UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case No. 20-23179-Civ-COOKE/GOODMAN 

MOUNTECH IP LLC, 

Plaintiff 

v. 

HMD AMERICA, INC., 

Defendant. 

________________________________/

MOTION TO APPEAR PRO HAC VICE FOR MATTHEW MOFFA, 

CONSENT TO DESIGNATION, AND REQUEST TO 

ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING 

In accordance with Local Rules 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 Matthew Moffa 

of the law firm of PerkinsCoie, 1155 Avenue of the Americas, 22nd Floor, New York, NY 10036-

2711, Telephone 212-262-6900, for purposes of appearance as co-counsel on behalf of Defendant 

HMD AMERICA, INC. in the above-styled case only, and pursuant to Rule 2B of the CM/ECF 

Administrative Procedures, to permit Matthew Moffa to receive electronic filings in this case, and 

in support thereof states as follows: 

1. Matthew Moffa is not admitted to practice in the Southern District of Florida and 

is a member in good standing of the state bars of New York and Massachusetts, U.S. District 

Courts for the Southern, Eastern, and Western Districts of New York, U.S. District Court for the 

District of Massachusetts, and U.S. District Court for the Eastern District of Texas. 

2. Movant, Joseph W. Bain, Esquire, of the law firm of Shutts & Bowen LLP, 525 

Okeechobee Boulevard, Suite 1100, West Palm Beach, Florida 33401, Telephone 561-835-8500, 

is a member in good standing of The Florida Bar and the United States District Court for the 

Case 1:20-cv-23179-MGC Document 11 Entered on FLSD Docket 09/09/2020 Page 1 of 3
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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. 

3. In accordance with the local rules of this Court, Matthew Moffa has made payment 

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

hereto. 

4. Matthew Moffa, 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 Matthew Moffa at email address: MMoffa@perkinscoie.com. 

WHEREFORE, Joseph W. Bain, moves this Court to enter an Order for Matthew Moffa, to 

appear before this Court on behalf of Defendant HMD AMERICA, INC. for all purposes relating 

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

filings to Matthew Moffa. 

Date: September 9, 2020 Respectfully submitted, 

 /s/ Joseph W. Bain

JOSEPH W. BAIN, ESQ. 

Florida Bar No. 860360 

Email: jbain@shutts.com

SHUTTS & BOWEN LLP

1100 CityPlace Tower 

525 Okeechobee Boulevard 

West Palm Beach, Florida 33401 

Telephone: (561) 835-8500 

Facsimile: (561) 650-8530 

Attorneys for Defendant HMD America, Inc. 

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on this 9th day of September 2020, I electronically filed the 

foregoing with the Clerk of Court by using the CM/ECF system, which will automatically send 

email notification of such filing to all counsel of record. 

/s/ Joseph W. Bain

JOSEPH W. BAIN, ESQ. 

Case 1:20-cv-23179-MGC Document 11 Entered on FLSD Docket 09/09/2020 Page 3 of 3