Case 2:22-cv-00828-CDS-BNW Document 16 Filed 06/20/22 Page 1 of 7
`Case 2:22-cv-00828-CDS-BNW Document 16 Filed 06/20/22 Page 1 of 7
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF NEVADA
`
`vAEeelUWwGODOe
`aosaaD
`
`)
`
`Case #2:22-cv-00828
`
`ALLEGIANT TRAVEL COMPANY,
`
`Plaintiff(s),
`
`vs.
`
`R2 SOLUTIONSLLC,
`
`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 FEEIS $250.00
`
`Edward R. NelsonIII
`(name ofpetitioner)
`
`, Petitioner, respectfully represents to the Court:
`
`A.
`
`That Petitioner is an attorney at law and a memberofthe law firm of
`
`Nelson Bumgardner Conroy PC
`
`(firm name)
`
`with offices at
`
`3131 West 7th Street, Suite 300
`(street address)
`
`Fort Worth
`(city)
`
`;
`
`Texas
`(state)
`
`;
`
`76107
`(zip code)
`
`817-377-9111 ©
`(area code + telephone number)
`
`,
`
`ed@nelbum.com
`(Email address)
`
`,
`
`:
`
`2.
`
`That Petitioner has been retained personally or as a memberof the law firm by
`R2 Solutions LLC
`to provide legal representation in connection with
`[client(s)]
`
`the above-entitled case now pending before this Court.
`
`Rev. 5/16
`
`
`Case 2:22-cv-00828-CDS-BNW Document 16 Filed 06/20/22 Page 1 of 7
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF NEVADA
`
`vAEeelUWwGODOe
`aosaaD
`
`)
`
`Case #2:22-cv-00828
`
`ALLEGIANT TRAVEL COMPANY,
`
`Plaintiff(s),
`
`vs.
`
`R2 SOLUTIONSLLC,
`
`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 FEEIS $250.00
`
`Edward R. NelsonIII
`(name ofpetitioner)
`
`, Petitioner, respectfully represents to the Court:
`
`A.
`
`That Petitioner is an attorney at law and a memberofthe law firm of
`
`Nelson Bumgardner Conroy PC
`
`(firm name)
`
`with offices at
`
`3131 West 7th Street, Suite 300
`(street address)
`
`Fort Worth
`(city)
`
`;
`
`Texas
`(state)
`
`;
`
`76107
`(zip code)
`
`817-377-9111 ©
`(area code + telephone number)
`
`,
`
`ed@nelbum.com
`(Email address)
`
`,
`
`:
`
`2.
`
`That Petitioner has been retained personally or as a memberof the law firm by
`R2 Solutions LLC
`to provide legal representation in connection with
`[client(s)]
`
`the above-entitled case now pending before this Court.
`
`Rev. 5/16
`
`
`
`Case 2:22-cv-00828-CDS-BNW Document 16 Filed 06/20/22 Page 2 of 7
`Case 2:22-cv-00828-CDS-BNW Document 16 Filed 06/20/22 Page 2 of 7
`
`oNAOUWF&FWSPY
`
`oSoOo
`
`3
`
`That since
`
`, Petitioner has been and presently is a
`
`11/1/1996
`(date)
`memberin good standing of the bar of the highest Court of the State of
`
`Texas
`(state)
`where Petitioner regularly practices law. Petitioner shall attach a certificate from the state bar or
`
`from the clerk of the supreme court or highest admitting court of eachstate, territory, or insular
`
`possession of the United States in which the applicant has been admitted to practice law certifying
`
`the applicant's membership therein is in good standing.
`
`A,
`
`That Petitioner was admitted to practice before the following United States District
`
`Courts, United States Circuit Courts of Appeal, the Supreme Court of the United States and Courts
`
`of other States on the dates indicated for each, and that Petitioneris presently a memberin good
`
`standing of the bars of said Courts.
`
`Court
`
`Date Admitted
`
`Bar Number
`
`SEE ATTACHED CONTINUATION PAGE
`
`TX Bar No. 00797142
`
`5,
`
`That there are or have been no disciplinary proceedings instituted against petitioner,
`
`nor any suspension ofany 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:
`
`2
`
`Rev. 5/16
`
`
`
`Case 2:22-cv-00828-CDS-BNW Document 16 Filed 06/20/22 Page 3 of 7
`Case 2:22-cv-00828-CDS-BNW Document 16 Filed 06/20/22 Page 3 of 7
`
`6.
`
`That Petitioner has never been denied admission to the State Bar of Nevada. (Give
`
`particulars if ever denied admission):
`
`Petitioner has never been denied admission to the State Bar ofNevada.
`State of Texas, Eastern District of Texas, and Federal Circuit.
`
`ih
`
`That Petitioner is a memberof good standing in the following Bar Associations.
`
`8.
`
`Petitioner has filed application(s) to appear as counsel under Local Rule IA 11-2
`
`(formerly LR TA 10-2) during the past three (3) years in the following matters: (State "none"if no applications.)
`
`Date of Application
`
`Cause
`
`Title of Court
`Administrative Body
`or Arbitrator
`
`Was Application
`Granted or
`Denied
`
`None
`
`
`
`(If necessary, please attach a statement of additional applications)
`
`9.
`
`Petitioner consents to the jurisdiction of the courts and disciplinary boards of the
`
`State of Nevada with respect to the law of this state governing the conductof attorneys to the same
`
`extent as a memberof the State Bar of Nevada.
`
`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.
