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Gold/Mining/Energy : USSE - What a scam! -- Ignore unavailable to you. Want to Upgrade?

To: scion who wrote (128)	2/19/2010 5:34:13 PM
From: scion	Read Replies (1) \| Respond to of 226

02/12/2010 19 MEMORANDUM in Support re 18 MOTION for Leave to File Pleading In Camera filed by U. S. Sustainable Energy Corp, John H. Rivera, Alice M. Price (Watson, Benjamin) (Entered: 02/12/2010) Doc 19 PDF file viewer.zoho.com MEMORANDUM BRIEF IN SUPPORT OF DEFENSE COUNSEL’S MOTION FOR LEAVE TO SUBMIT PLEADINGS FOR IN CAMERA REVIEW Defense counsel Thomas O. Gorman and William P. McGrath, Jr. (and their firm, Porter Wright Morris & Arthur LLP), and John C. Henegan and Benjamin M. Watson (and their firm, Butler, Snow, O’Mara, Stevens & Cannada, PLLC) (collectively “defense counsel”) respectfully request leave to submit their Memorandum Brief in Support of their Motion to Withdraw and Declaration of Thomas O. Gorman for in camera review. “A review of the relevant case law demonstrates that documents in support of motions to withdraw as counsel are routinely filed under seal where necessary to preserve the confidentiality of the attorney-client relationship between a party and its counsel, and that this method is viewed favorably by the courts.” Team Obsolete Ltd. v. A.H.R.M.A. Ltd., 464 F. Supp. 2d 164, 165 (E.D.N.Y. 2006). See also, Weinberger v. Provident Life & Cas. Ins. Co., No. 97-cv-9262, 1998 WL 898309, at *1 (S.D.N.Y. Dec. 23, 1998) (“it is appropriate for a Court considering a counsel's motion to withdraw to consider in camera submissions in order to prevent a party from being prejudiced by the application of counsel to withdraw.”); Harrison Conference Servs., Inc. v. Dolce Conference Servs., Inc., 806 F. Supp. 23 (E.D.N.Y. 1992). Accordingly, Defense Counsel respectfully request leave to submit their Memorandum Brief in Support of their Motion to Withdraw and Declaration of Thomas O. Gorman to the Court for in camera review. Dated: February 12, 2010 Respectfully submitted, BUTLER, SNOW, O’MARA, STEVENS & CANNADA, PLLC /s/ Benjamin M. Watson JOHN C. HENEGAN john.henegan@butlersnow.com BENJAMIN M. WATSON, MS Bar No. 100078 ben.watson@butlersnow.com 1020 Highland Colony Parkway Suite 1400 Post Office Box 6010 Ridgeland, MS 39158 Phone: (601) 948-5711 Fax: (601) 985-4500 Thomas O. Gorman (DC Bar No. 398734, admitted pro hac vice) tgorman@porterwright.com William P. McGrath, Jr. (DC Bar No. 422160, admitted pro hac vice) wmcgrath@porterwright.com 1919 Pennsylvania Avenue NW Suite 500 Washington, DC 20006 Phone: (202) 778-3000 Fax: (202) 778-3063 COUNSEL FOR DEFENDANTS U.S. SUSTAINABLE ENERGY CORP., JOHN H. RIVERA, and ALICE M. PRICE

To: scion who wrote (128)	2/25/2010 2:49:41 PM
From: scion	Read Replies (1) \| Respond to of 226

Pacer update 25 Feb 10 SEC v. U. S. Sustainable Energy Corp et al 5:08-cv-00245-DCB-JMR Date Filed # Docket Text 02/25/2010 TEXT ORDER ONLY granting 18 Motion for Leave to File In Camera pleading. No further written order shall be issued by this Court. Signed by Magistrate Judge John M. Roper on February 25,2010 (Nicaud, Jenny) (Entered: 02/25/2010) 02/25/2010 Set/Reset Hearings: Motion Hearing set for 3/18/2010 01:45 PM before Magistrate Judge John M. Roper. The Court finds that a hearing will be held on March 18,2010 in 1:45PM in Gulfport,Ms. Counsel to notify its client of the hearing by certified mail and present a copy of the return receipt to be introduced as an exhibit in at the hearing in this matter or obtain the signature of its client agreeing to the Motion to Withdraw and present the Order to the Court. (Nicaud, Jenny) (Entered: 02/25/2010) 02/23/2010 21 RESPONSE in Opposition re 18 MOTION for Leave to File Pleading In Camera, 17 MOTION to Withdraw as Attorney filed by Securities and Exchange Commission (Rue, Alex) (Entered: 02/23/2010) 02/22/2010 20 NOTICE to Take Deposition of John Rivera, Alice Price by Securities and Exchange Commission (Rue, Alex) (Entered: 02/22/2010) Defendant U. S. Sustainable Energy Corp Defendant John H. Rivera Defendant Alice M. Price ecf.mssd.uscourts.gov