Legal Document: Pandelo Corinne Vs The Governing Body O F Jehova

On August 18, 2021 a MOTION FOR ADMISSION PRO HAC VICE submitted by KESSLER, RAYNA, ELIZABETH of ROBINS KAPLAN LLP on behalf of CORINNE PANDELO against THE GOVERNING BODY OF JEHOVAHS WITNESSES, FAIRLAWN CONGREGATION OF JEHOVAHS WITNESSES, WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, HACKENSACK CONGREGATION OF JEHOVAHS WITNESSES, JOHN AND JANE DOES 1-100 was filed involving a dispute between Corinne Pandelo, and -100 John And Jane Does 1, Fairlawn Congregation Of Jehov, Hackensack Congregation Of Jeh, The Governing Body Of Jehovahs, Watchtower Bible Andtract Soc, for Personal Injury in the District Court of Bergen County.

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ROBINS KAPLAN LLP
Rayna E. Kessler, Esq.
NJ ID No. 031782010
1325 Avenue of the Americas, Suite 2601
New York, New York 10019
Telephone: (212) 980-7431
Facsimile: (212) 980-7499
Email: RKessler@RobinsKaplan.com

THE ZALKIN LAW FIRM, P.C.
Elizabeth A. Cate, Esq. (admitted pro hac vice)
10 Times Square
1441 Broadway, Suite 3147
New York, NY 10018
Telephone: (858) 259-3011
Email: elizabeth@zalkin.com

Attorneys for Plaintiff Corinne Pandelo

:
CORINNE PANDELO, : SUPERIOR COURT OF NEW JERSEY
: LAW DIVISION – BERGEN COUNTY
Plaintiff, :
: DOCKET NO. BER-L-005508-21
v. :
:
THE GOVERNING BODY OF : CIVIL ACTION
JEHOVAH’S WITNESSES; :
FAIRLAWN CONGREGATION OF :
JEHOVAH’S WITNESSES; : NOTICE OF MOTION FOR
WATCHTOWER BIBLE AND TRACT : ADMISSION PRO HAC VICE OF
SOCIETY OF NEW YORK; : ELIZABETH HILLER, ESQ.
HACKENSACK CONGREGATION OF :
JEHOVAH’S WITNESSES; and JOHN :
AND JANE DOES 1-100, whose identities :
are presently unknown to Plaintiff, in their :
official and individual capacities, :
:
Defendants. :
:
:
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TO: Reymond E. Yammine, Esq.
Anthony P. La Rocco, Esq.
Dana B. Parker, Esq.
K&L GATES LLP
One Newark Center, 10th Floor
Newark, New Jersey 07102
P: (973) 848-4000
F: (973) 848-4001
Attorneys for Defendants Watchtower Bible and Tract Society of
New York, Inc., and East Hackensack Congregation of Jehovah’s
Witnesses (improperly named as Hackensack Congregation

Margaret Korgul, Esq.
MarKorLaw
One Bridge Plaza North, Suite 275
Fort Lee, NJ 07024
T: (973) 986-0372
mkorgul@markorlaw.com
Attorneys for Defendant Fairlawn
Congregation of Jehovah’s Witnesses

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PLEASE TAKE NOTICE that on January 5, 2024, pursuant to Rule 1:21-2, the

undersigned, attorneys for the Plaintiff, CORINNE PANDELO (“Plaintiff”), move before the

Superior Court of New Jersey, Law Division, Bergen County for entry of an Order permitting

Elizabeth Hiller, Esq., to appear pro hac vice in the above-captioned action.

PLEASE TAKE FURTHER NOTICE that in support of the motion, Plaintiff will rely

upon the Certification of Rayna E. Kessler, Esq., and Declaration of Elizabeth Hiller, Esq.,

submitted herewith.

PLEASE TAKE FURTHER NOTICE that a proposed form of Order is submitted

herewith.

PLEASE TAKE FURTHER NOTICE that pursuant to Rule 1:6-2, Plaintiff waives oral

argument as counsel for Defendant has consented to the filing of this motion.

