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Country Mutual Insurance Co. v. Ellis-Gunn

United States District Court, D. Nevada

October 11, 2019

COUNTRY MUTUAL INSURANCE COMPANY as successor to HOLYOKE MUTUAL INSURANCE COMPANY a/s/o LAKERIDGE VILLAS HOMEOWNERS ASSOCIATION, Plaintiff,
v.
TYANNE ELLIS-GUN, Defendant.

          Marquis Aurbach Coffing Tye S. Hanseen, Esq. Nevada Bar No. 10365 Local counsel for Plaintiff

          de Luca Levine Benjamin D. Wharton, Esq. Three Valley Square Attorney for Plaintiff-pro hac pending

          VERIFIED PETITION FOR PERMISSION TO PRACTICE IN THIS CASE ONLY BY ATTORNEY NOT ADMITTED TO THE BAR OF THIS COURT AND DESIGNATION OF LOCAL COUNSEL

         Benjamin D. Wharton Esq., Petitioner, respectfully represents to the Court:

1. That Petitioner is an attorney at law and a member of the law firm of de Luca Levine, LLC with offices at Three Valley Square, Suite 220, Blue Bell, PA 19422. Telephone number: (215) 383-0081 and email address of bwharton@delucalevine.com.
2. That Petitioner has been retained personally or as a member of the law firm of de Luca Levine, LLC to provide legal representation in connection with Country Mutual Insurance Company in the above-entitled case now pending before this Court.
3. That since 2011, Petitioner has been and presently is a member in good standing of the bar of the highest Court of the State of Pennsylvania where Petitioner regularly practices law. Petitioner shall attach a certificate from the state bar or from the clerk of the Supreme Court or highest admitting court of each state, territory, or insular possession of the United States in which the applicant has been admitted to practice law certifying the applicant's membership therein is in good standing.
4. That Petitioner was admitted to practice before the following United States District Courts, United States Circuit Courts of Appeal, the Supreme Court of the United States and Courts of other States on the dates indicated for each, and that Petitioner is presently a member in good standing of the bars of said Court:

Court

Date Admitted

Bar Number

Pennsylvania

2011

312394

New Jersey

2012

033742011

U.S. District Court of N.J.

8/26/2019

U.S. District Court- ED PA

2011

         5. That there are or have been no disciplinary proceedings instituted against Petitioner, nor any suspension of any license, certificate or privilege to appear before any judicial, regulatory or administrative body, or any resignation or termination in order to avoid disciplinary or disbarment proceedings, except as described in detail below:

         6. That Petitioner has never been denied admission to the State Bar of Nevada. (Give particulars if ever denied admission):

         7. That Petitioner is a member of good standing in the following Bar Associations: (State "none" if Petitioner is not a member of other Bar Associations.) fc!()f\C

         8. Petitioner has filed application(s) to appear as counsel under Local Rule IA 10-2 during the past three (3) years in the following matters:

Date of Application

Cause

Title of Court Administrative Body or Arbitrator

Was Application Granted or Denied


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