HTML Document View

Full title: Ex Parte Motion to Appear Pro Hac Vice for Sean T. Greecher (Fee Amount $ 281) filed by John Madison Spencer on behalf of Sander Esserman. (Spencer, John)

Document posted on Oct 10, 2021 in the bankruptcy, 5 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

NOW COMES Felton E. Parrish, an attorney and member in good standing of the North Carolina bar and admitted to practice before this Court and, pursuant to the admission requirements of Local Rule 2090-2(b) of this Court and Local Rule 83.1 of the United States District Court for the Western District of North Carolina, moves this Court for admittance pro hac vice of Sean T. Greecher (“Applicant”) for the purposes of representing Sander L. Esserman, the legal representative for persons that have not yet asserted an asbestos-related personal injury claim against the Debtor in the above-captioned case but may in the future assert such a claim (the “Future Claimants’ Representative”).The Applicant is a partner with the law firm of Young Conaway Stargatt & Taylor, LLP (“Young Conaway”), Rodney Square, 1000 North King Street, Wilmington, Delaware 19801.By order dated June 9, 2020, the Court approved the retention of Young Conaway as counsel for the Future Claimants’ Representative.The undersigned movant will serve as co-counsel in this proceeding and will attend all hearings with the Applicant unless otherwise permitted by the Court.I am a partner with the law firm of Young Conaway Stargatt & Taylor, LLP, Rodney Square, 1000 North King Street, Wilmington, Delaware 19801.

List of Tables

Document Contents

UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION In re: Chapter 11 DBMP LLC,1 Case No. 20-30080 (JCW) Debtor. MOTION FOR ADMISSION PRO HAC VICE FOR SEAN T. GREECHER NOW COMES Felton E. Parrish, an attorney and member in good standing of the North Carolina bar and admitted to practice before this Court and, pursuant to the admission requirements of Local Rule 2090-2(b) of this Court and Local Rule 83.1 of the United States District Court for the Western District of North Carolina, moves this Court for admittance pro hac vice of Sean T. Greecher (“Applicant”) for the purposes of representing Sander L. Esserman, the legal representative for persons that have not yet asserted an asbestos-related personal injury claim against the Debtor in the above-captioned case but may in the future assert such a claim (the “Future Claimants’ Representative”). In support of this Motion, the undersigned states as follows: 1. The Applicant is a partner with the law firm of Young Conaway Stargatt & Taylor, LLP (“Young Conaway”), Rodney Square, 1000 North King Street, Wilmington, Delaware 19801. Mr. Greecher’s phone number is (302) 571-6558. Mr. Greecher’s email address is sgreecher@ycst.com. 2. By order dated June 9, 2020, the Court approved the retention of Young Conaway as counsel for the Future Claimants’ Representative. By order dated February 5, 2021, the Court 1 The last four digits of the Debtor’s taxpayer identification number are 8817. The Debtor’s address is 20 Moores Road, Malvern, Pennsylvania 19355.

1

approved the retention of Alexander Ricks PLLC as local co-counsel for the Future Claimants’ Representative. 3. The Applicant has not been disciplined by any court or administrative body and does not have any pending disciplinary proceedings. Further, the Applicant has never had a pro hac vice admission or admission in any other bar revoked. 4. The Applicant understands pro hac vice admission is for this case only and does not constitute formal admission to the bar of this Court. 5. The undersigned movant will serve as co-counsel in this proceeding and will attend all hearings with the Applicant unless otherwise permitted by the Court. 6. The $281 filing fee is being submitted with the filing of this Motion. 7. The Declaration of Applicant in support of this Motion is attached hereto and incorporated herein by reference. WHEREFORE, the undersigned movant respectfully requests that this Court enter an order admitting Sean T. Greecher pro hac vice in this matter. Dated: October 11, 2021 Respectfully submitted, /s/ Felton E. Parrish Felton E. Parrish ALEXANDER RICKS PLLC 1420 East 7th Street, Suite 100 Charlotte, NC 28204 Telephone: 704-365-3656 Facsimile: 704-365-3676 Email: felton.parrish@alexanderricks.com Counsel to the Future Claimants’ Representative

2

EXHIBIT A GREECHER DECLARATION

3

UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION In re: Chapter 11 DBMP LLC,2 Case No. 20-30080 (JCW) Debtor. DECLARATION OF SEAN T. GREECHER IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE I, SEAN T. GREECHER, hereby state as follows: 1. I am a partner with the law firm of Young Conaway Stargatt & Taylor, LLP, Rodney Square, 1000 North King Street, Wilmington, Delaware 19801. My phone number is (302) 571-6558. My email address is sgreecher@ycst.com. 2. I am admitted to practice before the United States District Court for the District of Delaware and the Supreme Court of the State of Delaware. 3. I have read the Motion for Admission Pro Hac Vice being filed contemporaneously herewith and know the contents thereof, and the statements contained therein are true and correct to the best of my knowledge. 4. I have never been disbarred or suspended in any court where I am admitted to practice. 5. I have not been, and am not currently, the subject of disciplinary action by the bar or courts of any state. 2 The last four digits of the Debtor’s taxpayer identification number are 8817. The Debtor’s address is 20 Moores Road, Malvern, Pennsylvania 19355.

4

6. I have obtained and reviewed a copy of the Local Rules of this Court and am generally familiar with such rules. 7. I agree to be bound by the rules of this Court, and I submit to the disciplinary jurisdiction of this Court for any alleged misconduct which occurs in the preparation or course of this action. 8. I declare under the penalty of perjury that the foregoing is true and correct. Dated: October 11, 2021 /s/ Sean T. Greecher Sean T. Greecher

5