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Home Court filings Agent Fee Litigation APPLICATION of Non-Resident Attorney Thomas V.… — Agent Fee Litigation (Dkt. 16)

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APPLICATION of Non-Resident Attorney Thomas V.… — Agent Fee Litigation (Dkt. 16)

Summary

An application of non-resident attorney Thomas V. Panoff of Mayer Brown LLP to appear pro hac vice in American Video Duplicating, Inc., et al. v. Citigroup Inc., et al., No. 2:20-cv-03815-ODW-AGR, in the U.S. District Court for the Central District of California, filed May 14, 2020 as Document 16. The G-64 form states he has been retained to represent defendants Citigroup, Inc. and Citibank, N.A., and designates Bronwyn F. Pollock of Mayer Brown LLP as local counsel. It lists his admissions to the Illinois Supreme Court, Michigan Supreme Court and District of Columbia Court of Appeals, with an attached sheet of federal court admissions. The 7-page filing includes certificates of good standing from Illinois, the State Bar of Michigan and the District of Columbia Bar dated May 12, 2020.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

No. 2:20-cv-03815-ODW-AGR · Doc. 16 · Docket on CourtListener

Full text

           Case 2:20-cv-03815-ODW-AGR                                 Document 16                 Filed 05/14/20               Page 1 of 7 Page ID
Name and
Name and address:
         address:
                                                                            #:67
             Bronwyn F.
             Bronwyn  F. Pollock (SBN 210912)
                         Pollock (SBN 210912)
                  MAYER BROWN LLP
                  MAYER    BROWN    LLP
            350 South
            350 South Grand  Avenue, 25th
                      Grand Avenue,  25th Floor
                                          Floor
                  Los Angeles, CA
                  Los Angeles, CA 90071
                                   90071

                                                       UNITED STATES
                                                       UNITED STATES DISTRICT
                                                                     DISTRICT COURT
                                                                              COURT
                                                      CENTRAL
                                                      CENTRAL DISTRICT
                                                              DISTRICT OF
                                                                       OF CALIFORNIA
                                                                          CALIFORNIA

 American Video
 American Video Duplicating,
                Duplicating, Inc.,
                             Inc., et
                                   et al.
                                      al.                                                CASE NUMBER
                                                                                         CASE NUMBER
                                                                                                                  2:20-cv-03815-ODW-AGR
                                                                                                                  2:20-cv-03815-0DW-AGR
                                                                     Plaintiff(s),
                                                                     Plaintiff(s),
                     v.
                     V.

