On June 08, 2020 a
Motion-Secondary
was filed
involving a dispute between
E.E. Cruz & Company, Inc.,
and
Starr Surplus Lines Insurance Company,
for Commercial - Insurance
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 04/05/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
E.E. CRUZ & COMPANY, INC., Index No.: 652321/2020
Plaintiffs,
AFFIDAVIT OF JONTHAN W.
- against - CHAMBERS, ESG. IN SUPPORT
OF MOTION FOR PRO HAC
VICE ADMISSION
STARR SURPLUS LINES INSURANCE
COMPANY
Defendants.
STATE OF CONNECTICUT)
: ss
COUNTY OF FAIRFIELD )
JONATHAN W. CHAMBERS, 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 Florida, and
the State of Vermont, I am admitted to practice before the courts of those jurisdictions. I was
admitted to the Florida State Bar in 2013 and the Vermont State Bar in 2020. I am also
admitted to practice before the United States District Court for the District of Southern District
of Florida and the United States District Court for the Middle District of Florida. Attached
hereto as Exhibit "A" are Certificates of Good Standing from both Florida and Vermont courts
to which I am admitted.
1
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FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 04/05/2022
3. I am not under suspension or disbarment by any court and have never been
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 NY CPLR §R2106, I declare under penalty of perjury that the
foregoing is true and correct.
Dated: April 5, 2022
____________________________
Jonathan W. Chambers
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FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 04/05/2022
EXHIBIT A
3 of 5
FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 04/05/2022
OF V£
* *
VERMONT SUPREME COURT
CERTIFICATE OF ADMISSION AND GOOD STANDING
This is to CERTIFY that Jonathan W. Chambers, #6257 was duly
licensed and admitted to practice as an Attorney and Counselor at Law in all
the courts of the State by the Vermont Supreme Court on the 6th day of May
2021.
This is to FURTHER CERTIFY that the said Jonathan Chambers, Esq.
is on active status and is in good standing according to the records of this
Court.
Dated at Montpelier, Vermont, this 31st day of March 2022.
Deputy Clerk
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FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020
NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 04/05/2022
Atipreme Cottet at florfba
Certitkate of ecob Stankfug
I, JOHN A. TOMASINO, Clerk of the Supreme Court of the State of Florida, do
hereby certify that
JONATHAN WICK CHAMBERS
was admitted as an attorney and counselor entitled to practice law in all the
Courts of the State of Florida on SEPTEMBER 30, 2013, is presently in good
standing, and that the private and professional character of the attorney appears
to be good.
coury, WITNESS my hand and the Seal of the
** **
c4 ] Supreme Court of Florida at Tallahassee,
**
'
the Ca 1, this MARCH 23, 2022.
ClerIof the Supreme Court of Florida
5 of 5
Document Filed Date
April 05, 2022
Case Filing Date
June 08, 2020
Category
Commercial - Insurance
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FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 04/05/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK E.E. CRUZ & COMPANY, INC., Index No.: 652321/2020 Plaintiffs, AFFIDAVIT OF JONTHAN W. - against - CHAMBERS, ESG. IN SUPPORT OF MOTION FOR PRO HAC VICE ADMISSION STARR SURPLUS LINES INSURANCE COMPANY Defendants. STATE OF CONNECTICUT) : ss COUNTY OF FAIRFIELD ) JONATHAN W. CHAMBERS, 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 Florida, and the State of Vermont, I am admitted to practice before the courts of those jurisdictions. I was admitted to the Florida State Bar in 2013 and the Vermont State Bar in 2020. I am also admitted to practice before the United States District Court for the District of Southern District of Florida and the United States District Court for the Middle District of Florida. Attached hereto as Exhibit "A" are Certificates of Good Standing from both Florida and Vermont courts to which I am admitted. 1 1 of 5 FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 04/05/2022 3. I am not under suspension or disbarment by any court and have never been 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 NY CPLR §R2106, I declare under penalty of perjury that the foregoing is true and correct. Dated: April 5, 2022 ____________________________ Jonathan W. Chambers 2 2 of 5 FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 04/05/2022 EXHIBIT A 3 of 5 FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 04/05/2022 OF V£ * * VERMONT SUPREME COURT CERTIFICATE OF ADMISSION AND GOOD STANDING This is to CERTIFY that Jonathan W. Chambers, #6257 was duly licensed and admitted to practice as an Attorney and Counselor at Law in all the courts of the State by the Vermont Supreme Court on the 6th day of May 2021. This is to FURTHER CERTIFY that the said Jonathan Chambers, Esq. is on active status and is in good standing according to the records of this Court. Dated at Montpelier, Vermont, this 31st day of March 2022. Deputy Clerk 4 of 5 FILED: NEW YORK COUNTY CLERK 04/05/2022 04:07 PM INDEX NO. 652321/2020 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 04/05/2022 Atipreme Cottet at florfba Certitkate of ecob Stankfug I, JOHN A. TOMASINO, Clerk of the Supreme Court of the State of Florida, do hereby certify that JONATHAN WICK CHAMBERS was admitted as an attorney and counselor entitled to practice law in all the Courts of the State of Florida on SEPTEMBER 30, 2013, is presently in good standing, and that the private and professional character of the attorney appears to be good. coury, WITNESS my hand and the Seal of the ** ** c4 ] Supreme Court of Florida at Tallahassee, ** ' the Ca 1, this MARCH 23, 2022. ClerIof the Supreme Court of Florida 5 of 5