Document Page 1 of 10 Dennis F. Dunne, Esquire (admitted pro hac vice) Evan R. Fleck, Esquire (admitted pro hac vice) Eric K. Stodola, Esquire (admitted pro hac vice) 28 Liberty Street New York, NY 10005 Telephone: 212-530-5000 David S. Cohen, Esquire (admitted pro hac vice) Aaron L. Renenger (pro hac vice pending) 1850 K Street, NW, Suite 1100 Washington, DC 20006 Telephone: 202-835-7500 William A. Gray, Esquire (VSB No. 46911) Roy M. Terry, Esquire (VSB No. 17764) W. Ashley Burgess, Esquire (VSB No. 67998) SANDS ANDERSON PC 1111 East Main Street (23219) P.O. Box 1998 Richmond, VA 23218-1998 Telephone: 804-648-1636 Facsimile: 804-783-7291 UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF VIRGINIA Richmond Division In re: ALPHA NATURAL RESOURCES, INC., et al. Debtors. Case No. 15-33896-KRH Chapter 11 Jointly Administered MOTION FOR ADMISSION TO PRACTICE PRO HAC VICE PURSUANT TO LOCAL BANKRUPTCY RULE 2090-1(E)(2) William A. Gray (the "Movant"), a member in good standing of the bar of the Commonwealth of Virginia and an attorney admitted to practice before the United States Bankruptcy Court for the Eastern District of Virginia (the "Court"), hereby moves (the "Motion") the Court, pursuant to Local Bankruptcy Rule 2090-1(E)(2), to enter an order, substantially in the form of the order attached hereto as Exhibit A (the "Order"), authorizing Aaron L. Renenger of the law firm of, 1850 K Street NW, Suite 1100, Washington, DC 20006 ("Mr. Renenger"), to appear and practice pro hac vice on behalf of the Official Committee of Unsecured Creditors of Alpha Natural Resources, Inc., et al. (the "Committee") in the above-captioned jointly-administered Chapter 11 cases and any related proceedings. In support of the Motion, the Movant states:
Document Page 2 of 10 1. Mr. Renenger is a member in good standing of the bars of the District of Columbia and California, and an attorney admitted to practice before the United States District Court for the District of Columbia; United States Court of Appeals, Second Circuit; United States Court of Appeals, Ninth Circuit; United States District Court, Northern California District and United States District Court, Central District of California. There are no disciplinary proceedings pending against him in any jurisdiction in which he is admitted to practice. 2. Mr. Renenger has completed a written Application to Qualify as a Foreign Attorney under Local Bankruptcy Rule 2090-1(E)(2), and copies of those applications are attached hereto as Exhibit B. 3. The Movant therefore requests that this Court authorize Mr. Renenger to file pleadings, appear and be heard at hearings, and otherwise participate on behalf of the Committee in the above-captioned jointly-administered Chapter 11 cases and related proceedings. 4. Pursuant to Local Bankruptcy Rule 9013-1(G), because there are no novel issues of law presented in this Motion, the Movant requests that this Court waive the requirement that the Motion be accompanied by a written memorandum of law. WHEREFORE, the Movant respectfully requests that this Court enter an order, substantially in the form of the Order attached hereto as Exhibit A, authorizing Mr. Renenger to appear pro hac vice on behalf of the Committee in these jointly-administered bankruptcy cases and any related proceedings, and granting such other and further relief as deemed necessary and proper. 2
Document Page 3 of 10 Date: April 5, 2016 Respectfully submitted, SANDS ANDERSON PC /s/ William A. Gray William A. Gray, Esquire (VSB No. 46911) Roy M. Terry, Esquire (VSB No. 17764) W. Ashley Burgess, Esquire (VSB No. 67998) SANDS ANDERSON PC 1111 East Main Street, Suite 2400 (23219) P.O. Box 1998 Richmond, Virginia 23218-1998 Telephone: 804-648-1636 3
Document Page 4 of 10 EXHIBIT A Proposed Order
Document Page 5 of 10 Dennis F. Dunne, Esquire (admitted pro hac vice) Evan R. Fleck, Esquire (admitted pro hac vice) Eric K. Stodola, Esquire (admitted pro hac vice) 28 Liberty Street New York, NY 10005 Telephone: 212-530-5000 David S. Cohen, Esquire (admitted pro hac vice) Aaron L. Renenger (pro hac vice pending) 1850 K Street, NW, Suite 1100 Washington, DC 20006 Telephone: 202-835-7500 William A. Gray, Esquire (VSB No. 46911) Roy M. Terry, Esquire (VSB No. 17764) W. Ashley Burgess, Esquire (VSB No. 67998) SANDS ANDERSON PC 1111 East Main Street (23219) P.O. Box 1998 Richmond, VA 23218-1998 Telephone: 804-648-1636 Facsimile: 804-783-7291 UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF VIRGINIA Richmond Division In re: ALPHA NATURAL RESOURCES, INC., et al. Debtors. Case No. 15-33896-KRH Chapter 11 Jointly Administered ORDER GRANTING MOTION FOR ADMISSION TO PRACTICE PRO HAC VICE PURSUANT TO LOCAL BANKRUPTCY RULE 2090-1(E)(2) This matter comes before the Court on the Motion for Admission to Practice Pro Hac Vice Pursuant to Local Bankruptcy Rule 2090-1(E)(2) (the "Motion"), filed by William A. Gray of