 Citigroup Inc.,
 Citigroup Inc., et
                 et al.
                    al.                                                                     APPLICATION OF
                                                                                            APPLICATION OF NON-RESIDENT
                                                                                                           NON-RESIDENT ATTORNEY
                                                                                                                           ATTORNEY
                                                                                                  TO APPEAR
                                                                                                  TO APPEAR IN A SPECIFIC
                                                                                                            IN A SPECIFIC CASE
                                                                                                                          CASE
                                                                  Defendant(s),
                                                                  Defendant(s),                          PRO HAC
                                                                                                         PRO HAC VICE
                                                                                                                  VICE
INSTRUCTIONS FOR
INSTRUCTIONS          FOR APPLICANTS
                            APPLICANTS
(1) The
(1) The attorney
         attorney seeking
                    seeking toto appear   pro hac
                                  appear pro    hac vice
                                                      vice must
                                                            must complete    Section II of
                                                                   complete Section     of this  Application, personally
                                                                                            this Application,   personally sign,
                                                                                                                              sign, in
                                                                                                                                     in ink,
                                                                                                                                        ink, the  certification in
                                                                                                                                              the certification   in
    Section II,
    Section  II, and
                 and have
                      have the
                             the designated
                                  designated Local
                                                Local Counsel      sign in
                                                        Counsel sign    in Section  III. ELECTRONIC
                                                                           Section III.  ELECTRONIC SIGNATURES
                                                                                                             SIGNATURES ARE      ARE NOT        ACCEPTED. Space
                                                                                                                                        NOT ACCEPTED.             Space to
                                                                                                                                                                         to
    supplement responses
    supplement     responses is   provided in
                               is provided       Section IV.
                                             in Section     IV. The
                                                                  The applicant
                                                                      applicant must
                                                                                  must also    attach aa Certificate
                                                                                        also attach      Certificate ofof Good
                                                                                                                          Good Standing
                                                                                                                                  Standing (issued     within the
                                                                                                                                              (issued within    the last
                                                                                                                                                                    last 30
                                                                                                                                                                         30
    days)  from every
    days) from           state bar
                  every state   bar to which he
                                    to which    he or   she is
                                                    or she   is admitted;  failure to
                                                                admitted;failure    to do  so will
                                                                                       do so   will be
                                                                                                    be grounds   for denying
                                                                                                       grounds for    denying the                     Scan the
                                                                                                                                      Application. Scan
                                                                                                                                 the Application.            the
    completed    Application with
    completed Application       with its
                                      its original
                                          original ink     signature, together
                                                      ink signature,             with any
                                                                       together with          attachment(s), to
                                                                                       any attachment(s),      to aa single
                                                                                                                     single Portable
                                                                                                                             Portable Document
                                                                                                                                        Document Format
                                                                                                                                                      Format (PDF)       file.
                                                                                                                                                                 (PDF)file.
(2) Have
(2) Have the
           the designated
               designated Local
                              Local Counsel     file the
                                     Counsel file         Application electronically
                                                      the Application    electronically using
                                                                                         using the
                                                                                                 the Court's
                                                                                                     Court's electronic    filing system
                                                                                                              electronic filing    system ("Motions
                                                                                                                                            ("Motions and and Related
                                                                                                                                                               Related
    Filings =>
    Filings  => Applications/Ex
                 Applications/Ex Parte
                                     Parte Applications/Motions/Petitions/Requests
                                            Applications/Motions/Petitions/Requests =>           => Appear
                                                                                                     Appear Pro
                                                                                                              Pro Hac
                                                                                                                    Hac Vice
                                                                                                                          Vice (G-64)"),     attach aa Proposed
                                                                                                                                (G-64)'9, attach        Proposed Order
                                                                                                                                                                    Order
    (using  Form G-64
    (using Form            ORDER, available
                    G-64 ORDER,      availablefrom from the
                                                          the Court's   website), and
                                                               Court's website),        pay the
                                                                                   and pay    the required
                                                                                                  required $400
                                                                                                             $400feefee online
                                                                                                                        online at   the time
                                                                                                                                 at the  time of          (using aa credit
                                                                                                                                                  filing (using
                                                                                                                                                offiling            credit
    card). The
    card).       fee is
            Thefee   is required
                        requiredforfor each
                                       each case
                                              case inin which
                                                        which thethe applicant  files an
                                                                     applicantfiles   an Application.
                                                                                         Application. Failure
                                                                                                          Failure to  pay the
                                                                                                                   to pay  thefee   at the
                                                                                                                                fee at       time of
                                                                                                                                        the time             will be
                                                                                                                                                      filing will
                                                                                                                                                   offiling        be
    grounds for
    grounds   for denying
                   denying the    Application. Out-of-state
                             the Application.                       federal government
                                                  Out-of-statefederal       government attorneys
                                                                                             attorneys are
                                                                                                         are not
                                                                                                             not required
                                                                                                                  required to     pay the
                                                                                                                               to pay  the $400    fee. (Certain
                                                                                                                                            $400fee.      (Certain
    attorneys   for the
    attorneys for   the United
                         United States
                                  States are
                                          are also
                                               also exempt
                                                      exemptfromfrom the
                                                                      the requirement
                                                                          requirement of of applying
                                                                                             applyingforfor pro hac vice
                                                                                                            pro hac        status. See
                                                                                                                      vice status.         L.R. 83-2.1.4.)
                                                                                                                                      See L.R.   83-2.1.4.) A A copy
                                                                                                                                                                copy of
                                                                                                                                                                      of the
                                                                                                                                                                          the
    G-64
    G-64 ORDER
          ORDER in   in Word
                         Word or or WordPerfect
                                    WordPerfectformat format must
                                                               must bebe emailed
                                                                         emailed toto the generic chambers
                                                                                      the generic   chambers email      address. L.R.
                                                                                                                email address.      L.R. 5-4.4.2.
                                                                                                                                          5-4.4.2.
SECTION II -- INFORMATION
SECTION        INFORMATION

Panoff,
Panoff. Thomas
        Thomas V.V.
Applicant's Name
Applicant's Name (Last Name, First
                 (Last Name, First Name
                                   Name &   Middle Initial)
                                        et. Middle Initial)                                                          check
                                                                                                                     check here
                                                                                                                           here if federal government
                                                                                                                                iffederal  government attorney
                                                                                                                                                      attorney El

