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  • Daniel Ocampo vs Dominic WilliamsComplex Civil Unlimited Class Action document preview
  • Daniel Ocampo vs Dominic WilliamsComplex Civil Unlimited Class Action document preview
  • Daniel Ocampo vs Dominic WilliamsComplex Civil Unlimited Class Action document preview
  • Daniel Ocampo vs Dominic WilliamsComplex Civil Unlimited Class Action document preview
  • Daniel Ocampo vs Dominic WilliamsComplex Civil Unlimited Class Action document preview
  • Daniel Ocampo vs Dominic WilliamsComplex Civil Unlimited Class Action document preview
  • Daniel Ocampo vs Dominic WilliamsComplex Civil Unlimited Class Action document preview
  • Daniel Ocampo vs Dominic WilliamsComplex Civil Unlimited Class Action document preview
						
                                

Preview

QUINN EMANUEL URQUHART & SULLIVAN, LLP 1 Michael E. Liftik (CA Bar No. 232430) 2 michaelliftik@quinnemanuel.com 1300 I Street NW, Suite 900 3 Washington, District of Columbia 20005 Telephone: (202) 538-8000 4 Facsimile: (202) 538-8100 5 Emily C. Kapur (CA Bar No. 306724) 6 emilykapur@quinnemanuel.com 555 Twin Dolphin Dr., 5th Fl. 7 Redwood Shores, California 94065 Telephone: (650) 801-5000 8 Facsimile: (650) 801-5100 9 Attorneys for Dfinity USA Research, LLC and 10 Dfinity Stiftung 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 COUNTY OF SAN MATEO 13 14 DANIEL OCAMPO, Individually and on Case No. 21-CIV-03843 15 Behalf of All Others Similarly Situated, Judge: Hon. Danny L. Chou 16 Plaintiff, Dept.: 22 17 vs. NOTICE OF UNOPPOSED 18 APPLICATION OF ANTONY L. RYAN DFINITY USA RESEARCH, LLC, DFINITY TO APPEAR AS COUNSEL PRO HAC 19 STIFTUNG, AH CAPITAL MANAGEMENT, VICE; VERIFIED APPLICATION OF 20 POLYCHAIN CAPITAL, DOMINIC ANTONY L. RYAN TO APPEAR AS WILLIAMS, and DOES 1-20, COUNSEL PRO HAC VICE; 21 DECLARATION OF MICHAEL E. Defendants. LIFTIK IN SUPPORT OF VERIFIED 22 APPLICATION 23 [Proposed Order Filed Concurrently] 24 25 26 27 28 Case No. 21-CIV-03843 APPLICATION TO APPEAR AS COUNSEL PRO HAC VICE 1 TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD: 2 Rule 9.40 of the California Rules of Court provides that a person who is not a member of 3 the State Bar of California, but who is a member in good standing of the Bar of any United States 4 court or the highest court in any state, and who has been requested to appear in a particular cause 5 pending in a court in this state, may, in the discretion of the court and upon written application, 6 appear as counsel pro hac vice, provided an active member of the State Bar of California is 7 associated as counsel of record. 8 Defendants Dfinity USA Research, LLC and Dfinity Stiftung respectfully request that this 9 application be granted as they expect that Antony L. Ryan’s participation and appearance may be 10 required on Defendants’ behalf from time to time throughout the course of this action. Proper and 11 timely notice of this application will be given to all parties that have appeared in this cause and upon 12 the State Bar of California at its San Francisco office and no party opposes the application. 13 As set forth in the attached declaration, all of the requirements of Rule 9.40 with respect to 14 the requested pro hac vice appearance have been met. Accordingly, Antony L. Ryan should be 15 permitted to appear as counsel pro hac vice. 16 17 DATED: March 11, 2022 QUINN EMANUEL URQUHART & SULLIVAN, LLP 18 19 By 20 MICHAEL E. LIFTIK EMILY KAPUR 21 Attorneys for Dfinity USA Research, LLC and 22 Dfinity Stiftung 23 24 25 26 27 28 -2- Case No. 21-CIV-03843 APPLICATION TO APPEAR AS COUNSEL PRO HAC VICE DECLARATION AND VERIFIED APPLICATION OF ANTONY L. RYAN 1 TO APPEAR AS COUNSEL PRO HAC VICE 2 I, Antony L. Ryan, declare as follows: 3 1. I am an attorney at law licensed to practice in the State of New York. I am a partner 4 in the law firm of Cravath, Swaine & Moore LLP. I have personal knowledge of the facts set forth 5 in this declaration, and if called as a witness, I could and would competently testify as stated herein. 6 2. I reside at 50 Remsen Street, Brooklyn, NY 11201, and have an office at 825 Eighth 7 Avenue, New York, NY 10019. 