IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA : : : : : : : Chapter 11

Transcription

1 Case jkf Doc 640 Filed 06/22/09 Entered 06/22/ Desc Main Document Page 1 of 4 In re MOTION FOR ADMISSION OF STEPHANIE WICKOUSKI PRO HAC VICE PURSUANT TO LOCAL RULE OF BANKRUPTCY PROCEDURE (c) Andrew J. Flame ( Movant ), a member in good standing of the Bar of the Commonwealth of Pennsylvania, an attorney admitted to practice before the United States Bankruptcy Court for the Eastern District of Pennsylvania and a partner in the law firm of Drinker Biddle & Reath LLP ( Drinker ), hereby moves the Court to enter an Order permitting Stephanie Wickouski, Esquire of Drinker Biddle & Reath LLP to practice pro hac vice before the United States Bankruptcy Court for the Eastern District of Pennsylvania and to represent Citizens Bank of Pennsylvania, as Agent on behalf of the Prepetition Secured Lenders in these cases. In support of this Motion, the Movant respectfully represents as follows 1. Ms. Wickouski is a partner with Drinker, which maintains an office for the practice of law at 140 Broadway, 39 th Floor, New York, NY Ms. Wickouski is a member in good standing of the bar(s) of the State of New York, the District of Columbia, the Commonwealth of Virginia and the State of Maryland. 3. Attached hereto as Exhibit A is a declaration of Stephanie Wickouski, which sets forth her qualifications in greater detail.

2 Case jkf Doc 640 Filed 06/22/09 Entered 06/22/ Desc Main Document Page 2 of 4 4. Movant requests that this Court grant this Motion so that Ms. Wickouski may be allowed to file pleadings and appear and be heard at any hearing in these cases. WHEREFORE, Movant respectfully requests that the Court enter the attached order permitting Stephanie Wickouski, Esquire to appear pro hac vice in these cases. Dated June 22, 2009 DRINKER BIDDLE & REATH LLP /s/ Andrew J. Flame Andrew C. Kassner Andrew J. Flame One Logan Square 18 th & Cherry Streets Philadelphia, PA Telephone (215) Facsimile (215) Attorneys for Citizens Bank of Pennsylvania, as Agent for the Prepetition Secured Lenders.

3 Case jkf Doc 640 Filed 06/22/09 Entered 06/22/ Desc Main Document Page 3 of 4 In re DECLARATION OF STEPHANIE WICKOUSKI, ESQUIRE I, Stephanie Wickouski, hereby submit this declaration in support of the Motion for admission of Stephanie Wickouski pro hac vice pursuant to local rule of Bankruptcy Procedure (c) (the Motion ). 1. The information contained in the Declaration is true and correct to the best of my knowledge and belief. 2. I am a partner in the law firm of Drinker Biddle & Reath LLP ( Drinker ) and regularly practice in the area of financial restructuring, including issues involving bankruptcy. 3. I received my Juris Doctorate degree from Franklin Pierce Law Center in I am a member in good standing of the bars of the State of New York, the District of Columbia, the Commonwealth of Virginia and the State of Maryland. 5. I regularly appear before the United States Bankruptcy Court for the Southern District of New York. 6. I am not under suspension or disbarment by any Court.

4 Case jkf Doc 640 Filed 06/22/09 Entered 06/22/ Desc Main Document Page 4 of 4

5 Case jkf Doc Filed 06/22/09 Entered 06/22/ Desc Proposed Order Page 1 of 1 In re ORDER AND NOW, this day of, 2009, it is hereby ORDERED that the application of Stephanie Wickouski, Esquire, to practice in this court pursuant to the Local Rule of Bankruptcy Procedure 2090-(c) is GRANTED. Jean K. FitzSimon United States Bankruptcy Judge