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Filing # 123185025 E-Filed 03/16/2021 02:06:20 PM
IN THE CIRCUIT COURT OF THE
17™ JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. 19-025692 ca 27
JOE CARL ROGERS and
HILDA ROGERS, his wife,
Plaintiffs,
vs.
ACOUSTI ENGINEERING
COMPANY OF FLORIDA, et al.,
Defendants.
/
VERIFIED MOTION FOR ADMISSION TO APPEAR PRO HAC VICE
PURSUANT TO FLORIDA RULE OF JUDICIAL ADMINISTRATION 2.510
—_— SE RE EN AERIS ERATION 2.510
COMES NOW James M. Kramer, Movant herein, and respectfully represents the
following:
1. Movant resides in Greenwich, Connecticut, and is not a resident of the State of
Florida.
2. Movant is an attorney and a Shareholder of the law firm of Simmons Hanly
Conroy, with offices at One Court Street, Alton, Illinois and 112 Madison Avenue, 7" Floor, New
York, NY 10016; Phone: (618) 259-2222 and (212) 784-6400.
3. Movant has been retained personally or as a member of the above-named law firm on
January 23, 2020, by Joe Carl Rogers and Hilda Rogers to provide legal representation in
connection with the above-styled matter now pending before the above-named court of the State
of Florida.
4. Movant is an active member in good standing and currently eligible to practice law
in the following jurisdiction(s):
** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/16/2021 02:06;17-PM.*%—————Admitted to the State Bar of New York, State Bar No. 4746913
Admitted to the State Bar of New Jersey, State Bar No. 025052008.
5. Movant has never been subject to any disciplinary, suspension, disbarment or
contempt proceedings.
6. Movant, either by resignation, withdrawal, or otherwise, has never terminated or
attempted to terminate Movant’ s office as an attorney in order to avoid administrative,
disciplinary, disbarment, or suspension proceedings.
7, Movant is not an inactive member of the Florida Bar.
8. Movant is not now a member of the Florida Bar.
9. Movant is not a suspended member of the Florida Bar.
10. Movant is not a disbarred member of the Florida Bar nor has Movant received a
disciplinary resignation from the Florida Bar.
11. Movant has not previously been disciplined or held in contempt by reason of
misconduct committed while engaged in representation pursuant to Florida Rule of Judicial
Administration 2.510.
12. Movant has filed a motion to appear as counsel in Florida state courts during the past
five (5) years: Diane Shoemaker French, as the Personal Representative of the Estate of Bobby
Shoemaker, Deceased, vs. American Biltrite Inc., et al., Case No. 17-017041-CA-27, in The
Circuit Court Of The 17" Judicial Circuit In And For Broward County, Florida (Order granted
on 8/30/2019); Kimberly Barretto, Personal Representative of the Estate of Patricia Ann Wheeler,
Deceased, vs Actuant Corporation, et al., Case No. 18-004949 CA27, in the Circuit Court of the
17" Judicial Circuit In and For Broward County, Florida (order granted 10/23/2020).
13. Local counsel of record associated with Movant in this matter is Rebecca Vinocur,
Florida State Bar Number 529915, who is an active member in good standing of the Florida Bar
and has offices at 5915 Ponce De Leon Blvd., Ste. 14, Coral Gables, FL 33146.14. Movant has read the applicable provisions of Florida Rule of Judicial Administration
2.510 and Rule 1-3.10 of the Rules Regulating the Florida Bar and certifies that this verified
motion complies with those rules.
15. Movant agrees to comply with the provisions of the Florida Rules of Professional
Conduct and consents to the jurisdiction of the courts and the Bar of the State of Florida.
WHEREFORE, Movant respectfully requests permission to appear in this court for this
cause only.
DATED this 6 day of March, 2021.
Respectfully submitted,
Isl Rebecea P Dineeue
REBECCA S. VINOCUR
Florida Bar No.: 529915
5915 Ponce De Leon Blvd, Ste. 14
Coral Gables, Florida 33146-2435
Tel: 786-691-1282
Fax: 786-691-1283
rvinocur@rsv-law.com
and
/s/__ James M. Kramer
James M. Kramer, Esq.
New York Bar No.: 4746913
Simmons Hanly Conroy
One Court St.
Alton, IL 62002
Tel: (618) 259-2222
Fax: (618) 259-2251
jkramer@simmonsfirm.comThereby consent to be associated as local counsel of record in this cause pursuant to
Florida Rule of Judicial Administration 2.510.
i
DATED this_Vic™™ day of March, 2021.
bs! Rebecea S. Vinweur
REBECCA S. VINOCUR
Florida Bar No.: 529915
REBECCA S. VINOCUR, P.A.
5915 Ponce De Leon Blvd., Ste. 14
Coral Gables, Florida 33146
Tel.: (786) 691-1282
Fax: (786) 691-1283
rvinocur@rsv-law.com
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a true and correct copy of the foregoing motion was served via
Lexis File&Serve Xpress upon all counsel of record and upon the Florida Bar at its Tallahassee
office, along with a check in the amount of $250.00 and a filing fee in the amount of $100.00 to
the Clerk of Court in the above-named Court of the State of Florida, on this this ge day of
March, 2021.