Mayer Brown
Mayer  Brown LLP
              LLP
Firm/Agency Name
Firm/Agency Name

 71 South Wacker
 71 South Wacker Drive
                 Drive                                                               (312) 701-8821
                                                                                     (312) 701-8821                                  (312)
                                                                                                                                     (312) 706-8297
                                                                                                                                           706-8297
                                                                                     Telephone
                                                                                     Telephone Number
                                                                                               Number                                Fax Number
                                                                                                                                     Fax Number
Street Address
Street Address

Chicago,
Chicago. Illinois    60606
            Illinois 60606                                                                                     tpanoff@mayerbrown.com
                                                                                                               tnanoffamaverbrown.com
City, State,
City, State, Zip
             Zip Code
                 Code                                                                                                E-mail Address
                                                                                                                     E-mail Address

II have been retained
   have been          to represent
             retained to represent the
                                   the following
                                       following parties:
                                                 parties:

 Citigroup,
 Citigroun. Inc.
            Inc.                                                                     ▪   Plaintiff(s)
                                                                                         Plaintiffs)     ✖   Defendant(s) n Other:
                                                                                                             Defendant(s)   Other:

 Citibank, N.A.
 Citibank. N                                                                         ▪   Plaintiff(s)
                                                                                         Plaintiffs)     ✖   Defendant(s) n Other:
                                                                                                             Defendant(s)   Other:
Name(s) of
Name(s) of Party(ies)
           Party(ies) Represented
                      Represented

List
List all state and
     all state and federal
                   federal courts
                           courts (including
                                  (including appellate courts) to
                                             appellate courts) to which the applicant
                                                                  which the            has been
                                                                            applicant has       admitted, and
                                                                                           been admitted,                         status of
                                                                                                                          current status
                                                                                                                      the current
                                                                                                              provide the
                                                                                                          and provide                    of his
                                                                                                                                            his or
                                                                                                                                                or
her membership.
her  membership. Use Use Section
                         Section IV
                                  IV if
                                     if more
                                        more room
                                             room is
                                                   is needed,
                                                      needed, or to provide
                                                              or to provide additional
                                                                            additional information.
                                                                                       information.

                     Name of
                     Name of Court
                             Court                                  Date of
                                                                    Date    Admission
                                                                         of Admission                Active Member
                                                                                                     Active Member in
                                                                                                                   in Good
                                                                                                                      Good Standing?
                                                                                                                           Standing? (if not, please
                                                                                                                                     (if not, please explain)
                                                                                                                                                     explain)
 Illinois Supreme
 Illinois Supreme Court
                  Court                                                11/04/04
                                                                        11/04/04                   Yes
                                                                                                   Yes
 Michigan Supreme
 Michigan Supreme Court
                  Court                                                   06/24/05
                                                                          06/24/05                 Yes
                                                                                                   Yes
 District of
 District of Columbia
             Columbia Court
                      Court of Appeals
                            of Anneals                                    03/05/07
                                                                          03/05/07                 Yes
                                                                                                   Yes

G-64 (02/20)
G-64 (02/20)                    APPLICATION OF NON-RESIDENT
                                APPLICATION OF NON-RESIDENT ATTORNEY TO APPEAR
                                                            ATTORNEY TO APPEAR IN A SPECIFIC
                                                                               IN A SPECIFIC CASE PRO HAC
                                                                                             CASE PRO HAC VICE
                                                                                                          VICE                                                    Page 11 of
                                                                                                                                                                  Page    of 3
                                                                                                                                                                             3
   Case 2:20-cv-03815-ODW-AGR                           Document 16             Filed 05/14/20            Page 2 of 7 Page ID
                                                              #:68
List all cases in which the applicant has applied to this Court for pro hac vice status in the previous three years (continue in Section IV if
needed):
        Case Number                                     Title of Action                            Date of Application       Granted / Denied?
 None




If any pro hac vice applications submitted within the past three (3) years have been denied by the Court, please explain:
 N/A




 Attorneys must be registered for the Court's electronic filing system to practice pro hac vice in this Court. Submission
 of this Application will constitute your registration (or re-registration) to use that system. If the Court signs an Order
 granting your Application, visit www.pacer.gov to complete the registration process and activate your e
 privileges in the Central District of California.

               SECTION II - CERTIFICATION

               I declare under penalty of perjury that:

               (1) All of the above information is true and correct.
               (2) I am not a resident of the State of California. I am not regularly employed in, or engaged in
                   substantial business, professional, or other activities in the State of California.
               (3) I am not currently suspended from and have never been disbarred from practice in any court.
               (4) I am familiar with the Court's Local Civil and Criminal Rules, the Federal Rules of Civil and
                   Criminal Procedure, and the Federal Rules of Evidence.
               (5) I designate the attorney listed in Section III below, who is a member in good standing of the Bar
                   of this Court and maintains an office in the Central District of California for the practice of law, in
                   which the attorney is physically present on a regular basis to conduct business, as local counsel
                   pursuant to Local Rule 83-2.1.3.4.

