2012-03-30 - MS - TEPPER - Pro Hac Vice Motion and Verified Application-FILED-Circuit Court

8/2/2019 2012-03-30 - MS - TEPPER - Pro Hac Vice Motion and Verified Application-FILED-Circuit Court

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IN THE CIRCUIT COURT OF THE FIRST JUDICIAL DISTRICTOF IDNDS COUNTY, MISSISSIPPI

DR. ORL Y TAITZ, ESQ PLAINTIFF

VS. fi"tTDNO. 251-12-107 CIVM ~R3 0 1 0 \2 DEFENDANTS

U NN C IRCU li CL ERK6ARBARA 0 I D .C

< ; t V , , - - - - ~t..i_--

DEMOCRATIC PARTY OF MISSISSIPPI,SECRETARY OF STATE OF MISSISSIPPI

MOTION FOR ADMISSION OF COUNSEL PRO HAC VICECOMES NOW the Defendant, the Mississippi Democratic Party Executive Committee

("Defendant"), by and through its local counsel and, pursuant to Rule 46(a) of the MississippiRules of Appellate Procedure, hereby respectfully moves for the admission of Scott J. Tepper ascounsel pro hac vice for the purpose of participating in this action as co-counsel for the Defendant,and in support thereof states the following:1. As set forth in the Application exhibited hereto as Exhibit "1", Scott J. Tepper ("Tepper") is

engaged in the practice of law in the State of California, is in good standing to practice law asset forth in Exhibit "2" attached hereto, and has been admitted to practice law in the followingjurisdictions and courts:

2. California Supreme Court (and California)U.S. District Court, Central District of CaliforniaU.S. District Court, Northern District of CaliforniaU.S. District Court, Southern District of CaliforniaU.S. Ninth Circuit Court of AppealsU.S. Supreme CourtU.S. Federal Circuit Court of Appeals,

January 5, 1972January 24, 1972March 14,1972July 18, 1974November 2, 1972January 20, 1975November 27, 1992

3. Tepper is not a resident of the State of Mississippi and does not maintain an office in

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Mississippi but associated counsel's law firm, Begley Law Finn, PLLC, does maintain anoffice inMississippi that is staffed by full time attorneys who are licensed to practice law inMississippi;

4. Tepper has not been admitted pro hac vice in the State of Mississippi within the proceedingtwelve months;

5. Tepper has not been disciplined inany manner by any jurisdiction inwhich he has beenadmitted to practice law and has no pending disciplinary proceedings in any jurisdiction;

6. All applicable provisions of the Mississippi Rules of Civil Procedure, Mississippi Rules ofAppellate Procedure and the Uniform Rules of Circuit and County Court Practice have beenread by Tepper and this motion for pro hac vice complies with those rules; and,

7. For the purpose of this representation of the Defendant, Tepper will be associated with theundersigned counsel and the law firm of Begley Law Finn, PLLC as counsel for theDefendant.

8. Samuel L.Begley, Esq., of Begley Law Finn, PLLC certifies that he is a member ingoodstanding of the Mississippi Bar.WHERFORE, PREMISES CONSIDERED, the undersigned, on behalf of the Defendant, the

Mississippi Democratic Party Executive Committee, respectfully requests that this Court grant thismotion permitting Scott J.Tepper to appear inthe above styled matter, pro hac vice, as co-counselfor the Mississippi Democratic Party Executive Committee.

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'VRESPECTFULLY SUBMITTED, this th~ day of March, 2012.

THE MISSISSIPPI DEMOCRATIC PARTYEXECUTIVE COMMITTEE, DEFENDANT

/lBY:~~~Samuel L. Begley (MSB No. 2315)

Attorney for the Mississippi DemocraticParty Executive Committee

OF COUNSEL:BEGLEY LAW FIRM, PLLCP. O. Box 287Jackson, MS 39205(601)969-5545 (Telephone )(601)969-5547 (Facsimile)

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CERTIFICATE OF SERVICE

The undersigned hereby certifies that on the date set forth hereinafter, a true and correctcopy of the above and foregoing document was caused to be served via email and u.S. Mail orhand delivery on the following:

