Page 1 Filing # 86084084 E-Filed 03/08/2019 10:52:27 AM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
EDGAR MONSERRATT, as Personal
Representative of THE ESTATE OF
EDGAR MONSERRATT MARTINEZ,
Deceased,
CASE NO,:; CACE-19-Plaintiff,
Vv.
TESLA, INC, a/k/a TESLA FLORIDA,
INC., HALSTON LOYD, JAMES B, RILEY,
individually, JAMES B. RILEY, as the
Personal Representative of THE ESTATE
OF BARRETT RILEY, Deceased, and JR
CORPORATE SERVICES GROUP, LLC,
a Florida limited liability company,
Defendants.
VERIFIED MOTION FOR ADMISSION TO APPEAR PRO HAC VICE
PURSUANT TO FLORIDA RULE OF JUDICIAL ADMINISTRATION 2.
I, Vincent Galvin, respectfully states as follows:
1. I reside in Campbell, California and am not a resident of the State of Florida.
2. I am an attorney with the law firm of Bowman & Brooke LLP, 1741 Technology
Drive, Suite 200, San Jose, CA 95110, Tel: 408-279-5393, Fax: 408-279-5845,
3, Tesla Florida, Inc. has retained me to provide legal representation in connection
with this matter now pending before this Court in the State of Florida.
4, I have been admitted to practice before the following courts
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 3/8/2019 10:52:26 AM.**#%*Page 2 Case No. CACE-19-Motion for Admission to Appear Pro Hac Vice
JURISDICTION ATTORNEY/BAR NUMBER
State Bar of California 104448 |
State Bar of Texas
Central District of California
Eastern District of California
Northern District of California
Southern District of California
U.S, Court of Federal Claims
U.S. Supreme Court
5. There have been no disciplinary, suspension, disbarment, or contempt proceedings
initiated against me in the preceding 5 years.
6. I, either by resignation, withdrawal, or otherwise, never have terminated or
attempted to terminate my office as an attorney in order to avoid administrative, disciplinary,
disbarment, or suspension proceedings.
7, Lam not an active member of The Florida Bar.
8, I am not now and have never been a member of The Florida Bar.
9, I am not a suspended member of The Florida Bar.
10. Tam nota disbarred member of The Florida Bar nor have I received a disciplinary
resignation from The Florida Bar.
11. [have not previously been disciplined or held in contempt by reason of misconduct
committed while engaged in representation pursuant to Florida Rule of Judicial Administration
2.510.
12. _ [have filed motions to appear as counsel in Florida state courts during the past five
(5) years in the following matters:Page 3 Case No, CACE-19-Motion for Admission to Appear Pro Hac Vice
Case Name: Court/Case Number: Date of Admission:
13, Local counsel of record in this matter is Robert J. Rudock, of the law firm Bowman
and Brooke LLP, who is an active member in good standing of the Florida Bar and has offices at
Two Alhambra Plaza, Suite 800, Coral Gables, Florida 33134, 305-995-5600, Fax: 305-995-6090,
14. [have read the applicable provisions of the Florida Rule of Judicial Administration
2,510 and Rule 1-3.10 of the Rules Regulating the Florida Bar and certify that this verified Motion
complies with those rules.
15. agree to comply with the provisions of the Florida Rules of Professional Conduct
and consent to the jurisdiction of the courts and the Bar of the State of Florida.
16. A true and correct copy of this Motion was sent via U.S, Mail to PHV Admissions,
The Florida Bar, 651 East Jefferson Street, Tallahassee, Florida 32399-2333, accompanied by
payment of the $250.00 filing fee made payable to The Florida Bar.
17, The original Motion was filed through the E-Filing Portal accompanied by payment
of the $100,00 filing fee.
WHEREFORE, I respectfully request permission to appear in this Court for this cause pnly.
