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Case l:17-cr-00182-RDM Document 14 Filed 10/04/17 Page 1 of 5 


FILED 

OCT OH 2017 

Clerk, U.S. District & Bankruptcy 

UNITED STATES DISTRICT COURT Courts forthe District of Columbia 

FOR THE DISTRICT OF COLUMBIA 

UNITED STATES OF AMERICA ) 

v. ) nar\ui®w) 

) 

GEORGE PAPADOPOULOS ) 

MOTION TO APPEAR PRO HAC VICE 

Thomas M. Breen and Robert W. Stanley, attorneys for Defendant George 
Papadopoulos, pursuant to Local Criminal Rule 44.1(d), respectfully moves this 
Honorable Court for their admission and appearance pro hac vice in the above 
captioned matter, and to waive the requirement that counsel have a sponsoring 
member in good standing of the bar of this Court sign the instant motion. In 
support thereof, Counsel shows to the Court the following: 

1. As set forth in the attached declarations, Counsel are admitted and 
active members in good standing of the Bar of the State of Illinois, the United 
States District Court for the Northern and Central Districts of Illinois, and the 
United States Court of Appeals for the Seventh Circuit. Further, Counsel has no 
pending disciplinary proceedings against them and have not previously been 
disciplined by any bar. 

2. Since approximately February 2017, Counsel has represented 
Defendant during the FBI’s investigation into the Russian government’s efforts to 
interfere with the 2016 presidential election. 



Case l:17-cr-00182-RDM Document 14 Filed 10/04/17 Page 2 of 5 


3. On July 28, 2017, Defendant was arrested for making a false 
statement to the FBI and for obstruction of justice. Defendant’s arrest and the 
criminal complaint were sealed by the Court and have remained under seal. 

4. Since his arrest, Defendant has made efforts to cooperate with Special 
Counsel’s investigation by participating in multiple proffer sessions and voluntarily 
turning over materials at the request of investigators. The parties have now 
reached a negotiated resolution to the charges pending against Defendant. 

5. Specifically, on October 5, 2017, the parties will enter into a plea 
agreement, where in exchange for dismissing the criminal complaint, and forgoing 
other charges related to Defendant’s conduct as outlined in the plea agreement, 
Defendant will plead guilty to making a false statement to the FBI in violation of 18 
U.S.C. 1001. The parties anticipate requesting the Court delay Defendant’s 
sentencing to allow Defendant to continue his efforts to cooperate with the Special 
Counsel’s investigation. Additionally, to facilitate any further cooperation by 
Defendant, the parties have requested that Defendant’s plea be taken in a closed 
courtroom and the case remain under seal for a period of time. 

6. Local Criminal Rule 44.1(d) requires counsel seeking admission pro 
hac vice to file a motion signed by a member of the bar of this Court. For Counsel to 
obtain a sponsoring member of this Court’s bar, it would be necessary to inform the 
sponsoring member of the existence and nature of this case. 


2 



Case l:17-cr-00182-RDM Document 14 Filed 10/04/17 Page 3 of 5 


7. Given the sensitive subject matter and underlying facts of this case, 
Counsel submits that obtaining a sponsoring member is impractical and not in the 
best interests of Defendant. 

Wherefore, Counsel respectfully requests the Court grant their motion to 
appear pro hac vice and waive the requirement of Local Criminal Rule 44.1(d) that 
the motion be signed by a member of the bar of this Court. 

Respectfully submitted, 

Is/ Thomas M. Breen 

BREEN & PUGH 
53 W. Jackson Blvd. 

Suite 1215 
Chicago, IL 60604 
(312) 360-1001 


3 



Case l:17-cr-00182-RDM Document 14 Filed 10/04/17 Page 4 of 5 


UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 

UNITED STATES OF AMERICA ) 

) 

v. ) No. 1-17-MJ-539 

) 

GEORGE PAPADOPOULOS ) 

DECLARATION OF THOMAS M. BREEN 
IN SUPPORT OF HIS MOTION FOR ADMISSION PRO HAC VICE 

1. My name is Thomas M. Breen, counsel for George Papadopoulos, I am 
a member of the law firm Breen & Pugh. 

2. My office is located at 53 West Jackson Boulevard, Suite 1215, 

Chicago, Illinois 60604. My office telephone number is (312) 360-1001. 

3. I am a member in good standing of the Bar of the State of Illinois. I am 
also admitted to practice in the United States District Court for the Northern 
District of Illinois and the Central District of Illinois. 

4. I certify that there are no pending disciplinary proceedings against me 
before any bar, and I have not previously been disciplined by any bar. 

5. I have not previously been admitted pro hac vice before this Court. 

6. I do not engage in the practice of law from any office located in the 
District of Columbia. 

I declare under the penalty of perjury that the foregoing is time and correct. 


Dated: October 4, 2017 




Case l:17-cr-00182-RDM Document 14 Filed 10/04/17 Page 5 of 5 


UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 

UNITED STATES OF AMERICA ) 

) 

v. ) No. 1-17-MJ-539 

) 

GEORGE PAPADOPOULOS ) 

DECLARATION OF ROBERT W. STANLEY 
IN SUPPORT OF HIS MOTION FOR ADMISSION PRO HAC VICE 

1. My name is Robert W. Stanley, counsel for George Papadopoulos, I am 
a member of the law firm Breen & Pugh. 

2. My office is located at 53 West Jackson Boulevard, Suite 1215, 

Chicago, Illinois 60604. My office telephone number is (312) 360-1001. 

3. I am a member in good standing of the Bar of the State of Illinois. I am 
also admitted to practice in the United States District Court for the Northern 
District of Illinois and the United States Court of Appeals for the Seventh Circuit. 

4. I certify that there are no pending disciplinary proceedings against me 
before any bar, and I have not previously been disciplined by any bar. 

5. I have not previously been admitted pro hac vice before this Court. 

6. I do not engage in the practice of law from any office located in the 
District of Columbia. 

I declare under the penalty of perjury that the foregoing is true and correct. 
Dated: October 4, 2017