Is! Rebecca Z. ODVinceur
REBECCA S. VINOCUR
Florida Bar No.: 529915VERIFICATION OF MOVANT, JAMES M. KRAMER
STATE OFNEW Yor (\
COUNTY OF WESTCHESTER
on
§
ooo
I, James M. aru do hereby swear or affim under penalty of perjury that Iam the Movane
inthe above-styled Matter; that I have read the foregoing Motion and know the contents thereof; that
the contents are true to best of my knowledge and belief,
The foregoing instrument was acknowledged before me this Lh day of March, 2021
‘9 Tames M. Kramer, wins personally iow tome and win dl isco poly
STEFANIE KALMANCY
NOTARY PUBLIC, STATE OF New
Registration No, O1KAG385g18
Qualified in Westchester Co
ly Commission, Expires: ZRebecca S. Vinocur, P.A.
Attomey at Law
Suite 14
5915 Ponce De Leon Blvd.
Coral Gables, Florida 33146
Rebecca S. Vinocur Telephone: 786-691-1282
rvinocur@rsv-law.com Facsimile: 786-691-1283
March 16, 2021
Via U.S. Mail
The Florida Bar
651 East Jefferson Street
Tallahassee, FL 32399-2300
Re: Joe Carl Rogers et al, vs. Acousti Engineering Company of Florida, et al.
Broward Circuit Court Case No. 19-025692 CA27
Dear Sir or Madam:
Enclosed please find copies of the following:
Verified Motion for Admissions to Appear Pro Hac Vice of James M. Kramer.
Our firm’s check in the amount of $250.00 payable to the Florida Bar.
Should you require additional information, please do not hesitate to contact the
undersigned.
f ar i
REBECCA S. VINGCUR
Jaa ea
Enclosures (as stated above)
ce: All counsel of record via File&Serve XpressWELLS FARGO BANK, NA ; |
Miami, Florida
63-751/631
REBECCA S. VINOCUR, PA
5915 Ponce De Leon Boulevard, Ste. 14
Coral Gables, FL 33146 03/16/2021
PAY TO THE The Florida Bar | $ "260.00
ORDER OF
Two hundred fifty and 00/1 00" ttt +teeiteteestestnteresenttenennnnineeninitinenenentsnianninitenineatanntinrstininens
DOLLARS f
The Florida Bar
James Kramer - Rogers, Joe Carl
Preview
Filing # 123185025 E-Filed 03/16/2021 02:06:20 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. 19-025692 ca 27 JOE CARL ROGERS and HILDA ROGERS, his wife, Plaintiffs, vs. ACOUSTI ENGINEERING COMPANY OF FLORIDA, et al., Defendants. / VERIFIED MOTION FOR ADMISSION TO APPEAR PRO HAC VICE PURSUANT TO FLORIDA RULE OF JUDICIAL ADMINISTRATION 2.510 —_— SE RE EN AERIS ERATION 2.510 COMES NOW James M. Kramer, Movant herein, and respectfully represents the following: 1. Movant resides in Greenwich, Connecticut, and is not a resident of the State of Florida. 2. Movant is an attorney and a Shareholder of the law firm of Simmons Hanly Conroy, with offices at One Court Street, Alton, Illinois and 112 Madison Avenue, 7" Floor, New York, NY 10016; Phone: (618) 259-2222 and (212) 784-6400. 3. Movant has been retained personally or as a member of the above-named law firm on January 23, 2020, by Joe Carl Rogers and Hilda Rogers to provide legal representation in connection with the above-styled matter now pending before the above-named court of the State of Florida. 4. Movant is an active member in good standing and currently eligible to practice law in the following jurisdiction(s): ** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/16/2021 02:06;17-PM.*%—————Admitted to the State Bar of New York, State Bar No. 4746913 Admitted to the State Bar of New Jersey, State Bar No. 025052008. 5. Movant has never been subject to any disciplinary, suspension, disbarment or contempt proceedings. 6. Movant, either by resignation, withdrawal, or otherwise, has never terminated or attempted to terminate Movant’ s office as an attorney in order to avoid administrative, disciplinary, disbarment, or suspension proceedings. 7, Movant is not an inactive member of the Florida Bar. 8. Movant is not now a member of the Florida Bar. 9. Movant is not a suspended member of the Florida Bar. 10. Movant is not a disbarred member of the Florida Bar nor has Movant received a disciplinary resignation from the Florida Bar. 11. Movant has not previously been disciplined or held in contempt by reason of misconduct committed while engaged in representation pursuant to Florida Rule of Judicial Administration 2.510. 