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RICHARD T, BOWLES (#46234) | ED
DAVID A. GOLDSTEIN (#319394)
Bowles & Verna LLP
2121 N. California Bivd., Suite 875 M9 NOV 25 P 1:02
Walnut Creek, California 94596
Telephone: (925) 935-3300
Facsimile: (925) 935-0371
Email: rbowles@bowlesvema,com
Attorneys for Plaintifis
NEW U LIFE and ALEXY GOLDSTEIN
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF CONTRA C
NEW U LIFE and ALEXY GOLDSTEIN Case No. C19-00188
Plaintifis, NOTICE OF HEARING ON APPLICATIO!
OF D.J. POYFAIR TO APPEAR PRO HAC
v. VICE AS COUNSEL FOR PLAINTIFFS
NEW U LIFE AND ALEXY GOLDSTEIN
PATTI SINCLAIR and DOES 1 through 10, By - FV
Time: a
Defendants, Dept.: 33
TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE THAT on +20__at___or as soon thereafter as
the matter may be heard, in Department 33 of the above-entitled court, located at 725 Court Street,
Martinez, California, Plaintiffs New U Life and Alexy Goldstein will and hereby do request that the
Court enter an order pursuant to California Rules of Court, Rule 9.40 permitting D.J. Poyfair to appear
as counsel pro hac vice in the above-captioned matter.
me
'E OF HEARING ON APPLICATION OF DJ. POYFAIR TO APPEAR PRO HAC VICE AS
COUNSEL FOR PLAINTIFFS NEW U LIFE AND ALEXY GOLDSTEIN10
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This application is based on this Notice and the Application of D.J. Poyfair, as well as on all
papers, pleadings, and records on file in this action,
Dated: November 15, 2019 Bowles & Verna LLP
char
David A. Goldstein
Attorneys for Plaintifi's
NEW U LIFE and ALEXY GOLDSTEIN
2
‘NOTICE OF HEARING ON APPLICATION OF DJ. POYFAIR TO APPEAR PRO HAC VICE AS
‘COUNSEL FOR PLAINTIFFS NEW U LIFE AND ALEXY GOLDSTEINeo a
Se
RICHARD T. BOWLES (#46234)
DAVID A, GOLDSTEIN (#319394)
Bowles & Verna LLP
2121 N. California Bivd., Suite 875
Walnut Creek, California 94596
‘Telephone: (925) 935-3300.
Facsimile: (925) 935-0371
Email: rbowles@bowlesverna.com
Attorneys for Plaintiffs
NEW U LIFE and ALEXY GOLDSTEIN
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF CONTRA COSTA
NEW U LIFE and ALEXY GOLDSTEIN | Case No. C19-00188
Plaintiffs, VERIFIED APPLICATION OF
POYFAIR TO APPEAR PRO HAC VICE AS.
v COUNSEL FOR PLAINTIFFS NEW U LIFE,
| AND ALEXY GOLDSTEIN.
PATTI SINCLAIR and DOES 1 through 10, a 4
inclusive, Date: | -7Y “74
Time: 9.50
Defendants. Dept. 33
VERIFIED APPLICATION
D.J. Poyfair (hereinafter “Poyfair”), a partner at Reese Poyfair Richards PLLC, applies for
admission to practice before this Court pro hac vice. in order to represent Plaintiffs New U Life and
Alexy Goldstein in this action, pursuant to Rule 9.40 of the California Rules of Court
1, Poyfair satisfies all requirements of Rule 9.40(a) with respect to a pro hac vice
appearance as he is not any of the following: a resident of the State of California; regularly employed
in the State of California; regularly engaged in substantial business, professional, or other activities in
the State of California.
2. Poyfair’s residential address is 8776 East Iliff Dr., Denver, CO 80231. His office
address is 1275 E. Fort Union Blvd. Suite 115, Cottonwood Heights, UT 84047.
