Case Doc 516 Filed 01/20/21 Entered 01/20/21 15:30:15 Desc Main Document Page 1 of 4

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UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF NORTH CAROLINA

CHARLOTTE DIVISION

In re:

ALDRICH PUMP, LLC, et al., Debtors.

Chapter 11

Case No. 20-30608 (JCW) (Jointly Administered)

MOTION FOR ADMISSION PRO HAC VICE FOR STEVEN KAZAN

I, Heather W. Culp, am a partner with the law firm of Essex Richards, P.A. (“Movant”) and am a member in good standing of the bar of this Court. Pursuant to the admission

requirements of Rule 2090-2 of the Local Rules of this Court and Rule 83.1 of the Local Rules for Procedure and Practice of the United States District Court for the Western District of North Carolina, I move for the pro hac vice admission of Steven Kazan (“Applicant”) to practice in this Court for the purpose of representing in the above-captioned case and related and associated proceedings Richard and Calvena Sisk, members of the Official Committee of Asbestos Personal Injury Claimants, and the other claimants for which Applicant’s law firm Kazan, McClain, Satterley & Greenwood, a Professional Law Corporation, is identified as primary plaintiff counsel in Appendix A to the Complaint filed in the associated adversary proceeding Aldrich Pump LLC et al. v. Those Parties Listed on Appendix A to Complaint et al., Adv. Pro. No. 20-03041 [Dkt. 1]. In support of this Motion, the undersigned respectfully represents to the Court as follows:

1. Applicant is an attorney with the law firm of Kazan, McClain, Satterley & Greenwood, a Professional Law Corporation, with an office located at 55 Harrison Street, Suite 400, Oakland, California 94607. Applicant’s telephone number is (510) 302-1000, his facsimile

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number is (510) 835-4913, and his e-mail address is skazan@kazanlaw.com.

2. Applicant is a member in good standing and admitted to practice before the following Bar of a United States District Court, the Bar of the court of the following state, and/or the District of Columbia Bar: New York State Bar, California State Bar, U.S. District Courts for the Northern and Eastern Districts of California, U.S. Courts of Appeal for the Third, Fifth and Ninth Circuits, and the United States Supreme Court.

3. Applicant’s appearance in this matter will be in association with the undersigned, who is a member in good standing of the North Carolina State Bar, the Kentucky Bar

Association (inactive status), the United States Tax Court, and all federal courts of North Carolina and Kentucky. Undersigned is also admitted to practice before this Court.

4. The Declaration of Applicant supporting this Motion is attached as Exhibit A and incorporated by reference.

5. The $281.00 fee for admission pro hac vice is being submitted with the filing of this Motion, consistent with Local Bankruptcy Rule 2090-2(c)(1).

6. Undersigned counsel will be Applicant’s associated local counsel and will accompany Applicant to all hearings unless otherwise permitted by the Court.

7. Applicant will establish an ECF account with the Clerk of Court after admission. WHEREFORE, Movant respectfully requests that the Court enter an Order, substantially in the form attached hereto as Exhibit B, admitting Applicant to appear before the Court pro hac vice in this case and related and associated proceedings.

This the 20th day of January, 2021.

/s/Heather W. Culp Heather W. Culp NC Bar No. 30386

Case 20-30608 Doc 516 Filed 01/20/21 Entered 01/20/21 15:30:15 Desc Main Document Page 2 of 4

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Local Counsel for Official Committee of Asbestos Personal Injury Claimants Members Richard & Calvena Sisk and Other Affected

Individuals Represented by Kazan, McClain, Satterley & Greenwood, a Professional Law Corporation

Essex Richards, P.A. 1701 South Boulevard

Charlotte, North Carolina 28203 Telephone: (704) 377-4300 Facsimile: (704) 372-1357

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CERTIFICATE OF SERVICE

I certify that on January 20, 2021, the foregoing MOTION FOR ADMISSION PRO HAC VICE FOR STEVEN KAZAN was filed with the Clerk of Court using the CM/ECF system, which will send notification of such filing to the parties registered to receive notices for this case.

/s/Heather W. Culp Heather W. Culp NC Bar No. 30386

Local Counsel for Official Committee of Asbestos Personal Injury Claimants Members Richard & Calvena Sisk and Other Affected

Individuals Represented by Kazan, McClain, Satterley & Greenwood, a Professional Law Corporation

Essex Richards, P.A. 1701 South Boulevard

Charlotte, North Carolina 28203 Telephone: (704) 377-4300 Facsimile: (704) 372-1357

E-mail: hculp@essexrichards.com

Case 20-30608 Doc 516 Filed 01/20/21 Entered 01/20/21 15:30:15 Desc Main Document Page 4 of 4

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UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF NORTH CAROLINA

CHARLOTTE DIVISION In re:

ALDRICH PUMP, LLC, et al.,

Debtors.

Chapter 11

Case No. 20-30608 (JCW) (Jointly Administered)

ORDER ALLOWING STEVEN KAZAN TO APPEAR PRO HAC VICE

This matter came before the United States Bankruptcy Court for the Western District of

North Carolina, Charlotte Division, upon the Motion for Admission Pro Hac Vice (“the

Motion”) filed by Heather W. Culp, for Steven Kazanto practice in this Court for the purposes

of representing in this case and related and associated proceedings Richard & Calvena Sisk, members of the Official Committee of Asbestos Personal Injury Claimants, and the other claimants for which Applicant’s law firm Kazan, McClain, Satterley & Greenwood, a

Professional Law Corporation, is identified as primary plaintiff counsel in Appendix A to the

Complaint filed in the associated adversary proceeding Aldrich Pump LLC et al. v. Those Parties

Listed on Appendix A to Complaint et al., Adv. Pro. No. 20-03041 [Dkt. 1], together with

counsel from the law firm of Essex Richards, P.A., who are admitted to practice in this Court;

Case 20-30608 Doc 516-2 Filed 01/20/21 Entered 01/20/21 15:30:15 Desc Exhibit B Page 1 of 2

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and it appearing to the Court, and the Court so finding, that for good cause shown the Motion should be granted;

NOW, THEREFORE, IT IS HEREBY ORDERED THAT, pursuant to Rule 2090-2 of the Local Rules of Practice and Procedure of this Court, Steven Kazan shall be, and hereby is

admitted pro hac vice to practice in this Court in the above-captioned case and related and

associated proceedings.

This Order has been signed electronically. United States Bankruptcy Court

The Judge’s signature and Court’s seal appear at the top of the Order.

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