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Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 01 6:28 PM-20CV007082
06530 - J1
IN THE COMMON PLEAS COURT OF FRANKLIN COUNTY, OHIO
GENERAL DIVISION
APF — CRE I, LLC & Case No. 20CV007082
APF — CPX I, LLC,
MAGISTRATE JENNIFER CORDLE
Plaintiffs,
PLAINTIFFS APF - CRE I, LLC &
Vv. APF - CPX I, LLC’S MOTION FOR
ADMISSION PRO HAC VICE OF
TEHRAH HOSPITALITY, LLC, ABHIJIT S. ALEXANDRA NELSON
VASANI & BHAVNA A. VASANI,
Defendants.
Pursuant to Gov.Bar R. XII(2)(A)(6), Plaintiffs APF - CRE I, LLC and APF — CPX I,
LLC (“Plaintiffs”), hereby move the Court of Common Pleas for Franklin County, Ohio to grant
Alexandra Nelson permission to appear pro hac vice and participate as co-counsel in this case for
Plaintiffs.
The following is a list of jurisdictions in which Ms. Nelson has ever been licensed to
practice law, including dates of admission to practice, resignation, or retirement, and any
attorney registration numbers:
© State of Georgia, admitted on November 9, 2011 (Attorney ID No. 241352); active and in
good standing.
Ms. Nelson represents that she has not been granted permission to appear pro hac vice in
more than three proceedings before Ohio tribunals in the current calendar year pursuant to Gov.
Bar. R. XII(2)(A)(5).
Sean A. Gordon of Thompson Hine, LLP, an active Ohio attorney in good standing, has
agreed to associate with Ms. Nelson in this case.
The affidavit required by Gov. Bar. R. XII(2)(A)(6), a copy of Movant’s certificate of pro
hac vice registration furnished by the Supreme Court of Ohio Office of Attorney Services,
and a
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 01 6:28 PM-20CV007082
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certificate indicating service of this Motion on all known parties and attorneys of record are
attached. Ms. Nelson understands that, if this Motion is granted, she must file a Notice of
Permission to Appear Pro Hac Vice and a copy of the Order granting permission with the
Supreme Court of Ohio Office of Attorney Services within 30 days of the Order.
Respectfully submitted,
/s/ Sean A. Gordon
Sean A. Gordon (#0074243)
Mary Csarny (#0097682)
THOMPSON HINE LLP
3900 Key Center
127 Public Square
Cleveland, Ohio 44114-1291
Telephone: 216.566.5500
Fax: 216.566.5800
Sean.Gordon@ThompsonHine.com
Mary.Csarny@ThompsonHine.com
Austin Alexander (PHV-26821-2023)
Two Alliance Center
3560 Lenox Road NE, Suite 1600
Atlanta, Georgia 30326-4266
Phone: (404) 541-2900
Fax: (404) 541-2905
Austin. Alexander@ThompsonHine.com
Attorneys for Plaintiff
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 01 6:28 PM-20CV007082
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CERTIFICATE OF SERVICE
I hereby certify that on September 1, 2023, I electronically filed the foregoing with the
Clerk of the Court using the electronic filing system which will send notification of such filing to
the following:
Troy J. Doucet
655 Metro Place South, Suite 600
Dublin, Ohio 43017
troy@doucet.law
/s/Sean A. Gordon
Sean A. Gordon (#0074243)
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 01 6:28 PM-20CV007082
06530 - J1
THE SUPREME CowurT of OHIO
Orrice of ATTORNEY SERVICES
Certificate of
IN THE MATTER OF THE APPLICATION OF
PRO HAC VICE
REGISTRATION
Alex Nelson
2023
FOR PRO HAC VICE REGISTRATION
per Gov. Bar R. XII, Section 2(A)(3) Registration Number:
PHV- 27040-2023
Alex Nelson
, having met the requirements of, and found to be in
full compliance with, Section 2(A)(3) of Rule XII of the Rules for the Government of the Bar of
Ohio, is hereby issued this certificate of pro hac vice registration in the state of Ohio.
To receive permission to appear pro hac vice in,an Ohio proceeding, a motion requesting such
permission must be filed with the tribunal in accordance with Section 2(A)(6) of Rule XII of the
Rules for the Government of the Bar of Ohio.
Jun
GWfo .
