AFFIDAVIT OF DAVID A. SCHEFFEL IN SUPPORT OF MOTION FOR ADMISSIONS OF THOMAS P. SWIGERT AND ERIN E. CONTI PRO HAC VICE

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1 FILED: NEW YORK COUNTY CLERK 10/11/ :19 PM INDEX NO /2016 NYSCEF DOC. NO. 11 RECEIVED NYSCEF: 10/11/2016 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK x GUOJI ZHONG, ZHENCHI LIANG, SHU DONG, and SIDENG CHEN, Index No.: /2016 -v- Plaintiffs, Hon. Jeffrey K. Oing, J.S.C. Commercial I.A.S. Part 48 CHIN WAH VINCENT LOK, KWOK WING DANNY LOK, CHIV AN LUONG, Motion Sequence No. 002 RICH GENG SUN, MARK QIAN, L & L TRAVEL ENTERPRISES, INC., and EAST COAST HOLIDAYS, INC., Defendants x AFFIDAVIT OF DAVID A. SCHEFFEL IN SUPPORT OF MOTION FOR ADMISSIONS OF THOMAS P. SWIGERT AND ERIN E. CONTI PRO HAC VICE STATE OF NEW YORK ) ) ss. COUNTY OF NEW YORK ) David A. Scheffel, an attorney duly licensed to practice law in the State of New York, affirms under penalty of perjury and says: 1. I am a partner of the firm Dorsey & Whitney LLP, 51 West 52nd Street, New York, NY , attorney for Plaintiffs Guoji Zhong, Zhenchi Liang, Shu Dong, and Sideng Chen in the above-captioned matter. I am familiar with the proceedings in this case. I make this statement based on my personal knowledge of the facts set forth herein and in support of the application to admit Thomas P. Swigert and Erin E. Conti as counsel pro hac vice to represent Plaintiffs Guoji Zhong, Zhenchi Liang, Shu Dong, and Sideng Chen in this matter. 2. I am a member in good standing of the Bar of the State of New York. 1 of 7

2 3. Thomas P. Swigert is a member in good standing of the Bars of the States of Minnesota, Colorado, and Illinois (Certificates of Good Standing are annexed to his affidavit, which is being filed concurrently with this motion). I have known and worked with Mr. Swigert for approximately five (5) years. 4. Accompanying this affirmation is an affidavit of Mr. Swigert sworn to on October 10, 2016, stating that he is familiar with and agrees to be bound by the standards of professional conduct imposed upon members of the New York Bar and relevant statutes, rules, and procedures. 5. Erin E. Conti is a member in good standing of the Bar of the State of Minnesota (Certificate of Good Standing is annexed to her affidavit, which is being filed concurrently with this motion). 6. Accompanying this affirmation is an affidavit of Ms. Conti sworn to on October 10, 2016, stating that she is familiar with and agrees to be bound by the standards of professional conduct imposed upon members of the New York Bar and relevant statutes, rules, and procedures. 7. Attached to this Affidavit as Exhibit A is a proposed order admitting Thomas P. Swigert and Erin E. Conti as counsel pro hac vice. WHEREFORE, this affiant respectfully requests that this application to admit Thomas P. Swigert and Erin E. Conti as counsel pro hac vice to represent Plaintiffs Guoji Zhong, Zhenchi Liang, Shu Dong, and Sideng Chen in the above-captioned matter be granted and that the accompanying proposed order be signed and filed by the Court. [ Remainder of page left intentionally blank; signature page follows.] AFFIDAVIT OF DA YID A. SCHEFFEL IN SUPPORT OF MOTION FOR ADMISSIONS PRO HAC VICE Page 2 of 3 2 of 7

3 David A. s'&rri(ei Sub~c~ and sworn to before me this~ day of October, '~~ Notary Public DIANNA E. KLAU Notary Public, St?te ot New York No ouahfied in New York County. /-.:L. commission Expires Sept. 30, 20 L:.L TO: Allen Wong, Esq. Rairnond & Wong LLC 305 Broadway, 7th Floor New York, NY (646) Attorneys for Defendants AFFIDAVIT OF DA YID A. SCHEFFEL IN SUPPORT OF MOTION FOR ADMISSIONS PRO HAC VICE Page 3 of3 3 of 7