3. Poyfair has been admitted to practice in the state courts of Colorado (October 30, 1984,
1
‘VERIFIED APPLICATION OF D1, POYFAIR TO APPEAR PRO HAC VICE AS COUNSEL FOR
PLAINTIFFS NEW U LIFE AND ALEXY GOLDSTEIN10
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registration #14266), as well as in the following federal courts: U.S. District Court, Utah (July 18,
1992); U.S. District Court, Nevada (January 8, 1993); U.S. District Court, Arizona (March 7, 1996):
United States Tax Court (April 30, 2001); U.S. District Court, Central District of Illinois (August 14
2000).
4, Poyfair is in good standing in all of those courts. He is not now, nor has he ever been,
suspended or disbarred in any court.
5. Poyfair last filed an application for appearance pro hae vice in a California court in the
USS. District Court, Southern District of California in the case Youngevity International Corp. v. Todd
Smith, et al., 16-CV0704W-JLB. That application was granted more than two years ago. on March 23,
2017.
6. The active licensees and attorneys of record for Plaintiffs in this action are Richard T
Bowles and David Goldstein of the law firm Bowles & Verna LLP. The address and phone number of
Bowles & Verna LLP are 2121 N. California Blvd., Suite 875, Walnut Creek, CA 94596 and (925)
935-3300, respectively
Dated: November 15, 2019 Bowles & Verna LLP.
yp LNs
Richard T. Bowles
David A. Goldstein
Attomeys for Plaintiffs
NEW U LIFE and ALEXY GOLDSTEIN
2
VERIFIED APPLICATION OF D.J. POYFAIR TO APPEAR PRO HAC VICE AS COUNSEL FOR
PLAINTIFFS NEW U LIFE AND ALEXY GOLDSTEINNovi22/2019 12:34:52 PM. Wells Fargo 3037570516 33
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VERIFICATION
1, DJ. Poyftir, declare:
Thave read the foregoing VERIFIED APPLICATION OF D.J. POYFAIR TO APPEAR
PRO HAC VICE AS COUNSEL FOR PLAINTIFFS NEW U LIFE AND ALEXY GOLDSTEIN
and know the contents thereof.
‘declare under penalty of perjury under the laws ofthe State of California that the foregoing is
‘rue and correct. ets Fargo Bank
20038, colato Bh,
Executed this_22_ day of November, 2019 at, 50 Beale ome
DIP
3
‘VERIFIED APPLICATION OF Di. POYFAIRTO APPEAR PRO HAC VICE AS COUNSEL FOR
PLAINTIFFS NEW U LIFE AND ALEXY GOLDSTEIN10
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RICHARD T. BOWLES (#46234)
DAVID A. GOLDSTEIN (#319394)
Bowles & Verna LLP
2121 N. California Blvd., Suite 875
Walnut Creek, California 94596
Telephone: (925) 935-3300
Facsimile: (925) 935-0371
Email: rhowles@bowlesverna.com
Attorneys for Plaintiffs
NEW U LIFE and ALEXY GOLDSTEIN
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF CONTRA COSTA
NEW U LIFE and ALEXY GOLDSTEIN | Case No. C19-00188
Plaintiffs, [PROPOSED] ORDER GRANTING D.1.
POYFAIR’S APPLICATION TO APPEAR
v. PRO HAC VICE AS COUNSEL FOR
PLAINTIFFS NEW U LIFE AND ALEXY
PATTI SINCLAIR and DOES | through 10, GOLDSTEIN
inclusive,
Date:
Defendants. Time:
Dept.: 33
D.J. Poyfair’s Application to Appear Pro Hac Vice as Counsel for Plaintifis New U Life and
Alexy Goldstein came on regularly for hearing in Department 33 of this Court on.
Having considered the papers submitted, argument of counsel, and good cause otherwise appearing
therefor, D.J. Poytait’s application is GRANTED.
