Trujillo v. Zimmer US, Inc. et al, No. 3:2019cv00056 - Document 16 (D. Nev. 2019)
Court Description: ORDER granting ECF No. 14 Verified Petition for Permission to Practice Pro Hac Vice by Tarifa B. Laddon for all Defendants, and approving Designation of Local Counsel. Signed by Judge Miranda M. Du on 3/19/2019. Any Attorney not yet registered with the Court's CM/ECF System shall submit a Registration Form on the Court's website www.nvd.uscourts.gov (Copies have been distributed pursuant to the NEF - KR)
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Trujillo v. Zimmer US, Inc. et al Doc. 16 1 2 3 4 5 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 6 7 8 9 Janene Trujillo, 10 11 12 Plaintiff(s), ) ) ) ) ) ) ) vs. Zimmer, US, Inc., et al. 13 Defendant( s). 14 ) ) ) ) ) Case #3:19-cv-00056-MMD-CBC VERIFIED PETITION FOR PERMISSION TO PRACTICE IN rats CASE ONLY BY ATTORNEY NOT ADMITTED TO THE BAR OF THIS COURT AND DESIGNATION OF LOCAL COUNSEL FILING FEE IS $250.00 15 16 __---,-T_ar_i_ fa_B~·-L...,.a.dd . . ._o_n--,--__ , Petitioner, respectfully represents to the Court: (name of petitioner) 17 1. That Petitioner is an attorney at law and a member of the law firm of 18 Faegre Baker Daniels LLP (firm name) 19 20 with offices at 21 Los Angeles (city) 22 23 11766 Wilshire Blvd., Suite 750 ------------:----:-::----:------------( street address) (310) 500-2126 ( area code + telephone number) California (state) 90025 (zip code) tarifa.laddon@FaegreBD.com (Email address) 24 2. That Petitioner has been retained personally or as a member of the law firm by 25 26 27 28 all Defendants [ 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 That since __D _ ec_e_m~b-=--e_r....,.6_,_ 20_0_5__ , Petitioner has been and presently is a (date) member in good standing of the bar of the highest Court of the State of C--:-a_li_fo....,.r_ n ia _ (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 3. 7 4. 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. 11 Court 12 California State Bar 12/06/2005 13 USDC Central District of California 12/07/2005 14 USDC Northern District of California 04/18/2006 15 USDC Southern District of California 05/25/2006 16 USDC Eastern District of California 12/18/2007 17 U.S. Court of Appeals for the Ninth Circuit 06/26/2014 Date Admitted Bar Number 240419 18 19 5. That there are or have been no disciplinary proceedings instituted against petitioner, 20 nor any suspension of any license, certificate or privilege to appear before any judicial, regulatory 21 or administrative body, or any resignation or termination in order to avoid disciplinary or 22 disbarment proceedings, except as described in detail below: 23 None. 24 25 26 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 7. That Petitioner is a member of good standing in the following Bar Associations. 10 8. Petitioner has filed application(s) to appear as counsel under Local Rule IA 11-2 11 (formerly LR IA J0-2) 12 Date of Application 6 7 8 9 during the past three (3) years in the following matters: Cause 13 (State "none" ifno applications.) Title of Court Administrative Body or Arbitrator Was Application Granted or Denied USDC District of Nevada Granted USDC District of Nevada Granted 14 November 1, 2018 3:18-cv-00437-RCJ 15 November 8, 2018 2:18-cv-01744-GMN 16 January 31, 2019 2: 16-cv-00264-APG USDC District of Nevada Granted 17 January 31, 2019 2: 18-cv-02394-APG USDC District of Nevada Granted 18 January 31, 2019 2: 19-cv-00043-RFB USDC District of Nevada Granted (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 FOR THE PURPOSES OF THIS CASE ONL_Y_._~ __,,.