Gina White Palmer
Director, Attorney Services
Expires December 31, 2023
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 01 6:28 PM-20CV007082
DG530 - J2
IN THE COURT OF COMMON PLEAS
FRANKLIN COUNTY, OHIO
GENERAL DIVISION
APF —CREI, LLC & Case No. 20CV007082
APF — CPX I, LLC,
MAGISTRATE JENNIFER CORDLE
Plaintiffs,
Vv. AFFIDAVIT OF OUT-OF-STATE
ATTORNEY ALEX NELSON (Gov.
TEHRAH HOSPITALITY, LLC, ABHIJIT S. Bar R. XII, Section 2(A)(6))
VASANI & BHAVNA A. VASANI,
Defendants.
STATE OF GEORGIA )
) ss
COUNTY OF Dekalb)
I, Alexandra Nelson, being first duly cautioned, swear or affirm as follows:
1 Ihave never been disbarred from the practice of law.
2. Ihave been admitted to the practice of law in the following jurisdictions:
° State of Georgia, admitted on November 9, 2011 (Attorney ID No. 241352).
3 1 am not currently suspended from the practice of law in any jurisdiction where I
have been admitted to practice.
4 I am presently a partner with the law firm Thompson Hine LLP, in its offices at
Two Alliance Center, 3560 Lenox Road NE, Suite 1600, Atlanta, Georgia 30326-4266.
5 I have not resigned from the practice of law with discipline pending in any
jurisdiction where I have been admitted to practice.
6 I am familiar with the Court’s Local Rules, the Ohio Civil Rules, the
Rules of
Evidence, and the Rules of Professional Conduct,
FURTHER AFFIANT SAYETH NAUGHT.
4854-26 11-3638
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 01 6:28 PM-20CV007082
DG530 - J2
(lim peta.
ALEXANDRA NELSON
Residential Address
1144 Haven Glen Lane
Brookhaven, GA 30319
Sworn to or affirmed before me and subscribed in my presence this QO day of
August, 2023, in the state of Ge Orda County of Fulton
i arouy /Meren
Notary Public
My Commission Expires July q 2027 allay,
cey erg ny,
> Sea eee
“ qoTaRy Rs
; EXPIRES .
! GEORGIA :
07-09-2027;
On UBS,
Tee ZX
Ny, 7ob COUN
AW
4854-26 11-3638
Preview
Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 01 6:28 PM-20CV007082 06530 - J1 IN THE COMMON PLEAS COURT OF FRANKLIN COUNTY, OHIO GENERAL DIVISION APF — CRE I, LLC & Case No. 20CV007082 APF — CPX I, LLC, MAGISTRATE JENNIFER CORDLE Plaintiffs, PLAINTIFFS APF - CRE I, LLC & Vv. APF - CPX I, LLC’S MOTION FOR ADMISSION PRO HAC VICE OF TEHRAH HOSPITALITY, LLC, ABHIJIT S. ALEXANDRA NELSON VASANI & BHAVNA A. VASANI, Defendants. Pursuant to Gov.Bar R. XII(2)(A)(6), Plaintiffs APF - CRE I, LLC and APF — CPX I, LLC (“Plaintiffs”), hereby move the Court of Common Pleas for Franklin County, Ohio to grant Alexandra Nelson permission to appear pro hac vice and participate as co-counsel in this case for Plaintiffs. The following is a list of jurisdictions in which Ms. Nelson has ever been licensed to practice law, including dates of admission to practice, resignation, or retirement, and any attorney registration numbers: © State of Georgia, admitted on November 9, 2011 (Attorney ID No. 241352); active and in good standing. Ms. Nelson represents that she has not been granted permission to appear pro hac vice in more than three proceedings before Ohio tribunals in the current calendar year pursuant to Gov. Bar. R. XII(2)(A)(5). Sean A. Gordon of Thompson Hine, LLP, an active Ohio attorney in good standing, has agreed to associate with Ms. Nelson in this case. The affidavit required by Gov. Bar. R. XII(2)(A)(6), a copy of Movant’s certificate of pro hac vice registration furnished by the Supreme Court of Ohio Office of Attorney Services, and a Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 01 6:28 PM-20CV007082 06530 - J1 certificate indicating service of this Motion on all known parties and attorneys of record are attached. Ms. Nelson understands that, if this Motion is granted, she must file a Notice of Permission to Appear Pro Hac Vice and a copy of the