Dated:
JUDGE OF TI ERIOR COURT
1 —
[PROPOSED] ORDER GRANTING D.J. POYFAIR'S APPLICATION TO APPEAR PRO HAC VICE AS
‘COUNSEL FOR PLAINTIFFS NEW U LIFE AND ALEXY GOLDSTEIN1] RICHARD T. BOWLES (#46234)
DAVID A. GOLDSTEIN (#319394)
2} Bowles & Verna LLP
2121 N. California Blvd., Suite 875
Walnut Creek, California 94596
hone: (925) 935-3300
4 || Facsimile: (925) 935-0371
Email: rbowles@bowlesverna.com
5
Attomeys for Plaintiffs
6 |] NEW U LIFE and ALEXY GOLDSTEIN
7
8 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF CONTRA COSTA
10
11 || NEW U LIFE and ALEXY GOLDSTEIN Case No. C19-00188
12 Plaintiffs, PROOF OF SERVICE
13 |v. Date: January 30, 2020
Time: 9:00 am
14 ]] PATTI SINCLAIR and DOES | through 10, Dept: 33
inclusive,
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Defendants.
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Swaine | _t Z a
Suis NOTICE OF HEARING ON APPLICATION OF Dl. POYFAIR TO APPEAR PRO IAC VICE AS
alt Ce 5496 COUNSEL FOR PLAINTIFFS NEW U LIFE AND ALEXY GOLDSTEIN10
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Poulet Vern 2
DIST N Caio
PROOF OF SERVICE
Contra Costa County Superior Court Case No. MSC19-00188
| am a citizen of the United tates of America, am over the age of eighteen (18) yeas, and not a party to the
within action, Lam an employee of Bowles & Vem, and my business address is2121 North California Blvd, Suite
875, Walnut Creek, California 94596,
‘On November 25, 2019, 1 caused to be served the following document(s):
NOTICE OF HEARING ON APPLICATION OF D.J. POYFAIR TO APPEAR PRO HAC
VICE AS COUNSEL FOR PLAITNIFFS NEW U LIFE AND ALEXY GOLDSTEIN;
APPLICATION; PROPOSED ORDER
on the parties involved addressed as follows:
Attorneys for Defendant PATTI SINCLAIR: Pro Hae Vice Program
sjane E, Bednar Office of Special Admissions
Law Office of Jane E, Bednar The State Bar of California
142 Laurel Drive 180 Howard Street
Carmel Valley, CA 93924 cae erat
Paine aaa) pou tanec ‘A 94105
‘Carmel Valley, CA 93924-0449 a “ees
Tel: 831-375-6381
Fax: 877-844-0031
X___ BY UNITED STATES MAIL: [enclosed the documents in a sealed envelope or package addressed to the
persons atthe addresses listed above. | placed the envelope for collection and mailing, following our
‘ordinary business practices. | am readily familiar with this business's practice for collecting and processing
correspondence for mailing. On the same day that correspondence is placed for collection and mailing, itis
deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with
postage fully prepaid.
BY OVERNIGHT DELIVERY: | enclosed the documents in an envelope or package provided by an
‘overnight delivery carrier and addressed to the persons at the addresses listed above. I placed the envelope or
package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight
delivery carver.
BY PERSONAL SERVICE: | personally delivered the documents to the persons at the addresses listed
above. Delivery was made to the attorney or at the attorney's office by leaving the documents in an envelope
‘or package clearly labeled to identify the attorney being served with a receptionist or an individual in charge
of the office.
X BY E-MAIL OR ELECTRONIC TRANSMISSION: Based on a court order or an agreement of the
parties to accept service by e-mail or electronic transmission, I caused the documents to be sent to the
persons atthe e-mail addresses listed above. I did not receive, within a reasonable time after the
transmission, any electronic message or other indication that the transmission was unsuccessful
| declare under penalty of perjury under the laws of the State of California thatthe foregoing is true and
correct.
Executed on November 25, 2019, at Walnut Creek, California
Dkite Dyn
Debbie Ayres
1
PROOF OF SERVICE