EMAIL AND U.S. MAIL:The Honorable RKenneth ColemanSpecial Circuit JudgeP.O. Box 1995New Albany, Mississippi 38652Harold E. Pizzetta, Esq.Justin L. Matheny, Esq.Office of the Attorney General550 High Street, Suite 1200P.O. Box 220Jackson, MS 39205Orly Taitz, Esq.29839 Santa Margarita Parkway, Suite 100Rancho Santa Margarita, CA 92688HAND DELIVERY:The Honorable Kathy Gillis450 High StreetP. O. Box 117Jackson, Mississippi 39205Ashley Sasser, Membership RecordsThe Mississippi Bar643 North State StreetJackson, MS 39202'--This the ~ day of March, 2012.

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IN THE CIRCUIT COURT OF THE FIRST JUDICIAL DISTRICTOF HINDS COUNTY, MISSISSIPPI

DR. ORLY TAITZ, ESQ PLAINTIFF

VS. CIVIL ACTION NO. 251-12-107 CIV

DEMOCRATIC PARTY OF MISSISSIPPI,SECRETARY OF STATE OF MISSISSIPPI

DEFENDANTS

VERIFIED APPLICATION OF SCOTT J. TEPPERSTATE OF MISSISSIPPICOUNTY OF HINDS

PERSONALLY APPEARED BEFORE ME, the undersigned authority in and for theaforesaidjurisdiction, the within named Scott J. Tepper, who after being duly sworn, states underoath as follows:

1. I desire to appear as co-counsel for the Mississippi Democratic Party ExecutiveCommittee, pro hac vice, before the Circuit Court of the First Judicial District of HindsCounty, Mississippi, in the above-styled case.

2. a. My full name is Scott J. Tepperb. My residential address is:

(Applicant's California residential address and phone number will be provided tothe Court, in camera, if so ordered.)

c. My office address is:Garfield &Tepper1801 Century Park East, Suite 2400Los Angeles, CA 90067-2326Tel: 310-277-1981

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Fax: 310-277-1980Email: [email protected]

3. I have been admitted to practice law in the following jurisdictions, as of the dates set forth:

Title of Court Date of AdmissionCalifornia Supreme Court (and California)U.S. District Court, Central District of CaliforniaU.S. District Court, Northern District of CaliforniaU.S. District Court, Southern District of CaliforniaU.S. Ninth Circuit Court of AppealsU.S. Supreme CourtU.S. Federal Circuit Court of Appeals,

January 5, 1972January 24, 1972March 14, 1972July 18, 1974November 2, 1972January 20, 1975November 27, 1992

4. I do not maintain an office within the State of Mississippi, but the law firm of associatedcounsel, Begley Law Firm, PLLC, maintains an office at 854 N. Jefferson Street, JacksonMississippi,39202.

5. I have not engaged in the general practice of law in the State of Mississippi without beingproperly admitted and licensed to practice law in the State of Mississippi.

6. I am currently licensed in good standing to practice law in each jurisdiction in which I havepreviously been admitted.

7. I have never been suspended or disbarred in any jurisdiction in which I have been admitted.8. I have not been the subject of any disciplinary action by the bar or courts of any

jurisdiction.9. I am of good moral character and I am familiar with the ethics, principles, practices,

customs and usages of the legal profession in the State of Mississippi.10. During the immediately preceding twelve (12) months, I have not appeared, am not

presently appearing or do not have a request pending for admission to appear as counselpro hac vice within this state.

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mailto:[email protected]:[email protected]


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11. Unless I am permitted to withdraw by order of the Circuit Court of Hinds County,Mississippi, I will continue to represent the Mississippi Democratic Party ExecutiveCommittee, in the cause until the final determination of the cause, and with reference to allmatters incident to such cause, I consent to the jurisdiction of the courts of the State ofMississippi, of the disciplinary tribunals of The Mississippi Bar, and of the MississippiBoard of Bar Admissions in all respects as ifI were a regularly admitted and licensedmember of the Mississippi Bar.

12. I have not been found, in an appropriate disciplinary proceeding, to have advertisedservices in violation of Rule 7.2 of the Mississippi Rules of Professional Conduct, nor am Iemployed by or am a member of a firm which has been so found.