`
`3
`
`Rev. 5/16
`
`
`
`Case 2:22-cv-00828-CDS-BNW Document 16 Filed 06/20/22 Page 4 of 7
`Case 2:22-cv-00828-CDS-BNW Document 16 Filed 06/20/22 Page 4 of 7
`
`That Petitioner respectfully prays that Petitioner be ad
`
`FOR THE PURPOSES OF THIS CASE ONLY:
`
`d to practice before this Court
`
`
`Petitioner’s signature
`
`STATE OF
`
`Texas
`
`COUNTY OF
`
`‘Tarrant
`
`)
`
`EdwardR.Nelson Ill
`
`That the foregoing statements are true.
`
`__, Petitioner, being
`
`fix o
`
`z
`
`oses and says:
`
`= =e
`
`x’
`
`Subscribed and sworn to before methis
`
`DM ay or Yue, 2022
`NotaryPublicorrgofCourt
`
`
`YY
`
`s,
`EMMACOX
`Ln“SRP,
`==
`NORAS Comm.Expires 01-21-2026
`sf 6 Notary Public, State of Texas
`
`mow
`
`__Notary ID 133546475
`
`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
`Joseph Ganley
`(name of local counsel)
`Attorney at Law, memberofthe 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:
`
`10080 West Alta Drive
`(street address)
`
`Las Vegas
`(city)
`
`‘
`
`Nevada
`(state)
`
`,
`
`89145
`(zip code)
`
`702-385-2500
`(area code + telephone number)
`
`,
`
`jganley@hutchlegal.com
`(Email address)
`
`;
`
`;
`
`4
`
`Rev. 5/16
`
`bo
`
`OofoHNDOHOHEeWwW
`
`11
`
`12
`
`13
`
`14
`
`i)
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`2 2
`
`6
`
`2E
`
`28
`
`
`
`Case 2:22-cv-00828-CDS-BNW Document 16 Filed 06/20/22 Page 5 of 7
`Case 2:22-cv-00828-CDS-BNW Document 16 Filed 06/20/22 Page 5 of 7
`
`By this designation the petitioner and undersigned party(ies) agree that this designation constitutes
`
`agreement and authorization for the designated resident admitted counsel to sign stipulations
`
`binding on all of us.
`
`APPOINTMENT OF DESIGNATED RESIDENT NEVADA COUNSEL
`
`The undersigned party(ies) appoint(s)
`
`Joseph Ganley
`(name of local counsel)
`his/her/their Designated Resident Nevada Counsel in this case.
`
`as
`
`// 4 paler
`
`(party's signature)
`
`R2 Solutions LLC
`(type orprint party name,title)
`
`(party's signature)
`
`(type or print party name,title)
`
`CONSENT OF DESIGNEE
`The undersigned hereby consents to serve as associate resident Nevada counsel in this case,
`a in Be
`|
`fi
`_*
`AL,{apt Roa—sy
`}
`— i
`.
`-
`Nawg ere
`Designated Resident Nevada Counsel’s signature
`
`See
`
`5643
`Bar number
`
`jganley@hutchlegal.com
`Email address
`
`APPROVED:
`
`Dated: this
`
`day of
`
`,20-
`
`UNITED STATES DISTRICT JUDGE
`
`5
`
`Rev. 5/16
`
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`
`\©
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`Case 2:22-cv-00828-CDS-BNW Document 16 Filed 06/20/22 Page 6 of 7
`Case 2:22-cv-00828-CDS-BNW Document 16 Filed 06/20/22 Page 6 of 7
`
`CONTINUED FROM PETITION
`
`
`
`
`
`
`
`
`
`Date of Admission
`Court
`
`
`
`Supreme Court of the United States
`11/27/06
` !"!#$% &#%'#&(!#)*+&!,# &-&!.#
`//012034#
`State of Texas
`11/01/96
`
` &-&!#%'#5!6-.#
`//03/074#
`
`United States Court of Appeals, Federal
`10/06/04
`)*+&!,# &-&!.#$% &#%'#8 !-9.:#;!,! -9#
`/303403=#
`Circuit
`
`$+ < +&#
`06/20/07
`United States Court of Federal Claims
`34013032#
`)*+&!,# &-&!.#$% &#%'#;!,! -9#$9-+".#
`
`United States District Court, Eastern District
`03/29/05
`)*+&!,# &-&!.#>+.& +<&#$% &:#?-.&! *#>+.& +<&#
`3@01703A#
`of Texas
`
`%'#5!6-.#
`05/12/97
`United States District Court, Northern District
`3A0/1072#
`)*+&!,# &-&!.#>+.& +<&#$% &:#B% &(! *#>+.& +<&#
`of Texas
`
`%'#5!6-.#
`08/03/01
`United States District Court, Southern District
`3C03@03/#
`)*+&!,# &-&!.#>+.& +<&#$% &:# % &(! *#>+.& +<&#
`of Texas
`
`%'#5!6-.#
`United States District Court, Western District
`09/29/17
`)*+&!,# &-&!.#>+.& +<&#$% &:#D!.&! *#>+.& +<&#
`370170/2#
`of Texas
`%'#5!6-.#
`United States District Court, District of
`)*+&!,# &-&!.#>+.& +<&#$% &:#>+.& +<&#%'#
`Colorado
`$%9% -,%#
`United States District Court, Eastern District
`)*+&!,# &-&!.#>+.& +<&#$% &:#?-.&! *#>+.& +<&#
`of Michigan
`%'#E+<(+F-*##
`G
`
`11/12/02
`//0/1031#
`
`08/20/21
`3C01301/#
`
`
`
`Case 2:22-cv-00828-CDS-BNW Document 16 Filed 06/20/22 Page 7 of 7
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