8 3. My email address is aryan@cravath.com. 9 4. I have been admitted to practice law in courts in the State of New York. I was 10 admitted to the Bar of the State of New York in 1997. I am also admitted to practice law in the 11 following courts: the United States Supreme Court (since 2012), the United States Courts of 12 Appeals for the Federal Circuit (since 2009), Second Circuit (since 2005), Third Circuit (since 2006), 13 Ninth Circuit (since 2019), Tenth Circuit (since 2017), and Eleventh Circuit (since 2010) and United 14 States District Courts for the Southern District of New York (since 2001), the Eastern District of 15 New York (since 2001), and the Northern District of New York (since 2008). I am an active member 16 in good standing with these Courts. 17 5. I have never been suspended or disbarred in any court. 18 6. I am not regularly employed in the State of California, nor am I regularly engaged in 19 substantial business, professional, or other activities in the State of California. 20 7. In the past two years, I have applied for and been admitted as counsel pro hac vice 21 in several courts in the State of California. A full list of those applications is attached hereto as 22 Exhibit 1. 23 8. I understand that I will be subject to the jurisdiction of the courts of California with 24 respect to the law of California governing the conduct of attorneys to the same extent as a licensee 25 of the State Bar of California. I have familiarized myself with and will comply with the standards 26 of professional conduct required of licensees of the State Bar of California and will be subject to the 27 28 -3- Case No. 21-CIV-03843 APPLICATION TO APPEAR AS COUNSEL PRO HAC VICE 1 disciplinary jurisdiction of the State Bar with respect to any of my acts occurring in the course of 2 my appearance. 3 9. The attorneys of record for Dfinity USA Research, LLC and Dfinity Stiftung include 4 Michael E. Liftik, a partner with Quinn Emanuel Urquhart & Sullivan, LLP, located at 1300 I Street 5 NW, Suite 900, Washington, D.C. 20005 and Emily C. Kapur, an associate of Quinn Emanuel 6 Urquhart & Sullivan, LLP, located at 555 Twin Dolphin Drive, Redwood Shores, CA 94065. Both 7 are members of the State Bar of California with whom I will be associated. 8 10. I request permission of the Court to appear and participate in the above-entitled 9 action as counsel pro hac vice for Defendants Dfinity USA Research, LLC and Dfinity Stiftung. 10 VERIFICATION 11 I am the applicant for admission pro hac vice and I have read the foregoing application and 12 know its contents. The matters stated in the application are true based on my own knowledge. I 13 declare under penalty of perjury under the laws of the State of California that the foregoing is true 14 and correct. 15 Executed this 11th day of March 2022 at New York, New York. 16 17 18 19 20 Antony L. Ryan 21 22 23 24 25 26 27 28 -4- Case No. 21-CIV-03843 APPLICATION TO APPEAR AS COUNSEL PRO HAC VICE 1 EXHIBIT 1 2 Court Case Submitted Action 3 N.D. Cal. Saliba v. Robinhood Markets, Inc. 3/31/2021 Moot (case transferred to et al. (21-cv-871) MDL before ruling) 4 Valenti v. Dfinity USA Research, 9/22/2021 Granted 5 LLC et al. (21-cv-06118) Valenti v. Dfinity USA Research, 11/23/2021 Granted 6 LLC et al. (21-cv-06118) 7 Valenti v. Dfinity USA Research, 2/16/2022 Granted LLC et al. (21-cv-06118) 8 Golubowski v. Robinhood (21-cv- 2/17/2022 Granted 9 09767) C.D. Cal. Cobos v. Robinhood Financial 2/3/2021 Moot (case dismissed 10 LLC et al. (21-cv-843) with prejudice) 11 Gossett et al v. Robinhood 2/3/2021 Granted Financial, LLC et al. (21-cv-837) 12 Kayali et al v. Robinhood 2/3/2021 Granted 13 Financial, LLC et al. (21-cv-835) Thompson v. Robinhood Financial 3/12/2021 Granted 14 LLC (21-cv-2230) 15 California Murphy v. Robinhood Financial 6/21/2021 Granted Superior Court LLC et al. (21STCV03560) 16 Los Angeles 17 Cnty. 18 19 20 21 22 23 24 25 26 27 28 -5- Case No. 21-CIV-03843 APPLICATION TO APPEAR AS COUNSEL PRO HAC VICE 1 DECLARATION OF MICHAEL E. LIFTIK 2 I, Michael E. Liftik declare as follows: 3 1. I am a partner in the law firm of Quinn Emanuel Urquhart & Sullivan, LLP, counsel 4 for Defendant Dfinity USA Research, LLC and Dfinity Stiftung. I have personal knowledge of the 5 facts stated herein and would and could competently testify thereto under oath if called upon to do 6 so. 7 2. I am an active member in good standing of the Bar of the State of California and 8 submit this declaration in support of the Verified Application of Antony L. Ryan to appear as 9 counsel pro hac vice on behalf of the aforementioned parties in this action. 