/ wl ¢
Vincént Galvin, Esq. N
Bowman & Brooke LLP
1741 Technology Drive, Suite
San Jose, CA
Tel: 408-279-5393/Fax: 408-279-vincent.galvin@bowmanandbrooke.com
DATED this 21 day of February, 2019,Page 4 Case No. CACE-19-Motion for Admission to Appear Pro Hac Vice
STATE OF CALIFORNIA
: COUNTY OF SANTA CLARA
I, Vincent Galvin, do hereby swear or affirm under penalty of perjury that I am the Movant
in the above-styled matter that I have read the foregoing Motion and-know the contents thereof,
and the contents are true of my own knowledge and belief. ,
YEE
Vincent Galvin /
The foregoing instrument was acknowledged before me this _ day of , 2019, by
, who is personally known to me or who has_ produced
as identification and who did take an oath.
Notary Public
Printed or Typed Name
Commission Number:
My commission expires:Page 5 A notary public or other officer completing this
certificate verifies only the Identity of the individual
who signed the document to which this certificate
is attached, and not the truthfulness, accuracy, or
validity of that document.
State of California
County of \) 27723 Clarg
Subscribed and sworn to (or affirmed) b fore me on this 2 27g”
day of f-eiaru Gor , 20 [apy Vine emt Gali
~~
proved to me on the basis of satisfactory evidence to be the
ee who appeared before me.
3 iy tou. ae mine scm i
Js A Nabe be
Signature_.Page 6 Case No. CACE-19-Motion for Admission to Appear Pro Hac Vice
I hereby consent to be associated as local counsel of record in this cause pursuant to Florida
Rule of Judicial Administration 2.510.
Robert J, Rudock
Florida Bar No.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on March 8, 2019, a true and correct copy of the
foregoing document was filed with the Clerk of Court using the Florida Courts e-Filing Portal
which will send an automatic e-mail message to all parties who have registered with the e-Filing
Portal.
/s/Robert J. Rudock
ROBERT J. RUDOCK.
Florida Bar No. BOWMAN AND BROOKE LLP
Two Alhambra Plaza, Suite
Coral Gables, Florida 33 134-
Tel: (305) 995-5600/Fax: (305) 995-Bub.Rudock@bowmanandbrooke.com
Attorneys for Tesla Inc., a/k/a Tesla Florida, Ine.
and Halston Lloyd
PDF Page 1
PlainSite Cover Page
PDF Page 2
Filing # 86084084 E-Filed 03/08/2019 10:52:27 AM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
EDGAR MONSERRATT, as Personal
Representative of THE ESTATE OF
EDGAR MONSERRATT MARTINEZ,
Deceased,
CASE NO,:; CACE-19-000422
Plaintiff,
Vv.
TESLA, INC, a/k/a TESLA FLORIDA,
INC., HALSTON LOYD, JAMES B, RILEY,
individually, JAMES B. RILEY, as the
Personal Representative of THE ESTATE
OF BARRETT RILEY, Deceased, and JR
CORPORATE SERVICES GROUP, LLC,
a Florida limited liability company,
Defendants.
VERIFIED MOTION FOR ADMISSION TO APPEAR PRO HAC VICE
PURSUANT TO FLORIDA RULE OF JUDICIAL ADMINISTRATION 2.510
I, Vincent Galvin, respectfully states as follows:
1. I reside in Campbell, California and am not a resident of the State of Florida.
2. I am an attorney with the law firm of Bowman & Brooke LLP, 1741 Technology
Drive, Suite 200, San Jose, CA 95110, Tel: 408-279-5393, Fax: 408-279-5845,
3, Tesla Florida, Inc. has retained me to provide legal representation in connection
with this matter now pending before this Court in the State of Florida.
4, I have been admitted to practice before the following courts
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 3/8/2019 10:52:26 AM.**#%*
PDF Page 3
Case No. CACE-19-000422
Motion for Admission to Appear Pro Hac Vice
JURISDICTION ATTORNEY/BAR NUMBER
State Bar of California 104448 |
State Bar of Texas 24049347
Central District of California
Eastern District of California
Northern District of California
Southern District of California
U.S, Court of Federal Claims
U.S. Supreme Court
5. There have been no disciplinary, suspension, disbarment, or contempt proceedings
initiated against me in the preceding 5 years.
6. I, either by resignation, withdrawal, or otherwise, never have terminated or
attempted to terminate my office as an attorney in order to avoid administrative, disciplinary,
disbarment, or suspension proceedings.
7, Lam not an active member of The Florida Bar.
