On March 21, 2018 a
Request,Application
was filed
involving a dispute between
Song, Ingeun,
and
Arias, Diana,
Cao, Yi,
China International Capital Corporation Hong Kong Securities Limited,
Citigroup Global Markets Inc.,
Credit Suisse Securities,
Du, Li,
Li, Shilei,
Luo, Min,
Lv, Lianzhu,
Morgan Stanley & Co., International Plc,
Needham & Company, Llc,
Nicolaus & Company, Inc,
Nomura Securities International, Inc.,
Qudian, Inc.,
Shu, Chao,
Stifel, Nicolaus & Company, Inc.,
Ubs Securities Llc,
Yeung, Carl,
Zhu, Tianyu,
for (28) Complex Unlimited Securities Litigation
in the District Court of San Mateo County.
Preview
ORGINN.
Laurence M. Rosen, Esq. (SBN 219683)
THE ROSEN LAW FIRM, PA.
355 South Grand Avenue, Suite 2450
FI ED
SAN MATEO COUNTY
Los Angeles, CA 90071 JUN 2 6 2018
Telephone: (213) 785-2610
Facsimile: (213) 226—4684
Email: lrosen@rosenlegal.com
\OOOflmm-hUJNr—t
Counsel for Plaintiff
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN MATEO
INGEUN SONG, Individually and on Behalf of ) Case No.: l8CIV01425
All Others Similarly Situated, )
) (1) NOTICE OF APPLICATION FOR
Plaintiff, ) ADMISSION OF DAVID P. DEAN TO STATE
) BAR PRO HAC VICE;
v. )
) (2) MEMORDANDUM OF POINTS A
~
QUDIAN INC., MIN LUO, CARL YEUNG, ) AUTHORITIES IN SUPPORT THEREOF;
LIANZHU LV, YI CAO, SHILEI LI, LI DU, )
CHAO ZHU, TIANYU ZHU, DIANA ARIAS, ) (3) VERIFIED APPLICATION OF DAV
MORGAN STANLEY & CO. ) P. DEAN
INTERNATIONAL PLC, CREDIT SUISSE )
SECURITIES (USA) LLC, CITIGROUP ) (4) DECLARATION OF LAURENCE M.
GLOBAL MARKETS INC., CHINA
NNNNNNNNNP—‘Hr—‘I—ir—lh—‘HI—‘I—lb—l
) ROSEN;
INTERNATIONAL CAPITAL )
mflam-PWNHOKDOOQONU‘I-p-WNI—‘o
CORPORATION HONG KONG ) (5) [PROPOSED ORDER]; and
SECURITIES LIIVIITED, UBS )
SECURITIES LLC, STIFEL, NICOLAUS & ) (6) PROOF OF SERVICE (filed under
COMPANY, INC, NEEDHAM & COMPANY, ) separate cover).
LLC, and NOMURA SECURITIES
INTERNATIONAL, IN C.,
_ h —
vvvvv
1s—cIv—o1425
.
APHV
Defendants. Application to A pp e ar as .
Counsel Pro Han Vice
.
1229837
; Illl11111111111111!!!“Hill!!!ll
-1-
APPLICATION FOR PRO HAC VICE ADMISSION OF DAVID P. DEAN
TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF-RECORD, PLEASE
TAKE NOTICE that on June 26, 2018 that an Application for Admission of David P. Dean To State
Bar Pro Hac Vice was filed with the Court. Upon instructions by the Court, the undersigned
counsel will provide notice of any hearing upon this Application if scheduled by the Court. As
\OOO\]O\U1-l>Wl\J>—t
indicated in the declaration of Laurence M. Rosen filed herewith, defendants have received notice
of this application and do not oppose my application.
This Application will be, and hereby is, brought pursuant to Rule 9.40 of the California
Rules of Court, on the ground that the above-named attorney is not a member of the State Bar of
California; that he meets the requirements set forth in Rule 9.40; and that this Application is brought
by an active member of the State Bar of California, who is a member of the firm acting as counsel
for Plaintiffs.
