Party Statement: Sonny St. John Individually and on Behalf of All Others Similarly Situated, v. Cloopen Group Holding Limited, Changxun Sun, Yipeng Li, Kui Zhou, Qingsheng Zheng, Xiaodong Liang, Zi Yang, Ming Liao, Feng Zhu, Lok Yan Hui, Jianhong Zhou, Ching Chiu, Cogency Global Inc., Colleen A. Devries, Goldman Sachs (Asia) L.L.C., Citigroup Global Markets, Inc., China International Capital Corporation Hong Kong Securities Limited, Tiger Brokers (Nz) Limited, Futu, Inc.

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                                FILED: NEW YORK COUNTY CLERK 12/19/2023 05:43 PM                                                INDEX NO. 652617/2021
NYSCEF DOC. NO. 115                                                                       RECEIVED NYSCEF: 12/19/2023




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF NEW YORK: COMMERCIAL DIVISION


          SONNY ST. JOHN, Individually and on Behalf of All
          Others Similarly Situated,

                                      Plaintiff,
                                                                        Index No. 652617/2021
                           v.
                                                                        Part 53: Hon. Andrew Borrok
         CLOOPEN GROUP HOLDING LIMITED,
         CHANGXUN SUN, YIPENG LI, KUI ZHOU,
         QINGSHENG ZHENG, XIAODONG LIANG, ZI                            Motion Seq. No. 010
         YANG, MING LIAO, FENG ZHU, LOK YAN HUI,
         JIANHONG ZHOU, CHING CHIU, COGENCY                             AFFIRMATION OF MAX R.
         GLOBAL INC., COLLEEN A. DEVRIES, GOLDMAN                       SCHWARTZ IN SUPPORT OF
         SACHS (ASIA) L.L.C., CITIGROUP GLOBAL                          PRO HAC VICE ADMISSION OF
         MARKETS INC., CHINA INTERNATIONAL                              MICHAEL DELL’ANGELO
         CAPITAL CORPORATION HONG KONG
         SECURITIES LIMITED, TIGER BROKERS (NZ)
         LIMITED, and FUTU, INC.,

                                      Defendants.


                 Max R. Schwartz, an attorney duly admitted to practice law by and before the courts of the

          State of New York, upon information and belief, affirms the following to be true under the

          penalties of injury:

                 1.      I am a partner with the law firm of Scott+Scott Attorneys at Law LLP, attorneys

          for Plaintiff Sonny St. John. I am fully familiar with the facts and circumstances as alleged by

          virtue of the file maintained in my office in the prosecution of this action.

                 2.      This affirmation is submitted in support of Plaintiff’s motion for an order granting

          admission of Michael Dell’Angelo, Esq., to practice in this Court pro hac vice for the purpose of

         assisting in the prosecution of the above-captioned matter.

                 3.      Michael Dell’Angelo, Esq., is an executive shareholder of the law firm of Berger

          Montague PC and is a member in good standing of the Bars of the Commonwealth of Pennsylvania

          and State of New Jersey. He is also admitted to practice in the United States District Court for the




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FILED: NEW YORK COUNTY CLERK 12/19/2023 05:43 PM                                                  INDEX NO. 652617/2021
NYSCEF DOC. NO. 115                                                                       RECEIVED NYSCEF: 12/19/2023




          District of Columbia, United States District Court for the Northern District of Illinois, United

          States District Court for the District of New Jersey, United States District Court for the Eastern

          District of Pennsylvania, and the United States Courts of Appeals for the Second, Fourth, and

          Eleventh Circuits.

                 4.      By affidavit, Mr. Dell’Angelo agrees to be at all times associated herein with

          counsel who is a member in good standing of the Bar of the State of New York and is an attorney

          of record for the party in question, and agrees that all pleadings, briefs, and other papers filed with

          the Court shall be signed by the attorney of record, who shall be held responsible for such papers

          and for the conduct of this action. Mr. Dell’Angelo further agrees, pursuant to Section 520.11 of

          the Rules of the Court of Appeals and all applicable rules of the Appellate Division, First

          Department, to abide by the standards of professional conduct imposed upon members of the New

          York Bar, including the Rules of the Courts governing the conduct of attorneys and the

          Disciplinary Rules of the Code of Professional Responsibility. Mr. Dell’Angelo further agrees to

          be subject to the jurisdiction of the courts of the State of New York with respect to any acts

          occurring during the course of his participation in this matter. Mr. Dell’Angelo further agrees to

          notify the Court immediately of any matter or event in this or any other jurisdiction that affects his

          standing as a member of the Bar. The affidavit of Mr. Dell’Angelo is attached hereto as Exhibit

          A and submitted in support of the application for his admission pro hac vice.

                 5.      A Certificate of Good Standing for attorney Michael Dell’Angelo, Esq., is annexed

          as Exhibit 1 to his Affidavit and submitted in support of his application for admission pro hac vice.

                 6.      All pleadings, briefs, and other papers filed with this Court will be signed by an

          attorney of record authorized to practice in this State and, more specifically, by the firm of

          Scott+Scott Attorneys at Law LLP, or any other firm of the State of New York that may be retained



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FILED: NEW YORK COUNTY CLERK 12/19/2023 05:43 PM                                               INDEX NO. 652617/2021
NYSCEF DOC. NO. 115                                                                    RECEIVED NYSCEF: 12/19/2023




          to succeed that firm. Scott+Scott Attorneys at Law LLP and/or any successor firm shall be held

         responsible for said pleadings, briefs, and other papers and for the conduct before the Court by

         attorney Michael Dell’Angelo, Esq.

                 7.     Plaintiff Sonny St. John seeks admission pro hac vice of attorney Michael

         Dell’Angelo, Esq., to assist in his representation in this matter.

                 8.     No previous application has been made for the relief sought herein.

                 9.     A proposed Order granting the relief requested is respectfully submitted herewith.

                 WHEREFORE, Plaintiff Sonny St. John requests an Order granting attorney Michael

         Dell’Angelo, Esq., admission pro hac vice.

           Dated: December 19, 2023                     SCOTT+SCOTT ATTORNEYS AT LAW LLP
                  New York, NY
                                                         /s/ Max R. Schwartz
                                                        Max R. Schwartz
                                                        The Helmsley Building
                                                        230 Park Avenue, 17th Floor
                                                        New York, NY 10174
                                                        Telephone: (212) 223-6444
                                                        Facsimile: (212) 223-6334
                                                        mschwartz@scott-scott.com

                                                        Counsel for Plaintiff Sonny St. John




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