Request,Application: PACIFIC FERTILITY CASES

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                                1   Marc G. Cowden SB No. 169391
     Adam Stoddard SB No. 272691
 2   ZENERE COWDEN & STODDARD APC                                                      ELECTRONICALLY
 3   2005 De La Cruz Blvd., Suite 240                                                      FILED
     Santa Clara, CA 95050                                                             Superior Court of California,
 4   (408) 430-3551
                                                                                        County of San Francisco

     mcowden@zcslawfirm.com                                                                04/25/2023
 5   astoddard@zcslawfirm.com                                                           Clerk of the Court
                                                                                          BY: ERNALYN BURA
 6                                                                                                  Deputy Clerk

     Attorneys for Defendants CHART INC.
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                         SUPERIOR COURT OF THE STATE OF CALIFORNIA
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                           IN AND FOR THE COUNTY OF SAN FRANCISCO
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     PACIFIC FERTILITY CASES                             Case No.: CJC-19-005021
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     [A.C., et al. v. PACIFIC FERTILITY CENTER, [Lead Case No.: CGC-18-565215]
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     et al.]                                    APPLICATION FOR AN ORDER
12                                              ADMITTING MARGARET REDSHAW,
                                                ESQ. AS COUNSEL PRO HAC VICE;
13                                              DECLARATION OF ADAM M.
14                                              STODDARD, ESQ.

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17          Defendant CHART INC. hereby applies to this Court for an order permitting Margaret
18   Redshaw, Esq. of the law firm Swanson, Martin & Bell, LLP to appear in this action and be
19   admitted to the bar of this Court pro hac vice.
20          This Application is made pursuant to Rule 9.40 of the California Rules of Court, which
21   provides that a person “who is not a member of the State Bar of California but who is a member
22   in good standing of and eligible to practice before the bar of any United States Court or the highest

23   court in any state,” and “who has been retained to appear in a particular cause pending in a court
     of this state, may in the discretion of the court be permitted upon written application to appear as
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     counsel pro hac vice, provided that an active member of the State Bar of California is associated
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     as counsel of record.”
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            This Application is necessary because CHART INC. anticipates that the participation and
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     appearance of Ms. Redshaw will be required on its behalf. As set forth in the attached Application,
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     Margaret Redshaw, Esq. will all meet the requirements of Rule 9.40. Proper and timely notice of
     APPLICATION FOR AN ORDER ADMITTING MARGARET REDSHAW, ESQ. AS COUNSEL PRO HAC
     VICE; DECLARATION OF ADAM M. STODDARD, ESQ. - 1
 1   this Application has been given to all parties who have appeared in this action and to the State
 2   Bar of California at its San Francisco address. Furthermore, a copy of this Application and

 3   supporting documents will be provided to the State Bar of California and the required $50.00 fee
     for Ms. Redshaw will be paid.
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 5          Accordingly, CHART INC. respectfully requests that Margaret Redshaw, Esq. appear as
     counsel pro hac vice in the above-captioned matter on its behalf.
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     Dated: April 25, 2023                               ZENERE COWDEN & STODDARD APC
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                                                         _______________________________
10                                                       MARC COWDEN
                                                         ADAM STODDARD
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                                                         Attorneys for Defendants CHART INC.
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     APPLICATION FOR AN ORDER ADMITTING MARGARET REDSHAW, ESQ. AS COUNSEL PRO HAC
     VICE; DECLARATION OF ADAM M. STODDARD, ESQ. - 2
 1                            APPLICATION TO APPEAR PRO HAC VICE
 2             I, Margaret Redshaw, apply for admission to practice before this Court pro hac vice to
 3   represent Defendant CHART INC. in this action. In support of this Application, I state the

 4   following:

