UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-cv-23753-KMM

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated, 

Plaintiffs, 

v. 

SAM BANKMAN-FRIED, 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 Richard M. 

Simins of the law firm of Montgomery McCracken, 1735 Market Street, 21st Floor, Philadelphia, 

PA 19103-7505, Telephone 215-772-1500, for purposes of appearance as co-counsel on behalf of 

Defendant Sam Bankman-Fried in the above-styled case only, and pursuant to Rule 2B of the 

CM/ECF Administrative Procedures, to permit Richard M. Simins to receive electronic filings in 

this case, and in support thereof states as follows:

1. Richard M. Simins is not admitted to practice in the Southern District of Florida 

and is a member in good standing of the Pennsylvania State Bar.

2. Movant, Gerald E. Greenberg, of the law firm of Gelber Schachter & Greenberg, 

P.A., SunTrust International Center, One Southeast Third Avenue, Suite 2600 Miami, Florida 

33131, Telephone: (305) 728-0950, is a member in good standing of The Florida Bar and the 

Case 1:22-cv-23753-KMM Document 86 Entered on FLSD Docket 03/08/2023 Page 1 of 4
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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, Richard M. Simins has made 

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

attached hereto.

4. Richard M. Simins, 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 Richard M. Simins at email address: rsimins@mmwr.com.

WHEREFORE, Gerald E. Greenberg, moves this Court to enter an Order Richard M. 

Simins, to appear before this Court on behalf of Defendant, Sam Bankman-Fried, for all purposes 

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

electronic filings to Richard M. Simins. 

Case 1:22-cv-23753-KMM Document 86 Entered on FLSD Docket 03/08/2023 Page 2 of 4
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Dated: March 8, 2023 Respectfully Submitted,

/s/Gerald E. Greenberg

GERALD E. GREENBERG

Florida Bar No. 440094

ggreenberg@gsgpa.com

ADAM M. SCHACHTER

Florida Bar No. 647101

aschachter@gsgpa.com

GELBER SCHACHTER & GREENBERG, P.A. 

SunTrust International Center 

One Southeast Third Avenue, Suite 2600

Miami, Florida 33131 

Telephone: (305) 728-0950

E-service: efilings@gsgpa.com

Counsel for Defendant Sam Bankman-Fried

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-cv-23753-KMM

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated, 

Plaintiffs, 

v. 

SAM BANKMAN-FRIED, et al., 

Defendants.

________________________________________/

CERTIFICATION OF RICHARD M. SIMINS

Richard M. Simins, Esquire, pursuant to Rule 4(b)(1) 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 Pennsylvania State Bar; and (3) I have not filed more than 

three pro hac vice motions in different cases in this District within the last 365 days.

 /s/Richard M. Simins

Richard M. Simins

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