the law firm of Sands Anderson PC, requesting entry of an order authorizing Aaron L. Renenger of the law firm of, 1850 K Street NW, Suite 1100, Washington, DC 20006 ("Mr. Renenger"), to appear and practice pro hac vice on behalf of the Official Committee of Unsecured Creditors of Alpha Natural Resources, Inc., et al., in the above-captioned jointly-administered Chapter 11 cases and any related proceedings. Based on the representations set forth in the Motion and the written Application to Qualify as a Foreign Attorney under Local Bankruptcy Rule 2090-1(E)(2) submitted by Mr. Renenger, the Court finds that (i) it has jurisdiction over the matters raised in the Motion pursuant to 28 U.S.C. 157 and 1334, (ii) this is a core proceeding pursuant to 28 U.S.C. 157(b), (iii) proper and adequate
Document Page 6 of 10 notice of the Motion has been given and no other or further notice is necessary, and (iv) after due deliberation on the Motion and all proceedings before the Court in connection with the Motion, good and sufficient cause exists for granting of the relief requested in the Motion. IT IS HEREBY ORDERED THAT: 1. The Motion is GRANTED as set forth herein; 2. Aaron L. Renenger is ADMITTED pro hac vice to appear and practice before this Court in these jointly-administered Chapter 11 bankruptcy cases and any related proceedings pursuant to Local Bankruptcy Rule 2090-1(E)(2); 3. The terms and conditions of this Order shall be immediately effective and enforceable upon its entry; and 4. This Court shall retain jurisdiction to hear and determine all matters arising from or related to this Order. Date:, 2016 Richmond, Virginia THE HON. KEVIN R. HUENNEKENS United States Bankruptcy Judge Entered on Docket: WE ASK FOR THIS: William A. Gray, Esquire (VSB No. 46911) Roy M. Terry, Esquire (VSB No. 17764) W. Ashley Burgess, Esquire (VSB No. 67998) SANDS ANDERSON PC 1111 East Main Street, Suite 2400 (23219) P.O. Box 1998 Richmond, Virginia 23218-1998 Telephone: 804-648-1636 Co-Counsel for the Official Committee of Unsecured Creditors 2
Document Page 7 of 10 -and- Dennis F. Dunne, Esquire (admitted pro hac vice) Evan R. Fleck, Esquire (admitted pro hac vice) Eric K. Stodola, Esquire (admitted pro hac vice) 28 Liberty Street New York, NY 10005 Telephone: 212-530-5000 David S. Cohen, Esquire (admitted pro hac vice) Aaron L. Renenger (pro hac vice pending) 1850 K Street, NW, Suite 1100 Washington, DC 20006 Telephone: 202-835-7500. RULE 90221-1 CERTIFICATION I hereby certify, under Local Rule 9022-1, that the foregoing Order has been endorsed by or served upon all necessary parties. 3
Document Page 8 of 10 EXHIBIT B Pro Hac Vice Application
Document Page 9 of 10 UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF' VIRGINIA RICHMOND DIVISION APPLICATION TO QUALIFY AS A FOREIGN ATTORNEY UNDER LOCAL BANKRTIPTCY RULE 2090-1(EX2) In Case s.3 15-33896 (KRH) * Case l\srns Alpha Natural Resoutces, Inc., et al' PERSONAL STATEMENT FULL NAME (no initials, please) Aaron L. Renenger B ar Identification Number State DC & Califomia Firm Name Mil Tweed Direct Dial # 202-835-7 505 Firm Phone # 202-835-7500 Direct Dial # 202-835-7505 t'ax FAX # u - ol't)v) 202-263- Office MaÍling Address 1850 K Street, NVy', Suite I100' wash ngton, DU zuuub Name(s) of federal court(s) in which I have been admitted see attached I certifi that the rules of the federal court in the district in which I maintain my office extend asimi\at pro hac vice admission privilege to members of the bar of the Eastem District of Virginia. I have not been reprimanded in any court nor has there been any action in any court pertaining to my conduct or fitness as a member of the bar. I hereby certifo that, within 90 days before the submission of this application, I have read the Local Rules of this Court and that my knowledge of the Federal Rules of Civil Procedure, the Federal Rules of Banktupjty Procedure, a rd the FederalRules of Evidence is cunent. 's Si I, the undersigned, do certifo that I am a member of the bar of this Court, not related to the applicant; that I know the applicant personally, that the said applicant possesses all ofthe qualifrcations required for admission to the bar ofthis Court; that have examined the applicant's personal statement. I affirm that his/her personal and professional character and standir þare good. and petition the court to admit the applicant pro hac více. (Signature April 5,2016 (Date) William A. Gray (Typed or Printed Name) *Pro hac vrce admission in a case shall include an adversary proceeding(s) in the case. Ver. 02/l l/10 [effective l2l01/09]
Document Page 10 of 10 Aaron L. Renenger Name(s) of federal court(s) in which I have been admitted: U.S. Distict Court, Central District of California U.S. District Court, Northem Califomia District U.S. Cor rt of Appeals, Ninth Circuit U.S. Court of Appeals, Second Circuit U.S. District Court for the Dishict of Columbia