IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OKLAHOMA. MARY BISHOP, et al., Plaintiffs, v. No. 04-CV-848-TCK-TLW UNITED STATES OF AMERICA, ex rel., ERIC H. HOLDER, IR., et al., Defendants. PLAINTIFFS’ RESPONSE AND OBJECTION TO MOTIONS FOR ADMISSION OF ATTORNEYS JAMES A. CAMPBELL, DALE SCHOWENGERDT, AUSTIN R. NIMOCKS, AND BRIAN W. RAUM PRO HAC VICE Plaintiffs submit the following objection to Defendant Sally Howe Smith’s motion to admit attorneys James A. Campbell, Dale Schowengerdt, Austin R. Nimocks, and Brian W. Raum pro hac vice (Doc. Nos. 149, 151, 153, 155) in the instant case. In support thereof, Plaintiffs state: 1. Local rule requires that an attorney, “representing a party in this Court” must associate themselves with an attorney personally appearing in the action and admitted to practice in this Court. LCvR 83.3(a) (Emphasis added). 2. Defendant's motions seek pro hac vice admission of attomeys James A. Campbell, Dale Schowengerdt, Austin R. Nimocks, and Brian W. Raum for the vague and conclusory purpose of “participating in this matter.” Defendant's motions neither specify whose interests these attorneys purport to represent, nor does it refute the notion of whether such attorneys seek admission for the purpose of representing a non-party, the AllianceDefense Fund (“ADF”),' in this matter. As Defendant's motion reads, the court clerk, an agent of the State of Oklahoma, and the State by consequence, is attempting to be represented by a public advocacy group. Thus, absent an express representation that these movant attorneys intend to represent a party in this Court and not their employer, the Alliance Defense Fund, admission should be denied. If ADF desires to participate in this lawsuit, it should straightforwardly seek intervenor status.” Accordingly, Plaintiffs request said motions be denied for failure to adhere to this Court’s local rules and to adequately ensure this Court’s previous order is followed. WHEREFORE, Plaintiffs request that Defendant Sally Howe Smith’s motion to admit attorneys James A. Campbell, Dale Schowengerdt, Austin R. Nimocks, and Brian W. Raum pro hac vice be denied. ‘According to its website, the Alliance Defense Fund is a “legal alliance” with the stated goal of defending the right to hear and speak the Truth through strategy, training, funding, and litigation. (Ex. 1). >This Court previously denied a motion brought by ADF attorney Kevin H. Theriot to intervene on behalf of then-State Representative Thad Balkman and Oklahomans for Protection of Marriage, Inc. (Doc. Nos. 4 & 90).Respectfully Submitted, s/Don G. Holladay Don G. Holladay, OBA No. 4294 James E. Warner II, OBA No, 19593 HOLLADAY & CHILTON PLLC 204 N. Robinson, Suite 1550 Oklahoma City, OK 73102 (405) 236-2343 - office (405) 236-2349 - facsimile ATTORNEYS FOR PLAINTIFFS CERTIFICATE OF SERVICE Thereby certify that on March 23, 2010, I electronically transmitted the foregoing document to the Clerk of Court using the ECF System for filing and transmittal of a Notice of Electronic Filing to the following ECF registrants: W. Scott Simpson UNITED STATES DEPARTMENT OF JUSTICE FEDERAL PROGRAMS BRANCH-CIVIL DIVISION P.O. Box 883 ‘Washington, DC 20044 scott simpson@usdoj.gov David T. Iski TULSA COUNTY DISTRICT ATTORNEY Tulsa County Courthouse 500 S. Denver Ave., Suite 900 Tulsa, OK 74103 diski@tulsacounty.org s/Don G. Holladay