This Application is based on this Notice, the accompanying Memorandum of Points and
Authorities, the Declaration of Laurence M. Rosen, the Verified Application of David P. Dean, all
exhibits filed in support of this Application, all pleadings, records and papers filed in this action,
and such other and further evidence may be presented at or before any Hearing on this Application.
NNNNNNNNNHD—lb—‘r—‘HHP—‘r—lr—‘r—l
Dated: June 26, 2108 Respectfully submitted,
THE ROSEN LAW FIRM, P.A.
mflom-PWNHOKOOOQONM-PWNF—‘O
‘1
By: , a KKK/taken!
Laurence M. Rosen (SBN 219683)
355 South Grand Avenue, Suite 2450
Los Angeles, CA 90071
Tel. (213) 785-2610
Fax: (213) 226—4684
Email: lrosen@rosenlegal.com
Attorneys for Plaintiff
-2-
APPLICATION FOR PRO HAC VICE ADMISSION OF DAVID P. DEAN
MEMORANDUM OF POINTS AND AUTHORITIES
California Rule of Court 9.40 provides, in part, that a person who is not a member of the
State Bar of California but is a member in good standing eligible to practice before the bar of any
United States Court may be permitted to appear as counsel pro hac vice. Permission is granted at
\DOO\IO'\UI-PUJN>—I
the discretion of the Court, upon written application where the attorney seeking admission has been
retained to an appearance in a case pending in a California court. The Verified Application required
by Rule 9.40(d) is attached hereto. A letter to the State Bar of California, enclosing a copy of the
Verified Application for Admission of David P. Dean to the State Bar Pro Hac Vice along with the
requisite State Bar fees, is attached as Exhibit A to the Declaration of Laurence M. Rosen.
Attorney David P. Dean is an attorney in the Jenkintown, Pennsylvania office of The Rosen
Law Firm, PA. and is counsel for plaintiff (“Plaintiff”). It is anticipated that Mr. Dean will appear
on behalf of Plaintiff in the above-titled action and all actions consolidated and/or deemed related
by this Court. For these reasons, it is requested that this Court grant an order admitting Mr. Dean to
the State Bar of California Pro Hac Vice to represent Plaintiffs before this Court in this action and
any other actions consolidated and/or deemed related by the Court.
Dated: June 26, 2018 Respectfully submitted,
NNNNNNNNNHHb—‘HHb—IHr—IHH
ooqom-PWNHOCOOQONU‘l-PWNHO
Laurence M. Rosen (SBN 219683)
355 South Grand Avenue, Suite 2450
Los Angeles, CA 90071
Tel. (213) 785-2610
Fax: (213) 226-4684
Email: lrosen@rosenlegal.com
-3-
APPLICATION FOR PRO HAC VICE ADMISSION OF DAVID P. DEAN
APPLICATION FOR ADMISSION PRO HAC VICE
Pursuant to Rule 9.40 of the California Rules of Court, 1, David P. Dean, hereby request that
I be admitted pro hac vice in the above captioned case. In support of this Application, I declare and
state as follows:
OOOQONM-kWNr—I
1. My home address is 2353 E. Hazzard Street, Philadelphia, PA 19125.
2. I am an attorney at The Rosen Law Firm, P.A., 101 Greenwood Avenue, Suite 440,
Jenkintown, PA 19046.
3. I am not a resident of the State of California, am not regularly employed in the State
of California, and am not regularly engaged in substantial business, professional or other activities
in the State of California.
4. I have been admitted to practice before all state courts in Pennsylvania and Florida,
as well as the United States District Court for the Eastern and Western Districts of Pennsylvania,
and the Middle District of Florida.
5. I am currently a member of good standing of these courts and am not currently
suspended or disbarred in any court.
6. Within the past two years, I have not been admitted pro hac vice to practice in
NNNNNNNNNHHHHP—‘h—lr—‘Hr—‘H
California.
7. Laurence M. Rosen of the law firm of The Rosen Law Firm, P.A., whose California
OOQOM-PWNHOKOOOflQm-PWNt—‘O
office address is 355 South Grand Avenue, Suite 2450 Los Angeles, CA 90071 and whose
telephone number is (213) 785-2610, is an active member of the State Bar of California and shall
act as an attorney of record in this matter.