__-=!!11111'=-----------Petitioner' s signature 4 STATE OF California ) ) 5 COUNTY OF __ L_ os_An ~g~e_ le_ s_ ) 6 7 8 Tarifa B. Laddon , deposes and says: That the foregoing statements are true. 9 10 Subscribed and sworn to before me this 11 ~'~e-Jn __day of 12 A notary public or other officer completing thil C1111ficate verifies only the identity of the individual who Signed the document to Which tltil Clftiflcate ii attached , and not the tNlhfulnlN ICCUracy, or validity of that document. ' MO/lc..h 13 14 15 16 DESIGNATION OF RESIDENT ATTORNEY ADMITTED TO THE BAR OF THIS COURT AND CONSENT THERETO. 17 Pursuant to the requirements of the Local Rules of Practice for this Court, the Petitioner 18 believes it to be in the best interests of the client(s) to designate 19 L_e_ A_nn _S_an _d_e_r_ s _ (name of local counsel) Attorney at Law, member of the State of Nevada and previously admitted to practice before the 20 above-entitled Court as associate resident counsel in this action. The address and email address of 21 said designated Nevada counsel is: 22 6605 Grand Montecito Pkwy., Suite 200 (street address) 23 24 25 26 Las Vegas (city) 702-384- 7000 (area code+ telephone number) Nevada (state) 89149 (zip code) lsanders@alversontaylor.com (Email address) 27 28 4 Rev. 5/16 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 The undersigned party(ies) appoint(s) -,-__L_,e=-=A_n_n"!""S_a_nd_e_r.s,.,. as (name of local counsel) 8 his/her/their Designated Resident Nevada Counsel in this case. 9 IO 11 12 13 (party's signature) 14 15 (type or print party name, title) 16 17 18 CONSENT OF DESIGNEE The undersigned hereby consents to serve as associate resident Nevada counsel in this case. 19 20 Designated Resident Nevada Counsel's signature 000390 lsanders@alversontaylor.com Bar number Email address 21 22 23 APPROVED: 24 25 Dated: this 19th day of March , 20_. 19 26 UNITED STATES DISTRICT JUDGE 27 28 5 Rev. 5/16 THE STATE BAR OF CALIFORNIA 180 HOWARD STREET, SAN FRANCISCO, CALIFORNIA 94105-1617 TELEPHONE: 888-800-3400 CERTIFICATE OF STANDING January 11, 2019 TO WHOM IT MAY CONCERN: This is to certify that according to the records of the State Bar, TARIFA BELLE LADDON, #240419 was admitted to the practice of law in this state by the Supreme Court of California on December 6, 2005; and has been since that date, and is at date hereof, an ACTIVE member of the State Bar of California; and that no recommendation for discipline for professional or other misconduct has ever been made by the Board of Trustees or a Disciplinary Board to the Supreme Court of the State of California. THE STATE BAR OF CALIFORNIA if,#u~ _1.r.,,_,,, Louise Turner Custodian of Records 1 2 3 4 5 6 7 8 FAEGRE BAKER DANIELS LLP TARIFA B. LADDON (Pro Hac Vice pending) tarifa.laddon@faegrebd.com THEODORE O’REILLY (Pro Hac Vice pending) theodore.oreilly@faegrebd.com 11766 Wilshire Boulevard, Suite 750 Los Angeles, CA 90025 Telephone: (310) 500-2090 Facsimile: (310) 500-2091 ALVERSON TAYLOR & SANDERS LEANN SANDERS, ESQ. (Nevada Bar No. 000390) lsanders@alversontaylor.com 6605 Grand Montecito Parkway, Ste. 200 Las Vegas, NV 89149 Telephone: (702) 384-7000 9 Attorneys for Defendants UNITED STATES DISTRICT COURT 11 LAWYERS 6605 GRAND MONTECITO PKWY STE 200 LAS VEGAS, NV 89149 (702) 384-7000 ALVERSON TAYLOR & SANDERS 10 DISTRICT OF NEVADA 12 13 JANENE TRUJILLO, CASE NO.: 3:19-cv-00056-MMD-CBC 14 Plaintiff, 15 vs. 16 17 18 19 20 21 ZIMMER, US, INC., a Delaware Corporation, SYNVASIVE TECHNOLOGY, a California Corporation, BIOMET ORTHOPEDICS, LLC, an Indiana Limited Liability Company, BIOMET, INC., an Indiana Corporation, and DOES I-X, inclusive, Defendants. AFFIDAVIT OF TARIFA B. LADDON IN SUPPORT OF VERIFIED PETITION AND DESIGNATION OF LOCAL COUNSEL Complaint Filed: November 16, 2018 22 23 24 25 26 27 28 1 AFFIDAVIT OF TARIFA B. LADDON 1 I, Tarifa B. Laddon, hereby declare as follows: 2 1. 