Page 1 of 19IN THE UNITED STATES DISTRICT COURT FOR THEEASTERN DISTRICT OF VIRGINIAAlexandria DivisionUNITED STATES OF AMERICAv.KIM DOTCOM,
,Defendants.)))))))Criminal No. 1:12CR3
OPPOSITION OF THE UNITED STATES TO MOTION OFQUINN EMANUEL URQUHART & SULLIVAN LLP,THE ROTHKEN LAW FIRM, AND CRAIG C. REILLY, ESQ.FOR LEAVE TO ENTER LIMITED AND SPECIAL APPEARANCESON BEHALF OF MEGAUPLOAD LIMITED, KIM DOTCOM,MATHIAS ORTMANN, BRAM VAN DER KOLK & FINN BATATO
Quinn Emanuel Urquhart & Sullivan LLP (“Quinn Emanuel”), The Rothken Law Firm,and Craig C. Reilly, Esq. (collectively, “Defense Counsel”) have requested leave for the secondtime to enter limited appearances in this matter.
Motion of Quinn Emanuel Urquhart & Sullivan LLP, The Rothken Law Firm, andCraig C. Reilly, Esq. for Leave to Enter Limited and Special Appearances on Behalf of Megaupload Limited, Kim Dotcom, Mathias Ortmann, Bram van der Kolk & Finn Batato and toExceed Page Limit & Memorandum in Support Thereof, (May 30, 2012) (Dkt. 96) (hereinafter(“Motion to Enter Limited Appearance”).The United States opposes the motion for fourreasons.
, the proposed limited appearance is inconsistent with Local Criminal Rule57.4(d)(3), which requires counsel to have “such authority that the Court can deal with theattorney alone in all matters connected with the case.”
, prior to entertaining any motionfiled on behalf of Defense Counsel, the Court must address and resolve potential conflicts of interest in their representation of the defendants.
, the motion is premature because thedefendants have not made an initial appearance before this Court, as required by the FederalRules of Criminal Procedure and the fugitive disentitlement doctrine.
, the ultimate relief
Case 1:12-cr-00003-LO Document 104 Filed 06/13/12 Page 1 of 20 PageID# 1109