UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 22-cv-23753-MOORE/BECERRA

EDWIN GARRISON, et al., on behalf of

themselves and all other 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 Eric A. Fitzgerald, 

Esq. of the law firm of McAngus Goudelock & Courie LLC, 2000 Market Street, Suite 780,

Philadelphia, PA 19103 & (484) 406-4334, for purposes of appearance as co-counsel on behalf of 

Defendant William Trevor Lawrence in the above-styled case only, and pursuant to Rule 2B of the 

CM/ECF Administrative Procedures, to permit Eric A. Fitzgerald, Esq. to receive electronic filings 

in this case, and in support thereof states as follows:

1. Eric A. Fitzgerald, Esq. is not admitted to practice in the Southern District of 

Florida and is a member in good standing of The Pennsylvania Bar, The New York Bar, The United 

States District Courts for the Eastern, Middle, and Western Districts of Pennsylvania, The United 

States District Courts for the Northern and Western Districts of New York, and the United States 

Court of Appeals for the Third Circuit.

Case 1:22-cv-23753-KMM Document 69 Entered on FLSD Docket 02/24/2023 Page 1 of 4
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2. Movant, David A. Rothstein, Esq., of the law firm of Dimond Kaplan & Rothstein, 

P.A., 2665 South Bayshore Drive, PH 2B, Miami, Florida 33133 & (305) 374-1920, 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, Eric A. Fitzgerald, Esq. has made 

payment of this Court’s $200 admission fee. A certification in accordance with Rule 4(b) is 

attached hereto.

4. Eric A. Fitzgerald, Esq., 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 Eric A. Fitzgerald, Esq. at email address: eric.fitzgerald@mgclaw.com. 

WHEREFORE, David A. Rothstein, Esq. moves this Court to enter an Order Eric A. 

Fitzgerald, Esq. to appear before this Court on behalf of Defendant William Trevor Lawrence, for 

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

notice of electronic filings to Eric A. Fitzgerald, Esq.

Case 1:22-cv-23753-KMM Document 69 Entered on FLSD Docket 02/24/2023 Page 2 of 4
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Dated: February 24, 2023 Respectfully submitted,

DIMOND KAPLAN & ROTHSTEIN, P.A.

Offices at Grand Bay Plaza

2665 South Bayshore Drive, PH-2B

Miami, Florida 33133

Telephone: (305) 374-1920

Facsimile: (305) 374-1961

By: /s David A. Rothstein 

David A. Rothstein, Esq.

Fla. Bar No. 995762

 DRothstein@dkrpa.com

Alexander M. Peraza, Esq.

Fla. Bar No. 107044

APeraza@dkrpa.com

Eshaba Jahir-Sharuz, Esq.

Fla. Bar No. 1038846

 Eshaba@dkrpa.com

Counsel for William Trevor Lawrence

Case 1:22-cv-23753-KMM Document 69 Entered on FLSD Docket 02/24/2023 Page 3 of 4
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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 22-cv-23753-MOORE/BECERRA

EDWIN GARRISON, et al., on behalf of

themselves and all other similarly situated,

Plaintiffs,

v.

SAM BANKMAN-FRIED, et al.,

Defendants.

___________________________________/

CERTIFICATION OF ERIC A. FITZGERALD, ESQ.

Eric A. Fitzgerald, Esq., 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 Bar, The New York Bar, The United States District 

Courts for the Eastern, Middle, and Western Districts of Pennsylvania, The United States District 

Courts for the Northern and Western Districts of New York, and the United States Court of 

Appeals for the Third Circuit; 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/ Eric A. Fitzgerald, Esq.

Eric A. Fitzgerald, Esq.

Case 1:22-cv-23753-KMM Document 69 Entered on FLSD Docket 02/24/2023 Page 4 of 4