chiquita collingsworth scherer motion to substitute counsel
DESCRIPTION
Conrad & Scherer seeks to withdraw as counsel for Does 1-144, who are the first clients obtained by myself (Paul Wolf) in what turned into a multi district case against Chiquita Brands.TRANSCRIPT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
Case No. 08-01916-MD-MARRA/JOHNSON IN RE: CHIQUITA BRANDS INTERNATIONAL, INC., ALIEN TORT STATUTE AND SHAREHOLDER DERIVATIVE LITIGATION ____________________________________________/ This Document Relates To: ATS ACTION _______________________________________________/ Case No. 9:08-cv-80465-KAM DOES (1-144), PEREZES (1-95), PEREZES (96-795), and Carmen Tulia Cordoba Cuesta, et al. Plaintiffs, v. CHIQUITA BRANDS INTERNATIONAL, INC., et al. Defendants ____________________________________________/
MOTION TO SUBSTITUTE COUNSEL AND NOTICE OF APPEARANCE
International Rights Advocates, on behalf of Plaintiffs DOES (1-144), PEREZES (1-95),
PEREZES (96-795), and Carmen Tulia Cordoba Cuesta, et al., and Conrad & Scherer LLP
jointly request an order for substitution of counsel and state as follows:
1. An order substituting International Rights Advocates for Conrad & Scherer LLP
as counsel for Plaintiffs is appropriate and necessary here.
2. Terrence P. Collingsworth formerly represented Plaintiffs in this action while
working at Conrad & Scherer.
3. Mr. Collingsworth now works at another organization, International Rights
Advocates, and continues to represent Plaintiffs.
4. Mr. Collingsworth and Conrad & Scherer are in the process of making reasonable
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efforts to provide Plaintiffs, who number over two thousand, with written notice indicating that
Conrad & Scherer and Mr. Collingsworth have agreed that Plaintiffs’ cases are being transferred
to Mr. Collingsworth’s organization.
5. Two current Conrad & Scherer lawyers also represent Plaintiffs in this action:
William R. Scherer and Eric J. Hager. The requested substitution will result in Mr. Scherer and
Mr. Hager, and Conrad & Scherer more generally, no longer representing Plaintiffs. Mr. Scherer
and Mr. Hager’s names should be removed from the CM/ECF docket upon entry of a substitution
order.
6. Substitution should be allowed because Plaintiffs will continue to have adequate
legal representation. Mr. Collingsworth and others working with him at International Rights
Advocates have litigated human rights cases in courts throughout the U.S. for many years. Mr.
Collingsworth has been active in this litigation for several years and has been the lead lawyer for
Conrad & Scherer on this matter during that time. In addition, because this is a multi-district
litigation, there are several other capable law firms litigating the common issues in this action.
Mr. Collingsworth regularly collaborates with those other law firms.
7. The requested substitution will not cause any delay in this action. A trial date has
not yet been set. Rather, motions to dismiss are pending and awaiting decision.
8. This motion also serves as Mr. Collingsworth’s notice of appearance and notice of
change of contact information. Mr. Collingsworth originally entered an appearance on behalf of
Plaintiffs in the United States District Court for the District of Columbia. Mr. Collingsworth’s
mailing and physical business address, phone number, and email address have changed. His new
contact information is in the signature block below.
For the foregoing reasons, movants request that International Rights Advocates be
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substituted as Plaintiffs’ attorneys in place of Conrad & Scherer LLP.
DATED: December 18, 2015 Respectfully submitted,
/s/ Terrence P. Collingsworth International Rights Advocates Terrence P. Collingsworth (admitted Pro Hac Vice) 621 Maryland Avenue NE Washington, D.C. 20002 Phone: 202-255-2198 Email: [email protected] Attorney for Plaintiffs, DOES 1-144, PEREZES 1-95, PEREZES 96-795, and Carmen Tulia Cordoba Cuesta et al.
/s/ William R. Scherer Conrad & Scherer LLP William R. Scherer (Fla. Bar No. 169454) 633 South Federal Highway, 8th Floor Fort Lauderdale, Florida 33301 Phone: 954-462-5500 Fax: 954-463-9244 Email: [email protected]
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