13. I hereby certify that simultaneously herewith:a. I will cause a copy of this Verified Application to be served on the Clerk of the

Supreme Court of Mississippi, and upon all counsel of record in this cause.b. I will cause the required fee to be forwarded to the Clerk of the Supreme Court of

Mississippi.c. I will cause the required payment to be forwarded to The Mississippi Bar.

14. The following is the name and office address of the member in good standing of TheMississippi Bar with whom I am associated in this cause:

Samuel L. Begley (MSB No. 2315)Begley Law Firm, PLLCP.O. Box 287Jackson, Mississippi 39205Telephone: 601-969-5545Facsimile: 601-969-5547

I declare under penalty of perjury that the foregoing is true and correct.3


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SWORN AND SUBSCffiED BEFORE ME, this the _29th_ day of March, 2012.

NOTARY PUBLIC

My Commission Expires: _ " - M , , ,k = v , , = k . _ , _ I _ , _ 1 ) . - '2 .0 "" " " - ' (=(. , .=---_

State of Califomla } saCounty of Los~MlfS u b sc rib e d a n d sworn to (er ... 1 R t M I ) bebe_ Oft . .. .2qm day of t1e" ' ,d. :z..Ot:L. bf

DATE MON lH ft:ARj&ott ;r: ' U r . e e fYName of Signer~

proved to m e o n the basis of satis factory evtdenceto be the person~ w hO appeared before m e.Signature La:m ~ ~Signature of N o ta ry P u bli c

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STATE OF MISSISSIPPICOUNTY OF HINDSPERSONALLY APPEARED BEFORE ME the undersigned authority in and for the

state and county aforesaid, the within named Samuel L. Begley who, being first by me duly sworn,states on aid that he agrees to have Scott J. Tepper, Esq. associated with him in the above styledcase as local counsel and that the matters and facts set forth in the foregoing Application andMotion are true and correct as therein stated.

-SWORN AND SUBSCIBED BEFORE ME, this the3 0 day of March, 2012 ..

My Commission EXPi~.{jIA O~,: J - u 1 6

NOTARY PUBLICB A R B A R A D U N N . C IR C U IT C L E R K

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CERTIFICATE OF SERVICE

The undersigned hereby certifies that on the date set forth hereinafter, a true and correctcopy of the above and foregoing document was caused to be served via email and U.S. Mail orhand delivery on the following:

EMAIL AND U.S. MAIL:The Honorable R. Kenneth ColemanSpecial Circuit JudgeP.O. Box 1995New Albany, Mississippi 38652Harold E. Pizzetta, Esq.Justin L. Matheny, Esq.Office of the Attorney General550 High Street, Suite 1200P.O. Box 220Jackson, MS 39205Orly Taitz, Esq.29839 Santa Margarita Parkway, Suite 100Rancho Santa Margarita, CA 92688HAND DELIVERY:The Honorable Kathy Gillis450 High StreetP. O.Box 117Jackson, Mississippi 39205Ashley Sasser, Membership RecordsThe Mississippi Bar643 North State StreetJackson, MS 39202This the~ d ~y of March, 2012.

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THE STATE BAROF CALIFORNIA MEMBERSER~CESCENTER

180 HOWARD STREET, SAN FRANCISCO, CALIFORNIA 94105-1617 TELEPHONE: 888-800-3400

CERTIFICATE OF STANDING

January 23,2012

TO WHOM IT MAY CONCERN:

This is to certify that according to the records of the State Bar, SCOTT JAREDTEPPER, #051693 was admitted to the practice of law in this state by theSupreme Court of California on January 5, 1972; and has been since that date, andis at date hereof, an ACTIVE member of the State Bar of California; that saidpublic record states that information has been provided pursuant to Business andProfessions Code section 6086.1 (c); and that no recommendation for disciplinefor professional or other misconduct has ever been made by the Board of Trusteesor a Disciplinary Board to the Supreme Court of the State of California.

THE STATE BAR OF CALIFORNIA

Louise TurnerCustodian of Membership Records

2012-03-30 - MS - TEPPER - Pro Hac Vice Motion and Verified Application-FILED-Circuit Court

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