On April 19, 2021 a
Motion-Secondary
was filed
involving a dispute between
Sonny St. John
Individually And On Behalf Of All Others Similarly Situated,,
and
Changxun Sun,
China International Capital Corporation Hong Kong Securities Limited,
Ching Chiu,
Citigroup Global Markets, Inc.,
Cloopen Group Holding Limited,
Cogency Global Inc.,
Colleen A. Devries,
Feng Zhu,
Futu, Inc.,
Goldman Sachs,
Jianhong Zhou,
Kui Zhou,
Lok Yan Hui,
Ming Liao,
Qingsheng Zheng,
Tiger Brokers,
Xiaodong Liang,
Yipeng Li,
Zi Yang,
for Commercial Division
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 11/09/2022 03:04 PM INDEX NO. 652617/2021
NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 11/09/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
)
SONNY ST. JOHN, Individually and on )
Behalf of All Others Similarly Situated, ) Index No. 652617/2021
)
Plaintiff, ) Hon. Andrew Borrok
)
v. )
) AFFIRMATION OF CHARLES D.
CLOOPEN GROUP HOLDING LIMITED, ) CORDING IN SUPPORT OF MOTION
CHANGXUN SUN, YIPENG LI, KUI ) FOR ADMISSION PRO HAC VICE
ZHOU, QINGSHENG ZHENG, )
XIAODONG LIANG, ZI YANG, MING )
LIAO, FENG ZHU, LOK YAN HUI, )
JIANHONG ZHOU, CHING CHIU, )
COGENCY GLOBAL INC., COLLEEN A. )
DEVRIES, GOLDMAN SACHS (ASIA) )
L.L.C., CITIGROUP GLOBAL MARKETS )
INC., CHINA INTERNATIONAL )
CAPITAL CORPORATION HONG KONG )
SECURITIES LIMITED, TIGER BROKERS )
(NZ) LIMITED, and FUTU, INC., )
)
Defendants. )
)
CHARLES D. CORDING, an attorney admitted to practice in the Courts of the State of
New York, and not a party to this action, hereby affirms the following to be true under the
penalties of perjury, pursuant to CPLR § 2106.
1. I am a partner with the law firm Willkie Farr & Gallagher LLP and counsel for Goldman
Sachs (Asia) L.L.C., Citigroup Global Markets Inc., Tiger Brokers (NZ) Limited, and Futu, Inc.
(n/k/a Moomoo Financial, Inc.) (collectively, the “Underwriter Defendants”) in the above-
captioned action. I am a member in good standing of the New York bar. Pursuant to 22
N.Y.C.R.R. § 520.11 and 22 N.Y.C.R.R. § 1250.4, I submit this affirmation in support of my
clients’ application for an order granting Sean Sandoloski admission pro hac vice to appear and
participate in this action on their behalf.
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FILED: NEW YORK COUNTY CLERK 11/09/2022 03:04 PM INDEX NO. 652617/2021
NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 11/09/2022
2. Annexed hereto is the Affidavit of Sean Sandoloski, sworn to on November 4, 2022. Mr.
Sandoloski is counsel at Willkie Farr & Gallagher LLP, 1875 K Street NW, Washington, D.C.
20006. As set forth in his affidavit, Mr. Sandoloski is licensed to practice law before the courts
of the District of Columbia and is a member of good standing of the Bar of the District of
Columbia. He has never been disciplined by any court, and no disciplinary proceedings are
pending against him. Annexed to his affidavit is a letter of good standing of the District Court of
the District of Columbia.
3. Mr. Sandoloski has been a litigator at Willkie Farr & Gallagher LLP since 2022, and I
have worked closely with him since. I have found Mr. Sandoloski to be a skilled attorney and an
individual of integrity.
4. Mr. Sandoloski is familiar with the facts of the above-captioned action. The interests of
the clients and of judicial economy support his admission pro hac vice.
5. Mr. Sandoloski is familiar with and will comply with the standards of professional
conduct imposed upon members of the New York Bar, including the Rules of Court governing
the conduct of attorneys and the Rules of Professional Conduct.
6. Mr. Sandoloski agrees to be subject to the jurisdiction of the Courts of the State of New
York with respect to any acts occurring during the course of his participation in this matter.
7. No prior application has been made for the relief sought herein in connection with the
above-captioned action.
8. WHEREFORE, for the reasons set forth herein, my clients respectfully request that this
motion be granted, and that Sean Sandoloski be admitted pro hac vice to appear and participate
in this action on their behalf, and for such other relief as this Court deems just and proper.
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FILED: NEW YORK COUNTY CLERK 11/09/2022 03:04 PM INDEX NO. 652617/2021
NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 11/09/2022
I declare under penalty of perjury that the foregoing is true and correct.
Dated: November 4, 2022
Respectfully submitted,
/s/ Charles D. Cording
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FILED: NEW YORK COUNTY CLERK 11/09/2022 03:04 PM INDEX NO. 652617/2021
NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 11/09/2022
CERTIFICATE OF WORD COUNT COMPLIANCE
As an attorney at Willkie Farr & Gallagher LLP, I hereby certify that this document
complies with Commercial Division Rule 17. The foregoing document was prepared using
Microsoft Word, and the document contains 458 words as calculated by the applications word
counting function and per the guidance of Rule 17.
