Case 09-11204-jkf Doc 177 Filed 03/13/09 Entered 03/13/09 09:24:45 Desc Main Document Page 1 of 2 UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA In re: Chapter 11 PHILADELPHIA NEWSPAPERS, LLC, et al., Case No. 09-11204-JKF Jointly Administered Debtors. MOTION FOR ADMISSION OF RUSSELL R. JOHNSON III PRO HAC VICE PURSUANT TO LOCAL RULE OF BANKRUPTCY PROCEDURE 2090-1(c John C. Kilgannon, Esquire ( Movant, a member in good standing of the Bar of the Commonwealth of Pennsylvania, an attorney admitted to practice before the United States Bankruptcy Court for the Eastern District of Pennsylvania, and a shareholder in the law firm of Stevens & Lee, P.C., hereby moves the Court to enter an Order permitting Russell R. Johnson III, Esquire ( Johnson, to practice pro hac vice before the United States Bankruptcy Court for the Eastern District of Pennsylvania and to represent PECO Energy Company in these Chapter 11 cases. In support of this Motion, the Movant respectfully represents as follows: 1. Mr. Johnson is a sole practitioner who maintains an office for the practice of law at 2258 Wheatlands Drive, Manakin-Sabot, VA 23103. Virginia. 2. Mr. Johnson is a member in good standing of the bar of the Commonwealth of 3. Attached hereto as Exhibit A is a declaration of Russell R. Johnson III, Esquire, which sets forth his qualifications in greater detail.
Case 09-11204-jkf Doc 177 Filed 03/13/09 Entered 03/13/09 09:24:45 Desc Main Document Page 2 of 2 4. Movant requests that this Court grant this Motion so that Mr. Johnson may be allowed to appear and be heard at any hearings in these Chapter 11 cases. WHEREFORE, PECO Energy Company, respectfully requests that this Court enter the attached Order permitting Russell R. Johnson, III, Esquire to appear pro hac vice in these Chapter 11 cases. Dated: March 13, 2009 STEVENS & LEE, P.C. /s/ John C. Kilgannon John C. Kilgannon 1818 Market Street, 29 th Floor Philadelphia, Pennsylvania 19103 Telephone: (215 751-1943 Facsimile: (610 371-7954 E-mail: jck@stevenslee.com Co-Counsel For PECO Energy Company 2
Case 09-11204-jkf Doc 177-1 Filed 03/13/09 Entered 03/13/09 09:24:45 Desc Declaration of Russell R. Johnson III Esquire Page 1 of 2 UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA In re: PHILADELPHIA NEWSPAPERS, LLC, et al., Debtors. --------------~ Chapter 11 Case No. 09-11204-JKF Jointly Administration DECLARATION OF RUSSELL R. JOHNSON III, ESQUIRE I, Russell R. Johnson III, hereby submit this declaration in support of the Motion for admission of Russell R. Johnson III pro hac vice pursuant to local rule of Bankruptcy Procedure 2090-1 (c (the "Motion". 1. The information contained in this Declaration is true and correct to the best of my knowledge and belief. 2. I am a sole practitioner with the law firm of Russell R. Johnson III and regularly practice in the area of bankruptcy law. 3. I received my J.D. from the T.e. Williams School of Law at the University of Richmond in 1990. 4. I am a member in good standing of the bar of the Commonwealth of Virginia. 5. I am a member of the bar of the United States District and Bankruptcy Courts for the Eastern and Western Districts of Virginia. 6. I am not under suspension or disbarment by any Court. 7. I have or will familiarize myself with the Rules of this Court and am familiar with 3
Case 09-11204-jkf Doc 177-1 Filed 03/13/09 Entered 03/13/09 09:24:45 Desc Declaration of Russell R. Johnson III Esquire Page 2 of 2 the Rules regulating the Pennsylvania Bar, and agree to adhere to those rules. 8. My firm maintains malpractice insurance. I declare under penalty of perj ury that the foregoing is true and correct. 4
Case 09-11204-jkf Doc 177-2 Filed 03/13/09 Entered 03/13/09 09:24:45 Desc Proposed Order Page 1 of 1 UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA In re: Chapter 11 PHILADELPHIA NEWSPAPERS, LLC, et al., Case No. 09-11204-JKF Jointly Administered Debtors. ORDER AND NOW, this day of,2009, it is hereby ORDERED that the application of Russell R. Johnson III, Esquire, to practice in this Court pursuant to Local Rule of Bankruptcy Procedure 2090-1 (c is GRANTED. Jean K. FitzSimon United States Bankruptcy Judge 5
Case 09-11204-jkf Doc 177-3 Filed 03/13/09 Entered 03/13/09 09:24:45 Desc Certificate of Service Page 1 of 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on March 13, 2009, I caused a true and correct copy of the foregoing Motion For Admission Of Russell R. Johnson III Pro Hac Vice Pursuant To Local Rule Of Bankruptcy Procedure 2090-1(c to be served electronically or by first-class mail, postage prepaid, or by some other form of service where indicated below, upon the persons listed below as well as upon the parties receiving notice via the Court s ECF system: Philadelphia Newspapers, LLC (via hand delivery Attn: Richard Thayer and Scott Baker 400 North Broad Street Philadelphia, Pennsylvania 19130 Mark K. Thomas Proskaur Rose LLP Three First National Plaza 70 West Madison, Suite 3800 Chicago, Illinois 60602 Counsel for Debtors Richard J. Corbi Proskaur Rose LLP 1585 Broadway New York, New York 10036 Counsel for Debtors Lawrence G. McMichael Dilworth Paxson LLP 1500 Market Street, Suite 3500E Philadelphia, Pennsylvania 19103 Counsel for Debtors United States Trustee Office of the U.S. Trustee 833 Chestnut Street Suite 500 Philadelphia, PA 19107 6
Case 09-11204-jkf Doc 177-3 Filed 03/13/09 Entered 03/13/09 09:24:45 Desc Certificate of Service Page 2 of 2 Gary M. Schildhorn Eckert Seamans Cherin & Mellott, LLC Two Liberty Place 50 South 16th Street 22nd Floor Philadelphia, PA 19102 Creditor Committee Counsel /s/ John C. Kilgannon John C. Kilgannon 7