UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 1:20-CV-23242-BLOOM/LOUIS 

UNITED STATES OF AMERICA ex rel.

SEDONA PARTNERS LLC, 

 Plaintiff, 

vs. 

ABLE MOVING & STORAGE, INC.; ARPIN VAN 

LINES, INC.; CARTWRIGHT INTERNATIONAL 

VAN LINES, INC.; COLEMAN AMERICAN 

MOVING SERVICES, INC.; DEWITT 

COMPANIES LIMITED, LLC; HILLDRUP 

COMPANIES, INC.; J.K. MOVING & STORAGE 

INC.; MAYFLOWER TRANSIT, LLC; NEW 

WORLD VAN LINES, INC.; PARAMOUNT 

TRANSPORTATION SYSTEMS; PAXTON VAN 

LINES, INC.; AND WESTERN EXPRESS 

FORWARDING, LLC, 

 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 Stephen Chahn 

Lee Esquire of the law firm of Benesch, Friedlander, Coplan & Aronoff, LLP, 71 S. Wacker Drive, 

Suite 1600, Chicago, IL 60606, 312.624.6361, slee@beneschlaw.com, for purposes of appearance 

as co-counsel on behalf of Defendant DeWitt Companies Limited, LLC, in the above-styled case 

only, and pursuant to Rule 2B of the CM/ECF Administrative Procedures, to permit Stephen 

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

Case 1:20-cv-23242-BB Document 70 Entered on FLSD Docket 07/07/2021 Page 1 of 7
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1. Stephen Chahn Lee is not admitted to practice in the Southern District of Florida 

and is a member in good standing of the State Bar of Illinois, Northern District of Illinois and 

Appellate Division of New York Supreme Court. 

2. Movant, Matthew J. Langley, of the law firm of Benesch, Friedlander, Coplan & 

Aronoff, LLP, 71 S. Wacker Drive, Suite 1600, Chicago, IL 60606, 312.212.4949, 

mlangley@beneschlaw.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, Stephen Chahn Lee has made 

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

attached hereto. 

4. Stephen Chahn Lee, 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 Stephen Chahn Lee at email address: slee@beneschlaw.com. 

WHEREFORE, Matthew J. Langley, moves this Court to enter an Order for Stephen Chahn 

Lee, to appear before this Court on behalf of Defendant DeWitt Companies Limited, LLC, for all 

purposes relating to the proceedings in the above-styled matter and directing the Clerk to provide 

notice of electronic filings to Stephen Chahn Lee. 

Case 1:20-cv-23242-BB Document 70 Entered on FLSD Docket 07/07/2021 Page 2 of 7
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Date: July 7, 2021 Respectfully submitted, 

/s/ Matthew J. Langley 

Matthew J. Langley (FL #097331) 

BENESCH, FRIEDLANDER, COPLAN 

 & ARONOFF LLP 

71 South Wacker Drive, Suite 1600 

Chicago, IL 60606-4637 

Telephone: 312-212-4949 

Facsimile: 312-767-9192 

Email: mlangley@beneschlaw.com 

Attorney for Defendant DeWitt Companies Limited, LLC

Case 1:20-cv-23242-BB Document 70 Entered on FLSD Docket 07/07/2021 Page 3 of 7
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 1:20-CV-23242-BLOOM/LOUIS 

UNITED STATES OF AMERICA ex rel.

SEDONA PARTNERS LLC, 

 Plaintiff, 

vs. 

ABLE MOVING & STORAGE, INC.; ARPIN VAN 

LINES, INC.; CARTWRIGHT INTERNATIONAL 

VAN LINES, INC.; COLEMAN AMERICAN 

MOVING SERVICES, INC.; DEWITT 

COMPANIES LIMITED, LLC; HILLDRUP 

COMPANIES, INC.; J.K. MOVING & STORAGE 

INC.; MAYFLOWER TRANSIT, LLC; NEW 

WORLD VAN LINES, INC.; PARAMOUNT 

TRANSPORTATION SYSTEMS; PAXTON VAN 

LINES, INC.; AND WESTERN EXPRESS 

FORWARDING, LLC, 

 Defendants. 

CERTIFICATION OF STEPHEN CHAHN LEE 

Stephen Chahn Lee, 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 State Bar of Illinois, Northern District of Illinois and Appellate 

Division of New York Supreme Court; and (3) I have not filed three or more motions for pro hac 

vice admission in this District within the last 365 days. 

Date: July 7, 2021 /s/ Stephen Chahn Lee 

 Stephen Chahn Lee

Case 1:20-cv-23242-BB Document 70 Entered on FLSD Docket 07/07/2021 Page 4 of 7
CERTIFICATE OF SERVICE 

 The undersigned attorney hereby certifies that the foregoing Motion to Appear Pro Hac 

Vice, Consent to Designation, and Request to Electronically Receive Notices for Electronic Filing 

was filed electronically on this 7th day of July, 2021, with the Clerk of Court using the ECF system, 

which will send notifications of such to all counsel of record. 

 

 /s/ Matthew J. Langley 

 Matthew J. Langley 

 

Case 1:20-cv-23242-BB Document 70 Entered on FLSD Docket 07/07/2021 Page 5 of 7
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 1:20-CV-23242-BLOOM/LOUIS 

UNITED STATES OF AMERICA ex rel.

SEDONA PARTNERS LLC, 

 Plaintiff, 

vs. 

ABLE MOVING & STORAGE, INC.; ARPIN VAN 

LINES, INC.; CARTWRIGHT INTERNATIONAL 

VAN LINES, INC.; COLEMAN AMERICAN 

MOVING SERVICES, INC.; DEWITT 

COMPANIES LIMITED, LLC; HILLDRUP 

COMPANIES, INC.; J.K. MOVING & STORAGE 

INC.; MAYFLOWER TRANSIT, LLC; NEW 

WORLD VAN LINES, INC.; PARAMOUNT 

TRANSPORTATION SYSTEMS; PAXTON VAN 

LINES, INC.; AND WESTERN EXPRESS 

FORWARDING, LLC, 

 Defendants. 

 

PROPOSED 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 

Stephen Chahn Lee, 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 fasctors, it is hereby 

ORDERED AND ADJUDGED that the Motion is GRANTED. Stephen Chahn Lee, may 

appear and participate in this action on behalf of Defendant DeWitt Companies Limited, LLC. The 

Case 1:20-cv-23242-BB Document 70 Entered on FLSD Docket 07/07/2021 Page 6 of 7
Clerk shall provide electronic notification of all electronic filings to Stephen Chahn Lee, at email 

address: slee@beneschlaw.com. 

IT IS SO ORDERED by the Court, this __ day of ____________________. 

 

 BETH BLOOM 

 UNITED STATES DISTRICT JUDGE 

Copies furnished to: All Counsel of Record 

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