4 EXHIBIT A to AFFIDAVIT OF DAVID A. SCHEFFEL IN SUPPORT OF MOTION FOR ADMISSIONS OF THOMAS P. SWIGERT AND ERIN E. CONTI PRO HAC VICE Guoji Zhong et al. v. Chin Wah Vincent Lok et al. Index No /2016 Hon. Jeffrey K. Oing, J.S.C. Commercial I.A.S. Part 48 Motion Sequence No of 7

5 At IAS Part 48 of the Supreme Court of the State of New York, to be held in and for the County of New York, at the County Court House, on the day of, Present: HON. JEFFREY K. OING J.S.C. Justice SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK x GUOJI ZHONG, ZHENCHI LIANG, SHU DONG, and SIDENG CHEN, Index No.: / v - Plaintiffs, Hon. Jeffrey K. Oing, J.S.C. Commercial I.A.S. Part 48 CHIN WAH VINCENT LOK, KWOK WING DANNY LOK, CHI VAN LUONG, RICH GENG SUN, MARK QIAN, L & L TRAVEL ENTERPRISES, INC., and EAST COAST HOLIDAYS, INC., Motion Sequence No. 002 Defendants x (PROPOSED) ORDER ON MOTION FOR ADMISSIONS OF THOMAS P. SWIGERT AND ERIN E. CONTI PRO HAC VICE David A. Scheffel, having applied to this Court for admissions pro hac vice to represent Plaintiffs Guoji Zhong, Zhenchi Liang, Shu Dong, and Sideng Chen in this action and having submitted in support thereof: (a) his own Affidavit, sworn to October 11, 2016; (b) the Affidavit of Thomas P. Swigert, a member of the Bars of the States of Minnesota, Colorado, and Illinois 5 of 7

6 GUOJI ZHONG et al. v. CHIN WAH VINCENT LOK et al. Page 2 of 3 Index No /2016 Mtn. Seq. No. 002 (PROPOSED) ORDER ON MOTION FOR ADMISSIONS PRO HAC VICE and a member of the law firm of Dorsey & Whitney LLP, attorneys of record for Plaintiffs in this action, sworn to October 10, 2016, and annexed thereto valid Certificates of Good Standing from the States of Minnesota, Colorado, and Illinois; and (c) the Affidavit of Erin E. Conti, a member of the Bar of the State of Minnesota and a member of the law firm of Dorsey & Whitney LLP, attorneys of record for Plaintiffs in this action, sworn to October 10, 2016, and annexed thereto valid a Certificate of Good Standing from the State of Minnesota, and the Court having reviewed the foregoing submissions and due deliberation having been had thereon, it is now therefore ORDERED that the motion is granted and Thomas P. Swigert and Erin E. Conti are permitted to appear and practice in this action on behalf of Plaintiffs Guoji Zhong, Zhenchi Liang, Shu Dong, and Sideng Chen; and it is further ORDERED that Thomas P. Swigert and Erin E. Conti shall at all times be associated herein with counsel who is a member in good standing of the Bar of the State of New York and is attorney of record for the party in question and all pleadings, briefs, and other papers filed with the Court shall be signed by the attorney of record, who shall be held responsible for such papers and for the conduct of this action on behalf of Plaintiffs Guoji Zhong, Zhenchi Liang, Shu Dong, and Sideng Chen; and it is further ORDERED that pursuant to Section of the Rules of the Court of Appeals and Section of the Rules of the Appellate Division, First Department, the attorneys hereby admitted pro hac vice shall abide by the standards of professional conduct imposed upon members of the New York Bar, including the Rules of the Courts governing the conduct of attorneys and the Disciplinary Rules of the Code of Professional Responsibility; and it is further 6 of 7

7 GUOJI ZHONG et al. v. CHIN WAH VINCENT LOK et al. Page 3 of 3 Index No /2016 Mtn. Seq. No. 002 (PROPOSED) ORDER ON MOTION FOR ADMISSIONS PRO HAC VICE ORDERED that said counsel shall notify the Court immediately of any matter or event in this or any other jurisdiction which affects his or her standing as members of the Bar. ENTER: This day of, 2016 JEFFREY K. OING J.S.C. 7 of 7