Preview
MID-L-003868-20 11/09/2020 10:11:38 AM Pg 1 of 2 Trans ID: LCV20202014651
ROBINS KAPLAN LLP
Rayna E. Kessler, Esq.
NJ ID No. 031782010
399 Park Ave, Suite 3600
New York, New York 10022
Telephone: (212) 980-7431
Facsimile: (212) 980-7499
Email: RKessler@RobinsKaplan.com
Attorneys for Plaintiff Jada Henderson
:
JADA HENDERSON, : SUPERIOR COURT OF NEW JERSEY
: LAW DIVISION - MIDDLESEX COUNTY
Plaintiff, :
v. : DOCKET NO. MID-L-003868-20
:
SANOFI U.S. SERVICES INC., : CASE TYPE: MCL NO. 628
formerly known as SANOFI-AVENTIS :
U.S. INC.; : MASTER DOCKET NO.
SANOFI-AVENTIS U.S. LLC, : MID-L-4998-18-CM
separately and doing business as :
WINTHROP U.S.; and : CIVIL ACTION
JOHN DOE DRUG COMPANY : IN RE TAXOTERE LITIGATION
DEFENDANTS #1-10, :
:
Defendants. : CERTIFICATION OF COMPLIANCE
: WITH THE COURT’S SEPTEMBER 17,
: 2020 ORDER ADMITTING
: DAVID B. FRANCO, ESQ., ESQ.
: PRO HAC VICE
:
I, RAYNA E. KESSLER, ESQ., of full age, hereby certifies as follows:
1. I am an attorney licensed to practice in the State of New Jersey and am an attorney
with the firm of Robins Kaplan LLP, counsel for Plaintiff Jada Henderson, in the above-captioned
matter.
2. By Order dated September 17, 2020, the Court admitted David B. Franco, Esq.,
Esq. of FrancoLaw PLLC at 500 W. 2nd Street, Floor 19, Suite 138, Austin, Texas 78701, pro hac
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vice, as counsel for Plaintiff Jada Henderson. A true and correct copy of the Court’s September
17, 2020 Order is attached hereto as Exhibit A.
3. The Court’s Order provides that David B. Franco, Esq., shall pay the fees required
by R. 1:20-1(b), R, 1:28B-1(e). See Ex. A.
4. David B. Franco, Esq., paid the fee to the New Jersey Lawyers’ Fund ($212.00) as
confirmed on October 5, 2020. A true and correct copy of the receipt is attached hereto as Exhibit
B.
5. The purpose of this Certification is to inform the Court that David B. Franco, Esq.,
Esq., through our firm, has complied with the Court’s September 17, 2020 Order.
6. I certify that the foregoing statements made by me are true. I am aware that if any
of the foregoing statements made by me are willfully false I am subject to punishment.
Dated: November 9, 2020 By: /s/Rayna E. Kessler
Rayna E. Kessler, Esq.
NJ ID No. 031782010
399 Park Ave, Suite 3600
New York, New York 10022
Telephone: (212) 980-7431
Facsimile: (212) 980-7499
Email: RKessler@RobinsKaplan.com
Attorneys for Jada Henderson
2
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EXHIBIT A
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:
JADA HENDERSON, : SUPERIOR COURT OF NEW JERSEY
: LAW DIVISION - MIDDLESEX COUNTY
Plaintiff, :
v. : DOCKET NO. MID-L-003868-20
:
SANOFI U.S. SERVICES INC., : CASE TYPE: MCL NO. 628
formerly known as SANOFI-AVENTIS :
U.S. INC.; : MASTER DOCKET NO.
