Batchelor, Jr. v. York Holding, Ltd. et al, No. 2:2024cv00239 - Document 18 (D. Nev. 2024)
Court Description: ORDER Granting 16 Verified Petition for Permission to Practice Pro Hac Vice for Attorney Michael Delynn Fielding for Rayford International Inc. and approving Designation of Local Counsel Attorney Matthew L. Johnson. Signed by Judge Gloria M. Navarro on 2/15/2024. Any Attorney not yet registered with the Court's e-filng system shall register on the PACER website www.pacer.gov (Copies have been distributed pursuant to the NEF - RJDG)
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Batchelor, Jr. v. York Holding, Ltd. et al 1 2 3 4 5 Doc. 18 Matthew L. Johnson (6004) JOHNSON & GUBLER, P.C. 8831 W. Sahara Ave Las Vegas, NV 89117 Phone: (702) 471-0065 Fax: (702) 471-0075 mjohnson@mjohnsonlaw.com UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 6 7 Case #2:24-cv-00239 8 9 WILLIAM A. BATCHELOR, JR. j 10 Plaintiff(s), 11 vs. YORK HOLDING, LTD; CHANGOING LIU, RAYFORD INTERNATIONAL INC; FREDRICK WAID; et al 12 13 14 ) ) ) ) ) j ) Defendant(s). _____________________________________ ) VERIFIED PETITION FOR PERMISSION TO PRACTICE IN THIS CASE ONLY BY ATTORNEY NOT ADMITTED TO THE BAR OF THIS COURT AND DESIGNATION OF LOCAL COUNSEL FILING FEE IS $250.00 15 Michael Delynn Fielding (name of petitioner) 16 17 That Petitioner is an attorney at law and a member of the law firm of 1. 18 Husch Blackwell LLP (firm name) 19 20 Kansas City (city) 22 24 25 26 27 28 4801 Main Street, Suite 1000 (street address) with offices at 21 23 , Petitioner, respectfully represents to the Court: 816-983-8000 (area code + telephone number) 2. Missouri (state) , 64112 (zip code) , michael.fielding@huschblackwell.com (Email address) That Petitioner has been retained personally or as a member of the law firm by Rayford International, Inc. [client(s)] to provide legal representation in connection with the above-entitled case now pending before this Court. Rev. 5/16 Dockets.Justia.com 3. 3 September 19, 2001 ; Petitioner has been and presently is a (date) member in good standing of the bar of the highest Court of the State of Missouri_______ (state) where Petitioner regularly practices law. Petitioner shall attach a certificate from the state bar or 4 from the clerk of the supreme court or highest admitting court of each state, territory, or insular 5 possession of the United States in which the applicant has been admitted to practice law certifying 6 the applicant's membership therein is in good standing. 1 2 7 4. That since That Petitioner was admitted to practice before the following United States District 8 Courts, United States Circuit Courts of Appeal, the Supreme Court of the United States and Courts 9 of other States on the dates indicated for each, and that Petitioner is presently a member in good 10 standing of the bars of said Courts. Bar Number 11 Court Date Admitted 12 Iowa January 18, 2018 79131 13 Utah April 6, 2021 17766 14 Missouri September 19, 2001 53124 15 Kansas April 26, 2002 20562 16 Nebraska August 10, 2022 27530 17 See Appendix 1 for Federal Admissions 18 19 20 21 22 23 24 25 26 5. That there are or have been no disciplinary proceedings instituted against petitioner, nor any suspension of any license, certificate or privilege to appear before any judicial, regulatory or administrative body, or any resignation or termination in order to avoid disciplinary or disbarment proceedings, except as described in detail below: In two separate, unrelated matters I was temporarily placed on the ineligibility list in New Jersey. The first occurred in 2017 when I inadvertently failed to inform the New Jersey fund that my work on a case was concluded. I noted the conclusion of the matter and was reinstated to the eligible list. The second occurred in 2022 when I inadvertently failed to timely pay a pro hac fee. I later paid the fee and was reinstated to the eligible list. 27 28 2 Rev. 5/16 6. 