NO IN THE SUPREME COURT OF THE STATE OF HAWAII

Transcription

1 NO IN THE SUPREME COURT OF THE STATE OF HAWAII ESTATE OF FRANCISCO SISON, JOSE MARIA SISON, and JAIME PIOPONGO, ORIGINAL PROCEEDING Plaintiff-Appellant, vs. ESTATE OF FERDINAND E. MARCOS, Defendants-Appellees. I'.. ~ ~ ('") I~ c:;:) c::;) r ttl..a ::"1,. 'l>',;r;. Z '"- -I" 0.::> ~;;; :::0 ::z.....,., 3: N ":.-:-trn l> -r:~- a -1- :-4 r ~~~ -0 :;rr, ~.-: - -) :: c; l> ~ :u -I &- en U1 REVELSTOKE INVESTMENT CORPORATION, INC.'S MOTION TO ADMIT EUGENE D. GULLAND TO PRACTICE PRO HAC VICE -., r..,1 0 DECLARATION OF THOMAS BENEDICT DECLARATION OF EUGENE D. GULLAND CERTIFICATE OF SERVICE GOODSILL ANDERSON QUINN & STIFEL A LIMITED LIABILITY LAW PARTNERSHIP LLP THOMAS BENEDICT Alii Place, Suite Alakea Street Honolulu, Hawaii Telephone: (808) Facsimile: (808) Attorney for REVELSTOKE INVESTMENT CORPORATION, INC

2 NO IN THE SUPREME COURT OF THE STATE OF HAWAII ESTATE OF FRANCISCO SISON, JOSE MARIA SISON, and JAIME PIOPONGO, ORIGINAL PROCEEDING Plaintiff-Appellant, vs. ESTATE OF FERDINAND E. MARCOS, Defendants-Appellees. REVELSTOKE INVESTMENT CORPORATION, INC.'S MOTION TO ADMIT EUGENE D. GULLAND TO PRACTICE PRO HAC VICE Revelstoke Investment Corporation, Inc. ("Revelstoke") by and through its attorneys, Goodsill Anderson Quinn & Stifel LLP, respectfully moves for admission of EUGENE D. GULLAND of the law firm of Covington & Burling LLP to practice pro hac vice as co-counsel with the undersigned and other attorneys with Goodsill Anderson Quinn & Stifel LLP in this matter, on behalf of Revelstoke subject to the conditions of Rule 1.9 of the Rules of the Supreme Court of the State of Hawai'i. This motion is brought pursuant to Rule 27 of the Hawai'i Rules of Appellate Procedure, and Rule 1.9 of the Rules of the Supreme Court of the State of Hawai'i, and is based upon the Declarations of Thomas Benedict and Eugene D. Gulland attached hereto, and the records and files herein

3 DATED: Honolulu, Hawaii, January 20, THOMAS BENEDICT Attorney for REVELS TOKE INVESTMENT CORPORATION, INC. 2

4 NO IN THE SUPREME COURT OF THE STATE OF HAWAII ESTATE OF FRANCISCO SISON, JOSE MARIA SISON, and JAIME PIOPONGO, ORIGINAL PROCEEDING Plaintiff-Appellant, vs. ESTATE OF FERDINAND E. MARCOS, Defendants-Appellees. DECLARATION OF THOMAS BENEDICT I, THOMAS BENEDICT, hereby declare: I. I am an attorney duly licensed to practice law in the State of Hawai' i and a partner in the law finn of Goodsill Anderson Quinn & Stifel ("Goodsill"), counsel of record for Revelstoke Investment Corporation, Inc. ("Revelstoke") in the MDL 840 in the United States District Court for the District of Hawaii. 2. I am an active member in good standing of the Bar of the State of Hawai'i. 3. Goodsill will continue to be subject to service of all pleadings and notices on behalf of Revelstoke and will at all times meaningfully participate in this action with authority and responsibility to act as one of the attorneys of record for all purposes

5 4. Because of the special experience and knowledge of Eugene D. Gulland concerning the legal and factual issues in this case, I respectfully request that he serve as co-counsel in this matter. 5. Payment of the annual disciplinary Board fee will be made, and proof of such payment will be filed in accordance with the requirements of Rule 1.9 of the Rules of the Supreme Court of the State of Hawai'i. I declare under penalty of law that the foregoing is true and correct. Dated: Honolulu, Hawai' i, January 20, THOMAS BENEDICT 2

6 NO IN THE SUPREME COURT OF THE STATE OF HAWAII ESTATE OF FRANCISCO SISON, JOSE MARIA SISON, and JAIME PIOPONGO, ORIGINAL PROCEEDING Plainti ff-appellant, vs. ESTATE OF FERDINAND E. MARCOS, Defendants-Appellees. DECLARATION OF EUGENE D. GULLAND I, EUGENE D. GULLAND, declare: 1. I reside at James Monroe Highway, Aldie, Virginia, I am a partner with the law firm of Covington & Burling LLP (,'Covington"), which is located at 1201 Pennsylvania Avenue, NW, Washington D.C Covington is counsel for Revelstoke Investment Corporation, Inc. I hereby seek admission pro hac vice before this Court with respect to No , as cocounsel with Thomas Benedict and the law firm of Goodsill Anderson Quinn & Stifel LLP, 1099 Alakea Street, Suite 1800, Alii Place, Honolulu, Hawai' i

