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Taylor v. MGM Resorts Int'l, Inc.

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA
Oct 18, 2011
CASE NO. 2:11-cv-01360-KJD-CWH (D. Nev. Oct. 18, 2011)

Opinion

CASE NO. 2:11-cv-01360-KJD-CWH

10-18-2011

RONALD & EVELYN TAYLOR, et al., Plaintiffs, v. MGM RESORTS INTERNATIONAL, INC., et al., Defendants.


VERIFIED PETITION FOR PERMISSION TO PRACTICE IN THIS CASE ONLY BY ATTORNEY NOTED ADMITTED TO THE BAR OF THIS COURT AND DESIGNATION OF LOCAL COUNSEL

EFFECTIVE JUNE 1, 2004

FILING FEE IS $175.00

Victoria L. Ersoff, Petitioner, respectfully represents to the Court:

1. That Petitioner resides in the city of Beverly Hills, Los Angeles County, California.

2. That Petitioner is an attorney at law and a member of the law firm of Wood, Smith, Henning & Berman LLP with offices at 10960 Wilshire Boulevard, 18th Floor, Los Angeles, California 90024, Telephone: (310) 481-7600; E-mail: versoff@wshblaw.com.

3. That Petitioner has been retained personally or as a member of the law firm by MGM Resorts International, et al. to provide legal representation in connection with the above-entitled case now pending before this Court.

4. That since December 14, 1992, Victoria L. Ersoff, Petitioner, has been and presently is a member in good standing of the bar of the highest Court of the State of California 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 ¦ +--------------------+---------------+------------¦ ¦California State and¦ ¦ ¦ ¦ ¦12/14/1992 ¦161795 ¦ ¦Federal Courts ¦ ¦ ¦ +-------------------------------------------------+

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: There have been no disciplinary proceedings or any of the other suggested activities against Petitioner.

7. Has Petitioner ever been denied admission to the State Bar of Nevada? No.

8. That Petitioner is a member of good standing in the following Bar Associations: The State Bar of California.

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 ¦ ¦ ¦ ¦ ¦ ¦Granted or Denied ¦ ¦ ¦ ¦Body or Arbitrator ¦ ¦ +---------------------+--------------+--------------------+-------------------¦ ¦ ¦Representation¦ ¦ ¦ ¦ ¦of ¦ ¦ ¦ ¦ ¦ ¦ ¦ ¦ ¦ ¦client ¦ ¦ ¦ ¦ ¦defendants in ¦ ¦ ¦ ¦February 25, 2011 ¦ ¦Las Vegas, Nevada ¦Granted ¦ ¦ ¦an action ¦ ¦ ¦ ¦ ¦pending ¦ ¦ ¦ ¦ ¦ ¦ ¦ ¦ ¦ ¦before the ¦ ¦ ¦ ¦ ¦court ¦ ¦ ¦ +-----------------------------------------------------------------------------+

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.

13. 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 CALIFORNIA COUNTY OF LOS ANGELES

Victoria L. Ersoff, Petitioner, being first duly sworn deposes and says: That the foregoing statements are true.

_______________

Petitioner's Signature
STATE OF CALIFORNIA COUNTY OF LOS ANGELES

Subscribed and sworn to (or affirmed) before me on September 13, 2011, by VICTORIA L. ERSOFF, who proved to me on the basis of satisfactory evidence to be the person who appeared before me.

(Seal)

____

Signature

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 client(s) to designate Martin J. Kravitz, Attorney at Law, member of the State Bar of Nevada and previously admitted to practice before the above-entitled Court as associate resident counsel in this action. The address of said designated Nevada counsel is: Kravitz, Schnitzer, Sloane & Johnson, LLP, 8985 S. Eastern Avenue. Suite 200. Las Vegas, Nevada 89123. Tel: (702) 362-6666.

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 Martin J. Kravitz as its 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 Bar number
APPROVED:

_______________

UNITED STATES DISTRICT JUDGE

#161795

Victoria L Ersoff

Wood Smith Henning & Berman

10960 Wilshire Blvd 18 Floor

Los Angeles, CA 90024-3702

310-481-7600

TO WHOM IT MAY CONCERN:

In accordance with your request, please find enclosed the form of certificate of standing you require.

RECORDS DEPARTMENT

CERTIFICATE OF STANDING

TO WHOM IT MAY CONCERN:

This is to certify that according to the records of the State Bar. VICTORIA LYNN GITT, #161795 was admitted to the practice of law in this state by the Supreme Court of California on December 14, 1992; that at her request, on August 25, 1994, her name was changed to VICTORIA LYNN ERSOFF on the records of the State Bar of California; that she has been since the date of admission, and is at date hereof, an ACTIVE member of the State Bar of California; and that no recommendation for discipline for professional or other misconduct has ever been made by the Board of Governors or a Disciplinary Board to the Supreme Court of the State of California.

THE STATE BAR OF CALIFORNIA

Dina DiLoreto

Custodian of Membership Records


Summaries of

Taylor v. MGM Resorts Int'l, Inc.

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA
Oct 18, 2011
CASE NO. 2:11-cv-01360-KJD-CWH (D. Nev. Oct. 18, 2011)
Case details for

Taylor v. MGM Resorts Int'l, Inc.

Case Details

Full title:RONALD & EVELYN TAYLOR, et al., Plaintiffs, v. MGM RESORTS INTERNATIONAL…

Court:UNITED STATES DISTRICT COURT DISTRICT OF NEVADA

Date published: Oct 18, 2011

Citations

CASE NO. 2:11-cv-01360-KJD-CWH (D. Nev. Oct. 18, 2011)