Motion for Leave to Appear pro hac vice — Greathouse v. Capital Plus Financial LLC (Dkt. 22, E.D. Ark. No. 4:21-cv-01243)

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Motion for pro hac vice admission of Andrew D. Bergman in Eric Greathouse v. Capital Plus Financial, LLC and Crossroads Systems, Inc., Case No. 4:21-cv-01243-BRW, U.S. District Court for the Eastern District of Arkansas, filed 02/23/22 as Document 22. The defendants ask under Local Rule 83.5(d) that Bergman, an attorney with Arnold & Porter Kaye Scholer LLP admitted in Texas and several federal courts, be allowed to appear as their counsel. The motion states he is in good standing, will be associated with Arkansas counsel at Mitchell, Williams, Selig, Gates & Woodyard, PLLC, and will pay the required fees. The case is brought by Greathouse individually and on behalf of all others similarly situated.

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IN THE UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF ARKANSAS 
CENTRAL DIVISION 
 
 
ERIC GREATHOUSE, Individually and 
on Behalf All Others Similarly Situated 
  PLAINTIFF 
 
vs.  
 
 
 
CASE NO. 4:21-cv-01243-BRW 
 
CAPITAL PLUS FINANCIAL, LLC; and  
CROSSROADS SYSTEMS, INC. 
        DEFENDANTS 
 
MOTION FOR PRO HAC VICE ADMISSION OF ANDREW D. BERGMAN 
 
Defendants Crossroads Systems, Inc. (“Crossroads”) and Capital Plus Financial, LLC 
(“CPF”) respectfully request pursuant to Local Rule 83.5(d) that the Court permit Andrew D. 
Bergman to appear pro hac vice in this matter as counsel of record.  In support of this request, 
Crossroads and CPF state as follows:   
1. 
Mr. Bergman is an attorney with the law firm of Arnold & Porter Kaye Scholer 
LLP.  His office address is 700 Louisiana Street, Suite 4000, Houston, Texas 77002-2755.  Mr. 
Bergman’s telephone number is (713) 576-2430, his fax number is (713) 576-2499, and his email 
address is andrew.bergman@arnoldporter.com. 
2. 
Mr. Bergman is a member of the bar of the State of Texas.  He is also admitted to 
practice before the following federal courts:  the United States Court of Appeals for the Second 
Circuit, the United States Court of Appeals for the Fifth Circuit, the United States Court of Appeals 
for the Eighth Circuit, the United States District Court for the District of Columbia; the United 
States District Court for the Southern District of Texas, the United States District Court for the 
Eastern District of Texas, the United States District Court for the Northern District of Texas, and 
the United States District Court for the Western District of Texas. 
Case 4:21-cv-01243-BRW     Document 22     Filed 02/23/22     Page 1 of 3

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3. 
Mr. Bergman is a member in good standing of all bars to which he has been 
admitted, and no disciplinary or grievance proceedings have been filed or are currently pending 
against him. 
4. 
In representing Crossroads and CPF in this matter, Mr. Bergman will be associated 
with undersigned counsel, who are members of the bar of this Court and who maintain an office 
in Arkansas.  Opposing counsel may readily communicate with undersigned counsel regarding the 
conduct of this case. 
5. 
Mr. Bergman affirms to the Local Rules of the United States District Court for the 
Eastern District of Arkansas and submits to the jurisdiction of this Court in matters of discipline.  
6. 
Mr. Bergman will remit the required application fees and complete the Electronic 
Case Filing Registration Form. 
Respectfully submitted,  
Karen P. Freeman (Ark. Bar No. 2009094) 
MITCHELL, WILLIAMS, SELIG 
GATES & WOODYARD, PLLC 
4206 South J.B. Hunt Drive, Suite 200 
Rogers, Arkansas 72758 
Telephone:  (479) 464-5650 
Facsimile:  (479) 464-5680 
kfreeman@mwlaw.com 
 
Graham Talley (Ark. Bar No. 2015159) 
MITCHELL, WILLIAMS, SELIG, 
GATES & WOODYARD, PLLC 
425 West Capitol Avenue, Suite 1800 
Little Rock, Arkansas 72201 
Telephone:  (501) 688-8800 
Facsimile:  (501) 688-8807 
 
 
 
 
 
 
gtalley@mwlaw.com 
Eric N. Whitney (admitted pro hac vice) 
ARNOLD & PORTER 
KAY SCHOLER LLP 
Case 4:21-cv-01243-BRW     Document 22     Filed 02/23/22     Page 2 of 3

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250 West 55th Street 
 
 
 
 
 
 
New York, NY 10019-9710 
Telephone:  (212) 836-8000 
Facsimile:  (212) 836-8689  
 
 
 
 
 
 
eric.whitney@arnoldporter.com 
Katherine Treistman (admitted pro hac vice) 
ARNOLD & PORTER 
KAY SCHOLER LLP 
700 Louisiana Street, Suite 4000 
 
 
 
 
 
 
Houston, TX 77002 
Telephone:  (713) 576-2400 
Facsimile:  (713) 576-2499 
 
 
 
 
 
 
katherine.treistman@arnoldporter.com 
 
 
 
 
 
 
Attorneys for Defendants Crossroads Systems, Inc.  
 
 
 
 
 
 
and Capital Plus Financial, LLC 
 
Case 4:21-cv-01243-BRW     Document 22     Filed 02/23/22     Page 3 of 3

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