FILED: NEW YORK COUNTY CLERK 04/15/2014 INDEX NO. 653695/2013 NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 04/15/2014 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ROYAL PARK INVESTMENTS SA/NV, Plaintiff, vs. MORGAN STANLEY, et al., Defendants. X X Index No. 653695/2013 AFFIRMATION OF SAMUEL H. RUDMAN IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE OF SCOTT H. SAHAM 930924_1
Samuel H. Rudman declares, pursuant to 520.11 of the Rules of the Court of Appeals and 602.2(a) of the Rules of the Appellate Division, First Department, as follows: I am a member in good standing of the bar of this Court and a partner at the law firm Robbins Geller Rudman & Dowd LLP ("Robbins Geller"), located at 58 South Service Road, Suite 200, Melville, New York 11747. I have never been disciplined, and there are no pending disciplinary proceedings against me. The affirmation is submitted in support of the Motion for Admission Pro Hac Viae of Scott H. Saham to act as counsel for plaintiff for purposes of participating and appearing in the above-captioned action. 3. 4. Scott H. Saham is fully familiar with this action. Mr. Saham is a partner at Robbins Geller's San Diego office, located at 655 West Broadway, Suite 1900, San Diego, California 92101. Mr. Saham received his law degree from the University of Michigan Law School. He was admitted to the California Bar in 1997. Mr. Saham remains in good standing as a member of the California Bar. His Certificate of Good Standing in the State of California is attached hereto as Exhibit A. I respectfully request that plaintiff's motion be granted in all respects. A proposed order is attached hereto as Exhibit B. I declare under penalty of perjury, that the foregoing is true and correct. DATED: April 15, 2014 ROBBINS GELLER RUDMAN & DOWD LLP SAMUEL H. RUDMAN DAVID A. ROSENFELD s/ SAMUEL H. RUDMAN SAMUEL H. RUDMAN 930924_1
58 South Service Road, Suite 200 Melville, NY 11747 Telephone: 631/367-7100 631/367-1173 (fax) ROBBINS GELLER RUDMAN & DOWD LLP ARTHUR C. LEAHY PATRICK W. DANIELS THOMAS E. EGLER JONAH H. GOLDSTEIN SCOTT H. SAHAM SUSAN G. TAYLOR RYAN A. LLORENS LUCAS F. OLTS NATHAN R. LINDELL IVY T. NGO L. DANA MARTINDALE DAVID J. HARRIS, JR. DARRYL J. ALVARADO ASHLEY M. ROBINSON ANGEL P. LAU CAROLINE M. ROBERT HILLARY B. STAKEM 655 West Broadway, Suite 1900 San Diego, CA 92101-3301 Telephone: 619/231-1058 619/231-7423 (fax) Attorneys for Plaintiff 930924_1
CERTIFICATE OF SERVICE I hereby certify that on April 15, 2014, I authorized the electronic filing of the foregoing with the Clerk of the Court using the NYSCEF system which will send notification of such filing to the registered participants. I certify under penalty of perjury under the laws of the State of New York that the foregoing is true and correct. Executed April 15, 2014. s/ SAMUEL H. RUDMAN SAMUEL H. RUDMAN ROBBINS GELLER RUDMAN & DOWD LLP 58 South Service Road, Suite 200 Melville, NY 11747 Telephone: 631/367-7100 631/367-1173 (fax) srudman@rgrdlaw.com 930924_1
EXHIBIT A
gs AM - (m ^upxhnue Court of Olalifnrttia 1 s FRANK A. McGUIRE Conn Xdministrator anil Clerk of the Supreme Court CERTIFICATE OF THE CLERK OF THE SUPREME COURT OF THE STATE OF CALIFORNIA SCOTT H. SAHAM I, FRANK A. McGUIRE, Clerk of the Supreme Court of the State of California, do hereby certify that SCOTT H. SAHAM, U J88355, ira.v on the 5 th day of June, 1997, duly admitted to practice as an attorney and counselor at law in all the courts of this state, and is now listed on the Roll of Attorneys as a member of the bar of this state in good standing. Witness my hand and the seal of the court on the 9th day of April, 2014. FRANK A. McGUIRE Clerk of the Supreme Court By; A. Allen, Senior Deputy Clerk
EXHIBIT B
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK ROYAL PARK INVESTMENTS SA/NV, Plaintiff, vs. MORGAN STANLEY, et al., Defendants. X X Index No. 653695/2013 [PROPOSED] ORDER GRANTING SCOTT H. SAHAM ADMISSION PRO HAC VICE 931770_1
Scott H. Saham, having applied to this Court for admission pro hac vice to represent plaintiff in this action, and said application having been submitted in support thereof, an affirmation of Samuel H. Rudman, a member of the Bar of the State of New York and attorney of record herein for plaintiff, an affidavit of the applicant dated April 14, 2014, and a Certificate of Good Standing from the jurisdiction in which the applicant was admitted to the practice of law, and the Court having reviewed the foregoing submissions and due deliberation having been had, it is now therefore: ORDERED and the motion is GRANTED on consent and Scott H. Saham is permitted to appear and participate in this action on behalf of plaintiff; and it is further ORDERED that he 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; and it is further ORDERED that pursuant to 520.11 of the Rules for the Court of Appeals and 602.2 of the Rules of the Appellate Division, First Department, the attorney 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 Court governing the conduct of attorneys and the Disciplinary Rules of the Code of Professional Responsibility; and it is further ORDERED that he shall be subject to the jurisdiction of the Court of the State of New York with respect to any acts occurring during the course of his participation with this matter; and it is further 931770_1
ORDERED that said counsel shall notify the Court immediately of any matter in this or any other jurisdiction which affects his standing as a member of the Bar. IT IS SO ORDERED. DATED:., 2014 HONORABLE CHARLES E. RAMOS JUDGE OF THE SUPREME COURT 931770_1