Opinion
2:22-cv-01392-GMN-BNW
11-09-2022
Richard Klein and Raymond Urias, individually and on behalf of all others similarly situated, Plaintiffs, v. National Collegiate Student Loan Trust aka I National Collegiate Master Student Loan Trust I, National Collegiate Student Loan Trust 20031, National Collegiate Student Loan Trust 2004-1, National Collegiate Student Loan Trust 2004-2, National Collegiate Student Loan Trust 2005-1, National Collegiate Student Loan Trust 2005-2, National Collegiate Student Loan Trust 2005-3, National Collegiate Student Loan Trust 2006-1, National Collegiate Student Loan Trust 2006-2, National Collegiate Student Loan Trust 2006-3, National Collegiate Student Loan Trust 2006-4, National Collegiate Student Loan Trust 2007-1, National Collegiate Student Loan Trust 2007-2, National Collegiate Student Loan Trust 2007-3, and National Collegiate Student Loan Trust 2007-4, Defendants.
WRIGHT, FINLAY & ZAK, LLP Darren T. Brenner, Esq., Ramir M. Hernandez, Esq. Attorneys for Defendants National Collegiate Master Student Loan Trust I, National Collegiate .Student Loan Trust (“NCSLT”) 2003-1, NCSLT 2004-1, NCSLT 2004-2, NCSLT 2005-1, NCSLL \\2005-2, NCSLT2005-3, NCSLT2006-1, NCSLT2006-2, NCSLT2006-3, NCSLT2006-4, NCSLL \2007-l, NCSLT2007-2, NCSLT2007-3, andNCSLT2007-4
WRIGHT, FINLAY & ZAK, LLP Darren T. Brenner, Esq., Ramir M. Hernandez, Esq. Attorneys for Defendants National Collegiate Master Student Loan Trust I, National Collegiate .Student Loan Trust (“NCSLT”) 2003-1, NCSLT 2004-1, NCSLT 2004-2, NCSLT 2005-1, NCSLL \\2005-2, NCSLT2005-3, NCSLT2006-1, NCSLT2006-2, NCSLT2006-3, NCSLT2006-4, NCSLL \2007-l, NCSLT2007-2, NCSLT2007-3, andNCSLT2007-4
VERIFIED PETITION FOR PERMISSION TO PRACTICE IN THIS CASE ONLY BY ATTORNEY NOT ADMITTED TO THE BAR OF THIS COURT AND DESIGNATION OF LOCAL COUNSEL
FILING FEE IS $ 250.00
GLORIA M. NAVARRO, DISTRICT JUDGE
II
1. That Petitioner is an attorney at law and a member of the law firm of Locke Lord LLP with offices at 200 Vesey Street, 20th Floor, New York, NY 10281, (212) 415-8600, rderose@lockelord.com.
2. That Petitioner has been retained by Defendants, National Collegiate Master Student Loan Trust I, National Collegiate Student Loan Trust (“NCSLT”) 2003-1, NCSLT 20041, NCSLT 2004-2, NCSLT 2005-1, NCSLT 2005-2, NCSLT 2005-3, NCSLT 2006-1, NCSLT 2006-2, NCSLT 2006-3, NCSLT 2006-4, NCSLT 2007-1, NCSLT 2007-2, NCSLT 2007-3, and NCSLT 2007-4, incorrectly sued as unknown purported entity “NCSLT aka National Collegiate Master Student Loan Trust I, NCSLT 2003-1, NCSLT 2004-1, NCSLT 2004-2, NCSLT 2005-L NCSLT 2005-2, NCSLT 2005-3, NCSLT 2006-1, NCSLT 2006-2, NCSLT 2006-3, NCSLT 20064, NCSLT 2007-1, NCSLT 2007-2, NCSLT 2007-3, and NCSLT 2007-4,” to provide legal I representation in connection with the above-entitled case now pending before this Court.
