Tentative Rulings

Case Number: *******3693 Hearing Date: October 27, 2021 Dept: 26

Superior Court of California

County of Los Angeles

Department 26

Steven J. Pacini (“Pacini”) and Anna Nicole Karnaze (“Karnaze”) apply as counsel pro hac vice for Plaintiff Endeavor Operating Company. The applications are unopposed.

Under CRC Rule 9.40, attorneys licensed and in good standing in other states may, upon the California court’s approval, appear as counsel pro hac vice in a pending case if an active member of the state bar is associated as attorney of record. (CRC 9.40(a).) Pacini is an active member, in good standing, of the Bar of the Commonwealth of Massachusetts, and the United States District Court for the District of Massachusetts, (Pacini Decl. ¶¶ 3-5.) In addition, Pacini states that he is not a resident of California or regularly engaged in business in Califonia and is a resident of Cotuit, Massachusetts with an office in Boston, Massachusetts. (Pacini Decl. ¶¶ 1-2, 7.) Pacini states states that he has not applied to appear as counsel pro hac vice in the last two years. (Pacini Decl. ¶ 6.)

Karnaze is an active member, in good standing, of the Commonwealth of Massachusetts, the United States District Court for the District of Massachusetts, and the State of New York. (Karnaze Decl. ¶¶ 3-5.) In addition, Karnaze states that she is not a resident of California or regularly engaged in business in Califonia and is a resident of Chicago, Illinoiswith an office in Boston, Massachusetts. (Karnaze Decl. ¶¶ 1-2, 7.) Karnaze states that she has not applied to appear as counsel pro hac vice in the last two years. (Karnaze Decl. ¶ 6.) Thus, Counsels satisfy the eligibility requirements of CRC 9.40(a).

Pacini’ and Karnaze’s applications successfully address all six content requirements outlined in CRC 9.40(d). Specifically, Pacini and Karnaze provides in their respective applications: (1) their residence and office address (Pacini Decl. ¶¶ 1-2; Karnaze Decl. ¶¶ 1-2); (2) the courts to which each Counsel has been admitted to practice and the dates of admission (Pacini Decl. ¶ 3-4; Karnaze Decl. ¶ 3-4); (3) that they are a member in good standing in those courts (Pacini Decl. ¶ 5; Karnaze Decl. ¶ 5); (4) that they are not currently suspended or disbarred in any court (Pacini Decl. ¶ 5; Karnaze Decl. ¶ 5); (5) the title of each court and cause in which the applicant has filed an application to appear as counsel pro hac vice in this state in the preceding two years, the date of each application, and whether or not it was granted (Pacini Decl. ¶ 6; Karnaze Decl. ¶ 6); and (6) the name, address, and telephone number of an active members, Robert J. Gilbert, David A. Barrett, Kirsten C. Jackson, and Dorn G. Bishop, of the State Bar of California who is the current counsel of record for Plaintiff Endeavor Operating Company (Pacini Decl. ¶ 8; Karnaze Decl. ¶ 8).

Furthermore, Pacini and Karnaze provide the declaration of Robert J. Gilbert, demonstrating that they both meet the requirement of CRC 9.40(c)(1). That rule provides: “a person desiring to appear as counsel pro hac vice in a superior court must file with the court a verified application together with proof of service . . . of a copy of the application and of the notice on all parties who have appeared in the cause and on the State Bar of California at its San Francisco office.” (Gilbert Decl. ¶ 3.)

CONCLUSION AND ORDER

The applications of Steven J. Pacini and Anna Nicole Karnaze to appear as counsel pro hac vice for Plaintiff Endeavor Operating Company are GRANTED.

The Moving Parties are ordered to provide notice of this order and file a proof of service of such.

DATED: October 27, 2021 ___________________________

Elaine Lu

Judge of the Superior Court

________________________________________________________________________________________________________

Superior Court of California

County of Los Angeles

Department 26

Kristin C. Cummings (“Cummings”) and Seth V. Jackson (“Jackson”) apply as counsel pro hac vice for Defendant HDI Global Insurance Company. The applications are unopposed.