                Dated May 13, 2020                                     Thomas V. Panoff
                                                                       Applicant's Name (please type or print)


                                                                      Applicant's Signature


G-61 (02/20)                APPLICATION OF NON-RESIDENT ATTORNEY TO APPEAR IN A SPECIFIC CASE PRO HA C VICE                            Page 2 of 3
    Case 2:20-cv-03815-ODW-AGR                       Document 16             Filed 05/14/20          Page 3 of 7 Page ID
                                                           #:69

SECTION III - DESIGNATION OF LOCAL COUNSEL

Pollock. Bronwvn F.
Designee's Name (Last Name, First Name ele Middle Initial)

Mayer Brown LLP
Firm/Agency Name

 350 S. Grand Ave.. 25th Floor                                    (213) 229-5194                          (2131576-8138
                                                                  Telephone Number                        Fax Number

Street Address                                                    bnollockOmaverbrown.com
                                                                  Email Address
Los Angeles, CA 90071
City, State, Zip Code                                             210912
                                                                  Designee's California State Bar Number

I hereby consent to the foregoing designation as local counsel, and declare under penalty of perjury that I maintain an office in the
Central District of California for the practice of law, in which I am physically present on a regular basis to conduct business.
               Dated May 14, 2020                                 Bronwvn F. Pollock
                                                                  DeIgns5's Name (please type or print)


                                                                  Designee's Signature
SECTION IV - SUPPLEMENT ANSWERS HERE (ATTACH ADDITIONAL PAGES IF NECESSARY)

 ***Please see attached sheet for additional Court admissions.




G-64 (02/20)             APPLICATION OF NON-RESIDENT ATTORNEY TO APPEAR IN A SPECIFIC CASE PRO HAC VICE                         Page 3 of 3
   Case 2:20-cv-03815-ODW-AGR                 Document 16   Filed 05/14/20   Page 4 of 7 Page ID
                                                    #:70



                                         Thomas V. Panoff
                                     Additional Bar Admissions

                          Court                              Bar No.        Date       Active
                                                                          Admitted    Member &
                                                                                       Good
                                                                                      Standing
U.S. District Court for the Northern District of Illinois     6283695     11/02/06      Yes
U.S. Court of Appeals for the Seventh Circuit               [no number]     3/2/07      Yes
U.S. Court of Appeals for the Ninth Circuit                 [no number]   10/27/09      Yes
U.S. District Court for the Eastern District of Michigan      P68416       12/1/09      Yes
U.S. District Court for the Central District of Illinois    [no number]    5/14/10      Yes
U.S. Court of Appeals for the Eleventh Circuit              [no number]    3/6/11;      Yes
                                                                          renewed
                                                                          12/20/16
U.S. District Court for the Western District of Michigan      P68416       12/5/11      Yes
U.S. Court of Appeals for the Sixth Circuit                 [no number]     3/6/12      Yes
U.S. Court of Appeals for the Eighth Circuit                [no number]     3/9/12      Yes
U.S. District Court for the Southern District of Illinois   [no number]   5/25/12;      Yes
                                                                          renewed
                                                                           1/20/16
U.S. Court of Appeals for the Fifth Circuit                 [no number]   1/28/13;      Yes
                                                                          renewed
                                                                            1/5/18
U.S. Court of Appeals for the Federal Circuit               [no number]    3/28/13      Yes
U.S. District Court for the District of Columbia              503040       4/8/13;      Yes
                                                                          renewed
                                                                          12/20/16;
                                                                          renewed
                                                                            5/2/19
U.S. District Court for the Eastern District of Texas       [no number]    5/21/13      Yes
U.S. Court of Appeals for the Second Circuit                [no number]    7/21/17      Yes
U.S. District Court for the Northern District of Texas       6283695IL     9/7/17       Yes
U.S. District Court for the Western District of Wisconsin     6283695      7/17/19      Yes




    1480583.11
    1480583.11
       Case 2:20-cv-03815-ODW-AGR                       Document 16            Filed 05/14/20             Page 5 of 7 Page ID
                                                              #:71

                                 Attorney Registration and Disciplinary Commission
                                                        of the
             I                               Supreme Court of Illinois
                                                   www.iardc.org



