Preview
FILED: NEW YORK COUNTY CLERK 11/24/2021 01:16 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 11/24/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
E.E. CRUZ & COMPANY, INC., Index No.: 652321/2020
Plaintiffs,
AFFIDAVIT OF MICHAEL D.
- against - ANGOTTI, ESG. IN SUPPORT
OF MOTION FOR PRO HAC
VICE ADMISSION
STARR SURPLUS LINES INSURANCE
COMPANY
Defendants.
STATE OF CONNECTICUT)
: ss
COUNTY OF FAIRFIELD )
MICHAEL D. ANGOTTI, of full age, being duly sworn according to law, hereby states
under penalty of perjury as follows:
1. I am a member of Saxe Doernberger & Vita, P.C., a law firm located in Connecticut.
I submit this Affidavit in support of the application of Plaintiff, E. E. Cruz & Company, Inc.
(“Plaintiff”), for leave permitting me to appear pro hac vice in this action.
2. I am currently a member in good standing of the Bar of the State of Connecticut,
and State of Massachusetts, admitted to practice before the courts of that jurisdiction. I was
admitted to the Connecticut State Bar and Massachusetts State Bar in 2016. I am also admitted
to practice before the United States District Court for the District of Connecticut. Attached
hereto as Exhibit "A" are Certificates of Good Standing from both Connecticut and
Massachusetts courts to which I am admitted.
3. I am not under suspension or disbarment by any court and have never been
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NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 11/24/2021
suspended or disbarred by any court.
4. Saxe Doernberger & Vita, P.C., is Plaintiff’s counsel in this case. My firm has
represented E. E. Cruz & Company, Inc. in the above-captioned case pending before this
court, I am familiar with this action and will be fully prepared to represent the Plaintiff in all
proceedings before this Court. In part, because of my familiarity with the facts of this case,
Plaintiff requested that I participate and represent it in this case.
5. I understand that if I am admitted pro hac vice, Stacy M. Manobianca, Esq., an
attorney of Saxe Doernberger & Vita, P. C., and a member in good standing of the New York
bar, is the attorney of record and that I will be associated with her in this matter.
6. I also understand that if I am admitted pro hac vice, I will be subject to the
disciplinary jurisdiction of the courts of New York with respect to any acts occurring during
my participation in this matter. I have become familiar with and shall 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 Disciplinary Rules of the Code of
Professional Responsibility.
7. Based upon the foregoing, I respectfully request that I be admitted pro hac vice
to the New York bar for the purpose of representing Plaintiff in this action.
8. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the
foregoing is true and correct.
Dated: November 24, 2021
____________________________
Michael D. Angotti
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NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 11/24/2021
EXHIBIT A
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NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 11/24/2021
State
of Connecticut .
Supreme Court
I, Carl D. Cicchetti, Chief Clerk of the Supreme Court of the State Connecticut and
of
keeper of the Seal thereof
Superior
Do hereby certify, that, in the Ap)6|OWNQi Court at
Hartford
28th December, 2016
on the day of
Michael D. Angotti
of
Avon, Connecticut
having been examined and found duly qualified, was sworn as an attorney and admitted to
practice before all courts of this state, and that said attorney is a member of in good standing of
the Bar of this State pursuant to Practice Book §2-65.
In Testimony Whereof I have hereunto set my hand
and affix the Seal of the Supreme Court of the State of
Connecticut, at Hartford, this day November 8, 2021
Carl D. Cicchetti
Chief Clerk
. .
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NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 11/24/2021
COMMONWEALTH OF MASSACHUSETTS
SUFFOLK, SS.
BE IT REMEMBERED, that at the Supreme Judicial Court holden at Boston
within and for said County of Suffolk, on the sixteenth
day of November A.D. 2016 , said Court being the highest
Court of Record in said Commonwealth:
Michael Angotti
being found duly qualified in that behalf, and having taken and subscribed
the oaths required by law, was admitted to practice as an Attorney, and, by virtue
thereof, as a Counsellor at Law, in any of the Courts of the said Commonwealth:
that said Attorney is at present a member of the Bar, and is in good standing
according to the records of this Court*.
In testimony whereof, I have hereunto set my hand and affixed the
seäTWšaid CouR, this tenth day of November
in the year of our Lord two thousand and twenty-one.
..........
..........
...........
. .............
MAURA S. OYL , erk
* Recordsof private discipline,if any,suchasaprivatereprirnandirnposed
by theBoardof Bar Overseersor by any court, arenot coveredby this .
X3116.
