This section contains the nature of the case and procedural background.

Liebowitz was not a member of the bar of the court, but is permitted to practice in this district pursuant to Local Civil Rule 83.1(e). That rule allows an attorney who is not a member of the bar to practice in this district for a particular case, by associating local counsel and filing a notice of special appearance. Rule 83.1(e) specifically provides: A special appearance is not a substitute for admission to the bar of this court, but rather is intended to facilitate occasional appearances only. Unless otherwise ordered for good cause shown, no attorney may be admitted pursuant to Local Civil Rule 83.1 in more than three unrelated cases in any twelve-month period, nor may any attorney be admitted pursuant to Local Civil Rule 83.1 in more than three unrelated cases at any one time. Prior to representing P, Liebowitz made special appearances in three other unrelated cases in this district in the 2019 calendar year.

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