Filing # 12625932 Electronically Filed 04/17/2014 12:17:54 PM RECEIVED, 4/17/2014 12:18:35, John A. Tomasino, Clerk, Supreme Court IN THE SUPREME COURT OF FLORIDA ALACHUA COUNTY, et al., ai., Petitioners, V. v. EXPEDIA,INC.etal, INC. ai, Case No.: SC13-838 DCACaseNo.: Case 1D12-2421 ID12-2421 LT Case No.: 2009-CA-4319 Respondents. ----------------------~/ VERIFIED MOTION OF GARY CRUCIANI FOR ADMISSION TO VERIFIED MOTION OF GARY CRUCIANI FOR ADMISSION TO APPEAR PRO HAC VICE PURSUANT TO FLORIDA RULE OF JUDICIAL ADMINISTRATION 2.510 Comes now GARY CRUCIANI, Movant herein, and respectfully represents the following: 1. Movant resides in Southlake, Texas. Movant is not a resident ofthe State of Florida. State offlorida. 2. Movant is an attorney and a member ofthe law firm ofmckool Smith PC, with offices at 300 Crescent Court, Suite 1500, Dallas, Texas 75201, (214) 978-4000. 978-4000. 3. Movant has been retained as a member of the above-named law firm 3. Movant has been retained as a member ofthe above-named law firm on September 1, 2008, by Broward County, Florida, and on August 31, 2009, by McKool 984300v 1 McKooI 984300V1 1
Osceola County, Florida, to provide legal representation in connection with the certified question that is now pending before the above-named court ofthe State of Florida. 4. Movant is an active member in good standing and currently eligible to practice law in the followingjurisdiction(s): JURISDICTION ATTORNEYIBAR NUMBER State Bar oftexas 05177300 U.S. District Court, NDTX U.S. District Court, SDTX U.S. District Court, EDTX U.S. District Court, WDTX U.S. Court ofappeals, 5 th Circuit U.S. Court of Appeals, 10 th Circuit 5. There are no disciplinary proceedings pending against Movant. 6. Within the past five (5) years, Movant has not been subject to any disciplinary proceedings. 7. Movant has never been subject to any suspension proceedings. 8. Movant has never been subject to any disbarment proceedings. 9. Movant, either by resignation, withdrawal, or otherwise, never has terminated or attempted to terminate Movant's office as an attorney in order to avoid administrative, disciplinary, disbarment, or suspension proceedings. 10. Movant is not an inactive member ofthe Florida Bar. 11. Movant is not now a member ofthe Florida Bar. McKool 984300v I 2
12. Movant is not a suspended member ofthe Florida Bar. 13. Movant is not a disbarred member ofthe Florida Bar nor has Movant received a disciplinary resignation from The Florida Bar. 14. Movant has not previously been disciplined or held in contempt by reason of misconduct committed while engaged in representation pursuant to Florida Rule ofjudicial Administration 2.510. 15. Movant has filed motion( s) to appear as counsel in Florida state courts during the past five (5) years in the following matters: Date of Motion Case Name Case Number Court Date Motion GrantedlDenied 04/23/2009 Orbitz, LLC, et al. v. Broward 372009 CA 000126 Circuit Court for the 2 nd Granted 04/24/2009 County, Florida, et ale Judicial Circuit, Leon County 03/14/2013 Broward County, FL, et ale v. Orbitz, LLC, et al. ID13-543 District Court ofappeal, First District, State of Florida Granted 03/26/2013 16. Local counsel ofrecord associated with Movant in this matter is Jon c. Moyle, Florida Bar No. 727016, who is an active member in good standing of The Florida Bar and has offices at 118 North Gadsden Street, Tallahassee, FL 32301, (850) 681-3828. McKool 984300v I 3