Order granting permission with the Supreme Court of Ohio Office of Attorney Services within 30 days of the Order. Respectfully submitted, /s/ Sean A. Gordon Sean A. Gordon (#0074243) Mary Csarny (#0097682) THOMPSON HINE LLP 3900 Key Center 127 Public Square Cleveland, Ohio 44114-1291 Telephone: 216.566.5500 Fax: 216.566.5800 Sean.Gordon@ThompsonHine.com Mary.Csarny@ThompsonHine.com Austin Alexander (PHV-26821-2023) Two Alliance Center 3560 Lenox Road NE, Suite 1600 Atlanta, Georgia 30326-4266 Phone: (404) 541-2900 Fax: (404) 541-2905 Austin. Alexander@ThompsonHine.com Attorneys for Plaintiff Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 01 6:28 PM-20CV007082 06530 - J1 CERTIFICATE OF SERVICE I hereby certify that on September 1, 2023, I electronically filed the foregoing with the Clerk of the Court using the electronic filing system which will send notification of such filing to the following: Troy J. Doucet 655 Metro Place South, Suite 600 Dublin, Ohio 43017 troy@doucet.law /s/Sean A. Gordon Sean A. Gordon (#0074243) Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 01 6:28 PM-20CV007082 06530 - J1 THE SUPREME CowurT of OHIO Orrice of ATTORNEY SERVICES Certificate of IN THE MATTER OF THE APPLICATION OF PRO HAC VICE REGISTRATION Alex Nelson 2023 FOR PRO HAC VICE REGISTRATION per Gov. Bar R. XII, Section 2(A)(3) Registration Number: PHV- 27040-2023 Alex Nelson , having met the requirements of, and found to be in full compliance with, Section 2(A)(3) of Rule XII of the Rules for the Government of the Bar of Ohio, is hereby issued this certificate of pro hac vice registration in the state of Ohio. To receive permission to appear pro hac vice in,an Ohio proceeding, a motion requesting such permission must be filed with the tribunal in accordance with Section 2(A)(6) of Rule XII of the Rules for the Government of the Bar of Ohio. Jun GWfo . Gina White Palmer Director, Attorney Services Expires December 31, 2023 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 01 6:28 PM-20CV007082 DG530 - J2 IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO GENERAL DIVISION APF —CREI, LLC & Case No. 20CV007082 APF — CPX I, LLC, MAGISTRATE JENNIFER CORDLE Plaintiffs, Vv. AFFIDAVIT OF OUT-OF-STATE ATTORNEY ALEX NELSON (Gov. TEHRAH HOSPITALITY, LLC, ABHIJIT S. Bar R. XII, Section 2(A)(6)) VASANI & BHAVNA A. VASANI, Defendants. STATE OF GEORGIA ) ) ss COUNTY OF Dekalb) I, Alexandra Nelson, being first duly cautioned, swear or affirm as follows: 1 Ihave never been disbarred from the practice of law. 2. Ihave been admitted to the practice of law in the following jurisdictions: ° State of Georgia, admitted on November 9, 2011 (Attorney ID No. 241352). 3 1 am not currently suspended from the practice of law in any jurisdiction where I have been admitted to practice. 4 I am presently a partner with the law firm Thompson Hine LLP, in its offices at Two Alliance Center, 3560 Lenox Road NE, Suite 1600, Atlanta, Georgia 30326-4266. 5 I have not resigned from the practice of law with discipline pending in any jurisdiction where I have been admitted to practice. 6 I am familiar with the Court’s Local Rules, the Ohio Civil Rules, the Rules of Evidence, and the Rules of Professional Conduct, FURTHER AFFIANT SAYETH NAUGHT. 4854-26 11-3638 Franklin County Ohio Clerk of Courts of the Common Pleas- 2023 Sep 01 6:28 PM-20CV007082 DG530 - J2 (lim peta. ALEXANDRA NELSON Residential Address 1144 Haven Glen Lane Brookhaven, GA 30319 Sworn to or affirmed before me and subscribed in my presence this QO day of August, 2023, in the state of Ge Orda County of Fulton i arouy /Meren Notary Public My Commission Expires July q 2027 allay, cey erg ny, > Sea eee “ qoTaRy Rs ; EXPIRES . ! GEORGIA : 07-09-2027; On UBS, Tee ZX Ny, 7ob COUN AW 4854-26 11-3638