I, David P. Dean, declare under penalty of perjury under the laws of the State of California
that the foregoing is true and correct to the best of my knowledge, information, and belief.
-4-
APPLICATION FOR PRO HAC VICE ADMISSION OF DAVID P. DEAN
Executed this 26th day of June, 2018, in Jenkintown, Pennsylvania.
\DOONQUI-PUJNH
//@m
David P. Dean
NNNNNNNNNHb—‘r—ir—lr—‘b—lr—‘r—‘r—ii—i
WQONM-PWNHOOOOQONUl-PWNV—‘O
-5-
APPLICATION FOR PRO HAC VICE ADMISSION OF DAVID P. DEAN
DECLARATION OF LAURENCE M. ROSEN
I, Laurence M. Rosen, do declare and state as follows:
1. I am a member of the State Bar of California and the managing attorney of The
Rosen Law Firm, PA, counsel for plaintiff Inguen Song (“Plaintiff”) in the above-captioned action.
I move for admission to the State Bar of California, pro hac vice, of David P. Dean.
\OOO\]O\UI-I>~UJK\Jp—A
2. I am confident that David P. Dean will perform all obligations required of him as a
member of the Bar of this Court.
3. The Verified Application for Admission of David P. Dean to the State Bar Pro Hac
Vice is filed concurrently with this declaration.
4. A true and correct copy of a letter to the State Bar of California, enclosing a copy of
the Verified Application for Admission of David P. Dean to the State Bar Pro Hac Vice, along with
the requisite State Bar fees, is attached hereto as Exhibit A.
I declare under penalty of perjury under the laws of the State of California, that the
foregoing statements are true and correct.
Executed this 26th day of June, 2018 in New York, New York.
m. N 7
Laurenc M. Rosen
mflam-PWNHOKDOOQQM-PWNF—‘O
NNNNNNNNNHHHHHHHHHH
-6—
APPLICATION FOR PRO HAC VICE ADMISSION OF DAVID P. DEAN
éupreme (flifiurt niifiennfil’lhania
CERTIFICATE OF GOOD STANDING
David Paul Dean, Esq.
DATE OF ADMISSION
April 13, 2009-
‘
|
The above named attorney was duly admitted to the bar of the Commonwealth of
Pennsylvania, and is now a-qualified member in good standing.
Witnes'smy hand.~and official seal
Dated: Jungj 5, 2018 Q
\ wax,
r ‘
q n
_
v.1- .i V.
N
rPa'tic‘ia A. J‘nfinson ;
Chief CIérk‘ i
Preview
ORGINN. Laurence M. Rosen, Esq. (SBN 219683) THE ROSEN LAW FIRM, PA. 355 South Grand Avenue, Suite 2450 FI ED SAN MATEO COUNTY Los Angeles, CA 90071 JUN 2 6 2018 Telephone: (213) 785-2610 Facsimile: (213) 226—4684 Email: lrosen@rosenlegal.com \OOOflmm-hUJNr—t Counsel for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN MATEO INGEUN SONG, Individually and on Behalf of ) Case No.: l8CIV01425 All Others Similarly Situated, ) ) (1) NOTICE OF APPLICATION FOR Plaintiff, ) ADMISSION OF DAVID P. DEAN TO STATE ) BAR PRO HAC VICE; v. ) ) (2) MEMORDANDUM OF POINTS A ~ QUDIAN INC., MIN LUO, CARL YEUNG, ) AUTHORITIES IN SUPPORT THEREOF; LIANZHU LV, YI CAO, SHILEI LI, LI DU, ) CHAO ZHU, TIANYU ZHU, DIANA ARIAS, ) (3) VERIFIED APPLICATION OF DAV MORGAN STANLEY & CO. ) P. DEAN INTERNATIONAL PLC, CREDIT SUISSE ) SECURITIES (USA) LLC, CITIGROUP ) (4) DECLARATION OF LAURENCE M. GLOBAL MARKETS INC., CHINA NNNNNNNNNP—‘Hr—‘I—ir—lh—‘HI—‘I—lb—l ) ROSEN; INTERNATIONAL CAPITAL ) mflam-PWNHOKDOOQONU‘I-p-WNI—‘o CORPORATION HONG KONG ) (5) [PROPOSED ORDER]; and SECURITIES LIIVIITED, UBS ) SECURITIES LLC, STIFEL, NICOLAUS & ) (6) PROOF OF SERVICE (filed under COMPANY, INC, NEEDHAM & COMPANY, ) separate cover). LLC, and NOMURA SECURITIES INTERNATIONAL, IN C., _ h — vvvvv 1s—cIv—o1425 . APHV Defendants. Application to A pp e ar as . Counsel Pro Han Vice . 1229837 ; Illl11111111111111!!!