SANOFI-AVENTIS U.S. LLC, : MID-L-4998-18-CM
separately and doing business as :
WINTHROP U.S.; AND JOHN DOE : CIVIL ACTION
DRUG COMPANY DEFENDANTS #1-10, : IN RE TAXOTERE LITIGATION
:
Defendants. :
: ORDER ADMITTING ATTORNEY
: DAVID B. FRANCO, ESQ. PRO HAC VICE
:
:
:
:
:
WHEREAS, Robins Kaplan LLP, counsel for the Plaintiff Jada Henderson in the above-
captioned action, upon notice to all interested parties, have moved before this Court for the
admission pro hac vice of David B. Franco, Esq.; the Court having considered the papers in support
thereof; and the Court having found that, David B. Franco, Esq. is a member in good standing for
the bar of the Supreme Court of Texas where he principally practices law; and further good cause
shown,
IT IS on this 17 day of September, 2020, hereby
ORDERED that the Motion is granted and David B. Franco, Esq. is admitted to practice
pro hac vice before this Court, pursuant to Rule 1:21-2, for all purposes and in the same manner
as an attorney who is admitted to practice in this State and is domiciled and maintains an office for
the practice of law in the State of New Jersey, provided that:
1. David B. Franco, Esq. shall abide by the Rules of Court for the State of New Jersey,
including all disciplinary rules;
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2. David B. Franco, Esq. shall consent to the appointment of the Clerk of the Supreme
Court as an agent upon whom service of process may be made for all actions against
him or his firm that may arise out of his participation in this matter;
3. David B. Franco, Esq. shall notify the Court immediately of any matter affecting
his standing before this Court;
4. David B. Franco, Esq. shall have all pleadings, briefs and other papers filed with
the Court in this action signed by an attorney of record authorized to practice in
this State, specifically the New York, New York office of Robins Kaplan LLP, who
shall be responsible for them and for the conduct of the cause and of the admitted
attorney herein;
5. David B. Franco, Esq. must, within 10 days, pay the fees required by Rule 1:20-
1(b) and Rule 1:28-2 and submit affidavits of compliance;
6. Automatic termination of pro hac vice admission will occur for failure to make the
required annual payments to the Ethics Financial Committee and the New Jersey
Lawyer’s Fund for Client Protection. Proof of such payment, after filing proof of
the initial payment, shall be made no later than February 1st, of each year;
7. Non-compliance with any of these requirements shall constitute grounds for
removal; and,
8. That a copy of this Order shall be served on all parties within seven (7) days.
/s/ James F. Hyland
Hon. James F. Hyland, J.S.C.
[X] Unopposed
“Having found the motion documents were served in accordance with R.1:6-3, this instant
motion is deemed uncontested and is decided essentially for the reasons set forth in the
moving papers pursuant to R.1:6-2.”
FILED
September 17 , 2020
Hon. James F. Hyland, J.S.C.
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EXHIBIT B
MID-L-003868-20 11/09/2020 10:11:38 AM Pg 2 of 2 Trans ID: LCV20202014651
Preview
MID-L-003868-20 11/09/2020 10:11:38 AM Pg 1 of 2 Trans ID: LCV20202014651 ROBINS KAPLAN LLP Rayna E. Kessler, Esq. NJ ID No. 031782010 399 Park Ave, Suite 3600 New York, New York 10022 Telephone: (212) 980-7431 Facsimile: (212) 980-7499 Email: RKessler@RobinsKaplan.com Attorneys for Plaintiff Jada Henderson : JADA HENDERSON, : SUPERIOR COURT OF NEW JERSEY : LAW DIVISION - MIDDLESEX COUNTY Plaintiff, : v. : DOCKET NO. MID-L-003868-20 : SANOFI U.S. SERVICES INC., : CASE TYPE: MCL NO. 628 formerly known as SANOFI-AVENTIS : U.S. INC.; : MASTER DOCKET NO. SANOFI-AVENTIS U.S. LLC, : MID-L-4998-18-CM separately and doing business as : WINTHROP U.S.; and : CIVIL ACTION JOHN DOE DRUG COMPANY : IN RE TAXOTERE LITIGATION DEFENDANTS #1-10, : : Defendants. : CERTIFICATION OF COMPLIANCE : WITH THE COURT’S SEPTEMBER 17, : 2020 ORDER ADMITTING : DAVID B. FRANCO, ESQ., ESQ. : PRO HAC VICE : I, RAYNA E. KESSLER, ESQ., of full age, hereby certifies as follows: 1. I am an attorney licensed to practice in the State of New Jersey and am an attorney with the firm of Robins Kaplan LLP, counsel for Plaintiff Jada Henderson, in the above-captioned matter. 