Dated: December 20, 2023 ROBINS KAPLAN, LLP

By: /s/ Rayna E. Kessler
Rayna E. Kessler, Esq.
NJ ID No. 031782010
1325 Avenue of the Americas, Suite 2601
New York, New York 10019
Telephone: (212) 980-7431
Facsimile: (212) 980-7499
Email: RKessler@RobinsKaplan.com

Attorneys for Plaintiff Corinne Pandelo

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:
CORINNE PANDELO, : SUPERIOR COURT OF NEW JERSEY
: LAW DIVISION - BERGEN COUNTY
Plaintiff, :
: DOCKET NO. BER-L-005508-21
v. :
:
THE GOVERNING BODY OF : CIVIL ACTION
JEHOVAH’S WITNESSES; :
FAIRLAWN CONGREGATION OF :
JEHOVAH’S WITNESSES; : [PROPOSED] ORDER ADMITTING
WATCHTOWER BIBLE AND TRACT : ELIZABETH HILLER, ESQ.
SOCIETY OF NEW YORK; : PRO HAC VICE
HACKENSACK CONGREGATION OF :
JEHOVAH’S WITNESSES; and JOHN :
AND JANE DOES 1-100, whose identities :
are presently unknown to Plaintiff, in their :
official and individual capacities, :
:
Defendants. :
:
:

WHEREAS, Robins Kaplan, LLP, counsel for the Plaintiff CORINNE PANDELO, in the

above-captioned action, upon notice to all interested parties, have moved before this Court for the

admission pro hac vice of Elizabeth Hiller, Esq.; the Court having considered the papers in support

thereof; and the Court having found that, Elizabeth Hiller, Esq., is a member in good standing for

the bar of the highest Court in the States of New York and California, the states where she

principally practices law; and further good cause shown,

IT IS on this day of _________, 2024, hereby

ORDERED that the Motion is granted and Elizabeth Hiller, 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:
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1. Elizabeth Hiller, Esq., shall abide by the Rules of Court for the State of New Jersey,
including all disciplinary rules;

2. Elizabeth Hiller, 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
her or her firm that may arise out of her participation in this matter;

3. Elizabeth Hiller, Esq., shall notify the Court immediately of any matter affecting
her standing before this Court;

4. Elizabeth Hiller, 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. Elizabeth Hiller, Esq., must 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.

The Honorable Gregg A. Padovano, J.S.C.

[ ] Opposed
[ ] Unopposed

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THE ZALKIN LAW FIRM, P.C.
Elizabeth A. Cate, Esq. (admitted pro hac vice)
10 Times Square
1441 Broadway, Suite 3147
New York, NY 10018
Telephone: (858) 259-3011
Email: elizabeth@zalkin.com

Attorneys for Plaintiff Corinne Pandelo

:
: SUPERIOR COURT OF NEW JERSEY
CORINNE PANDELO, : LAW DIVISION – BERGEN COUNTY
:
Plaintiff, : DOCKET NO. BER-L-005508-21
:
v. :
: CIVIL ACTION
THE GOVERNING BODY OF :
JEHOVAH’S WITNESSES; :
FAIRLAWN CONGREGATION OF : CERTIFICATION OF
JEHOVAH’S WITNESSES; : RAYNA E. KESSLER, ESQ.
WATCHTOWER BIBLE AND TRACT : IN SUPPORT OF MOTION FOR
SOCIETY OF NEW YORK; : ADMISSION PRO HAC VICE OF
HACKENSACK CONGREGATION OF : ELIZABETH HILLER, ESQ.
JEHOVAH’S WITNESSES; and JOHN :
AND JANE DOES 1-100, whose identities :
are presently unknown to Plaintiff, in their :
official and individual capacities, :
:
Defendants. :
:
:
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I, RAYNA E. KESSLER, ESQ., hereby certifies the following:

1. I am an attorney at law of the State of New Jersey with the law firm of Robins

Kaplan, LLP, attorneys for the Plaintiff CORINNE PANDELO (“Plaintiff”). I am personally

familiar with the facts and set forth herein.