10 3. This application is brought on the basis that Antony L. Ryan’s participation and 11 appearance may be appropriate from time to time throughout the course of this litigation. 12 4. A copy of the application of Antony L. Ryan to appear as counsel pro hac vice and 13 notice of the application will be duly served by mail on all parties that have appeared in this cause. 14 Attached hereto as Exhibit A is a true and correct copy of proof that the pro hac vice application for 15 Antony L. Ryan has been submitted to the State Bar of California through its online portal and that 16 the $50.00 fee required by California Rule of Court 9.40(e) has been paid. 17 I declare under penalty of perjury that the foregoing is true and correct. 18 Executed this 11th day of March 2022, at Washington, DC. 19 20 21 22 23 Michael E. Liftik 24 25 26 27 28 -6- Case No. 21-CIV-03843 APPLICATION TO APPEAR AS COUNSEL PRO HAC VICE EXHIBIT A From: State Bar of California - Special Admissions Date: March 9, 2022 at 8:58:01 PM EST To: Antony Ryan Subject: Pro Hac Vice Application Acknowledgement Notice Application's Case Number: 00788318Trial Case Name: DANIEL OCAMPO, Individually and on Behalf of All Others Similarly Situated, vs. DFINITY USA RESEARCH, LLC, DFINITY STIFTUNG, AH CAPITAL MANAGEMENT, Caution: External (special.admissions@calbar.ca.gov) Reported Spam, Sensitive Content Details Report This Email FAQ Application's Case Number: 00788318 Trial Case Name: DANIEL OCAMPO, Individually and on Behalf of All Others Similarly Situated, vs. DFINITY USA RESEARCH, LLC, DFINITY STIFTUNG, AH CAPITAL MANAGEMENT, POLYCHAIN CAPITAL, DOMINIC WILLIAMS, and DOES 1-20 Trial Case Number: 21-cv-03843 Dear Antony Ryan, Your Pro Hac Vice application has been received and is pending review. For your application to be approved, you must have submitted an uploaded copy of the original Pro Hac Vice application, in addition to the application fee. If you failed to upload the original Pro Hac Vice application/document during the online application process, please follow the steps below to upload the completed document to your existing application: 1. Login to the Applicant Community site. 2. Click the "Special Admissions" tab at the top of the home page, and then select the "Pro Hac Vice" option. 3. In the "Upload document(s) to a previously submitted application" box, select the "Next" button. 4. Follow the directions on the screen to search for the application using the application's "Case Number" (listed at the top of this message beginning with "00"), and upload the document(s). 1 Applicants who encounter problems gaining access to the Applicant Community, or those who have not yet created a password to the Applicant Community, should take the following steps: 1. Access the Applicant Community at admissions.calbar.ca.gov. 2. Click "Forgot your password." 3. Click "Send Password Reset Email." 4. Check your email and follow the instructions to reset your password. If you paid by e-check (ACH), then your application will not be approved until we can confirm that your payment processed, successfully. It may take up to 7 business days before the transaction is settled. In addition, if you owe any outstanding fees to the State Bar, your application cannot be approved until the fees are paid. Once the application is deemed complete, you will receive an email notifying you of a successful filing. If you have any questions, please contact the Special Admissions department at the number below. Sincerely, Office of Admissions State Bar of California (415) 538-2300 ref:_00Dt0TZax._500t0y5mRo:ref 2 01231445ÿ23748ÿ9 ÿÿÿ9ÿÿ9ÿÿ9ÿ "ÿ( -../01234ÿ67889304: ÿ)!"ÿ  *+ ÿ9ÿ,ÿ"ÿ9 ;2:8<34ÿ=>78ÿ?<@ÿ-../01234ÿA7/B03Cÿ-117934 ÿ ;2:8<34ÿ?28< ÿÿÿ9ÿ D4249E  9 ;2:8<34ÿF<4G7B ÿ  ;2:8<34ÿH24< 01814344ÿI7IJÿ K:.< !  K742/ÿ;20Bÿ-87934 LI2#4I h04GB>2@2/ÿH24< ÿ K742/ÿM<=93B824073 N23Oÿ-N-ÿ67B< ÿ ?28<ÿQ3ÿ-117934 ÿ N23Oÿ-117934ÿ?98R<> ÿ N9E03BÿP3=7>824073 6>Bÿ?98R<> ÿ 6>BÿK:.< 9+ S0>E4ÿ?28< T" UV.0>:ÿF734G 3W X2E4ÿ?28< Y UV.0>:ÿZ<2> 4340 M<=93BÿM<[9<31< 6734214 9ÿY  U820/ \]%!# 62E< 33J^^02^ ;G73< ÿ N0//03Cÿ-BB><<4 ^4Iÿ*!!ÿ9% N0//03Cÿ_0. 23328 N0//03Cÿ604: ÿ̀a N0//03Cÿ67934>: bc N0//03CÿD424< ` ÿ ÿ K>23E214073ÿP3=7>824073 K>23E214073ÿPH dWd^JJWIIWW^d33843W3I0 ;2:8<34ÿM71824073 6><24