Case: 11-13671-JMD Doc #: 130 Filed: 10/26/11 Desc: Main Document Page 1 of 3 Steven C. Reingold (BNH 06128 JAGER SMITH P.C. One Financial Center Boston, Massachusetts 02111 telephone: (617 951-0500 facsimile: (617 951-2414 email: sreingold@jagersmith.com Proposed Counsel to the Official Committee of Unsecured Creditors UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW HAMPSHIRE In re Chapter 11 KINGSBURY CORPORATION et al., 1 Case No. 11-13671-JMD Debtors. Jointly Administered MOTION FOR AUTHORIZATION TO APPEAR AND PRACTICE PRO HAC VICE The Official Committee of Unsecured Creditors (the Committee of Kingsbury Corporation and its affiliated debtors (the Debtors hereby moves (this Motion, pursuant to Rule 83.2(b of the Local Rules of the United States District Court for the District of New Hampshire (the Local Rules and Rule 2090-1(b of the Local Bankruptcy Rules of the United States Bankruptcy Court for the District of New Hampshire (the Local Bankruptcy Rules, for an order authorizing Brendan C. Recupero, Esq. ( Attorney Recupero of Jager Smith P.C. ( Jager Smith, One Financial Center, Boston, Massachusetts 02111, to appear and practice pro hac vice as counsel to the Committee in this case. 1 The Debtors in these cases, along with the last four digits of their federal tax identification numbers, are Kingsbury Corporation (9934, Ventura Industries, LLC (2563 and Donson Group, Ltd. (4306.
Case: 11-13671-JMD Doc #: 130 Filed: 10/26/11 Desc: Main Document Page 2 of 3 In support of this Motion, the Committee respectfully represents as follows: 1. On September 30, 2011, each of the Debtors filed with this Court a Voluntary Petition for relief under Chapter 11 of Title 11 of the United States Code, 11 U.S.C. 101 et seq. (the Bankruptcy Code. Since that date, the Debtors have continued in the possession of their assets and in the operation of their businesses as debtors-in-possession pursuant to Sections 1107(a and 1108 of the Bankruptcy Code. 2. On October 18, 2011, the United States Trustee appointed the Committee to represent the interests of all unsecured creditors of the Debtors, and on October 19, 2011, the Committee selected Jager Smith to serve as its counsel in these cases. 3. By way of this Motion, the Committee is moving for admission of Attorney Recupero pro hac vice. 4. Attorney Recupero is an associate of Jager Smith and currently practices at the firm s office located in Boston, Massachusetts. 5. Attorney Recupero is a member in good standing of the bar of the Commonwealth of Massachusetts and the United States District Court for the District of Massachusetts. Attorney Recupero is not, however, admitted to the bar of the State of New Hampshire or the United States District Court for the District of New Hampshire. 6. Attorney Recupero will be actively associated with the undersigned throughout the pendency of these cases. The undersigned is a member in good standing of the bar of the United States District Court for the District of New Hampshire. As required by Local Rule 83.2(b, the undersigned will receive service of all papers, sign all filings and attend all proceedings unless excused by the Court. 2
Case: 11-13671-JMD Doc #: 130 Filed: 10/26/11 Desc: Main Document Page 3 of 3 7. In further support of this Motion, and as required by Local Rule 83.2(b(1 and Local Bankruptcy Rule 2090-1(b, submitted herewith is an affidavit of Attorney Recupero. 8. Pursuant to Local Bankruptcy Rule 5075-1, notice of this Motion is being given to the following: (i counsel to the Debtors; (ii the Office of the United States Trustee; (iii the members of the Committee; and (iv all parties having filed notices of appearance and requests for notices and pleadings in these cases. The Committee submits that no other or further notice need be provided. WHEREFORE, the Committee respectfully requests that this Court enter an order authorizing Attorney Recupero to appear and practice pro hac vice in these cases, and granting to the Committee such and other relief as the Court deems just and proper. Dated: October 26, 2011 JAGER SMITH P.C. /s/ Steven C. Reingold Steven C. Reingold (BNH 06128 One Financial Center Boston, Massachusetts 02111 telephone: (617 951-0500 facsimile: (617 951-2414 email: sreingold@jagersmith.com Proposed Counsel to the Official Committee of Unsecured Creditors 3
Case: 11-13671-JMD Doc #: 130-1 Filed: 10/26/11 Desc: Affidavit of Brendan C. Recupero Page 1 of 3 Steven C. Reingold (BNH 06128 JAGER SMITH P.C. One Financial Center Boston, Massachusetts 02111 telephone: (617 951-0500 facsimile: (617 951-2414 email: sreingold@jagersmith.com Proposed Counsel to the Official Committee of Unsecured Creditors UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW HAMPSHIRE In re Chapter 11 KINGSBURY CORPORATION et al., 1 Case No. 11-13671-JMD Debtors. Jointly Administered AFFIDAVIT OF BRENDAN C. RECUPERO IN SUPPORT OF MOTION FOR AUTHORIZATION TO APPEAR AND PRACTICE PRO HAC VICE I, Brendan C. Recupero, hereby make oath and depose as follows: 1. I am an associate with the law firm of Jager Smith P.C. ( Jager Smith, which maintains an office for the practice of law at One Financial Center, Boston, Massachusetts 02111. I have read the accompanying Motion For Authorization to Appear and Practice Pro Hac Vice, and make this affidavit in support thereof. 2. The Official Committee of Unsecured Creditors (the Committee of Kingsbury Corporation and its affiliated debtors (the Debtors has requested that the law firm of Jager 1 The Debtors in these cases, along with the last four digits of their federal tax identification numbers, are Kingsbury Corporation (9934, Ventura Industries, LLC (2563 and Donson Group, Ltd. (4306.
Case: 11-13671-JMD Doc #: 130-1 Filed: 10/26/11 Desc: Affidavit of Brendan C. Recupero Page 2 of 3 Smith serve as the Committee s counsel in these cases. Jager Smith commenced its service on behalf of the Committee on October 19, 2011. 3. I am not a member of the bar of the State of New Hampshire or the United States District Court for the District of New Hampshire. I am, however, a member in good standing of the bar of, and am eligible to practice before the courts of, the Commonwealth of Massachusetts and the United States District Court for the District of Massachusetts, having been admitted in 1999. 4. I am not currently suspended or disbarred in any jurisdiction. 5. I have no disciplinary matters pending in any jurisdiction. 6. I am familiar with the requirements of Rule 2090-2 of the Local Bankruptcy Rules of the United States Bankruptcy Court for the District of New Hampshire regarding disciplinary jurisdiction and rules. 7. During the course of these cases, I will be associated with counsel who is familiar with the substantive and procedural requirements of the local rules and administrative orders of this Court. [Remainder of page intentionally left blank.] 2
Case: 11-13671-JMD Doc #: 130-1 Filed: 10/26/11 Desc: Affidavit of Brendan C. Recupero Page 3 of 3