Received 09/22/2015 Commonwealth Court of Pennsylvania IN THE COMMONWEALTH COURT OF PENNSYLVANIA Filed 09/22/2015 Commonwealth Court of P1 Pennsylvania 1 Rsyl REL ani 2001 IN RE: Reliance Insurance Company in NO. 1 REL 2001 Liquidation MOTION FOR ADMISSION PRO HAC VICE OF MARK BENEDICT Dwayne Stanley, of the law firm Husch Blackwell LLP, counsel of record for Associated Wholesale Grocer, Inc. ("AWG")( ") in these proceedings and a member of of the Pennsylvania Bar Admissions Rules admitting Mark Benedict to the bar of this Court, pro hac vice, for the purpose of representing AWG, and in support thereof would show the Court as follows: of representing AWG, and in support thereof would show the Court as follows: 1. Mr. Benedict a partner in Husch Blackwell LLP, located at 4801 Main Street, Suite 1000 in Kansas City, Missouri 64112. Mr. Benedict is is an an attorney duly admitted to to practice law in the following courts: the Kansas Supreme Court, the Missouri Supreme Court; U.S. District Court, Western District of Missouri; U.S. Bankruptcy Court, Western District of of Missouri; U.S. District Court, District of Kansas; U.S. Bankruptcy Court, District of Kansas; U.S. Court of Appeals for the 33h', rd, 8th, and 10 10th Circuits; and the U.S. Supreme Court. 2. He is in good standing to practice before all courts to which he has been admitted. See Affidavit of Mark Benedict, Esquire, attached hereto as Exhibit "A". ". 3. Mr. Benedict has applied to the Pennsylvania IOLTA Board and paid the appropriate fee. Attached as Exhibit "B" is the fee payment certification letters from the Pennsylvania IOLTA Board for the above-captioned cases.
4. The information required by Section 81.504 of the Pennsylvania IOLTA regulations in order for Mr. Benedict to be admitted pro kw hac vice has been provided to Pennsylvania IOLTA Board. 5. Mr. Benedict is familiar with Pennsylvania Bar Admission Rule 301 and has agreed to abide by the Rules of Professional Conduct applicable to Pennsylvania lawyers. 6. Mr. Benedict will be associated with Mr. Stanley at all remaining stages of of this action. 7. Mr. Stanley is a member in good standing of the Bar of Commonwealth of Pennsylvania. 8. Mr. Stanley submits a verified statement pursuant to Pa. R.C.P.1012.1(d)(2) which is attached as Exhibit "C" to this motion. IREMAINDER (REMAINDER OF THIS PAGE IS LEFT INTENTIONALLY BLANK]
Date: September 15, 2015 Respectfully Submitted: By: Dwayne Stanley (I.D. #86081) Counsel for Associated Wholesale Grocers, Inc. Husch Blackwell, LLP 190 Carondelet Plaza, #600 Saint Louis, Missouri 63105 (314) 480-1500 (314) 480-1505 (facsimile) 3
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IN THE COMMONWEALTH COURT OF PENNSYLVANIA IN RE: Reliance Insurance Company in NO. 1 REL 2001 Liquidation AFFIDAVIT OF MARK BENEDICT IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE COUNTY OF OF JACKSON ) ) SS. STATE OF MISSOURI ) I, Mark Benedict, hereby submit this affidavit in support of the Motion for Admission Pro Hac Vice of Mark Benedict to represent Associated Wholesale Grocers, Inc. ("AWG") ") in the above-captioned - action in the Commonwealth Court of Pennsylvania. 1. I am a partner in the law firm of Husch Blackwell LLP, located at 4801 Main Street, Suite 1000 in Kansas City, Missouri 64112; telephone number 816-983-8000; -8000; email address, mark.benedict@huschblackwell.com @huschblackwell.com.. 2. I was admitted to practice before, and I am in good standing as a member of the following courts: the Kansas Supreme Court, the Missouri Supreme Court; U.S. District Court, Western District of Missouri; U.S. Bankruptcy Court, Western District of Missouri; U.S. District Court, District of Kansas; U.S. Bankruptcy Court, District of Kansas; U.S. Court of Appeals for the 3rd, 8th, and 10th Circuits; and the U.S. Supreme Court. 3. I have never been suspended, disbarred, or otherwise disciplined, nor am I subject to any disciplinary proceedings.
