Case 1:15-bk MFW Doc 606 Filed 02/10/16 Entered 02/10/16 14:27:45 Desc Main Document Page 1 of 2

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1 Case 1:15-bk MFW Doc 606 Filed 02/10/16 Entered 02/10/16 14:27:45 Desc Main Document Page 1 of 2 IN THE DISTRICT COURT OF THE VIRGIN ISLANDS BANKRUPTCY DIVISION ST. CROIX, VIRGIN ISLANDS In re: HOVENSA L.L.C., Debtor. Chapter 11 No. 1:15-bk MFW MOTION FOR PERMISSION TO APPEAR PRO HAC VICE This motion for admission pro hac vice is being filed on behalf of Fred Wahrlich to appear on behalf of the HOVENSA Environmental Response Trust. Attached to this Motion are the Pro Hac Vice Application, Certificate of Good Standing, Declaration, and Application Fee of $ Mr. Wahrlich is a Shareholder in the firm of Munsch Hardt Kopf & Harr, P.C. in Houston, Texas. His Texas State Bar Number, office address, telephone number and fax number are: Fred Wahrlich Munsch Hardt Kopf & Harr, P.C. Texas Bar No Milam, Suite 2700 Houston, Texas Direct: (713) Fax: (713) fwahrlich@munsch.com 2. Mr. Wahrlich is an active member in good standing of the State Bar of Texas and is also admitted to practice before the United States District Court for the Southern District of Texas. He is not the subject of disciplinary matters, and will abide by the rules of the United

2 Case 1:15-bk MFW Doc 606 Filed 02/10/16 Entered 02/10/16 14:27:45 Desc Main Document Page 2 of 2 In re: HOVENSA, L.L.C., Case No. 1:15-bk MFW Motion for Permission to Appear Pro Hac Vice Page 2 States Bankruptcy Court in the United States Virgin Islands. A certificate of good standing from the United States District Court for the Southern District of Texas is attached. 3. Applicant shall be associated in this case with the following attorney who is a member of the Bar of the Bankruptcy Court in the United States Virgin Islands, Carl A. Beckstedt III. 4. Applicant and associated local counsel have read and shall comply with Local Rule B. Dated this 10 th day of February Respectfully submitted, By: /s/ Carl A. Beckstedt III, Esq. Carl A. Beckstedt III, Esq. Virgin Island Bar Number 684 Beckstedt & Associates 2162 Church St. Christiansted, VI Tel: carl@beckstedtlaw.com Local Counsel for HOVENSA Environmental Response Trust CERTIFICATE OF SERVICE A true and correct copy of the foregoing Motion to Appear Pro Hac Vice has been served via electronic means as listed on the Court s ECF noticing system on this 10 th day of February /s/ Carl A. Beckstedt III, Esq. Carl A. Beckstedt III, Esq.

3 Case 1:15-bk MFW Doc Filed 02/10/16 Entered 02/10/16 14:27:45 Desc Pro Hac Vice Application for Fred Wahrlich Page 1 of 3 DISTRICT COURT OF THE VIRGIN ISLANDS PRO HAC VICE APPLICATION You must jill in all blanks and answer all questions. {fa particular question does not apply to you. write "none" or "NIA ". Applications which are not properly completed will be returned. NAME FIRM ADDRESS MAIN FIRM PHONE NO. FAX NO. ADDRI<:SS Fred Wahrlich Munsch Hardt Kopf & Harr, P.C. 700 Milam Suite 2700 Houston TX fwahrlich@munsch.com Case caption for which admission is sought: In re: Hovensa LLC Motion made by: _...:..F.!..:re::.::d:...W.:..:..!:al~lrc!!lic:::::ch~ Party applicant represents: Environmental Response Trustee A. BACKGROUND QUESTIONNAffiE Please answer these questions yes or no. If you answer yes to any of these questions you must submit a statement under the penalties of perjury which includes the relevant facts. court, charge, date, whether the occurrence was disclosed to the highest court of the state(s) in which you are admitted, disposition. whether the occurrence was an isolated incident, and any other facts you deem relevant. I. Are there any disciplinary proceedings pending against you? 0 YES 1XJ NO 2. Have you ever been denied admission to practice, disbarred, suspended from practice, or disciplined by any court or bar authority? 0 YES ~ NO 3. If you have been suspended or disbarred from the practice of law by any court or bar authority, have you been reinstated? D YES 0 NO N/A 4. Have you ever resigned from the practice of law in any court? 0 YES 1XJ NO Pro Hac Vice Application Page I of 3

4 Case 1:15-bk MFW Doc Filed 02/10/16 Entered 02/10/16 14:27:45 Desc Pro Hac Vice Application for Fred Wahrlich Page 2 of 3 5. Excluding traffic violations punishable by fine only, have you ever been convicted of, or entered a plea of no contest to, any crime or are any criminal charges pending against you? 0 YES [!] NO 6. II ave you ever been held in contempt of court? D YES ~ NO 7. Have you ever been denied pro hac vice admission in a jurisdiction? D YES lij NO B. APPLICANT'S CERTIFICATION 1. I have been admitted to practice law in the following jurisdictions (states, territories, or the District of Columbia): COURT DATI-: OF ADMISSION/BAR NO. All Courts in the State of Texas November 1985 I Unless otherwise indicated in Section A, I am a member in good standing of the bars of each of the jurisdictions listed above. 3. I am familiar with the Rules of Professional Conduct, the Federal Rules of Civil and Criminal Procedure, the Federal Rules of Evidence, and the Local Rules of the District Court of the Virgin Islands. 4. My principal law office is located in H-'o'""u..:.. st...:. o--' n,'-t--'e_x_as' I am a member of the bar of the following United States Courts: U.S. COURT Texas Southern District I Bankruptcy Texas Eastern District Court Texas Northern District Court DATE OF ADMISSION/BAR NO. December 3 I, 1985 I Federal ID #248 June I November 8, 1985 I Pro Hac Vice Application 05/20 II Page 2 of 3