     One Prudential Plaza
                                                                                     3161 West White Oaks Drive
130 East Randolph Drive, Suite
                                                                                               Suite 301
              1500
                                                                                         Springfield, IL 62704
    Chicago, IL 60601-6219
                                                                                     (217) 522-6838 (800) 252-8048
 (312) 565-2600 (800) 826-8625
                                                                                          Fax (217) 522-2417
       Fax (312) 565-2320




                                                         Chicago
                                                         5/12/2020

                                                         Re: Thomas Vangel Panoff
                                                             Attorney No. 6283695



      To Whom It May Concern:

         The records of the Clerk of the Supreme Court of Illinois and this office reflect that
      Thomas Vangel Panoff was admitted to practice law in Illinois on 11/4/2004; is currently
      registered on the master roll of attorneys entitled to practice law in this state; has never been
      disciplined and is in good standing.




                                                         Very truly yours,
                                                         Jerome Larkin
                                                         Administrator




                                                             Andrew Oliva
                                                             Registrar
           Case 2:20-cv-03815-ODW-AGR                 Document 16          Filed 05/14/20         Page 6 of 7 Page ID
                                                            #:72




                   .zttt Var of Ati rbi
                                       Lilt
                                    Certificate of 14$ °art ,iptanbing
               !"#$%&'()#*#'$%)"+)%!",-+$%.+/0'1%2+/,**3%245674%,*%8"#&+0,3%911#/,#$%#$%+/%
               This certifies that Thomas Vangel Panoff, P68416 of Chicago, Illinois is an
               +&)#:'%-'-;'(%,*%)"'%<)+)'%=+(%,*%>#&"#0+/%#/%0,,?%$)+/?#/0@
               active member of the State Bar of Michigan in good standing.

               A'B<"'%C+$%+?-#))'?%),%D(+&)#&'%#/%>#&"#0+/%,/%EF/'%G63%GHHI%;J%)"'%
               He/She was admitted to practice in Michigan on June 24, 2005 by the
               >#&"#0+/%<FD('-'%8,F()%+/?%;'&+-'%+%-'-;'(%,*%)"'%<)+)'%=+(%,*%>#&"#0+/%
               Michigan Supreme Court and became a   member of the State Bar of Michigan
               ,/%EF/'%G53%GHHI@
               on June 28, 2005.




                                                                     !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
                                                                                 E+/')%K@%L'1&"3%MN'&F)#:'%O#('&),(
                                                                                Janet K. Welch,  Executive Ditectot
                                                                                                      >+J%7G3%GHGH
                                                                                                      May 12, 2020



This is an
This is an official
           official document
                    document issued
                              issued by
                                      by the  State Bar
                                         the State  Bar of
                                                        of Michigan
                                                           Michigan and
                                                                    and will be valid
                                                                        will be       for 45
                                                                                valid for 45 days
                                                                                              days from  the date
                                                                                                   from the  date on
                                                                                                                  on this
                                                                                                                     this certificate.
                                                                                                                          certificate.
While the
While  the State Bar of
           State Bar  of Michigan  operates under
                         Michigan operates   under the  advisement of
                                                    the advisement of government
                                                                      government officials
                                                                                    officials during the COVID-19
                                                                                              during the              pandemic,
                                                                                                         COVID-19 pandemic,
Certificates of Good   Standing  will only be issued in this manner and sent  by email.
Certificates of Good Standing will only be issued in this manner and sent by email.
No paper copies will be issued or mailed until further notice.
Case 2:20-cv-03815-ODW-AGR                                               Document 16   Filed 05/14/20       Page 7 of 7 Page ID
                                                                               #:73




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    On behalf of JULIO A. CASTILLO, Clerk of the District of Columbia Court of Appeals,
                     the District of Columbia Bar does hereby certify that




                                        Thomas Vtgrentio,
                                                  Panoff
          was duly qualified and admitted on March 5, 2007 as an attorney and counselor entitled to
                     practice before this Court; and is, on the date indicated below, a(n)
                               ACTIVE member in good standing of this Bar.




                                                                                                   In Testimony Whereof,
                                                                                               I have hereunto subscribed my
                                                                                               name and affixed the seal of this
                                                                                                    Court at the City of
                                                                                                Washington, D.C., on May 12,
                                                                                                            2020.


                                                                                                 licit# 4.          raa
                                                                                                     JULIO A. CASTILLO
                                                                                                       Clerk of the Court




                                                                                           Issued By:
                                                                                                    District of Columbia Bar Membership



  For questions or concerns, please contact the D.C. Bar Membership Office at 202-626-3475 or email
                                      memberservices@dcbar.org.


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