Dated: November 4, 2022 By: /s/ Charles D. Cording
New York, NY Charles D. Cording
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Preview
FILED: NEW YORK COUNTY CLERK 11/09/2022 03:04 PM INDEX NO. 652617/2021 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 11/09/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ) SONNY ST. JOHN, Individually and on ) Behalf of All Others Similarly Situated, ) Index No. 652617/2021 ) Plaintiff, ) Hon. Andrew Borrok ) v. ) ) AFFIRMATION OF CHARLES D. CLOOPEN GROUP HOLDING LIMITED, ) CORDING IN SUPPORT OF MOTION CHANGXUN SUN, YIPENG LI, KUI ) FOR ADMISSION PRO HAC VICE ZHOU, QINGSHENG ZHENG, ) XIAODONG LIANG, ZI YANG, MING ) LIAO, FENG ZHU, LOK YAN HUI, ) JIANHONG ZHOU, CHING CHIU, ) COGENCY GLOBAL INC., COLLEEN A. ) DEVRIES, GOLDMAN SACHS (ASIA) ) L.L.C., CITIGROUP GLOBAL MARKETS ) INC., CHINA INTERNATIONAL ) CAPITAL CORPORATION HONG KONG ) SECURITIES LIMITED, TIGER BROKERS ) (NZ) LIMITED, and FUTU, INC., ) ) Defendants. ) ) CHARLES D. CORDING, an attorney admitted to practice in the Courts of the State of New York, and not a party to this action, hereby affirms the following to be true under the penalties of perjury, pursuant to CPLR § 2106. 1. I am a partner with the law firm Willkie Farr & Gallagher LLP and counsel for Goldman Sachs (Asia) L.L.C., Citigroup Global Markets Inc., Tiger Brokers (NZ) Limited, and Futu, Inc. (n/k/a Moomoo Financial, Inc.) (collectively, the “Underwriter Defendants”) in the above- captioned action. I am a member in good standing of the New York bar. Pursuant to 22 N.Y.C.R.R. § 520.11 and 22 N.Y.C.R.R. § 1250.4, I submit this affirmation in support of my clients’ application for an order granting Sean Sandoloski admission pro hac vice to appear and participate in this action on their behalf. 1 of 4 FILED: NEW YORK COUNTY CLERK 11/09/2022 03:04 PM INDEX NO. 652617/2021 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 11/09/2022 2. Annexed hereto is the Affidavit of Sean Sandoloski, sworn to on November 4, 2022. Mr. Sandoloski is counsel at Willkie Farr & Gallagher LLP, 1875 K Street NW, Washington, D.C. 20006. As set forth in his affidavit, Mr. Sandoloski is licensed to practice law before the courts of the District of Columbia and is a member of good standing of the Bar of the District of Columbia. He has never been disciplined by any court, and no disciplinary proceedings are pending against him. Annexed to his affidavit is a letter of good standing of the District Court of the District of Columbia. 3. Mr. Sandoloski has been a litigator at Willkie Farr & Gallagher LLP since 2022, and I have worked closely with him since. I have found Mr. Sandoloski to be a skilled attorney and an individual of integrity. 4. Mr. Sandoloski is familiar with the facts of the above-captioned action. The interests of the clients and of judicial economy support his admission pro hac vice. 5. Mr. Sandoloski is familiar with and will comply with the standards of professional conduct imposed upon members of the New York Bar, including the Rules of Court governing the conduct of attorneys and the Rules of Professional Conduct. 6. Mr. Sandoloski agrees to be subject to the jurisdiction of the Courts of the State of New York with respect to any acts occurring during the course of his participation in this matter. 7. No prior application has been made for the relief sought herein in connection with the above-captioned action. 8. WHEREFORE, for the reasons set forth herein, my clients respectfully request that this motion be granted, and that Sean Sandoloski be admitted pro hac vice to appear and participate in this action on their behalf, and for such other relief as this Court deems just and proper. -2- 2 of 4 FILED: NEW YORK COUNTY CLERK 11/09/2022 03:04 PM INDEX NO. 652617/2021 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 11/09/2022 I declare under penalty of perjury that the foregoing is true and correct. Dated: November 4, 2022 Respectfully submitted, /s/ Charles D. Cording -3- 3 of 4 FILED: NEW YORK COUNTY CLERK 11/09/2022 03:04 PM INDEX NO. 652617/2021 NYSCEF DOC. NO. 86 RECEIVED NYSCEF: 11/09/2022 CERTIFICATE OF WORD COUNT COMPLIANCE As an attorney at Willkie Farr & Gallagher LLP, I hereby certify that this document complies with Commercial Division Rule 17. The foregoing document was prepared using Microsoft Word, and the document contains 458 words as calculated by the applications word counting function and per the guidance of Rule 17. Dated: November 4, 2022 By: /s/ Charles D. Cording New York, NY Charles D. Cording -4- 4 of 4