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Case 2:22-cv-00828-CDS-BNW Document 19 Filed 06/20/22 Page 1 of 6
`Case 2:22-cv-00828-CDS-BNW Document 19 Filed 06/20/22 Page 1 of 6
`
`unFeWHWO—
`oOoOonNDD
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF NEVADA
`
`ALLEGIANT TRAVEL COMPANY,
`
`Plaintiff(s),
`
`vs.
`
`R2 SOLUTIONS LLC,
`
`Defendant(s).
`
`)
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Case #2:22-cv-00828
`
`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
`
`Carder W. Brooks
`(nameofpetitioner)
`
`, Petitioner, respectfully represents to the Court:
`
`I.
`
`That Petitioner is an attorney at law and a memberofthe law firm of
`
`with offices at
`
`Nelson Bumgardner Conroy PC
`(firm name)
`
`3131 West 7th Street, Suite 300
`(street address)
`
`Fort Worth
`(city)
`817-377-9111
`(area code + telephone number)
`
`.
`
`.
`
`Texas
`(state)
`carder@nelbum.com
`(Email address)
`
`,
`
`,
`
`,
`
`76107
`(zip code)
`
`Ai
`
`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.
`
`Rey. 5/16
`
`

`

`Case 2:22-cv-00828-CDS-BNW Document 19 Filed 06/20/22 Page 2 of 6
`Case 2:22-cv-00828-CDS-BNW Document 19 Filed 06/20/22 Page 2 of 6
`
`3.
`
`That since
`
`, Petitioner has been and presently is a
`
`November3, 2017
`(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 baror
`
`from the clerk of the supreme court or highest admitting court of each state, 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.
`
`4,
`
`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 Petitioner is presently a memberin good
`
`standing of the bars of said Courts.
`
`Court
`
`Date Admitted
`
`Bar Number
`
`State of Texas
`November3, 2017
`TX Bar No. 24105536
`
`
`USDC, Northern District of Texas
`May 20, 2021
`
`
`USDC, Eastern District of Texas
`
`September 2, 2021
`
`USDC, Western District of Texas
`
`September 28, 2021
`
`United States Patent and Trademark Office
`
`October 17, 2016
`
`
`
`
`
`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 orderto avoid disciplinary or
`
` 2
`
`Rev. 5/16
`
`i)
`
`oOfFHNDHOHEeWD
`
`10
`
`11
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`23
`
`26
`
`27
`
`28
`
`

`

`Case 2:22-cv-00828-CDS-BNW Document 19 Filed 06/20/22 Page 3 of 6
`Case 2:22-cv-00828-CDS-BNW Document 19 Filed 06/20/22 Page 3 of 6
`
`6.
`
`That Petitioner has never been denied admission to the State Bar of Nevada. (Give
`
`particulars if ever denied admission):
`
`
`|None.
`
`|
`
`;
`
`ts
`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 IA 10-2) during the past three (3) years in the following matters: (State "none"ifno 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
`
`l
`
`2||
`
`3)
`
`4)
`
`j 6
`
`7 8 9
`
`10
`
`Ll
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22|)extent as a memberof the State Bar of Nevada.
`
`23
`
`10.
`
`Petitioner agrees to comply with the standards of professional conduct required of
`
`24|the membersof the barof this court.
`
`25
`
`11.
`
`Petitioner has disclosed in writing to the client that the applicant is not admitted to
`
`26||practice in this jurisdiction and that the client has consented to such representation.
`
`oF
`
`28
`
`3
`
`Rev. 5/16
`
`

`

`Case 2:22-cv-00828-CDS-BNW Document 19 Filed 06/20/22 Page 4 of 6
`Case 2:22-cv-00828-CDS-BNW Document 19 Filed 06/20/22 Page 4 of 6
`
`That Petitioner respectfully prays that Petitioner be admitted to practice before this Court
`
`g
`
`Petitioner’s signature
`
`FORTHEPURPOSESOFTHISCASEONLY. (\,
`
`))
`
`)
`
`STATE OF
`
`Texas
`
`COUNTY OF
`
`‘Tarrant
`
`Carder W. Brooks__,Petitioner, being first duly sworn, deposes and says:
`
`
`oosD
`
`Subscribed and sworn to before methis
`
`
`Petitioner’s s{gnature
`
`[4dy Wy L
`Thattheforegoingstatementsaretrue.
`, WL
`om day of yunt
` »
`GawayUDofCourt
`
`====%
`
`MEINseoa!
`
`EMMA COX
`eyeile,
`“Wh:4 Notary Public, State of Texas
`PNie= Comm. Expires 01-21-2026
`Gia’
`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
`
`believesit to be in the best interests of the client(s) to designate
`
`Joseph Ganley
`(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:
`
`10080 West Alta Drive
`(street address)
`
`,
`
`Las Vegas
`(city)
`
`:
`
`Nevada
`;
`89145
`
`(state)
`(zip code)
`
`,
`
`702-385-2500
`(area code + telephone number)
`
`jganley@hutchlegal.com
`(Email address)
`
`4
`
`Rev. 5/16
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`

`

`Case 2:22-cv-00828-CDS-BNW Document 19 Filed 06/20/22 Page 5 of 6
`Case 2:22-cv-00828-CDS-BNW Document 19 Filed 06/20/22 Page 5of6
`
`—"
`
`i 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 onall ofus.
`
`APPOINTMENT OF DESIGNATED RESIDENT NEVADA COUNSEL
`
`The undersigned party(ies) appoint(s)
`
`Joseph Ganley
`(nameof local counsel)
`his/her/their Designated Resident Nevada Counselin this case.
`
`as
`
`
`
` (party's signature) 7
`
`R2 Solutions LLC
`(type or print party name,title)
`
`
`(party's signature)
`
`
`(type or print party name,title)
`
`CONSENT OF DESIGNEE
`
`The undersigned hereby consents to serve|asassociate ee Nevada counselin this case.
`fax
`‘
`oy
`ee
`webbER os
`Designated ResidentNevadaCounsel’s signature
`
`5643
`Bar number
`
`jganley@hutchlegal.com
`Email address
`
`APPROVED:
`
`Dated: this
`
`day of
`
`,20
`
`UNITED STATES DISTRICT JUDGE
`
`5
`
`Rev. 5/16
`
`

`

`Case 2:22-cv-00828-CDS-BNW Document 19 Filed 06/20/22 Page 6 of 6
`
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