Motion to allow Stuart R. Lombardi to appear pro hac… — Oto Analytics, LLC v. Benworth Capital Partners PR LLC (Dkt. 9)

Record facts

U.S. District Court for the District of Puerto Rico · No. 3:23-cv-01034-GMM · Doc. 9 · 2023-01-27 · Docket on CourtListener

Full text

Case 3:23-cv-01034-GMM Document9_ Filed 01/27/23 Page1of6

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF PUERTO RICO

OTO ANALYTICS, LLC,
Plaintiff,
v. Civil Action No. 23-01034
BENWORTH CAPITAL PARTNERS PR
LLC, BENWORTH CAPITAL PARTNERS

LLC, BERNARDO NAVARRO and
CLAUDIA NAVARRO,

CO? (Or (OP 40? LO? COR OR OO? CO? (OO? CO?

Defendants.

APPLICATION FOR ADMISSION PRO HAC VICE FOR STUART R. LOMBARDI

Comes now, Stuart R. Lombardi, applicant herein and respectfully states:

1, Applicant is an attorney and member of the law firm of Willkie Farr & Gallagher

LLP, with offices at:

Address 787 Seventh Avenue
New York, NY 10019-6099

Email slombardi@willkie.com

Telephone No. (212) 728-8882

Fax No. (212) 728-9882
2. Applicant will sign all pleadings with the name Stuart R. Lombardi.
3. Applicant has been retained personally or as a member of the above-named firm

by Oto Analytics, LLC (f/k/a Oto Analytics, Inc., d/b/a Womply) (““Womply”) to provide legal
representation in connection with the above-styled matter now pending before the United States

District Court for the District of Puerto Rico.
Case 3:23-cv-01034-GMM Document9_ Filed 01/27/23 Page 2of6

4, Since November 20, 2012, applicant has been and presently is a member in good
standing of the bar of the highest court of New Jersey. Applicant’s attorney ID number is
026032012.

5. Since March 18, 2013, applicant has been and presently is a member in good
standing of the bar of the First Judicial Department, Appellate Division of the Supreme Court of

the State of New York. Applicant’s attorney registration number is 5103262.

6. Applicant has been admitted to practice law before the following courts:
Court Admission Date
oS District Court for the Southern District 04/15/2014
Ne vue Court for the Eastern District of 04/15/2014
7. Applicant is a member in good standing of the bars of the courts listed in
paragraph 6.
8. Applicant is not currently suspended from the practice of law before any court or
jurisdiction.
9. Applicant is not currently the subject of any complaint for unethical conduct,

disciplinary proceeding or criminal charges before any court or jurisdiction.
10. Applicant has not filed for pro hac vice admission in the United States District

Court of the District of Puerto Rico in the past three years.
Case 3:23-cv-01034-GMM Document9 _ Filed 01/27/23 Page 3of6

11. Local counsel of record associated with applicant in this matter is:

Alejandro J. Cepeda Diaz
USDC-PR 222110
McConnell Valdés LLC
270 Mufioz Rivera Ave.
San Juan PR 00918
Tel: (787) 250-5637
Email: ajc@mevpr.com
12. Applicant has read the local rules of this court and will comply with the same.
13. Applicant has read the Local Rules of the United State District Court for the
District of Puerto Rico which provide in part that attorneys appearing pro hac vice must comply
with the provisions set forth therein and pay an admission fee of $300 per appearance in each
new case before the Court. Accordingly, payment of the pro hac vice admission fee is attached
hereto in the form of a check or money order payable to “Clerk, U.S. District Court.”
WHEREFORE, applicant respectfully requests to be admitted to practice in the United

States District Court for the District of Puerto Rico for the above-styled case only.

Dated: January 27, 2023

Case 3:23-cv-01034-GMM Document9_ Filed 01/27/23 Page 4of6

I HEREBY CERTIFY, pursuant to Local Rule 83(A)(f), that I consent to the designation

of local counsel of record for all purposes.

Dated: January 27, 2023

I HEREBY CERTIFY that I have served a true and correct copy of this document upon
each attorney of record and the original upon the Clerk of the Court accompanied by a $300.00

pro hac vice admission fee.

Dated: January 27, 2023 vA Lyd, Eiptiithee— A

Alejandro J. J, Diaz //

Case 3:23-cv-01034-GMM Document9_ Filed 01/27/23 Page5of6

CERTIFICATE OF SERVICE

The undersigned certifies that on January 27, 2023, the foregoing document was filed
with the Clerk of the Court using CM/ECF, which sent notices to all parties receiving

notifications through the CM/ECF system.

Dated: January 27, 2023 By: ff [ee tot a

Akj andr¢ J ng coped Diaz/
USDC- ap 10
McConnell Valdés LLC
270 Mufioz Rivera Ave.
Hato Rey PR 00918

Tel: (787) 250-5637

Email: ajc@mcvpr.com

Attorney for Plaintiff Oto Analytics, LLC
Case 3:23-cv-01034-GMM Document9 Filed 01/27/23 Page 6of6

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF PUERTO RICO

OTO ANALYTICS, LLC, §
§
Plaintiff, §
§
Vv. § Civil Action No. 23-01034
§
BENWORTH CAPITAL PARTNERS PR §
LLC, BENWORTH CAPITAL PARTNERS §
LLC, BERNARDO NAVARRO and §
CLAUDIA NAVARRO, §
§
Defendants.
PROPOSED ORDER

The Court, having considered the Application for Admission Pro Hac Vice for Stuart R.

Lombardi, orders that:

x

the application be granted. The Clerk of Court shall deposit the admission fee to the
account of Non-Appropriated Funds of this Court.

the application be denied. The Clerk of the Court shall return the admission fee to the
applicant.

SO ORDERED.

In San Juan, Puerto Rico, this day of , 2023.

U.S. DISTRICT JUDGE

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