“Hill!!!ll -1- APPLICATION FOR PRO HAC VICE ADMISSION OF DAVID P. DEAN TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF-RECORD, PLEASE TAKE NOTICE that on June 26, 2018 that an Application for Admission of David P. Dean To State Bar Pro Hac Vice was filed with the Court. Upon instructions by the Court, the undersigned counsel will provide notice of any hearing upon this Application if scheduled by the Court. As \OOO\]O\U1-l>Wl\J>—t indicated in the declaration of Laurence M. Rosen filed herewith, defendants have received notice of this application and do not oppose my application. This Application will be, and hereby is, brought pursuant to Rule 9.40 of the California Rules of Court, on the ground that the above-named attorney is not a member of the State Bar of California; that he meets the requirements set forth in Rule 9.40; and that this Application is brought by an active member of the State Bar of California, who is a member of the firm acting as counsel for Plaintiffs. This Application is based on this Notice, the accompanying Memorandum of Points and Authorities, the Declaration of Laurence M. Rosen, the Verified Application of David P. Dean, all exhibits filed in support of this Application, all pleadings, records and papers filed in this action, and such other and further evidence may be presented at or before any Hearing on this Application. NNNNNNNNNHD—lb—‘r—‘HHP—‘r—lr—‘r—l Dated: June 26, 2108 Respectfully submitted, THE ROSEN LAW FIRM, P.A. mflom-PWNHOKOOOQONM-PWNF—‘O ‘1 By: , a KKK/taken! Laurence M. Rosen (SBN 219683) 355 South Grand Avenue, Suite 2450 Los Angeles, CA 90071 Tel. (213) 785-2610 Fax: (213) 226—4684 Email: lrosen@rosenlegal.com Attorneys for Plaintiff -2- APPLICATION FOR PRO HAC VICE ADMISSION OF DAVID P. DEAN MEMORANDUM OF POINTS AND AUTHORITIES California Rule of Court 9.40 provides, in part, that a person who is not a member of the State Bar of California but is a member in good standing eligible to practice before the bar of any United States Court may be permitted to appear as counsel pro hac vice. Permission is granted at \DOO\IO'\UI-PUJN>—I the discretion of the Court, upon written application where the attorney seeking admission has been retained to an appearance in a case pending in a California court. The Verified Application required by Rule 9.40(d) is attached hereto. A letter to the State Bar of California, enclosing a copy of the Verified Application for Admission of David P. Dean to the State Bar Pro Hac Vice along with the requisite State Bar fees, is attached as Exhibit A to the Declaration of Laurence M. Rosen. Attorney David P. Dean is an attorney in the Jenkintown, Pennsylvania office of The Rosen Law Firm, PA. and is counsel for plaintiff (“Plaintiff”). It is anticipated that Mr. Dean will appear on behalf of Plaintiff in the above-titled action and all actions consolidated and/or deemed related by this Court. For these reasons, it is requested that this Court grant an order admitting Mr. Dean to the State Bar of California Pro Hac Vice to represent Plaintiffs before this Court in this action and any other actions consolidated and/or deemed related by the Court. Dated: June 26, 2018 Respectfully submitted, NNNNNNNNNHHb—‘HHb—IHr—IHH ooqom-PWNHOCOOQONU‘l-PWNHO Laurence M. Rosen (SBN 219683) 355 South Grand Avenue, Suite 2450 Los Angeles, CA 90071 Tel. (213) 785-2610 Fax: (213) 226-4684 Email: lrosen@rosenlegal.com -3- APPLICATION FOR PRO HAC VICE ADMISSION OF DAVID P. DEAN APPLICATION FOR ADMISSION PRO HAC VICE Pursuant to Rule 9.40 of the California Rules of Court, 1, David P. Dean, hereby request that I be admitted pro hac vice in the above captioned case. In support of this Application, I declare and state as follows: OOOQONM-kWNr—I 1. My home address is 2353 E. Hazzard Street, Philadelphia, PA 19125. 