Under CRC Rule 9.40, attorneys licensed and in good standing in other states may, upon the California court’s approval, appear as counsel pro hac vice in a pending case if an active member of the state bar is associated as attorney of record. (CRC 9.40(a).) Cummings is an active member, in good standing, of the United States District Court, Eastern District of Texas, the United States District Court, Northern District of Texas, the United States District Court, Southern District of Texas, the United States District Court, Western District of Texas, the United States District Court, Western District of Oklahoma, the United States District Court, District of Colorado, and the Supreme Court of Texas. (Cummings Decl. ¶¶ 6-8.) In addition, Cummings states that she is not a resident of California or regularly engaged in business in Califonia and is a resident of Coppell, Texas with an office in Dallas Texas. (Cummings Decl. ¶¶ 2-5.) Cummings states that she has previously applied as counsel pro hac vice in five action in the past two years and was approved in each. (Cummings Decl. ¶ 9.)

Jackson is an active member, in good standing, of the Commonwealth of Massachusetts, the United States District Court for the District of Massachusetts, and the State of New York. (Jackson Decl. ¶¶ 6-8.) In addition, Jackson states that he is not a resident of California or regularly engaged in business in Califonia and is a resident of Franklin, Massachusetts with an office in Framingham, Massachusetts. (Jackson Decl. ¶¶ 2-5.) Jackson states that he has not applied to appear as counsel pro hac vice in the last two years. (Jackson Decl. ¶ 9.) Thus, Counsels satisfy the eligibility requirements of CRC 9.40(a).

Cummings’ and Jackson’s applications successfully address all six content requirements outlined in CRC 9.40(d). Specifically, Cummings and Jackson provides in their respective applications: (1) their residence and office address (Cummings Decl. ¶¶ 4-5; Jackson Decl. ¶¶ 4-5); (2) the courts to which each Counsel has been admitted to practice and the dates of admission (Cummings Decl. ¶ 7; Jackson Decl. ¶ 7); (3) that they are a member in good standing in those courts (Cummings Decl. ¶ 6; Jackson Decl. ¶ 6); (4) that they are not currently suspended or disbarred in any court (Cummings Decl. ¶ 8; Jackson Decl. ¶ 8); (5) the title of each court and cause in which the applicant has filed an application to appear as counsel pro hac vice in this state in the preceding two years, the date of each application, and whether or not it was granted (Cummings Decl. ¶ 9; Jackson Decl. ¶ 9); and (6) the name, address, and telephone number of an active member, Thomas J. D’Antonio, of the State Bar of California who is the current counsel of record for Defendant HDI Global Insurance Company (Cummings Decl. ¶ 10; Jackson Decl. ¶ 10).

Furthermore, Cummings and Jackson provide proof of service, demonstrating that they both meet the requirement of CRC 9.40(c)(1). That rule provides: “a person desiring to appear as counsel pro hac vice in a superior court must file with the court a verified application together with proof of service . . . of a copy of the application and of the notice on all parties who have appeared in the cause and on the State Bar of California at its San Francisco office.” (Cummings Decl., Ex. A; Jackson Decl., Ex. A.)

CONCLUSION AND ORDER

The applications of Kristin C. Cummings and Seth V. Jackson to appear as counsel pro hac vice for Defendant HDI Specialty Insurance Company are GRANTED.

The Moving Parties are ordered to provide notice of this order and file a proof of service of such.

DATED: October 27, 2021 ___________________________

Elaine Lu

Judge of the Superior Court

__________________________________________________________________________________________________________

Superior Court of California

County of Los Angeles

Department 26

G. Richard Dodge, Jr. (“Dodge”), Erin E. Bradham (“Bradham”), and M. Kaith Moskowitz (“Moskowitz”) apply as counsel pro hac vice for Defendant AIG Specialty Insurance Company. The applications are unopposed.