8, I am not now and have never been a member of The Florida Bar.
9, I am not a suspended member of The Florida Bar.
10. Tam nota disbarred member of The Florida Bar nor have I received a disciplinary
resignation from The Florida Bar.
11. [have not previously been disciplined or held in contempt by reason of misconduct
committed while engaged in representation pursuant to Florida Rule of Judicial Administration
2.510.
12. _ [have filed motions to appear as counsel in Florida state courts during the past five
(5) years in the following matters:
PDF Page 4
Case No, CACE-19-000422
Motion for Admission to Appear Pro Hac Vice
Case Name: Court/Case Number: Date of Admission:
13, Local counsel of record in this matter is Robert J. Rudock, of the law firm Bowman
and Brooke LLP, who is an active member in good standing of the Florida Bar and has offices at
Two Alhambra Plaza, Suite 800, Coral Gables, Florida 33134, 305-995-5600, Fax: 305-995-6090,
14. [have read the applicable provisions of the Florida Rule of Judicial Administration
2,510 and Rule 1-3.10 of the Rules Regulating the Florida Bar and certify that this verified Motion
complies with those rules.
15. agree to comply with the provisions of the Florida Rules of Professional Conduct
and consent to the jurisdiction of the courts and the Bar of the State of Florida.
16. A true and correct copy of this Motion was sent via U.S, Mail to PHV Admissions,
The Florida Bar, 651 East Jefferson Street, Tallahassee, Florida 32399-2333, accompanied by
payment of the $250.00 filing fee made payable to The Florida Bar.
17, The original Motion was filed through the E-Filing Portal accompanied by payment
of the $100,00 filing fee.
WHEREFORE, I respectfully request permission to appear in this Court for this cause pnly.
/ wl ¢
Vincént Galvin, Esq. N
Bowman & Brooke LLP
1741 Technology Drive, Suite 200
San Jose, CA 95110
Tel: 408-279-5393/Fax: 408-279-5845
vincent.galvin@bowmanandbrooke.com
DATED this 21 day of February, 2019,
PDF Page 5
Case No. CACE-19-000422
Motion for Admission to Appear Pro Hac Vice
STATE OF CALIFORNIA
: 88
COUNTY OF SANTA CLARA
I, Vincent Galvin, do hereby swear or affirm under penalty of perjury that I am the Movant
in the above-styled matter that I have read the foregoing Motion and-know the contents thereof,
and the contents are true of my own knowledge and belief. ,
YEE
Vincent Galvin /
The foregoing instrument was acknowledged before me this _ day of , 2019, by
, who is personally known to me or who has_ produced
as identification and who did take an oath.
Notary Public
Printed or Typed Name
Commission Number:
My commission expires:
PDF Page 6
A notary public or other officer completing this
certificate verifies only the Identity of the individual
who signed the document to which this certificate
is attached, and not the truthfulness, accuracy, or
validity of that document.
State of California
County of \) 27723 Clarg
Subscribed and sworn to (or affirmed) b fore me on this 2 27g”
day of f-eiaru Gor , 20 [apy Vine emt Gali
~~
proved to me on the basis of satisfactory evidence to be the
ee who appeared before me.
2
3 iy tou. ae mine scm i
Js A Nabe be
Signature_.
PDF Page 7
Case No. CACE-19-000422
Motion for Admission to Appear Pro Hac Vice
I hereby consent to be associated as local counsel of record in this cause pursuant to Florida
Rule of Judicial Administration 2.510.
Robert J, Rudock
Florida Bar No. 365157
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on March 8, 2019, a true and correct copy of the
foregoing document was filed with the Clerk of Court using the Florida Courts e-Filing Portal
which will send an automatic e-mail message to all parties who have registered with the e-Filing
Portal.
/s/Robert J. Rudock
ROBERT J. RUDOCK.
Florida Bar No. 365157
BOWMAN AND BROOKE LLP
Two Alhambra Plaza, Suite 800
Coral Gables, Florida 33 134-5214
Tel: (305) 995-5600/Fax: (305) 995-6100
Bub.Rudock@bowmanandbrooke.com
Attorneys for Tesla Inc., a/k/a Tesla Florida, Ine.
and Halston Lloyd