Moon v. Meadows Defendant-Intervenors' Motion for Order Allowing Withdrawal and Pro Hac Vice Admittance of Counsel

    IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division

DONALD MOON 
and ROBERT SMITH,

Plaintiffs,
v. No. 3:95 CV 942

M. BRUCE MEADOWS,
Defendant,

and
CURTIS W. HARRIS; JAYNE W. BARNARD;
JEAN PATTERSON BOONE; RAYMOND H. BOONE;
WILLIE J. DELL; HENRY C. GARRARD, SR.;
WALTER T. KENNEY, SR.; MELVIN R. SIMPSON; 
and GERALD T. ZERKIN,

Defendant-Intervenors.

DEFENDANT-INTERVENORS' MOTION
FOR ORDER ALLOWING WITHDRAWAL 

AND PRO HAC VICE ADMITTANCE OF COUNSEL

Defendant-intervenors in this case hereby move the Court 
for an Order allowing two of their attorneys, Mary Wyckoff 
and Stephen B. Pershing, leave to withdraw as counsel, and 
permitting another of their attorneys, Neil Bradley, to 
appear pro hac vice.

Ms. Wyckoff and Mr. Pershing are each leaving the employ 
of their respective American Civil Liberties Union 
organizations and will be unable to serve as counsel in this 
case after May 10, 1996. Mr. Bradley is associate director 
and senior staff counsel at the Southern Regional Office of 
the American Civil Liberties Union Foundation in Atlanta, and



his name has been set forth on the defendant-intervenors' 
previous filings in this case. Mr. Bradley is a member of 
the bars of Georgia and Wisconsin, and is admitted to 
practice before the United States Supreme Court, the United 
States Courts of Appeals for the Third, Fourth, Fifth and 
Eleventh Circuits, and the United States District Court for 
the Northern District of Georgia and other tribunals.

Wherefore, defendant-intervenors respectfully reguest 
that the Court permit the withdrawal and the pro hac vice 
admittance, as the case may be, of the attorneys named 
herein.

Respectfully submitted,

STEPHEN B. PERSHING 
Virginia Bar No. 31012 
American Civil Liberties Union 
Foundation of Virginia, Inc.
6 North Sixth Street, Suite 400 
Richmond, Virginia 23219 
(804) 644-8080
MARY WYCKOFF
American Civil Liberties Union
Foundation
132 West 43d Street
New York, NY 10036
(212) 944-9800, ext. 660
M. LAUGHLIN MCDONALD 
NEIL BRADLEY 
MAHA S. ZAKI
American Civil Liberties 

Union Foundation, Inc.
44 Forsyth Street, N.W.
Suite 202 
Atlanta, GA 30303 
(404) 523-2721



J. GERALD HEBERT 
Virginia Bar No. 38432 
800 Parkway Terrace 
Alexandria, Virginia 22302 
(703) 684-3585
ELAINE R. JONES 
Director-Counsel 
THEODORE M. SHAW 
NORMAN J. CHACHKIN 
NAACP Legal Defense and 

Educational Fund, Inc.
99 Hudson Street, Suite 1600 
New York, New York 10013 
(212) 219-1900
PENDA HAIR 
CASSANDRA Q. BUTTS 
NAACP Legal Defense and 

Educational Fund, Inc.
1275 K Street, N.W., Suite 301 
Washington, DC 20005 
(202) 682-1300
PAMELA S. KARLAN 
580 Massie Road 
Charlottesville, VA 22903 
(804) 924-7810

ATTORNEYS FOR DEFENDANT-INTERVENORS
Dated:

CERTIFICATE OF SERVICE
\  O  ^  ’I certify that on this ____ day of _______________,

1996, I mailed the foregoing motion for order allowing 
withdrawal and pro hac vice admittance of counsel, with 
proposed order, first class, postage prepaid, to Stephen A. 
Katsurinas, Esq., Hirsch, Robinson, Sheiness & Glover, 700 
East Main Street, Suite 1603, Richmond, VA 23219, and Paul 
Loy Hurd, Esq., 1101 Royal Avenue, P.0. Box 2190, Monroe, LA 
71207, counsel for plaintiffs; and to Mary E. Shea, Esq., 
Office of the Virginia Attorney General, 900 East Main 
Street, Richmond, VA 23219, counsel for defendants.



IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF VIRGINIA

Richmond Division

DONALD MOON
and ROBERT SMITH,

Plaintiffs,
v . No. 3:95 CV 942

M. BRUCE MEADOWS,
Defendant,

and
CURTIS W. HARRIS; JAYNE W. BARNARD;
JEAN PATTERSON BOONE; RAYMOND H. BOONE; 
WILLIE J. DELL; HENRY C. GARRARD, SR.; 
WALTER T. KENNEY, SR.; MELVIN R. SIMPSON; 
and GERALD T. ZERKIN,

Defendant-Intervenors.

ORDER ADMITTING DEFENDANT-INTERVENORS' 
COUNSEL PRO HAC VICE

Defendant-intervenors in the above-captioned case have 
moved the Court for an Order allowing two of their counsel, 
Mary Wyckoff and Stephen B. Pershing, to withdraw their 
appearances, and another of their counsel, Neil Bradley, to 
appear pro hac vice.

For good cause shown, IT IS SO ORDERED.

United States District Judge
Dated: