Opinion
Case# 2:10-cv-01930-RLH-LRL
08-08-2011
ROBERT BOSCH LLC Plaintiff, v. ADM 21 CO., LTD.; ADM USA; and ADM NORTH AMERICA Defendant(s).
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
EFFECTIVE JUNE 1, 2004
FILING FEE IS $175.00
Elizabeth A. Cutri, Petitioner, respectfully represents to the Court:
1. That Petitioner resides at Chicago (city), Cook (county ),Illinois (state).
2. That Petitioner is an attorney at law and a member of the law firm of Kirkland & Ellis LLP with offices at 300 N. LaSalle Street, 25th Floor (street address), Chicago (city), 60654 (zip code) , (312) 862-7160 (area code + telephone number), elizabeth.cutri@kirkland.com (Email address).
3. That Petitioner has been retained personally or as a member of the law firm by ADM 21 Co., Ltd.; ADM USA; and ADM North America [client(s)] to provide legal representation in connection with the above-entitled case now pending before this Court.
4. That since 11 -06-2008 (date), Petitioner has been and presently is a member in good standing of the bar of the highest Court of the State of Illinois (state) where Petitioner regularly practices law.
5. 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 ¦ +-----+--------------------+-------------+------------¦ ¦ ¦Illinois State Court¦11-06-2008 ¦6297285 ¦ +-----------------------------------------------------+
6. That there are or 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, except as described in detail below:
None. ____
7. Has Petitioner ever been denied admission to the State Bar of Nevada?. (If yes, give particulars of every denied admission):
No. ____
8. That Petitioner is a member of good standing in the following Bar Associations: ____
9. Petitioner or any member of Petitioner's firm (or office if firm has offices in more than one city) with which Petitioner is associated has/have filed application(s) to appear as counsel
+-----------------------------------------------------------------------------+ ¦under Local Rule IA 10-2 during the past three (3) years in the ¦ ¦ ¦following matters: ¦ ¦ +----------------------------------------------------------------+------------¦ ¦ ¦ ¦Title of Court ¦Was ¦ ¦ ¦ ¦ ¦Application ¦ ¦Date of Application ¦Cause ¦Administrative Body ¦ ¦ ¦ ¦ ¦ ¦Granted or ¦ ¦ ¦ ¦or Arbitrator ¦ ¦ ¦ ¦ ¦ ¦Denied ¦ +------------------------+--------------+------------------------+------------¦ ¦09/05/2008 ¦08-CV-0967 ¦USDC DNV ¦Granted ¦ +------------------------+--------------+------------------------+------------¦ ¦01/23/2009 ¦08-CV-0967 ¦USDC DNV ¦Granted ¦ +------------------------+--------------+------------------------+------------¦ ¦05/03/2010 ¦08-CV-0116 ¦USDC DNV ¦Granted ¦ +------------------------+--------------+------------------------+------------¦ ¦05/24/2010 ¦04-CV-01199 ¦USDC DNV ¦Granted ¦ +-----------------------------------------------------------------------------¦ ¦**CONTINUED ON ATTACHED PAGE ¦ +-----------------------------------------------------------------------------+
(If necessary, please attach a statement of additional applications)
10. 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.
11. Petitioner agrees to comply with the standards of professional conduct required of the members of the bar of this court.
12. 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.
That Petitioner respectfully prays that Petitioner be admitted to practice before this Court FOR THE PURPOSES OF THIS CASE ONLY.
____
Petitioner's Signature
STATE OF Illinois
COUNTY OF Cook
Elizabeth A. Cutri, Petitioner, being first duly sworn, deposes and says: That the foregoing statements are true.
____
Petitioner's Signature
Subscribed and sworn to before me this 5th day of August, 2011.
____
Notary public or Clerk of Court
DESIGNATION OF RESD3ENT 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 client(s) to designate Michael D. Rounds,Attorney at Law, member of the State of Nevada and previously admitted to practice before the above-entitled Court as associate residence counsel in this action. The address of said designate Nevada counsel is:
Watson Rounds, 5371 Kietzke Lane, Reno, NV 89511
(775) 324-4100
(Street, City, State, Zip Code and Telephone No.)
By this designation the Petitioner and undersigned party(ies) agree that this designation constitutes agreement 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(ies) appoints Michael D. Rounds as his/her/their Designated Resident Nevada Counsel in this case.
____
(Party signature)
____
(Party signature)
____
(Party signature)
CONSENT OF DESIGNEE
The undersigned hereby consents to serve as associate resident Nevada counsel in this case.
____
Designated Resident Nevada Counsel's Signature
4734
Bar number
DENIED pursuant to Local Rule LR IA 10-2(1).
____
UNITED STATES DISTRICT JUDGE
**9. Petitioner or any member of Petitioner's firm (or office if firm has offices in more than one city) with which Petitioner is associated has/have filed application(s) to appear as counsel under Local Rule IA 10-2 during the past three (3) years in the following matters (cont):
+----------------------------------------------------------------------+ ¦Date of Application ¦Cause ¦Title of Court ¦Granted or Denied ¦ +---------------------+-----------+----------------+-------------------¦ ¦09/28/2010 ¦08-cv-01463¦USDC DNV ¦Granted ¦ +---------------------+-----------+----------------+-------------------¦ ¦01/24/2011 ¦10-cv-01930¦USDC DNV ¦Granted ¦ +---------------------+-----------+----------------+-------------------¦ ¦04/12/2011 ¦10-cv-01930¦USDC DNV ¦Granted ¦ +---------------------+-----------+----------------+-------------------¦ ¦05/03/2011 ¦10-cv-01356¦USDC DNV ¦Granted ¦ +----------------------------------------------------------------------+