UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:20-cv-23242-BB

UNITED STATES OF AMERICA ex rel.

SEDONA PARTNERS LLC,

Plaintiff,

vs.

ABLE MOVING & STORAGE, INC., et al.,

Defendants.

MOTION TO APPEAR PRO HAC VICE, 

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 Stuart A. Berman, 

Esquire of the law firm of Lerch, Early & Brewer, Chtd., 7600 Wisconsin Avenue, Suite 700, 

Bethesda, MD 20814, 301.657.0729, saberman@lerchearly.com, for purposes of appearance as 

co-counsel on behalf of defendant Paxton Van Lines, Inc., in the above-styled case only, and 

pursuant to Rule 2B of the CM/ECF Administrative Procedures, to permit Stuart A. Berman to 

receive electronic filings in this case, and in support thereof states as follows:

1. Stuart A. Berman is not admitted to practice in the Southern District of Florida and 

is an member in good standing of the State Bars of Maryland, the District of Columbia, and New 

York (active status) and Massachusetts (inactive status); the United States District Courts for the 

District of Maryland, District of Columbia, and Southern and Eastern Districts of New York; the 

United States Supreme Court; and the United States Court of Appeals for the Second, Fourth, 

Sixth, Eleventh, and District of Columbia Circuits.

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2. Movant, Robert Harris, Esquire, of the law firm of Stack Fernandez & Harris, P.A., 

1001 Brickell Bay Drive, Suite 2650, Miami, Florida 33131, 305.371.0001, 

rharris@stackfernandez.com, 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.

3. In accordance with the local rules of this Court, Stuart A. Berman has made 

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

attached hereto.

4. Stuart A. Berman, 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 Stuart A. Berman at email address: saberman@lerchearly.com.

WHEREFORE, Robert Harris, moves this Court to enter an Order for Stuart A. Berman, 

to appear before this Court on behalf of defendant Paxton Van Lines, Inc., for all purposes relating 

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

filings to defendant Paxton Van Lines, Inc.

Case 1:20-cv-23242-BB Document 36 Entered on FLSD Docket 06/23/2021 Page 2 of 5
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Dated: June 23, 2021 Robert Harris

Robert Harris, Esq.

Fla. Bar No. 817783

Email: rharris@stackfernandez.com

 gmartich@stackfernandez.com

STACK FERNANDEZ & HARRIS, P.A. 

1001 Brickell Bay Drive, Suite 2650 

Miami, Florida 33131 

Telephone: 305.371.0001 

Attorneys for Defendant Paxton Van Lines, Inc. 

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:20-cv-23242-BB

UNITED STATES OF AMERICA ex rel.

SEDONA PARTNERS LLC,

Plaintiff,

vs.

ABLE MOVING & STORAGE, INC., et al.,

Defendants.

CERTIFICATION OF STUART A. BERMAN

Stuart A. Berman, Esquire, pursuant to Rule 4(b) of the Rules Governing the Admission,

Practice, Peer Review, and Discipline of Attorneys, hereby certifies that (1) I have studied the 

Local Rules of the United States District Court for the Southern District of Florida; (2) I am a 

member in good standing of the State Bars of Maryland, the District of Columbia, and New York 

(active status) and Massachusetts (inactive status); the United States District Courts for the District 

of Maryland, District of Columbia, and Southern and Eastern Districts of New York; the United 

States Supreme Court; and the United States Court of Appeals for the Second, Fourth, Sixth, 

Eleventh, and District of Columbia Circuits; and (3) I have not filed three or more motions for pro 

hac vice admission in this District within the last 365 days.

Date: June 23, 2021 /s/ Stuart A. Berman 

Stuart A. Berman

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:20-cv-23242-BB

UNITED STATES OF AMERICA ex rel.

SEDONA PARTNERS LLC,

Plaintiff,

vs.

ABLE MOVING & STORAGE, INC., et al.,

Defendants.

ORDER GRANTING MOTION TO APPEAR 

PRO HAC VICE, CONSENT TO DESIGNATION AND REQUEST TO

ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING

THIS CAUSE having come before the Court on the Motion to Appear Pro Hac Vice for 

Stuart A. Berman, Consent to Designation, and Request to Electronically Receive Notices of 

Electronic Filing (the “Motion”), pursuant to the Rules Governing the Admission, Practice, Peer 

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

of Florida and Section 2B of the CM/ECF Administrative Procedures. This Court having 

considered the motion and all other relevant factors, it is hereby 

ORDERED AND ADJUDGED that the Motion is GRANTED. Stuart A. Berman, may 

appear and participate in this action on behalf of defendant Paxton Van Lines, Inc. The Clerk shall 

provide electronic notification of all electronic filings to Stuart A. Berman at email address:

saberman@lerchearly.com.

DONE AND ORDERED in Chambers at Miami, Florida, this ____ day of 

June 2021. 

 

BETH BLOOM

United States District Judge

Copies furnished to: All Counsel of Record

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