IN THE SUPREME COIIRT OF OHIO

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Dale Elliott
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1 IN THE SUPREME COIIRT OF OHIO THE STATE OF OHIO ex rel. JACK MOR.ItISON; JR., LAW DIRECTOR, CITY OF MUNROE FALLS, OHIO, V. Plaintiff-Appellant BECK ENERGY CORP., et al. Case No ON APPEAL FROM THE SUMMIT COUNTY COURT OF APPEALS, NINTH APPELLATE DIS"I`RICT, CASE NO Defendant-Appellees MOTION FOR PERMISSION TO APPEAR PRO HAC VICE Pursuant to Gov. Bar. R. XII(2)(A)(6), Meleah Geertsma, PHV , respectfully moves the Supreme Court of Ohio to grant her pennission to appear pro hac vice and participate as co-counsel in this case representing Municipal Amici Curiael in the above referenced case, Docket Number Movant represents that the following is a list of the jurisdictions in which she has ever been licensed to practice law, including dates of admission to practice, resignation or retirement, and any attorney registration numbers: Bar of the District of Columbia, , 11/12/2004-present State Bar of Illinois, , 5/07/2009-present tlnited States Court of Appeals for the District of Columbia Circuit, 1/1$/20I 1-present United States Court of. Appeals for the Tenth Circuit, 3/28/2011-present Movant represents that she has not been granted pernzission to appear pro hac vice in more than three proceedings before Ohio tribunals in the current calendar year pursuant to Gov. 1 Municipal Amici Curiae are the Cities of Broadview Heights, Euclid, Mansfield, and North Royalton, and the Village of Amesville.

2 Bar. R. XII(2)(A)(5). As required by Gov. Bar. R. XII(2)(A)(6)(a), Movant has supplied her office address and the name and address of her employer below, and her residential address is 5027 N. I-Term.itage Ave, Apt 3N, Chicago, Illinois, Peter Precaaio (002W$O), an active Ohio att-oz^ney in good stand ing, agrees to associate with Movant Meleah Geertsma on this case. Mr. Precario is counsel in this matter, representing the Municipal.Aanici Curiae. Mr. Precario's office address is 2 Miranova Place, Suite 500, Columbus, Ohio, 43215, and his office phone number is A copy of the affidavit required by Gov. Bar. R..YII(2)(A)(6), a copy of Movant's certificate of pro hac vice registration furnished by the Supreme Court of Ohio Office of Attorney Services, and a certificate indicating service of this Motion on all known parties and attorneys of record are attached. Movant understands that, if this Motion is granted, she inust file a Notice of Permission to Appear Pro Hac Vice and a copy of the Order granting permission with the Supreine Court of Ohio Office of Attorney Services within thirty days of the Order. Respectfully submitted, Dated: h-i 1 1Vleleah A. ^Geertsna`'^- Natural Resources Defense Council 20 N. Wacker Dr., Ste 1600 Chicago, IL (direct) (fax) mgeertsma@nrdc.org

3 Certificate of Service I hereby certify that I sent by first class United States mail on September '6, 2013 a copy of this rn:-0tion I'or p:ern3ission to appear pro hac vice to the below attorneys of record. Dated: k /^ Peter Precario ( oo ^Z*e & e7 ) Jack Morrison, Jr. ( ) Thomas M. Saxer ( ) Thomas R. Houlihan* ( ) *Counsel of RecoYd AMER CUNNINGHAM CO., L.P.A. 159 S. Main Street, Suite 1100 Akron, Ohio Telephone: (330) Facsimile: (330) Houlihan@DAiner-law.com Counsel for Plaintiffs -Appellants Munroe Falls Barbara A. Tavaglione ( ) 9191 Paulding Street NW Massillon, Ohio Telephone: (330) bartava I^zoz^ela7{gmail.coin Counsel far Amicus Curiae Feople's Oil and Gas Collabor ative - Ohio John K. Keller* ( ) *Counsel of.record VORYS, SATER, SEYMOUR AND PEASE LLP 52 East Gay Street P.O. Box 1008 Columbus, Ohio Telephone: (614) Facsimile: (614) jkkeller@lvorys.com Counsel for Defendants-Appellees Beck Energy Corporation and Joseph YYill ingham

4 IN I'HE MATTE R OF THE IR!.IEBTAON OF CASE NO Mefeah A. Geertsma :FtlR I'&:RMISSI(3N TO APPEAR PRO I^AC VICE Meleah A. Geertsma follows: a. I have never been disbarred from the practice of law. f!ff6lmavi'i' OF O[1 Tm+OF-s'6'ATE E#TTOIt,^V EY Gov. Bar R. XII, Section 2(A)(6) being first duly cautioned, swears or affirnls as b. I have been admitted to the practice of law in the following jurisdictxons (attach additional jurisdictions if necessary): District of Columbia State of Illinois D.C. C'ircuit Court of Appeals (fed) Tenth Circuit Court of Ap^eais (fed) c. Choose one: I am not currently suspended fiorn the practice of law in any jurisdiction where I have been admitted to practice. I am cu.rr,ently suspended from the practice of laxv in the following jurisdictions: d. Choose one: a I have not resigned from the practice of law with discipline pending in any,jurisdiction where I have been admitted to practice. q I have resigned from the practice of law with discipline pendiiag in the following jurisdiction(s): SIGNATURE OF API'I TC.'AN't Sworn to or affzrnaed before me and subscribed in my presence the 4 day of September 2013, in the state of fl county of Cook NOTARY PUKC astase OF UOM *AffiR s SIGiV'AT ' IdE F NO't'ARY PUBI,IC"

5 JL I HE S^PREME COURT ^f OHIO OFFICE FATI'4JRNEY SERVICES I^?4 THE NUI"I'ER li' 'rl[e A.PP11CA'I'.6oN, OF Meleah Geertsma FOR PRO EiAl;" VICE II;t.C,IS7'It9:1'doN per Gov. Bar R. XII, Section 2(A)(3) Certificate of PRO RAC VICE REGiS TRA'TION 2013 Registration Number: PI-lv Meleah Geertsma having met the requiremeiits of, and found to be in full compliance with, Section 2(A)(3) of Rule XII of the Rules for the Governnient of the Bar of Ohio, is hereby issued this certificate of pro hac vice registration in the state of Ohio. To receive pennission to appearpro hac vice in an Ohio proceeding, a motion requesting such per^rnission must be filed mitll the ti-ibunat in accordayice with Section 2(A)(6) of Rule XII of the Rules for the Governrnent of the Bar of Ghio. Stisan B. Christoff Director, Attorney Services Expires Decettaber 31, 2013

IN THE SUPREME COURT OF OHIO

IN THE SUPREME COURT OF OHIO STATE OF OHIO, CASE NO. 2014-0120 Plaintiff-Appellee, : ON DISCRETIONARY APPEAL FROM THE MAHONING v. : COUNTY COURT OF APPEALS, SEVENTH APPELLA'TE DISTRICT, BRANDON MOORE,.