2. I make this Certification in support of Plaintiff’s application to admit Elizabeth

Hiller, Esq., pro hac vice in the above-captioned action.

3. Elizabeth Hiller, Esq., is an attorney with The Zalkin Law Firm, P.C., representing

Plaintiff.

4. Attached hereto is the Declaration of Elizabeth Hiller, Esq. In accordance with Rule

1:4-4(c), I certify that the facsimile signature of Elizabeth Hiller, Esq., is genuine and that the

document or a copy with an original signature will be filed if requested by the Court or a party.

5. It is respectfully submitted that this request for pro hac vice admission of Elizabeth

Hiller, Esq., meets the “good cause” requirement of Rule 1:21-2(b)(3), for the reasons set forth

herein.

6. As indicated in the Declaration of Elizabeth Hiller, Esq., Ms. Hiller is prepared to

comply with the financial requirements imposed by Rules 1:20-1(b) and 1:28-2. Moreover, it is

respectfully submitted that the proposed form of Order being submitted, together with this Motion,

is in compliance with Rule 1:21-2(b).

7. The appearance of Elizabeth Hiller, Esq., shall not delay discovery or the trial of

this action.

8. Pursuant to Court Rule 1:21-2(c)(4), I will sign all papers in these matters and will

be responsible for the conduct of the case as well as for Elizabeth Hiller, Esq., once admitted pro

hac vice.

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9. For the reasons set forth herein and those stated in the Declaration of Elizabeth

Hiller, Esq., Plaintiff respectfully requests that the Court admit Elizabeth Hiller, Esq., pro hac vice

in the above-captioned action.

I hereby 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: December 20, 2023

ROBINS KAPLAN, LLP

Attorneys for Plaintiff Corinne Pandelo

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THE ZALKIN LAW FIRM, P.C.
Elizabeth A. Cate, Esq. (admitted pro hac vice)
10 Times Square
1441 Broadway, Suite 3147
New York, NY 10018
Telephone: (858) 259-3011
Email: elizabeth@zalkin.com

Attorneys for Plaintiff Corinne Pandelo

:
CORINNE PANDELO, : SUPERIOR COURT OF NEW JERSEY
: LAW DIVISION - BERGEN COUNTY
Plaintiff, :
v. : DOCKET NO. BER-L-005508-21
:
THE GOVERNING BODY OF :
JEHOVAH’S WITNESSES; : CIVIL ACTION
FAIRLAWN CONGREGATION OF :
JEHOVAH’S WITNESSES; :
WATCHTOWER BIBLE AND TRACT :
SOCIETY OF NEW YORK; : DECLARATION OF
HACKENSACK CONGREGATION OF : ELIZABETH HILLER, ESQ.
JEHOVAH’S WITNESSES; and JOHN : IN SUPPORT OF MOTION FOR
AND JANE DOES 1-100, whose identities : ADMISSION PRO HAC VICE
are presently unknown to Plaintiff, in their :
official and individual capacities, :
:
Defendants. :
:
:

I, ELIZABETH HILLER, ESQ., hereby declares the following:

1. I am an attorney with The Zalkin Law Firm, P.C., and have my office at 10 Times

Square, 1441 Broadway, Suite 3147, New York, NY 10018. I offer this Declaration in support of
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the application for my admission pro hac vice pursuant to Rule 1:21-2 in the representation of the

Plaintiff CORINNE PANDELO in this action, venued in Bergen County, New Jersey, including

all pretrial matters and the trial thereof.

2. I graduated from the New York University School of Law in 2000 and have been

licensed to practice in the State of California since 2000 and in the State of New York since 2019.

I am domiciled in the State of New York and principally practice law in the State of New York,

where I have been licensed since 2019 and where my law firm maintains an office in which I

practice. I am currently a member in good standing of the State Bar of California and the State Bar

of New York.