1 That Petitioner has never been denied admission to the State Bar of Nevada. (Give 2 particulars if ever denied admission): 3 None 4 5 6 7 8 7. That Petitioner is a member of good standing in the following Bar Associations. Missouri Bar Association; Kansas Bar Association; Iowa Bar Association; Nebraska Bar Association; Utah Bar Association 9 10 8. 11 (formerly l r ia 10-2) 12 Date of Application Petitioner has filed application(s) to appear as counsel under Local Rule IA 11-2 during the past three (3) years in the following matters: Cause 13 (State "none" if no applications.) Title of Court Administrative Body or Arbitrator Was Application Granted or Denied 14 3/23/2021 21-11377 Bankr. D. Nev. Granted 15 8/3/2023 23-12852 Bankr. D. Nev. Granted 16 17 18 (If necessary, please attach a statement of additional applications) 19 20 9. Petitioner consents to the jurisdiction of the courts and disciplinary boards of the 21 State of Nevada with respect to the law of this state governing the conduct of attorneys to the same 22 extent as a member of the State Bar of Nevada. 23 24 25 26 10. Petitioner agrees to comply with the standards of professional conduct required of the members of the bar of this court. 11. Petitioner has disclosed in writing to the client that the applicant is not admitted to practice in this jurisdiction and that the client has consented to such representation. 27 28 3 Rev. 5/16 1 That Petitioner respectfully prays that Petitioner be admitted to practice before this Court 2 3 4 5 6 7 8 Michael Delynn Fielding ; Petitioner, being first duly swqrnpdeposes and says: That the foregoing statements are true. 9 10 Subscribed and sworn to before me this 11 12 CRYSTAL DAWN MANUEL Notary Public-Notary Seal STATE OF MISSOURI Jackson County My Commission Expires 9/15/2025 Commission # 21449199 13 14 15 16 17 18 19 20 21 22 23 DESIGNATION OF RESIDENT ATTORNEY ADMITTED TO THE BAR OF THIS COURT AND CONSENT THERETO. Pursuant to the requirements of the Local Rules of Practice for this Court, the Petitioner believes it to be in the best interests of the client(s) to designate Matthew L. Johnson ; (name of local counsel) Attorney at Law, member of the State of Nevada and previously admitted to practice before the above-entitled Court as associate resident counsel in this action. The address and email address of said designated Nevada counsel is: Lakes Business Park, 8831 West Sahara Avenue (street address) 24 25 26 27 28 Nevada (state) Las Vegas (city) ________ (702) 471-0065________ (area code + telephone number) 9 89117 . (zip code) mjohnson@mjohnsonlaw.com_____ . (Email address) 4 Rev. 5/16 1 By this designation the petitioner and undersigned party(ies) agree that this designation constitutes 2 agreement and authorization for the designated resident admitted counsel to sign stipulations 3 binding on all of us. 4 5 APPOINTMENT OF DESIGNATED RESIDENT NEVADA COUNSEL 6 7 8 Matthew L. Johnson (name of local counsel) his/her/their Designated Resident Nevada Counsel in this case. The undersigned party(ies) appoint(s) 9 - (party's signature) 11 Michael D. Fielding, Attorney for Rayford International Inc (type or print party name, title) 12 13 (party's signature) 14 15 (type or print party name, title) 16 18 CONSENT OF DESIGNEE The undersigned hereby consents to serve as associate resident Nevada counsel in this case. 19 /s/ Matthew L. Johnson Designated Resident Nevada Counsel’s signature 20 6004 21 24 25 26 27 28 mjohnson@mjohnsonlaw.com Bar number 22 23 so Muke 10 17 as Email address APPROVED: Dated: this 15 February day of , 2024 UNITED STATES DISTRICT JUDGE 5 Rev. 5/16 Appendix 1 Federal admissions of Michael D. Fielding U.S. Supreme Court (2018) U.S. Courts of Appeal: Eighth Cir. (2003); Tenth Cir. (2005), Fed. Cir. (2005) U.S. District Courts: W.D. Mo (2001); Kan (2002); Neb (2003); Colo (2016); E.D. Mo. (2017); N.D. Iowa (2018); S.D. Iowa (2018); D. Utah (2021) Other: U.S. Court of Fed. Claims (2003) Supreme Court of ^au^asi \ Certificate of (®oob iHaniJing I, Douglas T. Shima, Clerk of the Supreme Court of the State of Kansas, do hereby certify that the Supreme Court of Kansas is the highest court of law, and the court of last resort within the State of Kansas, and has exclusive jurisdiction over and control of the admission of applicants to the bar of this state. I do further certify that on April 26, 2002, Michael Delynn Fielding was duly admitted to practice as an attorney and counselor of the Supreme Court and all other courts of the State of Kansas and is, on the date indicated below, a member in good standing of the Kansas Bar. Witness my hand and the seal of the Supreme Court, hereto affixed at my office in Topeka, Kansas, this 23rd day of January, 2024. Active Status Clerk of the Supreme Court ofKansas STATE OF UTAH JuMrial department ^ttarnep’jJ Certificate IN THE SUPREME COURT OF THE STATE OF UTAH UNITED STATES OF AMERICA ss. STATE OF UTAH I, Nicole I. Gray, Clerk of the Supreme Court of the State of Utah, do hereby certify that by an Order of this Court duly made and entered wherein MICHAEL DELYNN FIELDING, #17766, was admitted to practice as an Attorney and Counselor at Law in all the courts of the State of Utah on the 6th day of April, 2021. I further certify that this attorney is now, and has been since admission, a member of the Bar of this Court in good standing; and that the private and professional character of this attorney appears to be satisfactory. IN TESTIMONY WHEREOF, I have here unto set my hand and affixed the Seal of said court this 23rd day of fanuary, A.D. 2024 The Supreme Court ofMissouri Certificate ofAdmission as an Attorney at Law I, Betsy AuBuchon, Clerk of the Supreme Court of Missouri, do hereby certify that the records of this office show that on 9/19/2001, MicfiaeCcDeCynn Tietfing was duly admitted and licensed to practice as an Attorney and Counselor at Law in the Supreme Court of Missouri and all courts of record in this state, and is, on the date indicated below, a member in good standing of this Bar. IN TESTIMONY WHEREOF, I hereunto set my hand and affix the seal of the Supreme Court of Missouri at my office in Jefferson City, Missouri, this 24,h day of January, 2024. Clerk of the Supreme Court of Missouri SUPREME COURT STATE OF NEBRASKA CERTIFICATE OF GOOD STANDING I certify that I am Clerk of the Supreme Court of the State of Nebraska, the highest court of the State, and that on August 10, 2022, Michael Delynn Fielding was admitted to practice as an Attorney and Counselor at Law by the Supreme Court. I further certify that the attorney is now in good standing in the Courts of Nebraska, and there is not now pending in this court any disciplinary action. The attorney's private and professional character appears to be good. IN TESTIMONY WHEREOF, I have hereunto set my hand and caused to be affixed the Seal of this Court, in the City of Lincoln, on January 25, 2024. Erika Schafer, Acting Clerk The Supreme Court of Iowa THE STATE OF IOWA Certification STATE OF IOWA, ss. I, Donna M. Humpal, Clerk of the Supreme Court of the State of Iowa, which court is the highest Court of said State, do hereby certify that Michael DeLynn Fielding was admitted to practice as an Attorney and Counselor at Law in the Courts of said State by the Supreme Court of Iowa on January 17, 2018, and at the present time he is in good standing at the bar in this Court. * IN TESTIMONY WHEREOF, I have hereunto set my hand and caused to be affixed the Seal of said Court, in the City of Des Moines, this day of February, 2024. Donna M. Humpal,, Clerk The Supreme Court of Iowa Any requests for disciplinary history should be submitted to: Iowa Supreme Court Attorney Disciplinary Board 1111 East Court Avenue Des Moines LA 50319
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