115537218.v1 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov 

In re: Chapter 11 

It’Sugar FL I LLC, et al., Case No. 20-20259-RAM 

(Jointly Administered) 

Debtors. 

/ 

MOTION TO APPEAR PRO HAC VICE 

I, Heather L. Ries (“Movant”), a member in good standing of the bar of the United States District 

Court for the Southern District of Florida and qualified to practice in this court, request that this 

court admit pro hac vice Paul J. Labov (“Visiting Attorney”), an attorney admitted to practice and 

currently in good standing in the Bars of the States of New York and New Jersey, the United States 

District Court for the District of New Jersey and the United States District Courts for the Southern, 

Eastern and Western Districts of New York, and qualified to practice in this court, who proposes 

to act as counsel for the Official Committee of Unsecured Creditors (“Client”) in the case listed 

above, and in any adversary proceedings therein in which the Visiting Attorney appears on behalf 

of such Client. 

I am aware that the local rules of this court require a member in good standing of the bar of the 

United States District Court for the Southern District of Florida and qualified to practice in this 

court to act as local counsel for such Client, unless the court specifically authorizes an attorney not 

so admitted to act as local counsel. I understand that local counsel is required to participate in the 

preparation and presentation of, and accept service of all papers in, the case identified above and 

any adversary proceedings in which the Visiting Attorney appears on behalf of such Client. 

I am a member in good standing of the bar of the United States District Court for the Southern 

District of Florida and qualified to practice in this court, and agree to act as local counsel for the 

above-referenced Client in this case and in any adversary proceedings in this case in which the 

Visiting Attorney appears on behalf of the Client. I understand that I am required to participate in 

the preparation and the presentation of the case above and any such adversary proceedings and to 

accept service of all papers served in such case and proceedings. 

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The order granting this Motion will serve to admit the Visiting Attorney to practice in the case 

noted above on behalf of the Client and in any adversary proceedings in that case in which the 

Visiting Attorney appears on behalf of such Client. I understand that if I decline to serve as local 

counsel in any such adversary proceeding, separate local counsel must file an additional Motion 

to Appear Pro Hac Vice, and that absent such separate motion and an order of this court approving 

the same I will continue to act as local counsel for the Client in all such proceedings. 

The affidavit of the Visiting Attorney required under Local Rule 2090-1(C)(2) is filed concurrently 

herewith. 

WHEREFORE, upon the foregoing representations, Movant respectfully requests an order of this 

court authorizing the Visiting Attorney to appear pro hac vice in this case and in any adversary 

proceedings in this case on behalf of the Client and indicating Movant as local counsel for the 

Client, and for such other and further relief as may be just. 

Dated: October 27, 2020 

FOX ROTHSCHILD LLP 

777 South Flagler Drive 

Suite 1700 West Tower 

West Palm Beach, FL 33401 

Tel: (561) 835-9600 

Fax: (561) 835-9602 

By: /s/ Heather L. Ries 

Heather L. Ries 

Florida Bar No. 581933 

hries@foxrothschild.com 

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115537218.v1 

Affidavit of Proposed Visiting Attorney 

I, Paul J. Labov, am a member in good standing of the Bars of the States of New York and 

New Jersey, the United States District Court for the District of New Jersey and the United States 

District Courts for the Southern, Eastern and Western Districts of New York, but am not admitted 

to the bar of the United States District Court for the Southern District of Florida. I certify that I 

have never been disbarred, that I am not currently suspended from the practice of law in the State 

of Florida or any other state, and that I am not currently suspended from the practice of law before 

any United States Court of Appeals, United States District Court, or United States Bankruptcy 

Court. 

I hereby request authority to appear pro hac vice in this case and in any adversary 

proceedings in this case on behalf of the Official Committee of Unsecured Creditors (“Client”). I 

designate Heather L. Ries (“Local Counsel”), who is qualified to practice in this court, as local 

counsel for the Client. I understand that Local Counsel is required to participate in the preparation 

and the presentation of the case above and any adversary proceedings in which I appear on behalf 

of such Client, and accept service of all papers served in such case and proceedings, unless and 

until other local counsel is designated and accepts such designation by filing a separate Motion to 

Appear Pro Hac Vice on my behalf. 

I certify that I am familiar with and shall and shall be governed by the local rules of this 

court, the rules of professional conduct and all other requirements governing the professional 

behavior of members of the Florida Bar. 

Dated: October 27, 2020 

PACHULSKI STANG ZIEHL & JONES LLP 

780 Third Avenue, 34th Floor 

New York, NY 10017-2024 

Tel: (212) 561-7700 

Fax: (212) 561-7777 

By: /s/ Paul J. Labov

Paul J. Labov 

NJ State Bar No. 039092002 

plabov@pszjlaw.com

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