 5             1.     I have been retained by CHART INC. to appear in this action as an attorney on its
     behalf.
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               2.     I reside in Chicago, Illinois. My residential address is 520 W. Huron St. #506,
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     Chicago, IL 60654. I am an attorney in the Chicago, Illinois office of Swanson Martin & Bell,
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     LLP located at 330 North Wabash Ave., Suite 3300, Chicago, Illinois 60611.
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               3.     I am not a resident of California, nor do I regularly practice law in the state. I am
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     not regularly employed in California, and I do not engage in any substantial business activities
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     within the state.
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               4.     Marc G. Cowden, an attorney in Santa Clara, California of ZENERE COWDEN
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     & STODDARD APC located at 2005 De La Cruz Blvd., Suite 240, Santa Clara, CA 95050, is
14   counsel of record for CHART INC. and an active member in good standing of the State Bar of
15   California.
16             5.     I was admitted to the Illinois state bar in 2017. My bar number is 6327480 and I
17   am a member in good standing. Attached as Exhibit C is a letter attesting to same.
18             6.     I have never been suspended or disbarred in any court.
19             7.     In the preceding two years, I have filed an application to appear pro hac vice in
20   the matter of In Re Pacific Fertility Center Litigation (Case No. 3:18-cv-01586 JSC) on May 18,

21   2020 which was granted and in the matter of Sherlene and Lawrence Wong, on behalf of

22   themselves and all other similar situated v. Chart Industries, Inc. (4:18-cv-04389-JSW) on May
     19, 2020 which was granted.
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               8.     Pursuant to the procedures required by the State Bar of California, a true and
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     correct copy of this Application is contemporaneously being submitted online through the
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     California Bar Admissions Information Management System (AIMS) to the San Francisco office
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     of the California State Bar, along with the required $50.00 fee.
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               9.     If admitted to this action pro hac vice, I agree to be subjected to the jurisdiction of
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     the courts of the State of California with respect to the law of the State of California governing
     APPLICATION FOR AN ORDER ADMITTING MARGARET REDSHAW, ESQ. AS COUNSEL PRO HAC
     VICE; DECLARATION OF ADAM M. STODDARD, ESQ. - 3
 1   the conduct of attorneys to the same extent as a member of the State Bar of California.
 2          I declare under the penalty of perjury under the laws of the State of California, that the
 3   foregoing is true and correct. Executed on April 12, 2023, in Chicago, Illinois.

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 5                                                        __________________________________

 6                                                               Margaret Redshaw

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     APPLICATION FOR AN ORDER ADMITTING JOHN DUFFY, ESQ., MARGARET REDSHAW, ESQ.
     AND KRISTINE C. REVEILLE, ESQ. AS COUNSEL PRO HAC VICE; DECLARATION OF ADAM M.
     STODDARD, ESQ.
 1                               DECLARATION OF ADAM M. STODDARD
 2          I, Adam M. Stoddard, declare as follows:
 3          1.      I am an attorney duly admitted to practice in all of the courts of the State of
 4   California and I am an attorney with ZENERE COWDEN & STODDARD APC, counsel of

 5   record for Defendant CHART INC. in this action. I have personal knowledge of the facts stated
     herein, and I am competent to testify to such facts.
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            2.      My office address is: ZENERE COWDEN & STODDARD APC, 2005 De La
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     Cruz Blvd., Suite 240, Santa Clara, CA 95050. I am currently a member in good standing with
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     the California State Bar (Bar No. 272691).
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            3.      I submit this declaration in support of the present application for an order admitting
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     Margaret Redshaw, Esq. of Swanson Martin & Bell, LLP to appear as counsel pro hac vice on
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     behalf of CHART INC. under Rule 9.40 of the California Rules of Court. Ms. Redshaw satisfies
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     all of the requirements of Rule 9.40.
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            4.      Contemporaneously with the filing of this Application with the Court, a true and
14   correct copy of this Application will have been served upon all parties and submitted online
15   through the California Bar Admissions Information Management System (AIMS) to the San
16   Francisco office of the California State Bar, along with the required $50 fee per applicant.
17          5.      I conferred with all parties in this matter, and none oppose this Application.
18          I declare under the penalty of perjury under the laws of the State of California, that the
19   foregoing is true and correct. Executed on April 25, 2023, in Santa Clara, California.

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22                                                                 Adam M. Stoddard

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     APPLICATION FOR AN ORDER ADMITTING MARGARET REDSHAW, ESQ. AS COUNSEL PRO HAC
     VICE; DECLARATION OF ADAM M. STODDARD, ESQ. - 5
EXHIBIT C




EXHIBIT C