Under CRC Rule 9.40, attorneys licensed and in good standing in other states may, upon the California court’s approval, appear as counsel pro hac vice in a pending case if an active member of the state bar is associated as attorney of record. (CRC 9.40(a).) Dodge is an active member, in good standing, of the State Bar for District of Columbia, State Bar for New York, U.S. Court of Appeals for the Second Circuit, U.S. District Court for the Eastern District of New York, U.S. District Court for the Southern District of New York, and U.S. District Court for the District of Columbia. (Dodge Decl. ¶¶ 6-8.) In addition, Dodge states that he is not a resident of California or regularly engaged in business in Califonia and is a resident of Washington D.C. with an office in Washington D.C. (Dodge Decl. ¶¶ 2-5.) Dodge states that he previously applied as counsel pro hac vice in California for General Star Idemnity Company, et al. v. JRK Property Holdings, Inc. in the United States District Court, Central District of California on July 6, 2021 and was approved. (Dodge Decl. ¶ 9.)

Bradham is an active member, in good standing, of the State Bar of Arizona, the United States District Court for the District of Arizona, and the 9^th Circuit Court of Appeals. (Bradham Decl. ¶¶ 6-8.) In addition, Bradham states that she is not a resident of California or regularly engaged in business in Califonia and is a resident of Phoenix, Arizona with an office in Phoenix, Arizona. (Bradham Decl. ¶¶ 2-5.) Bradham states that she has previously applied as counsel pro hac vice in four action in the past two years and was approved in each. (Bradham Decl. ¶ 9.)

Moskowitz is an active member, in good standing, of the State Bar of Connecticut, the State Bar of New York, the State Bar of Illinois, the US District Court for the Northern District of Illinois, the US District Court for the Southern District of Illinois, the US District Court for the Central District of Illinois, and the 9^th Circuit Court of Appeals. (Moskowitz Decl. ¶¶ 6-8.) In addition, Moskowitz states that he is not a resident of California or regularly engaged in business in Califonia and is a resident of Chicago, Illinois with an office in Chicago, Illinois. (Moskowitz Decl. ¶¶ 2-5.) Moskowitz states that he has previously applied as counsel pro hac vice in five actions in the past two years and was approved in each. (Moskowitz Decl. ¶ 9.) Thus, Counsels satisfy the eligibility requirements of CRC 9.40(a).

Dodge’s, Bradham’s, and Moskowitz’s applications successfully address all six content requirements outlined in CRC 9.40(d). Specifically, Dodge, Bradhamn, and Moskowitz provides in their respective applications: (1) their residence and office address (Dodge Decl. ¶¶ 4-5; Bradham Decl. ¶¶ 4-5; Moskowitz Decl. ¶¶ 4-5); (2) the courts to which each Counsel has been admitted to practice and the dates of admission (Dodge Decl. ¶ 7; Bradham Decl. ¶ 7; Moskowitz Decl. ¶ 7); (3) that they are a member in good standing in those courts (Dodge Decl. ¶ 6; Bradham Decl. ¶ 6; Moskowitz Decl. ¶ 6); (4) that they are not currently suspended or disbarred in any court (Dodge Decl. ¶ 8; Bradham Decl. ¶ 8; Moskowitz Decl. ¶ 8); (5) the title of each court and cause in which the applicant has filed an application to appear as counsel pro hac vice in this state in the preceding two years, the date of each application, and whether or not it was granted (Dodge Decl. ¶ 9; Bradham Decl. ¶ 9; Moskowitz Decl. ¶ 9); and (6) the name, address, and telephone number of an active member, Julia M. Beckley, of the State Bar of California who is the current counsel of record for Defendant AIG Specialty Insurance Company (Dodge Decl. ¶ 10; Bradham Decl. ¶ 10; Moskowitz Decl. ¶ 10).

Furthermore, Dodge, Bradham, and Moskowitz provide proof of service, demonstrating that they both meet the requirement of CRC 9.40(c)(1). That rule provides: “a person desiring to appear as counsel pro hac vice in a superior court must file with the court a verified application together with proof of service . . . of a copy of the application and of the notice on all parties who have appeared in the cause and on the State Bar of California at its San Francisco office.”

CONCLUSION AND ORDER

The applications of G. Richard Dodge, Jr., Erin E. Bradham, and M. Kaith Moskowitz to appear as counsel pro hac vice for Defendant AIG Specialty Insurance Company are GRANTED.

The Moving Parties are ordered to provide notice of this order and file a proof of service of such.

DATED: October 27, 2021 ___________________________

Elaine Lu

Judge of the Superior Court