5 Case 1:15-bk MFW Doc Filed 02/10/16 Entered 02/10/16 14:27:45 Desc Pro Hac Vice Application for Fred Wahrlich Page 3 of 3 Texas Western District Court December 8, 1986 I Arizona District Court February 18, I None Fifth Circuit Court of Appeals December I 0, 1984 I I lave you ever been admitted pro hac vice in any previous matters in the District Court of the Virgin Islands? D YES [] NO If yes, please indicate the case name, case number, date of previous pro hac vice admission to this Court. CASE NAME I NUMBER NA DATE OF PRO HAC VICE ADMISSION CASESTATlJS 7. I understand that it is my responsibility to notify the Attorney Admission Coordinator of any change in my address. 8. I understand that I submit myself to the jurisdiction of this Court for any disciplinary action to which I may be subject. I hereby certify under the penalties of perjury that the foregoing statements and answers arc true and correct. ULU2LJ February 5, 2016 Signature '-- For Court Use Only Fee: 0 Check 0 Cash Amount: Staff Notes (THIS APPLICATION SHOULD ACCOMPANY THE MOTION FOR ADMISSION AND BE A 1T ACHED TO ALL COPIES FORWARDED TO THE COUNSEL OF RECORD.) Pro I lac Vice AJlplication 05/20 II Page 3 of 3

6 Case 4:00-mc Document 4 Filed in TXSD on 02/08/16 Page 1 of 1 Case 1:15-bk MFW Doc Filed 02/10/16 Entered 02/10/16 14:27:45 Desc Certificate of Good Standing Page 1 of 1 United States District Court Southern District of Texas Certificate of Good Standing I, David J. Bradley, Clerk of Court, United States District Court for the Southern District of Texas, certify that the attorney identified below is admitted to practice in this court, and is in good standing as a member of the Bar of this Court. Fred Wahrlich, Federal ID No 248 Admission date: December, 31, 1985 Dated February 8, 2016, at Houston, Texas. David J. Bradley, Clerk of Court By: Donna Wilkerson, Deputy Clerk

7 Case 1:15-bk MFW Doc Filed 02/10/16 Entered 02/10/16 14:27:45 Desc Declaration of Fred Wahrlich Page 1 of 2 IN THE DISTRICT COURT OF THE VIRGIN ISLANDS BANKRUPTCY DIVISION ST. CROIX, VIRGIN ISLANDS In re: HOVENSA L.L.C., Debtor. Chapter 11 No. 1:15-bk MFW DECLARATION OF FRED WAHRLICH IN SUPPORT OF MOTION FOR PERMISSION TO APPEAR PRO HAC VICE I, Fred Wahrlich, pursuant to 28 U.S.C. Section 1746, declare under penalty of perjury that the foregoing is true and correct: 1. I am an attorney admitted to practice law in the State of Texas. I am a member of Munsch Hardt Kopf & Harr, P.C., 700 Milam, Suite 2700, Houston, Texas I am currently in good standing and an active member of the bar of the State of Texas; 3. I have not suffered any disbarment or suspension of my license to practice in any jurisdiction. 4. I have not been admitted pro hac vice in this Court during the last 12 months immediately preceding the filing of this motion. 5. I am not admitted pro hac vice in this Court in any other active cases. 6. I make this declaration in support of the motion for permission to appear pro hac vice as co-counsel for HOVENSA Environmental Response Trust.

8 Case 1:15-bk MFW Doc Filed 02/10/16 Entered 02/10/16 14:27:45 Desc Declaration of Fred Wahrlich Page 2 of 2 In re: HOVENSA, L.L.C., Case No. 1:15-bk MFW Declaration of Fred Wahrlich Page 2 Executed on February 10, Fred Wahrlich, Esq. Munsch Hardt Kopf & Harr, P.C. Texas Bar No Milam, Suite 2700 Houston, Texas Direct: (713) Fax: (713) fwahrlich@munsch.com

9 Case 1:15-bk MFW Doc Filed 02/10/16 Entered 02/10/16 14:27:45 Desc Proposed Order Page 1 of 1 IN THE DISTRICT COURT OF THE VIRGIN ISLANDS BANKRUPTCY DIVISION ST. CROIX, VIRGIN ISLANDS In re: HOVENSA L.L.C., Debtor. Chapter 11 No. 1:15-bk MFW ORDER GRANTING MOTION FOR PERMISSION TO APPEAR PRO HAC VICE OF FRED WAHRLICH Upon consideration of the Motion for Permission to Appear Pro Hac Vice of Fred Wahrlich, it is hereby ORDERED that the Motion is GRANTED. Fred Wahrlich, Esq., is hereby admitted to practice before this Court and appear on behalf of the HOVENSA Environmental Response Trust in this case. SO ORDERED this day of, MARY F. WALRATH UNITED STATES BANKRUPTCY JUDGE