Kansas City, MO 64108, 

(816) 474.6550, for purposes of appearance as co-counsel on behalf of ADT LLC in the abovestyled case only; to permit Charles C. Eblen to receive electronic filings in this case pursuant to 

Rule 2B of the CM/ECF Administrative Procedures; and to, if granted, consider Mr. Eblen’s pro 

hac vice admission in this and in the related case of Doty v. ADT LLC, to be one representation for 

purposes of Rule 4(b). In support hereof, Movant, Mr. Eblen, and ADT LLC state as follows: 

1. The instant action is one of two related class actions filed in this District against 

ADT arising out of the same course of criminal conduct by a former ADT technician. See Preddy 

v. ADT, LLC, Case No. 0:20-cv-60971 (S.D. Fla.); Doty v. ADT, LLC, Case No. 0:20-cv-60972-

AHS (S.D. Fla.). The plaintiffs are represented by the same lawyers in each case. The actions 

Case 0:20-cv-60971-AHS Document 48 Entered on FLSD Docket 10/23/2020 Page 1 of 3
were filed as separate actions on the same day, were assigned separate case numbers, and were 

assigned to different judges. 

2. Consistent with Local Rule 3.8, Plaintiffs Doty and Preddy notified the Court that 

their actions were related [Doty, ECF No. 43; Preddy, ECF No. 22] and on July 13, 2020 Judge 

Ruiz transferred the Doty action to this Court [ECF No. 45]. 

3. Prior to transfer, Mr. Eblen was granted pro hac vice admission in Doty. [ECF No. 

20]. 

4. ADT likewise desires for Mr. Eblen to represent and defend it in the instant action. 

5. Mr. Eblen is not admitted to practice in the Southern District of Florida and is a 

member in good standing of the State of Missouri and the United States District Court for the 

Western District of Missouri. 

6. Movant, Jennifer A. McLoone, Esquire, of the law firm of SHOOK, HARDY & 

BACON L.L.P., Citigroup Center, Suite 3200, 201 South Biscayne Blvd., Miami, Florida 33131, 

(305) 358-5171, is a member in good standing of The Florida Bar and the United States District 

Court for the Southern District of Florida and is authorized to file through the Court’s electronic 

filing system. Movant consents to be designated as a member of the Bar of this Court with whom 

the Court and opposing counsel may readily communicate regarding the conduct of the case, upon 

whom filings shall be served, who shall be required to electronically file and serve all documents 

and things that may be filed and served electronically, and who shall be responsible for filing and 

serving documents in compliance with the CM/ECF Administrative Procedures. See Section 2B 

of the CM/ECF Administrative Procedures. 

7. In accordance with the local rules of this Court, Mr. Eblen has made payment of 

this Court’s $200.00 admission fee. A certification in accordance with Rule 4(b) is attached hereto. 

8. Mr. Eblen, by and through designated counsel and pursuant to Section 2B CM/ECF 

Administrative Procedures, hereby requests the Court to provide Notice of Electronic Filings to 

him at email address: ceblen@shb.com. 

9. In addition to moving for pro hac vice admission in this case, Mr. Eblen and ADT 

request that the Court consider this Motion and any Order granting same in this case to arise out 

of the same, and not a separate, representation as in Doty, for purposes of Rule 4(b). See Rule 4(b) 

(providing that “the filing of more than three motions to appear pro hac vice within a 365-day 

period in separate representations before the Courts of this District shall be presumed to be a 

Case 0:20-cv-60971-AHS Document 48 Entered on FLSD Docket 10/23/2020 Page 2 of 3
‘general practice’”). In other words, Mr. Eblen and ADT request that Mr. Eblen’s pro hac vice 

admission in Doty and in this case count together as 1 of the 3 “separate representations” permitted 

by Local Rule 4(b) in a 365-day period. As indicated above, both cases arise out of the same 

isolated conduct; involve the same subject matter, similar claims, and overlapping legal and factual 

issues; both the parties and the Court have recognized that these cases are similar and related;1 and 

Mr. Eblen’s pro hac vice admission is on behalf of the same party in each case, ADT LLC. Good 

cause exists to consider the representation to be one representation and this Court has the discretion 

to so order. See Rule 4(b) (providing that “[u]pon written and for good cause shown the Court 

may waive or modify this prohibition”); Encarnacion v. Financial Corporation of America, Case 

No. 2:17-cv-566-FtM-38CM, 2018 WL 3860124 (M.D. Fla. 2018) (“It is well-settled that federal 

courts have wide discretion in granting admission to practice pro hac vice.”) 

WHEREFORE, Jennifer A McLoone, moves this Court to enter an Order for Charles C. 

Eblen, to appear before this Court on behalf of ADT LLC, for all purposes relating to the 

proceedings in the above-styled matter, directing the Clerk to provide notice of electronic filings to 

Charles C. Eblen, and to deem this admission and the pro hac vice admission in Doty to be one 

representation for purposes of Rule 4(b). 

Dated: October 23, 2020. Respectfully submitted, 

Jennifer A. McLoone 

Jennifer A. McLoone (Florida Bar No. 029234) 

E-Mail: jmcloone@shb.com 

SHOOK, HARDY & BACON L.L.P.

Citigroup Center, Suite 3200

201 South Biscayne Blvd.

Miami, Florida 33131 

T: (305) 358-5171 

Attorneys for ADT LLC 

1 Local Rule 3.8 (Notice of Transfer of Refiled And Similar Actions And Procedures) provides that: “[i]t shall be the 

continuing duty of the attorneys of record in every action or proceeding to bring promptly to the attention of the Court 

and opposing counsel the existence of other actions or proceedings as described in Section 2.15.00 of the Court’s 

Internal Operating Procedures . . . . Such notice shall be given by filing with the Court and serving a “Notice of 

Pending, Refiled, Related or Similar Actions,” containing a list and description thereof sufficient for identification. 

Likewise, Internal Operating Procedure 2.15.00 (Transfer of Similar Actions) provides that: “[w]henever an action 

or proceeding filed in the Court which involves subject matter which is a material part of the subject matter of another 

action or proceeding then pending before this Court, or for other reasons, the disposition thereof would appear to entail 

the unnecessary duplication of judicial labor if heard by a different Judge, the Judges involved shall determine whether 

the higher-numbered action or proceeding shall be transferred to the Judge assigned to the lower-numbered action.” 

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