PROCEDURAL HISTORY
6.
On behalf of Plaintiffs, Respondent participated in drafting a Verified
Complaint for Declaratory and Injunctive Relief (the “Initial Complaint”) in Donald
J. Trump for President, Inc. v. Boockvar, which was filed in the United States
District Court for the Middle District of Pennsylvania on November 9, 2020. The
defendants were the Secretary of the Commonwealth of Pennsylvania and the
bipartisan boards of elections of Allegheny County (which included the city of
Pittsburgh), Centre County, Chester County, Delaware County, Montgomery
County, Northampton County, and Philadelphia County (which included the city of
Philadelphia) (collectively “Defendant Counties”).
7.
Respondent was not a member of the Bar of the Middle District of
Pennsylvania, and he did not sign the Initial Complaint nor the accompanying
pleadings.
8.
On November 15, 2020, Plaintiffs filed a First Amended Verified
Complaint for Declaratory and Injunctive Relief. Respondent did not sign the First
Amended Complaint.
9.
On November 17, 2020, Respondent was admitted pro hac vice to the
Middle District of Pennsylvania and argued on behalf of Plaintiffs in opposition to
a Motion to Dismiss the First Amended Complaint.
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