2. By Order dated September 17, 2020, the Court admitted David B. Franco, Esq., Esq. of FrancoLaw PLLC at 500 W. 2nd Street, Floor 19, Suite 138, Austin, Texas 78701, pro hac MID-L-003868-20 11/09/2020 10:11:38 AM Pg 2 of 2 Trans ID: LCV20202014651 vice, as counsel for Plaintiff Jada Henderson. A true and correct copy of the Court’s September 17, 2020 Order is attached hereto as Exhibit A. 3. The Court’s Order provides that David B. Franco, Esq., shall pay the fees required by R. 1:20-1(b), R, 1:28B-1(e). See Ex. A. 4. David B. Franco, Esq., paid the fee to the New Jersey Lawyers’ Fund ($212.00) as confirmed on October 5, 2020. A true and correct copy of the receipt is attached hereto as Exhibit B. 5. The purpose of this Certification is to inform the Court that David B. Franco, Esq., Esq., through our firm, has complied with the Court’s September 17, 2020 Order. 6. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false I am subject to punishment. Dated: November 9, 2020 By: /s/Rayna E. Kessler Rayna E. Kessler, Esq. NJ ID No. 031782010 399 Park Ave, Suite 3600 New York, New York 10022 Telephone: (212) 980-7431 Facsimile: (212) 980-7499 Email: RKessler@RobinsKaplan.com Attorneys for Jada Henderson 2 MID-L-003868-20 11/09/2020 10:11:38 AM Pg 1 of 3 Trans ID: LCV20202014651 EXHIBIT A MID-L-003868-20 MID L 003868-20 11/09/2020 09/17/2020 10:11:38 AM Pg Pg 1 of22ofTrans 3 Trans ID: ID: LCV20201641204 LCV20202014651 : JADA HENDERSON, : SUPERIOR COURT OF NEW JERSEY : LAW DIVISION - MIDDLESEX COUNTY Plaintiff, : v. : DOCKET NO. MID-L-003868-20 : SANOFI U.S. SERVICES INC., : CASE TYPE: MCL NO. 628 formerly known as SANOFI-AVENTIS : U.S. INC.; : MASTER DOCKET NO. SANOFI-AVENTIS U.S. LLC, : MID-L-4998-18-CM separately and doing business as : WINTHROP U.S.; AND JOHN DOE : CIVIL ACTION DRUG COMPANY DEFENDANTS #1-10, : IN RE TAXOTERE LITIGATION : Defendants. : : ORDER ADMITTING ATTORNEY : DAVID B. FRANCO, ESQ. PRO HAC VICE : : : : : WHEREAS, Robins Kaplan LLP, counsel for the Plaintiff Jada Henderson in the above- captioned action, upon notice to all interested parties, have moved before this Court for the admission pro hac vice of David B. Franco, Esq.; the Court having considered the papers in support thereof; and the Court having found that, David B. Franco, Esq. is a member in good standing for the bar of the Supreme Court of Texas where he principally practices law; and further good cause shown, IT IS on this 17 day of September, 2020, hereby ORDERED that the Motion is granted and David B. Franco, Esq. is admitted to practice pro hac vice before this Court, pursuant to Rule 1:21-2, for all purposes and in the same manner as an attorney who is admitted to practice in this State and is domiciled and maintains an office for the practice of law in the State of New Jersey, provided that: 1. David B. Franco, Esq. shall abide by the Rules of Court for the State of New Jersey, including all disciplinary rules; MID-L-003868-20 MID L 003868-20 11/09/2020 09/17/2020 10:11:38 AM Pg Pg 2 of32ofTrans 3 Trans ID: ID: LCV20201641204 LCV20202014651 2. David B. Franco, Esq. shall consent to the appointment of the Clerk of the Supreme Court as an agent upon whom service of process may be made for all actions against him or his firm that may arise out of his participation in this matter; 3. David B. Franco, Esq. shall notify the Court immediately of any matter affecting his standing before this Court; 4. David B. Franco, Esq. shall have all pleadings, briefs and other papers filed with the Court in this action signed by an attorney of record authorized to practice in this State, specifically the New York, New York office of Robins Kaplan LLP, who shall be responsible for them and for the conduct of the cause and of the admitted attorney herein; 5. David B. Franco, Esq. must, within 10 days, pay the fees required by Rule 1:20- 1(b) and Rule 1:28-2 and submit affidavits of compliance; 6. Automatic termination of pro hac vice admission will occur for failure to make the required annual payments to the Ethics Financial Committee and the New Jersey Lawyer’s Fund for Client Protection. Proof of such payment, after filing proof of the initial payment, shall be made no later than February 1st, of each year; 7. Non-compliance with any of these requirements shall constitute grounds for removal; and, 8. That a copy of this Order shall be served on all parties within seven (7) days. /s/ James F. Hyland Hon. James F. Hyland, J.S.C. [X] Unopposed “Having found the motion documents were served in accordance with R.1:6-3, this instant motion is deemed uncontested and is decided essentially for the reasons set forth in the moving papers pursuant to R.1:6-2.” FILED September 17 , 2020 Hon. James F. Hyland, J.S.C. 2 MID-L-003868-20 11/09/2020 10:11:38 AM Pg 1 of 2 Trans ID: LCV20202014651 EXHIBIT B MID-L-003868-20 11/09/2020 10:11:38 AM Pg 2 of 2 Trans ID: LCV20202014651