Securities and Exchange Commission v. Nadel et al

Filing 972

Unopposed MOTION for James E. Connelly and Mark A. Rogers to appear pro hac vice by World Opportunity Fund, L.P.. (Schrils, Frederick)

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UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION SECURITIES AND EXCHANGE COMMISSION, Plaintiff, v. ARTHUR NADEL, SCOOP CAPITAL, LLC, SCOOP MANAGEMENT, INC., Defendants. ) ) ) ) ) ) ) ) ) ) ) CASE NO. 8:09-CV-87-T-26TBM UNOPPOSED MOTION TO APPEAR PRO HAC VICE AND DESIGNATION AND CONSENT TO ACT AS LOCAL COUNSEL WORLD OPPORTUNITY FUND, L.P. (“WOF”), hereby requests entry of an Order allowing James E. Connelly and Mark A. Rogers of the Womble, Carlye, Sandridge & Rice firm to appear, pro hac vice, as counsel for WOF. In support thereof, WOF states as follows: 1. Mr. Connelly and Mr. Rogers are members in good standing with the State Bar of Georgia and the United States District Court for the Northern District of Georgia.1 Mr. Connelly is also a member in good standing of the United States Eleventh Circuit Court of Appeals, the State Courts of New York and the U.S. District Courts for the Eastern and Southern Districts of New York; and Mr. Rogers is also a member in good standing of the United States Fifth and Eleventh Circuit Courts of Appeal. They are not residents of the State of Florida. They do not maintain a regular practice of law before the state courts of Florida or the U.S. District Court for the Middle District of Florida. 1 Messrs. Connelly and Rogers will file certificates of good standing when received from the Northern District of Georgia. 1 2. Mr. Connelly and Mr. Rogers were previously admitted pro hac vice in the related case of Wiand v. World Opportunity Fund, LP, Case No. 8:10-cv-203-EAK-MAP. 3. Mr. Connelly and Mr. Rogers have completed and sent to the Clerk the Special Admissions Attorney Certification and paid the applicable fee. 4. For purposes of this case, and in compliance with Local Rule 2.02, WOF hereby designates the undersigned attorneys and/or law firm as local counsel in the instant action: Local Counsel: Mailing Address: 5. Frederick S. Schrils frederick.schrils@gray-robinson.com GrayRobinson, P.A. 401 East Jackson Street, Suite 2700 P.O. Box 3324 (33601-3324) Tampa, Florida 33602 Telephone: 813-273-5000 Facsimile: 813-273-5145 Frederick S. Schrils and the law firm of GrayRobinson, P.A., consent to the foregoing designation and understand their obligations pursuant to Local Rule 2.02 of the United States District Court for the Middle District of Florida. WHEREFORE, WOF respectfully requests that this Honorable Court grant its motion to admit James E. Connelly and Mark A. Rogers pro hac vice and designate the above attorney of GrayRobinson, P.A., as local counsel. Certification In accordance with Local Rule 3.01(g), Frederick Schrils certifies that he has conferred with counsel for the SEC, Scott Masel, and counsel for the Receiver, Gianluca Morello, and that counsel do not object to the relief sought by this motion. 2 Respectfully submitted, this 19th day of February, 2013. /s/ Frederick S. Schrils Frederick S. Schrils Florida Bar No. 0604003 frederick.schrils@gray-robinson.com GrayRobinson, P.A. 401 East Jackson Street, Suite 2700 Tampa, Florida 33602 Telephone: 813-273-5000 Facsimile: 813-273-5145 - AND – James E. Connelly Georgia Bar No. 181808 jconnelly@wcsr.com Mark A. Rogers Georgia Bar No. 142487 marogers@wcsr.com Womble Carlyle Sandridge & Rice, LLP 271 17th Street, Suite 2400 Atlanta, Georgia 30363 Telephone: 404-888-7496 Facsimile: 404-879-2928 CERTIFICATE OF SERVICE I hereby certify that on February 19, 2013, the foregoing was electronically filed with the Clerk of the Court by using the CM/ECF system which will send notice of electronic filing to CM/ECF system participants. /s/ Frederick S. Schrils Attorney 3

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