United States District Court, D. Nevada
T. Blake, Esq. (#11059) Counsel for Plaintiff Paul
Ponomarenko and Third-Party Defendant Summit Estate, Inc
Shaddix Counsel for Defendant Nathan Shapiro 6166 S. Sandhill
Road, Suite 146 David T. Blake, Esq. Counsel for Summit
Estate Inc.1671 W. Horizon Ridge Parkway, Suite 200 Sanjiv N.
Singh, Esq. Sanjiv N. Singh, a PLC 1650 S. Amphlett Blvd.
Suite 220 Michael Indrajana, Esq. Indrajana Law Group, a PLC
1650 S. Amphlett Blvd. Suite 220 Paul Ponomarenko 1650 S.
Amphlett Blvd. Suite 220
Gentile An Employee of Clear Counsel Law Group
N. Singh, Esq. Sanjiv N. Singh Professional Law Corporation
Michael B. Indrajana, Esq. Indrajana Law Group, A
Professional Law Corp.
Ponomarenko Owner, Summit Estate Inc.
MOTION TO PERMIT WITHDRAWAL OF CALIFORNIA COUNSEL
SANJIV N. SINGH AND MICHAEL INDRAJANA AND TO PERMIT
SUBSTITUTION OF NEW COUNSEL FOR SUMMIT ESTATE, INC. AND PAUL
HOFFMAN JR. UNITED STATES MAGISTRATE JUDGE
COURT AND ALL PARTIES AND THEIR COUNSEL OF RECORD:
TAKE NOTICE that Plaintiff Paul Ponomarenko and Third-Party
Defendant Summit Estate, Inc. hereby move the Court for an
order permitting withdrawal of California counsel Sanjiv Nand
Singh and Michael Budi Indrajana as counsel of record and
permitting the filing of a substitution of counsel whereby
David T. Blake, Esq. will assume representation for both Mr.
Ponomarenko and Summit Estate, Inc.
motion is made pursuant to Local Rule IA 11-6 and in response
to the Court's order (Dkt. No. 115) requiring that Summit
Estate Inc. locate counsel and have California Counsel Sanjiv
Singh and Michael Indrajana appear pro hac vice. Mr. Blake
will assume representation for both Summit Estate and Paul
Ponomarenko, thereby obviating the need to have local counsel
appear pro hac vice.
motion is based on this Notice of Motion and Motion; the
accompanying Memorandum of Points and Authorities, the
accompanying Declaration of Paul Ponomarenko, and such other
matters as may be presented to the Court at the time of the
hearing (if one is required); and such other and further
evidence and arguments as the Court may properly consider.
submitted, MEMORANDUM OF POINTS AND
to Local Rule IA 11-6, Plaintiff Paul Ponomarenko and
Third-Party Defendant Summit Estate Inc. are requesting
permission to substitute in Mr. David Blake as their Nevada
counsel in the above captioned matter. Local Rule IA 11-6;
see also Declaration of Paul Ponomarenko In Support
of Motion (Ponomarenko Declaration) at ¶ 2 attached
herein as Exhibit A. California counsel Sanjiv Singh
and Michael Budi Indrajana are not admitted in Nevada, and
while the Plaintiff was considering having them appear pro
hac vice initially, it is now apparent that pro hac vice
appearances and/or representation is not necessary as Nevada
counsel has been located who can take over representation for
all purposes. Id. Mr. Blake has already filed a
notice of appearance for Summit Estate, Inc. All that is
needed at this time is for the court to grant this motion and
authorize filing of a true and correct copy of the attached
substitution of counsel attached herein as