UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

Case No. 1:20-cv-21865-FAM

PALM SPRINGS MILE ASSOCIATES, 

LTD., a Florida limited partnership, and 

PHILIPS LAKE WORTH LLC, a Florida 

limited partnership, 

Plaintiffs, 

v. 

ROSS DRESS FOR LESS, INC., a 

Virginia corporation, and ROSS STORES, 

INC., a Delaware corporation,

Defendants. 

MOTION TO APPEAR PRO HAC VICE, 

CONSENT TO DESIGNATION, AND REQUEST TO 

ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING 

In accordance with Local Rule 4(b) of the Rules Governing the Admission, Practice, Peer 

Review, and Discipline of Attorneys of the United States District Court for the Southern District 

of Florida, the undersigned respectfully moves for the admission pro hac vice of Paul R. Genender 

(“Mr. Genender”) of the law firm of Weil, Gotshal & Manges LLP, 200 Crescent Court, 

Suite 300, Dallas, Texas 75201, Phone: 214-746-7700, for purposes of appearance as co-counsel 

on behalf of Defendants Ross Dress for Less, Inc., and Ross Stores, Inc. (collectively, 

“Defendants”) in the above-styled case only, and pursuant to Rule 2B of the CM/ECF 

Administrative Procedures, to permit Mr. Genender to receive electronic filings in this case, and 

in support thereof states as follows: 

Case 1:20-cv-21865-FAM Document 9 Entered on FLSD Docket 05/13/2020 Page 1 of 4
1. Mr. Genender is not admitted to practice in the Southern District of Florida and is 

a member in good standing of The Texas Bar and the United States District Court for the Northern 

District of Texas. 

2. Edward Soto, Esquire (“Movant”), of the law firm of Weil, Gotshal & Manges 

LLP, 1395 Brickell Avenue, Suite 1200, Miami, Florida 33131; Phone: 305-577-3100, is a 

member in good standing of The Florida Bar and the United States District Court for the Southern 

District of Florida and is authorized to file through the Court’s electronic filing system. Movant 

consents to be designated as a member of the Bar of this Court with whom the Court and opposing 

counsel may readily communicate regarding the conduct of the case, upon whom filings shall be 

served, who shall be required to electronically file and serve all documents and things that may be 

filed and served electronically, and who shall be responsible for filing and serving documents in 

compliance with the CM/ECF Administrative Procedures. See Section 2B of the CM/ECF 

Administrative Procedures. 

3. In accordance with the local rules of this Court, Mr. Genender has made payment of 

this Court’s $200.00 admission fee. A certification in accordance with Rule 4(b) is attached hereto. 

4. Mr. Genender, by and through designated counsel and pursuant to Section 2B 

CM/ECF Administrative Procedures, hereby requests the Court to provide Notice of Electronic 

Filings to Mr. Genender at email address: paul.genender@weil.com. 

WHEREFORE, Edward Soto, moves this Court to enter an Order for Paul R. Genender to 

appear before this Court on behalf of Defendants, for all purposes relating to the proceedings in 

the above-styled matter and directing the Clerk to provide notice of electronic filings to Paul R. 

Genender. 

Case 1:20-cv-21865-FAM Document 9 Entered on FLSD Docket 05/13/2020 Page 2 of 4
Dated: May 13, 2020 Respectfully submitted, 

/s/ Edward Soto 

Edward Soto (Fla. Bar No. 0265144) 

Edward.Soto@weil.com 

1395 Brickell Avenue, Suite 1200 

Miami, Florida 33131 

Telephone: (305) 577-3100 

Fax: (305) 374-7159 

Attorneys for Defendants 

Ross Dress for Less, Inc., and Ross Stores, Inc. 

CERTIFICATE OF SERVICE 

 I hereby certify that on May 13, 2020, I electronically filed the foregoing with the 

Clerk of the Court for the United States District Court for the Southern District of Florida by using 

the CM/ECF system. As such, the foregoing was served electronically upon all counsel of record. 

/s/ Edward Soto 

Edward Soto (Fla. Bar No. 0265144) 

Edward.Soto@weil.com 

1395 Brickell Avenue, Suite 1200 

Miami, Florida 33131 

Telephone: (305) 577-3100 

Case 1:20-cv-21865-FAM Document 9 Entered on FLSD Docket 05/13/2020 Page 3 of 4
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

Case No. 1:20-cv-21865-FAM

PALM SPRINGS MILE ASSOCIATES, 

LTD., a Florida limited partnership, and 

PHILIPS LAKE WORTH LLC, a Florida 

limited partnership, 

Plaintiffs, 

v. 

ROSS DRESS FOR LESS, INC., a 

Virginia corporation, and ROSS STORES, 

INC., a Delaware corporation,

Defendants. 

CERTIFICATION OF PAUL R. GENENDER

Paul R. Genender, Esquire, pursuant to Rule 4(b) of the Rules Governing the Admission, 

Practice, Peer Review, and Discipline of Attorneys, hereby certifies that: (1) I have studied the 

Local Rules of the United States District Court for the Southern District of Florida; (2) I am a 

member in good standing of The Texas Bar and the United States District Court for the Northern 

District of Texas; and (3) I have not filed three or more motions for pro hac vice admission in this 

District within the last 365 days. 

Dated: May 13, 2020 

 /s/ Paul R. Genender 

Paul R. Genender 

 

Case 1:20-cv-21865-FAM Document 9 Entered on FLSD Docket 05/13/2020 Page 4 of 4