3. For an extended period of time, The Zalkin Law Firm, P.C. and I have had an

attorney-client relationship with Plaintiff Corinne Pandelo, who has specifically requested that I

continue to represent her in the above-captioned case.

4. This action involves a complex field of law in which I have extensive experience.

5. I understand that I will associate in this matter with our New Jersey counsel of

record, Rayna E. Kessler, Esq., as required by Rule 1:21–2.

6. I have reviewed the New Jersey Rules of Court and agree to comply with said Rules,

including all disciplinary rules.

7. Specifically, I agree to:

a. Pay all fees required by Rule 1:20-(b) and the Lawyers’ Fund for Client
Protection, Disciplinary Oversight Committee, and New Jersey Lawyers’
Assistance Program pursuant to Rule 1:28-2 and submit an affidavit of
compliance including all disciplinary rules;

b. Abide by the New Jersey Court Rules, including disciplinary rules;

c. Notify this Court immediately of any matter affecting my standing at any
court to which I am admitted; and

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BER-L-005508-21 12/20/2023 6:06:12 PM Pg 1 of 2 Trans ID: LCV20233684481

THE ZALKIN LAW FIRM, P.C.
Elizabeth A. Cate, Esq. (admitted pro hac vice)
10 Times Square
1441 Broadway, Suite 3147
New York, NY 10018
Telephone: (858) 259-3011
Email: elizabeth@zalkin.com

Attorneys for Plaintiff Corinne Pandelo

:
CORINNE PANDELO, : SUPERIOR COURT OF NEW JERSEY
: LAW DIVISION – BERGEN COUNTY
Plaintiff, :
: DOCKET NO. BER-L-005508-21
v. :
:
THE GOVERNING BODY OF : CIVIL ACTION
JEHOVAH’S WITNESSES; :
FAIRLAWN CONGREGATION OF :
JEHOVAH’S WITNESSES; :
WATCHTOWER BIBLE AND TRACT :
SOCIETY OF NEW YORK; :
HACKENSACK CONGREGATION OF : CERTIFICATE OF SERVICE
JEHOVAH’S WITNESSES; and JOHN :
AND JANE DOES 1-100, whose identities :
are presently unknown to Plaintiff, in their :
official and individual capacities, :
:
Defendants. :
:
:
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I, Rayna E. Kessler Esq., certify that a copy of the Motion of Elizabeth Hiller Esq., to

practice in this Court pro hac vice, supporting papers, and proposed form of Order which, if

granted, would permit such practice in this Court, was electronically filed with the Clerk of Court

for Bergen County via the New Jersey eCourts electronic filing system, and served upon all counsel

of record.

Additionally, a paper courtesy copy is being sent via overnight delivery to:

The Honorable Gregg A. Padovano, J.S.C.
Superior Court of New Jersey
Bergen County Courthouse
10 Main Street, 3rd Floor, Rotunda
Hackensack, New Jersey 07601

Dated: December 20, 2023

ROBINS KAPLAN, LLP

Attorneys for Plaintiff Corinne Pandelo

Case Info

Judge

Gregg A Padovano Track Judge’s New Case

Case No.

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Document Filed Date

December 20, 2023

Case Filing Date

August 18, 2021

County

Parties

-100 John And Jane Does 1 Defendant
Anthony P La Rocco Attorney for the Defendant
Carl Judah Schaerf Attorney for the Defendant
Corinne Pandelo Plaintiff
Dana Beth Parker Attorney for the Defendant
Fairlawn Congregation Of Jehov Defendant
Hackensack Congregation Of Jeh Defendant
Margaret T Korgul Attorney for the Defendant
Rayna Elizabeth Kessler Attorney for the Plaintiff
The Governing Body Of Jehovahs Defendant
Watchtower Bible Andtract Soc Defendant
Thomas Zelante Attorneys for Defendants
Raymond Hunter Attorneys for Defendants
JAMES FANT Attorney
Robyn Rubin Attorney

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Document for Pandelo Corinne Vs The Governing Body O F Jehova

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Case Info

Parties