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Preview
FILED: NEW YORK COUNTY CLERK 11/24/2021 01:16 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 11/24/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK E.E. CRUZ & COMPANY, INC., Index No.: 652321/2020 Plaintiffs, AFFIDAVIT OF MICHAEL D. - against - ANGOTTI, ESG. IN SUPPORT OF MOTION FOR PRO HAC VICE ADMISSION STARR SURPLUS LINES INSURANCE COMPANY Defendants. STATE OF CONNECTICUT) : ss COUNTY OF FAIRFIELD ) MICHAEL D. ANGOTTI, of full age, being duly sworn according to law, hereby states under penalty of perjury as follows: 1. I am a member of Saxe Doernberger & Vita, P.C., a law firm located in Connecticut. I submit this Affidavit in support of the application of Plaintiff, E. E. Cruz & Company, Inc. (“Plaintiff”), for leave permitting me to appear pro hac vice in this action. 2. I am currently a member in good standing of the Bar of the State of Connecticut, and State of Massachusetts, admitted to practice before the courts of that jurisdiction. I was admitted to the Connecticut State Bar and Massachusetts State Bar in 2016. I am also admitted to practice before the United States District Court for the District of Connecticut. Attached hereto as Exhibit "A" are Certificates of Good Standing from both Connecticut and Massachusetts courts to which I am admitted. 3. I am not under suspension or disbarment by any court and have never been 1 1 of 5 FILED: NEW YORK COUNTY CLERK 11/24/2021 01:16 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 11/24/2021 suspended or disbarred by any court. 4. Saxe Doernberger & Vita, P.C., is Plaintiff’s counsel in this case. My firm has represented E. E. Cruz & Company, Inc. in the above-captioned case pending before this court, I am familiar with this action and will be fully prepared to represent the Plaintiff in all proceedings before this Court. In part, because of my familiarity with the facts of this case, Plaintiff requested that I participate and represent it in this case. 5. I understand that if I am admitted pro hac vice, Stacy M. Manobianca, Esq., an attorney of Saxe Doernberger & Vita, P. C., and a member in good standing of the New York bar, is the attorney of record and that I will be associated with her in this matter. 6. I also understand that if I am admitted pro hac vice, I will be subject to the disciplinary jurisdiction of the courts of New York with respect to any acts occurring during my participation in this matter. I have become familiar with and shall 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 Disciplinary Rules of the Code of Professional Responsibility. 7. Based upon the foregoing, I respectfully request that I be admitted pro hac vice to the New York bar for the purpose of representing Plaintiff in this action. 8. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct. Dated: November 24, 2021 ____________________________ Michael D. Angotti 2 2 of 5 FILED: NEW YORK COUNTY CLERK 11/24/2021 01:16 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 11/24/2021 EXHIBIT A 3 of 5 FILED: NEW YORK COUNTY CLERK 11/24/2021 01:16 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 11/24/2021 State of Connecticut . Supreme Court I, Carl D. Cicchetti, Chief Clerk of the Supreme Court of the State Connecticut and of keeper of the Seal thereof Superior Do hereby certify, that, in the Ap)6|OWNQi Court at Hartford 28th December, 2016 on the day of Michael D. Angotti of Avon, Connecticut having been examined and found duly qualified, was sworn as an attorney and admitted to practice before all courts of this state, and that said attorney is a member of in good standing of the Bar of this State pursuant to Practice Book §2-65. In Testimony Whereof I have hereunto set my hand and affix the Seal of the Supreme Court of the State of Connecticut, at Hartford, this day November 8, 2021 Carl D. Cicchetti Chief Clerk . . 4 of 5 FILED: NEW YORK COUNTY CLERK 11/24/2021 01:16 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 38 RECEIVED NYSCEF: 11/24/2021 COMMONWEALTH OF MASSACHUSETTS SUFFOLK, SS. BE IT REMEMBERED, that at the Supreme Judicial Court holden at Boston within and for said County of Suffolk, on the sixteenth day of November A.D. 2016 , said Court being the highest Court of Record in said Commonwealth: Michael Angotti being found duly qualified in that behalf, and having taken and subscribed the oaths required by law, was admitted to practice as an Attorney, and, by virtue thereof, as a Counsellor at Law, in any of the Courts of the said Commonwealth: that said Attorney is at present a member of the Bar, and is in good standing according to the records of this Court*. In testimony whereof, I have hereunto set my hand and affixed the seäTWšaid CouR, this tenth day of November in the year of our Lord two thousand and twenty-one. .......... .......... ........... . ............. MAURA S. OYL , erk * Recordsof private discipline,if any,suchasaprivatereprirnandirnposed by theBoardof Bar Overseersor by any court, arenot coveredby this . X3116. 5 of 5