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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
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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
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Attorneys for Dfinity USA Research, LLC and
10 Dfinity Stiftung
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF SAN MATEO
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DANIEL OCAMPO, Individually and on Case No. 21-CIV-03843
15 Behalf of All Others Similarly Situated,
Judge: Hon. Danny L. Chou
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Plaintiff, Dept.: 22
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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]
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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.
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17 DATED: March 11, 2022 QUINN EMANUEL URQUHART & SULLIVAN, LLP
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By
20 MICHAEL E. LIFTIK
EMILY KAPUR
21 Attorneys for Dfinity USA Research, LLC and
22 Dfinity Stiftung
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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
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-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.
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20 Antony L. Ryan
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-4- Case No. 21-CIV-03843
APPLICATION TO APPEAR AS COUNSEL PRO HAC VICE
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EXHIBIT 1
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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)
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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
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LLC et al. (21-cv-06118)
7 Valenti v. Dfinity USA Research, 2/16/2022 Granted
LLC et al. (21-cv-06118)
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Golubowski v. Robinhood (21-cv- 2/17/2022 Granted
9 09767)
C.D. Cal. Cobos v. Robinhood Financial 2/3/2021 Moot (case dismissed
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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)
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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
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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.
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-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.
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23 Michael E. Liftik
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-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
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