Case 09-34791-RBR

Case 09-34791-RBR Doc 1636 Filed 04/19/11 Page 1 of 2 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA Fort Lauderdale Division www.flsb.uscourts.gov IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A. Debtor. CASE NO.: 09-34791-RBR CHAPTER 11 NOTICE OF JOINDER IN MOTION FOR LEAVE OF COURT TO DEPOSE AND TAKE RULE 2004 EXAMINATION OF INCARCERATED INDIVIDUAL, SCOTT W. ROTHSTEIN [D.E. 15891 R.L. Pearson and Associates, Inc., a defendant in a separate adversary proceeding initiated by the Trustee' ("Defendant RL Pearson"), by and through undersigned counsel, joins the Motion for Leave of Court to Depose and Take Rule 2004 Examination of Incarcerated Individual, Scott W. Rothstein, filed on April 1, 2011 (the "Motion for Leave"). [D.E. 1589]. Defendant RL Pearson would like the opportunity to question Scott Rothstein regarding issues relevant to the adversary case. If the Motion for Leave is Granted, Defendant RL Pearson anticipates cross-noticing Scott Rothstein for Deposition accordingly. CERTIFICATE OF SERVICE AND COMPLIANCE I hereby certify that I am admitted to the Bar of the U.S. District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this Court as set forth in Local Rule 2090-1(A). I hereby further certify that on April 19, 2011, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also I Herbert Stettin v. RL Pearson And Associates, Inc., Adv. Pro. No.10-3710-BKC-RBR-A EFTA01107711 Case 09-34791-RBR Doc 1636 Filed 04/19/11 Page 2 of 2 certify that the foregoing document is being served this day on counsel, via transmission of Notices of Electronic Filing generated by CM/ECF. Respectfully submitted, HUNTON & WILLIAMS LLP 1111 Brickell Avenue, Suite 2500 Miami, FL 33131 Telephone Facsimile: Attorneys for Defendant R.G. Pearson and Associates, Inc. By: Is/Matthew Mannering Marty Steinberg Florida Bar No. 187293 Laurie Uustal Mathews Florida Bar No. 0120618 Corey Lee Florida Bar No. 44448 Matthew Mannering Florida Bar No. 39300 76524.000006 EMF_US 35221249v2 EFTA01107712