3 with Faegre Baker Daniels LLP, attorneys of record for Defendants Biomet Inc.; Biomet 4 Orthopedics, LLC; Biomet Manufacturing Corp.; and Biomet U.S. Reconstruction, LLC 5 (collectively, “Biomet”). I make this declaration based upon personal knowledge and, if 6 called upon to do so, I could and would so testify. 7 8 9 10 11 LAWYERS 6605 GRAND MONTECITO PKWY STE 200 LAS VEGAS, NV 89149 (702) 384-7000 ALVERSON TAYLOR & SANDERS I am an active member of the Bar of the State of California and a partner 2. I make this declaration in support of my Verified Petition and Designation of Local Counsel in the above referenced matter, pursuant to LR IA 11-2(h)(2). 3. Faegre Baker Daniels is national products liability counsel for Biomet; the law firm does not have an office in Nevada. 4. In addition to this single plaintiff products liability case, Faegre Baker 12 Daniels represents Biomet in hundreds of other cases across the country alleging claims 13 against Biomet’s M2a hip replacement system. 14 5. On October 2, 2012, the Biomet M2a cases were consolidated and 15 centralized in the United States District Court for the Northern District of Indiana in the 16 South Bend Division, where Judge Robert L. Miller, Jr. presides over In Re: Biomet M2a 17 Magnum Hip Implant Products Liability Litigation (MDL 2391), cause number: 3:12- 18 MD-2391 (“Biomet M2a Magnum MDL”). 19 6. Beginning in 2018, Judge Miller remanded and transferred groups of cases 20 within the MDL to their local federal courts throughout the country, including those in 21 Nevada. On February 22, 2019 and March 11, 2019, Judge Miller remanded and 22 transferred additional cases out of the MDL. Additional cases are expected to be 23 remanded and transferred to local federal courts through 2019. 24 7. Faegre Baker Daniels LLP represents Biomet in the Biomet M2a Magnum 25 MDL, in the M2a remanded and transferred cases throughout the country, and in state 26 and federal court cases that were never centralized in the Biomet M2a Magnum MDL. 27 28 8. Tarifa Laddon and Theodore O’Reilly of Faegre Baker Daniels LLP represent Biomet in products liability cases such as this one, as well in many of the 2 AFFIDAVIT OF TARIFA B. LADDON 1 Biomet M2a Magnum cases, and have thus far appeared in five remanded and transferred 2 Biomet M2a Magnum MDL cases before this Court in which their verified petitions have 3 been granted: 4 Case Name 5 6 7 8 9 11 LAWYERS 6605 GRAND MONTECITO PKWY STE 200 LAS VEGAS, NV 89149 (702) 384-7000 ALVERSON TAYLOR & SANDERS 10 Mitchell Gonzalez v. Biomet, Inc., et al. Randall Hix v. Biomet, Inc., et al. Edward George v. Biomet, Inc., et al Veronica Gonzalez v. Biomet, Inc., et al Rebecca Franks v. Biomet, Inc., et al Case Number Remand Date 2:18-cv-01744-GMN September 6, 2018 3:18-cv-00437-RCJ-WGC September 6, 2018 2:18-cv-02394-APG-VCF December 12, 2018 2:19-cv-00043-RFB-VCF December 12, 2018 2:16-cv-00264-APG-PAL January 2, 2019 12 13 14 15 16 17 18 19 20 21 9. On February 22, 2019 and March 11, 2019, Judge Miller remanded and transferred four additional cases to this Court. Tarifa Laddon and Theodore O’Reilly of Faegre Baker Daniels LLP will also seek to appear in those cases on behalf of Biomet, as well as in future remanded, transferred, and filed Biomet cases before this Court. 10. For purposes of efficiency, Biomet requests that the Verified Petitions and Designations of Counsel for Tarifa Laddon and Theodore O’Reilly be granted. I declare under the penalty of perjury and the laws of the State of California and Nevada that the foregoing is true and correct. Executed this 18th day of March, 2019, at Los Angeles, California. 22 23 /s/ Tarifa B. Laddon Tarifa B. Laddon 24 25 26 27 28 3 AFFIDAVIT OF TARIFA B. LADDON
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