17. Movant has read the applicable provisions offlorida Rule of Judicial Administration 2.510 and Rule 1-3.10 of the Rules Regulating The Florida Bar and certifies that this verified motion complies with those rules. 18. Movant agrees to comply with the provisions ofthe Florida Rules of Professional Conduct and consents to the jurisdiction of the courts and the Bar of the State offlorida. WHEREFORE, Movant respectfully requests pennission to appear in this court for this cause only. DATED this 17th day of Apr~l, 2014. GaryC McKO S HPC 300 Crescent Court, Suite 1500 Dallas, TX 75201 (214) 978-4000 gcruciani@mckoolsmith.com McKocl 984300v I 4
STATE OF TEXAS ) ) ss. COUNTY OF DALLAS ) On April 17, 2014, before me, personally appeared Gary Cruciani, who proved to me on the basis of satisfactory evidence to be the person whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument the person, or the entity upon behalf of which the person acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of Texas that the foregoing paragraph is true and correct. WITNESS my hand and official seal. t). CYNTHIA 'JI.:. SIVINSKI ' Notary Public, State of Texa (SEAL "1/l(',, My Commission Expires ' ' JULY 14 2015 Signature ofnotary Public McKool 984300v I 5
J hereby consent to be associated as local counsel of reco rd in th is case pursuant to Florida Rul e of Judicial Ad l11ini stration 2.5 10. Dated thi s l ih day of Apri l, 20 14. aw Finn I 18 N. Gadsden Street Tallahassee, Florida 3230 I (850) 681-3828 7016)
CERTIFICATE OF SERVICE [ hereby certify that on April 17,2014, a true and correct copy of the foregoing was furnished by overnight Inail to PHV Adlllissions, The Florida Bar, 651 East Jefferson Street, Tallahassee, 32399-2333 accolllpanied by paylnent of $250.00 for filing fee Inade payable to The Florida Bar and by electronic 1l1ail to: Robert L. Nabors rnabors@ngnlaw.colll Harry F. Chiles hchiles@ngnlaw.coln legal-adil1in@ngnlaw.colll NABORS GIBLIN & NICI(ERSON, P.A. 1500 Mahan Drive, Suite 200 Tallahassee, Florida 32308 Ed\vard A. Dion edion@ngnlaw.coil1 NABORS GIBLIN & NICI(ERSON, P.A. 208 S.E. Sixth Street Ft. Lauderdale, Florida 33301 Roberto Marti nez bob@colson.coln Maureen E. Lefebvre Maureen@colson.coI11 Stephanie A. Casey scasev@colson.colll aurora@colson.co111 COLSON HICKS EIDSON 255 Aragon Avenue, 2 nd Floor Coral Gables, Florida 33134 Mark I-IolcOIllb 111holcoI11b@lngh-law.cOITI MADSEN GOLDMAN & I-IOLCOMB, LLP 1705 Metropolitan Blvd., Suite 101 Tallahassee, Florida 32308 Andrew J. Meyers arneyers@broward.org Joni AnTIstrong Coffey icoffey@broward.org BROWARD COUNTY ATTORNEY GovernlTIental Center, Suite 423 115 South Andre\vs Avenue Ft. Lauderdale, FL 33301 Andre\v W. Mai andrc\v.rnai@osceola.org OFFICE OF TI-IE OSCEOLA COUNTY ATTORNEY 1 Cou11house Square, Suite 4700 Kissinl1nee, FL 34741
Cynthia S. Tunnicliff cynthia@penningtonlaw.con1 PENNINGTON, P.A. 215 South Monroe Street, Second Floor P.O. Box 10095 Tallahassee, FL 32301 pete@penningtonlaw.coln Major B. Harding mharding@allsley.com Ruth E. Vafek rvafek@ausley.coln Steven M. Hogan shogan@ausley.com AUSLEY & McMULLEN, P.A. 123 South Calhoun Street Tallahassee, FL 32301 Susan L. Kelsey susanappeals@elnbargn1aii.coln I(elsey Appellate Law Finn, P.A. P.O. Box 15786 Tallahassee, FL 32317 Peter M. Dunbar PDunbar@deanlnead.coln Ashley E. Gault AGault@deanlnead.com DEAN MEAD 215 South Monroe Street, Suite 815 Tallahassee, FL 32301 Virginia Saunders Delegal gdel egal@fl-counties.com General Counsel FLORIDA ASSOCIATION OF COUNTIES, INC. 100 South Monroe Street Tallahassee, FL 32301 Stephen H. Grimes Stephen.grimes@hklaw.com James M. Ervin Jitn.ervin@hklaw.com Holland & Knight LLP P.O. Drawer 810 Tallahassee, Florida 32302 Larry Sn1ith laslnith@volusia.org Mary G. Jolley Iniolley@voillsia.org COUNTY OF VOLUSIA 123 West Indiana Avenue DeLand, FL 32720