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 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. Nevada Bar No. 8386 Ramir M. Hernandez, Esq. Nevada Bar No. 13146 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, NCSL1 2005-2, NCSLT 2005-3, NCSLT 2006-1, NCSLT 2006-2, NCSLT 2006-3, NCSLT 2006-4, NCSL1 2007-1, NCSLT 2007-2, NCSLT 2007-3, and NCSLT 2007-4.
WRIGHT, FINLAY & ZAK, LLP Darren T. Brenner, Esq. Nevada Bar No. 8386 Ramir M. Hernandez, Esq. Nevada Bar No. 13146 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, NCSL1 2005-2, NCSLT 2005-3, NCSLT 2006-1, NCSLT 2006-2, NCSLT 2006-3, NCSLT 2006-4, NCSL1 2007-1, NCSLT 2007-2, NCSLT 2007-3, and NCSLT 2007-4.
VERIFIED PETITION FOR PERMISSION TO PRACTICE TO PRACTICE IN THIS CASE ONLY BY ATTORNEY NOT ADMITTED TO THE BAR OF THIS COURT AND DESIGNATION OF LOCAL COUNSEL
GLORIA M. NAVARRO, DISTRICT JUDGE UNITED STATES DISTRICT COURT
1. That Petitioner is an attorney at law and a member of the law firm of Locke Lord LLP with offices at 111 South Wacker Drive, Chicago, IL 60606, (312) 443-0472, jmgoodin@lockelord.com.
2. That Petitioner has been retained by Defendants, National Collegiate Mastei 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 2005-1, 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 representation in connection with the above-entitled case now pending before this Court.
3. That since November 8, 2001, Petitioner has been and presently is a member in good standing of the bar of the highest Court of the State of Illinois where Petitioner regularly practices law. Petitioner shall attach a certificate from the state bar or from the clerk of the supreme 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 Courts, United States Circuit Courts of Appeal, the Supreme Court of the United States and Courts of other States on the dates indicated for each, and that Petitioner is presently a member in good standing of the bars of said Courts.
Court Date Admitted Bar Number Supreme Court of Illinois 2001 6275013 United States District Court for the Northern District of Illinois 2001 -- United States District Court for the Eastern District of Wisconsin 2007 -- United States District Court for the Northern District of Florida 2009 -- United States District Court for the Eastern District of Michigan 2010 -- 3 United States District Court for the Northern District of Indiana 2012 -- United States Court of Appeals for the First Circuit 2001 -- United States Court of Appeals for the Second Circuit 2015 -- United States Court of Appeals for the Sixth Circuit 2010 -- United States Court of Appeals for the Seventh Circuit 2006 -- United States Court of Appeals for the Eighth Circuit 2012 -- United States Court of Appeals for the Ninth Circuit 2008 -- United States Supreme Court 2013
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 disbarrnenl proceedings.
6. That Petitioner has never been denied admission to the State Bar of Nevada.
7. That Petitioner is a member of good standing in the American Bar Association.
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.
STATE OF ILLINOIS COUNTY OF COOK
J. MATTHEW GOODIN
J. Matthew Goodin, Petitioner, being first duly sworn, deposes and says: That the foregoing statements are true.
J. MATTHEW GOODIN
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, member 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
rhernandez@wr-ightlegal.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.
Bradly 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.