2. I am an attorney at The Rosen Law Firm, P.A., 101 Greenwood Avenue, Suite 440, Jenkintown, PA 19046. 3. I am not a resident of the State of California, am not regularly employed in the State of California, and am not regularly engaged in substantial business, professional or other activities in the State of California. 4. I have been admitted to practice before all state courts in Pennsylvania and Florida, as well as the United States District Court for the Eastern and Western Districts of Pennsylvania, and the Middle District of Florida. 5. I am currently a member of good standing of these courts and am not currently suspended or disbarred in any court. 6. Within the past two years, I have not been admitted pro hac vice to practice in NNNNNNNNNHHHHP—‘h—lr—‘Hr—‘H California. 7. Laurence M. Rosen of the law firm of The Rosen Law Firm, P.A., whose California OOQOM-PWNHOKOOOflQm-PWNt—‘O office address is 355 South Grand Avenue, Suite 2450 Los Angeles, CA 90071 and whose telephone number is (213) 785-2610, is an active member of the State Bar of California and shall act as an attorney of record in this matter. I, David P. Dean, declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct to the best of my knowledge, information, and belief. -4- APPLICATION FOR PRO HAC VICE ADMISSION OF DAVID P. DEAN Executed this 26th day of June, 2018, in Jenkintown, Pennsylvania. \DOONQUI-PUJNH //@m David P. Dean NNNNNNNNNHb—‘r—ir—lr—‘b—lr—‘r—‘r—ii—i WQONM-PWNHOOOOQONUl-PWNV—‘O -5- APPLICATION FOR PRO HAC VICE ADMISSION OF DAVID P. DEAN DECLARATION OF LAURENCE M. ROSEN I, Laurence M. Rosen, do declare and state as follows: 1. I am a member of the State Bar of California and the managing attorney of The Rosen Law Firm, PA, counsel for plaintiff Inguen Song (“Plaintiff”) in the above-captioned action. I move for admission to the State Bar of California, pro hac vice, of David P. Dean. \OOO\]O\UI-I>~UJK\Jp—A 2. I am confident that David P. Dean will perform all obligations required of him as a member of the Bar of this Court. 3. The Verified Application for Admission of David P. Dean to the State Bar Pro Hac Vice is filed concurrently with this declaration. 4. A true and correct copy of a letter to the State Bar of California, enclosing a copy of the Verified Application for Admission of David P. Dean to the State Bar Pro Hac Vice, along with the requisite State Bar fees, is attached hereto as Exhibit A. I declare under penalty of perjury under the laws of the State of California, that the foregoing statements are true and correct. Executed this 26th day of June, 2018 in New York, New York. m. N 7 Laurenc M. Rosen mflam-PWNHOKDOOQQM-PWNF—‘O NNNNNNNNNHHHHHHHHHH -6— APPLICATION FOR PRO HAC VICE ADMISSION OF DAVID P. DEAN éupreme (flifiurt niifiennfil’lhania CERTIFICATE OF GOOD STANDING David Paul Dean, Esq. DATE OF ADMISSION April 13, 2009- ‘ | The above named attorney was duly admitted to the bar of the Commonwealth of Pennsylvania, and is now a-qualified member in good standing. Witnes'smy hand.~and official seal Dated: Jungj 5, 2018 Q \ wax, r ‘ q n _ v.1- .i V. N rPa'tic‘ia A. J‘nfinson ; Chief CIérk‘ i