4. I have not previously applied for pro hac vice admission in any pending Pennsylvania actions. 5. I agree to comply with and be bound by the applicable statutes, case law and procedural rules of the Commonwealth of Pennsylvania, including the Pennsylvania Rules of of Professional Conduct. 6. I agree to subject myself to the jurisdiction of the Pennsylvania courts and the 6. I agree to subject myself to the jurisdiction of the Pennsylvania courts and the Pennsylvania Disciplinary Board with respect to acts or omissions occurring during my appearance in this matter for which admissionpro hac vice is being sought. 7. I have consented to the appointment of Dwayne Stanley, a member in good standing of the Pennsylvania bar, as the agent upon whom service of process shall be made for all actions, including disciplinary actions, that may arise out of the practice of law in in this matter for which admission pro hac vice is being sought. for which admissionpro hac vice is being sought. FURTHER AFFIANT SAYETH NOT. DATED this 44, day of September, 2015. M Mark T. T. Benedict. i3enedict., SUBSCRIBED AND SWORN to before me this '1 171 L..0 I LOO1 day of September, 2015. My Commission Expires: ALICE MICHELE SPILLMAN Notary Public - Notary Seal STATE OF MISSOURI Jackson County My Commission CommIssioh Expires: April 21, 2019 Commission # 15536338_ y., SLC-7669690-2
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SUPREME COURT OF PENNSYLVANIA PENNSYLVANIA INTEREST ON LAWYERS TRUST ACCOUNT BOARD PENNSYLVANIA INTEREST ON LAWYERS TRUST ACCOUNT BOARD September 17, 2015 MARK T BENEDICT, Esq. HUSCH BLACKWELL LLP 4801 MAIN STREET, SUITE 1000 KANSAS CITY, MO 64112 SENT TO MARK BENEDICT VIA Email: MARK.BENEDICT@HUSCHBLACKWELLCOM @HUSCHBLACKWELL.COM Dear Attorney BENEDICT: This letter serves as the fee payment certification referenced in 204 Pa Code 81.503 and acknowledges receipt of the $375.00 fee paid by Online Payment on this date related to your pursuit for admission pro hac vice in the case identified as In Re: Reliance Insurance Company in Liquidation, no. 1 REL 2001, filed in the Commonwealth Court of Pennsylvania. You should refer to Pa Rule of Civil Procedure 1012.1, local court rules, and other regulations of 204 Pa Code 81.501 et. seq. concerning additional requirements related to seeking pro hac vice admission. Sincerely, /Yx.4 / Stephanie S. Libhart Executive Director cc: DWAYNE STANLEY, Esq. dwayne.stanley@huschblackwell.com Pennsylvania Judicial Center 601 Commonwealth Ave., Ste. 2400 PO Box 62445, Harrisburg, PA 17106-2445 717/238-2001 888/PA-IOLTA q24-6582) (724 717/238-2003 FAX paiolta@pacourts.us www,paiolta.org www.paiolta.org Administering Pennsylvania's Interest On Lawyers Trust Account (IOLTA) Program
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IN THE COMMONWEALTH COURT OF PENNSYLVANIA IN RE: Reliance Insurance Company in NO. 1 REL 2001 Liquidation VERIFIED STATEMENT OF DWAYNE STANLEY I, Dwayne Stanley, state: 1) After reasonable investigation, I reasonably believe Mark Benedict to be a reputable and competent attorney and I am in a position to recommend Mr. Benedict's admission. 2) I am not acting as the sponsor of any other candidate for admissionpro hac vice in Pennsylvania. 3) Any proceeds from the settlement of this cause of action in which Mark Benedict is granted admissionpro hac vice shall be received, held, distributed, and accounted for in accordance with Rule 1.15 of the Pennsylvania Rules of Professional Conduct, including the IOLTA provisions thereof, if if applicable. I hereby declare under penalty of perjury that the forgoing is true and correct to the best of my knowledge. SLC-7669690-2
Date: September 15, 2015 Respectfully Submitted: By: Dwayne Stanley (I.D. #86081) Counsel for Associated Wholesale Grocers, Inc. Husch Blackwell, LLP 190 Carondelet Plaza, #600 Saint Louis, Missouri 63105 (314) 480-1500 (314) 480-1505 (facsimile) SLC-7669690-2
IN THE COMMONWEALTH COURT OF PENNSYLVANIA IN RE: Reliance Insurance Company in NO.1 1 REL 2001 Liquidation ORDER GRANTING MOTION FOR ADMISSION PRO HAC VICE OF MARK BENEDICT Comes now Mark Benedict, and the Motion for Admission Pro Hac Vice of Mark Benedict having been filed and the Court being fully advised, it is hereby Ordered that the Motion for Admission Pro Hac Vice of Mark Benedict be granted and that Mark Benedict be admitted pro hac vice as counsel for Associated Wholesale Grocers, Inc. DATED THIS DAY OF, 2015. SLC-7669690-2