MOTION to Appear Pro Hac Vice, Consent to Designation, and Request to Electronically Receive Notices of… (Dkt. 113)

Summary

Motion filed April 13, 2021 as Document 113 in In re: January 2021 Short Squeeze Trading Litigation, Case No. 21-2989-MDL-ALTONAGA/Torres, in the U.S. District Court for the Southern District of Florida. Peter W. Homer of Homer Bonner Jacobs Ortiz, P.A. moves under Local Rule 4(b) for the admission pro hac vice of Gina Cora of Davis Polk & Wardwell LLP as co-counsel for defendants Morgan Stanley Smith Barney LLC and E*TRADE Financial Holdings, LLC, E*TRADE Securities LLC and E*TRADE Financial Corporation, and for her to receive notices of electronic filing. The motion states that Cora is a member in good standing of the State Bar of New York, is admitted in the Southern District of New York and has paid the $200.00 admission fee. Homer consents to be designated as the member of the court’s bar on whom filings are served.

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Case 1:21-md-02989-CMA Document 113 Entered on FLSD Docket 04/13/2021 Page 1 of 3




                                UNITED STATES DISTRICT COURT
                                SOUTHERN DISTRICT OF FLORIDA

                             Case No.: 21-2989-MDL-ALTONAGA/Torres

   In re:

   JANUARY 2021 SHORT SQUEEZE
   TRADING LITIGATION
   __________________________________/


                        MOTION TO APPEAR PRO HAC VICE,
                    CONSENT TO DESIGNATION, AND REQUEST TO
              ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING


            In accordance with Local Rule 4(b) of the Rules Governing the Admission, Practice, Peer

   Review, and Discipline of Attorneys in the United States District Court for the Southern District

   of Florida, the undersigned respectfully moves for the admission pro hac vice of Gina Cora of

   the law firm Davis Polk & Wardwell LLP, 450 Lexington Avenue, New York, New York 10017,

   (212) 450-4000, for purposes of appearance as co-counsel on behalf of defendants Morgan

   Stanley Smith Barney LLC (“Morgan Stanley”), and E*TRADE Financial Holdings, LLC,

   E*TRADE Securities LLC, and E*TRADE Financial Corporation (collectively “E*TRADE”) in

   the above-styled case only, and pursuant to Rule 2B of the CM/ECF Administrative Procedures,

   to permit Gina Cora to receive electronic filings in this case, and in support thereof states as

   follows:


            1. Gina Cora is not admitted to practice in the Southern District of Florida and is a

   member in good standing of the State Bar of New York and is admitted to practice in the United

   States District Court for the Southern District of New York.




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Case 1:21-md-02989-CMA Document 113 Entered on FLSD Docket 04/13/2021 Page 2 of 3




          2. Movant, Peter W. Homer, Esquire, of the law firm of Homer Bonner Jacobs Ortiz,

   P.A., 1200 Four Seasons Tower, 1441 Brickell Ave., Miami Florida 33131, is a member in good

   standing of The Florida Bar and the United States District Court for the Southern District of

   Florida and is authorized to file through the Court’s electronic filing system. Movant consents to

   be designated as a member of the Bar of this Court with whom the Court and opposing counsel

   may readily communicate regarding the conduct of the case, upon whom filings shall be served,

   who shall be required to electronically file and serve all documents and things that may be filed

   and served electronically, and who shall be responsible for filing and serving documents in

   compliance with the CM/ECF Administrative Procedures. See Section 2B of the CM/ECF

   Administrative Procedures.


          3. In accordance with the local rules of this Court, Gina Cora has made payment of this

   Court’s $200.00 admission fee. A certification in accordance with Rule 4(b) is attached hereto.


          4. Gina Cora, by and through designated counsel and pursuant to Section 2B CM/ECF

   Administrative Procedures, hereby requests the Court to provide Notice of Electronic Filings to

   Gina Cora at email address gina.cora@davispolk.com.


          WHEREFORE, Peter W. Homer moves this Court to enter an Order authorizing Gina

   Cora to appear before this Court on behalf of Morgan Stanley and E*TRADE, for all purposes

   relating to the proceedings in the above-styled matter and directing the Clerk to provide notice of

   electronic filings to Gina Cora.




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Case 1:21-md-02989-CMA Document 113 Entered on FLSD Docket 04/13/2021 Page 3 of 3




  Date: April 13, 2021         Respectfully submitted,
                               /s/ Peter W. Homer_______________
                               Peter W. Homer
                               Florida Bar No.: 291250
                               Email: phomer@homerbonner.com
                               Homer Bonner Jacobs Ortiz, P.A.
                               1200 Four Seasons Tower
                               1441 Brickell Avenue
                               Miami, Florida 33131
                               Telephone: (305) 350-5139
                               Facsimile: (305) 372-2738

                               Attorneys for Morgan Stanley Smith Barney LLC;
                               E*TRADE Financial Holdings, LLC; E*TRADE Securities
                               LLC; E*TRADE Financial Corporation




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