12. Movant has filed a motion to appear as counsel in Florida state courts during the past five (5) years: Diane Shoemaker French, as the Personal Representative of the Estate of Bobby Shoemaker, Deceased, vs. American Biltrite Inc., et al., Case No. 17-017041-CA-27, in The Circuit Court Of The 17" Judicial Circuit In And For Broward County, Florida (Order granted on 8/30/2019); Kimberly Barretto, Personal Representative of the Estate of Patricia Ann Wheeler, Deceased, vs Actuant Corporation, et al., Case No. 18-004949 CA27, in the Circuit Court of the 17" Judicial Circuit In and For Broward County, Florida (order granted 10/23/2020). 13. Local counsel of record associated with Movant in this matter is Rebecca Vinocur, Florida State Bar Number 529915, who is an active member in good standing of the Florida Bar and has offices at 5915 Ponce De Leon Blvd., Ste. 14, Coral Gables, FL 33146.14. Movant has read the applicable provisions of Florida Rule of Judicial Administration 2.510 and Rule 1-3.10 of the Rules Regulating the Florida Bar and certifies that this verified motion complies with those rules. 15. Movant agrees to comply with the provisions of the Florida Rules of Professional Conduct and consents to the jurisdiction of the courts and the Bar of the State of Florida. WHEREFORE, Movant respectfully requests permission to appear in this court for this cause only. DATED this 6 day of March, 2021. Respectfully submitted, Isl Rebecea P Dineeue REBECCA S. VINOCUR Florida Bar No.: 529915 5915 Ponce De Leon Blvd, Ste. 14 Coral Gables, Florida 33146-2435 Tel: 786-691-1282 Fax: 786-691-1283 rvinocur@rsv-law.com and /s/__ James M. Kramer James M. Kramer, Esq. New York Bar No.: 4746913 Simmons Hanly Conroy One Court St. Alton, IL 62002 Tel: (618) 259-2222 Fax: (618) 259-2251 jkramer@simmonsfirm.comThereby consent to be associated as local counsel of record in this cause pursuant to Florida Rule of Judicial Administration 2.510. i DATED this_Vic™™ day of March, 2021. bs! Rebecea S. Vinweur REBECCA S. VINOCUR Florida Bar No.: 529915 REBECCA S. VINOCUR, P.A. 5915 Ponce De Leon Blvd., Ste. 14 Coral Gables, Florida 33146 Tel.: (786) 691-1282 Fax: (786) 691-1283 rvinocur@rsv-law.com CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and correct copy of the foregoing motion was served via Lexis File&Serve Xpress upon all counsel of record and upon the Florida Bar at its Tallahassee office, along with a check in the amount of $250.00 and a filing fee in the amount of $100.00 to the Clerk of Court in the above-named Court of the State of Florida, on this this ge day of March, 2021. Is! Rebecca Z. ODVinceur REBECCA S. VINOCUR Florida Bar No.: 529915VERIFICATION OF MOVANT, JAMES M. KRAMER STATE OFNEW Yor (\ COUNTY OF WESTCHESTER on § ooo I, James M. aru do hereby swear or affim under penalty of perjury that Iam the Movane inthe above-styled Matter; that I have read the foregoing Motion and know the contents thereof; that the contents are true to best of my knowledge and belief, The foregoing instrument was acknowledged before me this Lh day of March, 2021 ‘9 Tames M. Kramer, wins personally iow tome and win dl isco poly STEFANIE KALMANCY NOTARY PUBLIC, STATE OF New Registration No, O1KAG385g18 Qualified in Westchester Co ly Commission, Expires: ZRebecca S. Vinocur, P.A. Attomey at Law Suite 14 5915 Ponce De Leon Blvd. Coral Gables, Florida 33146 Rebecca S. Vinocur Telephone: 786-691-1282 rvinocur@rsv-law.com Facsimile: 786-691-1283 March 16, 2021 Via U.S. Mail The Florida Bar 651 East Jefferson Street Tallahassee, FL 32399-2300 Re: Joe Carl Rogers et al, vs. Acousti Engineering Company of Florida, et al. Broward Circuit Court Case No. 19-025692 CA27 Dear Sir or Madam: Enclosed please find copies of the following: Verified Motion for Admissions to Appear Pro Hac Vice of James M. Kramer. Our firm’s check in the amount of $250.00 payable to the Florida Bar. Should you require additional information, please do not hesitate to contact the undersigned. f ar i REBECCA S. VINGCUR Jaa ea Enclosures (as stated above) ce: All counsel of record via File&Serve XpressWELLS FARGO BANK, NA ; | Miami, Florida 63-751/631 REBECCA S. VINOCUR, PA 5915 Ponce De Leon Boulevard, Ste. 14 Coral Gables, FL 33146 03/16/2021 PAY TO THE The Florida Bar | $ "260.00 ORDER OF Two hundred fifty and 00/1 00" ttt +teeiteteestestnteresenttenennnnineeninitinenenentsnianninitenineatanntinrstininens DOLLARS f The Florida Bar James Kramer - Rogers, Joe Carl