Document for Joe Carl Rogers, et al Plaintiff vs. Certainteed Corporation Defendant

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                                Filing # 106842953 E-Filed 04/29/2020 12:38:34 PM

IN THE CIRCUIT COURT OF THE
17™ JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA

GENERAL JURISDICTION DIVISION

CASE NO. 19-025692 ca 27
JOE CARL ROGERS and

HILDA ROGERS, his wife, Rebecca S. Vinocur: 529915

J. Andrew Sealey: 52857
Plaintiffs,

vs.

ACOUSTI ENGINEERING
COMPANY OF FLORIDA, et al.,

Defendants.
/
————/

VERIFIED MOTION FOR ADMISSION TO APPEAR PRO HAC VICE
PURSUANT TO FLORIDA RULE OF JUDICIAL ADMINISTRATION 2.510

COMES NOW Todd R. Gampp, Movant herein, and respectfully represents the

following:

1. Movant resides in Saint Louis, Missouri. Movant is not a resident of the State of
Florida.

2. Movant is an attorney and a member of the law firm of Simmons Hanly Conroy,

with offices at One Court Street, Alton, Illinois and 112 Madison Avenue, 7" Floor, New York,
NY 10016; Phone: (618) 259-2222 and (212) 784-6400.

3. Movant has been retained personally or as a member of the above-named law firm
on January 23, 2020, by Joe Carl Rogers and Hilda Rogers to provide legal representation in
connection with the above-styled matter now pending before the above-named court of the State
of Florida.

4. Movant is an active member in good standing and currently eligible to practice law

in the following jurisdiction(s):

*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/29/2020 12:38:31 PM.****Admitted to the State Bar of Illinois, State Bar No. 6318749

Admitted to the State Bar of Missouri, State Bar No. 60918

Admitted to the State Bar of Pennsylvania, State Bar No. 317384

5. Movant has never been subject to any disciplinary, suspension, disbarment or
contempt proceedings.

6. Movant, either by resignation, withdrawal, or otherwise, has never terminated or
attempted to terminate Movant' s office as an attorney in order to avoid administrative,
disciplinary, disbarment, or suspension proceedings.

7. Movant is not an inactive member of the Florida Bar.

8. Movant is not now a member of the Florida Bar.

9. Movant is not a suspended member of the Florida Bar.

10. Movant is not a disbarred member of the Florida Bar nor has Movant received a
disciplinary resignation from the Florida Bar.

11. Movant has not previously been disciplined or held in contempt by reason of
misconduct committed while engaged in representation pursuant to Florida Rule of Judicial
Administration 2.510.

12. Movant has filed a motion to appear as counsel in Florida state courts during the
past five (5) years: Not applicable.

13. Local counsel of record associated with Movant in this matter is Rebecca Vinocur,
Florida State Bar Number 529915, who is an active member in good standing of the Florida Bar
and has offices at 5915 Ponce De Leon Blvd., Ste. 14, Coral Gables, FL 33146.

13. Movant has read the applicable provisions of Florida Rule of Judicial Administration
2.510 and Rule 1-3.10 of the Rules Regulating the Florida Bar and certifies that this verified

motion complies with those rules.

14, Movant agrees to comply with the provisions of the Florida Rules of ProfessionalConduct and consents to the jurisdiction of the courts and the Bar of the State of Florida.

WHEREFORE, Movant respectfully requests permission to appear in this court for this

cause only.

DATED this 29" day of April, 2020.

Respectfully submitted,

\s| Rebecca S, Vinoeur

REBECCA S. VINOCUR

Florida Bar No.: 529915

5915 Ponce De Leon Blvd, Ste. 14
Coral Gables, Florida 33146-2435
Tel: 786-691-1282

Fax: 786-691-1283
rvinocur@rsv-law.com

and

/s/__ Todd R. Gam
Todd R. Gampp, Esq.

Simmons Hanly Conroy
One Court Street

Alton, IL 62002

Tel: (618) 259-2222

Fax: (618) 259-2251
tgampp@simmonsfirm.comThereby consent to be associated as local counsel of record in this cause pursuant to

Florida Rule of Judicial Administration 2.510.

DATED this 29" day of April, 2020.

| Rebecca S. Vinoeun

REBECCA S. VINOCUR

Florida Bar No.: 529915

REBECCA S. VINOCUR, P.A.
5915 Ponce De Leon Blvd., Ste. 14
Coral Gables, Florida 33146

Tel.: (786) 691-1282

Fax: (786) 691-1283
rvinocur(@rsv-law.com

 

CERTIFICATE OF SERVICE

 

1 HEREBY CERTIFY that a true and correct copy of the foregoing motion was served
via Lexis File&Serve Xpress upon all counsel of record and upon the Florida Bar at its
Tallahassee office, along with a check in the amount of $250.00 and a filing fee in the amount
of $100.00 to the Clerk of Court in the above-named Court of the State of Florida, on this 29"
day of April, 2020.

Isl Rebecca S. Vinoeun

REBECCA S. VINOCUR
Florida Bar No.: 529915VERIFICATION OF MOVANT, TODD R. GAMPP

 

STATE ORYLECA LYS
AL plot
county or /¥ (Adise7te

or an wor

1, Todd R. Gampp, do hereby swear or affirm under penalty of perjury that | am the Movant
in the above-styled matter, that | have read the foregoing Motion and know the contents thereof:
that the contents are true to best of my knowledge and belief.

a >

Todd R. Gampp
Movant/A ffidavit

The foregoing instrument was acknowledged before me this _. y 2 day oLéprl

(dye

, 2020 by Todd R. Gampp.

  

Notary Public

My commission expires on butte. S ; M23Rebecca S. Vinocur, P.A.
Attomey at Law

Suite 14

5915 Ponce De Leon Blvd.

Coral Gables, Florida 33146
Rebecca S. Vinocur Telephone: 786-691-1282
rvinocur@rsv-law.com Facsimile: 786-691-1283

April 29, 2020

Via US. Mail
The Florida Bar

651 East Jefferson Street
Tallahassee, FL 32399-2300

Re: — Joe Carl Rogers et al, vs. Acousti Engineering Company of Florida, et al.
Broward Circuit Court Case No. 19-025692 CA27

Dear Sir or Madam:
Enclosed please find copies of the following:

Verified Motion for Admissions to Appear Pro Hac Vice of Todd R. Gampp.
Our firm’s check in the amount of $250.00 payable to the Florida Bar.

Should you require additional information, please do not hesitate to contact the
undersigned.

Sincerely,
|
er, i iy.
~Adtiana’Ayala, Paralegal to
REBECCA 8. VINOCUR
V

 

faa
Enclosures (as stated above)
ce: All counsel of record via File&Serve XpressWELLS FARGO BANK, NA 3507
REBECCA S. VINOCUR, PA Miami, Florida
5915 Ponce De Leon Boulevard, Ste. 14
Coral Gables, FL 33146 04/29/2020
PAY TO THE The Florida Bar $ 250.00
ORDER OF J
Two hundred fifty and 00/100**+**s++++0ssseeesssssarsevnsvoseeenesssazesiasasscasvnssservuasnazegyansisnvesnenssnvestesse
DOLLARS fi
The Florida Bar i }

  
 

Rogers - Todd R. Gamp