7 4. I am admitted to practice in the following courts as follows: Court / Bar United States Supreme Court United States Court of Appeals (1 st Cir.) United States Court of Appeals (2nd Cir.) United States Court of Appeals (3rd Cir.) United States Court of Appeals (4th Cir.) United States Court of Appeals (6th Cir.) United States Court of Appeals (7th Cir.) United States Court of Appeals (9th Cir.) United States Court of Appeals (10 th Cir.) United States Court of Appeals (11 th Cir.) United States Court of Appeals (D.C. Cir.) United States Court of Appeals (Fed. Cir.) United States Claims Court U. S. District Court for the District of Arizona U. S. District Court for the District of Columbia U. S. District Court for the Eastern District of VA U. S. District Court for the District of Maryland Virginia State Bar District of Columbia Bar Admission Date August 12, 1977 September 12, 1977 August 5, 1987 December 17, 1992 May 2, 1991 June 23, 1986 December 27, 1992 January 25, June 26, 2008 June 15, 1973 July 23, 1973 October 8, 1976 May 8, 1996 July 2, 1973 January 9, 1987 January 23, 1976 April 24, 1986 June 13, I am currently in good standing and eligible to practice in these courts and have never been suspended or disbarred in any other court. 6. I have neither currently, nor in the year preceding this motion, applied to appear pro hac vice in the Supreme Court of the State of Hawai' i. 7. I do not reside in the State of Hawai' i, am not regularly employed in the State of Hawai'i, nor am I regularly engaged in business, professional or law-related activities in the State of Hawai' i. 8. Thomas Benedict, a partner with the law firm of Goodsill Anderson Quinn & Stifel, whose address is 1099 Alakea Street, Suite 1800, Honolulu, Hawai' i 2

8 96813, telephone number (808) , is an active member in good standing of the Bar of the State of Hawai' i and licensed to practice before all courts in the State of Hawai'i, will continue to serve as counsel with whom this Court and opposing counsel may readily communicate regarding the conduct of the case and upon whom papers may be served. Dated: Washington, D. C., January

9 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the within document was served on this date in the following manner: HAND DELIVERED MAILED FAXED CARLM. VARADY, ESQ. Law Offices of Carl M. Varady American Savings Bank Tower 1001 Bishop Street, Suite 2870 Honolulu, HI [ ] [X] [ ] Attorney for Plaintiff-Appellants ESTATE OF FRANCISCO SISON, JOSE MARIA SISON and JAIME PIOPONGO BERT T. KOBAYASHI, JR., ESQ. LEX R. SMITH, ESQ. JOSEPH A. STEWART, ESQ. Kobayashi Sugita & Goda First Hawaiian Center 999 Bishop Street, Suite 2600 Honolulu, HI [ ] [X] [ ] and JAMES PAUL LINN, ESQ. James P. Linn Law Firm PLLC 1601 NW Expressway, Suite 1710 Oklahoma City, OK [ ] [X] [ ] and JOHN J. BARTKO, ESQ. Bartko Welsh Tarrant & Miller 900 Front Street, Suite 300 San Francisco, CA [ ] [X] [ ] Attorneysfor the Estate of Ferdinand E. Marcos

10 HAND DELIVERED MAILED FAXED MATTHEW J. VIOLA, ESQ. [ ] [X] [ ] Law Office of Matthew Viola 1132 Bishop Street, Suite 1860 Honolulu, HI and STEPHEN V. BOMSE, ESQ. [ ] [X] [ ] RACHEL M. JONES, ESQ. Heller Ehrman LLP 333 Bush Street San Francisco, CA and RICHARD CASHMAN, ESQ. [ ] [X] [ ] Heller Ehrman LLLP Times Square New York, NY Attorneys for the Republic of the Philippines CAROL A. EBLEN, ESQ. [ ] [X] [ ] Goodsill Anderson Quinn & Stife1 LLP Alii Place, Suite Alakea Street Honolulu, HI and JA Y R. ZIEGLER, ESQ. [ ] [X] [ ] Buchalter Nemer 1000 Wilshire Boulevard, 15 th Floor Los Angeles, CA Attorneysfor Philippine National Bank (Petitioner) 5

11 HAND DELIVERED MAILED FAXED SHERRY P. BRODER, ESQ. [ ] [X] [ ] Davies Pacific Center 841 Bishop Street, Suite 800 Honolulu, HI JON M. V AN DYKE, ESQ. [ ] [X] [ ] 2515 Dole Street, Room 239 Honolulu, HI ROBERT A. SWIFT, ESQ. [ ] [X] [ ] Kohn Swift & Graf One South Broad Street, Suite 2100 Philadelphia, P A DATED: Honolulu, Hawaii, January 20,2009. THOMAS BENEDICT Attorney for REVELSTOKE INVESTMENT CORPORATION, INC. 6