3. That since June 7, 2004, Petitioner has been and presently is a member in good standing of the bar of the highest Court of the State of New York where Petitioner regularly J J practices law. Petitioner shall attach a certificate from the state bar- or from the clerk of the supreme IJ court or highest admitting court of each state territory, or insular possession of the United States in which applicant has been admitted to practice law certifying the applicant's membership therein is in good standing.
4. That Petitioner was admitted to practice before the following United States District JI Courts, United States Circuit Courts of Appeal, the Supreme Court of the United States and Courts IJ of other States on the dates indicated for each, and that Petitioner is presently a member in good 11 standing of the bars of said Courts.
Court Date Admitted Bar Number Supreme Court of New York 6/7/2004 4241683 United States District Court of the Eastern District of New York 5/11 /2005 -- United States District Court of the Southern District of New York 4/12/2005 -- United States District Court of the Western District of Michigan 3/23/2017 -- United States Court of Appeals for the Second Circuit 10/12/2016 -- 3 United States Court of Appeals for the Sixth Circuit 8/8/2017 -- United States Court of Appeals for the Seventh Circuit 10/26/2011 -- United States Court of Appeals for the Eighth Circuit 9/14/2018 -- United States Court of Appeals for the Ninth Circuit 12/17/2009
5. That there have been no disciplinary proceedings instituted against Petitioner, nor any suspension of any license, certificate or privilege to appear before any judicial, regulatory or administrative body, or any resignation or termination in order to avoid disciplinary or disbarment proceedings.
6. That Petitioner has never been denied admission to the State Bar of Nevada.
7. That Petitioner is a not a member of good standing in any Bar Associations.
8. Petitioner has not filed any applications to appear as counsel under Local Rule IA 11-2 (formerly LR IA 10-2) during the past three (3) years.
9. Petitioner consents to the jurisdiction of the courts and disciplinary boards of the State of Nevada with respect to the law of this state governing the conduct of attorneys to the same extent as a member of the State Bar of Nevada.
10. Petitioner agrees to comply with the standards of professional conduct required of the members of the bar of this court.
11. Petitioner has disclosed in writing to the client that the applicant is not admitted to practice in this jurisdiction and that the client has consented to such representation.
Petitioner respectfully prays that Petitioner be admitted to practice before this Court FOR THE PURPOSES OF THIS CASE ONLY.
R. James DeRose III, Petitioner, being first duly sworn, deposes and says: That the foregoing statements are true.
Subscribed and sworn to before me this 8th day of November, 2022.
DESIGNATION OF RESIDENT ATTORNEY ADMITTED TO THE BAR OF THIS COURT AND CONSENT THERETO.
Pursuant to the requirements of the Local Rules of Practice for this Court, the Petitioner believes it to be in the best interests of the clients to designate Ramir M. Hernandez, Attorney at Law, membei of the State of Nevada and previously admitted to practice before the above-entitled Court as associate resident counsel in this action. The address and email address of said designated Nevada counsel is:
WRIGHT, FINLAY & ZAK, LLP
7785 W. Sahara Ave, Suite 200
Las Vegas, NV 89117
(702) 475-7964; Fax (702) 946-1345
riremandez@wrightlegal.net
By this designation, Petitioner and undersigned party agree that this designation constitutes agreemeni and authorization for the designated resident admitted counsel to sign stipulations binding on all of us.
APPOINTMENT OF DESIGNATED RESIDENT NEVADA COUNSEL
The undersigned party appoints Ramir M. Hernandez, Esq. as their Designated Resident Nevada, Counsel in this case.
Bradley Luke Senior Director, Legal Compliance Transworld Systems Inc.
CONSENT OF DESIGNEE
The undersigned hereby consents to serve as associate resident Nevada counsel in this case.
Ramir M. Hernandez Esq. Nevada Bar No. 13146 rhemandez@wrightlegal.net
ORDER
IT IS SO ORDERED.